MIXED ENERGY WASTE STUDY
(MEWS)
March 1987
U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
401 M Street, S.W.
Washington, DC 20460
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TABLE OF CONTENTS
Section
1.0
2.0
EXECUTIVE SUMMARY
INTRODUCTION
11 Background
1.2 Description of DOE Option
1.3 MEWS Task Force
HIGH-LEVEL AND TRANSURANIC (TRU) WASTE MANAGEMENT
2.1 High-Leve! Waste (HLW)
2.
2.
2.
2.
2.
2.
. I Generation
.2 On-Site Transfer and Tank Storage
.3 Treatment
.4 Waste Analysis
.5 Process Controls
.6 Long-Term Storage. Transport, and Disposal
2.2 Transuranic (TRU) Waste
2.2.1 Generation
2.2.1 Packaging
2.2.3 On-Site Transfer and Tank Storage
2.2.4 Treatment and Certification
2.2.5 Waste Analysis
2.2.6 Control
2.2.7 Post-Treatment Storage
2.2.8 Transport
2.2.9 Disposal
2.3 Special Wastes
2.4 Environmental Monitoring
2.5 Audits/Assessments/Overview
2.6 Security
3.0 State Perspectives
Page
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1-3
1-3
2-1
2-1
2-3
2-3
2-6
2-7
2-8
2-9
2-12
2-13
2-13
2-15
2-15
2-17
2-17
2-18
2-20
2-24
2-29
2-29
2-32
2-33
3-1
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TABLE OF CONTENTS (Conl'd)
4.0 Findings 4-1
4.1 HLW/TRU Waste Management Is Complex 4-1
4.2 TRU Waste Is Often Managed with LLW and RCRA
Hazardous Waste 4-2
4.3 The HLW/TRU Waste System Depends Heavily on
Future Actions 4-2
4.4 There Are Special Cases That Do Not Fit the "Normal"
Management Scheme 4-3
4.5 Most DOE Practices for HLW/TRU Seem Comparable to
RCRA Standards and Several Practices Seem Superior
to RCRA Requirements 4-4
4.6 Several Aspects of DOE Practices Probably Would Not
Meet RCRA Standards 4-4
4.7 RCRA Variances or Proposed Subpart X Could Apply
to Some Aspects. But Case-by-Case Evaluation is
Necessary 4-5
4.8 The Current Management Would Not Change Significantly
If HLW/TRU Were Controlled Under RCRA 4-5
5.0 Alternative Strategies 5-1
5.1 Description 5-1
5.2 Discussion 5-2
6.0 Bibliography 6-1
7.0 Acknowledgements 7-1
APPENDICES
APPENDIX A - Facility Reports
APPENDIX B - State Reports
in
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LIST OF FIGURES
FIGURE
ES-I
ES-2
2-1
2-2
2-3
2-4
2-5
2-6
2-7
2-8
2-9
2-10
TABLE
2-1
2-2
2-3
2-4
DESCRIPTION
Sources and Disposition of Radioactive Waste
Major Facilities Affected by DOE Option
Double Shell Tanks
Conceptual Design Cutaway - High-level Waste
Geologic Repository
Calcine Bin Set Model
Wide-Bottom Storage Trench for TRU Waste
TRU Waste Storage Pads Covered with Plastic and Earth
TRU Waste Storage Area - Contact-Handled Waste
Retrievably Stored
TRUPACT Being Transported
Waste Isolation Pilot Plant Schematic
Greater Confinement Disposal (GCD) Shaft
Navy Submarine Reactor Compartment
LIST OF TABLES
DESCRIPTION
DOE Facility Descriptions
High-level Waste Inventories as of 12/31/85
DOE-Projected TRU Waste Generation Rates
Inventory of DOE Receivable TRU Waste Through 1985
PAGE
4
7
2-5
2-10
2-11
2-21
2-22
2-23
2-25
2-26
2-28
2-30
PAGE
2-2
2-4
2-14
2-19
IV
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LIST OF ACRONYMS
AEA
CERCLA
CH-TRU Waste
DOE
DOT
DWPF
EPA
GCD
HL(W)
ICPP
INEL
LANL
LLNL
LLW
MEWS
MVST
NTS
ORNL
PREPP
PUREX
RCRA
RPP
RH-TRU Waste
RWMC
SGS
SRP
SWEPP
TRU
TRUPACT
11 SGS
WAC
WEAF
WHPP
WIPP
WVDP
Afomic Energy Act
Comprehensive Environmental Response, Compensation,
and Liability Act
Contact-Handled Transuranic Waste
U.S. Department of Energy
U.S. Department of Transportation
Defense Waste Processing Facility
U.S. Environmental Protection Agency
Greater Confinement Disposal
High-Level (Waste)
Idaho Chemical Processing Plant
Idaho National Engineering Laboratory
Los Alamos National Laboratory
Lawrence Livermore National Laboratory
Low-Level Waste
Mixed Energy Waste Study
Melton Valley Storage Tanks
Nevada Test Site
Oak Ridge National Laboratory
Process Experimental Pilot Plant
Plutonium - Uranium Extraction
Resource Conservation and Recovery Act
Rocky Flats Plant
Remote-Handled Transuranic Waste
Radioactive Waste Management Complex
Segmented Gamma Scanner
Savannah River Plant
Stored Waste Examination Pilot Plant
Transuranic
Transuranic Waste Package Transporter
U.S. Geological Survey
Waste Acceptance Criteria
Waste Examination Assay Facility
Waste Handling Pilot Plant
Waste Isolation Pilot Plant
West Valley Demonstration Project
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EXECUTIVE SUMMARY
"Radioactive mixed waste" has both radioactive and hazardous chemical properties. Many
Department of Energy (DOE) facilities generate or manage radioactive mixed waste, as well
as non-radioactive hazardous waste.
In November. 1986. DOE informally proposed an option for the Environmental Protection
Agency (EPA) in which current and future mixed high-level radioactive waste (HLW) and
transuranic (TRU) waste would be exempted from the hazardous waste control program under
Subtitle C of the Resource Conservation and Recovery Act (RCRA). While this proposal may
deregulate the hazards associated with both wastes, the DOE contends that controlloing
radiation hazards from HLW/TRU waste also controls chemical hazards. In response. EPA
formed the Mixed Energy Waste Study (MEWS) task force to evaluate DOE's proposed option.
The purpose was to compare DOE's practices to requirements for hazardous waste management
under RCRA Subtitle C.
From November. 1986. to February, 1987, the task force analyzed the current DOE management
practices for HLW, TRU, and certain other radioactive wastes. This report summarizes the
findings of the task force.
This Executive Summary provides:
• a brief definition of high-level and transuranic wastes and their sources.
• a description of current management practices for such waste at DOE
facilities.
• a summary of DOE's proposed option for waste management at DOE facilities.
• State government perspectives on the proposed option.
• findings of the MEWS task force.
The MEWS task force concluded that, with some exceptions, current DOE management of mixed
HLW/TRU waste is equivalent or superior to RCRA requirements. In other words, management
of these wastes would not change significantly if they were required to comply with RCRA
Subtitle C requirements for hazardous waste. However, there were a few aspects which
probably would not meet RCRA standards.
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Most States were concerned about DOE self-regulation of HLW/TRU waste (DOE option), but
were willing to consider case-by-case variances or specific exemptions.
A. HIGH-LEVEL AND TRANSURANIC WASTE:
High-level radioactive waste results from the processing of nuclear reactor fuels. One
type results from dissolving nuclear reactor fuel elements to recover plutonium. Another
results from dissolving naval reactor fuel elements to recover enriched uranium. When
formed. HLW is highly acidic (pH< I) and highly radioactive. It contains many fission
products and some transuranic elements. Most HLW has hazardous chemical characteristics
(corrosivity and toxicity), and may also contain listed RCRA hazardous wastes. Even so,
its hazard is due primarily to its intense radioactivity.
When generated, HLW is in liquid form. As a result of treatment, however, it can become a
sludge or slurry. It must be remotely handled and contained prior to disposal. HLW is
currently stored in double-walled steel, underground tanks. At the Idaho National
Engineering Laboratory (INEL), the HLW is further processed via high-temperature flash
evaporation into a solid, calcined, sand-like material which is stored in shielded
above-ground bins or silos. At the Savannah River Plant, a new $1 billion HLW
vitrification (glass) plant is about 50 percent complete and a similar facility is planned
for the Hanford site, although it is not yet funded. The vitrified HLW will be solidified
and stored inside large stainless steel cylinders. Ultimately, these cylinders will be
permanently disposed of in a future High Level Waste Repository which will accept both DOE
and commercial HLW.
By definition in EPA's Environmental Standards for the Management and Disposal of Spent
Nuclear Fuel. High-level and Transuranic Radioactive Wastes (40 CFR 191). transuranic
(TRU) waste is waste containing alpha-emitting transuranic isotopes with half-lives
greater than 20 years and containing more than 100 nanocuries per gram (NCI/G) of waste.
TRU waste arises mostly from the processing, shaping, and handling of plutonium-
containing materials. Most TRU waste is solid (e.g. gloves, rags, and tools), but some is
liquid. Some TRU waste contains listed RCRA hazardous waste such as spent cutting oils or
solvents. A small amount of TRU waste is classified. At (he Oak Ridge National
Laboratory (ORNL). a highly radioactive isotope of uranium (U-233) is also managed with
and considered to be TRU waste.
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At most facilities. TRU waste is triple-packaged. First, it is sealed in a plastic bag.
The bag is then placed in a plastic drum inner liner which in turn is placed in a steel
drum or box. This packaging usually provides sufficient shielding because most plutonium
isotopes are mainly alpha-particle emitters which are primarily hazardous when inhaled or
ingested. Alpha-particles are easily stopped by almost any barrier, and as a result, the
radiation level at the surface of the drum or box is relatively low. This type of waste
is called "contact-handled" TRU (CH-TRU).
Some TRU waste, however, also contains beta- and gamma-ray emitters. These wastes must be
handled remotely if the radiation level at the surface of the drum or box exceeds
200 milirems/hour (mrem/hr). This type of waste is called "remote-handled" TRU (RH-TRU).
Since 1970, DOE has stored its TRU waste in drums or boxes in earth-covered trenches or
in above-ground mounds. Waste stored at these sites is called "retrievable TRU waste".
In recent years, some DOE sites have started storing TRU drums or boxes on open concrete
pads or in air-inflated or steel-hoop buildings. Ultimately, most stored (and newly
generated) unclassified TRU waste will be disposed of at the Waste Isolation Pilot Plant
(WIPP), an excavation in a salt deposit 2,100 feet below ground near Carlsbad. New Mexico.
Classified TRU waste, however, is disposed of at the Nevada Test Site (NTS). TRU may be
classified because of its shape or form; its isotopic, chemical, or alloy composition; or
because the waste contains tools that may be classified. All classified TRU waste is
solid (such as graphite, steel, or plastic) and does not contain known RCRA hazardous
chemicals. Classified TRU waste was disposed in unlined shafts 10 feet wide and 120 feet
deep. DOE refers to this practice as greater confinement disposal (GCD). Disposal of TRU
waste in GCD shafts is currently suspended pending DOE demonstration of compliance with 40
CFR 191.
Sources and general management schemes for HLW and TRU waste are shown in Figure ES-I.
Low-level radioactive waste (LLW) also arises from the same sources, but is handled
differently. LLW is outside the scope of this study.
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FIGURE ES-1
SOURCES AND DISPOSITIONS OF RADIOACTIVE WASTE
Processing/
Reprocessing
Interim
Storage
(Tanks/Bins)
Plant
9
Repository
Interim
Storage
Processing
WIPP
^\\ v \ \
LLW
Near
Surface
Disposal
Facilities Planned
Or Under Construction
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B. DOE'S PROPOSED OPTION FOR HLW/TRU WASTE MANAGEMENT:
On November 1. 1985, under the Atomic Energy Act (AEA). DOE proposed in the Federal
Register a definition of the term "by-product material" as it pertained to DOE activities
under RCRA. Precise definition of the term is important because "by-product material" is
excluded from the RCRA statutory definition of solid waste and, therefore, from regulatory
control under the RCRA Subtitle C hazardous waste program. DOE's proposed definition was
based on the process from which a material is produced rather than defining the chemical
by its intrinsic properties. Under the proposal, all mixed HLW and TRU waste, as well as
some mixed LLW be excluded from RCRA control.
In March 1986, DOE initiated a policy review of the proposed "by-product material"
rulemaking, including an exploration of other options.
In early November, 1986, DOE informally proposed that EPA evaluate an option to the
"by-product material" rule. The option was based on the premise that controlling
radiological hazards from HLW and TRU waste also manages their chemical hazards in a
manner equivalent or superior to RCRA hazardous waste controls. DOE's proposed option had
the following elements:
• LLW mixed waste would be subject to RCRA regulations.
• Current and future HLW and TRU waste would be exempted from RCRA Subtitle C
control via EPA rulemaking [Note: while past disposal practices would be
subject to RCRA as Solid Waste Management Units (SWMUs). and NEPA. the AEA,
and RCRA Subtitle I (Underground Storage Tanks) would still apply. This
rulemaking requires finding inconsistency with the AEA under RCRA Section
1006].
• State laws would not apply to HLW/TRU Waste.
• DOE would make an annual report to EPA on HLW/TRU waste management; EPA could
verify the report's findings via site visits.
• DOE would revise its internal waste management directives to make them
consistent with RCRA regulations.
• Certain other radioactive wastes would also be exempt from RCRA and State
control. (DOE has identified uranium-233 contaminated waste and
decommissioned submarine reactor compartments in this category.)
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In response to DOE's proposed option, EPA formed the Mixed Energy Waste Study (MEWS) task
force. The project involved visits to 10 DOE facilities and discussions with seven State
governments where DOE facilities are located.
The major facilities affected by DOE's proposed option and the states and facilities
visited by the MEWS task force are shown in Figure ES-2.
C. STATE PERSPECTIVES:
The MEWS task force discussed the DOE option with personnel from the states of California,
Colorado, Idaho. New Mexico. South Carolina. Tennessee, and Washington. Each State is
directly concerned with current and future oversight and regulation of DOE facilities
within their borders.
The States response to the DOE option varied from strong opposition to mild reservations.
A consensus of State opinions is as follows:
• DOE/EPA/States must reach agreement on the precise definition of terms and
their application to specific wastes at specific facilities. Arbitrary
definitions and "moving targets" have caused past problems.
0 States want more control and oversight of DOE facilities. They are concerned
about DOE self-regulation of HLW/TRU waste because of past problems.
• States are willing, however, to consider specific variances or limited
exemptions for HLW/TRU waste where warranted.
• Most States are concerned about the resources and technical skills needed to
control HLW/TRU waste, but some are willing to prepare to meet the challenge.
D. MEWS FINDINGS:
The MEWS task force findings concerning DOE's current management of HLW and TRU waste are
summarized below. These findings are based on brief visits to the ten DOE facilities that
generate and manage all the HLW and over 95% of the TRU waste in the DOE system. In-depth
visits might uncover other details but most likely would not change the overall
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FIGURE ES-2
MAJOR FACILITIES AFFECTED BY DOE OPTION
LAWRENCE
LIVERMORE
LEGEND:
State Contacted by MEWS Task Force
• TRU Waste Only
* HLW/TRU Wastes
W1PP Sites Visited by MEWS Task Force
Mound Site Not Visited by MEWS Task Force
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impressions of the task force. These findings do not apply to DOE's past management
practices. Reviews of HLW/TRU waste management at each of the ten DOE facilities are
presented in the main report. More detailed visit reports for each facility and each
State are provided in Appendices A and B respectively.
The MEWS task force findings include the following:
A. HLW/TRU WASTE MANAGEMENT IS COMPLEX.
• HLW/TRU wastes arise from numerous, variable sources and are managed in many
different ways.
• Definitions of terms are not universally consistent.
• There are four different categories of TRU waste; each is managed through
different methods.
B. TRU WASTE IS OFTEN MANAGED WITH LLW AND WITH RCRA HAZARDOUS WASTE.
• TRU waste management is not a separable problem.
• Old HLW/TRU waste management sites are RCRA SWMUs.
C. THE HLW/TRU WASTE SYSTEM DEPENDS HEAVILY ON FUTURE ACTIONS.
• HLW repository.
• Vitrification plants (Hanford. Savannah River, West Valley).
• WIPP operation/expansion.
• RH-TRU waste processing facility at Oak Ridge.
D. THERE ARE SPECIAL CASES THAT DO NOT FIT THE "NORMAL" MANAGEMENT
SCHEME
• Submarine reactor compartments.
• Classified TRU.
• TRU waste unacceptable at the WIPP.
E. MOST DOE PRACTICES FOR HLW/TRU WASTE SEEM COMPARABLE TO RCRA
STANDARDS. AND SEVERAL PRACTICES SEEM SUPERIOR TO RCRA REQUIREMENTS.
• Security.
• Contingency plans and emergency response.
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• Continuous control of HLW tank systems.
• Waste tracking systems and documentation.
• WIPP deep containment for TRU waste (future).
• Deep repository for HLW (future).
F. SEVERAL ASPECTS PROBABLY WOULD NOT MEET RCRA STANDARDS
• Chemical analysis of waste.
• Ground-water monitoring systems.
• Retrievable storage for TRU waste.
• Classified TRU waste disposal.
• Self-inspection.
G. RCRA VARIANCES OR PROPOSED SUBPART X COULD APPLY TO SOME ASPECTS.
BUT CASE-BY-CASE EVALUATION IS NECESSARY.
RCRA variances may be applicable to some aspects noted above, such as waste analysis or
ground-water monitoring requirements. Each facility, however, must be evaluated on a
case-by-case basis before variances can be granted. The new RCRA Subpart X regulation may
provide a mechanism by which unusual management-options could be evaluated separately for
each facility or for new facilities or treatment units. Examples of possible application
of proposed Subpart X include the WIPP and the HLW vitrification plants.
H. CURRENT MANAGEMENT WOULD NOT CHANGE SIGNIFICANTLY IF HLW/TRU
WASTE WERE CONTROLLED UNDER RCRA.
The general management of HLW/TRU waste at DOE facilities would not change significantly
if the facilities were subject to RCRA Subtitle C hazardous waste controls. Areas that
would need to be addressed through improved practices or case-by-case variances include
chemical analyses include chemical analyses of water, ground-water monitoring, and
independent oversight.
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1.0 INTRODUCTION
In November, 1986. DOE informally proposed an option for the Environmental Protection
Agency (EPA) in which current and future mixed high-level radioactive waste (HLW) and
transuranic (TRU) waste would be exempted from Subtitle C of the Resource Conservation and
Recovery Act (RCRA) hazardous waste control program. While this proposal may deregulate
the hazards associated with both wastes, the DOE contends that controlling radiation
hazards from HLW/TRU waste also controls chemical hazards. In response. EPA formed the
Mixed Energy Waste Study (MEWS) task force to evaluate DOE's proposed option. The purpose
was to compare DOE practices to requirements for hazardous waste management under Subtitle
C of RCRA. This report summarizes the findings of the task force.
From November. 1986. to February. 1987, the task force analyzed the current DOE management
practices for HLW, TRU, and certain other radioactive wastes. This report summarizes the
findings of EPA's MEWS task force.
1.1 BACKGROUND
This section outlines the events which led to the formation of the MEWS task force. The
Atomic Energy Act (AEA) of 1954 set a statutory mandate to develop and use atomic energy.
RCRA. passed in 1976. established a broad regulatory scheme governing the generation.
transportation, and management of solid wastes. With the differing purposes of the AEA
and RCRA. it is not surprising that conflict has arisen over the applicability of RCRA to
the management of wastes at DOE facilities. Section 6001 of RCRA explicitly subjects all
Federal facilities and their activities to State and Federal regulation under RCRA.
Section 1006(a) of RCRA relieves facilities operating under the authority and control of
the AEA from compliance with RCRA; this occurs when it can be demonstrated that RCRA
regulations or requirements would be inconsistent with specific requirements mandated by
AEA. Thus. RCRA regulations would not apply if they were in direct conflict with the
directives contained in the AEA (e.g.. disclosing restricted data or preventing of the
production of nuclear materials or their components).
Furthermore, Section 1004(27) of RCRA exempts special nuclear or by-product material
defined by the AEA from the definition of "solid waste" (e.g., the only materials that can
be regulated under RCRA). Those radioactive materials which are naturally occurring or
accelerator-produced radioactive material (HARM) are not included in this exemption.
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In August, 1983, EPA and DOE entered into negotiations to address the control of hazardous
waste at DOE facilities and to determine what role EPA would play in controlling RCRA
hazardous wastes that are mixed with source, special nuclear, or by-product material.
On September 20, 1983, the Legal Environmental Assistance Foundation (LEAF) filed suit
against DOE in Tennessee, seeking a summary judgment that RCRA applies to DOE's Oak Ridge
plant "to the same extent as any other individual facility in the United States." This
suit addressed non-radioactive RCRA hazardous waste.
By February, 1984, EPA and DOE had negotiated a Memorandum of Understanding (MOU) stating
that DOE would manage its RCRA-type wastes and radioactive mixed wastes under a program
that would be the functional equivalent of RCRA and would include a comprehensive EPA
oversight program. Many of the provisions included in the MOU were superseded on April
13. 1984, when the U.S. District Court for ihe Eastern District of Tennessee ruled that
RCRA applied to DOE's Oak Ridge facility (LEAF v. Hodel. No. 3-83-562). DOE accepted that
opinion for all its facilities nationwide. The LEAF case did not address the
applicability of RCRA to radioactive mixed wastes. The lack of clarity on this issue has
hampered the implementation of the court's order to DOE to file for and seek a permit for
the treatment, storage, and disposal of hazardous waste "with all deliberate speed."
On November I. 1985, under the AEA, DOE proposed in the Federal Register a definition of
the term "by-product material" as it pertained to DOE activities under the RCRA. Precise
definition of the term is important because "by-product material" is excluded from the
RCRA statutory definition of solid waste and. therefore, from regulatory control under the
RCRA Subtitle C hazardous waste program. DOE's proposed definition was based on the
process from which a material was produced rather than defining the chemical by its
intrinsic properties. Under the proposal, all mixed HLW and TRU waste, as well as some
mixed low-level waste (LLW), would be excluded from RCRA control.
In March, 1986, DOE initiated a policy review of the proposed "by-product material"
I'ulemaking, including an exploration of other options.
In a related matter, on July 3, 1986. the EPA published a notice in the Federal Register
announcing that in order to obtain and maintain authorization to administer and enforce a
RCRA Subtitle C hazardous waste program. States must apply for authorization to regulate
the hazardous waste components of radioactive mixed wastes.
1-2
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1.2 DESCRIPTION OF DOE OPTION
In early November, 1986, DOE informally proposed that EPA evaluate an option to the
"by-product material" rule. The option was based on the premise that controlling
radiological hazards from HLW and TRU waste also controls their chemical hazards in a
manner equivalent or superior to RCRA hazardous waste controls. DOE's proposed option had
the following elements:
• Mixed LLW waste would be subject to RCRA standards.
• Current and future HLW and TRU waste would be exempt from RCRA Subtitle C
control via EPA rulemaking [Note: past disposal practices would be subject to
RCRA as Solid Waste Management Units (SWMUs), and NEPA. the AEA, and RCRA
Subtitle I (Underground Storage Tanks) would still apply. This rulemaking
requires finding inconsistency with the AEA under RCRA Section 1006].
• State laws would not apply to HLW/TRU waste.
• DOE would make an annual report to EPA on HLW/TRU management: EPA could
verify the report's findings via site visits.
• DOE would revise its internal waste management directives to make them
consistent with RCRA standards.
t Certain other radioactive wastes would also be exempted from RCRA and State
control. DOE has identified uranium-233 contaminated waste and
decommissioned submarine reactor compartments in this category.
DOE contends that its practices for controlling the radiological hazards of HLW, TRU
waste, and certain other radioactive wastes provide a level of protection that is
equivalent or superior to RCRA requirements. DOE proposes to demonstrate this equivalency
by supplying data to the Agency and providing lours of the facilities.
1.3 MEWS TASK FORCE
In response to DOE's proposed option. EPA formed the Mixed Energy Waste Study (MEWS) task
force. The objective of the study was to provide EPA senior management with technical
information on present and future DOE management practices for controlling HLW. TRU waste.
and certain other radioactive wastes that may also be RCRA hazardous wastes. Another
group conducted a concurrent legal review of the DOE option. The MEWS task force limited
its examination of present and projected DOE practices. It did not review the management
1-3
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practices for previously generated wastes. The task force assumed that problems arising
from past practices will be fully regulated under RCRA or the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA).
The task force also limited its investigation of DOE's compliance with hazardous waste
management requirements under Subtitle C of RCRA. Compliance with other RCRA
requirements, such as Subtitle I, was not part of the evaluation under this task. RCRA
Subtitle I establishes a comprehensive program for the regulating underground storage
tanks containing regulated substances. An underground storage tank is defined, with
certain exclusions, as a tank with 10 percent or more of its volume underground (including
the volume of underground pipe connected thereto). Regulated substances include petroleum
products and all substances including radioactive materials defined under Section 101 (14)
CERCLA, except for hazardous wastes which are already subject to regulation under Subtitle
C. Currently, most of the DOE facilities visited use tanks for both short-term and
long-term storage of HLW and TRU wastes.
The project involved visits to 10 DOE facilities and discussion with seven State
governments where DOE facilities are located. The facilities and States visited by the
MEWS task force are shown in Figure ES-2 (Executive Summary). The task force schedule of
•events is presented in Table 1-1..
The major DOE facilities which are candidates for exemption under the DOE option include
several minor generators and onsite storage facilities that were not visited by the task
force. Although these facilities (Bettis. Mound, Argonne) handle TRU wastes, they
generate smaller quantities in relation to the other facilities visited. The objectives
and operations at these sites are similar to at least one of the visited facilities. The
task force, however, realizes that the findings are based on an incomplete review of the
facilities. In addition, the facility visits were short; most were one day or less. Time
restraints prevented the task force from performing detailed evaluations about waste
management systems and practices at eacii facility. Although the the findings of this
report are general, the task force believes that additional investigations would not lead
to substantially different results.
1-4
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TABLE 1-1
MEWS TASK FORCE SCHEDULE OF EVENTS
November
November
December
December
December
December
December
December
December
December
December
24, 1986
25, 1986
2-3. 1986
4, 1986
4, 1986
4. 1986
8. 1986
9. 1986
10. 1986
11-12. 1986
17. 1986
January 8. 1987
January 12, 1987
January 13. 1987
January 14, 1987
January 15, 1987
January 16. 1987
January 19, 1987
January 21, 1987
February 20, 1987
Briefing of MEWS staff at DOE HQ
State of Washington
Savannah River Plant (South Carolina)
State of South Carolina
State of Tennessee
State of Idaho
Waste Isolation Pilot Plant (New Mexico)
Rocky Flats Plant (Colorado)
Idaho National Engineering Laboratory (Idaho)
Hanford Site (Washington)
Briefing for Dr. J. Winston Porter.
EPA Assistant Administrator
West Valley Demonstration Project (New York)
State of New Mexico
Los Alamos National Laboratory (New Mexico)
Nevada Test Site (Nevada)
Lawrence Livermore National Laboratory
(California)
State of California
State of Colorado
Oak Ridge National Laboratory (Tennessee)
Briefing for Lee M. Thomas, EPA Administrator
1-5
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2.0 HIGH LEVEL AND TRANSURANIC WASTE MANAGEMENT
The MEWS task force visited 10 DOE facilities over a two month period to evaluate the DOE
option. The facilities are located throughout the United States and exhibit diverse
characteristics. The climates range in different geographical locations from arid to
humid: facility size ranges from one square mile to 1.300 square miles. Some have been
operated by the same contractor; others have been operated by a series of contractors;
some are operated by multiple contrators. The mission of the facilities either focuses on
the production of materials for nuclear weapons or for weapons research. Specific facts
about each facility are presented in Table 2-1: individual facility reports appear in
Appendix A.
2.1 HIGH-LEVEL WASTE (HLW)
High-level radioactive waste is usually generated as a liquid resulting from processing
nuclear reactor fuels. One type results from dissolving production reactor fuel elements
to recover plutonium. Another results from dissolving submarine reactor fuel elements to
recover enriched uranium. When formed, high-level waste (HLW) is highly acidic (pH< 1) and
highly radioactive. It contains many fission products and some transuranic elements.
Most HLW has hazardous chemical characteristics (corrosiviry and toxiciry), and may also
contain listed RCRA hazardous wastes. Even so, its hazard is due primarily to its
radioactivity and must be remotely handled and contained prior to disposal.
At SRP and Hanford, the liquid waste is made alkaline (pH> 12) resulting in the
formation of sludge which is composed primarily of oxides and hydroxides of manganese.
iron and. to a lesser degree, aluminum. It contains essentially all of the actinides and
fission products originally contained in the irradiated fuel except cesium. The sludge
also contains small amounts of other hazardous constituents such as mercury.
High-level waste is generated only at certain DOE facilities and the process of producing
and storing HLW is unique to each facility. The steps can be characterized as generation,
on-site transfer and tank storage, treatment, characterization, control, and long-term
storage and disposal.
2-1
-------
TABLE 2-1
DOE FACILITY DESCRIPTION
EMPLOYEES
OPERVTORlS)
BUDGET FY !
ii MILLION)
HANFORD
IDAHO NATIONAL
ENGNEERNG LABORATORY
(INEL)
LOS ALAMOS
NATIONAL LABORATORY
(LANL)
LAWRENCE UVERMORE
NATIONAL LABORATORY
(LLNL)
NEVADA TEST SfTE (NTS)
OAK RIDGE
NATIONAL LABORATORY
(ORNL)
ROCKY FLATS PLANT
(RFP)
SAVANNAH RIVER PLANT
(SRP)
WEST VALLEY
DEMONSTRATION PROJECT
(WVDP)
WASTE ISOLATION
PILOT PLANT
(WIPP)
HIGHLAND, WASHINGTON
IDAHO FALLSL. IDAHO
LOS ALAMOS, NEW MEXICO
LIVERMORE. CALIFORNIA
LAS VEGAS, NEVADA
OAK RIDGE. TENNESSEE
GOLDEN, COLORADO
AIKEN. SOLTTH CAROLINA
WEST VALLEY. NEW YORK
CARLSBAD, NEW MEXICO
14.400
5.700
10.200
7,000 - 8.000
5,300
5.000
6.000
16.000
500
700
• ROCKWEU-
• UNITED NUCLEAR
•WESTINGHOUSE
• BATTELLE PACIFIC
• NORTHWEST LABORATORY
• BOEING
•EG&G
• WESTINGHOUSE
UNIVERSITY OF CALIFORNIA
UNIVERSfTY OF CALIFORNIA
REYNOLDS ELECTRICAL &
ENGINEERING CO.
MARTIN MARIETTA
ENERGY SYSTEMS, INC.
ROCKWELL INTERNATIONAL
DU PONT de NEMOURS, INC.
WESTNGHOUSE
• WESTINGHOUSE
• INTERNATIONAL
TECHNOLOGIES
$1.013
$500 - $600
$500 - $600
$800
$1,000
$400
$400
$1,200
72
55
• PRODUCTION OF NUCLEAR
MATERIALS
• REACTOR DEVELOPMENT
• REACTOR DEVELOPMENT
• MAJOR PROCESSOR OF
SPENT FUEL
•NUCLEAR WEAPONS
DEVaOPMENT
• RESEARCH ON DEFENSE
SYSTEMS AGAINST NUCLEAR
ATTACK
• NUCLEAR WEAPONS
DEVELOPMENT
•ENERGY RESEARCH
• NUCLEAR WEAPONS TESTS
•DEFENSE RESEARCH
• HEAVY ELEMENT PRODUCTION
• PRODUCTION OF NUCLEAR
WEAPONS COMPONENTS
• PRODUCTION OF NUCLEAR
MATERIALS
• PROCESS HLW
•STORE DEFENSE
• ESTABLISHMENT TRU WASTE
-------
2.1.1 GENERATION
Four DOE facilities generate or treat HLW: (I) Hanford, (2) Savannah River Plant (SRP).
(3) Idaho National Engineering Laboratory (INEL). and (4) West Valley Demonstration
Project (WVDP: Table 2-2). Hanford, SPvP. and WVDP use the PUREX (Plutonium-Uranium
Extraction) process, which was developed to recover plutonium and uranium from spent fuel
or irradiated fuel rods in production reactors. At INEL, spent naval reactor fuel is
processed by a variation of the PUREX method to recover U-235 and krypton.
In both processes the first step is acid dissolution of the cladding from the spent fuel
rods. This is followed by acid dissolution of the fuel rod. The choice of acid for each
of these steps is dependent of the cladding and the fuel. Solvent extraction is then used
to separate out desired products such as plutonium and uranium. The fuel from the
decladding dissolution and the solvent extraction steps make up the HLW.
2.1.2 ON-SITE TRANSFER AND TANK STORAGE
HLW generated during the PUREX process is acidic and, at Hanford and SRP, is treated with
a caustic to make it strongly alkaline before it is routed through pipe systems to storage
tanks. At most sites, transfer systems are double-walled pipe-in-pipe with annular space
which can be monitored. Other systems, however, are steel cased in ceramic or concrete or
steel suspended in concrete lined trenches. The piping systems are generally upgrades
from the original single pipe systems which have failed at several facilities, producing
teaks.
The waste is sent to "aging" tanks where short-lived fission products decay, evaporation
occurs, and sludge settles. This usually takes several years. The storage tanks
originally used at Hanford and SRP were single-walled steel. These tanks were susceptible
to leaks and were difficult or impossible to monitor. They have generally been replaced
by double-walled, carbon steel tanks, which may be placed on "saucers" of steel or
concrete. The capacity of these tanks ranges from 300.000 to 1,300,000 gallons of waste
(Figure 2-1). The old single-shelled tanks are being decommissioned by removing the
supernatant to new tanks and gradually removing the sludge for treatment. The old
single-shell tanks no longer receive new wastes. At INEL and WVDP. the HLW is left in an
acidic state and stored in double walled stainless tanks.
2-3
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TABLE 2-2
HIGH-LEVEL WASTE INVENTORIES
AS OF DECEMBER 31, 1985*
SITE
Hanford (DOE)
Idaho (DOE)
Savannah River (DOE)
West Valley (commercial)
VOLUME (R/|3 )
123,000
10,100
222.000
2,315
* Adapted from Table 3.5, "Integrated Data Base for 1986:
Spent Fuel and Radioactive Waste Inventories, Projections, and
Characteristics". DOE/RW-0006, REV. 2, September 1986.
2-4
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FIGURE 21
DOUBLE SHELL TANKS
-------
2.1.3 TREATMENT
HLW is often reduced in volume by evaporation to conserve tank capacity. For example, at
SRP. the supernatant is transferred to an evaporator for dewatering. The concentrate from
the evaporator is then transferred to a cooling tank where the suspended salts settle.
The supernatant is then returned to the evaporator for further concentration. This
process is repeated until the waste has been converted to a damp salt cake which consists
of NaNO3 . Na2 CO3 , NaNO2 , Na2 SO4 , and NaAI(OH)4 . The radionuclide concentration in the
salt is approximately three times that of the supernatant.
At Hanford, after evaporation, the aged supernatant in the old, single-shell tanks was
sent to (he B-plant where the cesium (Cs-137) and strontium (Sr-90) are removed through an
ion exchange process. This process was initiated in about 1983 to remove the dominant
heat and radiation sources from the waste.
At WVDP, the supernatant treatment will include extensive liquid waste treatment.
Supernatant HLW from the tanks will be pumped and cooled using a chiller. The supernatant
will then be pumped through cesium removal ion exchange columns. The ion exchange
effluent will be solidified with cement and disposed on site or as a low-level waste
(LLW).
At 1NEL, a unique process has been developed and is presently in use that changes HLW into
a sand-like material which can be stored for centuries. There, the wastes from decladding
and fuel rod dissolution are solidified in the New Waste Calcining Facility (NWCF). This
facility, which began hot (radioactive) operations in September, 1982, has a
3,000-gallon-per-day capacity. It uses a highly automated, remote-handled, high
temperature fluidized bed calcination process.
At all other facilities handling, HLW will be vitrified in a glass material. At the WVDP,
the vitrification has been completed unit and entered the cold test phase in February,
1987. The Hanford vitrification plant is in the planning stages with a completion date
projected for the mid-1990s. SRP's Defense Waste Processing Facility (DWPF) is 46 percent
complete and will be operational in 1990.
2-6
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The WVDP vitrification system, scheduled to be operational in April. 1989, is the most
fully developed example of the process and will serve as a prototype for SRP. The sludge
and resin treatment will involve vitrification using a melter and will result in the
production of 300 glass logs (2 feet x 10 feet) of waste suitable for HLW repository
disposal. HLW sludge will be pumped through access risers with mobilization pumps into
the main process tank which will contain a zeolite ion exchanger system to remove cesium
from the waste. Once the cesium is removed, the waste will be routed to a feed
concentration make-up tank. After glass formers are introduced, the waste will be routed
to a melter. then to a feed delivery system which will fill the canister. Off-gases will
being sent to a submerged bed scrubber. Once the canisters are filled, they will be
cooled, decontaminated, rinsed, welded, and placed in interim canister storage. The
canisters will remain in storage until a HLW repository is available.
