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Low Level Waste and Mixed Low Level Waste National Business Strategy
Phase I
Introduction
The Environmental Management (EM) program of the U.S. Department of Energy
(DOE) is committed to the environmental remediation of the DOE’s sites throughout the
nation. Central to this mission is the restoration of contaminated sites from nuclear
weapons research and production and the disposal of the resulting radioactive and
hazardous wastes. In the process, the Department seeks to reduce risk and minimize
lifecycle costs.
Facility Deactivation and Decommissioning (D&D) and the
environmental restoration of contaminated sites produce large amounts of Low Level
Waste (LLW), Mixed Low-Level Waste (MLLW), as well as transuranic waste (TRU)
and hazardous wastes. This DOE LLW/MLLW National Disposition Strategy, hereafter
referred to as the National Disposition Strategy, discusses the Department’s long range
strategy for managing its LLW and MLLW.
A recent GAO report1 examined the national LLW disposal capacity and concluded that
LLW disposal availability was adequate in the short term. In the long term, there may be
a lack of disposal options for Class B and C LLW. In addition, EM is possesses a
number of MLLW streams without a current treatment or disposal path, referred to as
“orphan waste”. For example, there is no offsite disposal path available today for MLLW
with radionuclide concentrations levels of 10 – 100 nCi/g (alpha MLLW). In some cases
Federal or commercial treatment capacity for a given waste stream may exist, but these
treatment facilities may have limited throughput and storage space.
The objective of the National Disposition Strategy is to evaluate DOE LLW and MLLW
disposition options for that waste which is transported off the generating site for
disposition, i.e., off-site waste disposal. Orphan waste streams will be discussed in detail.
The National Disposition Strategy will be developed in two phases. Phase I will examine
selected DOE sites with a significant quantity of EM LLW/MLLW, specifically: Oak
Ridge, Savannah River, Idaho, Hanford, Fernald, Miamisburg, Portsmouth and Paducah.
Phase I will consider LLW/MLLW requiring off-site disposal from the present to
approximately 2030. Phase II will examine those DOE LLW/MLLW streams not
included in Phase I.
TRU and hazardous waste are beyond the scope of this study because EM already
manages a program for the complex-wide integration of TRU waste disposal. In
addition, there is no compelling need for a hazardous waste national strategy because
disposal of this waste has not been a problem within the complex.
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LLW Commercial Disposal and Treatment Market
There are currently three commercial disposal facilities that can accept DOE LLW and an
additional facility that may become available.
Envirocare
Since 1988, Envirocare has operated a 540 acre disposal facility 80 miles west of Salt
Lake City. Prior to 1988, DOE used the area for the disposal of uranium mill tailings.
Much of the waste disposed at Envirocare comes from cleanup of commercial and
government facilities. Also, Envirocare is the only commercial disposal facility to accept
mixed waste. In 2003, Envirocare accepted about 99% of the nation’s Class A waste.
The Utah Department of Environmental Quality (DEQ) has licensing and regulatory
authority for the Envirocare facility. Utah originally approved Envirocare to accept
naturally occurring radioactive material – large volume, low activity LLW. Since then,
Envirocare’s license has been amended at multiple times to allow more types of
radioactive waste including in 1991 when the state permitted disposal of LLW. In 1992
the Utah Division of Solid and Hazardous Waste granted Envirocare a RCRA Part B
permit allowing the operation of a separate disposal cell for MLLW. In 1995 Envirocare
constructed a mixed waste treatment facility to treat mixed waste subsequent to disposal.
In July 2001, the Utah DEQ approved Envirocare’s license application to accept Class B
and C wastes. Appeals were filed and, in February 2002, the department affirmed the
approval. In March 2003, the Governor of Utah signed a bill placing a moratorium on
any acceptance of Class B or C wastes through February 2005, and requiring legislative
and gubernatorial approval for acceptance of these wastes. However, in February 2005,
after a change in ownership, Envirocare formally withdrew its Class B and C license
application.
Envirocare has operated the disposal facility since its inception in 1988. The company
has about 400 employees and about 250 employees are directly involved with LLW
operations. Envirocare owns the disposal site land. The disposal site has the capacity for
more than 20 years of operation under its current license. Currently the facility contains
approximately 1.7 x 106 m3 of Class A waste.
U.S. Ecology
U.S. Ecology operates a 100 acre radioactive waste disposal facility, the Richland
facility, located within the DOE Hanford site. Per the State of Washington Department
of Ecology, the Richland facility may only accept LLW generated within the Northwest
Compact. This Compact includes the states of Washington, Alaska, Hawaii, Idaho,
Montana, Oregon, Utah, and Wyoming. However, regardless of the state of origin, the
U.S. Ecology Richland facility may accept naturally-occurring and accelerator produced
radioactive material, which is not addressed by the compact.
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The State of Washington Department of Health exercises primary regulatory
responsibility over the disposal facility. It issues licenses to the facility operator and
regulates radioactive material. A Department of Health inspector examines each
shipment of waste prior to disposal. The Department of Ecology has primary program
responsibility. It issues individual permits for radioactive waste disposal to generators
and serves as the site landlord
U.S. Ecology currently has 18 employees at its Richland facility in addition to 4
administrative staff. The Richland facility has much unused capacity to accept LLW,
approximately 600,000 m3. To date, the facility has disposed of approximately 400,000
m3 of LLW in 20 trenches. About 95% of the waste is Class A.
U.S. Ecology also operates a waste disposal facility at Grandview, ID. Although licensed
to accept RCRA and PCB wastes, the Grandview facility cannot accept most LLW.
However, it can receive naturally occurring, accelerator produced and other NRC-exempt
low activity radioactive waste. U.S. Ecology also has the capability to stabilize and
encapsulate waste.
Barnwell Disposal Facility
The Barnwell disposal facility was opened in 1969, but the actual license for shallow
burial of LLW was issued in 1971. Chem-Nuclear Systems has operated the Barnwell
facility continuously since it opened. In 2000, this company became a subsidiary of
Duratek Inc. This commercial disposal site is located near the DOE Savannah River Site.
In 1976 the site was expanded to its present size of 235 acres with an original capacity to
hold approximately 870,000 m3 of all classes of radioactive waste. Duratek currently
employs about 100 people at the Barnwell facility. The South Carolina Department of
Health and Environmental Control has licensing and technical regulatory authority.
The Barnwell disposal facility is nearing capacity. About 102 acres of the 235 acre site
has been filled, with about 13 acres remaining for disposal. There are about 75,000 m3 of
space remaining. However, most of the remaining space has been reserved for the
decommissioning of 12 nuclear power plants. In addition, the facility is planned for
closure to out-of-compact waste by 2008. Furthermore, the South Carolina legislature
has imposed volume caps on the amount of waste that Barnwell can accept.
Waste Control Specialists (WCS)
The Waste Control Specialists (WCS) facility is located 30 miles west of Andrews,
Texas. At present this facility is licensed to treat, e.g. stabilization, process and store
LLW and MLLW, including Greater than Class C (GTCC), PCB’s and sealed sources.
The facility is not currently licensed for LLW disposal.
WCS has a license application pending before the Texas Commission on Environmental
Quality for near-surface land disposal of Class A, B and C LLW. Texas may license the
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compact facility and an adjacent, separate and distinct facility for disposal of Federal
low-level waste under Texas regulations. The regulations require that before accepting
Federal facility waste, a written agreement must be signed by the Secretary of Energy.
This agreement should state that the Federal government will assume all right, title, and
interest in land and buildings for the disposal of Federal facility waste, together with
requisite rights of access to the land and buildings.
Commercial Vendor Matrix
The Table on the following page summarizes the above commercial vendor information
as well as listing available contract vehicles.
LLW Commercial Treatment Market
In addition to the commercial waste disposal facilities discussed above, there are a
number of commercial vendors that are able to treat DOE radioactive wastes.
Duratek Bear Creek Facility
The Duratek Bear Creek Facility, located in Tennessee, offers LLW incineration, metal
decontamination and metal melting. There is no DOE Complex-wide procurement
vehicle, however Duratek has contracts and subcontracts at several DOE sites.
Envirocare
The Envirocare Facility, located in Clive UT, was discussed above as a disposal site.
Envirocare treats and/or solidifies MLLW & liquid radioactive waste prior to disposal
using macroencapsulation and stabilization in addition to PCB and organics removal.
Envirocare treatment services can be procured through a Complex-Wide Indefinite
Quantity Contract from the Chicago Operations Office.
Pacific EcoSolutions (PEcoS)
The PEcoS facility, located at Richland, WA, offers LLW thermal treatment and
LLW/MLLW supercompaction, neutralization, stabilization and macroencapsulation.
The facility can accept most kinds of waste under a Resource Conservation and Recovery
Act (RCRA) Part B permit. There is currently no DOE-wide contract. DOE site
contractors have been entering into direct procurements with PEcoS for waste treatment
services.
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Table 1
Commercial LLW/MLLW Disposal Facilities
Commercial
Vendor
Envirocare
Location
Waste Accepted
Restrictions
Contract
Vehicles
Complex Wide:
- DOE Chicago
- MLLW: Oak
Ridge
- LLW: Ohio
Clive, UT
Class A LLW,
MLLW &
11e(2)
byproduct
material
Cannot accept
class B & C
waste.
U.S. Ecology
Richland,
WA
Class A, B & C
LLW
Duratek
Barnwell,
SC
A, B & C LLW
Cannot accept
LLW from
outside of
Northwest
compact.
