EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

EPA's Review of DOE's Inventory Tracking for TRU Wastes at Waste Control Specialists

April 9, 2014

Summary

On April 9, 2014, EPA's Waste Isolation Pilot Plant (WIPP) waste characterization team visited
Waste Control Specialists (WCS) to determine whether the Department of Energy (DOE) was
meeting EPA's waste inventory tracking requirements at 40 CFR 194.24(c)(4). DOE began
shipping waste to the Andrews, Texas-based WCS in April 2014 due to the temporary closure of
WIPP in response to the February 2014 fire and subsequent radiological release. Despite this
temporary closure, DOE is required under a State of New Mexico Governor's Directive to
remove 3,706 cubic meters of transuranic (TRU) waste from Los Alamos National Laboratory
(LANL) by June 30, 2014. During the WCS visit, EPA observed unloading and storage
operations, interviewed WCS and DOE contractor staff from the Central Characterization Project
(CCP), and evaluated supporting information as objective evidence for technical adequacy. The
Agency also evaluated the system of controls in place for TRU waste containers from LANL and
determined that these controls are technically adequate and comply with requirements at 40 CFR
194.24 (c)(4).

Background

40 CFR 194.24 requires that all DOE TRU waste destined for WIPP disposal be characterized
using an EPA-approved waste characterization program and be tracked from generation through
disposal. The DOE's Waste Data System (WDS) tracks each waste container from generation
through characterization, storage, certification, shipment and emplacement at WIPP. However,
emplacement of TRU waste at WIPP was halted in February 2014 as a result of two separate
incidents: an underground salt truck fire and a radiation release at the WIPP. Because a State of
New Mexico Governor's Directive dated October 1, 2011, requires DOE to remove 3,706 cubic
meters of TRU waste from LANL by June 30, 2014, the stoppage required DOE to immediately
seek an alternate radioactive waste storage facility for LANL's remaining 577 cubic meters of
contact-handled (CH) TRU waste.

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EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

Selection of WCS for Temporary Storage

The DOE looked at a number of potential options for waste storage during the interruption of
WIPP activities. It identified alternate temporary storage capacity at the WCS facility in
Andrews, TX. WCS is a waste management facility authorized by the Texas Commission on
Environmental Quality (TCEQ) to accept hazardous, radioactive and mixed waste for treatment,
storage and disposal. WCS routinely accepts low-level mixed waste from various DOE locations,
including TRU waste generator sites, for treatment and disposal. The facility's radioactive
materials license authorizes storage of TRU waste from DOE.

Before DOE's WIPP contractor signed the contract to use the WCS facility for temporary TRU
waste storage, DOE's Carlsbad Field Office (CBFO) determined that WCS's security and safety
operations and controlled waste handling activities were able to provide adequate security and
safety throughout the storage period. CBFO also determined that the WCS storage area and
waste loading/unloading operations were well suited and readily available for this purpose.

Any radioactive mixed waste brought to WCS must meet WCS's radioactive waste acceptance
criteria (WAC). CBFO and their support contractor—the CCP, operated by the Nuclear Waste
Partnership (NWP) in consultation with LANL-CCP—determined that most (perhaps all) of the
remaining LANL Contact-Handled TRU waste that would be WIPP-certified would meet WCS's
WAC. However, before WIPP-certified TRU waste containers leave LANL, TCEQ inspectors
must verify the containers' eligibility for WCS acceptance.

EPA's Off-Site Evaluation of LANL-CCP's Waste Tracking System Used at WCS

On April 8, 2014, prior to visiting WCS, EPA inspectors (Rajani Joglekar and Ed Feltcorn) met
with CBFO staff (J. R. Stroble and James Rhoades) and CCP staff (Farok Sharif, Ronnie Lee, Ed
Gulbransen, Mike Sensibaugh and Mike Ramirez). The CCP staff described the flow of LANL
TRU waste containers from LANL to WCS to WIPP. This ensures that the chain of custody is
continuously maintained; they require that DOE's WIPP-certified waste inventory be continually
tracked - from a generator site to a location in the WIPP repository. To meet this requirement
during the temporary storage of the LANL contact-handled TRU waste at WCS, CCP developed
an "interface" procedure (CCP-PO-042, Rev 0, dated 3/25/2014), which describes the system of
controls to be implemented at WCS. As objective evidence of the interface procedure, CCP staff
provided EPA with documentation of LANL waste shipments #1, #5 and #7, which began
arriving at WCS on April 2, 2014.

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EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

EPA staff also reviewed a table included in the draft CCP-TP-199 procedure, which will be used
by CCP at WCS to verify WCS ID numbers and container locations. CCP will prepare monthly
reports using this verification information and provide them to EPA after their approval by
CBFO.

EPA's April 9 WCS Site Visit

During April 2-9, 2014, WCS received a total of seven shipments consisting of standard waste
boxes (SWBs) meeting WCS WAC requirements. Over the next few months, LANL-CCP plans
to send between 80-100 TRUPACT-II or HalfPact shipments consisting of approximately six
SWBs per shipment.

During their April 9 visit to WCS, in accordance with 40 CFR 194.24 (c)(4), EPA's inspectors
reviewed LANL-CCP's waste inventory tracking procedure (CC-TP-199). CCP demonstrated the
steps outlined in their interface document (CCP-PO-042, Rev 0 dated 3/25/2014), which define
CCP and WCS roles and responsibilities while TRU waste is stored at WCS. EPA also observed
the unloading of one TRU shipment (3 TRUPAC II) containing six SWBs with LANL-CCP's
container identification label as shown in Figure #1. Upon unloading of TRU waste containers,
WCS affixes its own container identification label, which is shown in Figure #2. Before LANL
waste can be stored in the enclosed storage area, TCEQ staff must verify the LANL markings on
waste containers against the pre-shipment information received from LANL-CCP. After TCEQ
verification, WCS moves the dual-labeled TRU waste containers to the controlled storage area
and enters relevant information (ID#s and location) into their tracking database. WCS then also
provides the same information to CCP, which CCP in turn enters into the WDS, designed to
track waste inventory and the status of every WIPP-certified container.

