SYSTEM PLAN

# FOR {#for .unnumbered}

## SOLID WASTE MANAGEMENT {#solid-waste-management .unnumbered}

**Revision 7**

**December 2004**

*Count on us*

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**Loading** **TRU DRUMS** **for Shipment to the WIPP** **IN TRUPACT-II
CONTAINERS**

*to make it happen*

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#  Mission, Critical Success Factors, and Goals

The mission of Solid Waste & Infrastructure (SW&I) is to provide an
exemplary, high quality and cost-effective solid waste management
service in support of the Department of Energy (DOE) missions at the
Savannah River Site (SRS) and across the Complex.

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Overview of the Solid Waste Management Facility

The critical success factors, which are essential for the SWI to achieve
its mission, are:

-   Technical competence to manage wastes safely using existing and
    emerging technology.

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Generator Certification Official (GCO) Training

-   Transparent cost effectiveness achieved through waste minimization
    and life cycle optimization of waste management strategies in the
    DOE Complex.

-   Development of a versatile and confident work force that respond
    enthusiastically to management-led change.

-   Building public confidence in the long-term safety of waste
    management plans and practices.

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-   Open relationship with regulators.

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Public Meeting held in North Augusta, SC

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SRS Citizens Advisory Board

Visits the WIPP in Carlsbad, NM

While these success factors support the SW&I mission, they are also key
to meeting the goals for the DOE including:

-   Driving down the unit cost of waste disposal operations at the SRS
    to a level that challenges the rest of the Complex and outside
    industry.

-   Establishing paths for the treatment, storage, and disposal of all
    SRS waste streams.

-   Cooperating across the Complex in optimizing the treatment, storage
    and disposal of DOE wastes.

The mission and goals set the focus for SW&I. In order to achieve them,
SW&I have a planning process that provides the tools necessary to focus
on the objectives and conduct the necessary activities to realize these
goals. The System Plan provides the tools necessary to focus on the
right path to safely disposition the Site's waste.

#  Introduction to the Planning Process

SW&I has developed a management planning process that integrates SW&I's
planning needs from strategic planning down to detailed plans, options
analysis, and source documents (e.g., reports and studies) necessary to
conduct its operations in a cost-efficient and effective manner. This
process supports every aspect of SW&I's business from the day-to-day
operational requirements to high-level budget proposals submitted for
congressional funding.

A key document providing cohesion throughout the planning process for
SW&I is the System Plan. This document considers all aspects of waste
handling including treatment, storage, and disposal. These include
low-level waste (LLW), mixed waste (MW), hazardous waste (HW),
transuranic (TRU) waste, and sanitary waste.

The System Plan has two primary functions. The first is to conduct a
detailed options analysis and life cycle cost evaluation for the
disposition of each of the waste streams identified and to make a
preferred option recommendation to disposition the waste. Disposition is
defined as the actions required to store, treat to applicable
requirements, and dispose within appropriate regulatory facilities. The
second is to provide the primary planning and outyear scope for the SW&I
Baseline, which supports DOE's Integrated Planning, Accountability, and
Budgeting System (IPABS). The DOE's Environmental Management Life Cycle
Baseline is developed from IPABS.

The Baseline consists of three main components, which are scope,
schedule, and cost. These components provide the mechanism to meet the
objectives for managing waste at the SRS through the achievement of a
steady-state condition for each waste stream and eventual end-state.

System Plan Description

The System Plan outlines the current plan to meet the DOE's
Environmental Management Life Cycle Baseline objective of "accelerated
environmental cleanup" by achieving steady state of different waste
streams and eventual end-state of the SRS. The purpose of the System
Plan is to determine the preferred operational scope utilizing a proven
system engineering approach. This is accomplished through options
analysis using a consistent set of evaluation criteria applied to the
options identified in the waste treatability groups for each individual
waste stream. This analysis results in the identification of a preferred
disposition path for each waste stream as shown in Attachment 1.

The wastes are broken down first by waste type (LLW, MW, TRU, HW and
Sanitary), then subdivided in treatability groups with streams having
similar characteristics being incorporated into the same treatability
group. Using a number of different inputs, including historical
documents, current research and development work, and the expertise of
appropriate Site personnel, a listing of disposition options was
generated for each waste stream. A set of discriminating criteria, which
includes life cycle cost estimates, was developed to assess the
viability of each option. The options were assessed against the criteria
and a numerical score applied for each attribute. The final score
reflected the experts' assessment of how well the option satisfied the
requirement posed by the attribute. Options that presented significant
obstacles or that were considered not to be viable were excluded from
the options analysis.

#  Pollution Prevention Program

At SRS, all operations are concerned with increasing Pollution
Prevention (P2) awareness and implementation of process improvement
opportunities. P2 is integral to the SRS Environmental Management
Policy, Environmental Management System (EMS), and Integrated Safety
Management System (ISMS). SRS embraces P2 as a primary strategy to
operate in a compliant, cost-effective manner that protects the
environment and the safety and health of employees and the public. The
P2 Program establishes the environmental management preference of source
reduction and recycling over treatment, storage, and disposal, and the
preferred use of energy-efficient and resource-conservative practices
and operations.