Cannot accept
MLLW or 11e(2)
byproduct
material
Army Corps of
Engineers
Army Joint
Munitions
Command
Duratek has
contracts and
subcontracts at
several DOE
sites.
Waste
Control
Specialists
(WCS)
Andrews,
TX
None, however
license pending
to accept class
A, B & C LLW
Cannot currently
dispose of LLW
Oak Ridge
Perma-Fix/Diversified Scientific Services (DSSI)
The Perma-Fix DSSI facility, located in Tennessee, offers thermal and non-thermal
treatment for high organic MLLW. Wastes are combusted in a licensed boiler to meet
land disposal restriction criteria. Perma-Fix treatment services can be procured through
the Oak Ridge Broad Spectrum contract.
Perma-Fix/Materials & Energy Corp. (M&EC)
The Perma-Fix M&EC facility, located in Tennessee, treats both organic and inorganic
MLLW (including PCB’s and Hg) using various non-incineration processes (e.g. vacuum
thermal desorption). All waste codes are accepted and the license encompasses most
isotopes. Perma-Fix treatment services can be procured through the Oak Ridge Broad
Spectrum contract.
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Waste Control Specialists (WCS)
The WCS facility, located in Andrews, TX, was discussed above as a potential disposal
site. WCS treats, (e.g. stabilization) processes and stores LLW & MLLW (including
GTCC, PCB’s, sealed sources, solids and liquids). The current hazardous waste
treatment capabilities include consolidation, repackaging, and stabilization for a wide
variety of RCRA and TSCA wastes. Storage capability includes pre-packaged and
treated LLW and MLLW, including GTCC and sealed sources. WCS treatment services
can be procured through the Oak Ridge Broad Spectrum contract.
LLW DOE Disposal and Treatment Capabilities
Most DOE sites have the capability to dispose their LLW at their own on-site burial
grounds. For example, Oak Ridge disposes waste from Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA) remedial actions at its
Environmental Management Waste Management Facility (EMWMF), an on-site
CERCLA disposal facility. The Idaho National Laboratory (INL) operates a LLW
disposal facility as part of the larger Radioactive Waste Management Complex (RWMC)
for disposal of both contact-handled and remote-handled LLW. Recently, only two DOE
sites, Hanford and the Nevada Test Site (NTS) have accepted LLW from other DOE
sites. These two sites are discussed in more detail below. Currently, Hanford is not
accepting LLW from other DOE sites because of a lawsuit with the State of Washington.
Hopefully, this will be resolved shortly. The Toxic Substances Control Act Incinerator
(TSCAI) is the only DOE facility capable of incinerating MLLW and, as such, is a
unique DOE asset.
Nevada Test Site
The Nevada Test Site is a U.S. Department of Energy National Nuclear Security
Administration Nevada Site Office facility. The site is approximately 1,375 square miles
and is larger than the state of Rhode Island. Established in 1950 as the Atomic Energy
Commission's proving ground for nuclear weapons testing, the site is located
approximately 65 miles north of Las Vegas in the Great Basin desert. The facility is
surrounded on three sides by federally owned and controlled land.
Low-level waste is accepted for disposal from on and off-site DOE generators. Further,
classified LLW is accepted for disposal from on and off-site DOE and DOD generators.
Prior to waste acceptance, generators undergo a rigorous certification and acceptance
process, which includes demonstrating compliance with the Nevada Test Site Waste
Acceptance Criteria (NTSWAC). The NTSWAC provides requirements for the generator
waste certification program, characterization, traceability, waste form, packaging, and
transfer.
The NTSWAC can be found at:
(http://www.nv.doe.gov/programs/RadioactiveWasteAcceptance.htm).
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There are two radioactive waste disposal facility areas on the Test Site:
The Area 5 Radioactive Waste Management Site (RWMS) is a 732 acre facility (160
acres currently used for disposal) located north of Frenchman Flat (southeast corner of
Nevada Test Site) and has a depth to groundwater of approximately 800 feet. The facility
started operations in 1961 and began accepting off-site waste in 1976. Low-level waste
is disposed in excavated trenches and pits, ranging in depth from 12 to 48 feet deep. The
facility has a Mixed Waste Disposal Unit which, because it is operating under RCRA
interim status, is currently restricted by the State of Nevada to disposal only DOE mixed
low-level waste generated within the State of Nevada. A RCRA Part B Permit
application is pending with the State to allow for the disposal of off-site generated
MLLW.
As of 13 March 2005, more than 350,000 m3 of LLW has been disposed at the Area 5
RWMS. Calculations based on existing inventory show that there is nearly 3 million m3
of remaining capacity in the existing 732 acres (including the developed 160 acres). The
facility has the capability of easily expanding disposal operations to accommodate
additional volumes of LLW.
The Area 3 RWMS is the second low-level waste disposal facility at the Nevada Test
Site. The 120 acre facility is located in Yucca Flat and has a depth to groundwater of
approximately 1,600 feet. Disposal operations at the facility began in 1968. Low-level
waste is actively disposed at the Area 3 RWMS. In addition, there is a closed, approved
and permitted mixed LLW disposal cell at the facility. Waste disposed at the Area 3
RWMS is placed in subsidence craters formed by historic underground nuclear weapons
tests. As of 13 March 2005, more than 550,000 m3 of low-level waste has been disposed
in the facility and there is approximately 200,000 m3 of remaining capacity.
The combined total of MLLW waste disposed (as of 13 March 2005) at both the Area 5
and 3 RWMS’s is 8,500 m3. The Nevada Site Office has submitted a revised RCRA Part
B Permit Application which, if approved, would allow for an additional 20,000 m3
generated by approved DOE sites, both within or outside the state of Nevada.
Hanford Site
The Hanford Site was established in 1943 as part of the World War II nuclear weapons
production effort. The Site occupies 586 square miles in southeastern Washington State
(north of and adjacent to Richland, Washington). Disposal of solid LLW and MLLW
currently occurs at two facilities – the Low Level Burial Grounds (LLBG’s) and the
Environmental Restoration and Disposal Facility (ERDF). Both facilities are on the
Hanford Site’s Central Plateau. There are other burial grounds throughout the Hanford
site, but these are no longer in operation.
The LLBG’s actual consist of eight specific burial grounds. They started operation in the
1960’s and cover about 1,050 acres, portions of which have never been used. Over
280,000 cubic meters have been disposed in the LLBG’s. Solid LLW and MLLW from
onsite and offsite generators have historically been disposed in the LLBG’s. As a result
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of the Hanford Solid Waste EIS Record of Decision (ROD)2, disposal of solid LLW and
MLLW has been limited to two RCRA-compliant (i.e., double-lined and with leachate
collection) mixed waste trenched within the LLBG’s. There is an exception for naval
reactor compartments which were subject to previous NEPA decisions. About 2/3 of the
approximately 45,000 cubic meter capacity (in terms of physical trench dimensions) of
the mixed waste trenches remains.
As a result of a preliminary injunction in an ongoing litigation, receipt of solid LLW and
MLLW from offsite generators for disposal is currently suspended (with some courtapproved exceptions). Washington State Initiative 297 which would also prevent the
receipt of offsite waste to Hanford has not yet been enacted pending other litigation.
Information on the Hanford Site "Solid Waste Acceptance Program" and their waste
acceptance criteria can be accessed at: http://www.hanford.gov/wastemgt/wac/index.cfm
The ERDF is authorized by the EPA under CERCLA. The ERDF meets RCRA design
requirements (e.g. double-lined with leachate collection) for disposal. The ERDF is a
modular facility of which two cells (1 and 2) are full, two cells (3 and 4) are nearly full,
disposal has started in two more (5 and 6), and the construction of two more cells (7 and
8) is planned for FY 2007. It is being pursued as an alternative disposal site (i.e., as an
alternative to the two mixed waste trenches in the LLBG’s) for the disposal of nonCERCLA LLW and MLLW from Hanford generators.
Construction of a new disposal facility, the Integrated Disposal facility (IDF) was started
based on the Hanford Solid Waste EIS ROD2. The IDF is proposed to accept both LLW
and MLLW from onsite and offsite generators, as well as the future Immobilized LowActivity Waste from the treatment of Hanford’s tank waste. Construction of the IDF has
been stopped due to delays in obtaining the permits necessary to continue construction.
These delays are associated with the litigation concerning receipt of LLW and MLLW
from offsite generators and the Hanford Solid Waste EIS.
Toxic Substances Control Act Incinerator (TSCAI)
The Toxic Substances Control Act (TSCA) incinerator located on the East Tennessee
Technology Park (ETTP) Site in Oak Ridge, Tennessee is DOE’s only treatment
alternative for wastes that require incineration. It provides cost effective treatment for
radioactively contaminated polychlorinated biphenyl (PCB) wastes and also provides for
treatment of mixed low-level waste (MLLW) requiring thermal treatment. It enables
other DOE sites to meet their Site Treatment Plan and Federal Facilities Compliance Act
milestones, as well as their accelerated clean-up schedules. The TSCA incinerator will
continue operations until 2008. Beyond that date, its future is uncertain, but will be
determined based on the inventory of wastes still needing thermal treatment and the
availability of cost effective alternative treatment methods.
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EM LLW Streams
The EM Closure Sites, Rocky Flats, Fernald and Mound
The EM closure sites, Rocky Flats, Fernald and Mound, are scheduled to close in FY06
with the LLW shipping campaigns terminating in FY05. These sites are predominantly
shipping their LLW and MLLW to either the Nevada Test Site (NTS) or Envirocare. In
general, the waste shipped to NTS consists of the waste that does not meet the Envirocare
Waste Acceptance Criteria (WAC).
