Long-Lived Legacy: Managing High-Level

and Transuranic Waste at the DOE Nuclear

Weapons Complex

May 1991

OTA-BP-O-83

NTIS order #PB91-186205
Recommended Citation:

U.S. Congress, Office of Technology Assessment, Lmg-Lived L.egacy: Managing High-L.ael

and Transuranic Waste at the DOE Nuclear Weapons Complex, OTA-BP-O-83 (Washington,

DC: U.S. Government Printing Office, May 1991).

For sale by the Superintendent of Documents

U.S. Government Printing Office, Washington, DC 20402-9325

(order form can be found in the back of this background paper)
Foreword

This background paper is a technical annex to the main OTA report Complex Cleanup:

The Environmental Legacy of Nuclear Weapons Production. It describes, documents, and

analyzes available data about two key waste management problems at the Department of

Energy Weapons Complex—those of high-level radioactive waste and transuranic waste. The

paper is organized in two chapters—”Chapter 1: Managing High Level Waste’ and ‘Chapter

2: Managing Transuranic Waste. ” Each chapter contains a summary overview followed by

a discussion and analysis of important areas in the waste management problem that the DOE

faces at present and in its future operations.

DOE has made significant investments in waste management throughout the Weapons

Complex in the past, and those investments are likely to grow in the future. The 1990

Five-Year Plan calls for almost $20 billion in waste management expenditures (about

two-thirds of the total in the plan) over the next 5 years. Major new facilities are nearing

completion and plans for additional facilities have been put forward. The challenge for DOE

is to develop more effective practices for managing both current and future waste in order to

avoid repeating the serious problems of the past.

In this assessment, OTA has focused on high-level and transuranic waste because these

forms often pose the most risk, they are essentially unique to DOE, and the bulk of DOE’s

waste management resources will be devoted to them. Large quantities of other wastes are also

generated throughout the Weapons Complex (i.e., low-level radioactive waste and hazardous

waste), and a comprehensive approach to all waste management must be followed by DOE.

This background paper, therefore, reviews only some of the critical areas and aspects of the

DOE waste problem in order to provide data and further analysis of important issues covered

in the main OTA report.

As noted above, this paper is part of a broader assessment of environmental restoration

and waste management at the DOE Nuclear Weapons Complex and was used to provide

background material for input to the larger assessment. Information for the study was obtained

from DOE and DOE contractor personnel, the Environmental Protection Agency, the National

Academy of Sciences, citizens groups, academics, other independent organizations, and a

variety of media. Visits to obtain information and observe practices firsthand were made to

the Savannah River Site, the Hanford Reservation, West Valley, NY, the Waste Isolation Pilot

Plant, Los Alamos National Laboratory, Sandia National Laboratory, the Environmental

Evaluation Group, and the Idaho National Engineering Laboratory. We are grateful to all who

provided information and to the reviewers who raised many valuable questions about earlier

drafts.

Detailed analysis and in-depth information about the entire DOE waste management

program is available largely from DOE itself. The subject is extensive and complex with along

history, some of which is undocumented in the public literature. The data that are available

are often in a form that is difficult to access, assemble, summarize, and interpret. While it may

be useful for some agency to investigate this subject more thoroughly, OTA concluded that

the analysis contained herein would be most useful for congressional policymakers at this

time.

~f~

a’4&’ ‘ >

JOHN H. GIBBONS

~ Director
Advisory Panel—Managing High-Level and Transuranic Waste

at the DOE Nuclear Weapons Complex

Roger H. Davidson, Chairman

Professor, University of Maryland

Jackie L. Braitman

Vice President and Manager

Environmental Management and Information

Systems Division

Roy F. Weston, Inc.

William A. Brewer

Consulting Geologist and Engineer

Norman Cohen

Professor & Director

Laboratory for Radiological Studies

New York University Medical Center

Gary A. Davis

Senior Fellow

Waste Management Institute

University of Tennessee

Patrick D. Eagan, P.E.

Program Director

Department of Engineering Professional

Development

University of Wisconsin

George M. Hornberger

Professor, Department of Environmental Sciences

University of Virginia

Joseph Hughart

Senior Assistant Sanitaria

U.S. Public Health Service

George R. Jasny

Retired Vice President

Martin Marietta Energy Systems, Inc.

Bernd Kahn

Director, Environmental Resources Center

Georgia Institute of Technology

Ellen J. Mangione

Director, Disease Control and Environmental

Epidemiology

Colorado Department of Health

Robert H. Neill

Director

Environmental Evaluation Group

State of New Mexico

Glenn Paulson

Research Professor, Pritzker

Department of Environmental Engineering

Illinois Institute of Technology

Dan W. Reicher

Senior Attorney

Natural Resources Defense Council

Jacqueline W. Sales

President

Hazardous and Medical Waste Services, Inc.

R. Lewis Shaw

Deputy Commissioner

South Carolina Department of Health and

Environmental Control

Office of Environmental Quality Control

NOTE: OTA appreciates and is grateful for the valuable assistance and thoughtful critiques provided by the advisory panel members. The panel does

not, however, necessarily approve, disapprove, or endorse this background paper. OTA assumes full responsibility for the background paper

and the accuracy of its contents.
OTA Project Staff-Managing High-Level and Transuranic Waste

at the DOE Nuclear Weapons Complex

John Andelin, Assistant Director, OTA

Science, Information, and Natural Resources Division

Robert W. Niblock, Oceans and Environment Program Manager

Peter A. Johnson, Project Director

Emilia L. Govan, Senior Analyst

Joan Ham, Senior Analyst

Judy Kowalski, Analyst

Robert P. Morgan, Visiting Senior Analystl

Tara O’Toole, Senior Analyst

German Reyes, Analyst

Laura L. Taylor, Intern

My K. Ton, Intern

Administrative Staff

Kathleen Beil

Sally Van Aller

Contributors

Florence Poillon, Editor

Ion sabbatical at (_jW from Washington University, St. ~~s, MO.
Reviewers—Managing High-Level and Transuranic Waste

at the DOE Nuclear Weapons Complex

The following persons assisted OTA in reviewing one or more drafts of this background paper for

accuracy, completeness, emphasis, and presentation. Their comments and suggestions were used to modify and

correct earlier drafts. This help was extremely valuable and contributed substantially to the quality of the final

report.

Carl Bannerman U.S. General Accounting Office

Allen G. Croff Oak Ridge National Laboratory

Bernd Kahn Georgia Institute of Technology

Arjun Makhijani Institute for Energy and Environmental Research

Robert H. Neill New Mexico Environmental Evaluation Group

Alfred Schneider Georgia Institute of Technology

David W. Turner Oak Ridge National Laboratory

NOTE: These reviewers do not necessarily approve, disapprove, or endorse this Background Paper. OTA assumes full responsibility for its accuracy

and content.

vi
Chapter 1

High-Level Waste Management at

the DOE Weapons Complex

Contents

Page

OVERVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

The Transition to More Stable Waste Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Monitoring the Waste Forms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Form of HLWat the Idaho National Engineering Laboratory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

HLW Repository . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Standards for HLW Disposal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Timeframe for Immobilization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Airborne Releases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Future of the PUREX Plant at Hanford.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Learning From International Experience . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ,.+..... ?... 6

INTRODUCTION AND DEFINITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

HIGH-LEVEL WASTE AT DEPARTMENT OF ENERGY SITES .. .. .. .. .. .. .. ... ... ...,..+ 8

High-Level Waste Management: Present and Planned . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Amount and Distribution . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Current and Potential Problems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

TECHNOLOGIES FOR IMPROVED MANAGEMENT OF HIGH-LEVEL WASTE ... ..++... 26

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...+ 26

Vitrification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Calcination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... 30

Alternative Waste Forms for the Idaho National Engineering Laboratory . . . . . . . . . . ...+..... 31

Technologies for pretreatment of High-Level Waste ,.,... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

Waste Minimization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
REGULATORY FRAMEWORK . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . ,..., 36

Definition of High-Level Waste . . . . . . . . . . . . . . . . . . . . . . . . . .. .., ,. .. .. .+, . . . . . . . . . . . .+.,.. 37

Regulations Affecting Single-Shell Tanks . . . . . . . . . ,,, ..,..+.,..,....,,++.,..+.,.,. ,.+.., 39

Regulations Affecting Restart of PUREX . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

Regulations Affecting Vitrification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..,..+.. . . . . . . . . . . . . 39

DISCUSSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

Definition of High-Level Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

Repository Delays and Contingency Planning . . . . . . . . . . . . . . . . . . . . . . ++.... . . . . . . . . . . . . . . . 42

Urgency of High-Level Tank Waste Treatment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

Technologies for High-Level Waste Treatment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ,...,+. 44

Rethinking the Waste Form and Package . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

Waste Form for the Idaho National Engineering Laboratory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

Releases to the Atmosphere . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .+ +,, .,, .,. .,.+++4 . . . . 45

Future of the PUREX Plant at Hanford, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

Waste Minimization; Tritium Production; International Cooperation . . . . . . . . . . . . . . . . . . . . . . . 46

Scenarios for Future HLW Production . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

CHAPTER PREFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. .. .. .. .. .., .., ,.. ....+.., 47

. . . . . . . .