2.1.4 WASTE ANALYSIS
HLW analysis for hazardous constituents has been minimal at DOE facilities. The wastes
are usually characterized only in terms of the percentage of hazardous constituents.
However, the three generating facilities as well as WVDP have a fair understanding of the
overall make-up of their waste streams. Analyses of pH. temperature, radio activity, and
other characteristics are performed at sufficient frequencies in most pipelines for
process control purposes.
DOE argues that quantitative analyses of HLW are unneccessary since personnel exposure is
high during an adequate sampling and analysis program, and that quantitative data of
hazardous constituent concentrations at various points within the system would not change
operations. At the older facilities, obtaining representative samples from a
one-million-gallon storage tank requires the use of large equipment and many workers for
several days. These samples must then be sent to specialized, remote-handling laboratory
facilities where some further personnel exposure occurs. For the few times when such
analyses were performed at SRP. the findings did not indicate the need for modification of
either hazardous waste treatment or disposal practices. On the other hand, INEL has a
remote analytical laboratory (RAL) which began operations in 1986. Because this
laboratory meets the "as low as reasonably achieved (ALARA) exposure criteria, many
chemical analyses can be routinely conducted. The laboratory is capable of analyzing the
RCRA Appendix IX list of parameters.
2-7
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2.1.5 PROCESS CONTROLS
Process controls for HLW include the monitoring of valves, pumps, tank levels, and of the
outer shells of the pipes and tanks for leaks. Controls for HLW at the DOE facilities
visited by the task force are sophisticated; they resemble the process controls at
chemical plants rather than the monitoring controls at RCRA waste management sites.
These DOE facilities are. in fact, related to industrial chemical processing plants where
tanks and pipes are closely monitored to protect the integrity of the product. Since
deviations in mixes during treatment would result in unwanted products or reactions the
operations are carefully controlled. There are elaborate systems where valves, pumps,
tank levels, and other important parameters can are continuously monitored from a central
area. The system may also employ interlocks and fail-safe systems (i.e., shutdown for
power failure). In the system seen at Hanford. a computer-automated surveillance system
makes 5,700 readings a day.
A leak monitoring system also exists at Hanford; double-walled pipelines have redundant
leak detection controls which include encasement alarms, diversion box alarms, diversion
and catch-tank air monitoring, material balance discrepancies, radiation monitoring above
grade, and periodic swabbing of encasements. Any liquid escaping from the primary pipe
flows by gravity to a collection tank or diversion box. From there, it can be pumped back
into the system.
Tanks at all the facilities are controlled or monitored using various combinations of tank
liquid level measurements, annulus air monitoring, annulus liquid level, and leak
detection pit monitoring for liquids and air. The annulus of the doubled-wall tanks at
SRP is equipped with at least two single-point conductivity probes located at the bottom
of the annulus on opposite sides of the tank. When a conductivity probe detects liquid,
it activates audio-visual alarms in the waste management control room. Each alarm is
investigated, including visual inspection of the annulus. and a formal investigation
report is issued to operating and technical supervisors describing each incident and the
corrective action. All annul! are visually inspected and conductivity probes are tested
on a monthly basis.
2-8
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For inventory control and as an additional backup to the leak detection system, liquid
levels inside the tanks may be measured and recorded at various facilities on a regular
basis. In practice, however, these mass balance records are often the most sensitive
indication of leaks, particulary when long distances between detectors and pipelines
exist.
SRP is unique because it also performs inspections of waste storage tanks. These
inspections are difficult due to radiation and contamination problems, but SRP has
developed techniques for remote inspection and evaluation. These include visual
inspection by means of a periscope, photography, ultrasonic measurement of wall thickness.
and corrosion specimens.
Double-walled tanks at SRP with a history of leaking are inspected through a selected
annulus-lop opening at least once a year. All other double-walled tanks are inspected
every two and four years, respectively.
2.1.6 LONG-TERM STORAGE, TRANSPORT, AND DISPOSAL
Final disposal of treated HLW will be at the planned HLW repository, which is scheduled
for operation in the 21st century (Figure 2-2). The DOE is presently in the site-
characterization phase for three sites, one of which will be selected for the repository.
They are located in three different states and in three different geologic media. The
site in basalt is located at Hanford: the site in welded tuffs is located at Yucca
Mountain. Nevada; and the site in bedded salt is located in Deaf Smith County, Texas. The
canisters of vitrified waste are designed to be sent to the repository. Since the
repository is not yet available, means of storing wastes on site are still required.
The INEL is storing calcined waste, which has the texture of sand, in cylindrical storage
bins set in a reinforced concrete silo (Figure 2-3). There are three to twelve bins per
silo and there are six silos currently in use; a seventh is under construction. Each silo
provides storage for 3.500 cubic feet of calcine and they are designed to provide storage
for a minimum of 500 years.
2-9
-------
FIGURE 2-2
CONCEPTUAL DESIGN CUTAWAY
HIGH LEVEL WASTE GEOLOGIC REPOSITORY
o
DISPOSAL CONTAINER
RECEIVING STATION
WASTE
ENTRY
SHAFT
WASTE TRANSPORT
FROM HOPPERS
ROCK REMOVAL CONVEYOR
SKIP SHAFT
-------
FIGURE 2-3
CALCINE BIN SET MODEL
2-1!
-------
Currently, several waste form storage options are under consideration at the INEL for use
during interim storage including continuation of the calcine production, incorporation of
the calcine into glass or ceramic logs, or discontinuing calcination and going directly to
glass or ceramic logs.
Transforming calcined waste into glass logs could be accomplished by mixing the calcined
wastes with small granules of glass (frit), heating the mixture, and then drawing it off
into a stainless steel canister. The canisters would be handled remotely. Because of the
heat generation, the canisters would be stored in such a way that air can be circulated
around them. Provisions would be made for decades of such storage.
2.2 TRANSURAN1C (TRU) WASTE
TRU waste is defined in DOE Order 5820.2 as waste contaminated with transuranium
radionuclides that are alpha emitters with an atomic number greater than 92. The
radionuclides have half-lives greater than 20 years and occur in concentrations greater
than 100 nanocuries per gram (nCi/g). This definition would include various isotopes of
plutonium (Pu), americium (Am), and curium (Cm).
Individual DOE facilities are also permitted to "designate" radionuclides with an atomic
number of 92 or less as TRU waste as they detertnine to be appropriate. Under the
authorization of this policy, an isotope uranium (U-233), which is unique for the thorium
fuel cycle, and an isotype radium (Ra-226) have been designated as transuranics by the DOE
Oak Ridge Operations office.
The majority of TRU waste contains plutonium which is a low-energy, alpha-particle
emitter. Alpha particles are easily stopped by almost any barrier, and thus the radiation
level at the surface of container (box or drum) with only Pu-239 in it is usually low.
This type of waste is called "contact-handled" TRU waste (CH-TRU). Some TRU waste.
however, also contains beta- and gamma-ray emitters. These wastes must be handled
remotely if the radiation level at the surface of the container exceeds 200 milirem per
hour (mrem/hr). This type of waste is called "remote-handled" waste (RH-TRU).
The various elements involved in the management of TRU waste include generation.
packaging, on-site transfer and tank storage, treatment and certification, waste analysis,
controls, post-treatment storage, transport, and disposal.
2-12
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2.2.1 GENERATION
TRU waste results mostly from the processing, shaping and handling of
plutonium-contaminated materials. Most TRU waste is solid (e.g., gloves, paper, rags.
tools, and machine parts): however, some waste is liquid resulting from chemical
processing for the recovery of plutonium. Some TRU waste contains listed RCRA hazardous
waste, such as spent cutting oils, solvents, or lead. A small amount of TRU waste (<2%)
is classified because of its shape or form: its isotopic, chemical, or alloy composition;
or because the waste contains tools that may be classified.
The average annual generation rate of TRU waste for the period 1986 through 1995 is
projected to be 6.057 cubic meters (m3). of which 6.024 m3 is CH-TRU and 32.8 m3 is RH-TRU
(Table 2-3). As can be seen from this table. Rocky Flats Plant (RFP) is by far the
largest generator of CH-TRU. followed by Hanford and SRP. ORNL is the largest generator
of RH-TRU.
2.2.2 PACKAGING
When it is determined that the amount of plutonium or other transuranic element is not
worth recovering, the waste material is packaged for storage and ultimate disposal. This
process generally involves placing the waste in an 11-mil PVC bag which is sealed with
tape and placed in either (I) a 90-niii. rigid polyethylene drum liner which is sealed and
placed inside a 55-gallon DOT I7-C metal drum, or (2) a 50-mil fiberboard liner which is
wrapped in an I I-mil PVC wrapper, sealed, and placed in a 4ft. x 4ft. x 7ft, 14-gauge.
corrugated metal, welded box. The drums and boxes are sealed with tamper-indicating
mechanisms.
Some facilities -- ORNL, LANL and LLNL -- use a second 1 I-mil PVC bag inside the drum.
While many of the facilities use a steel drum for the final container, LLNL and SRP use
galvanized drums. ORNL does not use a 90-mil drum liner. ORNL has recently switched to
stainless steel drums due to corrosion problems encountered with steel drums. As a result
of switching, LANL coats its steel drums prior to storage with a corrosion inhibitor which
will be steam-cleaned away before shipment.
2-13
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TABLE 2-3
DOE-PROJECTED TRU WASTE GENERATION RATES
(1986-1995)
SITE*' I VOLUME
••••••^^^^^•^••^^^^^^^^••••^•••••^•^^•^^^••••••^^^•HM
Hanford
INEL
LANL
LLNL
ORNL
RFP
SRP
WIPP
Other
TOTAL
CH-TRU
658
3.3
320
282
44
4,158
348
40
171
$.024
(M3 )
RH-TRU
6.1
3.6
1.4
0
15
0
0
0
6.7
32.8
Adapted from Table 3.5, "Integrated Data Base for 1986:
Spent Fuel and Radioactive Waste Inventories, Projections, and
Characteristics", DOE/RW-0006, REV. 2, September 1986.
2-14
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2.2.3 ON-SITE TRANSFER AND TANK STORAGE
Liquid TRU wastes are piped from the generation source to treatment, or to storage and
then to treatment. All facilities visited use double-walled (pipe-in-pipe) pipe systems
composed of polyethylene or stainless steel.
Liquid TRU waste is generally stored in above-ground tanks in buildings. If the tanks are
not double-walled, they have curbing around them for secondary containment. In the case
of ORNL, TRU wastes are stored as sludges in two types of underground tanks. ORNL's
Melton Valley storage tanks are stainless steel tanks. They are contained in a stainless
sleel-lined concrete vault. Each vault has a sump system with an alarm. In addition, six
single-wailed gunite tanks are used. These lack ground-water monitoring but are equipped
with sumps with alarms. Formerly, these tanks were used to store wastes prior to
evaporation and disposal by underground injection. This practice, called hydrofracture.
has been discontinued.
2.2.4 TREATMENT AND CERTIFICATION
Many different treatment systems for the processing of TRU waste are already in place or
are in (he planning stages. Some, of these systems were installed for the purpose of
recovering ptutoninum (liquid waste treatment at RFP and LANL), some are for the purpose
of reducing the volume of TRU waste (the planned incinerator for SRP. (he incinerator at
LANL. and the size reduction facility at LANL. and others are for the express purpose of
complying with the WIPP waste criteria (e.g. Process Experimental Pilot Plant (PREPP) at
INEL).
The LANL liquid waste treatment system, a physical-chemical plant, removes 99 percent of
the uranium and plutonium. The treatment steps include influent analysis,
flocculation/precipitation. filtration, ion exchange, treated liquid analysis, and
discharge. The sludge resulting from treatment, which is TRU waste, is dried on a vacuum
filter, mixed with cement, and placed in 55-gallon drums. Approximately 60 drums of
cemented sludge are produced each year. The supernatant from the plant is directly
discharged in accordance with a NPDES permit.
2-15
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The TRU waste incinerator at LANL is utilized for the volume reduction of TRU combustible
wastes. This incinerator consists of a ram feeder, a primary combustion tank and a
secondary combustion chamber to burn particulaies and volatiles. a feed preparation glove
box, and an off-gas cleanup system. The off-gas cleanup system consists of a high energy
scrubber, venturi scrubber, packed column, and three banks of high energy paniculate air
(HEPA) filters. The incinerator is presently permitted to incinerate PCB's and has
interim status as a hazardous waste incinerator. During a recent trial burn it achieved a
99.99 percent reduction of carbon tetrachloride (CCL) and a 99.9999 percent reduction of
trichloroethylene (TCE). The capacity of the incinerator is 100 pounds of solids per hour
or one million BTU's per hour of liquids. LANL plans to incinerate all TRU wastes
containing organics. solvents, and oil.
The size reduction facility at LANL is used to cut up large metallic TRU wastes, such as
glove boxes. The entire facility is fully contained and remotely operated. It can handle
wastes up to IS x 15 x 30 feet. A plasma torch is used to cut up the large objects.
The PREPP at INEL includes shredding, rotary kiln incineration with secondary combustion
with dry. off-gas handling, and particle-size separation with fine materials going to
grout mix and coarse materials being added to the grout product in certifiable WIPP
containers. The PREPP facility has been designed for full RCRA compliance, including
waste analysis, performance standards, operating requirements, and monitoring and
inspection. The expectation is that the facility will be used for both hazardous wastes
and mixed wastes in the future.
Currently, there is no facility in the DOE organization for processing RH-TRU wastes.
However, funding for a Waste Handling Pilot Plant (WHPP) at ORNL has been appropriated.
The WHPP is a processing facility for repackaging and WIPP certification of RH-TRU wastes.
The WHPP feasibility study was completed in 1984 with construction on the facility
scheduled to begin in 1991. Existing plans call for construction to be completed and the
plant operational by 1996. Since 94 percent of DOE's inventory of RH wastes is stored at
ORNL. it is conceivable that the WHPP may serve as a central processing facility for
RH-TRU wastes. Such wastes could be transported from INEL and Hanford. for example, for
processing.
2-16
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In addition to the waste treatment systems, the larger TRU waste generators and the
retrievable storage facilities have installed or are in the process of installing
facilities for examination and assay of containerized TRU waste. At ORNL, for example,
each drum must pass an examination by three separate assay systems in order to obtain
certification: (I) The ORNL real-time radiography (RTR) examination allows x-ray
inspection of individual drums. Using this system, liquids, partially filled aerosol cans
and other prohibited items can be detected. (2) Drums are also passed through a neutron
assay system (NAS) which scans the container for Fissile material. This is accomplished
by using active and passive scanning modes. The active mode of the NAS detects
thermal-neutron-induced fission reactions, while the passive mode detects neutrons emitted
by spontaneous fission. Using these data, the total TRU activity per drum may be obtained
by adding the results of the active and passive scans. The sensitivity of NAS ranges from
200 grams (g) to as low as 0.5g. Finally (3) the segmented gamma scanner (SOS) identifies
minimum detectable quantities of gamma-emitting isotopes. Although the SGS qualitatively
monitors for gamma-emitting isotopes at present, it will be upgraded to provide a
quantitative assay of individual waste containers.
2.2.5 WASTE ANALYSIS
TRU waste analysis is routinely performed for radioactive material content. The hazardous
constituents are routinely identified but not quantified. Lab experimenters and other
glove-box generators of TRU wastes must label the contents of each package, specifically
noting any hazardous waste contents. The individually wrapped packages are then doubly
wrapped and containerized for disposal at the WIPP, minimizing the chance of contact among
incompatible .wastes and thus at least reducing the need for quantitative analyses.
Quantitative analyses will be performed more regularly in the future as automated.
remote-handling laboratory capacity increases. As indicated in the next section, remote
monitoring of liquid TRU is being enhanced at LANL. TRU waste is analyzed prior to
incineration at LANL and in the newly constructed PREPP facility at INEL.
2.2.6 CONTROLS
Two types of controls — process and administrative — were observed in use for TRU waste
management. Extensive process controls are utilized with regard to the transfer of liquid
TRU waste as well as the treatment of this waste. This control generally consists of
2-17
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state-of-the-art, computerized control of such factors as valves, pumps, tank levels, and
chemical addition. In addition, remote, routine monitoring of several parameters such as
flow rate. pH, temperature, conductivity, and radioactivity is performed. Similar control
and monitoring technology is used with respect to the treatment systems dealing with solid
TRU wastes described in Section 2.2.4.
There are also extensive administrative controls for TRU waste. The majority of these
controls are a part of the WIPP Waste Acceptance Criteria (WAC) and must be met if a
facility is to ship its waste to the WIPP. Record keeping starts at many facilities with
a detailed description of each bag of waste placed in a drum or box. This data package
accompanies each drum certified for shipment to the WIPP. The data requirements include
shipment/transportation data (e.g., shipment number, shipment date, carrier code, vehicle
number, vehicle type, waste type, shipment certification, etc.), as well as waste package
data (various code and identification numbers, closure date, weight, surface dose rate.
neutron component, organic materials weight and percent volume, plutonium fissile gram
equivalent, total alpha activity, presense of hazardous waste, waste package certification
date. etc.). All waste examination and certification records are retained in duplicate.
Detailed and extensive record keeping for drum assay is also done and accompanies each
shipment to storage. Operator training is documented and quality assurance programs serve
to oversee me handling of TRU wastes at every facility.
A nonconformance report is issued for any newly generated TRU waste which cannot be
certified. This report accompanies any noncertified TRU waste container returned to the
generator for repacking. Appropriate signatures must be provided on the nonconformance
report before the waste will be reaccepted for re-examination and certification. Drums
which fail WIPP certification are color-coded and returned to the retrievable storage area
until such time as a disposition can be determined.
2.2.7 POST-TREATMENT STORAGE
Since 1970, DOE has placed its TRU waste in what is referred to as "retrievable storage."
As of the end of 1985. 90.555 m3 of CH-TRU waste was stored at six facilities and 1,572 m3
of RH-TRU waste was stored at four facilities (Table 2-4.) It should be noted that Table
2-4 does not account for the RH-TRU waste observed by the task force at SRP.
2-18
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TABLE 2-4
INVENTORY OF DOE RETRIEVABLE TRU WASTE
THROUGH 1985*
STORAGE SITE VOLUME (M3 )
^^^^^— ^^^^^^— ^VM^^^^^^^^^^^^^B^B^^^^^^^H
CONTAC
Hanford
INEL
LANL
NTS
ORNL
SRP
TOTAL
BEK/pTEt-
Hanford
INEL
LANL
ORNL
TOTAL
;T HANDLED
16,301
65,725
4,723
536
507
2,783
90.555
ADDLED
22
45
29
1,476
1,572
* Adapted from Table 3.3, "Integrated Data Base (or 1986:
Spent Fuel and Radioactive Waste Inventories, Projections, and
Characteristics", D'OE/RW-0006, REV. 2, September 1986.
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Storage of CH-TRU waste varies with the facility. However, the majority of TRU waste
stored at Hanford. INEL, LANL. and SRP has been placed on pads
-------
FIGURE 2-4
WIDE BOTTOM STORAGE TRENCH FOR TRU WASTE
2-21
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FIGURE 25
TRi; WASTE STORAGE PADS COVERED WITH PLASTIC AND EARTH
-------
FIGURE 2-6
TRU WASTE STORAGE AREA
CONTACT HANDLED WASTE RETRIEVABLY STORED
-------
With the startup of WIPP in 1988, contact-handled TRU will be shipped to the WIPP site via
highway or rail in TRUPACTs (Figure 2-7). These TRUPACTs will hold either 55-gallon metal
drums banded together in "six-packs" or various-sized metal boxes.
The TRUPACTS have been designed to satisfy all federal regulatory requirements of the
Department of Transportation and tested to withstand highway accident conditions. Only
one TRUPACT will be transported per truck, two per railcar. Remote-handled TRU waste, by
far the smaller amount anticipated at WIPP. will arrive in specially designed, shielded
casks which wilt contain the actual waste container,
2.2.9 DISPOSAL
All certifiable TRU wastes, (except for those from the WVDP, because they are not defense
related), will be sent to the WIPP starting October, 1988. The WIPP will handle both
contact-handled and remote-handled TRU waste (Figure 2-8). TRU waste will be received
first: RH-TRU waste will follow in 1989.
When a TRUPACT of CH-TRU waste arrives at WIPP, it will be inspected for damage and
contamination. Then, after all shipment documents are verified, it will be taken to the
contact-handling part of the Waste Handling Building, where it will go through an air
lock. The TRUPACT will be opened and the -waste packages inside removed and inspected
prior to being transferred to the underground storage area. Once underground, a forklift
will stack the waste packages ("six-packs" will be stored three high). This final
location will then be entered into a computer, so that every package will be traceable.
When a shielded cask of RH-TRU waste arrives at WIPP, it will be carefully inspected and
all of its shipping documents checked. The cask will then be transported into the
remote-handling portion of the Waste Handling Building, an area separated from the
contact-handled waste area. The cask is then isolated in a special room and opened to
remove the waste container, which will be taken to the "hot cell" where it will be
identified and inspected. The container will then be placed in a facility cask for
transport to the underground storage room. Once in the storage room, the facility cask
will be placed in a machine that removes the waste container and emplaces it into a
pre-drilled hole in the storage room wall. After the container is emplaced. the hole will
be plugged and the facility cask reused.
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FIGURE 27
TRUPACT BEING TRANSPORTED
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FIGURE 2-8
WASTE ISOLATION PILOT PLANT SCHEMATIC
r^>
to
CONSTRUCTION
SALT HANDLING
SHAFT
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The WIPP is currently limited by law to 25 years of operation. The amount of TRU waste
that can be stored at WIPP is limited by the total authorized TRU storage area of
approximately 6.4 million cubic feet. By the end of 1988. when the WIPP is scheduled to
begin operation, there will be an estimated 3.8 million cubic feet of retrievably stored
TRU waste. At the current rate of TRU waste generation -- about 0.23 million cubic feet
per year — the capacity of WIPP will be exceeded before the year 2000. assuming
production continues at (he current rate. At the expected emplacement rate, 0.3 million
cubic feet per year (limited by transportation), capacity will be reached by the year
2009.
Wastes disposed of prior to 1970 at many facilities will be left in place. Some TRU waste
which is uncertifiable and older TRU wastes at LANL were studied and a decision was made
to leave them in place. This particular decision is presently being re-evaluated with a
report due to DOE's Albuquerque Operations office in June 1987.
Classified TRU waste is disposed of at the NTS. All classified TRU waste is in solid form
(such as graphite, steel, or plastic). Most of the waste is uncontaminated by known RCRA
hazardous chemicals. Approximately 5,600 cubic feet of TRU waste has been disposed of at
NTS since 1985 in a greater confinement disposal (GCD) facility. The GCD shafts are
drilled 10 feet in diameter and 120 feet deep and are not lined (Figure 2-9). Waste is
then emplaced in the shaft to fill about half the volume and the shaft is then backfilled.
The GCD project began in 1981 to demonstrate the disposal of defense LLW at a depth
sufficient to minimize or eliminate natural intrusion processes — for example, animal
burrowing or plant rooting, - and to substantially reduce the potential for inadvertent
human intrusion. The two goals for the GCD test are to collect and analyze data on
radionuclide migration (using nonradioactive gaseous and liquid tracers) at the 120-foot
level and to develop handling procedures. Fiscal year 1987 is the final year of the GCD
test. Data from this test will be used in the forthcoming 40 CFR 191 performance
assessment (draft due September. 1987).
The GCD facility currently has a capacily (assuming 50% of the volume is waste) of about
40.000 cubic feet of waste. The GCD facility is being used for both
high-specific-activiry LLW and classified TRU waste. The classified TRU waste comes from
weapons facilities around the country. There are no plans to retrieve this waste.
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FIGURE 29
GREATER CONFINEMENT DISPOSAL (GCD) SHAFT
K>
GO
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2.3 SPECIAL WASTES
Hanford has been chosen as the disposal site for decommissioned reactor compartments from
nuclear submarines. These compartments are approximately 30 to 35 feet in diameter. 30 to
38 feet in length, and weigh approximately 1000 tons (Figure 2-10). The compartments
contain no spent fuels or TRU waste but pose a potential low-level radiation hazard due to
activation products, mainly cobalt (Co-60). The compartments also contain approximately
250 to 350 tons of lead.
The disposal site is located in the 200 east area and consists of an excavation
approximately one acre in area which will accommodate about 12 compartments. At the
present time, one unit has been placed at the site. When 12 compartments have been
placed, the site will be backfilled. No ground-water monitoring is planned after burial
of the units.
2.4 ENVIRONMENTAL MONITORING
Environmental monitoring by contractor-operators is carried out in some measure at every
facility and usually includes air and surface water and ground-water monitoring for
radionuclides. In some cases soil, sediment, biota, and foodstuffs are also collected and
analyzed for radioactivity.
Typically, the ground-water monitoring has been useful for establishing area-wide trends
but not for determining whether contaminants have entered the ground water from specific
waste treatment and disposal units. Some facilities have recently begun analyzing ground
water for hazardous constituents, although a majority of the installed wells do not meet
RCRA criteria.
At SRP and Hanford. where tank leakage has been documented, some ground water monitoring
wells have been installed to map the extent of radioactive material migration. The
monitoring system, however, like other DOE facilities visisted, did not meet RCRA
standards. In adequate analyses have also been performed for hazardous waste components
designed to detect and quantify the impact on ground water by each source.
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FIGURE 2-10
NAVY SUBMARINE REACTOR COMPARTMENT
NJ
o
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Area-wide air monitoring is usually extensive both at the perimeters of the facilities and
toward population centers. At INEL, constant air monitors in the milli curies per cubic
centimeter operational areas provide detection sensitivity at about I0~ (Ci/cc). roughly
equivalent to 15 parts per billion (ppb) of plutonium oxide. Perimeter monitoring
detection sensitivity is !0~ Ci/cc, or 1.5 x 10" ° ppb. of plutonium oxide.
Radiological baseline monitoring programs are conducted at new facilities such as WIPP.
The goal is to measure background levels of radiation and radionuclides. This program
includes sampling and analysis for atmospheric, terrestial, hydrologic biota, and ambient
radiation. An Ecological Monitoring Program monitors and evaluates the impacts of the
WIPP construction (and future operations) on the ecosystem. This program includes
environmental photography, soil sampling and analysis, soil microbiotic studies,
vegetation surveys, air and water quality monitoring, vertebrate censuses, and
meteorological monitoring.
The hydrogeology at WIPP has been studied extensively. There is no significant amount of
ground water in the vicinity of the underground site. There is a limited amount of ground
water in the Rustler Formation, which is located within 1,000 feet of the surface, about
1.100 feet above the underground site. No RCRA ground-water monitoring wells are
scheduled for installation prior to or after waste acceptance.
At NTS, the monitoring system for the waste management area centers on the detection of
gamma radiation and airborne radionuclides. No ground-water monitoring is done because
DOE believes that there is not enough water to drive the radionuclides to the ground
water, that the long distance through the unsaturated zone will protect the aquifer, and
that drilling monitoring wells would increase the spread of contamination.
ORLN has developed a remedial action program to control existing and future ground-water
contamination and investigate potential sources of continuing releases. This program is
based on a "Waste Area Groupings" (WAG) approach which uses information from U.S.
Geological Survey (USGS) studies, an ORNL developed ground-water strategy, geology.
hydrology, waste management reports and research results; and an inventory of
solid-waste-management units (SWMU's) identified at ORNL and other available data and
information.
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To date, there are 830 ground water monitoring wells at ORNL. Of this number, 258 are
newly constructed WAG Perimeter wells, 90 are new piezometer wells, and 27 are new
hydrostatic head-measuring stations. The extent of wells required for the remedial
investigation/feasibility study of the SWMU's has not been determined to date. The
program is not yet in full operation, and no data or results were available for the task
force. It is predominantly oriented towards older, low-level waste disposal practices
where extensive contamination is suspected.
At all facilities determinations would need to be made for many HLW/TRU waste management
units to determine whether Subpart F ground-water monitoring requirements apply and, if
so, whether the units would qualify for waivers. The above-ground inspectable waste
storage areas observed by the task force for example, probably would not require
ground-water monitoring under RCRA. Similarly, the double-wall piping and tanks with
interstitial monitoring would not need ground-water monitoring . On the other hand, the
task force observed "retrievably stored" drum areas which looked very much like landfills
or waste piles. These drums, buried under two to four feet of earth cover, were not
inspectable. Leak detection systems in some piping and storage tanks were sparse (one to
two thousand feet between sumps was not uncommon). Whether these systems qualified as
bases for ground-water monitoring waivers could require considerable documentation.
2.5 AUDITS/ASSESSMENTS/OVERVIEW
All of the DOE facilities operate under the same management system, which is characterized
by relatively high contractor autonomy, some operations or Area office oversight and
little headquarters involvement. DOE headquarters issues orders which are interpreted to
fit each operation by the appropriate operations office.
All facilities planning to ship TRU waste to the WIPP have been and will be subjected to
audits by the WIPP-WAC committee. Other audits are performed by the contractors' staff,
DOE Operations, DOE Headquarters, or outside consultants hired by DOE. However, there are
no audits by any groups who do not report to DOE.
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2.6 SECURITY
General security at most of the facilities is provided by 24-hour armed guards sometimes
supplemented by tactical response teams. There are usually barriers such as fences and
controlled access to TRU waste disposal or storage areas. At most sites, armed guards are
required for non-pipeline, TRU waste shipments made within the plant. There are materials
balance checks and satellite tracking for TRU waste shipments off site.
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3.0 STATE PERSPECTIVES
The MEWS task force discussed the DOE option with personnel from the States of California,
Colorado, Idaho, New Mexico, South Carolina, Tennessee, and Washington. The State of
Nevada declined to meet with the task force because of a time conflict. New York State
personnel who are actively involved in the project were present at the West Valley
briefing and participated in the discussions. This selection corresponds closely with the
DOE facilities visited by the MEWS task force. Each State is directly concerned with
current and future oversight and regulation of DOE facilities within its borders. Some
States are concerned with DOE operations outside their borders as well (e.g.. New Mexico).
Regional EPA representatives participated in all State discussions.
The State's response to the DOE option varied from strong opposition to mild reservations.
The following is a synopsis of the discussions with the States. Many of the same issues
were raised by each. Detailed State reports are provided in Appendix B.
A majority of the States felt that a "blanket RCRA exemption" would be unwise and would
lead to litigation. Most States, however, were willing to consider applications for
specific variances or limited exemptions. They did not agree that self-regulation of
mixed wastes by DOE was appropriate. Some States also expressed doubt about DOE'S
"inconsistency by duplication" argument.
Most of the States expressed the desire to have EPA and DOE definition of HLW, low-level
waste (LLW). and TRU waste. Universal definitions would provide a foundation for more
detailed waste management studies and for classifying waste streams at facility. Fixed
definitions would also simplify estimations of needed storage, treatment and disposal at
facilities and the Waste Isolation Pilot Project (WIPP) capacity. One State recommended
that EPA set specific activity levels to separate waste types. Several States were also
concerned that any LLW generated by treatment of HLW remain under RCRA purview.
Some States were concerned about the hazardous wastes or hazardous constituents released
from the wastes mixed with grout or vitrified for disposal. The leachability of these
products in different environments has yet to be established. The State's were also
concerned about the incompatibility of wastes while in containment. Better
characterization and segregation of waste streams would resolve these issues, although it
may be difficult to conduct chemical analyses for such wastes.
3-1
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Some States emphasized the need for a broad definition of equivalency when comparing RCRA
requirements with facility safeguards. They also pointed out that RCRA was written for
different situations, and there is thus a need to compare intents and results rather than
specific regulations and requirements.
Several States expressed concern with both the difficulty of monitoring underground
pipelines to tanks and the general lack of RCRA-quality ground-water monitoring at the
facilities. Most felt this situation was not acceptable.
Finally, each State, when queried about its desire and ability to regulate DOE facilities
under RCRA, replied that it wanted some oversight in conjunction with EPA. Some are
willing to prepare to meet the challenge.
In summation, the States were universally opposed to that portion of the DOE option which
would remove them from providing regulatory oversight at DOE operations.
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4.0 FINDINGS
The purpose of this section is to present the MEWS task force findings concerning DOE's
current management of high-level waste (HLW) and (TRU) waste. These findings are based on
short visits to 10 DOE facilities that generate and manage the nation's HLW and over 95
percent of the TRU waste in the DOE system. In-depth visits might uncover other details
but most likely would not change the overall impressions of the task force. These
findings do not apply to DOE's past management practices. More detailed visit reports for
each facility and each State are provided in Appendices A and B respectively.
4.1 HLW/TRU WASTE MANAGEMENT IS COMPLEX
As noted in Section 2.0. the size of the DOE facilities varies, the operations are
complex, and it would require considerable time to become familiar with them. Each
facility generates products and wastes differently. The differences depend on the
mission, the age of the facility, and the operating contractor. Similarly, once produced.
the wastes are often managed differently at the various sites.
At large production plants, such as the Savannah River Plant (SRP) or Hanford. operations
are more fixed and routine and produce waste streams that are more predictable than those
of the smaller research laboratory facilities. The research performed and the waste
generated at laboratories such as Los Alamos National Laboratory (LANL). Lawrence
Livermore National Laboratory (LLNL). and Oak Ridge National Laboratory (ORNL) vary from
year to year. Consequently, waste managers at these sites must be involved in current and
planned operations. They must also be able to deal wifh new situations. The large
plants produce very large quantities of waste over long periods of time. The wastes are
difficult to handle; they are mostly liquid, highly radioactive, and contain hazardous
chemicals.
As facilities change over time, the ways in which they produce and handle their wastes
change. Definitions of certain waste types have changed with time and also differ from
facility to facility. DOE facilities are run by several different contractors; therefore,
waste management attitudes and concepts vary. Requirements for disposing wastes at the
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Waste Isolation Pilot Plant (WIPP) or in a future HLW repository have helped to
standardize packaging and treatment, particularly for TRU waste. Even so. there are four
different types of TRU waste [contact-handled (CH-), remote-handled (RH-), classified, and
U-233] and each is managed in a different way.
Waste streams generated by different DOE facilities will continue to vary, requiring
flexibility in applying national regulatory guidelines. Various methods such as
incineration, glass vitrification, and grouting and cementing of the treated wastes
continue to be refined and improved, producing changing waste handling requirements.
4.2 TRU WASTE IS OFTEN MANAGED WITH LLW AND RCRA HAZARDOUS WASTE
TRU wastes are often managed together with LLW and RCRA hazardous waste. For example, at
LLNL, TRU waste is managed within the same staging area as LLW, RCRA non-radioactive
hazardous waste, and PCB waste. In other words. TRU waste is usually not a separable
waste management problem.
Many old HLW/TRU waste disposal sites are now designated as RCRA Solid Waste Management
Units (SWMUs). Some of these sites will require cleanup under RCRA permits because of the
hazardous waste component. The radioactive component will have to be dealt with at the
same time.
•»-•* THE HLW/TRU WASTE SYSTEM DEPENDS HEAVILY ON FUTURE ACTIONS
The handling and disposal system for HLW and TRU waste'depends heavily on the construction
of several new facilities, including the WIPP and a HLW repository.
Throughout the DOE system, TRU wastes are being packaged and stored pending delivery to
the WIPP beginning in October, 1988. If the WIPP operations should be delayed or stopped,
long-term storage of TRU waste will have to be implemented. Alternative disposal methods
may also be necessary (e.g., on-site disposal at each generating site). The WIPP
repository is limited in the amount of TRU waste it is designed to receive. Estimates of
the present quantities of TRU waste slated for WIPP storage indicates that the WIPP must
either be expanded or duplicated.
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The high-level waste repository is projected to be built in basalt, tuff, or bedded salt
and be operational by 1998. It is designed to dispose of both DOE and commercial wastes
and should be able to accept projected HLW volumes for at least 50 years.
HLW will be processed and stored at DOE facilities with the specifications of such a
repository in mind. If the repository is delayed or canceled, other disposal options must
be considered and developed.
Vitrification plants are either being designed or are in various stages of construction at
three facilities. The unit at West Valley is presently in the testing phase and should be
operational in 1987. The Defense Waste Processing Facility (DWPF) at the SRP is 46
percent complete and will be operational vitrifying HLW by 1990. The Hanford facility is
only in the planning stages and is projected to be completed in the mid-1990s.
Currently, there is no facility at ORNL for processing RH-TRU wastes. However, funding
for a Waste Handling Pilot Plant (WHPP) has been appropriated. The WHPP is planned as a
processing facility for repackaging and WIPP certification of RH-TRU wastes. The WHPP
feasibility study was completed in 1984 with construction on the facility scheduled to
begin in 1991. Existing plans call for construction to be completed and the plant
operational by 1996. Since 94 percent of DOE's inventory of RH-TRU waste is stored at
ORNL. it is conceivable that the WHPP may serve as a central processing facility for
RH-TRU wastes. Such wastes could be transported from INEL and Hanford, for example, for
processing.
4.4 THERE ARE SPECIAL CASES THAT DO NOT FIT THE "NORMAL" MANAGEMENT
SCHEME
There are also special disposal cases. Dismantling and decommissioning of submarine
reactor compartments would expose workers to high levels of radiation. Consequently.
these compartments are disposed of intact at the Hanford site without subsequent
monitoring.