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Size Reducing Scrap

Dumpsters for Salvage and Recycling

The Waste Minimization and Pollution Prevention Program scope includes
both in-field generator programs and site-wide coordination programs.
The generator program is responsible for implementation of
facility-specific improvement initiatives and is funded through each
generator's operating budget. Site-wide program coordination, which is
managed by the SW&I organization, is separately funded and provides the
following:

-   management support of Waste Minimization and Pollution Prevention
    Program

-   technical assistance for facility walk-downs, lifecycle waste cost
    analyses, and pollution prevention opportunity assessments

-   support for the SRS ALARA Center to promote radiological control and
    waste reduction technologies

-   forums for waste minimization and P2 information and technology
    exchanges to support implementation of facility/activity-specific
    improvement initiatives

-   increased employee P2 awareness and training programs

-   contaminated metal and large equipment recycling and disposition

-   mechanisms to increase waste generator accountability with respect
    to P2 through the Solid Waste Management Committee

-   completion of required annual plans and P2 program reports

-   implementations of site-wide initiatives such as sanitary waste
    recycle, Green-Is-Clean (GIC) programs, and other cost-cutting
    initiatives

-   establishing P2 components in the Site's Communication Plan to
    increase public awareness and support

In FY2004, DOE-SR approved 51 documented P2 projects, resulting in an
annualized avoidance of 7,093 m^3^ of waste. DOE-SR also validated that
33 of these P2 project completions met the P2 Program goal
implementation criteria, resulting in 6,466 m^3^ of waste avoidance
toward the P2 Program goal. WSRC exceeded its FY2004 performance goal of
5,279 m^3^ by 22.5%.

#  Waste Descriptions

## Low-Level Waste Groups

Low-level waste is radioactive waste that is not classified as
high-level waste, TRU waste, spent fuel or by-product material as
defined in DOE Order 435.1, *Radioactive Waste Management*, and does not
contain RCRA-regulated hazardous waste. It consists of radioactively
contaminated materials such as miscellaneous job control waste, small
and large equipment, plastic sheeting, gloves, soil, and suspect
contaminated materials that were used within a radioactive material
management area and cannot be proven to be free of radioactive
contamination.

SRS operations classify LLW as intermediate-level waste and low-activity
waste. Intermediate-level waste consists of waste material that radiates
greater than 200 millirem per hour from an unshielded-engineered metal
container at 5 centimeters. Low-activity waste consists of waste
material that radiates less than 200 millirem per hour from an
unshielded-engineered metal container at 5 centimeters. The primary
isotopes of concern are tritium, iodine-129, cesium-137, technetium-99,
plutonium-238, and plutonium-239.

### Low-Level Waste Integrated Operations

SRS has thirteen LLW streams in a wide range of physical forms. Five
streams have been inactive since FY2003. To effectively manage the LLW
streams, SRS maintains operations in six temporary storage areas,
disposes LLW in onsite trenches and vaults, and transports LLW to
offsite DOE and commercial facilities for disposal.

Most onsite waste projects generate LLW. LLW is also received from
offsite generators, primarily from the Naval Reactors Program. The
forecast for newly generated LLW includes about 21,000 m^3^ in FY2005,
11,000 m^3^ in FY2006, and 9,000 m^3^ in FY2007. There remains some
ambiguity with respect to outyear forecasts due to uncertainty in the
actual volume to be generated during accelerated closure activities, and
amounts of waste to be generated by the Plutonium Missions and Site
Decommissioning and Demolition Projects.

At SRS, LLW generators are responsible for segregating, characterizing,
and packaging their waste, and shipping it to the receiving facility
once the waste has been certified according to the waste acceptance
criteria. Generators also are responsible for providing justification
when requesting deviations from waste acceptance criteria requirements
and then requesting approval for the use of non-standard containers.

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Black Box Disposal as

Low-Level Waste in the Slit Trench

SW&I is responsible for receiving waste from generators, verifying that
the waste complies with the waste acceptance criteria, disposing of the
waste in the appropriate facility or shipping the waste offsite for
treatment, disposal or both, and maintaining up-to-date waste data in
the Waste Information Tracking System (WITS). Solid Waste Facilities
comply with safety and environmental requirements through use of a
system of procedures and standard operating practices.

For the most part, legacy LLW stored previously onsite was processed
through the Waste Sort Facility (WSF), Supercompactor Facility (SCF),
and/or was disposed of directly in appropriate disposal facilities.

Newly generated LLW is disposed directly in the Slit, Engineered and
Component-In-Grout Trenches, or shipped offsite to commercial and other
DOE facilities for disposal. This practice extends the use of the Low
Activity Waste Vaults (LAWV) through FY2025.

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Disposal of the

Paducah Cask in E-Area

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Low Activity Waste Vault

In FY2004, additional Undetermined Disposal Question Evaluations (UDQE)
and Special Analyses (SA) were completed to further remove some of the
conservatism in the performance assessment limits for SW&I disposal
facilities. This resulted in fit-for-purpose disposal facilities,
allowing a significant percentage of waste originally destined for
disposal in the LAWV to be disposed of in other lower cost disposal
units such as the Engineered and Slit Trenches. Continuing these special
evaluations and analyses is expected to further extend the life of the
LAWV.