The Miamisburg Closure Project, i.e., the Mound site, does not have any LLW or MLLW
orphan waste streams. However the Fernald Closure Project has one orphan waste stream
which consists of 27 pounds of combined organic laboratory standards. The waste is
liquid in laboratory containers that are currently packaged in two 5-gallon containers
inside one 85-gallon drum. The waste is a combination of several hundred vials of
unused organic laboratory standards.
The waste is characterized as Resource
Conservation and Recovery Act (RCRA) regulated, Toxic Substances Control Act
(TSCA) regulated PCB, low-level radioactive waste.
Table 2
FY 04 & FY05 Rocky Flats, Fernald and Mound LLW Shipments
Site
Rocky Flats
Fernald
Mound
Stream
MLLW
MLLW
LLW
LLW
LLW
LLW
LLW
Destination
Envirocare
Hanford
NTS
Envirocare
Envirocare
Envirocare
NTS
Quantity FY04 (m3)
14,227
0
63,500
86,900
110,000
41,000
5,120
Quantity FY05 (m3)
20,913
1,000
51,000
197,000
122,000
60,643
3,250
Originally, Rocky Flats had a number of waste streams designated as orphan. They have
now resolved the treatment and disposal issues for these formally orphan waste streams.
As an example of how Rocky Flats solved problematic waste streams disposal, one
orphan waste stream was drums of RCRA/PCB waste requiring thermal treatment. The
bulk of the RCRA/PCB drums, ~ 25 drums, went to Permafix for thermal destruction,
thermal desorption treatment prior to disposal at Envirocare. The remaining RCRA/PCB
drums, ~ 5 drums, did not meet Permafix’s Waste Acceptance Criteria (WAC). Rocky
Flats added these drums to the Toxic Substances Control Act Incinerator (TSCAI) burn
plan.
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As another example of problematic waste disposition, Rocky Flats shipped approximately
690 half crates B374 Solidified Bypass Sludge and B374 Wet Slurry to WCS for
stabilization. This waste is alpha contaminated MLLW between 10 – 100 nCi/gm, which
was intended for disposition at Hanford. Because of a current lawsuit by the State of
Washington and a recently passed ballot initiative prohibiting the importation of nuclear
waste into the State of Washington, the B374 waste remained in storage at WCS. Rocky
Flats sent B Pond sludges to WCS where they were blended with the B374 wastes until
the composite mixture met the Envirocare WAC for disposition at Envirocare.
Portsmouth and Paducah
The Portsmouth Project has several problematic waste streams. Some RCRA-regulated
Portsmouth waste streams are troublesome because key radiological constituents (99Tc,
235
U, and/or 235U assay) exceed the Nuclear Regulatory Commission license limits, and
therefore the waste acceptance criteria (WAC) of commercial mixed waste treatment
facilities. Appendix E contains a list of problematic Portsmouth waste streams.
The Paducah Site Office has one orphan waste stream, a 14.5 kg, 0.21 m3 container of a
RCRA mixed wood preservative, pentachlorophenol. This is a MLLW containing dioxin
with a listing of F027 and D037. Perma-Fix is the only mixed waste treatment facility
permitted for the F027 code. Currently there is no disposal option for treated F027 waste
in the United States. The Paducah Site Office plans to treat the waste at Perma-Fix and
then return the treated F027 waste to the site. They will then try to delist the treated F027
waste for disposal at Envirocare or NTS. In addition, there may be other Paducah
problem waste streams because a significant amount of waste from the Paducah DOE
Material Storage Area (DMSA) and D & D projects has not been fully characterized.
The Portsmouth and Paducah Project Office (PPPO) does not yet have an estimate of the
total lifecycle amount of LLW and MLLW. They have an estimated amount for the work
scope contained in both sites’ current contracts. This information is presented in
Appendix E, Table E-1. A detailed estimate of the total lifecycle LLW/MLLW from both
sites will be developed later. The Portsmouth site will transition into full scale D&D
shortly, with the Paducah site following into D&D in the 2010-2012 timeframe.
Savannah River Site
The Savannah River Site (SRS) disposes of LLW on site in either slit trenches (lower
activity waste, mainly soil and debris), engineered trenches (higher isotopic
concentrations), or vaults (still higher activities and large equipment). Some LLW is also
disposed off-site at NTS or Envirocare. SRS LLW and MLLW streams planned for offsite disposition through FY 2030 is presented in Appendix A, Table A-1. The
information in this table originates from the DOE Waste Information Management
System (WIMS) database. SRS disposed of most of their LLW and MLLW streams onsite, with off-site disposal occurring at Envirocare and NTS. SRS has not identified any
treatment or disposal orphan waste streams.
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Oak Ridge
The LLW and MLLW disposition data through FY 2030 for the Oak Ridge Site, which
consists of the Oak Ridge National Laboratory (ORNL) and the National Nuclear
Security Administration (NNSA) Y-12 site, is listed in Appendix B, Table B-1, which is
extracted from the WIMS database.
Table B-2 in Appendix B presents the current list of Oak Ridge problematic waste
streams. A number of the waste streams are orphans because they contain classified
shapes. There is a lack of treatment capacity for classified mixed waste. Materials and
Energy Corp. (M&EC), an operating Oak Ridge contractor, plans to install a classified
treatment and storage capacity under a special security plan. This should be operational
soon.
Idaho National Laboratory
The Idaho National Laboratory (INL) disposes of most of its LLW on-site at the
Radioactive Waste Management Complex (RWMC). The contact-handled (CH) LLW is
sent to the CH-LLW disposal pit while the remote-handled (RH) LLW goes to the RHLLW concrete vaults.3
The projected INL waste streams are listed in Appendix C, Tables C-1 and C-24. This
table omits LLW to be disposed in the INEEL Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) Disposal Facility (ICDF). The ICDF data is
currently unavailable. Table C-3 lists the known INL orphan waste streams.
DOE Richland and the Office of River Protection
Appendix D presents and LLW and MLLW data from the Richland Operations Office
and Office of River Protection, referred to collectively as Hanford. The data is derived
from the “Final Hanford Site Solid, Radioactive and Hazardous Waste Program EIS”
document # DOE-EIS-0286F, Appendix B.5 All Hanford LLW and MLLW will be
disposed on site at the Integrated Disposal Facility (IDF). CERCLA wastes are
dispositioned at the Environmental Restoration Disposal Facility (ERDF). Although
Hanford does not plan to ship any LLW or MLLW off-site for disposal, a few MLLW
streams will be sent to either PECoS or Permafix for treatment. The PECoS facility will
treat the waste by macroencapsulation and stabilization while the Permafix facility will
conduct thermal treatment.
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Commercial Contract Vehicles and Associated Costs
Envirocare
There are three contract vehicles available complex wide, through the DOE Ohio Field
Office, through the Oak Ridge Operations Office or via the DOE Chicago Operations
Office. In addition, the U.S. Army Corps of Engineers plans on establishing a new
Envirocare contract in the 2005 autumn. The costs for using each contract are presented
in Table 3. Costs are per October 2004.
In addition to the above, some DOE sites have direct contracts with Envirocare. For
example, SRS has a contract with Envirocare that is very similar to the Oak Ridge
contract. Also, the INEL M&O contractor, BBWI, has their own contract with
Envirocare. Currently Hanford is not disposing waste at Envirocare. Should they require
Envirocare’s services in the future, they indicated they would probably contract directly
with Envirocare.
U.S. Ecology
U.S. Ecology has disposal contracts with the U.S. Army Corps of Engineers and the U.S.
Army Joint Munitions Command. These contracts are available for use by the DOE. The
Corps of Engineers contract pertains to the U.S. Ecology Grandview Idaho site and has
been recently extended, while the Joint Munitions Command contract is applicable to
either the Grandview or Richland facilities.
The U.S. Ecology base disposal rate at their Richland facility is $80.00 per ft3 plus
$10,640 per manifested shipment plus $5,440 per container on each manifest. In addition
to the base rate there are further charges based on the dose rate on the container surface
and some supplementary taxes and fees.
Barnwell
Barnwell has the highest disposal rates among the three commercial disposal facilities.
The rates for Atlantic Compact generators, i.e. South Carolina, New Jersey and
Connecticut, are $263 per ft3 for class A, $368 per ft3 for class B, and $394 per ft3 for
class C. In addition, there is a $6.00 per ft3 compact surcharge. For generators outside of
the Atlantic Compact, the base rate is $600 per ft3 with an additional $6.00 per ft3
surcharge. Barnwell also has a calculated rate based on the waste amount and dose rate.
The larger of the two rates, base rate or calculated rate, is applied. Furthermore,
Barnwell charges an additional $0.399 per mci for all shipments equal or greater than 100
mci.
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Table 3
Envirocare LLW/MLLW Contracts Available to EM Sites
Contracting
Site
Chicago
Oak Ridge
Ohio
Contract #
AM0202CH11136
(9/2002-9/2007)
AC0504OR22693
(6/2004-5/2009)
AM2498OH20053
(7/1998-6/2008)
Contract
Services
Waste
Category
Treatment and
Disposal
MLLW Soil-Like
$1,382(1)(2)
MLLW DebrisLike
$1,848(1)(2)
MLLW MicroEncapsulation
$2,778 to
4,610(1)(2)(3)
MLLW Soils
Ranges from
$528 at 13,000
yd3 to $309 at
28,000yd3 (4)
MLLW Debris
$746 @ 13,000
yd3 to $527 @
28,000 yd3 (4)
LLW Soils
$ 145 (5)(6)
LLW Debris
$ 397 (4)
Disposal Only
Disposal Only
Cost ($/yd3)
Note: The Corps of Engineers anticipates establishing a new contract with Envirocare
during the autumn of 2005.
