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

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

 April 9, 2014 

Summary 

On April 9, 2014, EPA’s Waste Isolation Pilot Plant (WIPP) waste characterization team visited 

Waste Control Specialists (WCS) to determine whether the Department of Energy (DOE) was 

meeting EPA’s waste inventory tracking requirements at 40 CFR 194.24(c)(4). DOE began 

shipping waste to the Andrews, Texas-based WCS in April 2014 due to the temporary closure of 

WIPP in response to the February 2014 fire and subsequent radiological release. Despite this 

temporary closure, DOE is required under a State of New Mexico Governor’s Directive to 

remove 3,706 cubic meters of transuranic (TRU) waste from Los Alamos National Laboratory 

(LANL) by June 30, 2014. During the WCS visit, EPA observed unloading and storage 

operations, interviewed WCS and DOE contractor staff from the Central Characterization Project 

(CCP), and evaluated supporting information as objective evidence for technical adequacy. The 

Agency also evaluated the system of controls in place for TRU waste containers from LANL and 

determined that these controls are technically adequate and comply with requirements at 40 CFR 

194.24 (c)(4). 

Background 

40 CFR 194.24 requires that all DOE TRU waste destined for WIPP disposal be characterized 

using an EPA-approved waste characterization program and be tracked from generation through 

disposal. The DOE’s Waste Data System (WDS) tracks each waste container from generation 

through characterization, storage, certification, shipment and emplacement at WIPP. However, 

emplacement of TRU waste at WIPP was halted in February 2014 as a result of two separate 

incidents: an underground salt truck fire and a radiation release at the WIPP. Because a State of 

New Mexico Governor’s Directive dated October 1, 2011, requires DOE to remove 3,706 cubic 

meters of TRU waste from LANL by June 30, 2014, the stoppage required DOE to immediately 

seek an alternate radioactive waste storage facility for LANL’s remaining 577 cubic meters of 

contact-handled (CH) TRU waste. 
EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

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Selection of WCS for Temporary Storage

The DOE looked at a number of potential options for waste storage during the interruption of 

WIPP activities. It identified alternate temporary storage capacity at the WCS facility in 

Andrews, TX. WCS is a waste management facility authorized by the Texas Commission on 

Environmental Quality (TCEQ) to accept hazardous, radioactive and mixed waste for treatment, 

storage and disposal. WCS routinely accepts low-level mixed waste from various DOE locations, 

including TRU waste generator sites, for treatment and disposal. The facility’s radioactive 

materials license authorizes storage of TRU waste from DOE. 

Before DOE’s WIPP contractor signed the contract to use the WCS facility for temporary TRU 

waste storage, DOE’s Carlsbad Field Office (CBFO) determined that WCS’s security and safety 

operations and controlled waste handling activities were able to provide adequate security and 

safety throughout the storage period. CBFO also determined that the WCS storage area and 

waste loading/unloading operations were well suited and readily available for this purpose. 

Any radioactive mixed waste brought to WCS must meet WCS’s radioactive waste acceptance 

criteria (WAC). CBFO and their support contractor—the CCP, operated by the Nuclear Waste 

Partnership (NWP) in consultation with LANL-CCP—determined that most (perhaps all) of the 

remaining LANL Contact-Handled TRU waste that would be WIPP-certified would meet WCS’s 

WAC. However, before WIPP-certified TRU waste containers leave LANL, TCEQ inspectors 

must verify the containers’ eligibility for WCS acceptance. 

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

On April 8, 2014, prior to visiting WCS, EPA inspectors (Rajani Joglekar and Ed Feltcorn) met 

with CBFO staff (J. R. Stroble and James Rhoades) and CCP staff (Farok Sharif, Ronnie Lee, Ed 

Gulbransen, Mike Sensibaugh and Mike Ramirez). The CCP staff described the flow of LANL 

TRU waste containers from LANL to WCS to WIPP. This ensures that the chain of custody is 

continuously maintained; they require that DOE’s WIPP-certified waste inventory be continually 

tracked – from a generator site to a location in the WIPP repository. To meet this requirement 

during the temporary storage of the LANL contact-handled TRU waste at WCS, CCP developed 

an “interface” procedure (CCP-PO-042, Rev 0, dated 3/25/2014), which describes the system of 

controls to be implemented at WCS. As objective evidence of the interface procedure, CCP staff 

provided EPA with documentation of LANL waste shipments #1, #5 and #7, which began 

arriving at WCS on April 2, 2014. 
EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

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EPA staff also reviewed a table included in the draft CCP-TP-199 procedure, which will be used 

by CCP at WCS to verify WCS ID numbers and container locations. CCP will prepare monthly 

reports using this verification information and provide them to EPA after their approval by 

CBFO. 

EPA’s April 9 WCS Site Visit 

During April 2-9, 2014, WCS received a total of seven shipments consisting of standard waste 

boxes (SWBs) meeting WCS WAC requirements. Over the next few months, LANL-CCP plans 

to send between 80-100 TRUPACT-II or HalfPact shipments consisting of approximately six 

SWBs per shipment. 

During their April 9 visit to WCS, in accordance with 40 CFR 194.24 (c)(4), EPA’s inspectors 

reviewed LANL-CCP’s waste inventory tracking procedure (CC-TP-199). CCP demonstrated the 

steps outlined in their interface document (CCP-PO-042, Rev 0 dated 3/25/2014), which define 

CCP and WCS roles and responsibilities while TRU waste is stored at WCS. EPA also observed 

the unloading of one TRU shipment (3 TRUPAC II) containing six SWBs with LANL-CCP’s 

container identification label as shown in Figure #1. Upon unloading of TRU waste containers, 

WCS affixes its own container identification label, which is shown in Figure #2. Before LANL 

waste can be stored in the enclosed storage area, TCEQ staff must verify the LANL markings on 

waste containers against the pre-shipment information received from LANL-CCP. After TCEQ 

verification, WCS moves the dual-labeled TRU waste containers to the controlled storage area 

and enters relevant information (ID#s and location) into their tracking database. WCS then also 

provides the same information to CCP, which CCP in turn enters into the WDS, designed to 

track waste inventory and the status of every WIPP-certified container. 

Once in the controlled area, WCS segregates WIPP-bound waste containers in a roped off area as 

shown in Figure #3. WCS’s multiple layers of secured, controlled access insures against 

tampering or unauthorized movement of the WIPP-certified containers in WCS’s possession. All 

LANL waste containers will remain in the same location until they are moved for WIPP disposal 

when the repository restarts its emplacement operation. Until the TRU waste containers are 

moved to WIPP, CCP will perform verification checks at WCS using CCP-TP-199, Rev 0, dated 

4/22/2014, to validate that the information given by WCS remains true and applicable. CCP will 

continue to generate monthly reports tabulating the waste inventory as shown in the example in 

Attachment 1. EPA will receive a copy of CCP’s monthly inventory report. 
EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

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Conclusion 

 Based on its discussions with CCP staff and the WCS visit, EPA confirms that an adequate 

system of controls is in place to ensure necessary physical security and a chain of custody while 

LANL TRU waste containers are in temporary storage at WCS. 
EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

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Figure #1: Standard waste box with LANL-CCP’s container identification label shown 
EPA Air DOCKET NO: A-98-49; II-A4-187; April 2014

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

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

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

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

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