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Engineered Trench

The LLW Operations also includes shallow land disposal,
components-in-grout, disposal of naval reactor components and
contaminated large equipment, continued disposal of waste in the LAWV,
continued disposal of waste in the Intermediate-Level Vault (ILV), and
waste minimization and pollution prevention.

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Components-In-Grout Trench

LLW streams that exceed onsite disposal limits are shipped to the Nevada
Test Site (NTS) for disposal. Others are shipped to a commercial
facility for disposal. A total of 1,411 m^3^ of LLW has been shipped to
the Nevada Test Site through the end of FY2004. In addition, 539 m^3^ of
depleted uranium oxide waste was shipped to a commercial facility in
FY2004.

In FY2004, over 1,500 m3 of legacy waste was disposed of, reducing the
end of year inventory to about 20 m^3^. This exceeded an end of year
target of 100 m3 remaining in storage. Over 26,000 m^3^ of newly
generated LLW was disposed of, an increase of 60% over the previous
year. In addition, about 690 m^3^ of LLW was mined from the Low Activity
Waste Vault and disposed of in the trenches, freeing up valuable vault
space.

Nearly 360 m^3^ of LLW were shipped offsite to a commercial disposal
facility in FY2004. Offsite shipments of LLW are expected to continue
during FY2005 and later years.

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Intermediate Level Storage Vaults

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Disposing SRS Depleted

Uranyl Nitrate DUN at the Nevada Test Site

LLW Treatability Groups

The LLW is divided into 13 treatability groups with five treatability
groups inactive because legacy and forecast volumes have been combined
with other groups. The remaining eight treatability groups can be found
in Attachment 1. Should other groups become inactive, they will be
identified and labeled appropriately. The treatment technologies within
each group follow approved methods, and/or those proposed by the
following plans:

-   Savannah River Site Solid Waste Volume Reduction Strategic Plan (U),
    WSRC-RP-97-19, Rev. 0, January 1997.

-   Stored Low-Level Waste Disposition Plan (U), Rev.1 SWD-SWE-99-0046,
    April 1999.

-   Contaminated Large Equipment Disposition Plan (U), WSRC-RP-96-0410,
    Rev. 0, August 1996.

-   WSRC 1-01, Management Policies, MP 5-30 Disposition of Contaminated
    Large Equipment, Rev 0, 9/30/96.

Each treatability group includes a description of the preferred
treatment, disposal option, and the currently available options. Future
complex-wide decisions may require revisions to the LLW sections of the
System Plan.

## Mixed Waste Groups

Mixed waste (MW) is defined as waste that contains both radioactive
waste subject to the Atomic Energy Act (AEA) of 1954, and also contains
hazardous constituents, as defined in 40 CFR 261 and the South Carolina
Hazardous Waste Management Regulations (SCHWMR). Radioactive waste can
be classified as low-level, high-level, or transuranic. This section
only address mixed low-level waste.

MW streams are generated at SRS by various activities and operations,
environmental cleanup, decommissioning and demolition (D&D), and
construction activities. MW includes job control waste such as
solvent-contaminated wipes, cleanup and construction debris, lead,
laboratory samples, and soils from spill remediation. Mixed wastes are
managed in accordance with DOE Orders, Resource Conservation and
Recovery Act (RCRA), and SCHWMR. Treatment options identified must meet
Land Disposal Restrictions (LDR).

### Mixed Waste Integrated Operations

The MW Program involves four primary operations: receipt of waste from
generators, interim storage, treatment, and disposal. Waste minimization
and pollution prevention are equally important and are conducted mainly
at the generating facility.

Waste receipt and interim storage activities include receipt of newly
generated waste, placement of waste in storage, and subsequent
surveillance and maintenance of stored waste.

SW&I personnel certify waste prior to receipt to ensure that waste is
stored correctly and is categorized in the proper treatability group so
that it can be treated to meet LDR. Surveillance and maintenance
activities at the MW storage facilities require an ongoing effort to
inspect containers to ensure that container integrity is maintained.
This includes verifying secondary containment features, maintaining
facility grounds and equipment, and conducting remedial operations to
prevent releases from degraded containers. The forecast for newly
generated MW includes about 120 m^3^ in FY2005, 190 m^3^ in FY2006, and
30 m^3^ in FY2007.

Waste pre-treatment and treatment activities are necessary to ensure
that the waste will meet RCRA requirements for disposal. Examples of
these activities include characterization and preparation for treatment,
repackaging, and actual treatment of waste.

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Treated Mixed Waste Shipped to Offsite Disposal

The Consolidated Incineration Facility (CIF) is in "standby." The
decision not to operate the CIF was due to an FY2000 decision to fund
higher priority programs and DNFSB Recommendation 94-1 regarding Nuclear
Materials Stabilization Programs in FY2001. Since the System Plan
assumes that CIF will not restart, all streams originally designated for
treatment at the CIF have been redirected to alternative options. This
includes the organic PUREX waste stream, which has a preferred treatment
option of stabilization.

