DEFENSE NUCLEAR FACILITIES SAFETY BOARD
January 25, l994
MEMORANDUM FOR:G. W. Cunningham, Technical Director
FROM:          Steven Stokes, Senior Systems Engineer
SUBJECT:       Report on Solid Waste Operations at the Hanford Site, June 17,
               1993 and November 3, 1993
1.Purpose:  This report documents DNFSB technical staff trips to the Hanford Site
to review the solid waste program.  An overview approach was taken to familiarize
the staff with the Tank Farms Solid Waste operations and with operations at the
Central Waste Complex (CWC), a storage and staging area managed by Westinghouse
Hanford Company (WHC), and Solid Waste Operations (SWO).  The focus of the review
was to:  (1) understand how waste is managed from the point of generation to
disposal, (2) understand organizational and management responsibilities for solid
waste issues, (3) understand the standards used to manage the solid waste
program, and (4) evaluate the potential for safety issues.
2.Summary: The solid waste program at the Hanford Site is operated by two types
of organizations:  (1) solid waste management at the point of generation, i.e.,
Tank Farms solid waste management, Plutonium Finishing Plant solid waste
management, etc., and (2) Solid Waste Operations, a WHC organization that
receives, handles, stores, and disposes of solid waste at the Hanford Site.
Overall responsibility for solid waste issues has been given to a single
Department of Energy (DOE) Richland Operations Office (DOE-RL) organization.
Operational responsibility is, however, divided along program lines; this has led
to uneven emphasis being placed on solid waste management issues from program to
program.  Several issues, most notably the backlog waste issue (Occurrence Report
Number RL--WHC-SOLIDWASTE-1993-0013) have resulted from this organizational
division of responsibility and poor upper management attention.  The level of
DOE-RL management attention is changing, primarily due to Washington Department
of Ecology oversight and the increased emphasis placed upon DOE environmental
programs overall.  Additionally, radioactive wastes have been placed in burial
grounds at the Hanford Site for nearly 50 years.  There is very little
information regarding the exact nature of wastes placed in the ground in the
early years.  Any attempt to recover these wastes will be inherently dangerous,
both from a worker dose and public health and safety perspective.
3.Background:  Management of solid wastes, including transuranic wastes (TRU),
low level wastes, and mixed wastes (both mixed TRU and low level wastes), is
conducted at the Hanford Site.  The Hanford Site is also one of the few remaining
DOE sites that will accept wastes generated at other locations (i.e., Battelle
Columbus, Naval Reactors submarine hulls, etc.).  Solid waste at the Hanford Site
has recently been the subject of considerable controversy due to the violation
of Resource Conservation and Recovery Act (RCRA) requirements at the Tank Farms
(backlog waste issue).  Though this issue, the expeditious characterization and
shipment of mixed radioactive and hazardous waste, is based upon RCRA
requirements to characterize and ship wastes within 90 days of generation and is
not a safety issue per se, the potential for safety issues does exist if solid
wastes are not managed properly.
4.Discussion/Observations:
  a. DOE-RL Solid Waste Management:  Centrally, DOE-RL management of solid
     waste is performed by the Solid Waste and Transportation Branch, Waste
     Management Division.  This organization is responsible for key elements
     of the overall solid waste management program, including establishing and
     implementing waste management policy at the Hanford Site, oversight of
     the CWC and burial grounds, construction of facilities for the treatment
     of solid waste (i.e., Waste Receiving and Processing Facilities--modules
     1 and 2), and oversight of the generators of solid waste.
     DOE-RL oversight of each solid waste generator (e.g., Tank Farms) is
     delegated to the associated DOE program managers (for this example, the
     Tank Waste Remediation System Program Manager).
     The fracturing of responsibility along programmatic lines has led to
     uneven emphasis and expertise being placed on solid waste management
     issues from program to program.  This has resulted in a variety of
     programmatic and management issues, most notably the backlog waste issue.
     It was also evident from discussions with Waste Management Division
     personnel that historically, little emphasis has been placed upon solid
     waste issues by the individual program managers.  This is evident, for
     example, in the activities associated with disposal of TRU wastes in
     near-surface disposal trenches.  However, the level of DOE-RL Management
     attention is changing, apparently due to Washington Department of Ecology
     oversight and the increased emphasis placed upon DOE environmental
     programs overall.
  b. WHC Solid Waste Management:   SWO's primary function is to manage of on-
     site disposal and storage facilities (permanent disposal and long-term
     storage in excess of 90-days).  Additionally, SWO acts as a site-wide
     policy setting and internal oversight group that issues and enforces
     implementing standards used by the solid waste generators.
     (1).  Solid Waste Operations:
        Walkthroughs of the Central Waste Complex, burial grounds, and
        Transuranic Waste Storage and Assay Facility (TRUSAF) were conducted.
        Operations were generally well organized and effectively manned with
        emphasis being placed upon RCRA storage and handling requirements.
