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
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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
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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

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         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

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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

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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

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                                                  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.
                                 2-19

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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 
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                   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

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                FIGURE 2-6
         TRU WASTE STORAGE AREA
CONTACT HANDLED WASTE RETRIEVABLY STORED

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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.
                                              2-24

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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.
                                              2-27

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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.
                                              2-29

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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.
                                               2-31

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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.
                                              2-32

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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.
                                              2-33

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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.
                                               3-2

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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
                                               4-1

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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.
                                            4-2

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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).
                                              4-3

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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.
                                            4-4

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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.
                                          4-5

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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.
                                              5-1

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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

                                              5-2

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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).
                                              5-3

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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.
                                             5-4

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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.

                                            6-1

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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.
                                        6-7

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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

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                           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

                                                A-4

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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)
                                                A-6

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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

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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.
                                               A-ll

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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

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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.
                                               A-15

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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

                                               A-16

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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
                                         A-17

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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.
                                               A-18

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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.
                                                A-19

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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.
                                                A-20

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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.
                                                 A-21

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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

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                                         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

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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.

                                                A-24

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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).
                                                 A-25

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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.
                                                A-26

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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

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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
                                               A-28

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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.
                                                A-29

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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.
                                               A-31

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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
                                               A-32

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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

                                                A-33

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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

                                               A-34

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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.
                                               A-35

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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

                                               A-36

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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.
                                               A-37

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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.
                                              A-38

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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.
                                              A-39

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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.
                                              A-40

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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.
                                              A-42

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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
                                                A-43

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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.
                                               A-47

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           FIGURE 4
LANL WASTE MANAGEMENT AREAS

  8000*    I600O' ft
                 A-48

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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.
                                             A-49

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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]


                                              A-50

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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
                                             A-51

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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.
                                              A-52

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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
                                               A-53

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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.
                                               A-54

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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.
                                               A-55

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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".
                                               A-57

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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
                                             A-58

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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.

                                              A-59

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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.
                                               A-60

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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:
                                               A-61

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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.
                                                A-62

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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.
                                               A-64

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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.

                                               A-70

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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

-------
            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

-------
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.
                                             A-73

-------
     •    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
                                          A-75

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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;
                                              A-76

-------
     •    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.
                                              A-77

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                              FIGURE  1
      GENERAL LOCATION OF THE ROCKY FLATS PLANT
                           MOUNTAlNS *»»H.*IN
Comincnwl Divide
                                                      on
                                                    Commtret Gty

                                                    DENVER (City and County!
                CLEAR
                CREEK
                CO.
                   AHAPAHOE CO.
   I  »"»««n
 :—'  po.nt HI
                                                                ;  ELBERT CO.
                             «*t C'0»«t

                            FFERSON CO. J  \
                                     UNTAIHt »*m »t-AIN»


                                        OOUQLAS-CO.
                                                              • Grind Junction
                                                                                  •Color Ida
                                                                                   Soringt

                                                                                  • PutCHo
A-78

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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,

                                                A-79

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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.
                                                A-80

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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

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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.
                                              A-83

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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
                                              A-84

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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)
                                            A-85

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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.

                                               A-86

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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

-------
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.
                                                A-93

-------
                                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
<3r«rt*r Confin«m«m Dijpcaal
          Low Ltv«i Trtnch
               3ori«l Groood*  Showing 2oa«« of Trench Alpha,
               latcrmdiAt*  *ad Low(.*v*l
               «od Solvent Storage
                                      A-94

-------
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

-------
                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-

»



,

: 1
( )finn ]{
/COOLING
COILS . .
Illll '
I 1 1 1 1
"*• jJyu^
.
CONDENSER RISER
INSTRUMENT RISER
" -VV*

j i : \ EARTH COVER

\
I2.2'-0*OI
COLUMNS



n
>


^ STEEL
TANK

.






STEEL
PAN-.
















10' WALL 2' 6" BASE SLAB


7V f| mmmmmm




                                    COOLED WASTE STORAGE TANK
                                      Type D  1.030.000 Gallons
i
                                .

                          j,O
-INTAKE FAN

     x-3'-9"HOOF
                                                             EXHAUST
                          COOLING
                          COILS
                      2-9 WALL
 TYPICAL RISER x
-,—^-.	-.—....
' jl ft>^^ '"DOME 4 Sowrt^Sp^inh
y^ OPENING ^5..
^ SPRING LINE
l
, PNEUMATIC CONCRETE STEEL L.NER -,
/ WITH TENSIONING BANDS >
f '" •-
Y %*>' - o"



a
1



                                   COOLED WASTE STORAGE TANK

                            Stress Relieved Primary Liner .1.300.000 Gallons
                                             Type  m
                                                                   MM* PUHGt INI I >
                            «ooo<««
                                                                /
                                                                  ««•»•  »'""«»
                                                                        l
                              ,   nus•   i  •
                             f  W    f-:
                             -^i——	v.;
                                                                     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

-------
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

-------
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

-------
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

-------
                    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

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         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

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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

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                                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

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                                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

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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

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                          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

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                     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

-------
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

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                             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

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                             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

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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

-------
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.
                                             A-128

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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

                                              A-129

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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

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(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
                                            A-132

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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.
                                            A-134

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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.
                                              A-135

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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.
                                              A-136

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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
                                              A-137

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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
                                             A-138

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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
                                           B-3

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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
                                          B-7

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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
                                        B-8

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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.
                                             B-10

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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
                                        B-12

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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
                                              B-14

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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!
                                             B-15

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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.
                                             B-17

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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

                                             B-18

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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.
                                             B-19

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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
                                        B-20

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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.
                                              B-22

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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
                                               B-24

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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


                                      B-25

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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.
                                               B-27

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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.
                                             B-28

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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.
                                             B-29

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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
                                             B-30

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                                       APPENDIX  I


                                   LIST OF ATTENDEES
EPA/Project MEWS

 Dan forth Bodien
 Janet O'Hara

Stale of Washington

  Roger  Stanley
                                       B-31

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