Classified TRU waste will continue to be generated, even though DOE is trying to minimize
the quantity of this waste. It must either be treated to destroy the classified nature of
the material or be disposed of in such facilities as the Greater Confinement Disposal
(GCD) at the Nevada Test Site (NTS).
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Some TRU wastes are and will be uncertifiable and will not be accepted by the WIPP. A
final disposal site for this material has not yet been decided upon.
4.5 MOST DOE PRACTICES FOR HLW/TRU WASTE SEEM COMPARABLE TO RCRA
STANDARDS, AND SEVERAL PRACTICES SEEM SUPERIOR TO RCRA REQUIREMENTS
Assessment of the major operational features of each DOE facility leads to the general
conclusion that most aspects of DOE's current management practices for HLW and TRU waste
appear equivalent to RCRA requirements for hazardous waste. Moreover, DOE's practices for
these wastes seem to exceed RCRA requirements.
Security is very tight and generally exceeds that required by RCRA. The quality of
contingency planning and emergency response networks is also high. The controls for
monitoring HLW tank storage and treatment systems are sophisticated and are staffed
continuously. Waste tracking and documentation are strictly adhered to and often
computerized. The planned disposal of HLW and TRU wastes in deep underground repositories
appears to be superior to near-surface disposal in landfills allowable (after treatment)
under RCRA.
4.6 SEVERAL ASPECTS OF DOE PRACTICES PROBABLY WOULD NOT MEET RCRA
STANDARDS
There are other aspects of present DOE management practices for HLW/TRU waste which,
because they depend heavily on radiation detection for their effectiveness, would probably
not meet RCRA standards. The lack of detailed knowledge of the hazardous chemical
components of radioactive waste raises concern about incompatibility or the production of
toxic emissions when wastes are stored or treated together. Ground-water monitoring
systems, if they exist, generally do not meet RCRA standards (e.g., for number and
placement of wells, materials in well construction, etc.) Monitoring TRU waste contained
in retrievable storage is often not performed, cannot be performed on the present system,
or relies exclusively on sump monitoring or air sampling which frequently occurs at
irregular intervals. RCRA regulations and guidance assume independent inspection and
control of waste management sites. Self implemented and internally audited programs are
not consistent with this principle.
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4.7 RCRA VARIANCES OR PROPOSED SUBPART X COULD APPLY TO SOME ASPECTS.
BUT CASE-BY-CASE EVALUATION IS NECESSARY
RCRA variances may be applicable to some aspects noted above, such as waste analysis or
ground-water monitoring requirements. Each facility, however, must be evaluated on a
case-by-case basis before variances can be granted. The new RCRA Subpart X regulation may
provide a mechanism by which unusual management options could be evaluated separately for
each facility, or for new facilities or treatment units. Examples of possible application
of proposed Subpart X include the WIPP and the HLW vitrification plants.
4.8 THE CURRENT MANAGEMENT WOULD NOT CHANGE SIGNIFICANTLY
HLW/TRU WASTE WERE CONTROLLED UNDER RCRA;
The general management of HLW/TRU waste at DOE facilities would not change significantly
if the facilities were subject to RCRA Subtitle C hazardous waste controls. Areas that
would need to be addressed through improved practices or case-by-case variances include
chemical analyses of wastes, ground-water monitoring, and independent oversight.
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5.0 ALTERNATIVE STRATEGIES
This section presents alternative strategies to the DOE option for EPA's consideration.
The DOE operation is broad and permanent. It provides DOE with control over all current
and future mixed HLW and TRU waste management with essentially no further EPA or State
involvement. The MEWS task force has identified five alternatives to the DOE option.
These were developed as a result of task force visits to DOE facilities and discussions
with State and EPA Regional personnel. The alternatives presented do not include all
possible strategies. They do however, provide a broad spectrum of possible EPA and State
overviews ranging from full RCRA exemption with minimum oversight to full RCRA applic-
ability with maximum oversight. This section presents a description of each alternative
strategy followed by a general discussion of its implications, advantages, and dis-
advantages. Each strategy is described from an EPA perspective. A variation on each
strategy would have RCRA-authorized States participate with EPA in oversight or control of
DOE's HLW/TRU waste operations.
5.1 DESCRIPTION
Strategy I - Mixed HLW/TRU Waste Exempt. But Greater EPA Oversight
This alternative strategy is basically the DOE option but with a stronger, more visible
and assertive EPA presence. This strategy would be implemented through EPA regulation and
would be applicable to all facilities that manage HLW and TRU wastes.
Strategy 2 - Site-by-Site Exemption (e.g. WIPP)
This alternative strategy would provide exemptions on a site-by-site basis. It is based
on the assumption that there is such a wide variety of waste management practices among
the facilities that a nationwide exemption would be impractical. Under this alternative,
an individual site would be exempt if all HLW and TRU mixed-waste management practices at
that site were equivalent or superior to those required by RCRA. Potential candidates for
such exemptions might include the WIPP. the future HLW repository, other future facilities
designed with the exemption in mind, and any of the existing facilities meeting certain
criteria that could be developed jointly by the two agencies.
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Strategy 3 - Unit-by-Unit Exemption (e.g. Vitrification Plants)
This alternative strategy provides exemptions for all similar units nationwide. It is
based on the assumption that the identified processes incorporate best waste management
technology and could be exempt categorically. Possible examples include vitrification
plants, vitrified waste storage facilities, deep geologic repositories, and TRU waste
certification facilities.
Strategy 4 - Mixed HLW and RH-TRU Waste Exempt. But not CH-TRU (More RCRA-like)
This alternative strategy exempts HLW and RH-TRU waste as per the DOE option but regulates
CH-TRU waste under RCRA. The exemption for HLW and RH-TRU waste is based on the high
level of protection which is provided by controls for radiation hazards and on the risks
to operation personnel involved in sampling and analyzing of those wastes. CH-TRU waste
is regulated under RCRA because of its numerous similarities to low-level waste.
Strategy 5 - Mixed HLW/TRU Waste Controlted Under RCRA (With Variances)
In this alternative strategy, mixed HLW/TRU waste is regulated under RCRA, In those
instances where current DOE waste management practices do not conform with RCRA
requirements, EPA decides whether changes in those practices are necessary in order to
achieve performance levels equivalent to RCRA, or whether case-by-case variances are
appropriate.
5.2 DISCUSSION
In evaluating the aiternative strategies, the MEWS task force examined the following
issues identified through its site visits: definitional problems, conditional exemptions,
resources required, burden of proof, administrative barriers, levels of oversight, and the
role of RCRA-authorized States.
One of the findings (Section 3.0) of the MEWS task force is that there are definitional
problems that require resolution before exemptions can be considered. These problems
result in an unclear distinction between those units and processes which would be included
or excluded in any exemption or variance. This lack of certainty would vary in degree
depending on the extent of the exemption. For example, the total exemption of HLW and TRU
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wastes in Alternatives J and 2 would result in more definitional problems than in
Alternative 3 where only HLW and RH-RU waste would be exempt. Additionally, the exemption
of HLW and TRU wastes from RCRA regulation would not typically exempt entire DOE
facilities from RCRA control, because all sites visited to date are subject to RCRA
regulation for mixed low-level and/or hazardous waste.
The second issue is whether an exemption should be conditional. Under the DOE option, the
exemption is irrevocable. Alternative I, HLW/TRU waste exempt with greater oversight,
could either be irrevocable, or it could be made contingent upon satisfactory performance
by DOE with regard to mutually established nationwide criteria. Under Alternative 2,
site-by-site exemptions. EPA could establish an exemption which would remain in effect as
long as joint EPA/DOE reporting requirements and environmental performance criteria were
met. If the criteria were not met at any site, procedures could be established to
re-evaluate the criteria or revoke the exemption for that site. Exemptions under
Alternatives 3 and 4 could be contingent upon nationwide performance criteria. Under
Alternative 5, variances would normally extend only for the life of the RCRA permit.
The advantages of revocability are that EPA can respond more quickly to environmental
problems and can ensure that the conditions of any exemption continue to be met. A large
resource commitment may be needed in order to provide surveillance, and perhaps more
importantly, the procedural requirements to rescind an exemption could become complex.
Each of the listed alternatives requires greater EPA resources than the DOE option. These
resources would be needed by headquarters in the preparation of rulemaking packages
necessary for exemptions, and by the various Regions for oversight permitting and variance
processing. Given that each facility is already involved in the RCRA permitting process
for mixed low-level and/or hazardous waste, the additional resources for any of the
options will be less than would otherwise be required.
The burden-of-proof shifts from EPA to DOE under Alternative 5. In the granting of any
exemption, the Agency must make the determination that such an exemption is warranted and
justify that decision. Under Alternative 5. justification for a variance must be made by
the permit applicant (DOE).
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Many of the processes that the DOE proposes for the treatment, storage, and disposal of
HLW and TRU waste are in the construction or planning stages. Subjectd TRU
processing plants, for example).
There have been past problems regarding the handling of classified TRU waste information
and unclassified controlled nuclear information. The exemption of HLW and TRU waste from
RCRA would most likely circumvent these barriers. However, if all HLW and TRU waste
management were subject to the RCRA permitting process, it would be highly desirable for
EPA and DOE to jointly develop procedures protective of both national security and the
environment.
The final issue is the role of RCRA-authorized states under the DOE option and the
alternatives. The DOE option does not provide a role for RCRA-authorized state programs,
and EPA, of course, has no control over whether States choose to regulate substances
independent of RCRA. States may elect to implement a more stringent program. Any of the
five alternative strategies discussed above could be implemented either by the authorized
State or by EPA, as appropriate.
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6.0 BIBLIOGRAPHY
6.1 DOE BRIEFING DOCUMENTS
• Management of "Transuranic and High-Level Radioactive Waste"
• High Level Radioactive Waste Program - Compliance: Goal; Sources; Integrated
System; Repository; Regulations; Containment; Objectives; Storage;
Transportation.
• DOE/EPA/DOJ 11/21/86 Meeting on Option to the By-product Rule.
• Legal Issues of DOE Option to the Byproduct Rule.
EPA/MEWS BRIEFINGS
• Management of High-Level and Transuranic Radioactive Waste at DOE Facilities.
Briefing for Dr. J. Winston Porter. December 17. 1986.
• Management of High-Level and Transuranic Radioactive Waste at DOE Facilities.
Briefing for Lee M. Thomas. Administrator. USEPA. February 20. 1987.
MISCELLANEOUS
• State Authorization to Regulate Hazardous Components of Radioactive Mixed
Wastes. Oct. 20. 1986:
From: J. Winston Porter To: Waste Management Division Directors.
• Memo: DOE/DOD meetings with the OUST, from Bill Kline. Environmental
Scientist, to John P. Lehman. Director. Waste Management Division. February
4. 1987.
• Capsule Review of DOE Research and Development and Field Facilities by DOE.
September, 1986.
HANFORD SITE
• Hanford Underground Radioactive Waste Storage Tank Management. April 22,
1986.
• Hanford Defense Waste Environmental Impact Statement, Presentation to
Environmental Protection Agency by J.D. White. Director.
• Background Information-Technical: Scope of Efforts; Preparation for
Burial-Part I; Preparation for Burial-Part II; RCRA Constituents in Reactor
Compartment-Lead; RCRA Constituents in Reactor Compartment-
Other Elements; Environmental Analysis-Background: Environmental
Analysis-Background; Environmental Analysis-Technical Details.
• Grout Disposal Program, General Overview. 12/12/86 by T.B. Bergman. Grout
Systems Group. Agenda - General Grout Overview; Major Technology Development
Activities. Waste Characterization, Grout Formulation Development.
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• Hanford Production Operations, Fuel and Reactor Operations.
• DOE Management of High-Level and Transuranic Waste Provides Environmental
Protection Equivalent to RCRA. December. 1986.
• TRU Waste - Provide Total Volume and Curies Currently Stored and the Annual
Generation Rate for Remote Handled, Classified Contact-Handled.
0 An Explanation of Packaging Requirements (for) Liquid TRU Waste.
• Rockwell Implementation Criteria Describing How Off Normal Events are
Classified as UOs. Off Normal Events, etc.
• Explain Grout Leachability - What Does Performance Assessment Say About
Leachability?
• Technical Rationale for Groundwater Monitoring.
• DOE - RL Orders on Appraisals.
• DOE - RL Orders on Unusual Occurrence Reporting.
t Facilities to be Covered by an Exemption.
• Leak Detection on Transfer Lines.
• Amount of Transfer Piping that is Pipe-in-Pipe vs. Pipe-in-Encasement.
• Analysis of Discharges to Ponds and Ditches - What is Routinely Analyzed for?
What Special Analyses Have Been Performed?
• Diagram Showing Ground Water With Location Relative to TRU and Active HLW
Facilities.
• HDW - EIS Summary.
• Diagram Showing Types and Locations of TRU Trenches/Storage Facilities.
• Percent of HLW That Will Go To Glass vs Percent To Grout (Double-Shell Tank
Waste Only) and Description of the Characteristics of Each Waste Type.
• Implementation Plan for Hanford Site Compliance to DOE Order 5820.2,
Radioactive Waste Management. Richland Operations Office, September 4, 1986.
• Draft Interim Hanford Waste Management Technology Plan. September 1986.
Richland Operations Office.
• Draft Interim Hanford Waste Management Plan. September 1986. Richland
Operations Office.
• Environmental Monitoring at Hanford. 1985, Battelle Richland.
6-2
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• Results of the Separations Area Ground-Water Monitoring Network for 1985. Law
and Schatz.
IDAHO NATIONAL ENGINEERING LABORATORY (INEL)
• Summaries of Idaho National Engineering Laboratory Radioecology and Ecology
Program's Waste Management Related Studies, October, 1985 by Idaho National
Engineering Laboratory, DOE.
• Idaho Chemical Processing Plant.
• INEL Site Environmental Monitoring Data for the Second Quarter. 1986.
• ICPP Activities.
• Overview of INEL Waste Management Program, December 10. 1986 by Jim Solecki.
• Transuranic Waste Management at the Idaho National Engineering Laboratory,
December 10. 1986.
• Idaho National Engineering Laboratory by INEL.
• Waste Management Programs at EG & G Idaho. An Overview by DOE.
• N & IS Technical Evaluation Group - Hierarchy of Documents; Assessments of FY
86; Scope.
• Analysis of Water from Selected Sites at or near INEL.
• Management of "Transuranic and High-Level Radioactive Waste".
• Operational Safety - Policy; Organization; Responsibilities; Functions;
Staffing; Contractor Program; NEPA Reviews; NEPA Compliance.
LAWRENCE L1VERMORE NATIONAL LABORATORY (LLNL)
• Agenda, EPA/DOE Technical Working Group on HLW and TRU Waste. January 15,
1987.
• Plant and Technical Services Directorate; Funds. Staffing; Expenditures;
Locations.
• LLNL TRU Waste Certification Organization Chart.
• TRU Waste Audit Closeout. Type A Container Certification; Materials
Management.
• Hazardous Waste Management/TRU Waste Management Responsibilities:
Procurement; Inspection and Control; Preparation for Transport and Disposal;
Inspection Checklists.
• Overview, Hazardous Waste Management Section, from C. Susi Jackson, Section
Leader.
6-3
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• Lawrence Livermore National Laboratory Transuranic Waste Certification
Program by Irene M. Meisel.
• Lawrence Livermore National Laboratory (LLNL) Hazardous Mixed TRU Wastes.
Presented to the DOE/EPA Technical Working Group, January 15, 1987. presented
by Irene M. Meisel.
• Lawrence Livermore National Laboratory TRU Data Collection. Presented to the
Waste Acceptance Criteria Certification Committee, January 13, 1987, by Irene
M. Meisel.
LOS ALAMOS NATIONAL LABORATORY (LANL)
• Los Alamos National Laboratory; Organization; Overview FY 86; Mission Goals;
Staffing.
• The Los Alamos Controlled Air Incinerator for Radioactive Waste. Volume I:
Rationale, Process, Equipment. Performance, and Recommendations.
August, 1982.
• The Los Alamos Controlled Air Incinerator for Radioactive Waste, Volume II:
Engineering Design Reference Manual, October, 1982.
• Health and Safety Manual. Administrative Requirements, August, 1984. Section
9. Environmental Protection.
• Health and Safety Manual. Administrative Requirements, August. 1984. Section
10. Waste Management.
• Health and Safety Manual. Administrative Requirement 10-2. Radioactive Solid
Waste.
• Environmental Surveillance at Los Alamos During 1985 by LANL. April, 1986.
• Final TRU Waste Inventory Work-Off Plan by LANL, August. 1986.
• Los Alamos Waste Volumes; Sources; Waste Forms; The Laboratory Manual -
Health and Safety.
• Liquid Radioactive Waste Management; Collection System; Treatment Facility.
• Health. Safety and Environment - Objective; Council; Manual; Mission;
Division.
• Los Alamos Phase I Status and Report; Phase 2A Status; Phase 2B Status;
Schedule.
• National Environmental Policy Act of 1969; TRU Work-Off Plan.
• Environmental Permits Under Which Laboratory Operates; Permit NM0028355;
Compliance Agreement Schedule: Interactions Between Laboratory and Regulatory
Agencies: Part B Permit Application Calendar.
6-4
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• Environmental Transuranic Monitoring at Los Alamos: Number of Stations;
Number of Samples Collected in 1985: Buried and Special-Case Waste
Implementation Plan.
• Comprehensive Environmental Assessment and Response Program by LANL.
• Laboratory Environmental Compliance Management Committee; Organization Chart;
Background. Purpose and Objectives: Compliance; FY 87 Budget Issues;
Environmental Projects.
• LANL Information Packet and Brochures. Contents - 1943-1945 The Beginning of
An Era; Organizational Profile; Welcome to Los Alamos: LANL A Profile;
Agenda; DOE/EPA Interagency Team Review, January 13, 1987.
• DOE Summary.
NEVADA TEST SITE (NTS)
• HQ, DOE/EPA Transuranic Visit to Nevada Test Site. January 14, 1987.
• Greater Confinement Disposal Test at the Nevada Test Site by Reynolds
Electrical & Engineering, June, 1983.
• Monitoring of Heat and Moisture Migration From Low-Level Radioactive Waste at
the Nevada Test Site by Reynolds Electrical and Engineering and DOE.
• DOE Summary.
OAK RIDGE NATIONAL LABORATORY (ORNL)
• Agenda, January 21. 1987. EPA/DOE Site Visit.
• RCRA Compliance Strategy and Status at ORNL, January 21. 1987.
• Waste Examination and Certification. January 21, 1987.
• Independent Review and Oversight of Transuranic Waste Management Operations
at ORNL, January 21. 1987.
t TRU Waste System Description. January 21. 1987.
• DOE Summary.
ROCKY FLATS PLANT (RFP)
• Agenda. Rocky Flats Plant, December 9, 1986. Information on the Plant
provided by Rockwell.
• Briefing for EPA/DOE Technical Working Group on High Level and Transuranic
Waste, Rocky Flats Plant. December 9. 1986 by John Whitsett.
• Monthly Environmental Monitoring Report, September, 1986.
6-5
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• Colorado Department of Health Environmental Surveillance Report on the U.S.
DOE Rocky Flats Plant, Monthly Information Exchange Meeting, September, 1986.
• City of Broomfield Radiometric Monitoring Report. Monthly Information
Exchange Meeting. October 28. 1986.
• Agenda, DOE-State Exchange of Information Meeting, October 12. 1986.
• Audit of TRU Waste Certification Activities at Rocky Flats Plant, Golden, CO,
September 29 - October 3, 1986 by J.F. Bresson.
• Rocky Flats TRU Waste Certification and Transportation Documents, in a 3-ring
binder, dated December 17, 1986 with a cover memo from Allan Corson to Jack
Lehman. Subject: Equivalency of DOE's Transportation System to RCRA's
System.
SAVANNAH RIVER PLANT (SRP)
• Draft. MEWS Informational Needs at DOE's SRP Facility Visit, 11/86 and letter
to Ray Berube. DOE from John Lehman.
• Agenda, EPA Tour. High Level-Waste and Transuranic Waste, 12/2-3/86, Orange
Room.
• Underground Storage Tank Regulations & DOE Radioactive Material Tanks, April
22. 1986 by DOE. Outline - Inventory of Tanks; High Level Radioactive Waste
Tanks; Application of API Type Regulations; Notification Plans.
• DOE Savannah River Defense Waste Processing Facility Project Status for the
EPA. Presentation by Wm. Brumley, December 2, 1986.
• SRP TRU Waste Certification Program by Kim Wierzbicki, December 3. 1986.
• Determining the Composition of SRP Waste by P.D. d'Entremont, December 3,
1986.
• Tank Farm Operations. December 3, 1986 - High Level Radioactive Waste
Management Program Mission.
• Interim Radioactive Waste Management - Receive and Store High Level Waste in
Tanks; Reduce High Level Waste Volume by Evaporation; Remove Older Tanks from
Service; Provide Feed for the Defense Waste Processing Facility.
• SRP Site Descriptions. Maps.
• Containment and Leak Detection by Neil Davis.
• SRP Waste Management Program by L.C. Goidell.
WEST VALLEY DEMONSTRATION PROJECT (WVDP)
• Agenda - EPA/DOE By-product Rule Task Force, January 8, 1987.
* An Introduction to the West Valley Demonstration project by DOE. July, 1981.
6-6
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• West Valley Demonstration project. Project Overview, presented to the EPA/DOE
Byproduct Rule Task Force, January 8, 1987, presented by Dr. W.W. Bixby.
• External Interface Control Diagram.
• WVDP Decontamination Activity.
• RTS Waste Stream Data Sheets, Rev. 4, dated March, 1986, From: LWTS Design.
WASTE ISOLATION PILOT PLANT (WIPP)
• Presentation Materials, December 8, 1987.
• Certification Criteria.
• Environmental Activities.
• Sandia Technology Report.
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7.0 ACKNOWLEDGEMENTS
MEWS TASK FORCE MEMBERS
Office of Solid Waste and Emergency Response:
John P. Lehman, MEWS Task Force Chairman
Lynn Pirozzoli
Office of Radiation Programs
Ray Clark
Office of Solid Waste
Betty Shackleford
Burnell Vincent
Office of Waste Programs Enforcement
Tony Baney
Anna Duncan
Region X
Danforth Bodien
Janet O'Hara
DOE HQ Staff
Environment. Safety and Health:
Raymond Berube
Kenneth Farher
Jane Williams-Ward
Defense Programs
Critz H. George
Jill Ellman Lylle
John C. Tseng
Office of Civilian Radioactive Waste Management
Jerry Salzman
COM Federal Programs Corporation Team Members
Jonathan G. Curtis
Jay Davis
Mary H. Ferreira
Gina M. Giles
Brenda F. Overman
Johnny L. Palmer (C.C. Johnson & Malhotra P.C.)
Jacqueline M. Rams
Elizabeth A. Richert
Patrick T. Schaffner
Alexandra Silvernale 7-1
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APPENDIX A
FACILITY REPORTS
-------
Mixed Energy Waste Study (MEWS) Visit
U. S. Department of Energy (DOE)
Han ford Site
Richland, Washington
December 11-12, 1986
PURPOSE:
On December 11-12. 1986. the MEWS task force and EPA Region X representatives met at
Richland. Washington, with individuals frcm the Department of Energy's (DOE) Headquarters.
DOE's Richland Operations Office, other DOE field offices and the Hanford contractors. A
representative from the Washington State Department of Ecology attended the initial
briefings in Richland. The purpose of the meeting was for task force members to gain a
working knowledge about methods for treatment, storage and disposal of high level wastes
(HLW) and transuranic (TRU) wastes at DOE's Hanford site (see Section J Appendices).
SUMMARY:
DOE's Richland Operations Office and its Hanford contractors provided an overview briefing
of the site with the majority of emphasis on HLW and TRU waste management practices.
Subject areas included environmental monitoring, double-shell tank construction, operation
and control. TRU waste storage, event reporting, and the audit system. Also, at the task
force's request, additional briefings related to the deep geologic repository and the
grout system were provided. A bus tour of the 200-East and 200-West areas was provided
with special tours of the control systems for the tank farms and the computer-automated
surveillance system. The tour also included the nuclear submarine compartment disposal
area. The briefings and tour provided the task force with a good understanding of the
waste management systems.
In general, the current management systems at Hanford for HLW and TRU wastes from both an
administrative and technical standpoint are advanced and comprehensive with many areas
being apparently equal or superior to those required by RCRA. Specific weaknesses include
the lack of detailed analyses of wastes for hazardous chemicals, the lack of ground-water
A-l
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monitoring, and the lack of an independent outside audit. While the ultimate disposal
methods for HLW and TRU wastes appear excellent, they are not yet in place and, in the
case of the HLW, are not yet a certainty.
REPORT:
A. FACILITY DESCRIPTION:
The Hanford site is a 570-square mile DOE reservation located in remote south-central
Washington state on the Columbia River. The elevation of the Hanford site is about 600
feet above MSL and approximately 200 to 300 feet above the ground water. The average
annual precipitation is less than seven inches. Hanford's primary missions include the
production of plutonium for nuclear weapons and advanced reactor development which began
in 1943. Figure I details the facility's history.
During the I940's, Hanford originally consisted of three reactors and three related
chemical separation facilities. Since that time, six additional reactors have been built
including the dual-purpose N reactor which is currently the only operating production
reactor on the reservation. Hanford has a current operating budget of one billion dollars
and some 14,400 employees. Eight major contractors presently operate the facility. The
ones pertaining to HLW/TRU wastes are listed below:
Rockwell - Chemical Processing (PUREX Plant, B-Plant, PFP.
etc.). Waste Management and Support Services
United Nuclear - Operation of the N reactor
Westinghouse - Operation of the fast flux test facility (FFTF)
Battelle Pacific Northwest Laboratory - Research and
Monitoring
On December 12, DOE announced that a new five year contract had been awarded to
Westinghouse/Boeing which will incorporate all operations presently run by Rockwell,
United Nuclear, Westinghouse, and Boeing.
A-2
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FIGURE 1
HANFORD HISTORY
1943 - 1945
The Beginning
• Acquisition ol • 450,000 acre tile
• Construction oi 3 reactors and related
production and waste management facilities
• Production ol plulonium to help end World
War II
• Pioneering work in nuclear technology
1964 - 1972
Crisis and Recovery
• Declining onsile employment
• Adverse Impact on the community
• Segmentation and diversification
* FFTF siting at Hanford
• Defense watte problems
1947 - 1963
Hanford Expansion
• Construction ol 5 additional once-through
reactors and related production and waste
management facilities
• Construction ol dual-purpose N Reactor
• Expanded production of materials for national
defense
1973 - Present
Recovery, Transitions, Improvement*
• Restoration ol defense mission
• Upgraded management ol defense wastes
• Construction of the FFTF
• Changes In cognizant agency
• Public Involvement
• Non-Federal activities on site
(Supply System. US Ecology)
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Two major non-Federal activities are located on the reservation. These include a
low-level commercial waste disposal site run by U.S. Ecology and one commercial nuclear
power plant plus an electric generation facility connected to the N reactor, both run by
the Washington Public Power Supply System.
All waste management with respect to HLW and TRU waste is located in the 200-area which is
subdivided into the 200-East and 200-West areas. The 200-area is located near the center
of the Hanford site, approximately seven miles from the Columbia River (Figure 2).
B. HIGH LEVEL WASTE:
I. Generation
The majority of HLW at Hanford is presently generated in the PUREX (Plutonium Uranium
Extraction) facility. In the PUREX facility, the irradiated fuel from the N reactor is
declad and then dissolved with acid so that the plutonium can be separated out. The
resultant waste acid stream contains the majority of the fission products. While the
volume of the corrosive and radioactive components of the wastes are generally well known.
few data exists regarding their hazardous chemical composition. Other liquid wastes,
which are not dischargable to the environment, are also placed in the HLW tanks and
managed as HLW.
2. Waste Management
HLW generated in the PUREX facility is treated with a caustic to a pH in excess of 12 and
routed through a double-lined pipe system to underground double-shell tanks. The
double-lined pipes consist mainly of pipe-in-pipe; however, some pipe-in-concrefe
encasements are utilized.
The piping system is laid out such that transfers can be made to and from any tank for
treatment process. Any liquid escaping from the primary pipe flows by gravity to a
collection tank or diversion box; from there it can be pumped back into the system. The
waste is first sent to "aging tanks" where the short-lived fission products decay, wastes
cool and sludge is allowed to settle. Such sludge contains the majority of the fission
products. The HLW supernatant is reduced in volume through evaporation and the evaporator
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FIGURE 2
DOEs HANFORD SITE IN WASHINGTON STATE
Hanford
Site
Boundary
300 Area
Exxon Nuclear
Miles
048
0 6 12
Kilometers
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bottoms are returned to the double-shelled tanks. The condensate is presently being
disposed of in cribs (leaching fields) as a low-level waste. Supernatant from the older
single-shell tanks is sent to the B-plant where the cesium (Cs-137) and strontium (Sr-90)
were removed through an ion exchange process. This process was initiated in the mid
I960's to remove the dominant heat and radiation source from the waste. The cesium and
strontium were doubly encased in stainless steel and stored in a water bath at the B-plant
or shipped off site for use. In the future. HLW will be processed in the B-plant to
prepare the waste for immobilization in the planned vitrificiation facility.
3. Storage
Nationwide. Hanford has 62.3 percent of the volume of HLW in storage
(2 x 10 cubic meters) which contains 35.1 percent of the radioactivity (474 megacuries;
Figure 3). Prior to 1970. HLW was stored in single-shelled carbon steel tanks. Hanford
has 149 of these tanks. Between 1960 and 1970, many of these tanks were leaking. As a
result of double-shelled tanks were built and all pumpable liquid was removed from the
single-shelled tanks leaving only sludge, salt, and some interstitial liquid. Since 1970,
HLW has been stored in the double-shelled carbon steel tanks. There are presently 28 of
these at Hanford. Each tank can hold one million gallons of waste (Figure 4). Eight
additional tanks-are presently in the planning stage. While all currently generated HLW
at Hanford is stored in double-shelled tanks, not all of the wastes in the 28
double-shelled tanks are by definition HLW. The following is a list of stored wastes:
Complexed concentrate from Cs-i37 and Sr-90 removal systems
Double-shell slurry (mixtures of all types of past waste streams)
Cladding removal waste from PUREX plant
Facility waste (solvents, caustics, bases, metals )
PUREX first-cycle extraction waste
Plutonium Finishing Plant Waste (TRU waste)
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FIGURE 3
TOTAL HIGH LEVEL WASTE
(NOT SPENT FUEL)
VOLUMES OFHLW
RADIOACTIVITY OF HLW
HANFORD
623%
2 x 10s m3
SAVANNAH RIVER
340%
1.1 x 105m3
IDAHO
3.0%
9.7 x 103 m3
COMMERCIAL
07%
23 x 103 m3
HANFORD
35 1%
475 Met
SAVANNAH RIVER
57.5%
780 MCI
IDAHO
4.8%
65MCI
COMMERCIAL
2.6%
35 MCI
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FIGURE 4
DOUBLE SHELL TANKS
>
oo
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DOE is proposing that ail waste in the 28 double-shelled tanks be included in the proposed
option since it will be managed as HLW.
4. Control
Both technical and administrative controls exist at Hanford with regard to HLW. All
double-walled pipelines have leak detection systems consisting of encasement alarms,
diversion box alarms, material balance discrepancies, radiation monitoring above grade.
and periodic swabbing of encasements. Tanks are controlled or monitored through tank
liquid levels, annulus air monitoring, annulus liquid level, and/or leak detection pit
monitoring for liquids and air. Hanford employs a computer automated surveillance system
(CASS) which makes 5.700 readings/day. All monitoring (other than liquid levels) is for
radioactive components in air.
Hanford also has an elaborate process control system where valves, pumps, tank levels, and
other items can be monitored from a central area. The system also employs interlocks and
fail-safe systems (e.g.. shutdown for power failure). Administrative controls involve
extensive documentation on material balances, tank inventories, and treatment and tank
transfers. Hanford officials indicated that the tank level monitors would provide a first
indication of a loss, with readings to the nearest one-half inch amounting to a volume of
approximately 1.350 gallons.
Unlike the Savannah River Plant (SRP). annulus monitoring with photography is not utilized
at Hanford.
5. Disposal
Plans for the disposal of HLW at Hanford parallel those at the SRP. Sludges from the
double-shelled tanks will be reslurried and sent to a vitrification facility where the
waste would be mixed with a technically controlled boron silica frit, vitrified, poured
into a steel cylinder which would be sealed, and then decontaminated before shipment and
disposal in a deep geological repository (Figure 5). Unlike the SRP, the Hanford
vitrification facility is only in the planning stages and is projected to be completed by
the mid-1990's. The majority of the wastes (supernatant and salt cake) in the HLW tanks
contain small quantities of carbon (C-14). iodine (1-129). and other residual
A-9
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FIGURE 5
CONCEPTUAL DESIGN CUTAWAY
NUCLEAR WASTE GEOLOGIC REPOSITORY
DISPOSAL CONTAINER
RECEIVING STATION
I
•—
o
WASTE
ENTRY
SHAFT
WASTE TRANSPORT
FROM HOPPERS
ROCK REMOVAL CONVEYOR
SKIP SHAFT
-------
radionuclides. These would be classified as low-level waste (LLW) and would be mixed with
cement, clay, and fly ash to form a grout that will be disposed of near the surface on the
Hanford site. Thus, the grout system will treat the LLW and the vitrification process
will eventually treat the HLW. Present plans call for a portion of the N reactor plant's
LLW to be treated in the grout system starting March 1988 and the double-shell slurry
waste starting in December 1989.
C. TRU WASTES:
I. Generation
TRU wastes at Hanford are mainly generated at the PUREX plant, the plutonium finishing
plant (PFP), the FFTF, and the Battelle Laboratory. To date, approximately 525.000 cubic
feet of TRU waste, including 804 cubic feet of remote-handled TRU, has been placed at
Hanford in retrievable storage. Hanford also has a small quantity of classified TRU waste
in retrievable storage. The rate of generation of TRU waste at Hanford is approximately
12.000 cubic feet per year. Virtually no information is available about the quantity or
characterization of stored TRU waste containing hazardous chemicals.
2. Waste Management
The waste management system for the handling of TRU waste at Hanford is similiar to that
for other DOE facilities. To date, only the facilities run by Rockwell which generate the
most TRU waste at Hanford have completed the steps necessary to certify TRU waste for the
Waste Isolation Pilot Plant (WIPP). The remaining producers of TRU (Westinghouse and
Battelle) are moving toward the same status.
Similar to the INEL processing experimental pilot plant (PREPP), Hanford is developing a
plan for a WRAP (waste receiving and processing facility) which would process TRU waste as
required for certification. After processing and certification, the TRU waste will be
sent to the WIPP for disposal.
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3. Storage
Prior to 1970, ali TRU waste as well as LLW were disposed of in shallow land trenches at
Hanford. Since 1970. TRU waste has been segregated and placed in retrievable storage. To
date, none of the buried TRU waste has been certified for the WIPP. The retrievable
storage at Hanford (euphemistically labeled "Hanford Burial Garden") consists of placing
the waste in 55-gallon steel drums or steel boxes on an asphalt pad or plywood foundation
below grade. Plywood and plastic are placed over the drums which are then covered with
four feet of earth. Plastic standpipes are placed down into the storage modules to allow
for gas sampling.
4. Disposal
Disposal of all certified TRU Waste will be at the WIPP, which is scheduled to start
receiving waste in October 1988.
D. MONITORING:
All site monitoring at Hanford is performed by Battelle Pacific Northwest Laboratories.
This includes air, surface and ground-water monitoring. A tota!~of 339 ground-water
monitoring wells are located on site; most monitor for radionuclides. Recently, some 90
wells have been used for hazardous chemical characterization, although these wells were
not installed as per RCRA requirements (Figure 6).
Environmental monitoring in the separations area (200 area) is performed by Rockwell.
This includes air, soil and biota, surface water and ground-water monitoring. A total of
131 ground-water monitoring wells are sampled (Figure 7). As with the site monitoring,
analysis has been primarily for radionuclides. Water table measurements are also made for
the purpose of ground-water mapping.
To dale no specific program has been instituted at Hanford for the monitoring of ground
water in the vicinity of the retrievable TRU waste storage.
A-12
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FIGURE 6
LOCATIONS OF HAZARDOUS CHEMICAL CHARACTERIZATION WELLS
A-13
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FIGURE 7
LOCATIONS OF GROUND WATER MONITORING WELLS SAMPLED
w€STLAKE
BC CONTROL
AREA
PREPARED IN 19U6
-------
E. AUDITS/ASSESSMENTS/OVERVIEW:
Hanford operates under the standard DOE management system, DOE headquarters issues orders
which are then interpreted and narrowed in scope by the Richland Operations Office to meet
site-specific conditions. This process continues down to the procedures written by the
contractor for the plant operators to follow. Audits are performed by all of the
organizations under their jurisdiction. There are, however, no independent outside audits
conducted.
F. SECURITY:
Security for the 200 area is maintained 24-hours per day by armed guards and tactical
response teams. Security is especially heavy around the plutonium handling facilities.