        However, operators were generally not familiar with applicable safety
        requirements.  It was apparent that training is strongly focused on
        regulatory requirements.  This does provide a measure of safety
        compliance to the extent that RCRA embodies certain safety tenets, but
        RCRA alone cannot account for the fact that these are nuclear
        facilities (albeit very low hazard in most cases).  Reconciliation of
        RCRA requirements with ALARA concerns related to radiation dose (e.g.,
        frequent inspection of waste containers) has occurred.
        Review of storage records, by DNSFB Technical Staff, for randomly
        picked waste packages at storage facilities resulted in 100%
        reconciliation between field conditions and records.  These records
        also include data on waste packages dating back to initial site
        operations.  Although these records are not as complete as present day
        records, they do provide insight into the variety of wastes buries at
        the Hanford Site.  Waste packages weighing on the order of thousands
        of tons have been in the burial grounds since the 1940's.  Very little
        knowledge of their exact nature, and any attempted recovery of these
        waste packages will be inherently dangerous, both from a worker dose
        and public health and safety perspective.
     2. Tank Farms Solid Waste:
        (a)   Solid waste operations at the Tank Farms were reviewed to
              determine if wastes generated at the Tank Farms were certified
              for shipment to SWO.  The Hanford Waste Acceptance Criteria
              (WAC) require that all waste streams be certified by SWO prior
              to receipt at SWO facilities.  Receipt by SWO is necessary for
              proper disposal of all wastes at the Hanford Site.
           Until recently, Tank Farms had not been able to ship mixed
           radioactive wastes to SWO due to revocation of their status as a
           certified generator.  The inability to ship waste resulted in a
           backlog of waste retained in the tank farms in violation of RCRA
           requirements.  This was the subject of the backlog waste program.
           Tank Farms has since corrected waste operations deficiencies and
           is a certified waste generator.  They currently have five waste
           streams certified for shipment to the CWC.  These are: (1) Low
           Level Radioactive Waste, (2) Low Level Waste - Debris (radioactive
           mixed waste), (3) contaminated soil, (4) other chemical products
           (primarily hazardous wastes), and (5) maintenance wastes (hazardous
           wastes only).
           Given the past performance of Tank Farms, significant internal
           oversight efforts by SWO have been performed to ensure that Tank
           Farms properly characterizes wastes prior to shipment.  Weekly
           audits by SWO have been used to both educate Tank Farms solid waste
           personnel and closely follow their progress at implementing the
           waste acceptance criteria.
           Current efforts by Tank Farms solid waste management to trend data
           associated with failure to properly implement the WAC have not yet
           proven useful since data collection has only been conducted for one
           quarter.  Tank Farms Solid waste management did recognize the value
           of collecting this data, but they did not have a firm understanding
           of how they intended to incorporate results of data analysis into
           training or other efforts designed to correct deficiencies.
           Current efforts are underway to train and certify Tank Farms solid
           waste operations personnel.  The training matrix for these
           individuals was briefly reviewed.  The training courses do appear
           to represent an appropriate level of training given the job
           requirements.  However, problems have already been noted in
           application of training (i.e., operators are not consistently able
           to complete solid waste paperwork properly).  Therefore, the
           present level of training may not be adequate to meet quality
           requirements.
        (b)   Tank Farm Solid Waste Staging:
           Tank Farms solid waste staging areas, selected at random, were
           visited to view the general cleanliness and appropriateness of
           waste storage.  Each site was well maintained, free of debris,
           clearly and appropriately marked, and free of obvious safety
           hazards (e.g., open drums, leaking drums, etc.).  Waste drum
           inventory information was spot checked to see if actual inventories
           in the field matched records.  In all cases, official records
           matched field conditions.  The condition of waste staging areas
           observed is not considered to be representative of actual operating
           conditions since a Tank Farms administrative hold has essentially
           eliminated all solid waste generation at this time.
  c. Solid Waste Standards at the Hanford Site:  DOE-RL and WHC rely upon
     guidance provided in DOE Order 5820.2A, Radioactive Waste Management as
     the overall standard for solid waste management activities.  Since this
     DOE Order provides little, if any, specific guidance, the primary
     standards used at the site are:
       Hanford Waste Acceptance Criteria,
       WHC controlled manuals, and
       Line organization operating procedures.
     Additionally, these documents incorporate RCRA requirements as they apply
     to solid waste management at the Hanford Site.
     A DNFSB technical staff review of these standards revealed that they do
     encompass the body of knowledge required to effectively manage solid
     waste activities.  However, since they represent a tiered hierarchy of
     documents (i.e., the Hanford WAC provides very general requirements
     applicable to all waste generators, including offsite generators, while
     operating procedures provide specific instructions) consistency of
     quality and application is an issue.  There does not appear to be any
     effort to review standards down to the program level.  Rather, control
     and oversight are focused on waste shipment to SWO.  This results in
     detection of problems only after they have developed.  Note that due to
     the backlog waste issue, this condition appears to be improving at Tank
     Farms.
5.Future Staff Actions:  Recommended staff actions are based upon the level of
  risk associated with present solid waste operations and are restricted to
  observation of upcoming TRU waste retrieval activities (summer 1994).