Box

Box Page

l-A. Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ++.... 7

Figures

Figure Page

l-1. Schematic of High-Level Waste Generation, Treatment, and Disposal, . . . . . . . . . . . . . . . . . . . 8

l-2. High-Level Waste at DOE Facilities.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

l-3. Total Volume of High-Level Waste Through 1988 . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . 11

l-4. Total Radioactivity of High-Level Waste Through 1988 . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . 11

l-5. Total Volume, Radioactivity, and Thermal Power of High-Level Waste Stored in

Tanks, Bins, and Capsules at Savannah River, Idaho, and Hanford . . . . . . . . . . . . . . . . . . . . . . 12

l-6. Total Radioactivity of High-Level Waste in Storage by Site Through 2020. . . . . . . . . . . . . . . 14

l-7. Chemical Processing of PUREX Liquid Effluents .....,... . . .. . . . . . . . ., .,+. +....... . . . 21

l-8. Storage Capacity for DWPF Glass Canisters.. . ............+.. . . . . . . . . .....,.++ . . . . . . . 29

l-9. Alternative Long-Term High-Level Waste Management Strategies for the ICPP .,. .+..,.. 32

1-10. Treatment Methods for High-Level Waste in Tanks and Canisters at Savannah River . . . . . . 33

l-11. Economics of Pretreating Hanford waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... ...+. 38

l-12. Regulations for Management and Disposal of Nuclear and Hazardous Waste

(Hanford Single-Shell Tanks) .. .. .. .. .. .. .. .. .. .. ... ... .....4. . . . . . . . . . . . . . . . . . . . . . . 40

Tables

Table Page

l-1. Chronology of Major Events in the History of Single-Shell Tanks at Hanford . . . . . . . . . . . . . 17

l-2. Legislation and Regulations Applicable to Hanford Single-Shell Tanks .. .. .. ... ... +...... 41
Chapter 1

High-Level Waste Management at the DOE Weapons Complex

OVERVIEW

The first high-level defense waste was created as

a byproduct of the production of plutonium in a

natural uranium-graphite reactor at Hanford and the

subsequent remote ‘‘reprocessing’ of irradiated

uranium fuel elements to recover plutonium. The

byproduct was a highly radioactive, acidic, aqueous

solution containing a variety of fission products with

a wide range of half-lives, as well as residual

uranium and some residual radionuclides with larger

atomic numbers than uranium-the transuranics. It

was recognized that this liquid high-level waste

(HLW) required careful handling, as well as isolation from people and the environment for many

years. HLW is generally distinguished from other

radioactive waste types by its intense radioactivity

coupled with the longevity of its hazard. Huge,

underground, single-shell carbon steel tanks, eventually 149 in number, were built to store neutralized

liquid HLW at Hanford. An early practice of

discharging some of the liquid from the HLW tanks

into ‘‘cribs” and then into the soil was subsequently

discontinued. When some tanks began to leak, new

tanks of double-shell design were added.

Today, most liquid HLW has been neutralized,

forming mixtures of liquid, sludge, and salt cake,

and is currently stored on-site in steel tanks, some of

which have leaked and represent a potential threat to

groundwater. Storage of waste in less expensive

carbon steel, rather than stainless steel, tanks after

neutralization of acidic HLW requires complicated

waste handling and treatment. There is also concern

about the possibility of fire or explosion in the waste

tanks, accompanied by the release of radioactivity.

Four Department of Energy (DOE) sites have

HLW: the Hanford Plant, the Savannah River Site,

the Idaho National Engineering Laboratory (INEL),

and West Valley, NY; the last, a nonweapons site,

reprocessed some fuel commercially from 1966 to

1972. The prime contractors for the management of

HLW at all four sites are subsidiaries of Westinghouse. Two sites have more than 90 percent of the

HLW by both volume and radioactivity-Savannah

River and Hanford—and are planning to begin

operations to immobilize HLW in 1992 and 1999,1

respectively, although slippage of these schedules

would not be unusual. The Savannah River vitrification facility was built at a cost of about one billion

dollars. The Hanford facility is not yet constructed

but plans call for it to be very similar to Savannah

River. The West Valley site is also scheduled to

begin vitrifying waste in 1996; the cost of all West

Valley operations, including decontamination and

modification of existing facilities to accommodate

vitrification as well as new construction needed for

the vitrification plant, will be on the order of one

billion dollars. Canisters of vitrified waste (“glass

logs”) are to be stored on-site, pending disposal in

a deep geologic repository that is not expected to

begin operation until the second decade of the 21st

century. In contrast to the other three sites, for 25

years INEL has been converting liquid HLW from

the reprocessing of highly enriched uranium-235

spent fuel, from naval and other reactors, to a

powdery solid calcine and storing it in stainless steel

bins; DOE has not made a final decision about the

waste form for immobilization and disposal of INEL

HLW.

At West Valley, DOE is reducing the volume of

high-level tank waste to be vitrified by separating a

portion of the waste that DOE believes qualifies as

low-level waste, mixing it with cement, and temporarily storing it in drums above ground, pending a

disposal decision through the Environmental Impact

Statement (EIS) process. An analogous separation is

planned for Savannah River and Hanford because it

will greatly reduce the amount of waste to be

vitrified and should substantially reduce disposal

costs if the portion immobilized in grout or concrete

can be disposed of on-site at or near the surface. At

West Valley, DOE sought and obtained Nuclear

Regulatory Commission (NRC) approval to perform

such a separation; NRC has oversight authority

under the West Valley Demonstration Act of 1980.

However, there appears to be no such NRC authority

at the weapons sites. Concerns have been raised by

interested members of the public about the safety of

such waste separation; the grouted waste at West

Valley is reported to be “Class C low-level waste”

containing technetium-99, a long-lived (210,000-

year half-life) beta emitter. In South Carolina,

l~n Febm~ 19$)1, a z-yew dehy in operation of the Hanford Vitrification Pk@ was announced by DoE.

–3–
4 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

nevertheless, DOE is moving ahead, indicating that

it has all necessary permits from the State to begin

“saltstone" operations at Savannah River; by July

1990, those operations were underway but not using

waste from the main high-level tank farm.

Uncertainty exists about the composition of HLW

at DOE weapons sites. The uncertainty arises

because of the variety of processes that have been

used, the past mixing of wastes, and the heterogeneity of tank components after neutralization. Sampling is very difficult because of tank design, the

high radioactivity levels, and concern about the

possibility of tank explosions. Knowledge of waste

composition is important in designing waste treatments and it is needed for proper glass-waste

formulation for the vitrification process.

Historically, DOE has regulated HLW at weapons

sites under the Atomic Energy Act.2 However, EPA

has become a major factor in regulating waste

management at the weapons sites through its jurisdiction over hazardous waste and application of the

Resource Conservation and Recovery Act (RCRA)

and the Comprehensive Environmental Response,

Compensation and Liability Act (CERCLA) to these

sites. State agencies have also become involved

under RCRA and through mechanisms such as

interagency agreements under CERCLA.

The basic thrust of the HLW management program of DOE is to move from the present less secure,

less stable, less controlled condition to a more stable

one by immobilizing the tank waste. HLW vitrification, if successful, should reduce the threat of

groundwater contamination and tank explosions

posed by liquid HLW stored in tanks. An objective

of vitrification is to produce a waste form that will

immobilize waste safely for hundreds or thousands

of years; however, the process chosen, involving

borosilicate glass, has yet to operate on a large scale

in the United States,3 and long-term performance of

the vitrified waste form in various settings is

difficult to predict and hard to verify. If vitrification

works as planned, the glass logs produced represent

a potentially stable form for long-term storage

on-site or in a monitored retrievable facility if the

deep geologic repository should be delayed. DOE

and most experts working within the DOE program

believe that, at present, vitrification using borosilicate glass is the best available technology for

geologic disposal. However, some concerns have

been raised about whether DOE will be able to

demonstrate that borosilicate glass will perform as

required in the Yucca Mountain repository environment.

The Transition to More Stable Waste Form

A significant transition is beginning to take place

from the less secure and more threatening storage of

HLW in tanks to the more promising secure storage

of immobilized HLW in solid, glasslike form.

Bringing about this transition is a major and costly

undertaking, and a successful outcome is far from

being achieved. However, if it can be accomplished

with minimal occupational risk to workers, it should

greatly reduce if not remove the current, everpresent threat and concern regarding tank leaks and

explosions. The nominal design lifetime of vitrified

waste using borosilicate glass is such that even if a

geologic repository were delayed significantly, the

glass logs could be stored safely on-site at Savannah

River and Hanford for hundreds of years, as long as

the necessary institutional controls remain in place.

Calcine, even without immobilization in glass or

ceramic, also appears able to be safely stored for

hundreds of years at INEL.

The legacy of past practices in which HLW was

discharged into cribs or stored in 149 single-shell

tanks at Hanford must still be dealt with; DOE has

not yet decided how to accomplish the necessary

decontamination and safe disposal.

Monitoring the Waste Forms

Because of the importance and the cost of

vitrification to improve the safety and stability of

HLW storage and disposal, it is essential to carefully

monitor and regulate the integrity and hazard

potential of the waste forms, including both vitrified

and concrete products. Continuing studies and

monitoring are required to resolve opposing claims

that may arise concerning safety and health risks

during storage, along with a continued strong

research program on waste stability,4 container

integrity, and radionuclide transfer through the

environment.

~2 U.S.C. $$2011-2296 (1982 and Supp. IV 1986).

3nere is, however, comide~ble experience with commercial HLW vitritlcation in Europe, especiaUy France, Using a prOCWS SOmewhat s~af to

that built at or plamed for these DOE facilities.

4Factors conce~g waste stability over the long term that need investigation include leaching, embrittlement, and co~sion.
Chapter 1--High-Level Waste Management at the DOE Weapons Complex . 5

Form of HLW at the Idaho National

Engineering Laboratory

At INEL, DOE followed a very different waste

management approach and decided to produce a dry,

calcined waste form for the storage of HLW. This

decision provided considerable experience with an

alternative to the approach used at Hanford and

Savannah River. The calcined waste form has

proved suitable for interim storage. For ultimate

disposal, work is focusing on glass ceramic as a

promising medium for immobilization of the calcine

in order to reduce disposal costs relative to the use

of borosilicate glass. Cost, although important, is but

one factor to be considered. Environmental integrity

in response to evolving, possibly tightened environmental standards for radioactivity is another.