G. SUBMARINE REACTOR COMPARTMENT DISPOSAL:
Hanford has been chosen as the disposal site for decommissioned reactor compartments from
nuclear submarines. These compartments are approximately 30-35 feet in diameter, 30-38
feet in length and weigh approximately 1,000 tons. The compartments contain no spent
fuels or TRU waste but pose a potential radiation hazard due to activation products,
mainly cobalt (Co-60). The compartments also contain approximately 250-350 tons of lead.
The disposal site is located in the 200 East area and consists of an excavation which is
approximately one acre in area and will accommodate about 12 compartments. At the present
time, one unit has been placed at the site. When all 12 compartments have been pfaced,
the site will be backfilled. No ground-water monitoring is planned after burial of the
units.
H. RCRA EQUIVALENCY:
While a point-by-point comparison of waste management practices at Hanford with those
required by RCRA was not discussed, the areas where RCRA equivalency was provided include
the following:
• Excellent process control with regard to the treatment, transfer, and storage
of HLW. Includes computer-automated surveillance system.
• Extensive administrative controls for the tracking of waste from generation
through disposal for both HLW and TRU wastes.
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• Excellent conceptual plan for the final disposal of both TRU waste and HLW.
• Excellent security provided.
Areas where potential problems with RCRA equivalency include the following:
• Lack of or limited data on waste quantity and characterization with regard
to hazardous components.
• Lack of RCRA ground-water monitoring around buried TRU waste in retrievable
storage.
• Lack of RCRA ground-water monitoring around HLW piping and storage
(double-walled tanks) systems.
• Lack of independent audits.
• Disposal facility for HLW is not yet and may never be a reality.
I. ACTION ITEMS:
The following information was requested from the DOE:
• Analyses for heavy metals. pH and organics from all waste streams related to
high-level and TRU wastes.
• Percentage of ptpe-in-pipe and pipe-in-concrete encasement.
• Comparison of procedures for various DOE operation offices.
• Diagram of burial sites delineating what is in each trench
(classified waste. CH-TRU waste, etc.).
• Percentage of liquid in double-shelled tanks destined for grout
and percentage for deep geologic repository.
• Criteria for what is contained in an unusual occurrence (UO) report.
• Location of ground-water monitoring wells in vicinity of tanks,
processes, piping, etc. related to HLW and TRU waste.
• Map of site showing what tanks, pipes, treatment processes, etc. are
related to HLW and TRU waste.
• Listing of the contents of the double-shell tanks (including color coded
schedule).
J. APPENDICES:
1. Agenda; 12/10-12/12 Hanford Tour (Modified)
2. Welcome/Hanford Overview
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3. Hanford HLW and TRU Waste Management Overview
4. Disposal of Hanford Defense Wastes - Draft EIS Summary
5. Environmental Monitoring (Hanford Site)
6. Environmental Monitoring (Separations Area)
7. Double-Shell Tank Waste With Emphasis on: Facilities Description and Waste
Transfer Operations
8. Double-Shell Tank Waste With Emphasis on: Management Control
9. TRU Storage Operations
10. Double-Shell Tank Sampling
11. Event Management
12. Grout Disposal Program
13. Waste Minimization
14. Audit System - Rockwell Program
15. Audit System - DOE-RL/WMPO
16. Audit System - DOE-RL SQA
K. DISTRIBUTION:
MEWS Task Force Distribution List
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Mixed Energy Waste Study (MEWS) Visit
U.S. Department of Energy (DOE)
Idaho National Engineering Laboratory
Idaho Falls, Idaho
)ecember 10, 1986
PURPOSE:
On December 10. 1986. the MEWS task force met with individuals from the Department of
Energy's (DOE) headquarters, the Idaho National Engineering Laboratory (INEL), several
employees of Westinghouse and EG&G, and contractors operating the facilities at INEL which
were of interest to the task force. The purpose of the meeting was for task force members
to understand INEL's methods for treatment, storage, and disposal of high level (HLW) and
transuranic (TRU) mixed wastes.
SUMMARY:
DOE's Idaho Operations office provided a brief overview of the mission and the
waste-handling operations at INEL. As described in the body of this report, the task
force focused on rwo operations of this large, complex facility: (I) the HLW management
associated with enriched uranium recovery from spent naval reactor fuel and (2) the TRU
waste management services provided for many DOE facilities located around the country.
Tours of the facilities and detailed presentations of the operations were provided by
Westinghouse for HLW and by EG&G for TRU wastes.
While the HLW and TRU waste management areas differ, they do share several beneficial
characteristics including:
• highly automated, fully computerized process-control capabilities.
• self-auditing for contractors and DOE's auditing procedures which provide a
"paper trail", also available for audit.
• handling procedures for current waste streams provide some protection
against release of hazardous constituents to the environment.
• greatly improved current operations compared with past practices.
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In addition, they also share the following disadvantages:
• chemical characterization of waste streams is not well detailed.
• ground-water monitoring systems fail two important RCRA criteria in that they
do not assure defection of the first emission from any source and they will
not confirm the absence of RCRA hazardous constituents.
REPORT:
A. FACILITY DESCRIPTION:
The Idaho Operations office is responsible for a wide variety of operations at the Idaho
National Engineering Laboratory near Idaho Falls. The facility, covering 890 square miles
of sagebrush desert, was established in 1949 as a reactor testing station. INEL includes
thirteen nuclear reactors and many research and production facilities; the site has nine
program operating areas with a total operating budget of about $500 to $600 million per
year.
Annual precipitation is very low (8.5 inches per year or less) and the temperature varies
widely (between -47° and 103"). Highly porous and fractured basalt rock underlies
relatively shallow soil. The regional ground-water system is the Snake River Plain
aquifer. Its depth exceeds one billion acre feet of water and is among the fastest
flowing ground water in the nation. It flows through fractured basalt with average
velocities exceeding 100 to 200 feet per year. This aquifer lies beneath approximately
200 feet of intermittent beds of basalt and sandy silt/gravelly sand. This overburden
contains intermittent areas of perched ground water; this is the "uppermost aquifers" of
concern in the RCRA ground water monitorial regulations. The depth to this uppermost
aquifer is typically 20 to 40 feet and it is clearly interconnected with the regional
system.
Among the multiple facilities and contractors operating at INEL. the task force focused
predominately on the waste management operations under EG&G-Idaho and the Idaho Chemical
Processing Plant (ICPP) operated by the Westinghouse Idaho Company. The former has been
set up to manage TRU wastes from several DOE facilities including Rocky Flats. Mound.
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Bettis, and others around the country. The facility is effectively a transfer station
receiving, examining, processing as necessary, and repackaging TRU wastes for eventual
shipment to the Waste Isolation Pilot Plant (WIPP) near Carlsbad, New Mexico. The ICPP
receives and processes spent fuel from the Navy for recovery of enriched uranium,
generating HLW as a by-product.
B. OVERVIEW OF WASTE MANAGEMENT OPERATIONS:
I. High Level Wastes
The ICPP began reprocessing spent fuel in 1953, mostly from naval sources. The major
objective of the plant is to recover highly enriched uranium and krypton. Plant capacity
is 16 kilograms of uranium per day.
After incoming spent fuel is removed from its DOT approved packaging, it is stored under
water. Six pools containing 3 million gallons of water have 2600 fuel positions for
temporary storage and handling.
The major waste-generating step in the ICPP is fluorinel dissolution of the zirconium
cladding from the spent fuel rods. A strong acid (hydrofluoric acid) is used in the
decladding process. Since stainless steel would corrode in less than two weeks under
these conditions, a special alloy (called Hastalloy) is used for process vessels and
piping. This step complexes the hydrofluoric acid, ties up the free available fluorine,
and produces a clear but highly acidic waste liquid which is then sent to tank farms.
The next step after decladding is fuel dissolution. Extraction of the uranium is
accomplished through use of an organic solvent. It produces a highly acidic waste. The
radioactivity of this waste is due mostly to fission products and trace amounts of
transuranics. This waste and the still bottoms from the "intermediate level" evaporation
facility are sent to the tank farm.
Interim liquid waste storage is provided in stainless steel tanks which are cased in
concrete. There are 11 of these tanks. 10 of which are used for storage and the other
held for emergency use. Each tank has a 300.000 gallon capacity.
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There has never been a leak discovered in the HLW storage tanks, although there have been
gasket failures in lines leading to and from tanks. In 1980, INEL began doubly encasing
all lines. The lines to the tank farm and to the calciner are currently double-walled
stainless steel, but there are still seven steel pipes which are encased in ceramic.
Final plans are now in draft for replacing five of these; use of the other two has been
discontinued.
The attached flow diagrams (Figures I and 2) describe the six waste handling activities at
ICPP:
1. fuel receipt and storage:
2. fuel dissolution, uranium recovery, and product de-nitration;
3. interim liquid waste storage;
4. waste solidification and decontamination;
5. off-gas treatment; and
6. liquid process waste calcination.
The liquid wastes from the fuel reprocessing and the intermediate level waste evaporation
are solidified in the New Waste Calcining Facility (NWCF). This facility began hot
(radioactive) operations in September. 1982. It has a 3.000 gallon per day capacity in a
highly automated, remote-handled, fluidized bed calcination process. All dissolution
wastes are sent from the liquid waste storage tanks to the fluidized beds. Some sodium
liquid wastes are also generated; because of difficulties in calcining sodium, this waste
is added in at a ratio of 1:4. This ratio is less with the fluoride wastes. Spent
solvents are used as an auxiliary heat source in the calcine plant.
The calcined waste, which is in granular form, is pneumatically piped to cylindrical
stainless steel storage bins set in a reinforced concrete silo. There are three to twelve
bins per silo and there are six silos currently in use: a seventh is under construction.
Each silo holds an average of 35,000 cubic feet of calcine. Several chemical parameters
are monitored for process control. These quality-control analyses are performed daily,
and all HLW is sampled for some chemical analyses prior to every transfer.
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FIGURE 1
IDAHO CHEMICAL PROCESSING PLANT (ICPPJ
Radloacllua Wistl
ManigmMt Comptex
NJ
NJ
Wul* SolldlllutiM
Cilclnid Solids
SUragt Fulllly
Liquid WMU
Ti»k»
Proem
Wute ^m Ptrcaiatlan Pond
Almotphiric Prottctian Syidn
/~7\ iir«6uPlinl
OllurlNEl
W«U
tCPP S-11296
LiboriUrlu 4 Pilot Plants
Olfilte Nutrdout
WuU Fulllly
-------
FIGURE 2
IDAHO CHEMICAL PROCESSING PLANT UCPP) PROCESS FLOW
>
M
Underwater
Storage
Fuel Element
Dissolver
Spent Fuel
From
Reactors
Waste
Calciner
Calcine
Storage
Bins
Uranium
•f Waste
Solvent
Extraction
Uranium
Liquid
Acidic
Waste y/V Uranium
*/ h Solid
Product
Denitrator
(Solidification)
Transport
Off-Site
Transport
-------
Currently, several options are under consideration for the final waste form including
continuation of the calcine production, incorporation of the calcine into glass or ceramic
logs, or discontinuing calcination and going directly to glass or ceramic logs.
The ICPP is supported by a remote analytical laboratory (RAL) which began operations this
year. Samples are shipped to the RAL via pneumatic messenger systems. The facility has a
large (20 X 50 foot) hot cell served by 17 master/slave manipulators. Because this
laboratory easily meets the radioactive exposure criteria for workers, many more chemical
analyses can be routinely conducted on the radioactive wastes.
2. Transuranic Waste Management
Transuranic radioactive waste generated in DOE defense and research programs is stored or
buried at the Radioactive Waste Management Complex (RWMC). a restricted area in the
southwest corner of the INEL. The RWMC began in 1952 as a 13 acre shallow burial disposal
site. Until 1970, TRU and low-level waste (LLW) were buried, without plans for retrieval,
using practices which do not meet RCRA standards. Since 1970. over 2.1 million cubic feet
of TRU wastes have been placed in above-ground retrievable storage. RWMC expanded to 144
acres in the 1970s and now separately manages both TRU and LLW.
The old, discontinued practices are not part of the DOE option and therefore were not
subject to task force review. The mixed LLW will continue to be subject to RCRA
regulations under DOE's option. Consequently, the LLW site was not included in the task
force visit.
INEL defines TRU waste as waste which is contaminated with transuranic radionuclides,
primarily alpha emitting elements, with an atomic number greater than 92. a half life
greater than 20 years, and a surface concentration (specific radioactivity) greater than
100 nanocuries/gram (nCi/g).
Very little of the TRU waste handled at RWMC is generated at INEL (less than I % by volume,
mostly by the Argonne National Laboratory.) In fact, 95% of the TRU wastes at INEL comes
from Rocky Flats. The mission of RWMC is to serve as a transfer, processing, and storage
facility for other DOE locations until the WIPP begins operations and to continue as a
transfer and processing center for the smaller generators thereafter.
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The bulk of the TRU waste is received in specially designed railroad cars and
tractor-trailers. Waste packages are tested against Department of Transportation (DOT)
standards. Access control, barriers, and surveillance features at the RWMC provide
excellent security. Incoming waste is inspected, assayed, evaluated against acceptance
criteria, and stored on asphalt pads for subsequent retrieval. The current operating area
of the storage pad is covered by an air support weather shield extending the life
expectancy of containers and permitting year round operation and TV surveillance. Until
recently, however, wastes were covered with earth on these pads. Buried wastes will
eventually be retrieved, assayed, certified, and stored for transfer to the WIPP.
High efficiency paniculate air (HEPA) filters are discarded at a rate of 300 per year.
Two hundred of these currently fail TRU waste acceptance criteria for percent fines. It
is anticipated that this will be corrected this calendar year.
RWMC currently contains a majority (68%) of all DOE-generated, retrievably stored TRU
waste. Wastes currently being received are stored in above ground buildings but
previously buried retrievable drums must be exhumed, evaluated, processed as necessary,
and placed in the above ground storage. There is neither sufficient processing nor
sufficient storage capacity to process these wastes now.
Approximately one percent of the TRU waste at INEL must be remotely handled because of
high contact dose rates (greater than 200 millirems/hour (mr/h), but less than 4500
rem/hour (r/h)). These wastes are placed in steel pipe vaults with sand, cement, and
grout protection; containerized wastes are placed in these vaults and covered with a plug
and vault cap.
The WIPP has established waste acceptance criteria (WAC) which all generators and shippers
of TRU waste must meet. All wastes currently received at the RWMC are tested against the
WAC prior to storage. Previously stored but unclassified wastes are retrieved for
evaluation and segregated storage. Waste evaluation determines whether a waste package is
free of explosives, free liquids, pyrophorics. compressed gases, excessive radioactivity.
excessive fines, and other undesirable constituents. These criteria are subject to
revision; recently, for instance, the free liquids limit at INEL was raised from zero to
one percent (about four cups per drum).
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The Stored Waste Examination Pilot Plant (SWEPP) has been in operation since 1985. Wastes
are currently being evaluated against the WIPP WAC at this facility. A second facility,
the Process Experimental Pilot Plant (PREPP) is under construction. It is scheduled to
begin processing wastes which fail WIPP WAC by 1991. At the SWEPP, containers are
certified as meeting DOT Type A criteria and size and handling limits. They are weighed
and measured against waste form requirements including particle size limits (less than one
percent by weight of particulates smaller than 10 microns; and 15 percent by weight less
than 200 microns) and liquid limits (one percent by volume, although 0.75 percent is the
operating target). Rocky Flats, the major generator of wastes handled at INEL. has begun
similar waste examination prior to shipment. Few discrepancies are found.
Wastes which fail the certification criteria are transferred from the SWEPP to the PREPP.
The PREPP process flow (Figure 3) includes shredding, rotary kiln incineration with
secondary combustion, particle size separation with fines going to grout mix. and coarse
materials being added to the grout product in certifiable containers for transfer back to
SWEPP.
The PREPP facility design should be capable of meeting RCRA performance standards,
operating requirements, and monitoring and inspection. The expectation is that the
facility will be used for both hazardous wastes and mixed wastes in the future. Unlike
the waste experimental reduction facility (WERF) which handles LLW. the PREPP incinerator
has wet off-gas handling capabilities. Some LLW may be treated at PREPP in the future.
The record keeping system for transportation, storage, and waste certification activities
appears to be substantially equivalent to RCRA. Internal review by DOE audits and quality
assurance programs provides a "paper trail" which can be made available to the public.
C. ENVIRONMENTAL MONITORING:
INEL maintains a general level of environmental monitoring at the TRU waste facility.
Area-wide air, biota, and radiation monitoring provide reasonable assurance against gross
emissions of radioactive material. Surface and ground-water monitoring, to a lesser
degree, establishes area-wide trends useful in gauging facility impact. Ground-water
monitoring programs are being upgraded, particularly with regard to the RCRA controlled
LLW disposal operations.
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FIGURE 3
PREPP PROCESS FLOW
Drums Boxes or bins
Secondary
combustion
chamber
To SWEPP
Rotary
kiln
incinerator
Coarse material
Shredder
Trommel
-------
The ground-water monitoring program is conducted by a staff of five from the U.S.
Geological Survey. The most intensely monitored area is around an infiltration pond or
seepage pit for chromate wastes. This impoundment was closed in 1964 and replaced by an
injection well which discharged directly into the regional aquifer for the next ten years.
The monitoring program has delineated several miles of contaminant plume.
Historically. INEL officials assumed that the nature of the waste handling operation at
the RWMC provided adequate assurance against ground-water contamination. Ground-water
monitoring has not focused on either the HLW or the TRU waste facilities. The
ground-water monitoring system for the site provides an overall indication of ground-water
quality. It is comprised of 24 deep wells sampling the regional aquifer with dedicated
pumps, and several dozen shallower wells with portable, submersible pumps. Ground-water
monitoring protocols in use at the facility are not in agreement with the EPA guidance
documents with regard to location, design, materials of construction, or other
specifications. DOE is working with EPA Region X under a RCRA technical agreement and is
submitting upgraded monitoring plans for the INEL.
Constant air monitors in the operational areas provide detection sensitivity at about 10
curies/cubic centimeters (Ci/cc), roughly equivalent to 15 parts/billion (ppb) of
Pu-239 oxide. Perimeter monitoring detection sensitivity is 10" Ci/cc, or 1.5 x 10
ppb of Pu-239 oxide. The RWMC TRU waste storage area, as well as the "intermediate level"
storage facility with TRU storage in vaults, is monitored for airborne plutonium
contaminants.
The buried TRU wastes placed prior to 1970 were not subject to task force inspection. The
current plans call for a 1995 removal/remediation date for these older SWMU/CERCLA wastes.
D. RCRA EQUIVALENCY:
1. Comparison of Existing Monitoring to RCRA Requirements
Current HLW and TRU waste management practices for newly generated wastes do not include
land disposal; all tanks, piping, and storage is double contained, inspectable. or
otherwise qualified for exemption from RCRA ground-water monitoring requirements. The
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older (pre-1970) disposal facilities will probably require monitoring under HSWA Section
3004(u). These requirements are unaffected by the DOE option since it does not address
LLW.
The retrievably buried 55-gallon drum pads look very much like landfills which would
require monitoring if TRU waste management were to be RCRA regulated. RWMC contends that
soil-gas monitoring for radioactive emissions in the backfill material and between drums
on the asphalt pads provides assurance of detection better than that possible by ground
water monitoring.
2. Waste Characterization. Handling
Materials handling procedures for HLW and TRU wastes are heavily documented. Upon
receiving TRU wastes and from the moment of generation of HLW, detailed operating
procedures require signatures of managers, technicians, and inspectors each time the
wastes are handled. These records are separately checked by DOE personnel and remain
available as part of the public record. INEL officials contend that the operation of the
RAL has greatly improved the waste analyses. The RAL will be capable of the abbreviated
Appendix IX analysis and will routinely characterize the waste stream.
3. Oversight
The detailed operating procedures require sign-off at vital points throughout the waste
handling system. Operators must sign their names, clearly indicating who did what and
when. The load list duplicate gives blanks for health physics technicians to record
notes. There are 140 check points throughout the waste receipt and storage area prior to
the SWEPP and the PREPP. While there is no routine oversight by any independent agency,
there are many internal levels of oversight and DOE officials contend that these data are
part of the public record.
The Idaho State air quality office recently regained primacy; otherwise, Idaho is not
authorized for either the Clean Water Act or for RCRA programs. INEL officials estimate
that CERCLA remedial action (probably under Section 3004(u)) will be required at about 350
sites at the INEL reservation. The tank farms have dry wells for radiation detection.
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although these were not shown to the task force. The calcine storage bins do not have
wells, but since they are double-walled, they would probably not be subject to RCRA
Subpart F. The task force did not see the organic solvent storage area although we
understand that it does contain some transuranic wastes,
E. ACTION ITEMS:
INEL promised to deliver the following:
1. Examples of RWMC waste tracking forms.
2. Hazardous constituent analyses lists, with typical results,
from the RAL.
3. Hard copy of the environmental monitoring presentation by
Marcy Williamson.
4. Report on analysis of constituents and subsequent interpretive
reports.
E. APPENDIX:
I. Waste Management Programs at EG&G. Idaho
2. Idaho National Engineering Laboratory, An Overview
3. Overview of INEL Waste Management Program
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Mixed Energy Waste Study (MEWS) Visit
U.S. Department of Energy (DOE)
Lawrence Livermore National Laboratories
Livermore, California
January 15. 1987
PURPOSE:
On January 15. 1987. the MEWS task force, accompanied by an EPA Region IX representative.
met with individuals from the Department of Energy (DOE) headquarters, from the Lawrence
Livermore National Laboratories (LLNL), from other DOE facilities and from the University
of California (the DOE contractor operating LLNL). The purpose of the meeting was for
task force members to observe llnl's methods for handling, treating, storing, and
transporting transuranic (TRU) wastes.
SUMMARY:
University of California officials presented an overview of the objectives and management
of the LLNL. There are no high-level wastes (HLW) generated or managed at LLNL. Areas
potentially affected by the DOE option include ihe Plutonium Facility (Building 332), the
Heavy Element Facility (Building 251), the HWM Decontamination Facility (Building 419),
and the Hazardous Waste Storage Area (Area 612). LLNL generates approximately 265 cubic
meters of TRU wastes annually in the forms of solidified liquids, boxed wastes, and
barreled miscellaneous trash.
Like Los Alamos (LANL) and other research laboratories, LLNL's wastes vary depending upon
what projects are currently underway. Unlike production facilities such as Idaho National
Engineering Laboratory (INEL) and Savannah River Plant (SRP), the LLNL TRU waste
generators are limited to a small number of personnel. This allows for individual
attention to generator training and performance to assure conformance with waste form
requirements, and eliminates the need for real-time-radiography (RTR) and the other
certification procedures necessary at the larger TRU waste generating facilities.
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Much of the presentation by LLNL officials was directed toward description of low-level
waste (LLW) management and some of the more widely known environmental problems which have
resulted from past practices. The LLNL officials claim that none of the past problems are
TRU waste related. Prior to the 1970s, TRU waste was ocean disposed and has subsequently
been shipped to the Nevada Test Site (NTS) or INEL. TRU waste generation and on-srte
movement is separate and distinct from LLW and hazardous waste until wastes are received
at Building 419 and Area 612. However, at those facilities, waste containers are stored
side-by-side with LLW. PCB's. waste oil. etc. These wastes are currently shipped to NTS.
Future plans are to transport directly to the Waste Isolation Pilot Plant (WIPP).
In general, based on LLNL's hand-out materials and presentations, the level of protection
afforded by current and proposed TRU waste management practices appear to equal or exceed
RCRA requirements for hazardous waste. Waste characterization, similar to the Task Force
findings at other facilities, is less than would be required under RCRA. Regardless of
the chemical components, the Task Force learned that waste destined for the WIPP would not
be handled differently. Since packaging and waste segregation are carefully managed, this
may only be a factor for classified wastes going to NTS for greater confinement disposal
(GCD),
REPORT:
A. FACILITY DESCRIPTION:
The LLNL was founded in 1952 by E.O. Lawrence and Edward Teller. It is one of two DOE
nuclear weapons development laboratories, established as a separate and, to some extent,
competing laboratory to Los Alamos (LANL). Their missions are similar, but they differ in
methods and technological approach. Both facilities are operated by the University of
California.
The LLNL mission is research and development on nuclear weapons, energy, and national
security problems. The operating budget. $800 million per year, is over one-third weapons
research. The next largest areas are isotope separation, laser, magnetic, and inertial
fusion, and biomedical environmental and energy research. Waste management funding is
typically carried as overhead rather than as a line item. Employment has intentionally
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been kept at about 7000-8000 people for the last ten years. When larger projects are
assigned, such as recent Strategic Defense Initiative work, the increase has been handled
by subcontracts rather than expansion.
The physical plant is located on two distinct properties. The main site at Livermore, an
old Naval Air Station, occupies a one-mile by one-mile square. A buffer zone has been
recently purchased, doubling the site size (and temporarily resolving a problem of
ground-water contamination migrating off-site). A ten square-mile satellite facility,
called Site 300. is located 15 miles east. It is a high explosives testing facility
(non-nuclear only). There are multiple hazardous waste management units on the Main Site
and Site 300 including more than 20 impoundments and 160 underground tanks.
Both the Main Site and Site 300 have extensive ground-water contamination, (mostly PCE,
TCE, and tritium), from past practices; the Main Site is listed on the proposed N.P.L.
They are located in two different counties (Alameda and San Joaquin, respectively), in two
different California Water Board districts, and are regulated by several layers of
Federal, State, and local agencies. Extensive ground-water assessments have begun on both
sites. One hundred fifty RCRA wells have recently been installed and early results are
showing excellent resolution and plume definition. Some interesting findings are emerging
from this program (e.g., they have data indicating that aliphatic hydrocarbons will form
the plume "front" in gasoline-contaminated ground-water). The monitoring program will be
peer reviewed, and articles will be submitted to several professional journals and
conferences.
Considerable remedial work will be required but so far Congress has eliminated each line
item from the LLNL budget dealing with cleanup of environmental problems. Site managers
interpreted this congressional message to suggest more detailed and better planned
efforts, but there was some disagreement with and discussion of this interpretation.
B. OVERVIEW OF WASTE MANAGEMENT OPERATIONS:
The DOE option will have relatively little impact at LLNL. There is no HLW and the total
amount of TRU wastes is equivalent to less than two weeks of waste produced by Rocky
Flats, the largest generator. No radioactive wastes have been disposed on site. The
facility is already actively involved with Federal, State, and local regulators for air
and water discharges. It has a large and active public information program in response to
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citizen opposition to past practices. The ongoing RCRA and CERCLA investigations are
large and visible. Generator and transporter liability and other RCRA paperwork will
continue almost unaffected by the DOE option.
Altogether LLNL generates 5.500 cubic meters of LLW, hazardous wastes, waste oils, PCB's,
and other "dangerous substances". About half of this volume is radioactive. Waste
treatment includes an incinerator rated to burn at 375-575 pounds per hour solids and 300
gallons per hour liquids. It burns both hazardous (non-halogenated) wastes and mixed LLW.
It has a 1800° combustion temperature and is capable of sufficient retention time to
destroy pathogens. It is located in Area 614 with the drum storage and the TRU waste
handling operation. Two RCRA interim status landfills are located on Site 300.
The operating budget for complying with environmental protection requirements is $11
million and involves a total staff of 100 people. They have requested $40 million for
construction of a new waste management facility and $60 million for clean-up operations,
but they are several months away from beginning the permit and public hearing process for
these new facilities. Meanwhile, the waste management yard functions primarily as a drum
staging area for a variety of waste forms. Wastes are stored in tanks, drums and boxes.
Drums are lined up in rows according to category. Housekeeping is apparently good, but
the task force noted some instances of labels being separated from containers. While
there was some disarray among the non-hazardous liquid waste containers in the staging
area for the incinerator feed, the TRU waste containers were segregated, permanently
labeled, and well organized.
1. HLW Management
No HLW is generated, received, or otherwise handled at LLNL.
2. TRU Waste Management
The LLNL generates 265 cubic meters of TRU wastes annually, constituting about 5% of the
total "dangerous substances". TRU wastes are typically low activity, low volume, but
highly variable (38 isotopes). TRU waste originates from two buildings: Building 332
(americium. and plutonium) generates 95% and Building 251 (berkelium. curium, americium,
neptunium, einsteinium, and others) generates 3% of the total TRU wastes. Liquids from
each of these facilities are taken to Building 419 where they are solidified and the
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residue from this process constitutes the other 2% of the TRU waste total. These wastes
are currently stored at the DWT Area. Liquid wastes are stored in 1500-gallon tanks,
treated in a Dorr Oliver package plant providing neutralization, flocculation,
oxidation/reduction, precipitation, separation, and filtration designed for copper,
chromium, nickel, and zinc removal. Sludges with heavy metals and other RCRA
characteristics are sent to USPCI in Nevada and radioactive residuals are sent to the NTS.
TRU waste management at LLNL is characterized by a small number of waste handlers and a
relatively streamlined "matrix management" approach which delegates responsibility to a
small number of key managers. The design objective of the matrix is to incorporate line
management responsibility, not just relegating TRU waste management responsibility to
"support services" or others peripheral to the main mission. During the briefing, LLNL
officials promised to provide the task force with anecdotal examples showing how issues
were raised, decided, and subsequent resolution implemented. At the time of this report,
however, the examples had not been received.
The certification process at LLNL may also be characterized in terms of its manageable
scale. The waste handlers are routinely visited by the laboratory manager. They are
provided with standard packages of operating safety procedures. Floor supervisors perform
double checks by visually verifying that the description of a drum's contents are
accurate. Drums are selected randomly. Only a small proportion of drums have been
returned due to problems. WIPP certification at LLNL was conditionally approved by the
WIPP-WAC committee in June 1986. and all containers packaged after August 8. 1986 will be
certified as acceptable.
Average activity of the 300 drums produced annually is four curies and the 25 (5'x 5'x 8')
boxes typically have 30 curies. Only about eight to ten of the drums will contain
hazardous wastes, usually lead shielding contaminated by TRU. The drums are WIPP
approvable (Type A DOT) steel drums with 80 or 90 mil liners. They are currently placed
in a "Super Tiger" container for highway transport via commercial haulers. Eventually.
either TRUPACT or Super Tiger containers will be used for shipment to the WIPP. The Super
Tiger is currently loaded weekly and shipped bi-monthly (six times per year).
In the future, the DWTF will house the entire waste management operation including TRU
waste consolidation.
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C. ENVIRONMENTAL MONITORING:
Environmental monitoring, particularly ground-water monitoring, is extensive. Response to
mounting regulatory and public pressure has produced an extensive monitoring network for
air and ground-water. Data analysis has just begun on the new systems, providing
remarkable resolution of plume details. Annual soil sampling is done at one- and two-mile
radii around the plant and at the edge of the facility buffer zone. Surface water samples
are taken at ten locations on Site 300 and the Main Site. Drinking water samples are
taken at the community water supply. Public meetings are held periodically to share data
with the two counties, two water resource boards, the other regulatory agencies and an
alliance of public interest groups.
At the Main site, there are currently five areas of known ground-water contamination which
are under investigation. The release of the contaminants to the ground water was probably
due to the past practices of the U.S. Navy and LLNL. West of the southwest corner of LLNL
is a plume of VOCs (volatile organic compounds) which is 3600 feet long by 1700 feet wide
by 200 feet deep and consists of two subplumes. The larger of the two subplumes is
dominated by TCE (trichloroethylene) at concentrations up to 1100 ppb (parts per billion).
The smaller subplume is dominated by TCE at concentrations up to 580 ppb. LLNL is
currently evaluating remedial action alternatives for this area.
In the southeastern portion of the Main Site there are three main sources of VOCs. The
extent of contamination in this area has been determined. The next phases of work for
this area include long-term hydraulic testing and the evaluation of remedial action
alternatives.
An estimated 65.000 liters of gasoline leaked from an underground storage tank located
along LLNL's southern boundary prior to March, 1979. LLNL has determined the extent of
gasoline constituents in soil and ground water and is currently evaluating remedial action
alternatives.
At Site 300. LLNL is currently investigating the extent of high explosives. TCE, and
tritium in soil and ground water. The investigations are being conducted to determine the
extent and impact of process waste water lagoons and the "burn pit" area where small
quantities of high explosives are destroyed by burning. The investigations have found
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concentrations of TCE exceeding 200 ppm in a shallow water-bearing zone under
environmental test facilities where TCE has been used as a heat exchange fluid. Far lower
amounts of TCE have been found in ground water near inactive landfills and in an area to
the east and northeast which was used for testing explosives. With maximum velocities of a
few tens of meters per year, this rate of flow and direction poses no immediate threat to
any on- or off-site water supplies. The Site 300 investigations include evaluation of
remedial action alternatives.
RCRA ground-water monitoring would probably not be required for TRU waste management at
LLNL. There are no facilities or practices comparable to buried "retrievable" storage or
remote handled vaults seen at other DOE facilities. All TRU management is indoors in well
ventilated, easily inspectable areas.
D. AUDITS/ASSESSMENTS/OVERVIEW:
Waste management operations at LLNL are conducted under the Standard DOE Management
System, with relatively high contractor autonomy, some District or Area office oversight
(San Francisco Operations Office in LLNL's case) and little headquarters involvement.
Orders from DOE headquarters are interpreted and narrowed in scope to fit site-specific
situations by the San Francisco Operations Office.
The TRU Waste Certification Program has been authorized by the WIPP-WAC to certify drums
dated after August 20, 1986 and boxes generated after January 15, 1987. (Drummed waste
prior to August 20 will be certified at NTS and old boxed wastes will be certified at
LANL). The WIPP-WAC committee listed only minor deficiencies in their audit of LLNL
procedures. For example, WIPP-WAC found that LLNL's technical specifications for
containers and the container vendor's data requirements were excessive, resulting in
vendors not supplying necessary information. Other minor findings include absent entries
on TRU Waste Package Control Records and Data Log Cards. Personnel training was
recommended to remedy these.
TRU Waste Certification oversight is rigorous, but it is all internal to the contractor.
DOE or local/regional regulatory oversight of drum content lists is not routine.
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E. SECURITY:
Movement of all TRU materials and wastes on-site is controlled and documented. Material
balance checks are made regularly and documented. Each waste container is bar coded and
information on all shipments and the current status of each container is fully
computerized.
F. RCRA EQUIVALENCY:
Most aspects of TRU waste management at LLNL appear to be equivalent to RCRA Hazardous
Waste regulations. There is excellent process control with regard to treatment and
packaging; this is facilitated by the small number of people involved. There are
extensive administrative controls for the tracking of waste from generation to disposal
and there is excellent security. There is a lack of waste characterization with regard to
quantification of the hazardous chemical components, but otherwise the TRU management
program would not need to be substantially different under RCRA.
G. ACTION ITEMS:
The following items were requested from LLNL:
• Examples of deliberations and decisions under the matrix management system.
H. APPENDIXES:
Set of briefing materials.
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Mixed Energy Waste Study (MEWS) Visit
U. S. Department of Energy (DOE)
Los Alamos National Laboratory
Los Alamos, New Mexico
January 13. 1987
PURPOSE:
On January 13. 1987. the MEWS task force, and an EPA Region VI representative, met at the
Los Alamos National Laboratory (LANL), with individuals from the Department of Energy's
(DOE) headquarters, DOE's Albuquerque Operations Office. DOE's Los Alamos Area Office and
the Los Alamos Contractor (University of California). The purpose of the meeting was for
task force members to gain a working knowledge about methods for treatment, storage and
disposal of high-level wastes (HLW) and transuranic (TRU) wastes at the LANL.
SUMMARY:
DOE's Los Alamos contractor (University of California) provided an overview briefings of
the site with emphasis on TRU waste management practices (there are no HLW at LANL).
Subject areas included administrative organization and funding, TRU waste management,
environmental monitoring, environmental compliance and environmental assessment and
response program. Following the briefings, a tour of the liquid waste treatment plant,
the TRU incinerator, the size reduction facility and the TRU and low-level waste (LLW)
management area was provided. The briefings and tour provided the task force with a
thorough understanding of the waste management systems at LANL.
In general, the current management systems at LANL for TRU wastes, from both an
administrative and technical standpoint, are advanced and comprehensive with many areas
equal or superior to those required by RCRA. Specific weaknesses would include the lack
of detailed chemical analysis of TRU wastes, the lack of ground-water monitoring around
the TRU waste retrievable storage, the lack of an adequate disposal plan for uncertifiable
TRU wastes and the lack of independent inspection.
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REPORT:
A. FACILITY DESCRIPTION:
The LANL was established in 1943 as a part of the Manhattan Project to develop the world's
first nuclear weapons. Today LANL's primary missions include nuclear weapon development,
development of new concepts for defense against nuclear attack, advanced fission and
fusion theories and development of fossil, renewable and geothermal energy.
The LANL site occupies 43 square miles on the Pajarito Plateau of the Jemez Mountains in
north-central New Mexico (Figure I). It is organized into 32 distinct technical areas.
Precipitation averages 18 inches per year across the entire LANL site. At lower
elevations, precipitation averages only 13 inches per year.
The facility is operated under contract by about 8,200 employees of the University of
California. There are also about 2.000 contract maintenance people for a total of 10,200
employees. Approximately 430 persons work in the Health, Safety and Environment Division;
55 work in waste management. The LANL annual operating budget for FY 86 was $800 million.
B. HIGH-LEVEL WASTE:
No HLW is generated, treated, stored or disposed of at the LANL.
