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

1 EPA’s Review of DOE’s Inventory Tracking for TRU Wa stes at Waste Control Specialists

April 9, 2014

Summary

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

Background

40 CFR 194.24 requires that all DOE TRU waste desti ned for WIPP disposal be characterized using an EPA-approved waste characterization progra m and be tracked from generation through disposal. The DOE’s Waste Data System (WDS) tracks each waste container from generation through characterization, storage, certification, s hipment and emplacement at WIPP. However, emplacement of TRU waste at WIPP was halted in Febr uary 2014 as a result of two separate incidents: an underground salt truck fire and a rad iation release at the WIPP. Because a State of New Mexico Governor’s Directive dated October 1, 20 11, requires DOE to remove 3,706 cubic meters of TRU waste from LANL by June 30, 2014, the stoppage required DOE to immediately seek an alternate radioactive waste storage facilit y for LANL’s remaining 577 cubic meters of contact-handled (CH) TRU waste.EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

2 Selection of WCS for Temporary Storage

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

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

Any radioactive mixed waste brought to WCS must mee t WCS’s radioactive waste acceptance criteria (WAC). CBFO and their support contractor—t he CCP, operated by the Nuclear Waste Partnership (NWP) in consultation with LANL-CCP—det ermined that most (perhaps all) of the remaining LANL Contact-Handled TRU waste that would be WIPP-certified would meet WCS’s WAC. However, before WIPP-certified TRU waste cont ainers leave LANL, TCEQ inspectors must verify the containers’ eligibility for WCS acc eptance.

EPA’s Off-Site Evaluation of LANL-CCP’s Waste Track ing System Used at WCS

On April 8, 2014, prior to visiting WCS, EPA inspec tors (Rajani Joglekar and Ed Feltcorn) met with CBFO staff (J. R. Stroble and James Rhoades) a nd CCP staff (Farok Sharif, Ronnie Lee, Ed Gulbransen, Mike Sensibaugh and Mike Ramirez). The CCP staff described the flow of LANL
TRU waste containers from LANL to WCS to WIPP. This ensures that the chain of custody is continuously maintained; they require that DOE’s WI PP-certified waste inventory be continually tracked – from a generator site to a location in th e WIPP repository. To meet this requirement during the temporary storage of the LANL contact-ha ndled TRU waste at WCS, CCP developed an “interface” procedure (CCP-PO-042, Rev 0, dated 3/25/2014), which describes the system of controls to be implemented at WCS. As objective evi dence of the interface procedure, CCP staff provided EPA with documentation of LANL waste shipm ents #1, #5 and #7, which began arriving at WCS on April 2, 2014.EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

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

EPA’s April 9 WCS Site Visit

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

During their April 9 visit to WCS, in accordance wi th 40 CFR 194.24 (c)(4), EPA’s inspectors reviewed LANL-CCP’s waste inventory tracking proced ure (CC-TP-199). CCP demonstrated the steps outlined in their interface document (CCP-PO- 042, Rev 0 dated 3/25/2014), which define CCP and WCS roles and responsibilities while TRU wa ste is stored at WCS. EPA also observed the unloading of one TRU shipment (3 TRUPAC II) con taining six SWBs with LANL-CCP’s container identification label as shown in Figure # 1. Upon unloading of TRU waste containers, WCS affixes its own container identification label, which is shown in Figure #2. Before LANL waste can be stored in the enclosed storage area, T CEQ staff must verify the LANL markings on waste containers against the pre-shipment informati on received from LANL-CCP. After TCEQ verification, WCS moves the dual-labeled TRU waste containers to the controlled storage area and enters relevant information (ID#s and location) into their tracking database. WCS then also provides the same information to CCP, which CCP in turn enters into the WDS, designed to track waste inventory and the status of every WIPP- certified container.

Once in the controlled area, WCS segregates WIPP-bo und waste containers in a roped off area as shown in Figure #3. WCS’s multiple layers of secure d, controlled access insures against tampering or unauthorized movement of the WIPP-cert ified containers in WCS’s possession. All
LANL waste containers will remain in the same locat ion until they are moved for WIPP disposal when the repository restarts its emplacement operat ion. Until the TRU waste containers are moved to WIPP, CCP will perform verification checks at WCS using CCP-TP-199, Rev 0, dated 4/22/2014, to validate that the information given b y WCS remains true and applicable. CCP will continue to generate monthly reports tabulating the waste inventory as shown in the example in Attachment 1. EPA will receive a copy of CCP’s mont hly inventory report.EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

4 Conclusion

Based on its discussions with CCP staff and the WC S visit, EPA confirms that an adequate system of controls is in place to ensure necessary physical security and a chain of custody while LANL TRU waste containers are in temporary storage at WCS.EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

5 Figure #1: Standard waste box with LANL-CCP’s conta iner identification label shownEPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

6 Figure #2: WCS affixed container identification lab elEPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

7 Figure #3: WIPP-bound waste containers in a roped o ut and segregated area at WCSEPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

8 Attachment 1 – Sample Inventory ReportEPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

9EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

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