(1) The annual escalation factor is 1.5%.
(2) The treatability study is approximately $16,000 for each different waste stream;
also add 4% for winter shipments.
(3) The charge varies depending upon the type of container, e.g. 55 gal. drum vs. a B25 box.
(4) Price fixed for the duration of the contract.
(5) For lined railcar/truck with disposable containers. For unlined railcar/truck with
lined containers add $28-30 per yd3.
(6) Annual escalation factor of 2%.
Rev.0
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17 May 05
DRAFT
Other Contract Vehicles
Other contract vehicles may be available for DOE sites. For example, the DOD
Executive Agency for Low Level Radioactive Waste, part of the, Army Field Support
Command, can negotiate contracts with any of the waste treatment/disposal facilities
discussed above.
Pre-Disposal Costs
When considering the disposal cost of a given waste stream, the actual fee paid to the
TSD facility is a fraction of the total cost. A significant portion of the total LLW/MLLW
treatment/disposal cost are the expenses incurred in preparing and shipping the waste,
referred to as pre-disposal generator costs. The primary components of pre-disposal
generator costs are waste characterization, treatment, packaging and transportation.
A DOE report on life cycle costs of waste disposal estimated that pre-disposal costs may
represent as much as 90% of the total cost6. Unit pre-disposal costs are strongly
influenced by the radioactive constituents in the waste, the physical form of the waste, the
origin of the waste, its point of generation relative to its disposal destination, and the
waste volume. Because the Department disposes of a wide variety of LLW/MLLW, the
amount of pre-disposal costs also varies extensively depending on the waste stream. Predisposal costs for on-site CERCLA disposal cells are much lower than for other TSD
facilities because of the low costs associated with bulk landfill disposal as well as the
large waste volumes. On the other hand, low volume waste streams requiring treatment,
extensive characterization and special packaging could require pre-disposal cost
exceeding $5,000/m3.
The authors of the DOE report reference above conclude that it is difficult to accurately
assess pre-disposal costs because the pre-disposal cost elements (characterization,
treatment, packaging and transportation) are not customary DOE project accounting
categories. There is no uniform complex-wide protocol for collecting and reporting such
costs. However, because pre-disposal costs represent such a significant fraction of the
total life cycle waste disposal costs, they also represent a significant life cycle cost
savings opportunity.
LLW and MLLW Disposition Gap Analysis
Given the LLW and MLLW disposition data above, the study team conducted a gap
analysis to identify potential bottlenecks and disposal capacity. First, the team designed a
Waste Breakdown Structure (WBS) to categorize each major waste stream from the
Phase I sites. The WBS is discussed in more detail in Appendix F. We then classified
each waste stream per the WBS. The Phase I off-site LLW/MLLW treatment and
disposition paths were then mapped onto an integrated waste disposition template.
In general, adequate capacity exists at both commercial and federal disposal facilities for
the bulk of the Department’s LLW. However, disposal of alpha MLLW between 10 Rev.0
14
17 May 05
DRAFT
100 nCi/gm remains a problem. The Department had planned to dispose of this type of
waste at the Hanford site. Currently, legal obstacles preclude this disposal option. The
State of Washington is suing the Department to prevent the importation of radioactive
waste, including LLW. Issues pertaining to a recently-passed Washington state ballot
initiative, Initiative 297, also need to be resolved before LLW shipments to Hanford can
be resumed. The Department is now storing MLLW between 10 – 100 nCi/gm until
Hanford becomes available. Should LLW shipment to Hanford remain impossible, the
Department will have to consider commercial disposal options. At present there are no
commercial waste sites that can accept alpha LLW between 10 - 100 nCi/gm. However,
WCS has applied for a license modification that will allow it to dispose of LLW and
MLLW, including this category of waste.
Currently, each EM site is responsible for the disposal of its Low Level Waste (LLW).
This decentralized approach could result in decreased cost efficiencies. For example,
across the DOE Complex multiple contractors may seek disposal options for the same or
very similar material. Consequently, opportunities may be missed for economies of
scale. Sites cannot take advantage of economies of scale if they are seeking individual
disposal contracts. Furthermore, sites may be competing for waste disposal capacity or
overwhelming capacity because of schedule overlaps. Inefficiencies may also result
because individual sites need to maintain duplicative capabilities. For example, small
generators must maintain characterization programs for relatively small volumes and lack
of priority for LLW disposal can result in costly storage. In addition disposal of some
Mixed Low Level Waste (MLLW) can be difficult. Federal and commercial treatment
capacity for most MLLW exists, but these treatment facilities have limited throughput
and storage space. Individual sites often compete for access to treatment. Furthermore,
there is no offsite disposal path available today for MLLW with radionuclide
concentrations levels of 10 – 100 nCi/g (alpha MLLW).
Although adequate treatment and disposal capacity exists for the bulk of the
Department’s LLW and MLLW, some bottlenecks exist in throughput capacity.
Treatment facilities have limited throughput and storage space, which may result in
individual sites competing for access, e.g. TSCAI. As another example of a bottleneck,
ORP’s revised plan for Hanford Tank waste may generate approximately 600 m3 of
MLLW that may require thermal treatment. The throughput of the existing demo plant is
inadequate to achieve the closure plan schedules. The current plant would require 70
years to treat all the tank waste. Even when adequate capacity exists, MLLW shipments
may be infrequent, thereby stressing capacity at certain times of the year while under
utilizing the same capacity at other times.
Conclusions and Recommendations
There is adequate capacity at both DOE and commercial Treatment, Storage and Disposal
(TSD) facilities for the bulk of the Department’s LLW and MLLW. However, as noted
in the gap analysis discussion above; problematic MLLW and 10-100 nCi/g orphan waste
streams exist. To increase the efficiency of LLW and MLLW disposal, this report makes
the following recommendations:
Rev.0
15
17 May 05
DRAFT
Consolidate Problem Wastes Prior to Treatment or Disposal
To mitigate treatment or disposal bottlenecks, the Department could consolidate
problematic wastes in a centralized location. This central facility could receive wastes
from other sites to accelerate cleanup and prepare the waste for treatment and disposal.
This would reduce the infrastructure and expertise requirements at each individual site for
characterization, processing, and packaging. Consolidation should occur at sites with
longer term missions and the appropriate NEPA analyses in place. Waste consolidation
will allow sites to remove wastes, reduce the mortgage associated with storage, and
enhance coordination of treatment and disposal opportunities. Consolidation may allow
for an economy of scale as all similar wastes, even from different sites, could be disposed
of in a single campaign.
This should reduce the cost to disposition small waste quantities. The sites with small
waste quantities would still characterize waste to the consolidated site’s WAC. Once the
waste was consolidated, the cost per unit for disposing of the waste should be reduced by
the economy of scale. Consolidating waste would provide cost savings by reducing
overhead and mortgage costs at individual sites. For example, the alpha contaminated
MLLW between 10 - 100 nCi/g, could be consolidated and stored until a suitable disposal
site became available. This may also reduce the inter-site competition for treatment and
disposal capacity. Problematic wastes could be stored at the consolidation site until
treatment schedules can be synchronized more efficiently between the storage and
treatment/disposal site.
Develop a LLW/MLLW Database
A centralized LLW/MLLW database can assist the Department in developing a corporate
approach to LLW/MLLW treatment and disposal and consequently improve efficiencies.
As observed above, because each site disposes its LLW and MLLW individually,
opportunities may be lost for economies of scale. Multiple sites with similar waste
streams may be able to negotiate more favorable disposal rates. Furthermore, with each
site independently disposing waste, some sites may be maintaining duplicative
capabilities. In addition to capacity issues, lack of centralized planning may result in
various sites competing for limited treatment or disposal capability, e.g. TSCAI.
Previously, EM had developed such a centralized database, the Integrated Planning,
Accountability, and Budgeting System (IPABS) Stream Disposition Data (SDD). This
system documented EM’s management strategy for more than 4,000 waste, contaminated
media, spent fuel, and nuclear materials streams. Because of the complexity of the effort,
EM discontinued the IPABS SDD. It may, however, be feasible to develop a system of
fewer waste streams and minimal data that can meet the Department’s corporate need
without being onerous. Perhaps the WBS developed during this project could prove to be
an acceptable starting point.
Cost information could be a significant component of any LLW/MLLW database.
However, there are no uniform requirements for defining, monitoring and reporting waste
Rev.0
16
17 May 05
DRAFT
disposal costs. Across the Complex, there are significant site-to-site protocol differences
in collecting cost information. If the Department is to use life cycle cost metrics to guide
disposal site decisions, standardized protocols should be established to improve the bases
for such decisions and for any subsequent analysis.
Reduce Pre-Disposal Costs
Pre-disposal costs are those costs incurred in preparing and transporting a given waste
stream for disposal. Pre-disposal costs typically include: waste characterization, waste
treatment, packaging and transportation. Pre-disposal costs are a major portion of the
total waste disposal cost and therefore represent significant life cycle cost savings
opportunities. Pre-disposal cost savings may be realized by:



Rev.0
Developing a common pre-disposal cost chart of accounts for use by all waste
generators.