C. TRU WASTES:
I. Generation
TRU waste generation rates for LANL are estimated to be 450 cubic meter per year (m3 /year)
of which 317 m /year will be sent to the Waste Isolation Pilot Project (WIPP) beginning in
1989. The difference between these figures is due to the volume reduction accomplished in
the size reduction facility. TRU waste represents approximately six to ten percent of the
total radioactive waste generated at LANL.
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FIGURE 1
LOS ALAMOS NATIONAL LABORATORY (LAND
I I JMIOOVU '.om't p
sun fE
ItJiOIUl.
!»/'*>,
! v*&u
A-41
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Of the 396.6 cubic meters (m ) of TRU waste generated in 1986 at LANL, the origin of
generation was as follows.
Plutonium Facility 76%
Analytical Chemistry 10%
Liquid Waste Treatment 8%
Other 6%
In addition, LANL receives approximately five drums of TRU waste (cemented) per year from
the Lovelace Clinic and the Sandia Laboratory in Albuquerque, NM.
The composition of the currently stored retrievable TRU waste at LANL is as follows:
Large Metallic Wastes 32% (e.g. glove boxes,)
Misc. Combustibles 19% (e.g. paper, cloth,)
Dewatered Sludge 15%
Misc. Noncombustibles 14%
Cemented Wastes 10%
Process Residues 6%
Soil 2%
Chemicals/Oils 0.1%
Others 1.9%
Aside from cemented waste and soil, much of this TRU waste may also be RCRA hazardous
waste due to the presence of lead shielding or solvents.
Almost all of the TRU waste at LANL is contact-handled with only one-half of one percent
being remotely-handled. LANL also generates some classified TRU waste, but this waste is
treated by the generator so that it is not classified when turned over to the waste
management group.
2. Management
Management of TRU waste at LANL includes treatment of liquid wastes, incineration of
combustible wastes, size reduction for large metallic wastes and certification for
disposal at the WIPP.
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There are three liquid waste treatment plants at LANL, one of which services the plutonium
plant and other generators of liquid TRU wastes. This facility, a physical-chemical
plant, removes 99 percent of the uranium and plutonium. The treatment steps include
influent analysis, flocculation/precipitation. filtration, ion exchange, treated liquid
analysis and discharge (Figure 2). The sludge resulting from treatment, which is TRU
waste, is dried on a vacuum filter, cemented and placed in 55-gallon drums. The
supernatant from the plant is directly discharged in accordance with a NPDES permit. The
rated capacity of the plant is 250 gallons per minute (86,000 gallons per day); however,
the plant is presently treating about 20.000 gallons per day of liquid waste resulting in
the generation of approximately 60 drums of cemented sludge per year. The facility does
not allow organics in the cemented sludges. In addition. LANL does not perform any
leachability tests due to concerns about radiation exposure.
The treatment facility has an elaborate process control system. This system provides
computerized monitoring of tank levels. Pumps and values are computer controlled; pH
adjustment and chemical feeds are automated. There are about four and one-half miles of
pipeline used in the conveyance of liquid TRU waste to the treatment facility. This
pipeline was installed in FY 86 at a cost of two million dollars and consists of a
six-inch polyethylene pipe inside a 10-inch polyethylene pipe. The interstitial space
contains liquid sensors placed every 500 to 600 feet which are monitored to detect any
leakage in the inner pipe. The Previous pipelines leaked for about 20 years prior to
replacement. Contaminated soil resulting from those leaks was dug up and stored in
55-gallon drums.
An incinerator is utilized at LANL to reduce the volume of TRU combustible wastes. In
1975, this incinerator consisted of a ram feeder, a primary combustion tank and a
secondary combustion chamber to burn particulates and volatiles. In 1979, a feed
preparation glove box and off-gas clean-up system were added. The off-gas clean-up system
consists of a high-energy scrubber, venturi scrubber, packed column and three banks of air
filters. The present cost of the incinerator was given as five million dollars. The
incinerator is presently permitted for incineration of PCB's and has interim status as a
hazardous waste incinerator. During a recent trial burn, it achieved a 99.99% reduction
of carbon tetrachloride (CCI4) and a 99.9999% reduction of trichloro ethylene (TCE). The
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FIGURE 2
LANL TREATMENT STEPS
KWDBIED ACT CAieCNIPAC)
l«4£. IRON.
COAGULATION AKB
RjkSHUIXffe
TREATED MW
•
TCSSTOfWOE
r^ *
:
\
*
MSCMAROE TO
ENVIRONMENT
-------
solids capacity of the incinerator is one hundred pounds per hour, liquids must be limited
to less than one million Btu's per hour. LANL plans to incinerate all TRU wastes
containing organics, solvents, and oil.
The size reduction facility at LANL is used to cut up large metallic TRU wastes such as
glove boxes. The entire facility is fully contained and remotely operated. It can handle
wastes up to 15 x 15 x 30 feet and uses a plasma torch to cut up the large objects. The
facility cost two million dollars.
All generating units are responsible for certification of new TRU waste under the
direction of a Waste Management Group. The Waste Management Group can reject any waste
that does not comply with the WIPP criteria. Present plans call for the neutralization
and cementing of all corrosives, and the incineration of all solvents, oils and the
majority of all paper and cloth prior to certification. The WIPP certification team has
not yet approved the LANL certification process. The final WIPP audit is scheduled for
February, 1987. Until approval is received, newly generated TRU wastes are being labeled
as certifiable. After approval, this label will be changed to "certified". A back-log
plan has been developed for the TRU wastes in retrievable storage. It calls for all waste
to be certified by 1997. As a part of this process, LANL is presently in the design phase
for a neutron assay facility which .is scheduled to be operational in late 1988. The
entire certification flow sheet is shown in Figure 3.
3. Storage
Prior to 1970. all TRU waste was mixed with LLW and landfilled on site. Since 1970, TRU
waste has been segregated and placed in retrievable storage. The volume of retrievable
TRU waste is presently 7453 m3 and LANL
shipped to the WIPP over the next 30 years.
TRU waste is presently 7453 m3 and LANL estimates that 14,000 m3 of TRU waste will be
The Los Alamos site is divided into many waste management areas (Figure 4). Pre-1970 TRU
wastes are buried in areas B, C. G, T. AB and possibly area A. Areas K, E. D. U. V, W. X
and Y contain only LLW. Area G is currently active as a LLW disposal area and has been
receiving all TRU wastes since 1970. The TRU retrievable storage consists of asphalt pads
similar to those at the Idaho National Engineering Laboratory (INEL). These pads are
above ground and are on top of an older LLW disposal ground. TRU waste is stored in
55-gallon drums and boxes on the pads. The drums are coated with a yellow corrosion
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FIGURE 3
LANL CERTIFICATION FLOW SHEET
New waste
generated at
TA-3, 50, 55
Size
Reduction
Incineration
Preparation
waste holding
Processing
NOA & NDE
Transport
TRU Burial
(gcd)
Retrieve from
uncertified
storage at
TA-54
LLW
Burial
(Temporary
Storage
TA-54)
CMP Saw
TO
WIPP
Retrieve from
uncertifed
storage at
TA-21
OOOO Volume of waste in
cubic m*t«rs
A-46
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inhibitor which will be steam cleaned away before shipment to the WIPP. As a pad is
filled, the drums and boxes are covered with plywood, polyethylene sheets and a two-foot
layer of earth. At one location on each pad. four columns of four drums are left out to
allow for an inspection portal. Air monitoring can also be performed on the buried
storage. Inspections to date have shown no drum leakage or need for routine air
monitoring. Unlike other DOE facilities visited (Hanford, INEL, WVDP) where certified TRU
waste goes to storage in buildings, LANL plans on continuing to cover and bury certified
TRU wastes. At present, two pads have been filled with an estimated three years of
storage capacity remaining on two additional pads.
Remote-handled TRU waste at LANL is stored in the G area in concrete culverts with two
drums per culvert. Some of these have been opened for inspection and sampled for gas;
however, gas was only found in the newer drtims.
4. Disposal
Disposal of all certified TRU waste will be at the WIPP which is scheduled to start
receiving waste in October, 1988. About 125 m of uncertifiable TRU waste may be disposed
of on-site in greater confinement. This greater confinement will consist of cemented
waste placed at a greater depth than LLW is presently being buried.
A 1979-80 study of old TRU burial sites resulted in a decision to leave that waste in
place and to add earth, plant shallow rooted vegetation, add fencing, and establish a
maintenance plan for the sites. This decision is being restudied with a report due to the
Albuquerque Operations Office in June. 1987.
D. MONITORING:
A comprehensive monitoring program for transuranics is carried out at LANL. This includes
routine sampling of the air, surface water, ground water, soil, sediments, and foodstuffs
for radioactivity. In addition, the waste water discharge from the liquid TRU waste
treatment plant is monitored weekly for pH, chemical oxygen demand (COD), ammonia.
cadmium, chromium, copper, iron, lead, mercury and zinc as required by the NPDES permit.
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FIGURE 4
LANL WASTE MANAGEMENT AREAS
8000* I600O' ft
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Through the use of modeling, LANL has estimated the travel time from the waste management
areas to the regional aquifer to be in excess of one million years. The average depth to
ground water is 1,100 feet. Based on this effort, ground-water monitoring at waste
management area G has only been for radioactivity. However, monitoring for hazardous
chemicals has been performed, when possible, on perched water tables where they discharge
at the surface into surrounding canyons.
In 1976. LANL did horizontal borings from the canyon to give side access to the area
beneath one of the TRU waste disposal facilities where waste had been buried for 11 years.
Borings came within one foot of the bottom of the trench. No TRU migration was found;
however, analyses for hazardous waste were not performed.
E. AUDITS/ASSESSMENTS/OVERVIEW:
LANL operates under the standard DOE management system. DOE headquarters issues orders
which are then interpreted and narrowed in scope to meet site specific conditions by the
Albuquerque Operations Office. This process continues down to the procedures written by
the contractor for the plant operators to follow. The DOE Headquarters' Health. Safety,
and Environment Office has no direct power to require implementation or compliance. The
LANL Environmental Compliance Office operates with borrowed staff and can only refer
problems to the Laboratory Environmental Compliance Management Committee. Audits are
performed by all of the organizations under their respective jurisdictions. However,
independent, outside audits are not conducted.
F. SECURITY:
Security for the TRU waste treatment and storage areas is maintained 24-hours per day
through controlled access and armed guards.
G. RCRA EQUIVALENCY:
Most aspects of TRU waste management at LANL appear to be equivalent to RCRA hazardous
waste requirements. The areas where TRU waste management appears to exceed RCRA standards
include the following:
• Excellent process control with regard to the treatment and transfer of TRU
liquid waste. Includes a computer automated surveillance system.
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• Extensive administrative controls for the tracking of waste from generation
through disposal.
• Excellent conceptual plan for final disposal of certified TRU waste.
• Excellent security.
Areas where there seem to be potential problems with RCRA equivalency include the
following:
• Lack of or limited data on waste quantity and characterization with regard to
hazardous chemical components.
• Lack of RCRA ground-water monitoring around buried TRU retrievable storage
(probably a waste pile or landfill under RCRA).
• Lack of adequate disposal plan for uncertifiable TRU waste.
• Lack of independent audit or inspection.
H. ACTION ITEMS:
The following information was requested from the DOE:
• Listing of all disposal sites with the type and amounts of wastes identified.
• Example of non-conformance report.
• Map of LANL showing which portions (tanks, pipelines, processes, storage
sites, etc.) would be included in DOE option.
I. APPENDICES:
I. "Los Alamos National Laboratory. A Profile". LALP-84-35
2. "Organizational Profile; Health. Safety and Environment Division".LALP-83-36
3. "Welcome To Los Alamos", LALP-85-9
4. "Los Alamos 1943-1945; The Beginning of an Era", LASL-79-78 Reprint
5. Agenda. Department of Energy (DOE)/Environmental Protection Agency (EPA)
Interagency Team Review. January 13. 1987.
6. Set of briefing materials to MEWS Task Force, January 13, 1987.
a. Wayne Hansen Overhead Slides [Laboratory and Health. Safety and
Environment Division Overviews],
b. Doris Garvey Overhead Slides [Environmental Compliance
Management Office - Organization and Funding]
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c. John Warren Overhead Slides [Transuranic (TRU) Waste Management
at Los Alamos].
d. "Comprehensive Environmental Assessment and Response Program",
Gunderson. T.C.. Vocke. R.W. & Stoker, A.K., Los Alamos National
Laboratory, Los Alamos, New Mexico.
e. Bob Vocke Overhead Slides [Environmental Oversight Monitoring]
f. Tony Drypolcner Overhead Slides [Environmental Oversight:
Compliance]
g. Liquid Waste Treatment Plant Overhead Slides
7. "Final TRU Waste Inventory Work-Off Plan", LA-UR-862932
8. "Environmental Surveillance at Los Alamos During 1985", LA-I0721-ENV
9. Health and Safety Manual, Section 9 - Environmental Protection
10. Health and Safety Manual, Section 10 - Waste Management
11. "The Los Alamos Controlled Air Incinerator for Radioactive Waste", Volume I:
Rationale, Process, Equipment. Performance and Recommendations, LA-9427,
Vol. I
12. "The Los Alamos Controlled Air Incinerator for Radioactive Waste", Volume II:
Engineering Design Reference Manual. LA-9427. Vol. II.
J. DISTRIBUTION:
MEWS task force Distribution List
Mark Sides. Region VI
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Mixed Energy Waste Study (MEWS) Visit
U.S. Department of Energy (DOE)
Nevada Test Site
Las Vegas. Nevada
January 14, 1987
PURPOSE:
On January 14, 1987, the MEWS task force visited the Nevada Test Site (NTS), meeting with
representatives of the Department of Energy (DOE) headquarters, DOE Nevada Operations
Office, Idaho National Engineering Laboratory, and Reynolds Electrical and Engineering
Co., Inc. the (REECO), prime contractor-operator of NTS.
The purpose of the visit was for task force members to gain a working knowledge of the
mission of the NTS and the operation of the transuranic (TRU) waste management system
including disposal of classified wastes.
SUMMARY:
The major discussion subjects were:
• The NTS TRU waste program.
• The greater confinement disposal (GCD) facility.
• The geology and hydrology of NTS.
• The NTS low-level waste (LLW) program.
• The development of mixed-LLW disposal facility at NTS.
The major findings were:
• Neither high-level nor TRU waste is currently produced on-site; TRU waste may
be produced if a proposed site clean-up is pursued.
• The only TRU waste now being disposed on-site is classified.
• AM non-classified TRU waste in storage is from Lawrence Livermore National
Laboratory.
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• An intermediate-depth disposal technology (GCD) has been developed and is
currently in use.
• The GCD facility is used for classified TRU waste and high specific activity
LLW.
• The GCD wastes are about 850 feet above the aquifer.
• Approximately I millimeter per year of precipitation infiltrates 1000 feet
below the surface.
• Ground water takes about 3.800 years to move off-site from the disposal area.
• Continuous security is present.
• Documentation on TRU waste packages is thorough.
• The NTS is used for disposal of DOE LLW.
* The NTS is planning to develop and operate a RCRA permitted mixed-LLW
facility.
REPORT:
A. SITE DESCRIPTION:
The NTS is located about 60 miles northwest of Las Vegas. Nevada. The 1,300-square mile
reserve encompasses both mountain and desert environs, with the waste areas being located
in the desert.
The rock underlying the waste management area is tuff, a volcanic rock, which is overlain
by fine alluvial soil. There is about five inches of precipitation per year, most of
which (97%) evaporates; it is estimated that less than 1% infiltrates to the 800-foot
depth of the ground water. A DOE contractor. Desert Research Institute of the University
of Nevada, reported that there is no gravity drainage without continuous (about two years)
ponding and that the estimated travel time for ground water from the disposal area to
off-site (Ash Meadows outflow) is 3,800 years.
The NTS began operations in 1950 as the continental nuclear weapons proving ground. Its
primary mission is still to provide a remote, secure facility for the safe conduct of
underground nuclear weapons testing. One other important but subordinate function is
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waste management and disposal of defense-related radioactive waste, including classified
TRU waste. The fiscal year 1986 budget was about one billion dollars overall, with $1.2
million designated for waste management.
B. HIGH-LEVEL WASTE:
No high-level waste is generated, treated, stored or disposal of on-site.
A potential site for the first national high-level waste repository (Yucca Mountain) is
located within the NTS reserve. If Yucca Mountain is chosen, the high-level waste
situation on-site would obviously change; however, that decision is at least several years
away.
C. TRU WASTE MANAGEMENT:
1. Management and Storage
TRU waste is not produced on-site; the NTS has been used only as a waste storage and
disposal facility. Prior to 1970. TRU waste was disposed of on-site. The only wastes
currently being disposed of are defense related low-level and classified TRU wastes. All
other TRU waste is in retrievable storage in above ground shipping overpacks.
All the nonclassified TRU waste on-site is from Lawrence Livermore National Laboratory
(California). From 1974 through 1985. NTS received about 21.000 cubic feet of TRU waste
containing about 3,300 curies. In July 1985, NTS stopped receiving TRU waste packages
which were not certified for disposal in the Waste Isolation Pilot Plant (WIPP). For TRU
waste received before July 1985. NTS has begun a certification program. Using portable
equipment, almost 1,500 drums and 32 of the 64 total steel boxes have been neutron
assayed. Of those drums, 1,349 were found to contain TRU wastes and were sent through
real-time radiography (RTR); all but 229 passed. Those drums that passed are now awaiting
sonic testing, bar coding, weighing and banding. The drums found to contain non-TRU waste
have been disposed as LLW; the 229 drums not passing the RTR test (mostly because of
liquid content) have been placed in storage awaiting a decision on how to process them.
The NTS is expecting to build an RTR facility and sampling station in about two years.
While this is mainly for LLW. it could be used for TRU waste packages also.
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Incoming waste shipments are inspected by the organizational element known as RADSAFE for
both physical and administrative requirements. If shipments are not accepted, they are
returned to the generator unless leakage is found. Leaking packages are overpacked and
held pending a decision to dispose, store, or return them. Outgoing shipments to the WIPP
will be in conformance with the WIPP Waste Acceptance Criteria labeling, packaging, and
documentation requirements.
2. Disposal
Approximately 5,600 cubic feet of classified TRU waste have been disposed on-site since
1985 using a technique called greater confinement disposal (GCD). The GCD test project
began in 1981 to demonstrate the disposal of defense LLW at a depth sufficient to minimize
or eliminate natural intrusion processes, e.g.. animal burrowing or plant rooting, and to
substantially reduce the potential for inadvertent human intrusion. A test shaft was
drilled 10 feet in diameter and 120 feet deep, the same dimensions as the operational
shafts now being used. The shafts are not lined. Waste is emplaced to fill about half
the volume, then the shaft is backfilled. Fiscal year 1987 is the final year of the GCD
test. Data from this test will be used in the 40 CFR 191 performance assessment (EPA's
Environmental Standards for the management and disposal of spent nuclear fuel, high-level
and radioactive wastes; draft due.September, 1987). The two goals for the GCD test are to
collect and analyze data on radionuclide migration (using nonradioactive gaseous and
liquid tracers) at the 120-foot level and to develop handling procedures. The GCD
facility currently has capacity (assuming 50% of the volume is waste) for about 40,000
cubic feet of waste.
The NTS is a major defense disposal site for LLW produced both on-site and off-site. This
is a much larger operation than the TRU waste operation; for fiscal years 1982 through
1986, approximately 5.8 million cubic feet of LLW were disposed in shallow land burial.
The GCD is being used for both high-specific activity LLW and classified TRU waste. The
classified TRU waste comes from weapons facilities around the country. The high-specific
activity LLW includes about 2.5 megacuries of tritium. There is an effort to concentrate
LLW radionuclides for GCD and reduce the concentration in shallow-land LLW disposal areas.
Following the visit, it was learned that GCD of TRU waste has been suspended pending
demonstration of compliance with 40 CFR 191.
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A problem which is becoming more pressing for the DOE defense facilities is the disposal
of mixed-LLW waste. At the moment, there are no active, interim status, or permitted DOE
disposal sites for mixed radioactive waste. In an effort to relieve this problem, the NTS
is planning to develop and operate a mixed-LLW facility adjacent to the current GCD
facility. Assuming the timetable can be followed, this facility would be operational in
late 1988. The RTR and sampling station mentioned earlier would be built to support this
facility and could be used in the TRU waste management system as well.
E. ENVIRONMENTAL MONITORING:
The monitoring system for the waste management area centers on the detection of gamma
radiation and airborne radionuclides with monitoring stations located around the perimeter
of the waste management site. There is no dedicated monitoring for either the GCD
facility or the TRU storage overpacks or area.
When packages are moved they are monitored and to date, no leakage has been found. No
ground-water monitoring has been completed; there is very little water to drive the
radionuclides to the ground water or the long distance through the unsaturaled zone to the
aquifers. Drilling monitoring wells may increase the spread of contamination. NTS has
requested a variance from Region IX for the ground-water monitoring requirements.
There is a large water monitoring program both on and off-site for NTS. The nearest such
well to the waste management site is about 3/4 mile away in Frenchman Flat. The
monitoring detects radionuclide migration from the nuclear test sites; there are no
RCRA-quality wells.
Soil sampling has been conducted sporadically. Sampling of surface soil was initially
done in 1980 and again in 1986. Current plans call for annual sampling. The focus will
be on alpha, beta, and gamma scans, and plutonium, tritium, and fission products.
F. AUDITS/ASSESSMENTS OVERVIEW:
The NTS operates under the standard DOE management system. DOE headquarters issues orders
which are then interpreted and narrowed in scope by the Nevada Operations Office to meet
site-specific conditions. The contractor. REECO, then writes procedures for the operators
A-56
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to follow. Audits are performed by all of the organizations under their jurisdiction as
well as by the WIPP Waste Acceptance Criteria Certification Committee. No independent.
outside audits are conducted.
G. SECURITY:
There is no dedicated security force for the waste management area. However, security for
the overall NTS is maintained 24-hours per day by armed guards.
H. RCRA EQUIVALENCY:
The areas where TRU waste management appears to exceed RCRA requirements include:
0 Extensive administrative controls for the trading of waste from acceptance to
storage through disposal for shipment off-site,
• Excellent conceptual plan for disposal of WIPP-certifted TRU waste.
• Continuous overall site security.
Areas where there may be potential problems with RCRA equivalency include:
• Lack of classification for any RCRA-hazardous waste contained in classified
TRU waste.
• Lack of adequate disposal plan for WIPP-uncertifiable TRU waste.
• Lack of independent audit or inspection.
• Public access to RCRA permit application information due to the classified
TRU waste.
I. ACTION ITEMS:
None
J. APPENDICES:
1. Bound copy of briefings entitled "HQ. U.S. Department of Energy and Environmental
Protection Agency Visit to Nevada Test Site. January 14. 1987".
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2. Booklet entitled, "Greater Confinement Disposal Test at the Nevada Test Site".
K, DISTRIBUTION:
MEWS task force Distribution List
Lou Johnson, Region VIII
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Mixed Energy Waste Study (MEWS) Visit
U.S. Department of Energy (DOE)
Oak Ridge National Laboratory
Oak Ridge, Tennessee
January 21, 1987
PURPOSE:
On January 21, 1987, the Mixed Energy Waste Study (MEWS) task force, accompanied
representatives from EPA Region IV and the Department of Energy (DOE) Headquarters and
visited the Oak Ridge National Laboratory (ORNL) in Oak Ridge. Tennessee. The purpose of
the visit was to review transuranic (TRU) waste management operations at the facility. A
list of attendees is provided in Attachment 1.
SUMMARY:
Once a major producer of plutonium for use in weapons production, ORNL operations now
focus primarily on research and development of heavy elements for use in medical
applications. No HLW is generated at ORNL as a result of these or other operations at the
laboratory. ORNL is not a major contact-handled TRU (CH-TRU) waste generator. However.
the facility is a major generator of RH-TRU wastes and 94% of DOE's inventory of
retrievably stored remote-handled TRU (RH-TRU) waste and are housed at ORNL. Funding has
been appropriated for a Waste Handling Pilot Plant (WHPP) which will allow processing,
repackaging and certification of these wastes for final disposition at the Waste Isolation
Pilot Plant (WIPP).
Newly generated and stored CH-TRU wastes are being certified for disposal at the WIPP in
preparation for initial waste acceptance in 1988. However, thirty percent of stored TRU
wastes fail the certification process. At this time, ORNL does not have a facility
available to process drums failing certification; however, a repacking facility for stored
CH-TRU wastes is being planned.
Additionally, some TRU wastes are stored in tanks. These tanks are both single-walled and
double-walled although wastes are no longer being added to the single-walled tanks. DOE
plans to send these wastes to the WIPP. However, technology for retrieval and
solidification of these wastes has yet to be developed by ORNL.
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ORNL has initiated a remedial action program based on detecting contamination, migration
of contaminants and delineation of the source of contaminants from groupings of
ground-water monitoring wells. These wells typically do not conform with RCRA
requirements but their use, as outlined, may satisfy that requirement.
Lastly. ORNL operates under the standard DOE management/audit system. However, unlike
other DOE operations. ORNL has solicited independent audits for their operations.
NOTES:
It should be noted that the discussion which follows addresses TRU waste management
operations at ORNL. Use of ORNL for the purpose of this report is considered to be
synonymous with X-IO operations. No classified TRU wastes are either stored or generated
at ORNL. ORNL contends there is no high-level waste at the facility although dissolution
and processing of fuel rods yield wastes characterized as high-level by other DOE
operations. At this time, the task force is not challenging ORNL's waste classification.
REPORT:
A. FACILITY OVERVIEW:
Although DOE-owned. ORNL is contractor-operated by Martin-Marietta Energy Systems.
Incorporated. The 2.900-acre Laboratory (X-IO) is located approximately 10 miles from
downtown Oak Ridge, Tennessee and is one of three major DOE production and research
facilities located in Oak Ridge. The other facilites are 1) the Y-12 plant which is
involved in non-plutonium weapons components manufacture and services, and 2) the Gaseous
Diffusion Plant (K-25) which is currently in stand-by mode.
The first reactor was started at Oak Ridge in 1942 as a pilot plant for the production of
plutonium from irradiated reactor fuel. Currently, ORNL activities include production of
heavy elements such as uranium, americium, einsteinium, californium, and curium for
medical, industrial, and research applications while weaponry applications are a secondary
consideration at this time.
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B. HIGH LEVEL WASTE:
None at ORNL. notwithstanding the previously noted exception.
C. TRANSURANIC (TRU) WASTE:
I. Characteristics
TRU wastes are defined in DOE Order 5820.2 as waste contaminated with transuranium
radionuclides (that have atomic numbers greater than 92) that are alpha-emitters having
half-lives greater than 20 years and in concentrations greater than 100 nanocuries per
gram (nCi/g). This definition would include various isotopes of neptunium, plutonium.
americium. curium, californium and berkelium (i.e.. elements that are heavier than
uranium).
TRU wastes at ORNL are categorized as either contact-handled which is primarily low
penentrating, alpha emitting particles, or remote-handled, containing sizable quantities
of more penetrating beta- and gamma-emitting radionuclides. CH-TRU wastes exhibit less
than 200 millirems/hour (mrem/hr) hour at the container surface. Conversely, RH-TRU
wastes exhibit greater than 200 mrem/hr at the container surface.
ORNL also indicated individual DOE operations offices are permitted to "designate" certain
isotopes as TRU, when appropriate. In accordance with this policy, U-233. an alpha
emitter which is unique to the thorium fuel cycle and R-226 are being considered as
transuranics by ORNL for waste management purposes.
2. Generation
ORNL does not generate large quantities of TRU waste when compared to other DOE operations
and projects where annual generation rates are cubic meters/year 28 (m /yr) and 10 in /yr
for CH- and RH-TRU wastes, respectively. This inventory is generated from five major
operations at ORNL. They are:
1. the radiochemical processing plant operations which generate U-233 CH wastes:
2. the transuranium heavy elements reprocessing plant operations whichs
generates CH- and RH-TRU wastes:
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3. the isotopes area where some plutonium and heavy elements are handled,
generating CH-TRU wastes:
4. the High Radiation Level Analytical Laboratory generates CH wastes; and
5. the Transuranium Research Laboratory which generates approximately I drum of
heavy-element-TRU wastes biannually.
Currently, no classified TRU wastes are generated or stored at ORNL.
3. TRU WASTE MANAGEMENT:
I. Overview
All newly generated and retrievably stored TRU wastes which can be "certified" to meet the
Waste Isolation Pilot Plant (WIPP) Waste Acceptance Criteria (WAC) will ultimately be
shipped to the WIPP for permanent disposal. The WIPP. which is located 26 miles east of
Carlsbad, New Mexico was conceived as a research and development facility to demonstrate a
technology for permanent disposal of defense-generated TRU wastes. This is to be
accomplished by entombment of the waste in a 225 million-year-old bed of salt at a depth
of approximately 2. J50 feet. The WIPP and its waste acceptance criteria are the subject
of a separate report. Interested persons are referred to that report for further details.
The WIPP-WAC not only specifies waste container requirements which include type of
container, package size, and radionuclide handling limits but also specifies waste form.
That is. liquids (not more than 1.0% at some DOE facilities but 0% at ORNL). pyrophoric
materials, explosives and compressed gases are prohibited. Additionally, waste package
requirements such as package weight, nuclear criticality. plutonium equivalent activity.
surface dose rate and contamination, thermal power, gas generation, labeling, and
accompanying data package/certification are specified by the WIPP-WAC. Waste may be
packaged in metal drums or corrugated metal boxes for shipment to WIPP. ORNL. unlike
other DOE facilities, uses stainless steel drums (without plastic liners) to package TRU
wastes because of concerns that high humidity in the Oak Ridge area might corrode carbon
steel drums thus compromising their integrity. In fact, some of the black iron drums have
corroded and leaked.
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2. Certification
Sealed drums containing CH-TRU wastes are certified at the Waste Examination Assay
Facility (WEAF). Each drum must pass an examination by three separate assay systems in
order to obtain certification. One, the ORNL real-time radiography unit (RTR)
examination, allows x-ray inspection of individual drums. Using this system, liquids.
partially filled aerosol cans and other prohibited items can be detected. Two. drums are
passed through a neutron assay system (NAS) which scans the container for fissile
material. This is accomplished by using active and passive scanning modes. The active
mode of the NAS detects thermal-neutron-induced Fission reactions while the passive mode
detects neutrons emitted by spontaneous fission. Using these data, the total TRU activity
per drum may be obtained by adding the results of the active and passive scans. The
sensitivity of NAS ranges from 200 grams (g) to as low as 0.5 g. Three, the segmented
gamma scanner (SGS) identifies minimum detectable quantities of gamma-emitting isotopes.
Although the SGS currently qualitatively monitors for gamma-emitting isotopes, it will be
upgraded to provide a quantitative assay of individual waste containers.
Drums from retrievable storage as well as newly generated TRU wastes are examined at the
WEAF. A total of 565 CH-TRU drums have been inspected at the WEAF since October. 1985.
As of January, 1987, 354 drums (63%) passed inspection. 373 (30%) failed inspection, and
38 (7%) were undetermined primarily because of the suspected presence of high-efficiency
paniculate air (HEPA) filters or other problems encountered during examination. HEPA
filters pose a special problem because the WIPP-WAC limits fines smaller than 10 microns
to less than 1% by weight and fines smaller than 15 microns to less than 2% by weight.
Unlike other DOE facilities, delineation of the size of fines cannot be standardized at
ORNL due to the diversity and variations of its operations.
A nonconformance report is issued for "newly" generated TRU waste packages which cannot be
certified at the WEAF. This report accompanies any noncertified TRU waste drum returned
to the generator for repacking. Appropriate signatures must be provided on the
nonconformance report before the waste will be reaccepted at the WEAF for re-examination
and certification.
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Drums formerly housed in retrievable storage and failing WIPP certification are
color-coded and returned to the retrievable storage area until a repackaging facility
becomes available. TRU waste drums found to contain less than 100 nCi/g of transuranics
are managed as low-level wastes.
A data package accompanies each drum certified for shipment to the WIPP. These data
requirements include shipment/transportation data (i.e.. shipment number, shipment date,
carrier code, vehicle number, vehicle type, waste type, shipment certification, etc.), as
well as waste package data which includes various codes and identification numbers.
closure date, weight, surface dose rate, neutron component, organic materials weight and
percent volume, plutonium fissile gram equivalent, total alpha activity, hazardous waste,
waste package certification date. etc. All waste examination and certification records
are retained in duplicate.
The ORNL TRU waste certification program has not received final approval from the WIPP-WAC
Certification Committee. The committee is, however, scheduled to review ORNL operations
in May 1987 and it is anticipated that the certification program will receive final
approval at that time.
3. Storage - Present and Pasl Practices
ORNL currently has 1750 cubic meters (m ) of TRU waste in retrievable storage; of this
quantity. CH-TRU waste accounts for 486 m and RH-TRU wastes for 1264 m . Ninety-four
percent of the total DOE inventory of RH-TRU waste is stored at ORNL in comparison to 0.7%
of CH waste and 3.6% of buried TRU. Newly generated CH-TRU wastes are packaged in
stainless steel drums and certified for shipment to the WIPP as generated. Formerly.
however, several retrievable storage technologies have been applied to TRU wastes
including storage in drums, concrete casks, stainless steel wells and as sludges in tanks
under varying amounts of supernatant. The range of storage practices used at ORNL are
summarized below in Figure I.
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FIGURE1
ORNL WASTE TYPES
CONTACT HANDLED
REMOTE-HANDLED
NEWLY GENERATED
-SS DRUMS
STORED
•DRUMS
NEWLY GENERATED
•CONCRETE CASKS
- SS WELL WASTE-
STORED
-CONCRETE CASKS
-SS WELL WASTES
•SLUDGES
• CEUSP CANS"
SS • Stainless Steel
CEUSP • Consolidated Edison Uranium Solidification Process,
under consideration for designation as RH-TRU.
Retrievable CH-TRU waste drums are stored below grade in IO x IO ft concrete block storage
cells on concrete block bottoms while the newer storage cells have a poured concrete
bottom. Access to the cells can be gained through a square-shaped port in the top of the
cell. Drums are slacked four high in older cells andjive high in the newer storage
cells. The cells are not completely dry and, occasionally, small quantities of water have
been seen to accumulate in the storage cell. Storage cells are, however, equipped with a
monitoring sump which is checked monthly for liquids.
Some RH-TRU wastes are stored in concrete casks. The wall thicknesses of the newer casks
are either 6 or 12 inches with some older casks having four-inch thick walls; however,
these older four-inch walled casks are no longer used. Storage casks are lined with
polyethylene and can accommodate 27 drums. Typically, ORNL RH-TRU waste must be stored
five to ten years in order to allow sufficient radioisotope decay to meet the WIPP-WAC.
Storage is below grade in storage cells equipped with a monitoring sump which is checked
monthly.
Other RH-TRU wastes are stored in single-shelled stainless steel wells with a welded
stainless steel bottom and anchored to a six-inch concrete slab (Figure 2). These wells
vary in diameter anywhere from 20 to 76 centimeters and vary in depth from 3.1 to 4.6
meters. Each well is capped with a removable concrete plug. ORNL has a total of 54
A-65
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FIGURE 2
DESIGN FEATURES OF STAINLESS STEEL WELL FACILITIES
A-66
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stainless steel wells which are used to store segmented fuel rod elements as well as some
high-specific activity, low-level waste. The fuel rod elements are first placed in
stainless steel primary containers which are lowered into the wells. ORNL has classified
this waste, which weighs approximately 6000 kg, has a volume of 4 m , and exhibits more
than 65.000 curies of activity of which 300 curies is plutonium. as "special case" waste.
It is anticipated that the special case waste may be difficult to certify for disposal at
the WIPP because of the potential concentration of fissile material. Additionally, there
is no leak detection system dedicated to this well system.
Lastly, wastes characterized as TRU by ORNL resulting from heavy element reprocessing and
a multitude of other operations are stored as sludges in two types of tanks at ORNL. The
Melton Valley Storage Tanks (MVST) are stainless steel tanks contained in a stainless
steel-lined concrete vault (Figure 3). Each vault is equipped with a sump system that has
an alarm. There>are a total of 8 MVST's containing a total of 51,300 gallons of sludge.
Sludges totaling 65,000 gallons are also stored in six Gunite tanks with approximately 60%
of the total volume being contained in Gunite tank W-10. The Gunite tanks are
single-walled tanks that lack ground-water monitoring but are equipped with sumps with
alarms (Figure 4). Formerly, these tanks were used to store wastes prior to evaporation
and disposal by hydrofracture, a practice which has been discontinued.
At this time, the Gunite tanks are inactive and ORNL has yet to identify a removal.
handling and solidification process for the residual sludges (hey contain. Conversely,
liquid TRU wastes are currently added to the second-generation MVST tanks as
evaporation/concentration operations permit.
4. Treatment
Currently, there is no facility at ORNL for processing RH-TRU wastes. However, funding
for a Waste Handling Pilot Plant (WHPP) has been appropriated. The WHPP is planned as a
minimal processing facility for repackaging and WIPP certification of RH-TRU wastes. The
WHPP feasibility study was completed in 1984 with construction on the facility scheduled
to begin in 1991. Existing plans call for construction to be completed and the plant
operational by 1996. Since 94% of DOE's inventory of RH-TRU wastes are stored at ORNL, it
is conceivable that the WHPP may serve as a central processing facility for RH-TRU wastes.