Once in the controlled area, WCS segregates WIPP-bound waste containers in a roped off area as
shown in Figure #3. WCS's multiple layers of secured, controlled access insures against
tampering or unauthorized movement of the WIPP-certified containers in WCS's possession. All
LANL waste containers will remain in the same location until they are moved for WIPP disposal
when the repository restarts its emplacement operation. Until the TRU waste containers are
moved to WIPP, CCP will perform verification checks at WCS using CCP-TP-199, Rev 0, dated
4/22/2014, to validate that the information given by WCS remains true and applicable. CCP will
continue to generate monthly reports tabulating the waste inventory as shown in the example in
Attachment 1. EPA will receive a copy of CCP's monthly inventory report.

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EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

Conclusion

Based on its discussions with CCP staff and the WCS visit, EPA confirms that an adequate
system of controls is in place to ensure necessary physical security and a chain of custody while
LANL TRU waste containers are in temporary storage at WCS.

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EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014


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EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

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Figure #2: WCS affixed container identification label

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EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

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Figure #3: WIPP-bound waste containers in a roped out and segregated area at WCS

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EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

Attachment 1 - Sample Inventory Report

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Controlled
Copy

CCP-TP-199, Rev. 0

CCP/WCS CH TRU Waste Inventory Control

EPA Air	April 2014

Page 11 of 11

Attachment 1 - CCP/WCS Monthly Inventory Review Checklist

Reviewer: ; '

Escort:

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Dat e:_J±^L±±

Description of Criteria Reviewed

Are stored TRU waste containers
physically segregated from other
containers and placed in a clearly
identified and designated holding
area?

2 Are stored TRU waste containers
with NCRs segregated from
non-NCR waste in the storage
area?

3. Was a visual examination of
accessible surfaces performed on
each stored TRU waste container to
verify no Integrity issues exist?

4. Does each container number
correlate with the WCS container
number listed on the WCS TRU
waste inventory document?

5. Does each container location match
the location specified on the WCS
TRU waste inventory document?

6. Does the receipt date on the WCS
TRU waste inventory document
match the receipt date on the AK
tracking spreadsheet printout for
each container?

7, Were ail stored containers on the
AK tracking spreadsheet printout
examined?

Are only TRU waste containers
located in the segregated TRU
waste area''

Was this monthly inventory review
acceptable, meeting the storage
requirements of CCP-PO-042?
(Comments required if answered
NO)

YES

X



NO

NA

Comments

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9


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CONTAINERS

AKA

SONTAINER_TYPE

CONTAINER.,STATU!



f NO:



68283

14-108415

SWB

SHIP WCS

04/02/2014





68268

14-108416

SWB

SHIP WCS

04/02/2014



xsk-

68272

14-108417

SWB

SHIP WCS

04/02/2014



3 k

68286

14-108418

SWB

SHIP WCS

04/02/2014



C5 ^

68275

14-108419

SWB

SHIP WCS

04/02/2014





68269

14-108420

SWB

SHIP WCS

04/02/2014



-3)C

68281

14-108421

SWB

SHIP WCS

04/03/2014



1X

LASB02195

14-108422

SWB

5HIP WCS

04/03/2014

56449, S818401, S834576, S841245

-j\c

68762

14-108423

SWB

SHIP WCS

04/03/2014

S802727, S818259, S823273, S824250

trie

LASB02166

14-108424

SWB

SHIP WCS

04/03/2014

55348, 56452, 57376, 68426



68009

14-108425

SWB

SHIP WCS

04/03/2014

S804S17, S813495, S813516, S855610



LA5B02224

14-108426

SWB

SHIP WCS

04/03/2014

55330, 92833, S833264, 5852998

1 Y-

-j\C

68284

14-108427

SWB

SHIP WCS

04/03/2014



LAS802193

14-108428

SWB

SHIP WCS

04/03/2014

57356, S818304, S853650, S864571

1'c

68763

14-108429

SWB

SHIP WCS

04/03/2014

S813553, 5816411, S816448, S816666

UK

LA5B02190

14-108430



SHIP WCS

04/03/2014

55377, S825850, S835425, S862089

^\C

68003

14-108431

SWB

SHIP WCS

04/03/2014



-j\c

LA5B02191

14-108432

SWB

SHIP WCS

04/03/2014

S818299, S8183G0, S834604, S834763

Jt

LASB02214

14-108433

SWB

SHIP WCS

04/04/2014

56427, 56474, 63830, 5832421

3 K

68266

14-108434

SWB

SHIP WCS

04/04/2014





LASB02205

14-108435

SWB

SHIP WCS

04/04/2014

54078, 55331, S832422, S835295



68004

14-108436

I

1SWB

SHIP WCS

04/04/2014



IK

68116

14-108437

SWB

SHIP WCS

04/04/2014



3 k

68122

14 108438

SWB

SHIP WCS

04/04/2014



*31<

68244

14-108439

SWB

SHIP WCS

04/04/2014



^\c

OK

LASB02206

14-108440

SWB

SHIP WCS

04/04/2014

57351, 64414, 68656. S832424

68250

14-108441

SWB

SHIP WCS

04/04/2014



•IK

LASB02204

14-108442

SWB

SHIP WCS

04/04/2014

55378, 64488, 68315, S832485



68267

14-108443

SWB

SHIP WCS

04/04/2014



ov"

68126 1

14-108444

SW

SHIP WCS

04/04/2014



10


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