Re-evaluating site generator pre-disposal costs on a common basis.
Establishing contractor incentives to reduce pre-disposal costs.
17
17 May 05
DRAFT
References
1. General Accounting Office (GAO) report GAO-04-604, Low-Level Radioactive
Waste, Disposal Availability Adequate in the Short Term, but Oversight Needed to
Identify any Future Shortfalls, dated June 2004.
2. Record of Decision for the Solid Waste Program, Hanford Site Richland WA:
Storage and Treatment of Low Level Waste and Mixed Low Level Waste and
Storage, Processing and Certification of Transuranic Waste for Shipment to the
Waste Isolation Pilot Plant, Federal Register, Vol. 69 No. 125, dated 30 June
2004.
3. Adler Flitton, M.K. and Mullen, C.K., Low-Level Waste Forecasting Assessment
for the Idaho National Engineering and Environmental Laboratory, EDF-1591,
Rev. 3, dated Aug. 2003.
4. Low-Level Waste Forecasting Assessment for the Idaho National Engineering and
Environmental Laboratory, EDF-1591, Revision ID: 4; dated 22 July 2004.
5. Final Hanford Site Solid, Radioactive and Hazardous Waste Program EIS,
document # DOE-EIS-0286F, Appendix B, dated Jan. 2004.
6. U.S. Dept. of Energy, Office of Environmental Management, Report to Congress,
The Cost of Waste Disposal: Life Cycle Cost Analysis of Disposal of Department
of Energy Low-Level Radioactive Waste at Federal and Commercial Facilities,
dated July 2002.
Rev.0
18
17 May 05
DRAFT
APPENDIX A
SAVANNAH RIVER SITE
Table A-1
Off-Site Disposition of Savannah River Site LLW and MLLW Streams
Material
Quantity (m3)
Destination
FY05
FY06
FY07
FY08
FY09
FY10
FY11FY15
FY16FY20
FY21FY25
FY26FY30
MLLW
Debris
Envirocare
5.12
5.12
0
0
0
0
0
0
0
0
MLLW
Metal
Envirocare
0.6
0.6
0.61
0
0.61
16.5
166.1
85.7
13.5
0.2
MLLW
Debris
Envirocare
0.4
0.4
0.4
0.4
0.4
0.4
2.0
2.0
2.0
2.0
MLLW
Other Liq.
Envirocare
0.08
0.08
5.9
11.7
11.7
11.7
58.5
39.8
7.0
0
MLLW
Other Liq.
Envirocare
0.9
0.9
0.9
0.9
0.9
0.9
4.4
0
0
0
MLLW
Soil, Sed.,
Sludge
Envirocare
1.2
1.2
0.9
0.6
0.6
0.4
3.0
4.0
4.5
4.2
MLLW
Debris
Envirocare
80.5
80.5
18.3
56.8
16.6
17.7
116.1
119.8
233.4
146.3
LLW Soils
Sed.
Sludge
NTS
5681
5681
0
0
0
0
0
0
0
0
MLLW
Metal
Envirocare
1.2
1.2
0.4
0.4
0.4
0.4
2.1
0.4
0
0
MLLW
Debris
Envirocare
0.3
0.3
0
0
0
0
0
0
0
0
Rev.0
19
17 May 05
DRAFT
APPENDIX B
OAK RIDGE NATIONAL LABORATORY
Table B-1, Disposition of Off-Site Oak Ridge LLW and MLLW Streams
Destination
Material
NTS
LLW Debris
LLW Soil*
LLW Metal
LLW Liq..
LLW Debris
LLW Metal
LLW Debris
LLW Soil*
LLW Metal
MLLW Debris
MLLW Soil*
MLLW Liq.
MLLW Debris (1)
MLLW Debris (2)
MLLW Debris (3)
LLW Metal (3)
LLW Debris (4)
LLW Debris (3)
MLLW Debris (3)
MLLW Soil (3)*
MLLW Metal (3)
MLLW Debris (3)
MLLW Debris (3)
LLW Soil* (3)
LLW Debris (3)
LLW Debris (3)
LLW Debris (3)
MLLW Soil* (3)
LLW Soil* (3)
LLW Metal (3)
LLW Metal (3)
LLW Debris (3)
LLW Debris (3)
LLW Debris (3)
MLLW Debris (3)
GTS
Duratek
Envirocare
TSCAI
TBD
(orphans)
Quantity (m3)
FY05
FY06
FY07
FY08
FY09
FY10
11-15
16-20
21-25
26-30
4211
1053
4006
10
10
0
347
645
0
2764
9
69
0
0
0
0
0
0
0
0
0
1144
8.1
1.5
0
36.4
0
0
0
0
0
0
0
2.21
223
4274
33
1928
10
10
0
271
5923
28
74
9
83
0.43
6.5
7.4
45
0
158.7
955.7
3410
295
581.5
8.1
1.5
1.6
35.4
0
0
0
0
7.8
0
66.5
1.1
3640
3086
0
417
10
0
0
274
334
4
0
9
0
0
0
8.2
15
0
158.7
955.7
3410
548
721.0
8.1
1.5
3.0
36.4
0
21.2
0
163
46.7
259
395
0
4250
419
0
8
0
0
17
717
231
64
0
8640
0
0
0
5.8
0
0.01
0
0
0
0
51.1
0
0
0
0
0
21.2
0
163
23.3
259
204
0
133
193
0
0.4
0
0
0
694
9
152
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
27.8
0
0
2
0
3140
0
0
0
966
26
159
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0.25
0
52.8
0
0
0
27.8
0
0
2
0
9411
0
0
0
106
0
27
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0.03
0
52.8
0
0
0
6.9
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
*
Soil, Sediment and Sludge
(1)
(2)
(3)
(4)
Rev.0
Orphan – no existing LDR treatment and disposal options.
Orphan – No existing pretreatment option to remove classification issues.
Orphan – Undecided destination, incomplete characterization.
Orphan – Technology gap. Seven unirradiated mixed oxide (MOX) fuel rods
containing U and Pu.
20
17 May 05
DRAFT
Table B-2,
Oak Ridge LLW and MLLW Problematic Waste Streams
Waste
Stream
Remain
On-Site
Containers
Final
Treated
Vol. (m3)
Planned
Treatment
Planned
Treat
Facility
Lack of Treatment
capacity for classified
MW.
Classified
Mixed
Waste
(D-Codes)
99
50.65
Shred
Stabilization
M&EC
Classified
Mixed
Waste
(F-Codes)
16
4.17
Shred/VTD/
stabilization/
debris wash
M&EC
Classified
Mixed
Waste
(U-Codes)
3
Dioxin/Fur
an Mixed
Wastes
Planned
Disposal
Status
18
1.3
8.06
Shred/VTD/
stabilization/
debris wash
VTD/
debris wash/
Chem Ox
M&EC to install
classified
treatment/storage
capacity under special
security plan.
Lack of treatment
capacity and RCRA
Subtitle C disposal
capacity for classified
mixed waste.
M&EC to install
classified
treatment/storage
capacity under special
security plan.
Lack of treatment
capacity and RCRA
Subtitle C disposal
capacity for classified
mixed waste.
M&EC
M&EC to install
classified
treatment/storage
capacity under special
security plan.
Lack of RCRA Subtitle
C disposal capacity.
M&EC
M&EC to install
classified
treatment/storage
capacity under special
security plan for
classified portion (6
containers)
NTS
NTS/
Hanford
NTS/
Hanford
NTS/
Hanford
Envirocare to submit
permit modification to
include dioxin/furan
waste codes.
Rev.0
21
17 May 05
DRAFT
Table B-2, Oak Ridge LLW and MLLW Problematic Waste Streams (Continued)
Waste
Stream
RH Mixed
Wastes
Combust
Code
Mixed
Wastes
RTG
Remain
On-Site
Containers
1
150
Final
Treated
Vol. (m3)
0.42
31.2
Planned
Treatment
Stabilization
VTD
Planned
Treat
Facility
M&EC/
ORNL
M&EC
Planned
Disposal
Status
Lack of treatment
capacity for RH MW.
Evaluating facility
modifications at M&EC
to handle high dose.
Working agreement to
treat at ORNL hot cell
under TDEC temporary
authorization or permit.
Lack of treatment
capacity for mixed
wastes bearing
combustion technology
treatment standards.
NTS
E-Care
Submit application for
variance for alternative
treatment technology
IAW 268.42.
Lack of approved Type
B cask for shipment
and burial at NTS.
2
0.1
None
None
Obtain NTS determnatn
on Type B equivalent
inner package for disp.
NTS
Revise shipping Cask
CoC/SARP for Sr-90
RTG’s.
Dose hazards associated
with repackaging.
Generator characterztn
inadequate for NTS.
Perform characterztn.
RH LLW
Vaults
29
116
None
None
Design and certify DOT
compliant packaging
for Type A shipment.
NTS
Vaults do not meet
DOT Type A/B specs.
Repackage some vault
contents into smaller
DOT complaint
packages.