Such wastes could be transported from INEL and Hanford, for example, for processing at
ORNL once the WHPP is on line.
A-67
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FIGURES
COMPARISON OF EARTHEN PIT VERSUS VAULT-TYPE TANKS
I
MONITORING
WELL
COLLECTION
TANK
TROUGH TO
DRY SUMP
CONTROL CABINET
Off GAS SYSTEM
STAINLESS
S1E£L LINER
STAINLESS
STEEL LINER
EARTHEN PIT
VAULT
-------
FIGURE 4
TYPICAL CONCRETE (GUN1TE) WASTE TANK INSTALLATION
s
TO WASTE
PROCESSING
FACILITIES
STANDARD
VALVE PIT
I
DEPTH
1 INDICATOR
WELL TAMPED EARTH FILL
(6 fl TYPICAL)
^t£
PLUG
VALVE
PIT
GRAVEL OR
CRUSHED
STONE
DRAIN
FROM
BUILDING
-------
5. Disposal
Disposal of all certified TRU waste will be at the WIPP which is scheduled to start
receiving waste in October, 1988.
D. MONITORING:
ORNL has developed a remedial action program to control existing and future ground-water
contamination and investigate potential sources of continuing releases. Because of the
complexity of the hydrogeology and the extent of contamination, the ground-water
monitoring program was based on a "Waste Area Groupings" (WAG) approach rather than the
traditional RCRA array of wells up- and down-gradient of each unit. The program uses
information from US Geological Survey (USGS) studies, an ORNL-developed ground-water
strategy: geology, hydrology, waste management reports and research results; an inventory
of solid waste management units (SWMUs) identified at ORNL; and other available data and
information. This approach is based on grouping 250 formerly identified SWMUs, which have
been grouped into 20 WAGs. Each WAG undergoes hydrogeologic review and characterization.
The review includes installation of piezometer wells which permit delineation of flow
patterns and some preliminary characterization of the uppermost aquifer.
Secondly, additional wells which are installed on WAG perimeters for water quality
determinations are used to establish priorities. A Remedial Investigation/Feasibility
Study (RI/FS) constitutes the third phase of the program and is intended to confirm
ground-water contamination including delineation of SWMU's within WAGs which include TRU
sites. The ground-water flow system and vertical gradients are ascertained using data
obtained from hydro-static head measuring stations. These stations are three well
clusters set at distances of 200. 300, and 400 feet connecting the WAGs. Because
ground-water monitoring is on the perimeter of the WAG. the nature of the contaminants
found in the ground water, flow paths etc. is used to identify the facility contributing
to contamination. Typical ground-water wells are depicted in Figures 5 and 6.
To date, there are 830 ground-water monitoring wells at ORNL. Of this number. 258 are
newly constructed WAG perimeter wells. 90 are new piezometer wells, and 27 are new
hydrostatic-head measuring stations. The extent of wells required for the RI/FS for the
SWMUs have not been determined to date.
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FIGURE 5
MONITORING WELL SPECIFICATIONS
PROTECTIVE CASING
GROUT
BENTONITE
PEA GRAVEL
OR FINE SANO
LOCKING CAP
4" STAINLESS STEEL
WITH 0.01" SCREEN
BOTTOM CAP
A-71
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FIGURE 6
MONITORING WELL SPECIFICATIONS
IT
PROTECTIVE ••»
CASING ^
— itf^S
fcss
ros
8§
8" CARBON STEEL— ^KJ |
OUTER CASINO ffe §
I!
GROUT— -^Jfc ^
i
1
11
BEDROCK AQUIFER
WATER LEVEL T :
5 K-l
OR FINE SANO
mm^mmmmm
I
s
s
I
1
i
V*
" —
MM
* «»^
•a ^^
«^^«
fevr
r
of^_
i ^^t
^ ^
§ «
I
II
1
1
§! §S
^ ^
iS
^
LOCKING CAP
OVERBURDEN
BEDROCK
V INTERFACE
4
Uft
^— 4" STAINLESS STEEL
WttH Q 01" SCREEN
^x" BOTTOM CAP
A-72
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Ground-water flow rates in the area can vary from one to 100 feet per year with typical
conductivity of 10~5 centimeters/second (cm/sec) detected in ground water and at the
burial sites. To date, limited chemical contamination has been observed in ORNL ground
water. It should be noted that although it appears that a comprehensive ground-water
monitoring program has recently been developed, study results were not made available to
the task force. ORNL personnel did. however, indicate that data from the current
monitoring system could not be used to meet RCRA requirements.
E. AUDITS/ASSESSMENTS:
ORNL operates under the standard DOE management system. DOE headquarters issues Orders
which are then interpreted and narrowed in scope by DOE Oak Ridge Operations as
appropriate. Typically, audits of waste management, compliance and environmental reviews
are performed by ORNL's Department of Environmental Management, Energy Systems'
Environmental and Safety Activities Office. DOE/Oak Ridge Operations Headquarters Lead
Programs and an independent consultant to Energy Systems, Additionally, both EPA
Region IV and the State of Tennessee tour the facility biannually although no formal
inspection has been performed by either Agency to date. The State of Tennessee has
EPA-delegated authority for all programs with the exception of mixed waste and the
Hazardous and Solid Waste Amendments. 1984.
F. SECURITY:
Security at ORNL is maintained 24 hours a day by armed guards. This practice is
consistent with that observed at other DOE operations.
G. RCRA EQUIVALENCY:
Insofar as ORNL has identified TRU waste management operations for newly generated and
retrievably stored wastes, those practices appear to be comparable to RCRA requirements.
However, there are areas where deficiencies can be identified because ultimate disposal
parameters have not been determined such as:
• disposal of RH-TRU wastes is contingent on construction of the WHPP facility.
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• the absence of a disposal plan for sludges stored in the single-walled Gunite
tanks and the Melton Valley tanks; no disposal plan for wastes stored in
stainless steel wells.
• absence of "RCRA" ground-water monitoring wells.
• no chemical analyses of wastes.
• the possession of a fair amount of potentially "non-certifiable" TRU wastes.
H. ACTION ITEMS:
None identified.
I. APPENDICES:
Briefing packages on:
I. Overview of Site Organization and Mission
2. ORNL RCRA Compliance Strategy and Status
3. TRU Waste System Description
4. Waste Examination and Certification
5. ORNL Hydrology and Ground-Water Monitoring
6. Independent Review and Oversight
J. DISTRIBUTION:
MEWS task force Distribution List
James H. Scarbrough, EPA Region IV
A-74
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ATTACHMENT f
NAME
E.D. Bates
Danforth Bodien
James K. Farley
Ray Clark
Betsy Jordon
Doyle R. Brown
John Tseng
Carroll Nix
Fred Schultz
Lance J. Mezga
Carol A. Broderick
Dale D. Huff
Doug Turner
Cindy Kendrick
Mike Eisenhower
Jim Scarbrough
Burnell W. Vincent
Sonce SHvernale
Betty Shackleford
Tony Baney
John Lehman
Ray Berube
ORGANIZATION
ORNL
EPA/Region X
DOE/ER
EPA/Radiation Programs
DOE/DP
DOE/ORD
DOE/DP
ORNL
ORNL
Energy Systems
Energy Systems
ORNL
ORNL
ORNL
ORNL
EPA/Region IV
EPA/OSW
Camp Dresser & McKee Inc.
EPA/OSW
EPA/Enforcement/HQ
EPA/OSW
DOE/EH
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Mixed Energy Waste Study (MEWS) Visit
U.S. Department of Energy (DOE)
The Rocky Flats Plant
Golden, Colorado
December 9, 1987
PURPOSE:
On December 9, 1986, the Mixed Energy Waste Study (MEWS) task force visited the Rocky
Flats Plant (RFP) near Golden, Colorado. Those present were members of the MEWS task
force. Lou Johnson from EPA Region VIII, representatives of Department of Energy (DOE)
Headquarters, DOE Albuquerque Operations Office, DOE Rocky Flats Area Office, DOE Rocky
Flats Plant. Rockwell International (contract-operator of RFP), and personnel from DOE's
Idaho National Engineering Laboratory (INEL), Savannah River Plant (SRP). and Hanford. No
attendance list was compiled.
The objectives of the visit were to be briefed on the operations of RFP, the waste
management system, and to review the transuranic (TRU) waste management facilities and
practices.
SUMMARY:
Since there is no high-level waste (HLW) at RFP, the briefings were all related to TRU
waste production and management. There were descriptions of the processes and facilities
in which wastes are produced, how those wastes are collected and treated (if necessary),
packaged, and transported. Discussions also covered administrative controls such as
radiation safety, document control, reviews of facility construction and operational
safety, environmental monitoring, quality assurance, CERCLA activities, security, audits.
and operator training.
The major findings were:
• RFP generates no HLW.
• RFP generates more TRU waste than any other DOE facility;
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• Almost all TRU waste streams at RFP have RCRA-hazardous chemical components
which are not known quantitatively. They are known only qualitatively from
by their use in the processes that generate these streams;
• Both liquid and solid TRU waste streams exist;
• There are no buried TRU waste tanks;
• All TRU waste packages leaving the site are certified for disposal at the
Waste Isolation Pilot Plant (WIPP);
• Approximately ninety-nine percent of the TRU wastes are sent to INEL for
storage. One to two percent is classified for security reasons and sent to
the Nevada Test Site (NTS) for disposal;
• Documentation and security appear to exceed RCRA requirements; and
• DOE stated that mixed TRU waste is exempt from RCRA compliance under an
agreement among RFP. the Colorado Department of Health, and EPA Region VIII.
REPORT:
A. FACILITY DESCRIPTION:
The RFP is located about 20 miles northwest of downtown Denver. Colorado and just east of
the Front Range of the Rocky Mountains (Figure 1). The 6,500-acre reserve is on a
generally grassy plain with a thin, gravely topsoil underlain by 20 to 50 feet of thick,
coarser, clayey gravel. The plant is located on 350 acres near the center of the reserve.
Operations began in 1953 and have been continuous since. The RFP has an annual budget of
$400 million and employs about 5.500 people. The main mission for RFP is the development
and production of nuclear weapons components from plutonium, beryllium, depleted uranium,
and stainless steel.
B. HIGH-LEVEL WASTE:
No HLW is generated, stored, or disposed of on the site.
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FIGURE 1
GENERAL LOCATION OF THE ROCKY FLATS PLANT
MOUNTAlNS *»»H.*IN
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C. TRU WASTES:
There are three sources of plutonium for the operations at RFP: (1) the DOE production
facilities at SRP and Hanford supply fresh plutonium; (2) fission assemblies from old
weapons are sent from Pantex and recycled; and (3) recovery of plutonium from liquid and
solid production wastes. Once solidified, the plutonium metal is cast, machined, or
otherwise formed into the necessary shapes.
I. Generation
TRU wastes are generated primarily from the chemical processes for recovery and the
machining of plutonium; these sources determine the major separation between liquid and
solid wastes, respectively. There were about 100,000 cubic feet of TRU waste generated in
FY 1986.
2. Management
Solid TRU wastes are typically items contaminated during the processing of plutonium
metal, e.g. gloves, paper, tools, or machine parts. The wastes are assayed to determine
whether the amount of plutonium in them makes it economically reasonable to recover the
plutonium. If recovery is found to be uneconomical, the waste may be cut. compacted, or
washed, depending on the nature of the material. The wastes are then placed in an 11-mil
PVC bag which is sealed with tape and placed in either (1) a 90-mil. rigid polyethylene
drum liner which is sealed and placed inside a 55-gallon DOT 17-C metal drum; or (2) a
50-mil fiberboard liner which is wrapped in an 11-mil PVC wrapper, sealed, and placed in a
4'x 4'x7' 14-gauge corrugated metal welded box. The drums and boxes are sealed with
tamper-indicating mechanisms. These containers are then stored in buildings to await
certification processing (discussed later).
Liquid wastes, mainly from the plutonium recovery processes, are sent to above ground.
in-building storage tanks. The wastes are held for up to one year while waiting for
treatment. Examples of chemicals in the mixed wastes are hydrofluoric acid, nitric acid,
potassium hydroxide, sodium hydroxide, carbon tetrachloride, and various reagents. If the
tanks are not double-walled, they have berms around them for secondary containment; all
piping is double-walled. Depending on the nature of the waste, it may be treated with any
or all of the following: neutralization, precipitation, flocculation, clarification,
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filtration, and drying (Figure 2). There is also processing for organic and miscellaneous liquid TRU wastes. E
ventually, all of the liquid TRU wastes are mixed with cement, placed in the previously described 55-gallon dru
ms. and stored until the certification process
begins.
All movements of materials on the site are controlled and documented. Armed guards are
required for non-pipeline shipments made within the plant. Materials balance checks are
made regularly and documented. Each waste container is given a unique number and will be
tracked through to disposal. All shipments are accompanied by a hard-copy load list and
the load list is electronically sent to the destination prior to the shipment leaving the
site. In addition, off-site shipments will eventually be monitored by satellite.
Following the site visit, it was learned that a system is in place at NTS and has been
initiated for INEL to acknowledge receipt of the TRU shipments and waste containers.
3. Storage and Disposal
Prior to shipment off-site, each TRU waste container is tested for compliance with the
WIPP Waste Acceptance Criteria (WIPP/WAC; Figure 3). Those drums containing compatible
wastes are emptied. The waste is compacted and placed in boxes. Each container is then
radioassayed before being sent to the real-time radiography (RTR) facility. If the
package meets the WIPP/WAC, it is marked, labeled, and signed off as certified for
disposal in the WIPP. If it does not meet the criteria, it is returned to the facility in
which it was originally packaged to be repackaged in accordance with the criteria; it is
then retested. This procedure is repeated, as necessary, until the package is in
conformance. The containers are then placed inside storage buildings until they are
shipped to INEL for storage.
The shipments are made in specially constructed enclosed railcars called "ATMX." These
cars hold up to 140 drums or 24 boxes. Beginning in October. 1988 these shipments will go
directly to WIPP and will use the new TRUPACT overpack on railcars and trucks. The
TRUPACT-I is designed to hold 36 drums; there will be two TRUPACTS per railcar and one per
truck.
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FIGURE 2
BUILDING 374 LIQUID WASTE TREATMENT FLOW DIAGRAM
-------
FIGURE 3
\\IPP WASTE ACCEPTANCE CRITERIA FLOW DIAGRAM
own rctrr DISPOSAL
SUE REDUCTION
oo
K>
CONUNI SPECIFIC ORUH
ASSAY
CONTENT SPECIFIC CRATE
ASSAY
HARKING, LABELING & FINAL
INSPECTION
CERTIFIER'S REVIEW
LOAD LIST
RELEASE
-------
D. ENVIRONMENTAL MONITORING:
The environmental program centers on the detection of radiation in air, soil, and water.
Air monitoring is continuous at all 50 RFP air exhaust systems as well as 51 sites away
from the plant. Annual soil sampling is done at one- and two-mile radii around the plant
to determine the distribution and migration of pltitonium. Surface water samples are taken
at six locations and drinking water is taken from nine community water systems.
Ground-water monitoring began in the early 1960s for radionuclides.
The RFP is beginning to install RCRA-quality ground-water monitoring wells. In 1986, 70
RCRA-qualiry wells were installed and more are scheduled. Data from these wells are
unavailable.
Public meetings are held monthly to share the data from all monitoring programs.
E. OVERSIGHT:
The DOE stated that mixed TRU waste management at RFP is exempt under a recent RCRA
compliance agreement with EPA and the State of Colorado. The State monitors air, soil,
and water independently from the DOE; EPA participates in the air monitoring.
The RFP operates under the standard DOE management system. The DOE headquarters issues
orders which are then interpreted and narrowed in scope by the Albuquerque Operations
Office to fit site-specific conditions. This process continues down through the DOE Rocky
Flats Area Office to the procedures written by Rockwell for the plant operators to follow.
Audits are performed by all of the organizations under their jurisdiction as well as the
WIPP/WAC Certification Committee. No independent outside audits are conducted.
F. SECURITY:
Security for the site is maintained 24-hours per day by armed guards and S.W.A.T. teams.
Security is especially heavy around plutonium handling facilities.
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G. RCRA EQUIVALENCY:
Most aspects of TRU waste management appear to be equivalent to RCRA hazardous waste
requirements. The areas where TRU waste management appears to exceed RCRA standards
include:
• Excellent process control with regard to the collection, treatment and
transfer of TRU waste.
• Extensive administrative controls for the tracking of waste from generation
through disposal.
• Excellent conceptual plan for final disposal of WIPP-certified TRU waste.
• Excellent security, including armed escorts for on-site solid TRU waste
movements.
Areas where there seem to be potential problems with RCRA equivalency include the
following:
• Lack of quantitative data on RCRA hazardous chemical components in the mixed
waste; presence of such chemicals is usually known from their use during
processing.
• Lack of RCRA-quality ground-water monitoring data; 70 RCRA-type wells have
been installed and more are scheduled but no data is yet available.
• Lack of independent audit or inspection.
H. ACTION ITEMS:
The MEWS task force requested the risk level acceptability for equipment design and
example copies of shipping documentation. (The examples of shipping documentation were
received shortly after the visit).
I. DOCUMENTS OBTAINED:
To all member of the MEWS task force:
The Rocky Flats Plant (orientation booklet)
Briefing for EPA/DOE Technical Working Group on High-Level
and Transuranic Waste
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One copy of the following:
WO-4500-E. "TRU Waste Compliance Program for WIPP/WAC" (a
representative Rocky Flats procedure)
"Rocky Flats Waste Streams" (Appendix C-3 from Part B permit
application)
"Waste Management Units" (Appendix 1 from Part B application)
Typical report of environmental data from the monthly exchange meeting
between Rocky Flats and the Colorado Department of Health
Latest WIPP/WAC audit report and the Rocky Flats response
"Transuranic Waste Certification and Transportation Documents." dated
December 17, 1986.
DISTRIBUTION:
MEWS task force Members:
Win Porter (WH-562A)
Jack McGraw (WH-562)
Marcia Williams (WH-562)
Gene Lucero (WH-527)
Sheldon Meyers (ANR-458)
Lloyd Guerci (WH-527)
Bruce Weddle (WH-563)
Joe Carra (WH-565)
Tony Montrone (WH-562A)
Margie Russell (WH-562A)
Susan Bullard (WH-562A)
Charles Findley (Region X)
Frank Blake (LE-130)
Lisa Friedman (LE-I32S)
Mark Greenwood (LE-I32S)
Robin Woods (A-107)
Richard Sanderson (A-104)
Edward Reich (LE-134S)
John Skinner (RD-681)
Pat Tobin (Region IV)
Al Davis (Region VI)
Bob Duprey (Region VIII)
Lou Johnson (Region VIII)
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Mixed Energy Waste Study (MEWS) Visit
U.S. Department of Energy (DOE)
Savannah River Plant (SRP)
Aiken, South Carolina
December 2 - 3, 1986
SUMMARY:
Officials from the Savannah River Plant (SRP) provided an overview briefing of the
facility's current hazardous, high-level waste (HLW) and transuranic (TRU) waste
management practices. Subject areas included the Defense Waste Processing Facility
(DWPF), the DWPF research and development program, tank farm operations, and TRU waste
certification and storage operations. Tours of the above areas were also provided. The
briefings and the tours were quite comprehensive, and provided the task force with a
general understanding of the facility and methods for the treatment, storage and disposal
of HLW and TRU waste. Both past and current methods were discussed.
Early in the briefings, attendees discussed definitions to clarify exactly what was meant
by hazardous. HLW, TRU waste and mixed waste. SRP's definition of mixed waste included
waste with both RCRA hazardous waste and radioactive waste, but did not encompass mixed
HLW waste and TRU waste. Concern was also raised about to the period of time required for
institutional controls in the definition of TRU waste. The group agreed to resolve the
definitional differences at the next DOE facility.
Audits were also discussed and SRP highlighted their methods for appraisals, audits, and
inspections. MEWS task force officials emphasized the importance of documenting
independent oversight.
In general, SRP's methods for handling HLW appeared to equal or exceed RCRA requirements
for hazardous waste tank design and construction, surveillance, inspection, and
monitoring. However, the management program specifically focuses on the migration of
radioactive rather than hazardous components. More information is needed to make a
preliminary determination about TRU waste (i.e., specific types and amounts of hazardous
chemicals commonly associated with TRU waste). Additional documentation will be necessary
to demonstrate the capability of the existing ground-water monitoring system and the
system planned for the future.
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REPORT:
A. FACILITY DESCRIPTION:
The SRP is a 300 square mile DOE reservation located in South Carolina on the Savannah
River. The SRP is engaged in the production of nuclear materials for defense purposes and
research. DOE owns and administers the SRP; the facility is operated by Du Pont.
The SRP was constructed during the 1950's and is the nation's sole producer of tritium and
plutonium-238 and is a major producer of plutonium-239. These isotopes are produced by
absorption of neutrons in lithium (Li 6), neptunium-237 and uranium-238, respectively.
The SRP has a budget of $1.2 billion/year for the operation of three nuclear production
reactors, two nuclear production reactors on standby, one small reactor shutdown, two
separations areas for processing irradiated materials, a fuel and target fabrication
facility and the Savannah River Laboratory. Operations of the SRP include several
hazardous waste and low level mixed waste facilities which are operated under interim
status authorization from the South Carolina Department of Health and Environmental
Control (DHEC).
Mixed liquid radioactive and hazardous waste are produced at SRP primarily for nuclear
fuel reprocessing operations. Two facilities are equipped to chemically separate and
purify the products from fuel and target assemblies irradiated in the reactors.
The major HLW storage areas for radioactive liquids, sludges, and crystallized salts
(Figure 1) included in DOE's proposed option are adjacent to the F and H separations area
(Figures 2 and 3). The HLW storage areas are linked to the separations area and to each
other by pipelines with secondary containment. High level waste will be vitrified in the
S-area (Figure 4) and the salt stone will be stored in the z-area. Three burial grounds
totaling 195 acres between the F and H areas are used for controlled storage of solid
radioactive wastes and interim storage at TRU waste. The reactors, separations area, and
waste management areas are at least 4 miles from the nearest plant boundary.
A-87
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FIGURE 1
SAVANNAH RIVER PLANT SITE OVERVIEW
N
Z-AREA
SALTSTONE
UPPER THREE RUNS
CREEK
00
oo
SEEPAGE BASINS
TANK FARMS
H-AREA
LINED RETENTION
BASIN
SEEPAGE BASINS
S-AREA
VITRIFICATION
ETF
LINED RETENTION
BASIN
FOUR MILE CREEK
-------
FIGURE 2
F AREA TANK FARM
!!i!!
II tl
I • J17 I I
-------
FIGURE 3
H AREA TANK FARM
-------
FIGURE 4
S-AREA VITRIFICATION FACILITY
-------
B. OVERVIEW OF WASTE MANAGEMENT OPERATIONS:
An environmental impact statement on waste management activities for ground-water
protection is being prepared to address waste management in particular. The EIS will not
address sanitary landfills. HLW or TRU waste. However, it will address the publication of
the draft EIS which is planned for April, 1987, and the final EIS which is scheduled for
October, 1987. The SRP also plans to construct and operate an incinerator by November,
1991, for hazardous waste, low-level waste (LLW) and mixed wastes.
The SRP has a contingency plan and emergency procedures. Emergency and evacuation plans
exist and drills occur regularly. The site also has an emergency operating center which
is staffed 24 hours/day with direct access notification to key personnel by radio alert.
The HLW is stored in tank farms which are within controlled, limited-access areas and are
fenced and guarded by patrols. The HLW is contained in underground tanks which are not
easily accessible and 24 hour surveillance is maintained by operations personnel.
Contractor employees and subcontractors are subject to a drug testing program. TRU waste
storage areas are similarly fenced and controlled.
C. HIGH LEVEL WASTE (HLW):
I. Generation
The SRP produces approximately 3 million gallons of HLW annually (Hanford has
approximately two-thirds of the total; Idaho only approximately 3%). SRP's HLW consists
of supernate (61 %). salt cake (28%) and sludge (11%). Thirty-three million gallons of HLW
is currently stored at SRP. While this is approximately 34% of DOE's total stored HLW, it
contains 62% of the radionuclide acivity. Stored waste is blended with that which is
currently produced. Options are under consideration regarding the final closure of the
HLW tanks.
The supernate portion of the liquid waste, after aging, contains dissolved salts and
radioactive cesium. This supernate is transferred to an evaporator for dewatering. and
the concentrate from the evaporator is transferred to a cooled waste tank where the
suspended salts settle. Cooling causes additional salt to crystallize. The supernate is
A-92
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returned to the evaporator for further concentration. This process is repeated until this
portion of the waste has been converted to damp salt cake. The salt produced by
evaporation of the aged supernate consists of NaNO , NAOH, Na,C03 , NaNO,, Na SO. , and
NaAI(OH). The radionuclide concentration in the salt is approximately three times that of
the supernate. This process continues until the liquid has been converted to a
crystallized salt cake. The evaporator condensate from all HLW tanks is a mixed waste.
The sludge is composed primarily of oxides and hydroxides of manganese, iron, and to a
lesser degree, aluminum. It contains essentially all of the fission products originally
in the irradiated fuel except cesium, and essentially all of the actinides. The sludge
also contains mercury. Trace elements and a wide variety of other hazardous constituents
are present.
2. Treatment and Storage of High Level Waste
The Defense Waste Processing Facility (DWPF), currently under construction (46% complete).
will vitrify HLW. The facility should be operational by 1990. Vitrified waste will be
stored on-site until a repository becomes available (Figure 5). Decontaminated salt
solution produced at modified facilities will be transfered to the DWPF. At the DWPF, the
solution will be mixed with solidifying materials in an enclosed treatment facility (TETH)
to form salt stone. The State of South Carolina DHEC has granted a TETF exemption; salt
stone will be poured into above ground vaults which are permitted as an industrial waste
landfill by the State. Ground-water monitoring is required.
Concern was raised about the TETF exemption because waste material may be stored for up to
fifteen years before being processed. In addition, the exemption would impact HLW storage
tanks further back in the process stream.
Areas F and H each have a large shielded "canyon" building for processing irradiated
materials (fuel and/or targets), a waste concentration and storage system, and seepage
basins. Recovery processes in the canyons generate liquid waste streams that contain most
of the fission products. The wastes are made alkaline and flow through under-ground pipes
by gravity from the processing buildings to the waste storage tank farm. The underground
pipes are enclosed in a secondary concrete conduit for double containment or are
double-walled with leak detection.
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FIGURE 5
TRU WASTE STORAGE
NOTE: Blackened areas indicate areas
which will be affected by DOEs
proposed option.
843-0
LL - Low 8tt»-G«flw« W««t
TA
GCO
EULT
Trtncn AiplM W«tt
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latcrmdiAt* *ad Low(.*v*l
«od Solvent Storage
A-94
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Some concern was raised about the distance between leak detection devices in the pipes
(approximately I mile). This distance could potentially impair the detection systems
overall effectivness. A shorter distance between leak detection devices may indicate
leaks faster and reduce the potential for external contamination.
The HLW waste is stored in large underground tanks in these areas. The method of storage
does not eliminate options for long-range waste management. Fresh (high heat) waste is
aged for one to two years to permit settling and the decay of short-lived fission
products. During this period, insoluble materials settle to form a layer of sludge at the
bottom of the tank. The sludge is a mixture of oxides and hydroxides of manganese, iron
and aluminum; small amounts of uranium, plutonium, mercury and essentially all of the
fission products orginally in the irradiated fuel except cesium. After aging, the
supernate containing dissolved salts, primarily sodium nitrate and radioactive cesium, is
transferred to a continuous evaporator. Fresh low heat waste may be transferred directly
to this evaporation for volume reduction.
The separations process began operating in F-Area in 1954 and in H-Area in 1955. and waste
storage began immediately (Figures 6 and 7). Since that time, 51 waste tanks have been
used to contain the 33 million gallons of high-level liquid waste at the SRP.
Nine tanks have leaked radioactive waste from the primary tank into the annulus between
the primary and secondary tanks. These are Tanks 1,9, 10. II, 12, 13, 14, 15, and 16.
Of the nine primary tanks that have leaked into the annulus. only one (Tank 16) has leaked
any waste into the surrounding ground, as verified by radiological analyses of
ground-water samples drawn from wells in the vicinity of the tanks. No samples were taken
to assess chemical migration. Tanks 9, 14 and 16 have leaked large volumes of wastes into
the annulus. One single-wall tank (Tank 20) has possible leaks, but these are well above
the level of contained wastes. No waste was detected outside the tank. The tank has
since been emptied.
All of the waste tanks are below ground, and are built of carbon steel and reinforced
concrete, with four different designs (Figure 8). Three designs have double steel walls
and bottoms, forced water cooling systems and are used primarily for high-heat waste and
waste concentrate: the fourth design has a single steel wall directly supported by the
reinforced concrete, has no orced cooling, and is used primarily for low-heat waste and
concentrate.
A-95
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FIGURE 6
F AREA HIGH LEVEL WASTE TANKS BY NUMBER
-------
FIGURE 7
H AREA HIGH LEVEL WASTE TANKS BY NUMBER
-------
FIGURE 8
STORAGE TANKS - TYPES 1IV
COOLED WASTE STORAGE TANK
Type |. Orif inal 750.0OO Gallons
s- VENT RISERS
f
1
,.10 ROOf^j.o-
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,
: 1
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>
^ STEEL
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.
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10' WALL 2' 6" BASE SLAB
7V f| mmmmmm
COOLED WASTE STORAGE TANK
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i
.
j,O
-INTAKE FAN
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a
1
COOLED WASTE STORAGE TANK
Stress Relieved Primary Liner .1.300.000 Gallons
Type m
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««•»• »'""«»
l
, nus• i •
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iNC CUMCHl t
-------
• Type I
The original 12 storage tanks constructed during 1951-1953 are designated as
Type I tanks. Tanks \ through 8 were placed in F Area and Tanks 9 through 12
in H Area. Each primary tank holds 720,000 gallons, is 75 feet in diameter,
and is 24 1/2 feet high. The essential features of Type I tanks, include the
primary tank, the secondary pan, and the concrete support structure. Five
Type I tanks have leaked.
• Type II
Tanks 13 through 16. constructed in H Area in 1955-1956, are designated Type
II tanks. Each primary tank holds 1,070,000 gallons, is 85 feet in diameter,
and 27 feet high.
The primary container for Type II tanks consists of two concentric steel
cylinders assembled with a flat bottom and a fiat top to form a doughnut like
structure. Four Type II tanks have leaked.
• Type III
The tanks constructed most recently are designated as Type III. The Type III
tank design was developed after an investigation into the causes for leaks
from Type I and Type II primary tanks.
For the Type III tanks, each finished tank was heated to relieve the stresses
generated during fabrication. In addition, some stress patterns were
avoided, or minimized, by mounting the roof supporting column on the
foundation pad rather than on the bottom of the primary tank (as in Type I
and II). Each primary tank holds 1,300.000 gallons, is 85 feet in diameter,
and 33 feet high. None of the tanks have developed cracks or have leaked.
• Type IV
Tanks 17 through 24 are of different design than those constructed previously
and are called single-wall, uncooled, or Type IV tanks. They were designed
for storage of waste that does not require auxiliary cooling. Tanks 17
through 20 were built in F Area in 1958. and Tank 21 through 24 were built in
H Area in 1958-61. Each tank holds 1.300,000 gallons, is 85 feet in
diameter, and is 34 feet high. One Type IV tank has leaked.
3. Controls
Primary leak detection methods rely on automatic surveillance in areas where waste that
has leaked is most likely to migrate. Inventory surveillance is performed to ensure the
integrity of the tanks.
A-99
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The annulus of each of the doubled-wall tanks is equipped with at least two single-point
conductivity probes located at the bottom of the annulus on opposite sides of the tank.
When a conductivity probe detects liquid, it activates audio-visual alarms in the waste
management control room. Each alarm is investigated, including visual inspection of the
annulus, and a formal investigation report is issued to operating and technical
supervision to describe each incident and the corrective action. AH annuli are visually
inspected and conductivity probes (designed to be fail-safe) are tested on a monthly
basis.
The existing single-walled tanks are located on a concentrate slab with a network of leak
collection channels which drain to a common sump. The liquid level in each sump, as
measured by differential pressure transmitters, is recorded continuously, and an alarm is
automatically activated if the level reaches a preset value. These sumps frequently
contain ground water and rainwater and are sampled and pumped out as required.
For inventory control and as a backup to the leak detection system, liquid levels inside
the tanks are measured and recorded. Each waste tank is equipped with a reel tape for
measuring liquid level in the tank. The reel tape is checked manually once a month.
The liquid level in every tank is read once every eight-hour shift, recorded, and compared
with previous readings. Additionally, tank levels are recorded every two hours on both
the evaporator feed tank and concentrate receipt tank. This occurs while an evaporator is
operating hourly on both sending and receiving tanks. The evaporator helps provide the
information needed to compare the quantity received in each tank to the quantity sent.
The waste management employee on shift reviews and signs the data sheets used to record
all sump, annulus, and tank level measurements indicated above, and any required
corrective actions. These data sheets are reviewed by operating and technical
supervisors. Daily reports on waste management activities are provided for operating and
technical management. These reports describe any significant incident shortly after it
has happened, how the problem developed, and follow-up action.
A-100
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4. Monitoring
In the past, mixed waste could leave areas in several ways: in exhaust, ventilation air
from building, off-gases from operations, and radioactive liquid that migrates from
seepage basins through the soil to a natural waterway. The MEWS task force was assured
that this effluent would not be included in the proposed option. However, the F and H
seepage basis will be closed by November. 1988.
Nitrates, sodium, mercury and tritium have been identified as ground-water contaminants
beneath the H-Area Seepage Basins. The F-Area Seepage basins show nitrate, sodium and
tritium contamination in the ground water. The SRP has installed monitoring systems to
detect the presence of contamination. Concern was raised that these systems were
inadequate to fully characterize the rate and extent of migration of either the
radioactive or hazardous waste consituents. The SRP agreed to submit further
documentation in support of monitoring systems. Region IV is assessing all ground-water
monitoring wells to ensure that they meet RCRA specifications.
5. Inspection
The inspection of equipment used for handling and storing radioactive wastes is difficult
due to worker exposure to radiation and contamination problems. However, the SRP has
developed techniques for remote inspection and evaluation of the condition of waste tanks.
These include visual inspection by means of a periscope, photography, ultrasonic
measurement of wall thickness, and corrosion specimens.
Recurrent waste tank inspections have consisted of visual surveys in the annular spaces,
and to a lesser extent, inside the primary tanks. For closer, more comprehensive
inspections, a portable optical periscope, composed of up to four ten-foot sections, is
extended from grade into the annutus or tank with the objective (ens relatively close to
the location of interest.
Double-walled tanks with a history of leakage are inspected through a selected annulus-top
opening at least once a year. All other double-wall tanks are inspected every two and
four years, respectively.
A-101
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Single-wall tanks are inspected internally above the waste level through a selected access
riser at least once a year. Six of the eight single walled tanks were emptied by the end
of 1986. The seventh should be emptied by mid 1987. The remaining tank is used for LLW
storage. Two of the decomissioned single wall tanks will store DWPF wash-water.
D. TRANSURANIC (TRU) WASTE:
I. Generation
Approximately 5% of DOE's total volume of TRU waste is located at the SEP: however, this
waste contains 62% of the radioactivity. TRU waste is contaminated with transuranic
nucUdes. mostly plulonium, with half-lives greater than 20 years and in concentrations
greater than 100 nanocuries per gram of material.
2. Storage
Up until 1965, alph-emitting waste was buried unencapsulated in alpha trenches. At
Savannah River, beginning in 1965. TRU waste was segregated according to two categories.
Waste containing less than 0.1 Ci of the TRU materials was buried. In 1974, procedures
were modified to reflect new criteria governing retrievable storage of solid TRU waste.
TRU waste contaminated with more than 100 nCi/g is now stored on above ground concrete
pads (Figure 9). Polyethylene galvanized drums are used as the primary containers. These
drums are no longer buried. Waste packages containing more than O.I Ci are additionally
protected by placement in concrete cylinders. Containers are stored on a concrete pad and
covered with 4 feet of earth (Figure 10). These concrete culverts were 6 feet in diameter
by 6.5 feet high. Waste that did not fit into the prefabricated concrete culverts were
encapsulated in concrete. Transuranium waste from Savannah River Laboratory was buried in
cubical concrete containers. Waste containing less that 0.1 Ci per package was buried in
retrievable concrete culverts.
3. Monitoring
Ground-water monitoring wells help survey the buried wastes. The SRP has installed three
types of non-RCRA monitor well systems to determine the extent of radioactive migration
into the surrounding environment: perimeter wells, boreholes and trench wells. RCRA
A-102
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FIGURE 9
TRU WASTE STORAGE PADS
WITH
GALVANIZED 55 GALLON DRUMS AND CONCRETE CULVERT
-------
FIGURE 10
TRU WASTE STORAGE PADS COVERED WITH PLASTIC AND EARTH
>
o
-------
monitor wells will also be installed in the future to monitor hazardous components. To
date, the radioactive component of mixed waste has taken precedence in the monitoring
program.