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Mixed Waste Shipped to Offsite Treatment

Options for treating MW are available through offsite commercial
facilities. Untreated MW is shipped routinely offsite for treatment.
Treated MW is also shipped offsite for disposal. In FY2004, 570 m^3^ of
waste was shipped offsite for treatment. This activity will continue
during FY2005 and the out-years. Also in FY2004, SRS exceeded its Mixed
Waste legacy inventory reduction goal of 527 m^3^ by 55% to 235 m^3^.
The availability of offsite treatment and disposal facilities and
emergent technologies is assessed on an ongoing basis to support
planning and scheduling for the ultimate treatment and/or disposal of
MW.

The main waste minimization and pollution prevention measures for MW are
to avoid unnecessary generation, reduce the volume and toxicity of waste
through substitution of non-hazardous materials in place of hazardous
materials at the source, and decontaminate and recycle radiologically
contaminated lead. An early example of SRS's implementation of waste
minimization and pollution prevention involved job-control waste
contaminated with various regulated solvents. This waste was declared
MW, according to the Mixture Rule under RCRA. In an effort to eliminate
or substantially reduce the generation of this type of waste, SRS
modified procedures and practices regarding the generation and
management of solvent-contaminated wipes by replacing regulated solvents
used across the Site with non-hazardous materials.

Mixed Waste Treatability Groups

For the purpose of the System Plan, MW is divided into treatability
groups (Attachment 1). These treatability groups are based on the types
of waste in storage at SRS. MW is typically grouped with waste with
similar characteristics or treatments. The treatment technologies within
each group follow the Savannah River Site Treatment Plan (STP),
WSRC-TR-94-0608, Rev. 11. The treatment technologies identified in the
STP are based on Environmental Protection Agency (EPA) regulations.
Treatment methods inappropriate under RCRA are not evaluated.

At present, there are 19 treatability groups within the MW program. Of
these groups, five are inactive due to either that the waste was already
disposed of, the waste was merged into another group, or the treatment
facility is no longer available. As other groups become inactive, they
will be identified and labeled appropriately. The current active MW
groups are presented in Attachment 1.

Transuranic Waste Groups

Transuranic waste is defined in DOE Order 435.1 as waste contaminated
with alpha-emitting TRU radionuclides (radionuclides with atomic numbers
greater than 92) with half-lives greater than 20 years, in
concentrations greater than 100 nanocuries per gram (nCi/g) of waste
matrix. The TRU waste at the Savannah River Site that also contains
hazardous constituents, as defined in 40 CFR 261 and the SCHWMR
R.61-79.261, is managed in accordance with both DOE Orders and SCHWMR
and is referred to as TRU-mixed waste.

TRU waste generated at SRS is primarily job-control waste, which
includes combinations of the following: plastic, paper, rubber,
glassware, metal items, lead-lined gloves, filters, used equipment, and
other contaminated materials from routine processing.

Because of the various contents of waste containers, TRU waste is
generally described by its container: drums, poly boxes, concrete casks,
large steel black boxes, and other odd-sized container. The container
also dictates the storage configuration for the waste packages, as drums
are stored in culverts or on covered pads, and other containers may be
stored on open pads exposed to the weather.

TRU and TRU-mixed waste streams are, and have been, generated primarily
by Plutonium Separations Facilities and the Analytical Laboratories.
Other past generators of significantly smaller volumes include Naval
Fuels Facility, the Reactor Facilities, the Fuel Fabrication Facility,
the High-Level Waste Tank Farms, and the Solid Waste Management
Facility.

In the late 1970s, SRS received TRU waste from offsite generators,
including Los Alamos National Laboratory and the DOE Mound Site. At
present, only the Mound Site ships TRU waste to SRS. In FY2000, the
Mound Site identified about 300 m^3^ of TRU waste (primarily Pu-238)
that required expedited disposition. The Mound Site is scheduled for
closure in 2006. The DOE and the South Carolina Department of Health and
Environmental Control (SCDHEC) have an agreement to allow the transfer
of this waste to SRS. Mound also obtained a Department of Transportation
(DOT) exemption for shipment of fissile and non-fissile transuranic
waste in two refurbished ATMX/OHOX railcars. Under this agreement, SRS
was not allowed to receive waste from Mound until SRS shipped twice the
volume of waste to the Waste Isolation Pilot Plant (WIPP) expected from
Mound. SRS has received nine ATMX/OHOX railcars from Mound, completing
the receipt of legacy waste. In FY2005, newly generated (soil and
debris) waste is expected from Mound to closeout the Mound Site Project.

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TRU Waste Storage Facility

Under existing disposal requirements, the Mound waste streams cannot go
directly to the WIPP without adhering to the same assay, sorting,
segregating, and repackaging requirements as similar waste from SRS.
Consolidating this activity at SRS reduces the costs and will allow the
Mound Site to close on schedule. The schedule for shipping SRS TRU waste
to WIPP was accelerated to facilitate timely closure of the Mound Site
and to meet the agreement with the SCDHEC.