Calcining appears to be a proven, relatively

low-cost means of solidifying liquid waste and a

viable medium-term (about 500 years) alternative to

vitrification. More research on the calcined waste

form and on bin hardening of calcine for disposal

could supply data for use if some future treatment,

storage, and/or disposal alternatives were considered.

HLW Repository

The U.S. approach to HLW disposal is to license

and use a geologic repository to contain potentially

harmful radionuclides for the tens or hundreds of

thousands of years that may be necessary. The

Swedish approach places more reliance on engineered barriers, including a thick container wall to

provide the necessary isolation; other European

countries are also focusing on engineered barriers.

By contrast, in the United States, current policy

places reliance on the geologic repository itself.

The U.S. high-level defense waste glass logs are

to be formed in thin-walled canisters that meet NRC

repository criteria; the canisters will then be put in

containers before repository emplacement. One

issue is whether to place more reliance on engineered barriers for isolating the waste, for example,

by increasing either canister thickness or container

thickness and backfill, or by some combination of

these modifications for the geologic repository

setting. Factors to consider include cost, interaction

between barriers and the chosen repository environment, and the fact that both defense HLW and

commercial spent fuel are now required to use the

same container design.

Standards for HLW Disposal

Standards for disposal of HLW have been remanded by the courts but are expected to be reissued

for comment by the Environmental Protection Agency

(EPA). 5 These standards have important implications for defense HLW. The long-term trend has

been to issue progressively more stringent standards

for nuclear waste disposal as new information

becomes available about health risks from radiation

exposure. This trend may continue but the process is

very slow and thus has affected planning for ultimate

safe disposal.

Timeframe for Immobilization

Decisions about the urgency and rapidity with

which liquid high-level tank waste should be immobilized are difficult to make because of the lack of

good information on the contents of some tanks or

on the movement of radioactive and hazardous

materials that have leaked from tanks. In the absence

of such information, and given continuing concern

about the possibility of waste tank explosions, it may

be prudent to move forward with vitrification

projects as quickly as feasible and to make sure that

technical, environmental, and policy questions or

concerns are addressed promptly and effectively as

well. Trade-offs between moving ahead with dispatch and moving ahead too precipitously require

careful consideration. Among the current concerns

is the possibility of explosion when disturbing or

heating tanks or tank contents. Also, occupational

radiation doses should be carefully controlled and

monitored.

Airborne Releases

Airborne release of both radioactive and hazardous materials is a significant potential health threat

from DOE weapons sites. The movement of contaminants in the air is direct and rapid compared with

movement via groundwater. Reactors, reprocessing

plants, and HLW treatment operations all involve

some routine air emissions; in addition, there is the

possibility of accidental release. Although air releases have been greatly reduced from the early days

of the weapons program, attention to air emissions

5Envfio~en~ Wdiation Protwtion Standards for Management and Disposal of Spent Nuclear Fuel, High-Level and Transmtic Radioactive

Wastes, 40 C.F.R. $191 (1989).
6 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

is continually important, both in setting standards

and in monitoring waste management activity.

Future of the PUREX Plant at Hanford

The Plutonium and Uranium Extraction (PUREX)

fuel reprocessing plant has been of concern because

of its age, the large amounts of hazardous and

radioactive wastes it produces, past atmospheric

releases, and continued release of liquid effluents to

the soil. In early 1990 DOE had plans to restart

PUREX to reprocess backlogs of spent defense fuel

over a 5-year period and then to close the facility

permanently. A principal reason for this was concern

about the 2,100 metric tons of metallic spent fuel

from the Hanford N reactor awaiting reprocessing

and currently being held in water basins at K plant,

near the Columbia River. DOE needs to prevent any

radionuclide release from failed fuel elements since

these basins have leaked in the past.

In October 1990, DOE announced that it would

not restart PUREX for at least 2 years, but would

prepare an Environmental Impact Statement (EIS) to

evaluate a variety of treatment and disposal methods

for stored N reactor fuel.6 Some have interpreted this

announcement as indicating that PUREX will never

again operate.7 The EIS process requires full consideration with public input of the impact of alternatives to restart, including the consequences of

continued storage of fuel elements in the K basins.

Learning From International Experience

Since the U.S. decision in the 1970s not to

encourage reprocessing of commercial nuclear fuels,

other nations have moved ahead in acquiring expertise in reprocessing that could prove useful to DOE’s

fledgling efforts at waste minimization. Learning

from these international sources could be part of a

necessary upgrading of DOE waste minimization

activity, particularly in planning for any new reprocessing capability in connection with modernization

of the Weapons Complex.

INTRODUCTION AND

DEFINITIONS

High-level radioactive waste is a consequence of

the materials and methods used by the United States

to produce plutonium and tritium for nuclear weapons. Neither substance occurs in nature, and both are

produced by neutron capture in nuclear reactors. For

these reactors to operate, neutron chain reactions

must occur, which require that fission takes place in

one or more heavy isotopes of uranium. Fission

produces numerous elements—strontium-90 and

iodine-13 1 are two examples-that are radioactive.

Each time a fission event occurs, two (or occasionally three) radioactive fission products are formed.

In the United States, the high-level waste (HLW)

found in defense facilities differs from its spent fuel

counterpart found in the commercial sector. Commercially, fission products, uranium and transuranic

isotopes, are contained in irradiated fuel elements

removed from reactors—so-called spent fuel—that

(with the exception of a plant operating intermittently in West Valley, NY from 1966 to 1972) have

not been subjected to reprocessing. In reprocessing,

fuel elements are chopped up and dissolved; plutonium and, in some cases, uranium are separated from

the fission products for reuse in a reactor. Spent fuel

in the U.S. commercial sector is stored at reactor

sites pending development of a deep geologic

repository for its disposal. In this report, spent fuel

is not considered to be a form of, or to fall within the

definition of, defense HLW. However, spent fuel is

present at some Department of Energy (DOE)

weapons sites.8

High-level waste is defined by a DOE order as

“the highly radioactive waste material that results

from the reprocessing of spent nuclear fuel, including liquid waste produced directly in reprocessing

and any solid waste derived from the liquid, that

contains a combination of transuranic waste and

fission products in concentrations requiring permanent isolation’ (63). Box 1-A compares this and

other definitions of high-level waste.

Defense HLW arising from reprocessing of fuel

elements or irradiated targets (see figure l-l) leaves

6N.K. Geranios, “Plutonium Processing Plant Won’t Reope~ Energy Secretary Says,” Associated Press News Release, Oct. 17, 1990.

Tc. Holden (cd.), ‘‘Bailing Out of the Bomb Business, ’ Science, NOV. 9, 1990, p. 753.

8APP. c of the DOE ~teWated Da~ Base ~DB) for 1989 lists spent fuel elements at the ~E weapo~ Sites for which no reprOCessillg kpkIIIId.

Included are some irradiated, damaged fuel elements. The IDB does not list spent fuel scheduled to be reprocessed that is present at the weapons sites.

See U.S. Department of Energy, “Integrated Data Base for 1989: Spent Fuel and Radioactive Waste Inventories, Projections and Characteristics,”

DOE/RW-0006, November 1989.
Chapter 1--High-Level Waste Management at the DOE Weapons Complex ● 7

the reprocessing plant as highly radioactive liquid

that usually contains more than 99 percent of the

nonvolatile fission products from the fuel elements

or targets during their time in the reactor. It also

contains roughly 0.5 percent of plutonium and 0.5

percent of the uranium that was present in the spent

fuel, if both these elements are recovered in the

reprocessing operation (3). The radioactive liquid is

stored in tanks, pending conversion to a glassy solid

by a process known as vitrification. The major

exception to this waste form conversion is at the

Idaho National Engineering Laboratory (INEL)

where some HLW liquids have been subject to

calcination, producing a powdery solid that is not

generally considered to be in final form for disposal.

The only way to turn off the HLW source term

(the ultimate in HLW waste minimization) is to stop

producing plutonium and tritium, to produce them

by methods completely different from those currently used, or to utilize a substitute for plutonium

whose production does not require a nuclear reactor.

For example, uranium-235, which occurs in nature

could, in principle, replace plutonium if the need for

new fissionable material arose. Plutonium might be

recovered from existing materials in the civilian

reactor program, but that would violate a longstanding policy of separation of military and civilian

nuclear activities. Tritium,9 although not essential

for weapons, makes them smaller and enhances their

explosive yield; it could conceivably be made in a

linear accelerator rather than a reactor.

The feasibility of alternatives to current nuclear

weapons materials and production methods is not

explored here. However, the intense radioactivity of

HLW is a direct consequence of present production

methods, and HLW minimization is difficult at

current facilities. As of late 1990, no high-level

defense waste was being generated anywhere in the

DOE complex, although reprocessing facilities at

Savannah River and Idaho were scheduled to resume

operations and small amounts of research reactor

fuel were being reprocessed at Savannah River.10 In

January 1990, DOE agreed to perform a programmatic Environmental Impact Statement (EIS) of its

plans for modernizing weapons facilities and that

process began in late 1990 (25).

Unlike civilian HLW which is “locked up” in

solid fuel elements, defense HLW is currently stored

in tanks, either as liquid or a form resulting from

waste neutralization and liquid evaporation, including sludge, salt cake, and slurry. Some of these tanks

were built in 1943; some have already leaked. The

composition of waste in some tanks is not well

known, and concerns have been raised about possi-

$“llitium can be produced in reactors without reprocessing the driver fuel elements; hence no HLW would be produced, as the term is defined in this

paper. However, highly radioactive spent fuel is produced that must eventually be disposed of.