Rev.0
22
17 May 05
DRAFT
APPENDIX C
IDAHO NATIONAL LABORATORY
Table C-1
Disposition of Idaho National Laboratory LLW Streams, FY05 – FY12
Waste
Type
CH
RH
Quantity (m3)
Destination
FY05
FY06
FY07
FY08
FY09
FY10
FY11
FY12
RWMC
10,455
6,012
6,045
6,017
4,812
4,284
4,267
4,167
Hanford
0.5
0.27
0.51
150
900
900
900
900
NTS
0
0
0
0
360
360
360
360
Total
10,455
6,012
6,045
6,167
6,072
5,544
5,527
5,427
RWMC Vaults
66
64
64
64
64
2
2
2
RWMC Bulk
Pit
47
63
59
64
64
64
64
64
Hanford
0
0
0
0
0
27
27
27
Hanford GTC3
Total
0
0
0
0
0
3
3
3
113
127
123
128
128
96
96
96
Table C-2
Disposition of Idaho National Laboratory LLW Streams, FY13 – FY30
Waste
Type
CH
RH
Quantity (m3)
Destination
FY13
FY14
FY15
FY16-20
FY21-25
FY26-30
RWMC
919
919
1,030
3,797
3,784
3,784
Hanford
900
900
900
4,500
4,200
4,200
NTS
360
360
360
0
0
0
Total
2,179
2,179
2,290
8,297
7,984
7,984
RWMC Vaults
2
5
5
12
17
12
RWMC Bulk Pit
41
39
39
207
201
207
Hanford
27
27
27
133
133
133
Hanford GTC3
3
3
3
13
13
13
Total
73
74
74
365
364
365
CH = Contact handled waste
RH = Remote handled waste
RWMC = Radiological Waste Management Complex
Remote handled waste is defined by the Idaho National Engineering and Environmental
Laboratory Waste Acceptance Criteria as waste having a radiation limit of > 500 mR/h at
1 meter. Conversely, contact handled waste is defined by the same document as waste
having a radiation limit < 500 mR/h at 1 meter.
Rev.0
23
17 May 05
DRAFT
Table C-3
Idaho National Laboratory Orphan Waste
Containers
Volume
(m3)
Treatment
Disposal
1
3.09
Macro
Envirocare
1
0.68
ANL
RWMC
17
30.90
Macro/Stab
Envirocare
1@
PECoS
WIR (has been
resolved)
88
121.57
Macro/Stab
Hanford
21 @
PECoS
Class B&C; U134; Hanford
Disposal
Opening
10
7.47
Macro
Hanford
3@
PECoS
Class B&C;
Hanford
Disposal
Opening
12
33.38
Aerosols/Stab/DF
INEEL/PECoS/PESI/Envirocare
35
7.46
Thermal
Envirocare
30
20.39
Specialty
WIPP
6
4.09
Direct Disposal
Hanford
200
229.02
Total
Rev.0
Status
Issues
Transportation
S1G Sodium
Specialty
PCB’s
TRU
Hanford
Disposal
Opening
25 @ PECoS
24
17 May 05
DRAFT
APPENDIX D
RICHLAND OPERATIONS OFFICE AND THE OFFICE OF RIVER
PROTECTION
Table D-1
LLW Generated by Hanford (Richland and ORP) (m3)
Stream
#
1
2
Stream
Name
LLW
Cat1
LLW
Cat3
2005
2006
2007
2008
2009
2010
2011
3,107
3,120
3,117
3872
4,611
3,827
3,902
20122046
36,156
561
551
534
534
349
345
1,513
30,782
The above data are from the “Final Hanford Site Solid, Radioactive and Hazardous Waste
Program EIS” document # DOE-EIS-0286F, Appendix B
Cat 1 LLW is the largest waste volume at Hanford. It has the lowest radioactive
concentrations and can be placed directly into the Low Level Burial Ground (LLBG)
trenches without treatment and, in some cases, without additional packaging. Cat 1 LLW
can be either CH or RH waste.
Originally, Cat 2 LLW was defined. However, this category was a small waste volume
and now the previous Category 2 material is managed as Cat 3 LLW. Cat 3 LLW is
defined as having radionuclide concentrations greater than the limits specified in the
Hanford Site Solid Waste Acceptance Criteria (HSSWAC) for Cat 1 LLW, but lower
than the maximum concentration limits defined for Cat 3 LLW. Cat 3 LLW is similar to
Cat 1 LLW except that it has a higher concentration of certain radionuclides and requires
greater confinement for burial in the LLBG. Cat 3 LLW may also be CH or RH waste.
Greater confinement in the LLBG has typically been provided by either packaging the
wastes in high-integrity containers (HIC) or by in-trench grouting prior to burial. Typical
sources of Cat 3 LLW are operation or cleanout of hot cells and canyon facilities,
removal of HLW storage tank equipment, and other operations that handle higher activity
items.
Hanford is not planning on shipping any LLW or MLLW off-site for disposal. They will,
however, be shipping some MLLW off-site for treatment.
Rev.0
25
17 May 05
DRAFT
Table D-2
LLW from Off-Site Generators to be Received by Hanford (m3)
Stream
#
1
2
Stream Name
2005
2006
2007
2008
2009
2010
2011
LLW
Cat 1
lower
bound
663
1,121
376
369
387
369
373
20122046
11,669
upper
bound
20,585
21,043
20,298
20,291
2,798
2,764
3,980
82,892
lower
bound
115
17
25
18
17
17
17
621
upper
bound
2,293
2,196
2,203
2,196
281
279
412
8,408
LLW
Cat 3
The lower bound numbers include wastes from off-site generators approved for shipment
to Hanford. The upper bound numbers include all waste in the lower bound data as well
as potential future off-site waste that may be managed at the Hanford site.
Table D-3
MLLW Generated by Hanford (Richland and ORP) (m3)
Stream
#
11
Stream
Name
Treated
& Ready
for Disp.
2005
2006
2007
2008
2009
2010
2011
1,183
863
1,111
1,612
2,164
2,136
2,613
20122046
12,726
12
RH &
NonStandard
111
97
43
56
112
118
123
1,743
13A
CH
Inorg.
Solids &
Debris
426
377
329
368
385
381
688
12,724
13B
CH Org.
Solids &
Debris
190
187
160
171
201
190
153
2,241
14
Elemental
Lead
10
11
8
9
10
9
6
65
15
Elemental
Mercury
0
1
1
1
1
1
1
1
MLLW Treated and Ready for Disposal – waste that has been treated meet the applicable
RCRA and state requirements for land disposal. The River Protection Project (RPP) will
Rev.0
26
17 May 05
DRAFT
be the primary Hanford generator of MLLW. The RPP waste includes long length
equipment from Hanford tank retrieval operations which will be macroencapsulated.
MLLW received from off-site generators is assumed to arrive in a regulatory compliant
form and ready for disposal.
MLLW RH and Non-Standard Packages – this waste has physical and chemical
characteristics similar to other MLLW, but requires a shielded facility and special
equipment for remote handling. In the future, some non-standard packages of CH waste
may also be received for which there is no treatment facility. This waste would remain in
storage until treatment facilities are available.
MLLW CH Inorganic Solids and Debris – Inorganic solid waste may include substances
such as sludges, paints and dried inorganic chemicals. Debris waste must meet the
requirements defined in state regulations. Inorganic debris waste often contain metal,
ceramic, and concrete items and may result from removal of failed or obsolete equipment
or from disposal of items used in process operations. They may also result from the
cleanout or decommissioning of inactive facilities. These wastes generally require
treatment by stabilization or macroencapsulation before disposal.
MLLW CH Organic Solids and Debris – Organic solid waste may include substances
such as resins, organic absorbents, and activated carbon. Organic debris waste meet the
regulatory requirements for debris waste and have a great than 10%
organic/carbonaceous content. Typical wastes include paper, wood and plastic. These
wastes are normally required to be thermally treated if capacity is available. As there are
no Hanford facilities with thermal treatment capability, DOE has been authorized to treat
organic debris waste by macroencapsulation.
MLLW Elemental Lead – Most of the lead waste has surface contamination and some of
the lead is radioactive from neutron activation. Some lead must be treated as mixed
waste by macroencapsulation, or other approved technology, before disposal.
MLLW Elemental Mercury – Elemental mercury is a contaminant for several different
types of waste. Waste can contain liquid mercury from various items (e.g. switches,
thermometers and chemical process equipment). Mercury can be removed from bulk
waste by thermal desorption and then solidified by amalgamation.
Table D-4 provides the Hanford’s expectations of the MLLW streams that may arrive
from other sites in the complex. As in Table D-2, the lower bound numbers include
wastes from off-site generators approved for shipment to Hanford. The upper bound
numbers include all waste in the lower bound data as well as potential future off-site
waste that may be managed at the Hanford site. MLLW from off-site generators is
assumed to arrive in a regulatory compliant form and ready for disposal.
Rev.0
27
17 May 05
DRAFT
Table D-4
MLLW from Off-Site Generators to be Received by Hanford (m3)
Stream
#
11
12
13A
13B
14
15
Stream Name
Treated
&Ready
for
Disposal
lower
bound
0
0
0
0
0
0
0
20122046
28
upper
bound
19,500
19,500
19,500
19,500
1,521
1,305
1,307
38,731
RH &
NonStandard
lower
bound
0
0
0
0
0
0
0
0
upper
bound
0
0
0
0
0
0
0
0
CH
Inorg.
Solids &
Debris
lower
bound
0
0
0
0
0
0
0
0
upper
bound
0
0
0
0
0
0
0
0
CH Org.