4. Controls
The SRP plans to minimize waste generation and contamination by segregation and
identification at the point of origin. All TRU wastes are currently packaged to meet WIPP
requirements which will enable direct waste transfer starting in late 1988, according to
the schedule. Some TRU waste will require further processing to meet WIPP criteria.
Waste Isolation Pilot Plan/Waste Acceptance Criteria (WIPP/WAC) considers I) Waste
Container Requirements including DOT Type A packages, size and handling limits, and a
twenty year design life; 2) Waste Forum Requirements - which include paniculate size
limits, no free liquids (i.e. no more than l%): no explosives or compressed gas. no
pyrophorics. and all hazardous waste constituents must be identified (but not quantified
as would be required under RCRA); and 3) Waste Packaging Requirements - including weight
and criticality limits, radiation dose limits/surface contamination limits, labeling, data
packages and documentation (Figure 11).
The certification program ensures that waste is packaged according to TRU waste
certification operating procedures. TRU waste certification data and records ensure that
each drum containing TRU waste has been assayed and X-rayed. Operator training is
documented. A quality assurance program acts to oversee the handling of TRU waste at the
facility. Audits are conducted internally and by external groups. The SRP operations
office and WIPP also conduct audits. A diagram of the SRP's TRU Waste Management Plan is
show in Figure 12.
5. Audits and Assessments
At DOE Headquarters, the Assistant Secretary of Environmental Safety and Health (ES&H)
oversees an annual environmental audit of the SRP's field operations. At SRP, the
Assistant Manager for Operations is responsible for waste management operations and audits
or appraisals of the contractor. The Assistant Manager for ES&H conducts independent
audits. The SRP emphasizes that responsibilities for audits and assessments were not
specifically outlined.
A-105
-------
FIGURE 11
TRU WASTE PACKAGING FORM
««SK ^ 172
TRU WASTK DATA PA( KA(ih
WAS IK PA* KA<.-|N<;OUUeCOMtt.t,Ta>OrWAiltOLNl:KAIOH)
JTAMft COW COJCJUTCD b
S K
6UX5/AREA
IS)
DATE DRUM CUV5EP . PACKAGED BVflHUHT)
22
21124
LAST NAME. FIRST INITIAL
WASTE DESCKll'llUN
VOt*
»a LIQUIDS
Crc
N
51
!H10slVEs/ COMHtESsTB CASES
V I
N
J2_
6ll62l 6Tl 641
1 6?l
70l
TS PAKTICLtS 7l »8| VV|00
AlmlQRJZtDSJQiATDRE
DATE
lit ALIII t-KUIfeXllUN SURFACE DOSE RATE NEUTRON DOSE RATE SURFACE CONTAMINATION SURFACE CONTAMINATION READINGS TAKEN BYJUUNT)
SURVEY I>ATA I "** I ™" I I ""* I
III II 1J | »|iq|ll.imniM ||S|I6|I7||» I LAST NAME.rHtSr INITIAL
WASTE
rKOCKSbING
00 BE CUMOJHIU) BY WASTE MANAGEMENT)
DATE X RAYED TAPE NO
I I 2l II 4 I jj>
DRUM NET WT(kn)
OUALITY
ASSUKANCK:
REASON IF
NONCIRT1HABLE: 72 | 711 74 I 7} 1 7fe 177 I ?i 1781 JO IIII »2 I »ll J41141J6
AUH RTWZED SIGNATURE
DATE
(TO BE CUMfLETED BY WASTE MANAGEMENT)
RRIER
cxx«
II 21 1
wyTDr
SinPUENTNff
(UmlhD
,M*IM ».
I I I I
I »|'"l lli»l»|M|»l I"
IALANCE DATE CEM11FIED FOR SI IIP!
SHIPMENT DATE
DATE VBOOENQ.
IV| 2U|
rtfc
11
12
4>l «b| 47| 4111 4V I 5U
-------
FIGURE 12
SRP TRU WASTE MANAGEMENT PLAN
WASTE
CERTIFICATION
FACILITY
CERTIFIABLE
VIA TWF?
RETOEVABLE
WASTE
CERTIFIED
STORAGE/
WIPP
TRANSURANIC
WASTE
FACILITY
LOW
LEVEL
WASTE
THJ WASTE
PROCESSN3
PATCHY
DEOON&SIZE
REDUCTION
NONERATOR
OAIPF
-------
The SRP orders govern these audits. Appraisals are conducted to evaluate general
compliance with orders; audits are more specific in nature and inspections ensure specific
compliance with specific requirements. Management and functional appraisals are media
specific and are conducted in three-year cycles.
The SRP has an unwritten open site policy with the State of South Carolina. State and EPA
inspections are conducted regularly on water, air. and waste. The State reviews the
location and design of all ground-water monitoring wells. An annual monitoring report is
available to the public.
The WIPP Certification team also conducts appraisals. Field-oriented appraisals are
conducted in addition to office/record-keeping audits. Examples of FY-86 audits include
the Burial Ground Survey (8/86) and WIPP Certification Survey (9/86). Several audits are
planned in FY-87.
All audits and reports are sent to the Manager of the Savannah River Plant Operations
office and the Manager of Dupont Operations. Audit reports are not sent to the State.
Audit information is also available through FOIA unless classified. Most material.
however, is unclassified. An example of a Defense Programs Waste Transfer audit is shown
in Figure 13.
E. ENVIRONMENTAL PROTECTION/EQUIVALENCY TO RCRA REQUIREMENTS:
I. High-Level Waste
Based on the materials presented by the SRP, the current level of protection for handling
HLW appeared to equal or exceed RCRA requirements for hazardous waste on several accounts:
tank construction, surveillance and inspection. Secondary containment was provided in the
form of carbon steel pipe, stainless steel pipe, or concrete encasement. All connections
in transfer lines were provided with secondary containment such as diversion boxes, waste
tank inlet risers, or evaporator enclosures. All tanks, piping and storage, are inspected
and otherwise qualified for exemption from Subpart F requirements.
A-108
-------
FIGURE 13
DEFENSE WASTE TRANSFER AUDIT FORM
(Page 1 of 3)
DO NOT 3EWOVE From 3RP
rtitnout Aooroval
g) Senior Supervisor must verify that up-to-date transfer procedure is
available.
h) Refer to OPSOL 241-F/H-55 and 241-F/H-56 for leak detection and
containment for waste transfers. If this transfer is not covered,
special handwritten and approved sections must be provided. (CnecK one
below.)
Covered in OPSOL 241-F/H-55 and 56
Leak detection and containment sections special procedure
provided
i) Indicate whether this transfer has potential for starting a siphon.
Refer to applicaoie transfer procedure specified in step A,i),g).
(Check one.)
Siphon present: Yes No If yes, provide section for stopping
a siphon.
Siphoning creaking section provided: Yes No
J) Record the transfer tank jet suction elevation and the latest sludge
elevation. If these elevation are within 1.5 ft. of each other, the
Jet should be raised to insure that sludge is not transferred.
Transfer Tank Sludge
Jet suction elevation Elevation
(NOTE: This is to ensure that sludge is not being processed in tne
evaporators, thereby releasing 90Sr.)
k) Record the following data for use oy waste Management Technology in
calculating supemate temperature and chemical composition resulting
from the transfer.
Maximum suoemate temperature (highest value of recorded supernate
points).
Transfer tank °C Receiver tank °C
1) Sample analyses (to be filled in oy waste Management Technology).
Transfer Tank Receiver Tank
Last Sample Calculated* Last Sample Calculated*
Date Date date Date
OH"
DM ^__^____
astep At2),b).
A-109
-------
FIGURE 13
DEFENSE WASTE TRANSFER AUDIT FORM
(Page 2 of 3)
00 NOT BEHOVE From SRP
without Approval
Technical Comoosition
Standard Calculated Composition within Limits
Limits8 in Receipt TankQ (Yes) "
NOj (Max)
OH"
OH"* NO!
8.3 M
•When N03 « 5.5 - 8.5M, Limits are: OH > 0.6 / OH * N02 * 1.1
* a When NO' a 2.75-5.5M, limits are" OH a 0.3M (min)
OH" * NOl » 1.1M (min)
When NOj » 1-2.75M, limits are: OH" » 0.1 x
When
OH" * NOj » 0.4 x
IM, limits are OH" » 0.01M (min)
(pH = 12)
(min)
If calculated composition is not within technical standard limits,
transfer should not DC made.
A-110
-------
FIGURE 13
DEFENSE WASTE TRANSFER AUDIT FORM
(Page 3 of 3)
00 NOT REMOVE From SSP
flooroval
B. RECEIVER TANK AIR PURGE REQUIREMENTS
1. Uson reouest from the waste Management Technology Area Supervisor,
measure and adjust receiver tank purge air flow oer OPSOL 241-FH-121.
2. Record adjusted purge air flow in the receiver tank.
Completed Oy
Date Time a.m.
C . SERVICE GROUP NOTIFICATION
1. Operating Senior Suoervisor (or designate) must inform applicable service
grouQ(s) of pending transfer. This aoolies to transfer routes with
exposed transfer Dicing or excavations near transfer piping. Signature
(and date) of service group Area Supervisor is required, and implies that
ne will inform his personnel.
Signature of
Service Group Area Supervisor or Engineer Date
Operating Senior Supervisor
Date
This approval can be obtained by phone dy the Senior Supervisor. If
contacted by phone, indicate here: (initials)
2. Have HP establish exposure rates in areas of exposed transfer oioing or
excavations near transfer piping.
3. Barricade exposed transfer piping or excavations near transfer piping
using yellow and magenta rope, set up portable sign to indicate transfer
in progress, and have HP affix radiation tag(s).
Radiation tag(s) attached: Yes NO
HP signature
Date
A-Ill
-------
2. TRU Waste
Current practices including retrievable TRU waste buried in concrete cylinders or concrete
pads closely resemble land filling activities and may therefore be subject to RCRA.
Ground-water monitoring is conducted although RCRA specified monitoring wells are not
used. The task force will further assess if hazardous constituents can adequately be
detected through the ground-water monitoring system currently in place. Further
information may be needed to make a final determination about the equivalency of TRU waste
handling to RCRA requirements. The SRP. however, has submitted a RCRA ground-water
monitoring program to South Carolina.
ACTION ITEMS:
The following documents have been requested from John Tseng (DOE).
• Hydrogeological studies.
• Monitoring Results.
• Plume Information.
• Diagram of the SRP -- defining mixed HL and TRU waste areas, process
streams: treatment and storage units that would be exempt under the
proposal.
• Ground Water Report.
• Index of Standard Operating Procedures.
• Audits and Reports:
- Examples of paper train for accountability
• SRP Orders Governing Waste.
• Waste-type definitions.
DOCUMENTATION:
Appendices:
I. Attendance Sheet
2. Agenda 12/2-12/3 SRP Tour
3. Principal Constituents of HLW
A-112
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4. Defense Programs Waste Transfer Audit
5. TRU Waste Data Briefing Package
6. Savannah River Hazardous Waste Management Program Briefing Package
7. Defense Waste Processing Facility Project Starters Briefing
Package
8, Interim Radioactive Waste Management Briefing Package
9. Tank Farm Operations Briefing Package
10. Determining the Composition of SRP Waste Briefing Package
11. Containment and Leak Detection Briefing Package
12. SRP TRU Waste Certification Program Briefing Package
13. Waste Management Operations - SRP September 1977
A-l!3
-------
Mixed Energy Waste Study (MEWS) Visit
U.S. Department of Energy
West Valley Demonstration Project
West Valley, New York
January 8, 1987
PURPOSE:
On January 8, 1987. the MEWS task force, accompanied by EPA Region II representatives, met
at the West Valley Demonstration Project (WVDP) site near West Valley, New York with
individuals from the Department of Energy's (DOE) Headquarters, DOE's WVDP Office and
DOE's contractor at WVDP, Westinghouse, and the New York State Department of Environmental
Conservation.
The purpose of the visit was for task members to gain a working knowledge of the WVDP.
SUMMARY:
Members of the DOE's West Valley Demonstration Project Office and the WVDP contractor
provided an overview briefing of the site with the majority of emphasis on high-level
waste (HLW). low-level waste (LLW), and transuranic (TRU) waste management practices.
Subject areas included HLW storage, characterization, vitrification, and treatment; LLW
storage, cement solidification, and disposal; TRU waste collection, assay, and storage;
environmental monitoring; general operation and control; and the audit system. A van tour
included stops at the environmental lab. the supernatant treatment system, the lag storage
building where TRU waste assaying is performed, and the chemical process cell. The tour
also included the cement solidification system, the liquid waste treatment system, and the
U.S. Nuclear Regulatory Commission (NRC) licensed disposal area.
In general, the current waste management systems at WVDP for HLW and TRU wastes from both
an administrative and technical standpoint are advanced and comprehensive with many areas
being apparently equal or superior to those required by RCRA. Specific weaknesses include
the lack of detailed RCRA chemical analyses of wastes (although WVDP had more chemical
information about their HLW than other DOE facilities visited) and the lack of RCRA
ground-water monitoring or waiver documentation. By the public law establishing the WVDP,
A-114
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NRC has an independent audit role. Other organizations (e.g., USGS, NYSDEC, NYSDOH, EPA
and OSHA) are involved in both cooperative and regulatory capacities. While the ultimate
disposal methods for HLW and TRU wastes appear excellent, they are not yet in place and,
in the case of HLW. are not yet a certainty.
REPORT:
A. FACILITY DESCRIPTION:
WVDP is located on 3.300 acres in a rural area about 30 miles southeast of Buffalo. New
York (Figure 1): the communities of West Valley. Riccville, Asford Hollow, and Springvjlle
are located within 5 miles of the project (New York State owns the property). WVDP is
operated and maintained for DOE by its contractor, Westinghouse.
The WVDP site comprises three basic operational entities: a former nuclear fuel
reprocessing plant now a DOE HLW vitrification demonstration project, an NRC-licensed
shallow-land LLW disposal area, and a former New York State licensed LLW burial ground
(now closed).
Between 1962-1966, a nuclear fuel reprocessing plant was licensed and built on the site by
a group of private companies operating as Nuclear Fuel Services, Inc. (NFS). The facility
was designed with an 80,000 square foot main process building which is 90-feet high and
has a ventilation stack which exhausts 200-feet above grade. It is composed of a number
of process areas and shielded cells in which remotely operated mechanical and chemical
operations were performed. The building also contains the fuel receiving and storage
facilities (spent fuel pool), which were used later to store spent fuel from other
commercial reactors, analytical laboratories, and a control room. Smaller structures
include an office building, a warehouse, maintenance shops, and a liquid LLW treatment
facility. The liquid LLW treatment facility consists of a building containing waste
treatment equipment and a peripheral system of lagoons and concrete lined interceptor
basins for effluent accumulation and batch pH adjustment and discharge.
In 1972. the plant was shut down to expand its capabilities and make modifications to
reduce radioactive effluents and radiation exposure to personnel. By 1976, the
modification cost estimates had increased from $15 million to over $600 million, and NFS
exercised its right under its development agreement with the State of New York to
A-115
-------
FIGURE 1
WVDP LOCATION
ONTARIO
NEW YORK
MICHIGAN
'Lansing
PENNSYLVANIA
OHIO
'Columbus
-------
surrender the responsibility for the site, including all wastes, to New York State.
This was done pursuant to Public Law No. 96-368 (enacted in 1980) which mandated the
demonstration of technology for solidification of roughly 560,000 gallons of liquid HLW
that was produced by NFS and stored on site.
Two types of liquid HLW are stored in waste storage tanks at West Valley. There are two
large carbon-steel tanks (8DI and 8D2) housed in separate concrete vaults. Tank 8D2
contains about 550.000 gallons of HLW from the Purex processing of uranium-based fuels and
Tank 8DI is a spare. There are also two smaller, stainless steel tanks (8D3 and 8D4)
which are housed in a common concrete vault. Tank 8D4 contains about 12,000 gallons of
acidic HLW from the Thorex processing of thorium-based fuels and Tank 8D3 is a spare.
The scope of the WVDP, as laid out in Public Law 96-368, is to:
I. Solidify liquid HLW in a form suitable for transportation and disposal;
2. Develop containers suitable for permanent disposal;
3. Transport solidified waste to the federal repository for permanent disposal;
4. Disposal of LLW and TRU waste produced; and
5. Decontaminate and decommission tanks, facilities, material, and hardware
used.
B. HIGH-LEVEL WASTES:
The majority of the HLW at West Valley resulted from the Purex extraction process used to
reprocess the fuel. This process utilized nitric acid to dissolve the spent fuel followed
by a solvent extraction process where the extractant was a 30% solution of tributyl
phosphate in a hydrocarbon solvent. This produced an acidic liquid HLW which was
pH-adjusted to reduce corrosion prior to storage in the carbon steel tank. This
neutralization process resulted in both settling and precipitation of the waste in Ihis
tank into two layers: I) an upper liquid portion, containing most of the radioactive
cesium, and 2) a dense solid (usually referred to as sludge) containing most of the
radioactive strontium, other fission products, and long-lived radionuclides that
constitute less than one-tenth of one percent of the total curies of radioactivity in the
tank.
A-117
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The Pure* HLW is stored in Tank 8D-2 which sits in a steel saucer and is located in its
own concrete vault. The concrete vault surrounding Tank 8D-2 provides complete secondary
containment (Figure 2}. Tank 8D-4, holding the Thorex waste, is co-located in a vault
with its spare tank, 8D-3. The inside bottom of the carbon steel tank has a grid work of
I-beams and girders which will make it difficult to remove the denser solid portion of the
waste (see Figure 3).
As part of the decontamination activities at the reprocessing plant, additional LLW and
possibly TRU waste is being added to these tanks. Figures 4 and 5 indicate WVDP progress
on the decontamination activities. Roughly 33% of the total square footage remains to be
decontaminated.
The radioactivity of the HLW owned by the State of New York at WVPD represents 2.5% of the
total DOE HLW inventory at Hanford, Idaho. Savannah River, and WVDP (Figure 6). The
estimated radioactivity at WVDP is 3.24 x I07 curies.
The overall plan calls for treatment of the supernatant, the upper liquid layer, followed
by treatment of the bottom sludges and the spent resins resulting from the supernatant
treatment. The supernatant treatment will involve the use of extensive liquid waste
treatment systems. There will be .cement solidification for disposal of the LLW generated
during supernatant treatment. The sludge and resin treatment will involve vitrification
using a melter and will result in the production of 300 glass logs (2' x 10') suitable for
HLW repository disposal.
1. Vitrification System
Thorex waste in 8D-4 and spent zeolites from 8D-I will be pumped into 8D-2 and mixed with
the washed sludge. The mixture will then be pumped to the vitrification system. The feed
delivery system routes the feed from the concentrator Feed Makeup Tank FMT) to the melter.
Glass is poured directly from the melter into a canister. Off-gases will be sent to a
submerged sand bed scrubber as well as remaining off-gas treatment systems. The filled
canisters will be cooled and stored. At a later date, the canisters will be welded and
decontaminated just prior to shipment. The canisters will remain in storage until a
NRC-licensed HLW repository has been opened.
A-118
-------
FIGURE 2
HIGH LEVEL LIQUID WASTE TANK
GRAVEL WATER
INJECTION LINE
CONCRETE
VAULT
STORAGE
FEED LINE
STEEL SAUCER
PERLITE BLOCKS
BOTTOM OF
TANK GIRDERS
(ENLARGED)
-------
FIGURE 3
TANK 8D-2 SLUDGE LAYERING - SECTIONAL VIEW
* 3m • *
924mm
Support
Girder
of Steel
25mm Plate
w
• Supernatant * • •
• * • • • •
• • • • .
Interface 1
• • * •
* • •
Interface 2
318mm I (Plates steel)
279mm 1
254mm f
Stay Bolts
38mm Steel Rods
Assembly
10-D
SS^^^WT
r
|^—Assembly
11-E
0123 4
=fi^5E=
Scale in Meters
-------
FIGURE 4
TOTAL FACILITY DECONTAMINATION STATUS
Total Calculated Square Footage Of Area-350,000
Square Feet
Clean Area
03 Working Area
f~l Remaining Area
FY82 WVNS Takeover
Status as of Oct. 1, 1986
-------
FIGURE 5
WVDP DECONTAMINATION ACTIVITY
10
NJ
Area
MSMShop
Extraction Cef Room
XC-1
XC-t
XC-S
Product Purification Cal
Analytical Lab
RadtoaohemMry Lab
Cowling Lab
Component Taat Stand Lab
Sample Storage Ce*
Plutonium Product Handing
Equipment Daconlamsiallon Room
ClKmleal Crana Room
Chomieal Proeoi* Col
Extraction Sampto AM*
RAM Equipment Room
Afcha Lab
UrankjmLab
Upper Warm Auto
Lovor Warm Ante
Uranium Loadout
Uanun Product C*l
Proeasa MoehaMcal Cat
Oanoral Purpoaa Col
Scrap Ramoval Room
Proeaat Cnamieal Room
Hot AcU Cat
Statu*
Comptot*
Complala
Future
Future
Complete
Complete
Complete
Compiata
Complete
Comptota
Compiata
In Progres*
Complete
Comptota
to Progress
Complala
Complete
Comptota
Comptota
Complete
Complete
Complete
Compute
In Prograit
In Progress
\n Progress
Comptota
Future
Q Complete
D In Progress
E2 Future
ALPHA LAB
ANA Gels
URAN LAB
C4J57WV005
-------
FIGURE 6
RADIOACTIVITY OF HLW THROUGH 1984
SRP
60.9%
WVDP
2.5%
HANF
32.1%
Site Curies
SRP 7.96 X 108
ICPP 5.90 X 10 7
HANF 4.20 X 108
WVDP 3.24 X 107
Total 1.31 X 109
-------
The HLW vitrification system planned at WVDP draws upon the same vitrification technology
as that developed by DOE for Savannah River's Defense Waste Processing Facility. WVDP's
vitrification system will be operational by late 1989.
2. Supernatant Treatment System (STS)
HLW supernatant from 8D2 and 8D4 will be pumped through a chiller and then through a
zeolite ion exchanger system to remove cesium. Some is returned to 8DI where it will be
intermixed with HLW sludge and run through the vitrification system. The remainder will
be routed to the liquid waste treatment system (LWTS). The Thorex waste in 8D-4 will be
blended with the washed sludge in 8D-2 and processed through the LWTS. Cesium-loaded
zeolite will be stored in Tank 8D-! until it is transferred to 8D-2 and then to the
vitrification system.
C. TRU WASTE:
DOE uses more stringent criteria for TRU waste at WVDP than at other DOE facilities. The
WVDP definition for TRU waste is:
• Radioactive waste containing alpha-emitting transuranic radionuclides with
half-lives greater than 5 years and concentrations greater than 100
nanocuries per gram.
TRU waste is currently being stored on-site until shipment off-site for disposal.
Although WVDP TRU waste cannot be disposed of at WIPP because it is a commercial TRU
waste. WVDP is using the WIPP Waste Acceptance Criteria for TRU waste packaging. The
original estimate of TRU waste expected at WVDP is only about 3% of the total waste
present. More specifically:
TRU Waste in Storage 23 cubic meters
Suspected TRU in Storage 135 cubic meters
Projected TRU Generation 300 cubic meters
A-124
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Most of this TRU waste will be contact-handled TRU, with only a small percentage being
remote-handled. Two methods of TRU waste assaying will be used: 1) a segmented gamma
scanner which uses a lithium-drifted germanium (GeLi) detector and 2) a 4Pi Passive
Neutron System using 78 BF3 probes and a polyemelene moderator. The final disposal
destination of this commercial TRU waste has not yet been determined.
D. MONITORING:
The ground-water monitoring program was expanded in 1986 to provide coverage of the
following waste management units:
• HLW tank complex
• LLW lagoon system
• NRC-licensed disposal area.
The monitoring network consists of five old wells (installed by USGS in 1982), nine new
wells, one seep well and a french drain outlet. All the wells are 80 to 90 feet in depth
and screened only once. These wells do not meet RCRA ground-water monitoring
requirements. These wells, the seep, and french drain will be sampled quarterly the first
year beginning December. 1986. and semi-annually thereafter. The monitoring parameters
include:
t Ground-water quality parameters: Cl, Mn. Na, SO." , Fe, phenols
• pH
• Specific conductance
• Total organic carbon
• NO3~
• Gross alpha
t Gross beta
• Specific gamma emitters, and
• the eight metals in the EPA drinking water criteria.
A-125
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A radiological monitoring program also exists at WVDP. Thirty-two wells, in addition to
those previously mentioned, are sampled semt-annually for gross alpha, beta, tritium and
pH.
E. AUDITS/ASSESSMENTS/OVERVIEW:
WVDP operates under the standard DOE management system. DOE headquarters issues orders
which are then interpreted and narrowed in scope to fit their particular situations by the
Idaho Operations Office. This process continues down to the procedures written by the
contractor for the plant operators to follow. By the public law establishing the WVDP,
NRC has an independent audit role. Other State and Federal agencies are involved in both
a cooperative and regulatory capacity.
F. SECURITY:
Security for the WVDP is maintained 24-hours a day by armed guards and chain-link fences.
G. RCRA EQUIVALENCY:
The areas where RCRA equivalency appears to be provided include the following:
• Excellent process control with regard to the treatment, transfer and storage
of HLW. This includes a computer-automated surveillance system.
• Extensive administrative controls for the tracking of waste from the waste
tanks through disposal for both HLW and TRU wastes.
• Excellent conceptual plan for qualifying HLW for disposal.
• Good security provided.
Areas where potential problems with RCRA equivalency include the following:
• Lack of or limited data on HLW & TRU waste quantity and characterization with
regard to hazardous components.
• Lack of RCRA ground water monitoring around HLW piping and storage (HLW
tanks) systems.
• Lack of sufficient independent audits.
A-126
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H. ACTION ITEMS:
None.
I. APPENDICES.
!. Agenda for EPA/DOE By-product Rule Task Force Meeting, January 8, 1987.
2. West Valley Demonstration Project - Project Overview presented to the
EPA/DOE By-product Rule Task Force, January 8, 1987.
3. External Interface Control Diagram.
4. An Introduction for the West Valley Demonstration Project, July 1981, DOE.
5. Thorex Waste Chemical Composition.
6. Acronyms used at West Valley.
7'. High-Level Waste Characterization at West Valley, Report of Work performed
1982-1985, by Larry E. Rykken Under Contract No. DE-AC07-81NE 44139.
8. West Valley Demonstration Project Candidate Mixed Hazardous Waste Streams.
prepared by DOE, Idaho Operations Office, October, 1986.
9. Letter to EPA from W.W. Bixby, Acting Director of WVDP on Tumulus Location
for Disposal of Project Low-Level Waste.
10. DOE's Finding of No Significant Impact - Disposal of Project Low-Level
Waste, West Valley Demonstration Project, West Valley, New York.
11. RTS Waste Streams Data Sheets, Rev. 4, Dated March 27, 1986.
A-127
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Mixed Energy Waste Study (MEWS) Visit
U.S. Department of Energy (DOE)
Waste Isolation Pilot Plant
Carlsbad, New Mexico
December 8, 1986
PURPOSE:
On December 8, 1986. the MEWS task force, accompanied by EPA Region VI representatives.
met with individuals from the Department of Energy's (DOE) Headquarters. Albuquerque
Operations Office. Waste Isolation Pilot Plant (WIPP) Project Office, and Westinghouse,
the WIPP site contractor. The purpose of the meeting was for task force members to gain a
working knowledge of the WIPP's mission, WIPP's transuranic (TRU) waste acceptance
criteria, and how TRU waste will be managed once the WIPP is operational.
SUMMARY:
The WIPP's mission is to demonstrate the safe shipment, emplacement, retrieval, and
disposal of TRU waste as well as to perform some experiments with high-level wastes. The
WIPP has developed a waste acceptance program which is designed to assure that only TRU
waste meeting certain waste form and packaging requirements are sent to WIPP.
The WIPP is located in a 3000-foot thick salt formation in southeastern New Mexico. There
is no known significant amount of ground water in the vicinity of the underground
facility. Nearby ground water is high in total dissolved solids, making it unusable for
humans, livestock, or irrigation.
Specific procedures have been developed on how TRU waste will be packaged for WIPP.
handled, and emplaced once received at WIPP. The procedures are specific to whether the
waste is contact-handled TRU (CH-TRU) or remote-handled TRU (RH-TRU).
In the areas of ground-water monitoring and oversight, RCRA equivalency has not been met
by the WIPP facility.
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By the time the WIPP begins waste operations, retrievably stored waste at the Idaho
National Engineering Laboratory (INEL) and other generating sites will account for 56% of
the total disposal capacity available at WIPP (6.4 million cubic feet). At the rate TRU
waste is currently produced (at about 0.23 million cubic feet per year), WIPP is only a
partial solution for TRU waste disposal.
REPORT:
A. FACILITY DESCRIPTION:
Authorized by Public Law 96-164 in 1977. WIPP's mission is to provide a research and
development facility to demonstrate the safe shipment, emplacement, retrieval, and
disposal of TRU wastes resulting from the production phases of DOE's nuclear defense
program. Experiments with defense high-level waste (HLW) will also be conducted for
developing and testing designs for future bedded-sak repositories. The HLW will be
retrieved at the end of the experiments which are scheduled for completion by the time
decommissioning is authorized. The WIPP was exempt from NRC regulation by Public Law
96-164. DOE is currently completing construction of the WIPP. WIPP is scheduled to begin
receiving wastes in October 1988.
The WIPP site is located approximately 26 miles southeast of Carlsbad, New Mexico over the
Permian Salt Basin. This 3000-foot thick salt formation, which starts about 850 feet
beneath the surface, extends laterally for many miles in all directions from the site.
The main storage area is near the vertical center of the salt formation (approximately
2150 feel beneath the surface).
Geological exploration and facility design began in 1975. After public hearings and
receipt of written comments, the final environmental impact statement was released in
October, 1980. In January. 1981, DOE issued the record of decision allowing the project
to proceed. Actual construction began by mid-1981, after the Bureau of Land Management
and DOE signed an agreement allowing use of the federally owned land. A preliminary
demonstration period which will involve non-radioactive (mock) waste will run from April,
1987 through September. 1988. A five-year demonstration period with actual TRU waste will
begin October. 1988. Because the WIPP will be the first bedded-salt, waste research and
development facility, the waste will be emplaced in such a manner that it can be retrieved
from its place of burial if removal becomes necessary. After tests and analyses are
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performed, a decision will be made on whether to leave the TRU waste em placed permanently.
The WIPP was designed with the expectation that permanent emplacement will be implemented
near the end of the five-year demonstration period, Retrieval could take up to 10 years
if the decision for retrieval is made.
Currently, the WIPP facility is composed of surface buildings, three shafts penetrating
into the earth's subsurface, and a series of underground storage rooms and tunnels. The
shafts connect the surface facilities to the underground areas and make it possible to
transport workers, equipment, mined salt, and fresh air. The underground facility
provides both a storage area for isolating wastes as well as a separate area for
conducting experiments.
Continuous mining equipment is used to excavate the bedded salt. This excavation carves
out a series of rooms for storing the waste. The rooms will be mined on an as-needed
basis during the operation of the facility. Prior to the receipt of any waste, the first
storage panel (a series of rooms) will be completely mined. While waste is being stored
in the first panel, the second panel will be mined. This process will continue as storage
panels are needed. Eight storage panels are planned with seven storage rooms each.
B. OVERVIEW OF FUTURE WASTE MANAGEMENT OPERATIONS:
The WIPP will handle both CH- and RH-TRU waste.
CH-TRU waste is defined as transuranic waste materials which have a dose rate at the
surface of the waste package not greater than 200 millirem per hour (mrem/hr).
RH-TRU waste is defined as transuranic waste materials which have a dose rate at the
surface of the waste package greater than 200 mrem/hr. The normal upper limit for WIPP
disposal will be 100 rem/hr. WIPP will accept waste with a dose rate in the range of 100
rem/hr up to 1000 rem/hr as long as the quantity of waste within this range does not
exceed 5% of the total volume of the RH-TRU waste at WIPP.
Currently, numerous DOE facilities generate TRU waste (Figure I). The largest TRU waste
generator is DOE's Rocky Flats Plant (RFP). Currently, RFP packages CH-TRU waste in
55-gallon drums or corrugated metal boxes and then ships it to the Idaho National Energy
Laboratory (INEL) by rail. Although INEL is not the only facility to store TRU waste
A-130
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FIGURE 1
DOE FACILITIES GENERATING TRU WASTE
1. LLML. Lawrence Livermore National Laboratonea. CA
2. NTS. Nevada Tatt Sit*. NV
3. SNLA. Sendia National Laborato'iea, Albuquerque. NM
4. LANL. Lot Alamot National Laboratories. NM
5. IMEL. Idaho
0. Mound Plant. Miamiaburg, Ohio
7. Battalia Memorial Inatituta. Columbua, Onto
8.
a
10
11
12
13
14
Argonna National Laboratorlat, Chicago, It
Battls Atomic Power Lab, P«nn»ylvanla
OR Nat Lab, Oak Ridge National Laboratory. TN
Savannah River Plant, GA
flocky Flata Plant, Colorado
WIPP, Watte laolatlon Pilot Plant, Carltbad. NM
Hanlord Site, Rlchland, WA
-------
(e.g., Hanford and Savannah River Plant (SRP) also do), INEL has the largest inventory of
stored TRU wastes. In the past, INEL would store these shipments of TRU waste on asphalt
pads, cover the containers with plastic once the waste containers were stacked to a
desired height, then cover the plastic with a "removable" layer of earth. Currently, INEL
stacks the containers on concrete/asphalt pads with curbing under roofs. Almost all of
the retrievably stored TRU waste is destined for disposal at the WIPP (Figure 2).
The WIPP will start actual waste handling activities in October, 1988. All waste, prior
to shipment to WIPP. must be certified by the generator or storage facility as meeting
certain pre-established criteria called the Waste Acceptance Criteria (or WIPP/WAC).
Specific certification criteria have been established for CH- and RH-TRU waste. The
general elements of the criteria include:
Waste Form Requirements
IMMOBILIZATION
LIQUID WASTES
PYROPHORIC MATERIALS -
EXPLOSIVES OR COMPRESSED
GASES
NUCLEAR CRITICALITY
ACTIVITY
PU-239 EQUIVALENT
ACTIVITY
HAZARDOUS WASTE
WASTE CONTAINERS
WASTE PACKAGE WEIGHT* -
powders, ashes, and similar waste materials shall be
immobilized if more than 1 % of waste matrix is smaller
than 10 microns in diameter or if more than 15% is below
200 microns in diameter
no more than I % free liquid
no more than 1 %
none
the fissile radionuclide content shall not exceed certain
values
waste package shall not exceed 1000 Pu-239 equivalent
activity
none are allowed in the waste package, unless they exist
as co-contaminants with TRU waste
Waste Package Requirement
non-combustible, 20-year design life, meet the structural
and design requirements for Type A packaging, see 49 CFR
I73.4l2(b)
CH-TRU package assemblies shall not exceed 25.000 ibs
RH-TRU packages shall not exceed 8.000 Ibs
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FIGURE 2
FUTURE TRU WASTE MANAGEMENT
IAWNCMCC
UVCftMOftE
UJ
OJ
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WASTE PACKAGE SIZE*
WASTE PACKAGE HANDLING
LABELING
THERMAL POWER
SURFACE DOSE RATE
SURFACE CONTAMINATION -
RELIEF FOR GAS
GENERATION
DATA PACKAGE/
CERTIFICATION
* These criteria are related to the
facility,
CH-TRU package assemblies shall not exceed 12'x 8'x 8.5'
RH-TRU packages shall not exceed 26" in diameter with a
maximum length of 10'
both CH- and RH-TRU packages shall be equipped with
special devices to facilitate handling
shall be labeled with a standardized form to include the
package ID. number, weight information, and radionuciide
content
RH-TRU packages are limited to a maximum of 300 watts.
The thermal power for an RH-TRU package shall be listed on
the data package
CH-TRU no greater than 200 mrem/hr
RH-TRU no greater than 100 mrem/hr
no greater than 50 picocuries/100 cm for alpha-emitting
radionuclides and
450 picocuries/100 cm for beta-gamma-emitting
radionuclides
for short term, during transportation and emplacement, all
waste packages shall provide appropriate gas relief
shall be transmitted in advance of shipment
design limitations at the WIPP
Each facility which will be shipping TRU waste to the WIPP must have an approved
waste certification plan before any of its waste will be accepted at the WIPP. The
waste certification plan must be approved by DOE's Waste Acceptance Criteria
Certification Committee (WACCC). Once approved, there will be periodic audits at
each generator facility to ensure that the approved waste certification plan is being
followed. Any problems noted during this audit must be resolved before any future
waste from the facility will be accepted at the WIPP. Facilities with approved
certification plans are currently certifying their waste and storing it until the
WIPP begins accepting waste.
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CH-TRU waste will be received first; RH-TRU waste will follow in 1989. The CH-TRU
wastes, packaged in 55-gal/on metal drums and/or other sturdy containers meeting
specific structural requirements, design conditions, and dimensions, will be
transported either by trucks or railcars to the W1PP. Remote-handled TRU waste, by
far the smaller amount due at the WIPP. will arrive in shielded casks which will
contain the waste container. When the shielded cask arrives at the WIPP, it will be
carefully inspected and all of its shipping documents checked. The cask will then be
transported into the remote-handling portion of the Waste Handling Building, an area
separated from the contact-handled waste area. The cask is then isolated in a
special room and opened to remove the waste container, which will be taken to the
"hot cell" where it will be identified and inspected. The container will then be
placed in a facility cask for transport to the underground storage room.