1% &to~r 1989, Energy Secrew James D. Watkins amounced that the PUREX reprocessing plant at Hanford would be placed on s~db for

at least 2 years (see N.K. Geranios, op. cit., footnote 6). Reprocessing of small amounts of research reactor fuel from Taiwan and U.S. commercial test

reactor fuel was being carried out at Savannah River (personal communication to P. Johnsou OTA, Oct. 26, 1990).
8 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

Figure l-l—Schematic of High-Level Waste Generation, Treatment, and Disposal

Weapons

Fabrication

Fuel, Target

Fabrication Tritium Uranium Recycle

-

- Plutonium

- Tritium Calcination

- Uranium (Idaho)

Nuclear Spent Fuel Fuel, Target Liquid HighReactor b

Processing /

Reprocessing * Level Waste

Irradiated

Targets Plants

(Interim Storage)

-E: --

-

----- :

; Vitrification ; ~ (Savannah,West ~

I Valley, Hanford) ,

Legend s :

Current operations —~

Future operations - - ~

L--- _____J

I

I

----I

I

I

r ----t ---- I

~ Immobilization ~

: Process I

, (To Be Determined) ~

L--------—l

I

I

J---- 9-7

~ Disposal \

I In I

{ Repository ~

L————— —--J

— SOURCE: Office of Technology Assessment, 1991.

ble tank explosions. Both the double-shell and

single-shell tanks at Hanford, Savannah River,

Idaho, and West Valley pose a continuing technical

and economic challenge for the environmental

cleanup and waste management agenda.

HIGH-LEVEL WASTE AT

DEPARTMENT OF ENERGY SITES

High-Level Waste Management: Present

and Planned

Figure 1-2 illustrates the present generation and

management of HLW at DOE facilities. When all

facilities are operating, wastes are generated by

reprocessing and stored as liquids in tanks at three

sites: Hanford, Idaho, and Savannah River, DOE

through its Idaho Operations Office has also assumed principal responsibility for managing the

high-level commercial waste generated at West

Valley, NY. Currently, at all four locations, the

principal DOE contractor for managing the HLW is

associated with Westinghouse. Technical support to

DOE headquarters for the HLW management program is supplied by the BDM Corp.

The essence of DOE’s strategy for managing

HLW, described in the 1989 Five-Year Plan (52), is

to move from the current situation in which most

HLW is in tanks as liquid, sludge, or salt cake to a

situation in which the waste is immobilized, put in

stainless steel canisters, and eventually shipped to a

deep geologic repository for disposal. According to

DOE, “Vitrification and calcining are two demonstrated methods for treating HLW for storage and/or

disposal” (52).

In its 1989 Five-Year Plan, DOE characterized

vitrification as follows: vitrification produces a

glasslike form with “long-term stability.” Extensive research undertaken in fiscal year (FY) 1983,

which included consideration of about 15 different

waste forms, resulted in DOE selection of borosilicate glass as a suitable final HLW form. After

vitrification, waste is poured into stainless steel

canisters that are sealed and stored until a geologic

repository becomes available. Three facilities are

planned to use this vitrification process: 1) the

Defense Waste Processing Facility (DWPF) at

Savannah River, 2) the West Valley Demonstration

Project (WVDP), and 3) the Hanford Waste Vitrifi-
Chapter 1--High-Level Waste Management at the DOE Weapons Complex ● 9

Figure 1-2—High-Wvel Waste at DOE Facilities

HANFOR D r

---------- -

-1

~ Hanford Waste ~ Fuel From High-Level Double-Shell Tank Waste-

* Vitrification Project;

Plutonium Plutonium and Waste Liquid Tank Storage

L ---------- -d

Production - Uranium Extraction 28 Double-Shell Tanks r

---------- -

1

Reactors Facility (PUREX) 149 Single-Shell Tanks ----- - < To Be Determined ~

Single-Shell Tank Waste I I

------------ -

.—————— ——————— ——————— ——————————————————

Fuel From

Naval

Reactors

————

/ IDAH O /

/ /

Chemical High-Level @

Waste Liquid Tank Storage Solid

Processing 11 Stainless Steel Tanks Calcine

Plant L

1 I

I I I I

————————————————.—————————

----------,

I Immobilized ~

*L Calcine I

-------- -

OR

~ ---------,

~ Bin ~

I Hardening ,

----------

———————

SAVANNA H RIVE R

High-Level

Fuel, Targets From

r ---------- -7

Chemical Separation waste b

Liquid Tank Storage : Defense Waste :

Savannah River Facilities ~, Processing I

Production Reactor 51 Tanks (4 different designs) j Facility (Vitrification) ~

------------ -

.—————— ——————— ——————— ——————————————————

/ WEST VALLEY /

SOURCE: Office of Technology Assessment, based on U.S. Department of Energy data, 1990.

cation Project (HWVP). The DWPF and West

Valley facilities represent priority 1 of the 1989

Five-Year Plan, that is, ‘‘ongoing waste management activities that, if they were interrupted, could

lead to near-term adverse impacts on workers, the

public, or the environment” (52). The HWVP,

because it is subject to an agreement among the

Environmental Protection Agency (EPA), the State,

and DOE and physical construction has not begun,

is priority 2; the latter ‘‘adds waste management

activities that directly respond to agreements between DOE and State or Federal regulatory bodies’

(52). Start dates for the operation of vitrification

facilities are DWPF, FY 1992; West Valley, FY

1995; HWVP, after FY 2000 (52).

DOE plans to pretreat the high-level liquid waste

streams at Hanford, Savannah River, and West

Valley to reduce the volume of waste to be vitrified.

Pretreatment involves evaporation and separation of

a “low-level” fraction to be disposed of by mixing

with cement to make a concrete or grout that is

subsequently placed in a disposal facility at or near

the surface. Facilities for pretreatment have been

constructed; some startup operations have begun at

Hanford and Savannah River, whereas immobilization with cement is quite far along at West Valley.

The “low-level” grout material at Hanford is

subject to mixed waste regulation under the Resource Conservation and Recovery Act (RCRA).

However, DOE contends that the Savannah River
10 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear weapons Complex

grout is a “non-hazardous waste form and qualifies

for disposal in an industrial waste landfill. ’’11

Calcination solidifies liquid waste by spraying

droplets onto hot particles, resulting in a granular

end product that is transferred to stainless steel bins

encased in near surface concrete vaults. In the

process, the volume is reduced eightfold (9). Calcining operations began at the Idaho chemical Processing Plant (ICPP) in 1963. The newest facility, the

New Waste Calcining Facility (NWCF) that came on

line in 1982, has calcined more than 2 million

gallons of liquid waste (73). The NWCF has had two

extended shutdowns and was not operating throughout most of 1990 (35). According to the 1989

Five-Year Plan, although calcined waste is suitable

for extended storage (400 to 500 years in the current

stainless steel bin-concrete vault arrangement) .12

66

. . . DOE has not determined its acceptability for

final disposal” (15). Calcined waste is “readily

retrievable and, if necessary, will be immobilized for

disposal. ’ Design of an immobilization plant is due

to start in FY 2002 “if this is the decision of DOE”;

the treatment method is unknown (52). DOE appears

to be leaning toward a glass ceramic as the preferred

final waste form.

Conditions of HLW storage is described in the

1989 Five-Year Plan (53). All HLW is mixed waste.

Double-shell tanks at Hanford and Savannah River

containing liquid waste meet RCRA requirements.

However, new tank construction is planned for

INEL. “Double-shell (double containment) tanks

for liquids, salts and sludges at the Hanford Site and

the Savannah River Site and stainless steel bins at

the Idaho National Engineering Laboratory (INEL)

for dry calcine provide high integrity storage pending final treatment and disposal of high-level waste.

At INEL,storage tanks and concrete containment

vaults were built about 35 years ago. They are still

sound but do not meet current earthquake standards

or RCRA secondary containment rules. A major

effort is planned, beginning in FY 1991, to design

and build four new 500,000-gallon stainless steel

tanks for liquid waste at INEL, to replace some of the

current ones (53).

Both DWPF and HWVP will include storage

capability for vitrified waste, with the ability to add

additional storage space until the geologic repository is ready to receive HLW for disposal. Plans for

the final HLW form at INEL are still under

development. “Shipments to the repository will

fulfill DOE’s long-term goal of ending the need for

interim storage of high-level waste” (54). “Highlevel waste is to be immobilized and disposed of

using highly reliable isolation technology-a deep

geologic repository’ (55). Present efforts focus on

a site at Yucca Mountain, NV. However, according

to a 1989 Nuclear Regulatory Commission (NRC)

assessment, such a facility may not be ready until the

second decade of the 21st century .13 According to

the 1989 Five-Year Plan, recent EPA restrictions on

storage mean that if disposal is not accomplished,

operations could be curtailed. As a waste producer,

DOE must obtain approval from the NRC to place

waste in a repository that will house the Nation’s

spent commercial fuel. DOE must also pay a share

of the repository costs (55).

Amount and Distribution

Figures 1-3 and 1-4 show the distribution of HLW

at DOE sites by volume and radioactivity. Of the

four locations with high-level waste, Hanford and

Savannah River have a combined total of more than

90 percent of the waste, as measured by both volume

and radioactivity. Idaho (ICPP) has 5.6 percent of

the total radioactivity and 2.9 percent of the total

volume. The fourth site, West Valley, has the

smallest amount, occupying one large carbon steel

tank and one small stainless steel tank. However,

solidifying this “small’ amount, along with decontaminating the old fuel reprocessing facility and

converting it to a vitrification plant, will cost about

one billion dollars (45).

For purposes of comparison, high-level defense

waste is estimated to contain 1.17 billion curies (Ci),

some 40 times the radioactivity of commercial HLW

but one-sixteenth the radioactivity of commercial

spent fuel.14 With the exception of 3,400 cubic

meters (m3

) of solid calcine stored in stainless steel

bins at Idaho and a small volume of separated

strontium-90 (Sr90) and cesium-137 (CS

137) in stain1lS.P. Cowam U.S. D~ment of Energy, personal communication to R.P. Morgan, Mm. 21, 19~.