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Loading TRUPACT-II

Containers for Shipment to the WIPP

### TRU Integrated Operations

The TRU waste operations that are required to ship waste packages to the
WIPP include waste characterization, certification, packaging, and
shipment. The WIPP began accepting TRU waste in 1999. Since the first
TRU shipment to the WIPP on May 8, 2001, multiple shipments have been
made, totaling 294 drums in FY2001, 672 drums in FY2002, 5,814 drums in
FY2003, and 7,170 drums in FY2004. The cumulative number of TRU waste
drums shipped is 13,950. This number represents about half of the
original legacy TRU-drum inventory at SRS. This milestone was achieved
significantly earlier than the original baseline schedule. Also in
FY2004, 4,768 TRU drums were safely retrieved from culvert overpacks for
characterization. The forecast for newly generated TRU waste includes
about 166 m^3^ in FY2005, 124 m^3^ in FY2006, and 21 m^3^ in FY2007.

The TRU Waste Program involves safe management of twenty-two TRU waste
storage pads located in E-Area. Waste packages are received from
generators in accordance with the Westinghouse Savannah River Company
(WSRC) Waste Acceptance Criteria (WAC). Waste is segregated and stored
on pads based on its packaging type, total curie inventory, and
hazardous waste category. Drums and other containers with higher
activity are placed in concrete culverts to comply with safety
requirements of the facility. Containers with high radiation rates are
placed in controlled radiation areas for personnel protection in
accordance with Manual 5Q, Radiological Controls.

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TRU Visual Examination Facility on TRU Pad 6

Certification for TRU waste disposal at WIPP requires characterization
of the waste matrix for all containers, using radionuclide assay,
radiographic techniques (i.e., x-ray), and sampling of the headspace
gas. Additionally, a representative number of containers must be opened
for visual examination to confirm the characterization results. The TRU
Waste Visual Examination Facility has been developed to perform this
function, including waste sorting, segregating, and repackaging on a
limited population of drums to facilitate waste shipments to the WIPP.
Unrestricted hot operations of the facility commenced September 2000.

In an effort to accelerate risk reduction, a modular approach for the
TRU facilities to process the high-activity Pu-238/Pu-239 waste and bulk
containers is being developed. As opposed to the original concept of a
large Hazard Category II facility, the accelerated approach will include
the use of existing facilities at SRS for infrastructure and major
containment structure. The initiative also includes fit-for-purpose
modular design concepts for certain activities (e.g., storage of
containers waiting processing). This, combined with enhancements to the
TRUPACT-II SARP and the use of a new TRUPACT-III transporter, will allow
SRS to accelerate the end-state in excess of fifteen years.

The accelerated program for high-activity TRU is directed at about 5,400
m^3^ of Pu-238/Pu-239 waste, including large bulk equipment stored in
black steel boxes, casks and other containers. The accelerated plan will
ship about 80% of this TRU waste inventory to WIPP in the new
TRUPACT-III transporter with the remaining 20% undergoing repackaging
and shipment in an enhanced TRUPACT-II transporter with higher payload
capability. The new TRUPACT-III, having the capability to accommodate 5
feet by 5 feet by 8 feet waste boxes, could be in operation as early as
FY2007. Moreover, the TRUPACT-III transporter has the potential to
significantly reduce the amount of processing necessary to prepare bulk
waste for shipment.

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TRU Waste Shipment to WIPP

### 

### TRU Waste Groupings

TRU waste is divided into waste groupings based primarily on the
containers that are used to store the waste. The amount of detailed
information on the contents of each legacy waste container is limited.
However, information such as container type, generator, and radionuclide
data is adequate to facilitate waste groupings and planning for
processing to meet the requirements of the WIPP WAC.

One TRU treatability group (SRS-TRU-1) is now inactive due to procedural
changes and the implementation of LLW certification programs at SRS. The
active groups are presented in Attachment 1.

Hazardous Waste

Hazardous wastes are those wastes that are specifically identified by
the EPA as HW (i.e., listed wastes contained in 40 CFR 261, Subpart D)
or wastes that meet one of four HW characteristics identifies in 40 CFR
261, Subpart C. The four HW characteristics are ignitability,
corrosivity, reactivity, or toxicity. Also considered HW is
Polychlorinated Bi-phenyl (PCB) waste regulated under 40 CFR 761.
Hazardous waste has been generated at SRS as a result of past operations
and continues to be generated as a result of current operations. Typical
HW includes materials such as lead, solvents, paints, pesticides, and
hydrocarbons.

## Hazardous Waste Integrated Operations

The HW Program involves three primary operations: receipt of waste from
onsite generators, interim storage, and shipment of waste for offsite
treatment and disposal. Waste minimization and pollution prevention
(Section 4.0) are equally important operations, which are conducted
mainly at the generating facility.

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Hazardous Waste Storage Building

Waste receipt and interim storage activities include receipt of newly
generated waste, placement of the waste in storage, and subsequent
surveillance and maintenance of the stored waste. Similar to MW
operations, surveillance and maintenance activities at the HW facilities
require an ongoing effort to inspect containers to ensure that container
integrity is maintained. This also includes verifying secondary
containment features, maintaining facility grounds and equipment, and
conducting remedial actions to prevent releases from degraded
containers.