Once in the storage room, the facility cask will be placed in a machine that removes
the waste container and emplaces it into a pre-drilied hole in the storage room wall.
After the container is emplaced, a shield plug will be em placed and the facility cask
reused.
The storage process for contact-handled waste is quite different. The waste packages
will arrive at the WIPP site in me specially designed transuranic package
transporters called TRUPACTS. These TRUPACTS will hold either 55-gallon metal drums
banded together in "six-packs" or various-sized metal boxes. The TRUPACTS have been
designed to satisfy all federal regulatory Type B package requirements of the
Department of Transportation and. therefore, tested to withstand transportation
accident conditions. One TRUPACT will be transported per truck and two per railcar.
When the TRUPACT arrives at the WIPP. it will be inspected for damage and
contamination. It will then be taken to the contact-handling part of the Waste
Handling Building where it will go through the air lock. The TRUPACT will be opened
and the waste packages inside removed and inspected again, prior to being transferred
to the underground storage area. Once underground, a forklift will stack the waste
packages ("six-packs" will be stored three high). This final location will then be
entered into a computer so that every package will be traceable.
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The WIPP storage areas have been planned and designed to accomodate 6.4 million cubic
feet of TRU waste. By the end of 1988, there will be an estimated 3.5 million cubic
feet of retrievably stored TRU waste at INEL and other DOE waste management sites.
At the current TRU waste production rate, about 0.23 million cubic feet per year, and
the expected emplacement rate at WIPP of 0.3 million cubic feet per year (limited by
transportation), there will quickly be a capacity problem at WIPP.
An integrated work-off plan is being developed to methodically accommodate newly
generated waste and the retrievably stored waste during the projected 25-year
operating life of the WIPP.
C. MONITORING/OVERSIGHT/EQUIVALENCY TO RCRA REQUIREMENTS:
I. Monitoring
A Radiological Baseline Program is currently underway at the WIPP. Its goal is to measure
background levels of radiation and radionuclides around the WIPP prior to acceptance of
waste. This program includes sampling and analysis to obtain a baseline for the
atmospheric, terrestrial, hydrologic. biota, and ambient radiation. An Ecological
Monitoring Program monitors and evaluates the impacts of the WIPP construction (and future
operations) on the ecosystem. This program includes environmental photography, soil
sampling and analysis, soil microbiotic studies, vegetation surveys, air and water quality
monitoring, vertebrate censuses, and meteorological monitoring.
The hydrology around WIPP has been extensively studied and is still undergoing
characterization. Results indicate that while there are several water-bearing zones
within the rocks (Rustler Formation) that overlie the salt deposits, none of these produce
large quantities of usable ground water. The Rustler Formation is located about 1000 feet
from the surface, about 1100 feet above the underground site. Studies have further shown
that there are no natural communication paths in the 1100 feet between these water-bearing
zones and the horizon in which wastes will be emplaced. Since the nearest ground water to
the waste horizon is 1000 feet above, no ground-water monitoring within the waste horizon
is planned. DOE considers ground-water monitoring unnecessary and argues that this would
compromise the integrity of the facility. Although the site may qualify for a waiver from
ground-water monitoring, no such application has been made by DOE.
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Near-surface ground waters will be monitored through the life of the facility in order to
evaluate operational impacts and to characterize long-term ground-water trends.
2. Oversight/Audit/Inspection Procedures
The WTPP/WAC Program will conduct periodic audits of DOE facilities generating TRU waste
for disposal at the WIPP. These audits will ensure that the waste generators are
maintaining a high level of quality in the waste certification program. The expected
result is that all wastes that are shipped to WIPP will be within the restrictions of the
waste acceptance criteria.
At DOE Headquarters, the Assistant Secretary of Environment, Safety and Health oversees an
environmental audit of the WIPP Field Operations annually. At the WIPP, the Albuquerque
Operations Office conducts audits and appraises the contractor (Westinghouse). The
Headquarter's audits are independent of the Operations Office audits. The audits and
appraisals are conducted to evaluate compliance with DOE orders. All audits and reports
are sent to the Project Manager's Office and the Westinghouse Project Manager.
The audits performed by DOE do not monitor for compliance with all applicable RCRA
requirements. These are not independent audits. On both these counts. DOE's audits
cannot be considered equivalent to RCRA inspections.
3. Equivalency to RCRA Requirements
Containers of TRU wastes will be certified to be in compliance with the WIPP/WAC prior to
shipment to WIPP. This certification will be verified by audits and spot checks at the
shipper's facility. The certification and data package for every container will be
checked at the WIPP prior to emplacement. No physical sampling or inspection which
requires opening containers will be performed at the WIPP.
This approach is inconsistent with RCRA because the owner or operator who treats, stores.
or disposes of off-site waste must inspect and, if necessary, analyze each hazardous waste
shipment received at the facility to determine whether it matches the identity of the
waste specified on the accompanying manifest and shipping paper. Lack of waste analysis
and waste identification raises the question of whether or not the DOE will be able to
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properly segregate potentially incompatable reactive wastes within the salt rooms. DOE
argues that sampling the waste, as required by RCRA, violates the "as low as reasonably
achievable" principle of radiation protection, commonly referred to us ALARA.
DOE also indicated that the Waste Acceptance Plan had recently been amended to allow
"some" free liquids in waste containers if the generator could demonstrate there was a
sufficient amount of absorbents added to completely absorb all of the liquid waste. The
RCRA requirements for no free liquids does not make allowances for the use of absorbents.
ACTION ITEMS:
Handouts from Ed Hess' discussion on transportation were requested.
DOCUMENTATION:
I) Waste Isolation Pilot Plant Handout
2) WIPP Certification Criteria
3) TRU Waste Acceptance Criteria for the WIPP - September 1985
4) Environmental Activities at WIPP
5) Sandia Technology Handout
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APPENDIX B
STATE REPORTS
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MEWS TASK FORCE
Meeting with State of California
Department of Health Services
Sacramento, California
January 16, 1987
PURPOSE:
On January 16, 1987, members of the MEWS task force met with Laura Yoshii and other
personnel from the Toxic Substances Control Division of the California Department of
Health Services (DHS) in Sacramento, California (Appendix I lists attendees). The purpose
of the meeting was to get the State's perspective on the Department of Energy's (DOE)
proposed option to exempt high-level (HLW) and transuranic (TRU) mixed waste management at
DOE facilities from the RCRA hazardous waste program.
SUMMARY:
The Lawrence Livermore National Laboratory (LLNL), operated for DOE by the University of
California, is the main TRU waste generator in the State. RCRA hazardous waste management
oversight for LLNL is conducted out of the Emeryville District Office of the Department of
Health Services. The State also issues air quality and water discharge permits at LLNL
via regional air and water control boards. Some RCRA violations (mainly administrative)
have been noted by the State at LLNL. Enforcement at LLNL is somewhat sensitive since the
University of California is also an arm of the State government. The State declined to
provide information on RCRA violations at LLNL because negotiations are in progress.
Personnel at the DHS headquarters in Sacramento were not familiar with TRU waste
management activities at LLNL, but thought the Emeryville office would be. Much of the
meeting time was taken up by MEWS personnel giving DHS personnel a description of TRU
waste, low-level waste (LLW), and hazardous waste management at LLNL, as observed during
the MEWS visit there the previous day.
B-l
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Laura Yoshii stated that while no decision has been made, DH5 would probably seek mixed
waste authorization. The Radiation Health Office, also a part of DHS, has expressed an
interest in taking the lead for mixed waste authorization. She did, however, question the
State's capabilities for overseeing TRU waste management at LLNL, and any other DOE
facilities in California (Rockwell.International has a fuel de-cladding operation in
Conoga Park that may also generate TRU).
Ms. Yoshii expressed conditional support for the DOE Option but wanted to learn more about
the Option's implications before offering complete support. In any event, the State of
California wants some oversight role at DOE facilities. It is not yet clear which State
government unit would conduct such oversight.
ACTION ITEMS:
None
DOCUMENTATION:
Appendix I - List of attendees at meeting with California DHS
January 16. 1987.
DISTRIBUTION:
MEWS Distribution List
Jeff Zelikson - Region 9
B-2
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APPENDIX I
LIST OF ATTENDEES
EPA/Project MEWS
John Lehman
Dan Bodien
Ray Clark
Burnel! Vincent
State of California
Laura Yoshii
Caroline Cabilas
Jan Smith
Florentine Castillon
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MEWS TASK FORCE
Teleconference with Slate of Colorado
January 19. 1987
PURPOSE:
On January 19. 1987, members of the MEWS task force, along with a representative from EPA
Region VIII, spoke with officials from the State of Colorado (Appendix I lists attendees).
The purpose of the meeting was to get the State's perspective on the Department of
Energy's (DOE) proposed option to exempt high-level (HLW) and transuranic (TRU) mixed
waste management at DOE facilities from the RCRA hazardous waste program.
SUMMARY:
State officials are doubtful about the workability of the DOE Option at Rocky Flats Plant
(RFP), primarily because the history of the contractors' performance is not encouraging.
The waste streams merge and split in a complex fashion, impeding the identification of
wastes to be covered by the option and complicating the determination that RFP is abiding
by terms of the agreement. The State has invested considerable resources in understanding
the waste management practices and problems at RFP; the incremental resources to be
"saved" by the DOE option are not consequential. They have the expertise and can obtain
lab services as needed to adequately regulate TRU waste management at RFP.
REPORT:
After briefly describing the DOE option and MEWS task force objectives, the (ask force
chairman asked if the State was aware of facilities, other than RFP, which might be
affected. Although there are several low-level mixed waste handlers in the State, no one
other than RFP would be affected by the DOE Option.
B-4
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The State, referring to the agenda originally proposed by DOE for Project MEWS, asked
about the current estimated date for the promulgation of an EPA rule. They were gratified
to hear that no decision had been made to propose a rule; the State has many reservations
regarding DOE self-regulation. They asked whether DOE was attempting to demonstrate
validity of the option or simply providing EPA with the information needed to make the
case. The task force responded that it was the latter.
The State also expressed concern that DOE's approach to monitoring solely for radioactive
indicators does not assure the absence of hazardous constituents. The State does not
believe that solidification of solvent-containing wastes will effectively bind all
hazardous constituents against subsequent release.
Resources to monitor HLW/TRU waste may be a near-term issue for the State. DOE spent $2
million on preparation of the RCRA Part B for hazardous waste, and reviewing it will be a
major effort. In the long run, however, the State is confident that they will have enough
personnel and enough resources in the chemistry lab to provide proper oversight for TRU
waste management at RFP. If State labs cannot handle radioactive samples, the Department
will contract for the service. Health physicists are available now, on loan, from the
divisions and could be hired if full-time need was justified.
The State also expressed concern about the complexity of identifying which waste streams
at RFP would be included in the exemption. The State's understanding of the hazardous
waste management practices at RF has grown considerably over the last few years.
Considering that the known inventory of prior and existing waste streams has grown from 14
in 1985 to 2200 at present, they are unsure how a RCRA inspector will know which waste
streams are not exempt after the DOE option is implemented. Recycling and burning and
blending practices have been particularly tricky to monitor.
The facility has not withheld information from the state; information contained in the
facility's RCRA Part B form and any technical data from RFP has been designated as
Unclassified Controlled Nuclear Information by the DOE. The designation does not require
formal clearance for access because UCNI data is fully available to public agencies. It
is not. however, available for release to the general public.
B-5
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This was the first time the task force had encountered this classification. The State was
instructed not to forward any UCNI or otherwise restricted information for task force use
since all task force background materials would be publicly disclosed.
The State was aware that the Nevada Test Site (NTS) was no longer receiving TRU wastes
from RFP. They were also aware that the waste shipments were stopped because NTS lacked
RCRA "status", but denied that the State (or Region VIII) had ever suggested the shipments
be curtailed. It is possible that Nevada requested the termination, but Region VIII and
Colorado agreed that shipment of TRU waste to the NTS was environmentally safer and should
not be curtailed because of NTS's confusion over RCRA procedures.
The State was not aware that classified TRU wastes were separately handled in "Greater
Confinement Disposal" at NTS.
B-6
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ACTION ITEMS:
State expressed desire to be kept informed of results of MEWS briefings and reports.
DOCUMENTATION: No documents were exchanged.
DISTRIBUTION:
J. Solenski
P. Bierbaum
N. Mueller
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EPA/OSW
John Lehman
Betty Shackleford
Burnell Vincent
EPA/OWPE
Tony Baney
EPA/REGION X
Dan Bodien
EPA/REGION VIII
Nat Mueller
State of Colorado
Charlie Brinkman
Joan Solinski
Phil Bierbaum
APPENDIX I
LIST OF ATTENDEES
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MEWS TASK FORCE
Meeting and Teleconference with
State of Idaho, Division of Environment
Boise, Idaho
December 4. 1986
January 22. 1987
PURPOSE:
On December 4. 1986, a member of the MEWS task force met with personnel from the Division
of Environment, Department of Health & Welfare of the State of Idaho and on January 22,
1987. additional discussions were held by telephone (Appendix I lists attendees). The
purpose of the discussions was to get the State's perspective on the Department of
Energy's (DOE) proposed option to exempt high-level waste (HLW) and transuranic (TRU)
mixed waste management of DOE facilities from the RCRA hazardous waste program.
SUMMARY:
The State of Idaho currently does not have RCRA authorization but is working on its
application which should be ready in early 1987. The State does not anticipate
authorization until the end of 1987, at the earliest.
The State has little information with respect to HLW or TRU waste generated or stored at
the INEL site. The State meets with the DOE twice yearly (May and October) to discuss
environmental problems.
With regard to problems at the site. Bob Funderburg stated that the State is notified of
all press releases made available to the public. Bob said that over the past five years.
he can only remember two minor incidents with respect to environmental problems.
B-9
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Mark Torf estimated that INEL employs 10.000 workers, making DOE the largest employer in
the State. He added that the main emphasis of the newly elected administration will be in
relation to jobs and that any action taken by EPA or OOE resulting in loss of employment
at INEL would cause problems.
The State emphasized the need for oversight on either the State or Federal level. They
expressed iheir concern about DOE's current self-regulatory program.
Mark and Bob were interested in how the task force worked and wanted to be informed about
MEWS's progress, However, they wanted to reserve any comment they may have about the DOE
option for a later date.
The State is interested in obtaining information from INEL about the following issues:
• How are HLW and TRU waste generated?
• What hazardous wastes are mixed with the HLW and TRU waste?
• What is the potential for spills and how are spills handled?
With the assumption that the RCRA mixed waste program would be authorized.
Mark Torf stated that he did not believe that the inclusion or exclusion of
HLW and TRU waste would change the amount of resources of required for
INEL. If the Stale encounters problems with resources such as technical
assistance or laboratory support, Mark indicated that the State would find
a way to get the job done. Mark also stated that the State wants to
oversee HLW and TRU waste management at INEL.
ACTION ITEMS:
Keep State informed about direction of task force and provide information
about INEL obtained from DOE.
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DOCUMENTATION:
Appendix I - List of participants in discussions with Idaho Department of
Health and Welfare. Division of Environment, December 4. 1986 and January
22. 1987.
DISTRIBUTION:
MEWS Distribution List
8-11
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APPENDIX I
LIST OF ATTENDEES
EPA/Project MEWS
Danforth G. Bodien
State of Idaho
Steve Provant
Mark Torf
Bob Funderburg
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MEWS TASK FORCE
Meeting with New Mexico State
Environmental Improvement Division
Sante Fe. New Mexico
January 12, 1987
PURPOSE:
Members of the MEWS task force and a representative from Region VI met with officials from
the State of New Mexico in Santa Fe to explain the overall mission of the task force and
to solicit the State's views on the issues surrounding mixed waste management by the
Department of Energy (DOE).
SUMMARY:
The MEWS Task Force presented a brief history of the issues including: LEAF v Model, the
by-product rulemaking, the reorganization of DOE to form a new Office of Assistant
Secretary to deal with health, safety and environmental issues, and the November. 1986.
advancement of new proposals by DOE to exempt the management of high-level waste (HLW) and
Transuranic (TRU) waste by DOE from RCRA waste management standards.
In the state of New Mexico. DOE owns three facilities [Waste Isolation Pilot Plant (WIPP).
Sandra and Los Alamos] where radioactive wastes are managed. Although Sandia and Los
Alamos both have research reactors. HLW spent fuel rods are shipped out-of-state for
processing. TRU wastes are currently being processed and stored at Los Alamos prior to
shipment to the WIPP. TRU wastes may also be generated at the White Sands Proving Grounds
as a result of certain Strategic Defense Initiative (SDI) experiments.
The State's relations with DOE were characterized as "strained" due to: (1) the State's
view that DOE's radioactive waste management practices are less stringent than those
imposed by the Nuclear Regulatory Commission on commercial facilities, (2) DOE's
propensity to miss agreed-on deadlines for completion of environmental projects, (3) DOE's
B-13
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practice of not always following its own internal orders, and (4) DOE's secretive nature.
The State did express its general concurrence with the Waste Acceptance Criteria for WIPP.
However, the State indicated that comprehensive decisions could not be made until more
information about waste volumes, characteristics, and management practices was made
available.
REPORT:
To date, the State of New Mexico has not been involved in the regulation of radioactive or
radioactive mixed waste management at Sandia or Los Alamos. The State believes that it
has the legal authority to regulate these wastes under current state statutes. The State
also expressed reluctance at this time to take on any additional regulatory burdens. This
is due to a temporary employee shortage brought about by reduced revenues from the
production of oil and natural gas (EPA has grouped the radioactive mixed waste program in
Cluster Three of state authorization and states are required to apply for this Cluster by
July. 1988).
In New Mexico. DOE owns three facilities which could be impacted by any decision on HL and
TRU waste management. Sandia National Laboratory generates a small amount (three to five
drums per year) of TRU wastes which are sent to Los Alamos for processing and storage.
Los Alamos generates and manages TRU and radioactive mixed wastes. The TRU wastes are
being processed to the acceptance criteria for the WIPP. Some radioactive wastes are sent
to other DOE facilities for processing and disposal while low level wastes will continue
to be disposed of on-site.
The WIPP is an underground disposal facility located in a salt formation which is designed
to receive currently generated and backlogged inventories of TRU and mixed TRU wastes.
The Stale has limited veto power over WIPP development and operation but it has the right,
acquired in a civil proceeding, to inspect out of state DOE generators of TRU waste
destined for the WIPP. This insures compliance with the acceptance criteria. The WIPP is
scheduled to receive waste beginning in October of 1988.
In 1983, DOE agreed to complete hydrogeologic studies on the WIPP by 1986. This has been
delayed until 1989. DOE is required to comply with 40 CFR Section 191 regulations
concerning high-level and TRU wastes but has told New Mexico that it does not have to
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compJy unlil disposal (backfilling) occurs. DOE argues that until disposal takes place,
the WIPPP is a storage project and is not subject to Subpart B. Both of these delays are
distressing to State officials and. in their view, are examples of a disturbing pattern.
The State did not have an opinion on the MEWS project objectives or DOE's HL or TRU waste
management practices. The newly elected State governor and his staff have not had the
opportunity to review the issues. Nonetheless, Mike Burkhart, the new BID Director, said
the State would be concerned about the loss of State options if the DOE option were
adopted.
The State's waste management professionals indicated that they had too little information
on the volumes and types of wastes generated and DOE's waste management practices to
express any opinions. This lack of information was blamed on the DOE's secretive nature
and use of executive privilege to block information flow. DOE releases decision documents
which cite other "draft" reports as the basis for a decision. However, those draft
reports are not releasable. Therefore, the validity of the decision cannot be judged or
challenged. The State could not provide many specifics about the management of HLW and
TRU wastes at the DOE facilities outside of (he WIPP. The State was concerned about past
on-site disposal practices for a variety of RCRA, PCB, TRU wastes and other wastes at Los
Alamos.
ACTION ITEMS: None.
DOCUMENTATION: No memoranda or documents were exchanged.
DISTRIBUTION:
Michael Brown
Jim Channel!
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APPENDIX I
LIST OF ATTENDEES
EPA/ PROJECT MEWS
Jack Lehman
Ray Clark
Tony Baney
EPA REGION VI
Marc Sides
STATE OF NEW MEXICO
Jim Channel
Kirk Jones
Mike Burkhart
Mike Brown
Richard Mitzelfelt
Jack Ellnnger
Boyd Hamilton
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MEWS TASK FORCE
Meeting with the State of South Carolina
Department of Health
and Environmental Control
Columbia, South Carolina
December 4. 1986
PURPOSE:
On December 4. 1986. MEWS task force representatives and EPA Region IV representatives met
with the State of South Carolina's Department of Health and Environmental Control (DHEC)
Commissioner Bob King and staff (Appendix I lists attendees). The purpose of the meeting
was to discuss the Department of Energy's (DOE) option to assess methods of handling
high-level (HLW) and transuranic (TRU) mixed waste in the context of affording an
equivalent or superior level of protection than RCRA requirements prescribe.
SUMMARY:
The State of South Carolina's DHEC stated that they preferred to have as much control over
the Savannah River Plant (SRP) as possible. Upon consideration of DOE's proposed option,
DHEC stated that oversight or regulatory control should be mandatory at SRP. They stated
that they preferred Slate and EPA oversight, with DHEC taking the lead.
In general, DHEC expressed confidence in the adequacy of SRP's management of HLW and TRU
mixed waste that is intended to be sent off-site. DHEC stated that they currently do not
have jurisdiction over the radiological components of HLW or TRU waste at SRP. Also, DHEC
expressed concern about their limited capability and expertise to handle these wastes.
DHEC stated that it may take some time to build their capability. In conclusion. DHEC
urged that HLW. TRU wastes and by-product definitional differences be resolved so that the
program could move forward.
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REPORT:
The State of South Carolina's Department of Health and Environmental Control (DHEC)
provided background information concerning formal agreements that may affect DOE's
proposed option. Several documents currently exist. In April 1985, DHEC signed a
memorandum with SRP which stated that SRP would be treated in the same manner as a private
facility. In addition, DHEC described a letter from the Department of the Navy which
stated that no submarine hull disposal is proposed at SRP. Through a Memorandum of
Understanding (MOU) with SRP. the State does provide oversight of low-level radioactive
waste that is mixed with hazardous waste.
DHEC's reading of the July 3, 1986. Federal Register notice concerning mixed waste did not
include HLW and TRU waste. They stated that their interpretation of the Federal Register
notice was that it addressed only low-level radioactive mixed waste.
Currently, DHEC does not exercise control over mixed HLW or TRU waste. However, it does
exercise jurisdiction over air, water and Resource Conservation and Recovery Act (RCRA)
permits at SRP. DHEC understood that without the by-product definition, HLW and TRU mixed
waste would be encompassed by the Federal Register notice.
As a matter of policy. DHEC's Deputy Commissioner expressed preference in having as much
control over SRP as possible. In consideration of DOE's proposed option, DHEC stated that
independent oversight and/or regulatory control should be required at SRP. They
emphasized the need for State and EPA oversight, with their preference for DHEC taking the
lead.
DHEC slated that jurisdiction over radionuclides has typically been handled by the federal
government, as is mandated by the Atomic Energy Act (AEA) and South Carolina State law.
Representatives from DHEC's Radiation Health (RH) Division stated that SRP has done an
acceptable job of off-site radiological control.
When DHEC's RH Division was asked about their ability to manage the HLW and TRU mixed
waste program at SRP, they responded that they currently did not have the personnel.
procedures, or expertise to handle the program. They stated that it would take time to
build that capability. DHEC-RH expressed concern that if HLW and TRU mixed waste was
regulated by their division, they would require an account of all processes involved in
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generation of the waste streams and that there may be some concern over those processes
that are classified. DHEC stated that if the program fell under RCRA's jurisdiction, only
the hazardous waste component would be regulated.
DHEC also raised concern that some mixing of low-level waste with HLW and TRU waste may
have occurred in the past. They expressed concern that DOE may not have adequately
controlled substances that were mixed with HLW and TRU mixed waste.
The meeting concluded with a discussion of the definition of HLW. TRU. and by product
material. DHEC urged that definitional differences be resolved so that the mixed waste
program could move forward.
DHEC referred to Dan Reicher from the National Resource Defense Council (NRDC) as a
knowledgeable contact on this subject, stating that he had recently been involved in legal
proceedings on this issue.
ACTION ITEMS:
Region IV will obtain a copy of the documents listed below.
DOCUMENTATIONS:
April 5. 1985, Memorandum of Understanding between DHEC and SRP concerning
treatment as a private facility.
Letter from Department of the Navy concerning the disposal of spent
submarine hulls.
Memorandum of Understanding between DHEC and SRP concerning low-level
radioactive waste.
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APPENDIX I
LIST ATTENDEES
EPA/PROJECT MEWS
Jack Lehman
Lynn Pirozzoli
EPA/REGION IV
Richard Campbell
John Dickenson
SC/DHEC-RA
Heyward G. Shealy
SC/DHEC.RAD. HEALTH
Virgil R. Autry
Pearce O'Kelley
SC/DHEC-SOLID & HAZ. WASTE
Hartsill Truesdale
Lewis R. Beckenbaugh
Robert W. King, Jr.
David Wilson
Eric Gleason
SC/DHEC-INDUSTRIAL WW
Alan Coffey
Burl Ruiler
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MEWS TASK FORCE
Meeting with State of Tennessee
Tennessee Department of Health and Environment
Nashville. Tennessee
December 4, 1986
PURPOSE:
Members of the MEWS task force met with Tom Tiesler. director of the State Solid Waste
Management Division and other personnel from the Solid Waste Radiological. Health, and
general counsel offices of the States Department of Health and Environment (TDHE), General
Counsel of the State's Department of Health and Environment (TDHE). and with
representatives from EPA's Region IV. The purpose of the meeting was to discuss the DOE
option, to understand the State perspective on high-level waste (HLW) and transuranic
(TRU) waste management oversight and to discuss State perception of those operations at
Oak Ridge National Laboratory (ORNL).
SUMMARY:
The task force presented a brief description of EPA's Mixed Energy Waste Study (MEWS)
objectives and progress and requested the State's general reaction to DOE's suggested
option to the proposed by-product definition. State attendees were all basically familiar
with DOE's November 1985 proposal on the definition of by-product material, and offered
suggestions and cautions regarding conduct of Project MEWS. The task force raised the
issues listed in Appendix I!.
While there were several misgivings and caveats expressed at the meeting, there were no
strong "stopper" issues identified. The following general reactions were presented by the
State:
DOE's track record does not fully support a blanket exemption
of either mixed high-level waste (HLW) or mixed transuranic
(TRU) waste management from RCRA requirements.
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• There are philosophical objections to self-regulation by any
agency.
• There could be a problem with establishing the precedent that
Federal agencies can use Section 1006 to find "inconsistency
by duplication".
• Limited exemptions are preferable to broad-based exemptions.
REPORT:
State personnel identified several concerns regarding the DOE option. They urged EPA to
focus on the workability and clarity of the delineations between HLW and low-level wastes
(LLW) and between TRU and other mixed wastes. The definitions should be tested on actual
waste streams encountered at DOE facilities during the site visits. They suggested that
it is not sufficient that a theoretically correct definition be in place, but that it must
be practical as well. EPA and DOE should resolve the confusion because current
definitions are partially based on the waste's origin and characteristics. The State
suggested that specific activity levels should be used in distinguishing mixed wastes.
Low-level, high-activity waste (sometimes called intermediate waste) is different from
other LLW; the distinction could be useful as various exemption scenarios are considered.
State personnel indicated that ORNL revised their interpretation of the definition of LLW
to include disposal practices called hydrofracture. As a result, state personnel
suggested that the wording of any final agreement should specify that future changes in
interpretation of waste classification or definitions be reviewed for their impact on the
agreement. The agreement should be worded so as to enhance and assure the autonomy of the
environmental organization at DOE, and to assure that production-oriented entities at DOE
cannot edit environmental findings before the EPA, State, and public have access.
HLW treatment residues which are no longer HLW should not be part of the exemption. EPA
should make sure that any exemptions agreed to under the DOE option do not apply to the
non-HLW residues or effluents and that a tracking system is instituted to ensure that any
resulting mixed wastes or hazardous wastes will be picked up by the RCRA system.
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The State suggested that in presenting the findings, the task force should keep in mind
the kinds of sanctions that an EPA authorized State could invoke. After discovering a
problem, would the DOE self-regulating system move quickJy and effectively to a remedy?
Furthermore, it should be pointed out that the existing RCRA rules were drafted for
different conditions and as a result, MEWS's analyses should include more than a single
comparison between DOE procedures and existing RCRA rules. Comparisons should also
envision a future "Subpart Z, Mixed Waste Management", if and where it would be
appropriate. As a final step, the task force should consider applying two or three
hypothetical scenarios of full RCRA (including Subpart "Z"). existing RCRA, and partially
exempt programs to one or two of the DOE facilities as a demonstration or illustration of
equivalency.
At each facility and for each waste stream. DOE should demonstrate the inseparability of
the radioactive and chemical components (e.g. could toluene ever be released from a
mixed-waste stream and not contain radionuclides?) Hydrofracture fixation at ORNL has
released ground-water contaminants due to dissociation of hazardous constituents. In
general. EPA should assure that DOE's ground-water monitoring objectives include tracking
these discharges after they enter the environment.
EPA should provide a "safety net" for any cases where the DOE option would result in
exemptions from Sec. 3004 (u). For instance, if a facility were only subject to
RCRA-permitting requirements for HLW or TRU waste management units, an exemption could
result in old solid waste management units (SWMU's) escaping requirements of Sec. 3004
(u): such a facility should still be required to clean up the SWMU's as if the permit were
required.
The status of past practices should be carefully delineated in the agreement with DOE.
Some TRU wastes are retrievably stored at ORNL: other TRU waste will probably remain in
place. The exemption should allow case-by-case determinations of individual waste
management areas. The State asked about the Underground Injection Control requirements
and whether plugging, monitoring, and other considerations would be subject to a separate
task force.
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Delays in obtaining "Q-clearances" were a problem, but only at the annoyance level; a
cleared inspector could be hampered by inability to report the specifics of a finding
which was based on classified information.
The State also discussed ongoing DOE/TDHE interactions and the existing, potentially
affected facilities in the State. The DOE/TDHE relationship has been positive (i.e., ORNL
is much less inclined to use the by-product rule than SRP has). State concerns are
primarily limited to generator/transport/storage issues; disposal in Tennessee is not
anticipated. There are three activities/facilities in the state which could be affected
by the DOE option: TRU waste storage, molten salt reactors, and a biodenitrification tank
farm (eight 500,000 gallon tanks, five more on order). Some of these may be
source-material related and therefore not affected. DOE identification of all waste
streams and facilities which could be affected by the option would be appreciated.
Existing DOE facilities have recently begun to comply with Subpart F. Not one facility
has completed their second quarter of background determinations; comparison sampling is
more than a year away. Traditional pump-and-treat remedial measures for corrective action
could be affected by considerations of worker exposure to radiation.
ACTION ITEMS:
The State will provide the following additional information:
I. Reference material regarding the change in DOE's definition of
LLW.
2. Ground-water data at the hydrofracture site and evidence of the
release of organic constituents.
DISTRIBUTION:
Attendees
Mews Distribution List
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APPENDIX I
LIST OF ATTENDEES
EPA/REGION IV
Doug McCurry
Suzie Riddle
EPA/STATE PROGRAMS
Betty Shackleford
EPA/RADIATION PROGRAMS
Ray Clark
EPA/OFFICE OF SOLID WASTE
Burnell Vincent
TDHE/RADIOLOGICAL HEALTH
Michael H. Mobley
Lisa Stetar
Debra Shults
TDHE/SWM
Elizabeth Phillips
TDHE/OGC-E
Mary Johnston
TDHE/SOL1D WASTE
Tom Tiesler
April Ingram
Wayne Gregory
TDHE/DOE PROJECT COORDINATOR
Earl Lemtng
TDHE/SOLID WASTE MGMT. DIV
John Leonard
TDHE/SWM
Larry Leford
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APPENDIX II
Questions for Slates Regarding High-Level
Mixed Wasted Management
I. Query the State about their view on the approach currently under consideration by the
Agency (i.e. exemption of transuranic (TRU) and high-level mixed wastes, and other
wastes such as low-level nuclear submarine reactor compartments from RCRA regulation
if management of the radioactive component is determined to adequately safeguard the
hazardous waste component or if compliance with RCRA is found to be inconsistent as
defined by Section 1006).
NOTE: Colorado is the only State authorized to regulate the hazardous component of
radioactive mixed wastes.
2. Does the State have specific concerns regarding DOE management of high-level mixed
waste with EPA oversight? If yes, what are the concerns?
3. When does the State intend to seek mixed waste authorization?
4. To date, have there been any documented incidents associated with DOE waste management
practices? If yes, obtain appropriate documentation.
5. What, if any, information does the State have concerning DOE facilities?
6. Does the State anticipate that the regulation of high-level mixed wastes will pose
problems significantly contrasting with those associated with low-level mixed waste
management? If yes, what are the problems?
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7. How many DOE facilities are located in the State? Are there any commercial Facilities
within the State that generate TRU or high-level mixed wastes? If yes, how many?
8. How many facilities within the State could potentially be affected by the approach
under consideration by EPA? Obtain a listing if possible.
9. Other permits - air. water. RCRA.
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MEWS TASK FORCE
Meeting with State of Washington
Department of Ecology
Olympia. Washington
November 25, 1986
PURPOSE:
On November 25, 1986. members of the MEWS task force met with Roger Stanley of the
Washington Department of Ecology (WDOE) in Olympia, WA from approximately 2:00 to 4:30
(Appendix I lists attendees). The purpose of the meeting was to get the State's
perspective on the Department of Energy's (DOE) proposed option to exempt high-level waste
(HLW) and transuranic (TRU) mixed waste management at DOE facilities from the RCRA
hazardous waste program. A summary of the issues raised/discussed including the State's
reaction to the DOE option follow:
SUMMARY:
The State has a problem with DOE's definition of high-level waste;
double-shell tanks do not contain only high-level waste. Hanford has told
the Slate that low-level mixed wastes are also contained in the double-shell
tanks. Roger used this example to illustrate the point that the
double-walled tanks contain wastes other than high-level wastes; the
information is from a presentation made by Hanford on a hazardous waste
treatment facility it is preparing to construct.
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Purex plant and double-walled tank waste will go to:
SEPARATIONS PLANT
LOW-LEVEL CHEMICAL WASTE
TREATMENT
GROUT FACILITY
"VAULTS*
HIGH-LEVEL RADIOACTIVE
WASTE VITRIFICATION
COMMERCIAL REPOSITORY OR
RETRIEVABLE STORAGE
Roger stated that "the State won't buy up-front exemptions to RCRA - these
would lead to litigation." He feels the DOE proposal would exempt the wastes
with greatest environmental hazard (liquid, concentrated) from the oversight
that is necessary to protect the environment.
He stated that the report "Liquid Waste Disposal Units" of October 1986 shows
how waste going to tanks has been mismanaged in the past. The State does not
take the word of DOE that wastes will be managed properly in the future.
Roger expressed a concern that the double-shell tanks are all piped
underground. "We do not know whether they are leaking." Hanford lacks
ground-water monitoring data to verify there is no contamination - "this is a
major problem."
Roger would expect to see waste analyses for TRU waste. Not all TRU wastes
are gloves and booties - Hanford has stated that it also includes process
sludges. Waste analyses must show what the chemical (hazards) components
are. DOE must show how it handles the chemical aspects, show whether liquids
are present, how concentrated, etc.
Roger feels that the State is not "gaining ground fast enough" on the
by-product issue. Instead. DOE goes from issue-to-issue and does not make
progress in managing its most hazardous wastes. State does not want a
"gentleman's agreement trading off some wastes for others," which is what
DOE's proposal does, in his opinion.
There is a precedent in Washington State concerning the issue of
inconsistency between Sections 1006 and 6001: the commercial low-level waste
disposal site (U.S. Ecology) claimed it was not subject to RCRA even though
it handled chemical and radiological waste, and US Ecology said 1006 and 6001
were inconsistent. However. US Ecology could not come up with an example of
the inconsistency, and neither could the State. Jim Michaels, Bruce Weddfes,
and several NRC people were involved. The result, apparently, was that EPA
and NRC said dual regulation would continue.
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ACTION ITEMS:
The task force may wish to interview a member of the Office of High-level Nuclear Waste
Management in addition to Roger Stanley. It is located within the WDOE and it deals
primarily (but not solely) with issues concerning the siting of the geologic repository.
It interfaces with the Governor's High-level Nuclear Waste Board, which consists mainly of
legislators.
DOCUMENTATION:
Tank Waste Data supplied in response to Roger Stanley's questions of
July 14. 1986.
DISTRIBUTION:
MEWS Distribution List
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APPENDIX I
LIST OF ATTENDEES
EPA/Project MEWS
Dan forth Bodien
Janet O'Hara
Stale of Washington
Roger Stanley
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