12J. Solecki, U.S. Department of Energy, “INEL Waste Management Strategies,” presentation and viewgraphs, July 28, 1989.

13Waste Confidenw Decision Review—pro~sed Revision of Waste Confidence Decision, 54 Fed. Reg. 39767, 39783 (1989).

14Swnt fiel at DOE sites is not ~clud~ ~ he deffition of defense ~W, nor does the IDB provide my comprehensive information 011 the ilTIIOUllt

of defense spent fuel at DOE weapons sites.
Chapter 1--High-Level Waste Management at the DOE Weapons Complex ● 11 —

Figure l-3—Total Volume of High-Level Waste Through 1988

\A/nL+ !IOII~i, n~m~m~+.+ifim DrOjeCt(O,G~O)

k

Site Volume

Hanford \~~ v WI )244,000

Savannah River

 Plant(2.9%)

128,000

ICPP 11,000

WVDP (commercial)

L

2,130

Total 385,000

*: NR\ 1. Volumes are in cubic meters

\

2 These percentages WiII change

““CC), VClllcy “c, ,,”, ,>,, a,,”, , ,

/\ Al\ IITD\

Idaho Chemical Processing

(ICPP)

after treatment

Savannah River(33.2%)

\\\\\\\\\\v Hanford(63.3%)

SOURCE: U.S. Department of Energy, “Integrated Data Base for 1989,” DO13RW-0008, November 1989.

Figure l-4—Total Radioactivity of High-Level Waste Through 1988

‘est ‘a”ey ‘&+XiFjat’ Curies

446,000,000

‘dahOchemicfi&P~e’s

661,000,000

67,000,000

al) 29,300,000

1,200,000,000

Savannah River(54.9%)

7.1%)

SOURCE: U.S. Department of Energy, “Integrated Data 8ase for 1989,” DOE/RW4008, November 1989.

less steel capsules stored underwater at Hanford, all phases: liquid, sludge, salt cake, and precipitate,

HLW is stored in steel tanks. These exceptions with sludge containing 60.5 percent of the radioacamount to more when their radioactivity is consid- tivity.

ered: 4.8 percent of the total HLW radioactivity at

Hanford, Idaho, and Savannah River is found in the At Hanford, 149 single-shell tanks contain an

Idaho calcine, and 15.1 percent is found in the estimated 157 million curies of radioactivity .15

strontium and cesium capsules. Some of these tanks were initially designed to

cascade (discharge) waste into cribs, followed by

Some 128,000 cubic meters (339 million gallons) percolation through soils so that the radioactive

of HLW at Savannah River is stored in carbon steel material would be retained in the soil. This practice

tanks. The radioactivity is distributed among four was discontinued after the 1950s, when evaporators

ls~e Cfie, a Conventioml unit of radioactivity, is equivalent to 37 billion disintegrations per second.

292-864 0 - 91 - 2
12 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

Figure 1-5—Total Volume, Radioactivity, and Thermal Power of High-Level Waste

Stored in Tanks, Bins, and Capsules at Savannah River, Idaho, and Hanford

(figures projected for 1989 to 2020)

400 1

1600

o

*

202

Year

5000 , t

‘o

4000

3000

2000

1000

0

1980 1990 2000 2010 2020

Year

● Accumulated by end of year IEa Actual Projected

SOURCE: Adapted from U.S. Department of Energy, “Integrated Data Base for 1989,” DO13RW-0006, November

1989.

were built to concentrate the waste. About 66 tanks meters); however, the radioactivity of the calcine is

are believed to have developed leaks. The contents

of these tanks, therefore, are subject to more

uncertainty than indicated in the IDB. The salt cake

has the largest volume, whereas the sludge contains

the highest radioactivity. Also at Hanford are 28

double-shell tanks containing 111 million curies of

radioactivity, reported in the IDB as ‘‘slurry. ’

Idaho has 7,600 cubic meters of HLW liquid,

more than twice the volume of calcine (3,400 cubic

56.9 million curies, 5.6 times the radioactivity of the

liquid (10.1 million curies). Calcination reportedly

reduces the volume of HLW by a factor of eight (73).

The volume reduction and radioactivity concentration that occur are indicated by the ratio of liquid-tocalcine volume per unit of radioactivity (12.6 to 1).

West Valley has three types of commercial waste:

1) 50 cubic meters (13,200 gallons) of acid liquid

waste from reprocessing fuel containing. thorium,
Chapter 1--High-Level Waste Management at the DOE Weapons Complex ● 13

located in one stainless steel tank; 2) alkaline waste

consisting of 2,020 cubic meters (534,000 gallons)

of liquid and 46 cubic meters (12,200 gallons) of

sludge, all in one carbon steel tank; and 3) 13 cubic

meters (3,430 gallons) of solid zeolite loaded with

cesium-137 and stored underwater.

Inventories of defense HLW, both past (historical) and future (projected), are presented in tabular

form in the IDB; they are plotted in figure 1-5. From

the end of 1980 through 1988, the accumulated

volume of HLW at the sites increased by 30 percent;

radioactivity decreased by 10 percent, and thermal

power (the rate at which heat is generated due to

radioactive decay) increased by 1 percent. The fact

that the radioactivity decreased while the volume

increased can be explained in part by the decay of

short-lived radionuclides. However, other factors

may also be involved.

DOE is constantly revising its estimates of the

volume and radioactivity of defense HLW as a result

of new information that permits either better estimates of already existing HLW or reclassification of

HLW to other categories such as transuranic (TRU)

waste or low-level waste (LLW). For example, in the

1989 IDB, the volume and radioactivity of the

Hanford strontium and cesium capsules were each

reduced by roughly 10 percent from values in the

1988 report. The reason given was that over the

years, a number of capsules had been dismantled and

the contents used outside of Hanford; these will not

be returned to Hanford (61). In addition, substantial

changes were made to estimates of West Valley

waste. Finally, estimates in the IDB include no error

bounds to help the reader judge the accuracy of

information. In the past, questions have arisen about

the inventory of plutonium in the HLW tanks at

Savannah River (26). Characterization of the contents of the single-shell tanks at Hanford could yield

changes in estimates of their volume, radioactivity

and composition.

Projections of HLW through the year 2020 are

also included in figure 1-5. Projections are based on

a scenario for weapons production dictated by

national nuclear weapons material stockpile needs.

They assume that three reactors at Savannah River

will be restarted during 1989-90 (they were not) and

will operate through the year 2000; after 2000 the

three reactors will be replaced by one new production reactor. The projections include conversion of

some liquid HLW to glass in the Defense Waste

Processing Facility at Savannah River (and at West

Valley) but not at Hanford or Idaho; however,

elsewhere in the IDB, estimates are presented for the

potential number of canisters holding immobilized

waste at INEL and borosilicate glass waste at

Hanford.

In figure 1-5, the cumulative volume, radioactivity, and thermal power of defense HLW stored in

tanks, capsules, and bins, projected to the end of the

year 2020, are somewhat lower (20 percent decrease

in volume, 12 percent decrease in radioactivity, 9

percent decrease in thermal power) than those at the

end of 1988. However, if projected glassified waste

is added to the waste in tanks, bins, and capsules, the

end-of-year projections for radioactivity and thermal

power show an increase of 17.6 and 20.1 percent,

respectively, whereas the volume decreases by 19.3

percent due to vitrification (see figure 1-6 for

radioactivity projections). The volume decrease

could be even greater by the end of 2020, the last

year for which projections were made, if the Hanford

vitrification and Idaho immobilization facilities

come on-line as scheduled.

In terms of specific sites, a substantial increase in

HLW volume and radioactivity (see figure 1-6) is

expected for ICPP in the 21st century; 16 both are

projected to grow to more than five times their 1988

values by the year 2020. As figure 1-6 indicates,

most of the projected ICPP radioactivity is associated with the calcine. The projected radioactivity of

HLW from accumulated production at Savannah

River continues to increase, whereas it remains

constant at Hanford. If the deep geologic repository

is available by 2020, some of the glass attributed to

Savannah River could be emplaced in, or in transit

to, the repository.

Current and Potential Problems

Liquid Tank Storage: Soil and Groundwater

Contamination; Tank Explosion

The three DOE weapons facilities with HLW—

namely, Hanford, Idaho, and Savannah River-as

well as the site at West Valley, all have a number of

tanks on site that contain highly radioactive liquids

and associated physical forms requiring constant

vigilance. Many of these tanks can hold on the order

l@ne of tie fictiom of tie ICPP is to recover highly-efiched uranium from spent naval reactor fuel for use in the “driver” fuel elements Of the

Savannah River production reactor (31).
14 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

Figure 1-6-Total Radioactivity y of High-Level Waste in Storage by Site Through 2020

(figures projected for 1989 to 2020)

1000

900

800

z

Q 700

a 600

: 500

-: 400

~ 300

g 200

100

0

Savannah River Site

Yea r

Idaho Chemical Processing Plant

3004 1

250

.- u

+-0%

50

0

❑ Sludge

❑ Liquid

❑ Salt cake

❑ Glass a

■ Precipitate

■ Calcine

❑ Liquid

o m

a3

o

co

m a) o u) m o

0 u)

o

0

a a’) Cn m v

o

Y

o z

N

7 7 N

z No

N CN N

Yea r
Chapter 1---High-Level Waste Management at the DOE Weapons Complex . 15

Figure 1-6—Total Radioactivity of High-Level Waste in Storage by Site Through 2020

(figures projected for 1989 to 2020)-Continued

%.-

>.-

Z

m0

u

%

u-)

c

.—0

=.—

E

Hanford Reservation

❑ Capsules b

❑ Sludge

❑ Slurry

❑ Liquid

❑ Salt cake

.—c

‘5

(n

c

.—0

=.—

E

30

25

20

15

10

5

West Valley Demonstration Project

35 J Jlnm

❑

El

EN

Liquid

Sludge

Zeolite

Glass a

NOTES: a. Glass maybe in storage at the site, in transit to a repository, or in a repository.

b. Capsules contain either strontium fluoride or cesium chloride.