Hazardous waste is routinely shipped offsite to commercial facilities
for treatment and disposal. During FY2004, 285 m^3^ of newly generated
Hazardous and PCB waste was shipped offsite for treatment. Of this
waste, about 170 m^3^ was shipped from the Hazardous Waste Storage
Facility, thus reducing the legacy waste inventory to 58.4 m^3^ and
exceeding the SRS goal (60 m^3^) by 2%. This waste was released in
accordance with the WSRC Program as identified in Radiological Release
of Material, 5Q1.1. The forecast for newly generated HW includes about
210 m^3^ in FY2005, 255 m^3^ in FY2006, and 35 m^3^ in FY2007.

The main waste minimization and pollution prevention measures for HW are
to avoid unnecessary waste generation and reduce the volume and toxicity
of the waste through substituting non-hazardous materials in place of
hazardous materials at the source. In an effort to eliminate or
substantially reduce the generation of this type of waste, SRS modified
procedures and practices regarding the use of hazardous materials across
the Site, substituting non-regulated materials as much as practical.

The methods used to treat HW are governed by RCRA regulations. Offsite
treatment of HW is an ongoing and established process with multiple
commercial vendors and facilities available. Contracts are generally
easy to place through the normal procurement cycle. Because of these
factors, it is not necessary to complete detailed options analyses for
the treatment of HW.

## Sanitary Waste

Sanitary or municipal solid waste is solid waste that is neither
radioactive nor hazardous as defined by the AEA or RCRA. Sanitary waste
consists of materials that would be received by a municipal sanitary
landfill. This includes salvageable and recyclable materials such as
scrap metal.

The DOE-SR and the Lower Savannah Council of Governments have committed
to the development and use of the Three Rivers Landfill, which disposes
waste from SRS and eight South Carolina counties. The Three Rivers
Landfill is a 1,400 acre site, located off Highway 125 adjacent to SRS.
This is the South Carolina's first publicly owned, regulated landfill.
Three Rivers is expected to provide safe and efficient disposal capacity
for over 200,000 tons of sanitary waste a year for the next 50 years.
The SRS sends about 500 tons of waste a month to this landfill.

In November 2003, SRS began operation of an onsite construction and
demolition (C&D) landfill. This facility takes inert debris, avoiding
disposal and transportation fees for this waste to the Three Rivers
Landfill. The new C&D landfill received about 31,000 tons of waste from
November 2003 to October 2004. This waste was shipped in over 2,600
"truck loads" and was moved primarily by Site Transportation. Based on
Three Rivers Regional Landfill's current tipping fee of nearly \$50 per
ton for this type of material, fee savings total about \$1.5 million for
FY2004 and is expected to continue at near this rate during the
accelerated cleanup period.

![](media/image47.jpeg){width="2.986111111111111in"
height="2.2395833333333335in"}

First Material Dump at the

New C&D Landfill

Waste minimization and pollution prevention activities conducted onsite
include recycling of scrap metals. Over 3,000 tons of scrap metal was
recycled in FY2004. Other industrial debris was recycled through Site
Salvage Operations and Construction Recycle Services. Chemical products
are reused or recycled through the Chemical Commodity Management Center.

![](media/image49.jpeg){width="2.9895833333333335in"
height="1.9534722222222223in"}

Three Rivers Regional Landfill

In addition, SRS ships office sanitary waste to the North Augusta
Material Recovery Facility (MRF) to remove white office paper,
newspaper, magazines, cardboard, plastics, steel cans, aluminum cans,
and glass. The MRF removes about 40% of this waste stream for recycle
and reuse.

SRS has initiated a program to produce fuel cubes from sanitary waste to
fuel the A-Area boiler. Continuing this effort in FY2005, the Site will
work with the Three Rivers Landfill to improve waste feed consistency,
and by that enhance fuel cube operations. This program will save SRS
about \$250,000 a year in fuel savings and avoided landfill and recycle
costs.

#### Attachment 1 Preferred Options for LLW, MLLW, and TRUW Streams {#attachment-1-preferred-options-for-llw-mllw-and-truw-streams .unnumbered}

The following table is a summary of the preferred options for each of
the [active]{.underline} treatability groups for LLW, MLLW and TRUW.
These options are the result of an engineering assessment incorporating
a detailed options analysis and life cycle cost analysis reported in the
System Plan, Volume II, Revision 7, and earlier revisions. The table
also specifies the previous option for treatment, storage, and disposal
of wastes currently managed by the Solid Waste Program. The preferred
and previous options will differ if the options analysis was re-done.
New options analyses are listed in the Waste Stream Description Sections
of Volume II.

  ----------------------------------------------------------------------------------
  **WASTE STREAM  **WASTE STREAM       **CURRENT PREFERRED     **PREVIOUS PREFERRED
  NO.**           NAME**               OPTION**                OPTION**
  --------------- -------------------- ----------------------- ---------------------
  LOW-LEVEL WASTE                                              

  SRS-LLW-1       Bulk Waste           No treatment required.  Same as preferred
                                       Direct disposal in      option.
                                       E-Area Engineered       
                                       Trench (if WAC met),    
                                       remainder to Slit       
                                       Trenches and LAWV.      