Solids &
Debris
lower
bound
2
2
2
2
2
2
2
43
upper
bound
2
2
2
2
2
2
2
43
Elemental
Lead
lower
bound
0
0
0
0
0
0
0
0
upper
bound
0
0
0
0
0
0
0
0
lower
bound
0
0
0
0
0
0
0
0
upper
bound
0
0
0
0
0
0
0
0
Elemental
Mercury
2005
2006
2007
2008
2009
2010
2011
Table D-5
MLLW to be sent from Hanford to Commercial Treatment (m3)
2005
2006
2007
2008
2009
2010
2011
628
578
500
551
599
583
850
20122046
15,074
Per the “Final Hanford Site Solid, Radioactive and Hazardous Waste Program
EIS” document # DOE-EIS-0286F, MLLW streams 13A CH Inorganic Solids and
Debris, 13B CH Organic Solids and Debris, 14 Elemental Lead and 15 Elemental
Mercury are to be send to commercial treatment facilities. This table was created
by summing the annual projections from these waste streams.
Rev.0
28
17 May 05
DRAFT
The waste streams will be sent to either PECoS or Permafix. The PECoS facility
will treat the waste by macroencapsulation and stabilization while the Permafix
facility will conduct thermal treatment. Assuming that streams 13 A, CH
Inorganic Solids and Debris, 13 B, CH Organic Solids and Debris and 14
Elemental Lead, will require stabilization or macroencapsulation treatment.
Furthermore, assume stream 15, Elemental Mercury, will require thermal
desorption followed by solidification by amalgamation. The Hanford MLLW
sent to commercial facilities would be:
Table D-6
Hanford MLLW to be Sent to Commercial Treatment, by Treatment Site (m3)
2005
2006
2007
2008
2009
2010
2011
PECoS
628
577
499
550
598
582
849
20122046
15,073
Permafix
0
1
1
1
1
1
1
1
Rev.0
29
17 May 05
DRAFT
APPENDIX E
PORTSMOUTH AND PADUCAH SITES
Table E-1
Disposition of Off-Site Paducah LLW and MLLW Streams (FY05-FY12)
Material
Type
Destination
Debris
Liq./Solv./Oils
PPE Trash
Soil
Soil, Sludge
Envirocare
LLW
Trtmt Residue
Compct Metal
Metal Equip.
UF4 Drums
PPE Trash
TSCA/E-care
Soil
Sludge
Lime Residue
Debris
Trtmt Residue
MLLW Envirocare
PPE Trash
Compct Metal
Excess Chem
Metal Equip.
Solids
TSCA Solids
TSCA/E-care
MLLW
Solids
TSCA/E-care
PPE Trash
Soil
Classifd Metal
Debris
LLW
NTS
Metal Equip.
Asbestos
Solids
TSCA Soil
MLLW TSCA/NTS
Liq. TSCA
MLLW TSCAI
Debris
LLW
TBD
Waste Water
PPE Trash
TBD
DewtrdSludge
Soil
MLLW
Debris
Liq./Solv./Oils
TSCA/TBD
PPE Trash
Compct Metal
Total Envirocare
Total NTS
Rev.0
FY05
Quantity (m3)
FY06 FY07 FY08 FY09 FY10 FY11 FY12
153
0
0
300
0
39
1,928
425
639
0
87
132
0
4
39
0
142
0
715
0
136
0
0
0
0
2,009
2,855
266
0
541
10
1,500
0
0
0
0
1
62
376
0
146,597
5,671
553
0
0
300
0
3
15,821
32,350
0
0
233
1
0
33
0
42
10
0
6
10
0
10
0
0
0
2,301
4,673
0
30
0
0
0
4
0
0
0
1
62
161
0
49,372
7,004
30
708
0
0
7
0
3
1,305
11,069
0
0
1,688
6
0
48
0
0
0
0
10
10
388
10
0
0
0
1,304
0
0
30
387
0
0
4
0
0
75
1
62
161
0
15,246
1,721
866
0
0
0
0
0
1,790
2,145
0
0
1,572
6
0
39
0
0
0
1
10
10
0
10
0
0
0
1,940
36
0
30
0
0
0
1
0
0
75
0
62
287
0
6,449
2,006
5,680
0
0
0
0
<1
1,209
1,703
0
0
927
0
0
72
0
0
0
0
13
10
0
10
0
0
0
2,509
399
743
30
0
0
0
0
0
0
0
0
62
233
0
9,624
3,681
1,098
0
0
0
0
0
0
3,583
0
0
4,166
0
0
52
0
1
0
0
13
10
800
10
0
1,014
0
8
0
0
30
805
0
0
0
0
0
0
0
62
107
0
9,733
1,857
2,385
495
0
5,521
0
0
0
2,297
0
92
9,371
0
0
4
0
12
0
0
0
10
0
10
0
821
0
0
0
0
30
0
0
0
0
0
0
0
0
62
54
0
20,197
851
17 May 05
750
1,485
0
3,675
0
0
0
316
0
36
279
3
0
105
0
0
0
0
0
10
0
10
4
321
0
1,066
0
0
30
0
0
0
0
59
15
592
0
0
0
0
6,669
1,421
DRAFT
Table E-2
Disposition of Off-Site Paducah LLW and MLLW Streams (FY13-FY19)
Material
Type
Destination
Debris
Liq./Solv./Oils
PPE Trash
Soil
Soil, Sludge
Envirocare
LLW
Trtmt Residue
Compct Metal
Metal Equip.
UF4 Drums
PPE Trash
TSCA/E-care
Soil
Sludge
Lime Residue
Debris
Trtmt Residue
MLLW Envirocare
PPE Trash
Compct Metal
Excess Chem
Metal Equip.
Solids
TSCA Solids
TSCA/E-care
MLLW
Solids
TSCA/E-care
PPE Trash
Soil
Classifd Metal
Debris
LLW
NTS
Metal Equip.
Asbestos
Solids
TSCA Soil
MLLW TSCA/NTS
Liq. TSCA
MLLW TSCAI
Debris
LLW
TBD
Waste Water
PPE Trash
TBD
Dewtd Sludge
Soil
MLLW
Debris
Liq./Solv./Oils
TSCA/TBD
PPE Trash
Compct Metal
Total Envirocare
Total NTS
Rev.0
Quantity (m3)
FY13 FY14 FY15 FY16 FY17 FY18 FY19
0
0
31
0
7
0
0
0
0
0
543
2
61
164
0
0
0
0
0
10
0
10
22
2,176
0
1,656
0
0
30
0
0
0
0
59
15
592
0
0
0
1,678
828
3,884
2,049
0
42
0
11
0
0
0
0
0
8,552
0
0
164
0
0
0
0
0
10
0
10
0
3
0
1,656
0
0
30
0
0
0
0
59
15
592
0
0
0
0
10,838
1,689
31
706
0
67
9,884
11
0
0
0
0
0
8,775
0
0
163
0
0
0
0
0
10
0
10
0
0
0
1,656
0
0
30
0
0
0
0
0
15
592
0
0
0
0
19,626
1,686
2,823
0
37
43,107
7
0
0
0
0
0
1,409
0
3
163
0
0
0
0
0
10
0
10
0
0
2,355
1,666
0
0
30
0
0
0
0
59
0
0
0
0
0
0
47,569
4,051
2,823
0
23
45,940
2
0
0
0
0
0
1,319
0
58
40
<1
0
0
0
0
10
0
10
0
0
3,767
405
0
0
30
0
0
0
0
0
0
0
0
0
0
0
50,225
4,202
706
0
3
3
0
0
0
0
0
0
127
0
0
0
<1
0
0
0
0
10
0
10
0
0
3,297
0
0
0
30
0
0
0
0
0
0
0
0
0
0
0
859
3,327
0
0
0
0
0
0
0
0
0
0
6
0
0
0
0
0
0
0
0
10
0
10
0
0
0
0
0
0
30
0
0
0
0
0
0
0
0
0
0
0
26
30
17 May 05
DRAFT
Paducah Waste Streams without Viable Treatment/Disposal Options
The Paducah site has identified one waste steam that may be problematical. The
Pentachlorophenol waste stream does not meet the appropriate Waste Acceptance Criteria
(WAC) because of its EPA hazard code. In addition, there may be other problem waste
streams because there is still a lot of waste from the DMSA and D & D Projects at
Paducah that has not been fully characterized.
RCRA/MIXED WOOD PRESERVATIVE (Pentachlorophenol)
 One container (14.5 kg) (0.21 m3)
 Dioxin waste F027, D037
 Mixed waste
 Perma-Fix is the only mixed waste facility with the F027 code on their permit.
 Currently there is no disposal option for treated F-027 waste in the United States.
 Treat waste at Perma-Fix, and return treated F-027 waste to Paducah.
 Padcuah will try to delist treated F-027 waste for disposal at Envirocare or NTS
Portsmouth (PORTS) Troublesome Waste Streams
Several RCRA-regulated waste streams at PORTS have been identified as troublesome
because one or more of the key radiological constituents (99Tc, 235U, and/or 235U assay)
exceed the Nuclear Regulatory Commission license limits, and therefore the waste
acceptance criteria (WAC), of the available commercial mixed waste treatment facilities
(either Broad Spectrum facilities [PermaFix or Waste Control Specialists] or Envirocare
of Utah). For example, the commercial treatment facilities are generally limited to 350
grams of 235U onsite.