SOURCE: U.S. Department of Energy, “Integrated Data Base for 1989,” DO13RW-0006, November 1989.
16 ● Long-Lived Legacy: Managing High Level and Transuranic Waste at the DOE Nuclear Weapons Complex

of 1 million gallons (3,800 cubic meters) of waste.

Tanks at Hanford and Savannah River have been the

object of scrutiny by States, environmental groups,

and local citizens concerned with leakage and

subsequent environmental ,contamination, and with

the possibility of explosion. Tanks at Idaho, although used mostly for short-term storage prior to

calcining the waste, are in concrete containment

vaults that do not meet either current design basis

earthquake standards or present-day RCRA secondary containment rules (53).

Hanford has 149 single-shell tanks and 28 doubleshell tanks, both made of carbon steel as opposed to

the more expensive stainless steel. Because of the

highly acidic nature of liquid waste leaving the

Plutonium Production and Extraction reprocessing

plant, the waste must be neutralized to prevent

reaction with the tank walls. The neutralization step

precipitates sludge at the bottom of the tanks and

complicates subsequent transfer. At Hanford, the

single-shell tanks were built before the double-shell

tanks, when there was less concern with environmental and health effects than exists now; the frost

tank was put in operation in 1944 (see table 1-1 for

chronology).

According to a 1989 General Accounting Office

(GAO) report, DOE officials estimate that from

1959 through 1988, definite or possible leaks had

occurred in 66 of the 149 single-shell tanks (5

leaking tanks were identified in 1988), releasing

about 750,000 gallons of HLW as estimated by

contractor personnel (42). Earlier, liquid waste from

some single-shell tanks was deliberately released to

cribs from which waste percolated into the soil as

part of the disposal process.17 The first indication of

a potential leak occurred in 1956; no new liquid has

been added to the single-shell tanks since 1980 (see

table 1).

The environmental and health impacts due to the

movement of liquid waste from single-shell tanks

into the soil are not well established. There is no

unanimity about pathways through which the radioactive and hazardous substances travel or their

ultimate fate. The GAO summarizes the situation as

follows (43):

DOE officials have stated that the environmental

impact of the single shell tank leaks will be low or

non-existent and have cited several studies as a basis

for their assessment. However, we believe the

studies do not provide conclusive evidence about the

degree of environmental impact attributable to tank

leaks. Some studies indicated there would be limited

environmental impact, but they did not analyze the

impact of several mobile contaminants on Hanford’s

groundwater, One study predicted groundwater contamination would exceed safe “ drinking water standards but did not project the impact on the Columbia

River.

Information in a recent report by the Hanford

Education Action League (HEAL) supports the case

that groundwater contamination from a variety of

sources on the Hanford reservation reached the

Columbia River much more rapidly than was

previously believed due to geological charnels

under the Hanford site or to the presence of organic

chemicals that speed migration (1 1). DOE has yet to

complete a comprehensive study of subsurface

. Contamination at Hanford.

.

Since 1973, DOE’s strategy for limiting singleshell tank leaks has been to remove the liquid and

seal the tanks to prevent penetration by liquids such

as rainwater. A large volume of liquid has been

removed by evaporation or by pumping to doubleshell tanks. However, according to GAO, pumping

has been delayed in part because of space limitations

as a result of tank space being allocated to ongoing

production programs. GAO recommended that DOE

develop specific plans to place an interim ground

surface material over the tank farms to slow water

drainage through the soil (44).

In a 1987 DOE final EIS, the preferred alternative

for dealing with the Hanford single-shell tank waste

was to study the matter further and defer decision

(59); this alternative was singled out because the

need for action was believed to be less immediate

than in other tasks to be performed, given that most

of the liquid had already been removed from the

tanks and that the remaining sludge and semisolids

had limited mobility. The Hanford Federal Facility

Agreement and Consent Order and the associated

Action Plan of May 1989, entered into by DOE,

EPA, and the State of Washington’s Department of

Ecology, known as the tri-party agreement, codify

deferral of disposal of single-shell tank waste (71),

as proposed in the Hanford EIS. According to the

tri-party agreement, a full-scale tank waste farm

retrieval demonstration is not scheduled until the

year 2004, with complete closure of all 149 tanks by

2018 (71). At present, effort appears to be focused on

ITperso~ comrn~cation during visit to Hanford, November 1989. See alSO S.P. COWm op. cit, foo~ote 11.
Chapter 1--High-Level Waste Management at the DOE Weapons Complex ● 17

Table l-l—Chronology of Major Events in the History of Single-Shell Tanks at Hanford

1944 First single-shell tank went into service.

1956 First indication is obtained of a potential leak.

1959 First leak occurred.

1964 Construction was completed on last group of single-shell tanks.

1966 Last of single-shell tanks went into service.

Total volume of waste in single-shell tanks reached ca. 77 million gallons.

1968 Construction of first double-shell tanks began.

1970 Groundwater monitoring well was drilled. Highly radioactive contaminants leaking from

single-shell tanks were later detected in groundwater. According to DOE, migration to

groundwater most likely occurred during drilling of well but might have been a natural

progression through the soil.

1971 Double-shell tanks became operational.

1972 Pumping program was begun to transfer liquid from single to double-shell tanks.

1973 Largest single-shell leak occurred--an estimated 115,000 gallons.

1980 DOE stopped placing waste in single-shell tanks.

Liquid waste levels in single-shell tanks were reduced to no more than 1 foot above solid

waste.

Plans were adopted to transfer the remaining 8.5 million gallons of single-shell tank waste

that could be feasibly pumped into double-shell tanks by 1985.

1985 Planned pumping schedule was not followed, and scheduled pumping of single-shell tanks

ended. Since August 1985, DOE had pumped liquids only from tanks it assumed had

leaked, with the exception of about 16,000 gallons pumped from one tank in 1986.

1988 Five tanks were added to the list of assumed leakers.

1989 DOE, EPA, and Washington State signed an agreement in which DOE agreed to pump

most of the remaining 5.3 million gallons of pumpable liquid waste from the single-she!

tanks by the end of FY 1995. However, in accordance with the agreement, two tanks that

may be susceptible to excessive heating and require supplement cooling are scheduled to

be pumped by the end of FY 1996.

SOURCE: U. S. Congress, General Accounting Office, “Nuclear Waste: DOE Management of Single-Shell Tanks at Hanford, Washington,” Report

GAORECD-89-157, July 1989.
18 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

characterizing tank wastes. A National Academy of

Sciences panel advises DOE on a continuing basis

on single-shell tank waste. At a December 1989

meeting, panel members urged DOE and its contractors to conduct a systems analysis of alternative

approaches for treating and disposing of tank

wastes .18

High-level waste in Hanford double-shell tanks is

to be vitrified, starting in 1999, at the Hanford Waste

Vitrification Facility (HWVF); a $550-million contract for construction of the HWVF was awarded in

December 1989 to United Engineers and Contractors (72). Waste from these tanks is to be pretreated

prior to vitrification. Because there are only 28 of

these tanks and they are very expensive to build,

DOE is concerned with managing the waste in them

to conserve storage space. Pretreatment serves to

separate a portion of the original liquid HLW so that

it can be treated as low-level waste (i.e., grouted),

and to free up tank space for additional HLW.

Although double-shell tanks appear to be a technological advance over single-shell tanks, the form

(sludge and supernatant liquid) and intense radioactivity of their contents are given priority in the major

milestones for disposal of tank waste in the tri-party

agreement, which include initiation of pretreatment

of double-shell tank waste in B Plant by October

1993 and initiation of HWVP operations by December 1999 (71). In February 1991, DOE proposed a

two-year delay in the startup of the HWVP; startup

of B-Plant may be delayed until the end of 1997.19

A potential problem that has received widespread

public attention only recently is the possibility of

explosions in HLW tanks. In the 1950s, potassium

ferrocyanide was added to the single-shell tanks at

Hanford to precipitate radioactive cesium and strontium so that liquid could be pumped from the tanks

to create room for more high-level liquid waste.

Ferrocyanide, mixed with nitrites and nitrates in the

tanks, can be explosive if certain temperatures are

exceeded. A ‘‘worst case’ scenario, considered in a

1984 Battelle Northwest Laboratories report, indicates that the energy release in such an explosion

could be equivalent to 36 tons of TNT (7). Concern

about tank explosion has been heightened by reports

of a chemical explosion in a nuclear waste tank at

Kyshtym in the Soviet Union, that occurred in 1957

and resulted in the evacuation of 10,000 people and

reportedly released 20 million curies of radioactive

materials (15).

DOE’s position regarding the explosion hazards

in the Hanford tanks has been that there is no

immediate risk because temperatures in the tanks are

well below those at which ferrocyanide explosions

might occur.20 However, concerns have been expressed about uncertainties in characterization of the

waste and about possible hazard if the waste was

mechanically or thermally disturbed (e.g., through in

situ vitrification, vitrification in the Hanford Waste

Processing Facility, or cutting into the salt cake).

Although DOE is studying the situation, further

research has been recommended to learn whether

any other materials present in the tanks represent an

explosion hazard under certain conditions.21

In March 1990, DOE revealed that hydrogen gas

has been building up in 20 of the HLW storage tanks

at Hanford (19). Hydrogen arises from the decomposition of organic materials placed in the tanks and

from radiolysis of water. Although Michael Lawrence, the DOE Hanford facility manager at the time,

is quoted as stating that DOE believes the danger of

an explosion is low and the potential for radioactive

release even lower, according to Lawrence, ‘‘the

worst case is any explosion that could cause the

dome to collapse and send the contents up to the

air . . . . I can’t sit here and say it’s not going to

happen” (19). John Conway, chairman of the

Defense Nuclear Facilities Safety Board, stated after

a briefing on the Hanford tank situation in March

1990 that the board considers the danger of a

hydrogen explosion potentially more serious than a

ferrocyanide explosion (4). However, a subsequent

statement in April 1990 quoted Conway as saying,

“We don’t believe there is any kind of risk to the

public” (18).