  SRS-LLW-5       Liquid Low Level     Treatment by DOE TSCAI  Same as preferred
                  Waste                Facility and disposal   option
                                       at Commercial Facility  
                                       O.                      

  SRS-LLW-7       Contaminated Large   No treatment. Disposal  Same as preferred
                  Equipment (CLE)      in the Slit Trench.     option.
                  Waste                                        

  SRS-LLW-8       Contaminated         No treatment required.  Same as preferred
                  Soils/Debris Waste   Direct disposal in      option.
                                       E-Area Slit Trenches or 
                                       Offsite Facility        
                                       (Nevada Test Site).     

  SRS-LLW-10      Naval Reactor        No treatment required.  Same as preferred
                  Component Waste      Disposal in the Slit    option.
                                       Trench.                 

  SRS-LLW-11      Intermediate-Level   No treatment required.  Same as preferred
                  Waste                Disposal in the         option.
                                       Intermediate Level      
                                       Vault.                  

  SRS-LLW-12      Waste With No        Treatment and disposal  Same as preferred
                  Identified Path to   for this waste to be    option.
                  Disposal             determined.             

  SRS-LLW-13      Process Water Waste  Treatment at ETP and    Same as preferred
                                       disposal to the         option.
                                       National Pollution      
                                       Discharge Elimination   
                                       System (NPDES) outfall  
                                       and the Saltstone       
                                       Facility.               

  MIXED WASTE                                                  

  SRS-MLLW-2      Debris Waste         Treatment by Commercial Same as preferred
                                       Facility D and disposal option.
                                       by Commercial Facility  
                                       D.                      

  SRS-MLLW-3      Lead Waste           Treatment by Commercial Same as preferred
                                       Facility D and disposal option.
                                       by Commercial Facility  
                                       D.                      

  SRS-MLLW-6      Aqueous Liquid for   Effluent Treatment      Same as preferred
                  Onsite Treatment     Facility                option.

  SRS-MLLW-7      Aqueous Liquid for   Treatment by Commercial Same as preferred
                  Offsite Treatment    Facility D and disposal option.
                                       by Commercial Facility  
                                       D.                      

  SRS-MLLW-8      Organic Liquids for  Treatment by Commercial Treatment by
                  Onsite Treatment     Facility B and disposal commercial vendor
                                       at the Nevada Test      (TBD) onsite.
                                       Site.                   Disposal at the
                                                               Nevada Test Site.

  SRS-MLLW-9      Organic              Treatment by Commercial Treatment by
                  Other-Liquids for    Facility S and disposal Commercial Facility D
                  Offsite Treatment    by Commercial Facility  and disposal by
                                       D.                      Commercial Facility
                                                               D.

  SRS-MLLW-10     Contaminated Soils,  Treatment by Commercial Same as preferred
                  Sludges, etc.        Facility S and disposal option.
                                       by Commercial Facility  
                                       D.                      

  SRS-MLLW-12     Elemental Mercury    Amalgamation at         Same as preferred
                                       Commercial Facility D   option.
                                       and disposal at         
                                       Commercial Facility D.  

  SRS-MLLW-13     Mercury Contaminated Amalgamation followed   Same as preferred
                  Waste                by stabilization at     option.
                                       Commercial Facility D   
                                       and disposal at         
                                       Commercial Facility D.  

  SRS-MLLW-14     Incinerable          Treatment at Oak Ridge. Same as preferred
                  Radioactive PCB      Disposal taken care of  option.
                  Waste                by treatment vendor.    

  SRS-MLLW-15     Non-Incinerable      Treatment by Commercial Same as preferred
                  Radioactive PCB      Facility D and disposal option.
                  Waste                by Commercial Facility  
                                       D                       

  SRS-MLLW-16     Already Treated      Disposal at Nevada Test Same as preferred
                  Wastes               Site.                   option.

  SRS-MLLW-17     Tritiated Oil with   TBD treatment (thermal  Same as preferred
                  Mercury              treatment or            option.
                                       incineration). Disposal 
                                       taken care of by        
                                       treatment vendor.       

  SRS-MLLW-18     Waste with No Path   TBD                     Deactivation.
                  for Disposal                                 

  **TRANSURANIC                                                
  WASTE**                                                      

  SRS-TRU-2       Drummed Low Activity No longer generated as  Same as preferred
                  TRU Waste            a waste stream. Legacy  option.
                                       waste only. Drums with  
                                       detectable transuranic  
                                       isotopes managed with   
                                       higher activity waste   
                                       to meet shipping        
                                       requirements. Sort,     
                                       segregate, and          
                                       repackage at SRS in CAT 
                                       III capable facility    
                                       and disposal is at      
                                       WIPP.                   

  SRS-TRU-3       Drummed Waste        Sort, segregate, and    Same as preferred
                  contaminated with    repackage at SRS in CAT option.
                  weapons grade        III capable facility    
                  plutonium            and disposal at WIPP.   