Each of the PORTS troublesome waste streams is briefly summarized below. For each
waste stream, the following information is provided:





The volume currently in inventory
The basis (hazardous waste code) for which it is hazardous
Available radiological characterization information
The treatment technology to be utilized
Projected disposal path for the treated waste
W015 – Heavy Metal Sludge
 26 containers (110’s and B-25’s) (841 ft3; 23.8 m3) (22, 827lbs)
 Characteristic for metals D006, D008, D009
 Many containers with high 235U gram content, 99Tc
 On site Chemical Oxidation/Stabilization treatment
 Disposal at NTS
Rev.0
32
17 May 05
DRAFT
W016 – Microfiltration Sludge and Filters
 10 containers (drums) (41 ft3; 1.2 m3) (1,021 lbs.)
 Characteristic for metals D006, D008
 High 235U gram content
 On site Stabilization treatment
 Macroencapsulation/shredding for filters
 Disposal at Envirocare
W018 – Ion Exchange Resins
 265 containers (drums, B-25s) (3,192 ft3; 90.4 m3) (127,504 lbs.)
 262 drums characteristic hazardous waste (DOO8 - <240 ppm Hg)
 3 B-25 boxes of F001 Resin from x-701E – NOTE: each of these is >200 grams
of 235U in each container
 Some containers with high 235U gram content, some with high 235U assay, 99Tc (1213x106 pCi./g)
 Airborne rad contamination (99Tc, 235U) anticipated during sampling/treatment – may
require a glovebox or some type of enclosure
 On site Stabilization treatment for drums
 On site Vacuum Thermal Desorption (VTD) treatment or possibly offsite TSCAI
Incineration for B-25 boxes (need to evaluate if TSCAI candidate – metals content
and number of grams per box may not meet TSCAI WAC)
 Disposal at NTS
W022 – Waste Decontamination Solids
 412 containers (F Cans, drums) (1,581 ft3; 44.8 m3) (68, 566 lbs.)
 Characteristic for metals D010/D011/D018, also F001/F002
 On site Stabilization treatment
 Disposal at Envirocare
W025 – HEPA Filters
 4 containers (Lab Pack, drum, B-25 box), (202 ft3; 5.7 m3) (2,410 lbs.)
 3 containers characteristic for metals D006/D008/D009
 1 container F001 (Evaluate moving this to MWIR W001 with other F001 Treatment
Filters)
 Some containers with high 235U gram content, some with high 235U assay
 On site Macroencapsulation treatment
 Disposal at Envirocare
Rev.0
33
17 May 05
DRAFT
W026 – Metal Shavings and Scrap
 204 containers (5 are classified) (drums) (1,796 ft3; 50.9 m3) (75,523 lbs.)
 Characteristic for metals D006, D007, D009, (1 unclassified container F001, F002)
 Some containers with high 235U gram content, some with high 235U assay
 1 container on site F001 VTD treatment
 Non classified treat onsite – On site Macroencapsulation treatment or treat at Duratek
followed by disposal at NTS or on site disposal cell
 Classified – must be treated onsite, disposal following treatment at NTS
W027 – X-705A Incinerator Ash
 41 containers (F Cans, Drums) (167 ft3; 4.7 m3), (3,950 lbs.)
 25 are in X-326 L Cage – HEU
 Characteristic for metals D006, D007, D008, D009, D011
 Some containers with high 235U gram content, some with high 99Tc
 Airborne rad contamination (235U, 99Tc, Transuranics) expected
sampling/treatment - may require a glovebox or some type of enclosure
 On site Stabilization treatment
 Disposal at NTS
during
W036 – Seal Dismantling Scrap Metal
 3 containers (drums) (30 ft3; 0.8 m3) (1,269 lbs.)
 Characteristic for metals D006, D008
 Containers expected to have high 99Tc
 On site Macroencapsulation treatment
 Disposal at Envirocare
W043 – Filter Tank Gunk (Dissolved trap material (sludge))
 98 containers (drums) (1,048 ft3; 29.7 m3) (47,990 lbs.)
 Some containers with high 235U gram content, some with high 99Tc
 Characteristic for metal D009
 Additional TCLP metals characterization data needed. Some rad and characterization
data available.
 Airborne rad contamination (235U, 99Tc, Transuranics) expected during
sampling/treatment - may require a glovebox or some type of enclosure
 On site Stabilization treatment
 Disposal at NTS
W059 – Bag Filters
 6 containers (drums) (35 ft3; 1.0 m3) (675 lbs.)
 Characteristic for metals D006/D009/D010/D011
 Containers have high 99Tc
 On site Macroencapsulation treatment
 Disposal at Envirocare
Rev.0
34
17 May 05
DRAFT
W082 – HEU Waste
 2 containers (8 ft3; 0.2 m3) (F- Can, drum)
 F-Can – D011 – Need to evaluate if this needs to be moved to W027 with other Filter
Ash containers
 Drum – Lab Pack Characteristic for metals D008, P015 – Lab Pack container list
indicates presence of Tower Ash – Transuranics present
 Airborne rad contamination (235U, 99Tc, Transuranics) expected during
sampling/treatment - may require a glovebox or some type of enclosure
 Treat drum onsite with disposal at NTS
W083 – Alumina Trap Material
 188 containers (F-Cans, Drums, B-25 Boxes) (1,918 ft3; 54.3 m3)
 Characteristic for metals D004, D005, D006, D007
 Additional TCLP metals characterization data needed. Some rad and characterization
data available.
 Some containers with very high 235U gram content (i.e. 858 grams), some with high
99
Tc
 Airborne rad contamination (235U, 99Tc, Transuranics) expected during
sampling/treatment - may require a glovebox or some type of enclosure
 On site stabilization treatment
 Disposal at NTS
Rev.0
35
17 May 05
DRAFT
APPENDIX F
WASTE BREAKDOWN STRUCTURE
Phase I
1. Level 1 – Generator Program
a. EM – 01
b. NNSA – 02
c. NE – 03
d. SC – 04
2. Level 2 – Generator Site
a. Oak Ridge – 01
b. Savannah River Site – 02
c. Idaho National Lab – 03
d. Hanford (to include the Office of River Protection) – 04
e. Fernald Closure Project – 05
f. Miamisburg Closure Project – 06
g. Portsmouth Project – 07
h. Paducah Site – 08
3. Level 3 – Waste Class
a. Digit 1 – category
i. Unknown = 0
ii. LLW = 1
iii. MLLW = 2
iv. 11e1 = 3
v. 11e2 = 4
vi. 11e3 = 5
b. Digit 2 – Is it GTCC?
i. Unknown = 0
ii. No = 1
iii. Yes = 2
c. Digit 3 – Shielding/Handling Requirements
i. Unknown = 0
ii. CH = 1
iii. RH = 2
d. Digit 4 – Level of transuranic radionuclides
i. Unknown = 0
ii. < 10 nCi/gm = 1
iii. 10-100 nCi/gm = 2
Rev.0
36
17 May 05
DRAFT
Appendix F, Waste Breakdown Structure (WBS), Phase I
4. Level 4 – Physical Waste Description (see note 4)
a. Unknown – 00
b. Debris – 01
c. Metals – 02
d. Soil – 03
e. Liquid – 04
f. Other – 05
5. Level 5 – Treatment (see notes 5, 6 and 7)
a. Unknown – 00
b. None – 01
c. Incineration – 02
d. Macroencapsulation – 03
e. Stabilization – 04
f. Vapor Thermal Desorption (VTD) – 05
g. Supercompaction – 06
h. Solidification – 07
i. Neutralization – 08
j. Metal Decontamination – 09
k. Metal Melting – 10
l. Other – 11
6. Level 6 – Disposal Site
a. Unknown – 00
b. TBD – 01
c. Envirocare – 02
d. WCS – 03
e. U.S. Ecology – Richland, WA site – 04
f. U.S. Ecology – Grandview, ID site – 05
g. Barnwell, SC – 06
h. Oak Ridge Environmental Management Waste Management Facility
(EMWMF) – 07
i. Savannah River Site Waste Management Complex – 08
j. Idaho National Laboratory Radioactive Waste Management Complex
(RWMC) – 09
k. Idaho National Laboratory CERCLA Disposal Site – 10
l. Hanford Low Level Burial Grounds (LLBG) – 11
m. Hanford Environmental Restoration and Disposal Facility (ERDF) – 12
n. Hanford Integrated Disposal facility (IDF) (projected facility) – 13
o. Nevada Test Site Area 5 Radioactive Waste Management Site – 14
p. Nevada Test Site Area 3 Radioactive Waste Management Site – 15
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Appendix F, Waste Breakdown Structure (WBS), Phase I
Notes:
1. The Generator Program, Level 1, is defined as the DOE program who “owns” the
waste now, irrespective of which program may have originally generated the
waste.
2. The WBS will include a dictionary that will define and describe each term and
category.
3. Low Activity Waste is a level 3 waste class item that may be necessary pending
future regulatory action.
4. We plan to also have a separate are, not linked to the WBS, were each individual
waste stream will be described on a separate sheet. This will allow more
information, such as chemical composition, to be included. This section will
augment Level 4, Physical Waste Description.
5. The WBS will use a separate designator in level 5, Treatment, to indicate the site
where treatment is occurring, e.g. Permafix, WCS, Envirocare.
6. The dictionary will explain that in Level 5, Treatment, if a waste stream is treated
and cannot go directly to disposal, it will be treated as a new waste stream. For
example, if a waste stream is to undergo Vapor Thermal Desorption (VTD) and
then will be incinerated; the product from the VTD step is a new waste stream as
it feeds to the incineration step.
7. For the Treatment (5) and Disposal Site (6) levels, the WBS will also include an
“R” or “T” designator to indicate rail or truck transport mode.
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