In a July 23,1990 letter to the Secretary of Energy,

DOE’s Advisory Committee on Nuclear Facility

Safety (ACNFS) stated that: “The (high level) waste

tanks are a serious problem. The possibility of an

explosion of an unstable chemical (such as ferrocyanide) or a flammable, gas must be taken seriously

because of the magnitude of the radioactive invenlgDiscussion at meeting of Natioti Academy of Sciences Panel on Hanford Single-Shell Tanks, Dec. 6, 19*9.

Is’’secretw De~ys Commction of Hanford Waste Vitrification Plant” Weapons Complex kfotzzIor, Feb. 25, 1991, p. 12.

m FD Pecsomd communication during visit to Hanford, November 1989.

Zlcoment by pme~st at meeting of Nation~ Academy of Sciences on Hanford Single-Shell RiIIJIS, Dec. 6, 1989.
Chapter 1--High-Level Waste Management at the DOE Weapons Complex . 19

tory available for dispersal. “

22Although the ACNFS

“found nothing to indicate that emergency action

was required, ’ ’23 serious concerns were presented:

1) apparent lack of concern on the part of the

operating staff for the tanks about the hazard; 2)

apparent lack of attention by top DOE management

and the contractor about achieving higher levels of

tank safety; 3) an attitude at the DOE Richland

Operations Office that because the tri-party agreement exists, waste issues are being efficiently

resolved, even though the agreement postpones

major decisions on waste handling and risks from

operations. The apparent neglect of several factors

that may call into question Hanford’s belief that

there is “no deflagration or detonation hazard

because of the differences between temperatures

measured in the tanks and temperatures of the onset

of reactions observed in the laboratory tests. ’ They

go onto state that:

The Hanford tanks present a serious situation, if

not an imminent hazard . . . much more effort must

go into determining what is in the tanks, what is

happening in the tanks, and what are the possible

reactions that can occur. . . 24

Uncertainty surrounding the possibility of conflagration and explosion in the waste tanks does need

to be resolved as rapidly as possible. The material

presented to us at Hanford was weak, but did include

the suggestion that the probability of conflagration

may be low and that, even if it were to occur, the

energy release might not rupture the tanks. However,

the available information, the analyses and the

experiments that have been done, leave wide margins of uncertainty.

Until this uncertainty is resolved, the ACNFS

recommends establishing continuous monitoring

and action plans for coping with the event of

excessive pressures or temperatures, or for a release. 25

A significant airing of the tank explosion issue

took place at a hearing on ‘‘Accident and Explosion

Risks at Department of Energy High-Level Radioactive Waste Facilities’ by the Senate Committee on

Governmental Affairs on July 31, 1990. One of the

witnesses, the DOE Director of the Office of

Environmental Restoration and Waste Management,

Leo Duffy, indicated that additional steps being

taken by DOE include formation of a Headquarters

Tank Advisory Panel to review waste tank technical

issues at all DOE sites, and formation of a Senior

Chemists Panel for Hanford to review waste chemical reactions.26 Two additional statements by Duffy

shed light on DOE’s ambivalent attitudes toward

external oversight as well as the apparent seriousness with which they now view the tank explosion

issue:

All the oversight in the world will not do the job

that we must do ourselves. We have had independent

reviews of various pieces to this puzzle-first, the

presence of ferrocyanide in the tanks, followed by

the discovery of hydrogen gas generation, followed

then by the realization that nitrous oxide was present

in the tanks as well-all of which indicates a material

weakness on the part of DOE and its contractors to

understand the fundamental chemistry present in its

HLW tanks.

As slow as we may have been to uncover these

events and then link them together, our ‘discovery’

was not made with the help of the technical safety

appraisals, which failed also to identify the potential

hazards posed by the presence of these chemicals and

failed to add to our understanding of the potential

seriousness of the chemical reactions that were

taking place.27

. . . in my opinion, the issue of accident potential in

the high-level waste tanks would not have surfaced

without your (Senator John Glenn) question on

ferrocyanide in the single-shell tanks. This question

resulted in the subsequent examination of hydrogen

generation, the presence of nitrous oxide and our

need to understand tank chemistry issues, and the

general lack of discipline and follow-up needed to

resolve long-standing technical issues in the Hanford

tank farm. It resulted also in the evolution of

methods used in Technical Safety Appraisals, safety

audits, and Tiger Team Assessments. I want to

express to the Chair my appreciation to this Commit22~fier from Jo~ F. ~eme, c~~% Advi~~v committ~~ on N~clear Facility safety, to the Us. Department of Energy, to James D. Watkhls,

Secretary of Energy, July 23, 1990, p. 4.

‘Ibid.

‘Ibid., pp. 5-6.

‘Ibid., pp. 6-7.

26 S~tementby ~D*, Dfie~tor, DOE Office of Enviro~en~ Restoration ~d Waste M~gementathmon ‘ ‘Accident and Explosion fiSkS

at Department of Energy High-Level Radioactive Waste Facilities, ’ U.S. Senate Committee on Governmental Affairs, July 31, 1990, p. 13.

271bid., pp. 15-16.
20 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

tee and to its staff for helping us to begin resolving

these potentially serious issues.28

In October 1990, the Defense Nuclear Facilities

Safety Board (DNFSB), which was established by

Congress to provide oversight of DOE activities,

indicated in a letter to DOE Secretary Watkins that

DOE and Westinghouse Hanford Co. were not

moving fast enough to implement safety measures at

the Hanford tanks.29 These measures include installing new instrumentation, accelerating tank sampling, and developing plans for dealing with possible explosions.

The tank situation at Savannah River has received

less media attention than that at Hanford. Savannah

River has the largest amount of radioactivity of all

sites in the form of HLW. According to the FY 1989

Savannah River Waste Management Plan, there are

51 large, subsurface tanks for storing and processing

aqueous HLW (64). All are made of carbon steel and

there are four different designs; none of the tanks

appears to be equivalent to the Hanford single-shell

tank. According to DOE, some leakage of tanks has

occurred along with rusting of tank walls (64). A

program to transfer waste from older tanks to newer,

Type III tanks, which are believed to have good

near-term integrity, is scheduled to be completed

through 1995. There are 27 of these double-shell

Type III tanks (64).

Problems with the HLW tanks at Savannah River

figured prominently in a 1986 report (26) by the

Environmental Policy Institute (EPI), namely concern about: 1) contamination of the shallow aquifers

beneath Savannah River; 2) possibility of tank

explosions; 3) potential threat of an earthquake,

which the tanks were not designed to withstand (in

an area that had a large earthquake in 1886); and 4)

excessive radiation exposure of personnel working

around the tanks or dealing with certain aspects of

the DWPF vitrification plant when it begins operation (26). The highly critical tone of the EPI

assessment contrasts with DOE descriptions of

Savannah River HLW operations.

In EPI’s 1987 reply to Du Pent’s response to its

Savannah River critique, the report states that the

buildup of organic vapors in tanks has a larger

likelihood of occurring than does buildup of hydrogen (27). Furthermore, EPI finds Du Pent’s estimates of the probability of a tank explosion to be

considerably lower than its own (27). In October

1990 the condition of the tanks at Savannah River

and the possibility of explosions and fires were

being studied by a variety of groups including the

Advisory Committee on Nuclear Facility Safety.

According to the 1989 Five-Year Plan, INEL’s

HLW tanks, although stainless steel and still sound,

are 35 years old and their concrete containment

vaults do not meet either current earthquake standards or RCRA secondary containment rules. As a

result, DOE plans in FY 1991 to design and

eventually construct four 500,000-gallon tanks to

replace five of the eleven 300,000-gallon tanks

currently storing HLW at the Idaho facility (53); the

new tanks are to be put into operation by FY 1997

(56). This appears to be the only facility in which

new HLW tank construction is planned. If shutdown

of the calcination facility continued for a long time,

the liquid tank storage capacity required would

increase.

Insummary, HLW storage tanks represent potential sources of radioactive releases to the soil-and,

hence, to water under the site and eventually

off-site--or of more widespread release by explosion or natural disaster such as an earthquake. Many

tanks were not designed for long-term storage, and

the use of carbon steel necessitated neutralizing the

waste, which has resulted in complex mixtures of

liquid, sludge, and salt cake that are difficult to move

and represent a potential hazard to those involved in

sampling tank contents or in other operations.

Ironically, new tanks are to be built at the one

location of three in the Weapons Complex that has

the smallest amount of HLW, where stainless steel

rather than carbon steel tanks are present, and where

calcining is used to solidify HLW, namely, Idaho.

By contrast, at Hanford, no decision seems near on

how to dispose of single-shell tank waste. A lot is

riding on the success of the vitrification plants at

Savannah River and Hanford to reduce the risk

posed by high-level tank wastes.

Reprocessing Plants: PUREX

The high-level radioactive waste in interim storage as liquid slurry or calcine is generated by the

reprocessing of spent fuel and irradiated targets.

Before reprocessing, most of the radioactivity is

associated with and contained in the confines of the

solid spent fuel and targets. To recover plutonium

‘Ibid., pp. 16-17.