  SRS-TRU-4       Drummed Waste        Sort and segregate at   Same as preferred
                  contaminated with    SRS in CAT III capable  option.
                  heat source          facility; transport     
                  plutonium            using revised           
                                       TRUPACT-II with and     
                                       disposal at WIPP.       

  SRT-TRU-5       Drummed Waste        Processing (e.g.,       Same as preferred
                  contaminated with    repackaging) at SRS in  option.
                  heat source          CAT II capable          
                  plutonium requiring  facility; transport     
                  load management      using enhanced          
                                       TRUPACT-II, and         
                                       disposal at WIPP.       

  SRS-TRU-6       HEPA Filters         Processing (e.g.,       Same as preferred
                  contaminated with    venting and             option.
                  weapons grade        overpacking) in CAT III 
                  plutonium in         capable facility at SRS 
                  polyboxes            and disposal at WIPP.   

  SRS-TRU-7       HEPA Filters         Processing (e.g.,       Same as preferred
                  contaminated with    repackaging) at SRS in  option.
                  heat source          CAT II capable          
                  plutonium in         facility, transport     
                  polyboxes            using enhanced          
                                       TRUPACT-II, and         
                                       disposal at WIPP.       

  SRS-TRU-8       Steel boxes          Sort, segregate, and    Same as preferred
                  containing waste     size reduce in CAT II   option.
                  contaminated with    capable facility;       
                  weapons grade        transported using       
                  plutonium            TRUPACT-III, and        
                                       disposal at WIPP.       

  SRS-TRU-9       Steel boxes          Sort, segregate, and    Same as preferred
                  containing waste     size reduce in CAT II   option.
                  contaminated with    capable facility,       
                  heat source          transport using         
                  plutonium            TRUPACT-III, and        
                                       disposal at WIPP.       

  SRS-TRU-10      Remote Handled Waste Overpack in RH-72-B     Same as preferred
                                       shipping container at   option.
                                       SRS and disposal at     
                                       WIPP.                   
  ----------------------------------------------------------------------------------

Notes:

> **Commercial Facility** **A \--** Provides for the disposal in a
> landfill of a wide range (isotopes, concentrations) of Low-level Solid
> Radioactive Waste.
>
> **Commercial Facility** **B \--** A permitted landfill for the
> disposal of a restricted range (isotopes, concentrations) of Low-level
> Solid Radioactive Waste.
>
> **Commercial Facility** **C \--** A permitted landfill for the
> disposal of a wide range (isotopes, concentrations) of Low-level Solid
> Radioactive Waste.
>
> **Commercial Facility** **D \--** Provides a Subtitle C Landfill for
> the disposal of LDR compliant Mixed Waste.
>
> **Commercial Facility** **E \--** Provides a Subtitle C Landfill for
> the disposal of LDR compliant Mixed Waste and treatment capabilities
> for macroencapsulation and PCB contaminated waste.
>
> **Commercial Facility** **F \--** Provides capabilities to treat
> hazardous waste by incineration and stabilization and to dispose of
> residuals.
>
> **Commercial Facility** **G \--** Provides capabilities to treat
> hazardous waste by incineration and stabilization and to dispose of
> residuals.
>
> **Commercial Facility** **H \--** Provides capabilities to treat
> hazardous waste by incineration and stabilization and to dispose of
> residuals.
>
> **Commercial Facility** **I \--** Provides capabilities to treat
> hazardous waste by incineration and stabilization and to dispose of
> residuals.
>
> **Commercial Facility** **J \--** Provides capabilities to treat
> hazardous waste by incineration and stabilization and to dispose of
> residuals.
>
> **Commercial Facility** **K \--** Provides capabilities to treat
> hazardous waste by incineration and stabilization and to dispose of
> residuals.
>
> **Commercial Facility** **L \--** A NRC licensed, RCRA permitted
> disposal facility that is currently operating and can dispose of a
> range of mixed low-level waste.
>
> **Commercial Facility** **M \--** A RCRA permitted facility for the
> storage of hazardous waste. The facility is not NRC licensed or RCRA
> permitted for the disposal of mixed low-level waste.
>
> **Commercial Facility** **N \--** An NRC licensed disposal facility
> currently operating and it disposes of a wide range of low-level
> waste.
>
> **Commercial Facility** **O \--** A RCRA permitted treatment facility
> currently operating that can treat a wide range of mixed low-level
> waste.
>
> **Commercial Facility** **P \--** A RCRA permitted facility for the
> storage of hazardous waste that has applied for RCRA permits and NRC
> license for treatment of mixed low-level waste.
>
> **Commercial Facility** **Q \--** Provides capabilities to treat
> hazardous waste by incineration and stabilization and to dispose of
> residuals.
>
> **Commercial Facility R \--** Provides capabilities to treat mixed
> waste using thermal treatment and to decontaminate radioactively
> contaminated material.
>
> **Commercial Facility S \--** Provides treatment capabilities for
> stabilization, macroencapsulation, and PCB contaminated waste.
>
> **Commercial Facility T \--** Provides decontamination services for
> radioactively contaminated material.
>
> **Commercial Facility U \--** Provides capabilities to treat mixed
> waste by incineration and stabilization.
>
> **General Comment** - Some facilities above are not currently being
> used by SRS.