29Geranios, N.K., ‘‘Federal Board Finds ‘llmk Plans Inadequate,’ Associated Press News Release, Oct. 17, 1990.
Chapter 1--High-Level Waste Management at the DOE Weapons Complex ● 21

Figure 1-7-Chemical Processing of PUREX Liquid Effluents

Process Cooling Water Cooling Water / Chemical Sewer

Chemicals, B-3 Pond

Steam, Water

Steam Condensate

1 A-30 / A-37 -2 Cribs

PUREX ;-, ‘P;oiei;is;i’i’;- ---- ‘;-;;5;;;- :

I Ammonia Scrubber I

I

I

I

I I

I Distillate

A-45

(Planned) ~

I

-------- ———-——— — — - —------- -

Miscellaneous Plant waste

High-Level Waste

Declad Waste Double-Shell Tanks

Ammonia Scrubber Waste

SOURCE: Westinghouse Hanford Co., November 1989.

for weapons use, these solids must be chopped up,

dissolved, and processed with both organic and

aqueous solvents. The net result is a huge increase in

the volume of radioactive waste. Figure 1-7 illustrates some of the liquid streams from the Plutonium

and Uranium Extraction (PUREX) plant at Hanford;

the PUREX process with appropriate modifications

has generally been adopted as the standard for

reprocessing nuclear fuel, both in the United States

and worldwide.

Some indication of the potential environmental

impact of the PUREX plant is given by the following

(40):

Reprocessing plants like PUREX and its predecessors, which recover plutonium from irradiated uranium, have been responsible for some of the worst

environmental contamination at Hanford because

they generate huge volumes of toxic chemical and

radioactive wastes. The process that produces one

kilogram of plutonium at PUREX also produces over

340 gallons of liquid high-level radioactive wastes

mixed with hazardous chemicals, more than 55,000

gallons of low- to intermediate-level radioactive

wastes discharged to cribs, and over 2.5 million

gallons of cooling waters disposed to ponds.

Some advocate reprocessing fuel to recover and

recycle transuranic radionuclides as a way of reducing the radioactive waste disposal burden. According to this approach, with recycling, long-lived

transuranics such as plutonium-239 are contained

within the reactor, reprocessing plant, and fuel

fabrication plant or their immediate vicinity. Therefore, the waste to be disposed of contains fewer

long-lived radioisotopes. However, reprocessing

usually expands the volume of waste to be dealt

with, and long-lived radionuclides are not totally

eliminated by transmutation in the reactor.

In December 1989, the PUREX facility at Hanford was shut down in “mid-campaign,”30 that is,

with highly radioactive materials dispersed throughout the system. Some 20 metric tons of material was

present in the dissolvers and 70 metric tons elsewhere in the system.31 PUREX, which is more than

30 years old, went through a long shutdown period

in the 1970s and early 1980s (9). In November 1989,

Westinghouse and DOE officials at Hanford were

hoping to perform a “stabilization” run on the

~~e tm“campai~” asused by DOE, means operation of the facility to process one batch of fuel from Start to ffish.

Slpemoml comm~cation during visit to Hanford, November 1989.
22 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

system (i.e., operating the system to clean out

material dispersed through it) as soon as possible,

followed by a campaign to reprocess the 2,100

metric tons of fuel, including 350 metric tons of

weapons-grade material awaiting reprocessing.32

Obstacles to restart included environmental regulation, concerned citizens groups, and the age and

condition of the facility.

Concerns about PUREX reported in the media or

raised by environmental and citizen groups include

the following:

1. Some reports claim that radioactive liquid

effluent streams from the plant continue to be

discharged into the soil, even though the fate of

radioactive and hazardous materials in these

discharges is not well known. The following

material is from Associated Press (17): “According to the Hanford Education Action

League, PUREX discharges up to 9,000 gallons

of liquid per day (into the soil) when operating;

even in a standby (shutdown) condition, it

discharges 4,000 to 5,000 gallons per day into

the soil. A DOE spokesman maintains that

continued liquid flow is necessary during ‘idle’

for safety reasons. Although PUREX is only

one source of liquid discharges at Hanford, it is

the ‘biggest single liquid waste generator. ’ “

Again, according to the Hanford Education

Action League, of the 33 liquid waste streams

identified at Hanford, the 19 most radioactive

must be stopped, stored, or treated by June 1995

(in compliance with the tri-party agreement). A

Hanford report estimates the cost to prevent

dumping of liquid wastes into the soil to be

$244 million.”

An article in October 1989 (40) reported that

after PUREX was built in 1956, it took only 7

years for a radioactive tritium plume from its

operations to reach the Columbia River, some

9 miles away; that plume results in about 4,000

curies of tritium entering the river annually,

according to DOE-contractor water monitoring

reports. 33 Originally, it was expected to take

175 to 180 years for contaminated groundwater

to travel to the Columbia River; the fact that

movement is an order of magnitude more rapid

is perhaps due to channeling effects under the

Hanford site or to the presence of organic

chemicals that speed migration.34

2. An Associated Press article in December 1989

3.

4.

5.

stated that shutdown of the plant in 1989,

during a campaign, necessitated a stabilization

run to blow out material that had settled in pipes

and other equipment. A concern was that

radioactive and hazardous liquids might be

discharged if the plant were started up in this

condition, with materials distributed throughout the system, especially if any equipment

were to fail. Because of the age of the plant,

equipment failure has been common in recent

years.

35 In December 1989, DOE and Westinghouse-Hanford began a “phased restart to

stabilize chemicals” (75).

The ACNFS has expressed concern about the

high turnover of workers and management at

PUREX that could lead to a potential safety

issue when the plant is restarted.36

There is also some concern that DOE and

Westinghouse-Hanford have not always provided information on occurrences at the plant in

a timely and accurate fashion.

Finally, some have stressed a number of

regulatory issues that center on hazardous

waste streams in the PUREX facility, such as

the use, treatment, and disposal of “listed

wastes’ (e.g., acetone, n-butyl alcohol, xylene,

and toluene). These issues are important in

considering the restart of PUREX.

Support for the restart of PUREX offered by DOE

and DOE-contractor personnel at an OTA meeting at

Hanford in November 1989 was based on the

321bid.

ss~e DOE contractor report cited is Pac~lc Northwest Laboratory, “Environmental Monitoring at Hanford for 1984,” PNL-540-1, May 1985.

~Tritium is not produced deliberately by irradiation of lithium targets in the Hanford reactors. However, it is produced by fiSSiOn in the fiel. Some

tritium is released as a gas in the dissolution process, whereas the remainder follows the aqueous reprocessing stream and is released to the environment

as tritiated water vapor or liquid. See M. Benedic~ T.H. Pigford, and H.W. Levi, Nuclear chem”cdEng&tv-ing, 2d ed. (New York NY: McGraw-Hill,

1981), p. 357.

qsFor ex~ple, a concen~atorf~ue led to an extended outage; it was one of several factors involved in the suspension of P~X operations dtig

1989. Source: Viewgraph from briefing by D.H. Shuford, “PUREX Status, Plans and Issues, ” Nov. 17, 1989. In addition, the New York Times, on Dec.

16, 1989, reported that on Dec. 3, 1989, an unexplained chemical reaction in a pipe of the shutdown PUREX plant “ruptured a gasket and sprayed acid

into an area sometimes occupied by workers. ’

3GJ.F. ~eme, U.S. Department of Energy Advisory Committee on Nuclear Facility Safety, letter to James D. W?UkhIS, secrew of Energy, J~Y

23, 1990.
Chapter 1--High-Level Waste Management at the DOE Weapons Complex ● 23

following: Spent fuel from the N reactor awaiting

reprocessing is being held in water basins at K plant,

just one-quarter mile from the Columbia River.

These basins have leaked in the past. The metallic

fuel elements sustained some mechanical damage in

being unloaded from the N reactor into storage

pools; some 6 to 10 percent of the fuel is estimated

to be in a failed condition.37 In this condition,

radionuclides can be released to the water basins

which, if they were to leak again, could cause

groundwater and river contamination .

In March 1990, DOE provided the following

information concerning the PUREX stabilization

run and proposed restart:38

PUREX was restarted on December 17, 1989, to

complete a processing run that was interrupted on

December 7, 1988. The processing run was successfully completed March 1, 1990. Only minor operational/equipment problems were encountered during

the run. PUREX is now scheduled for an extended

outage of approximately one year to prepare for the

processing of the irradiated N reactor fuel now in

storage. Activities scheduled during the outage

include an inventory of special nuclear materials,

maintenance and repairs, and the construction of

waste disposal facilities. An Environmental Analysis

(EA) will be issued in March, 1990. The EA will

determine whether the previous environmental impact statement for PUREX needs to be updated.

A July 1990 analysis of whether or not to restart

PUREX was prepared by the Institute for Energy and

Environmental Research (IEER) for the Hanford

Education Action League (HEAL) .39 In a subsequent article, the situation is described as follows:40

The environmental problem posed by the fuel is

real enough. About 3-7 percent of the N-reactor fuel

is damaged and is being corroded by contact with

water. The spent fuel in K-West is sealed inside

water-filled containers which contain the radioactivity, but the fuel elements in K-East are stored in open

cans, and the water in the basin is highly contaminated. Workers do not enter the pool area without

special radiation protection equipment. The pool

itself leaked before it was repaired in 1980, and

Westinghouse estimates that some 15 million gallons of water contaminated the surrounding environment with up to 2,500 curies of strontium 90 and

cesium 137.

The IEER-HEAL report’s preliminary short-term

recommendations were: 1) PUREX should not

restart because the hazards of greatest consequence

appear to be connected with reprocessing as opposed

to other N-fuel management options; 2) to minimize

the risks of continued storage of N-fuel in the

K-basins, exposed N-fuel should be encapsulated as

soon as possible; and 3) preliminary design of dry

storage facilities for interim management of N-fuel

should also begin as soon as possible.41

The decision as to whether or not to restart

PUREX is a significant one. It depends on factors

such as the need for additional plutonium for the

U.S. weapons stockpile and the desirability of

keeping some form of production mission for the

Hanford site. In October 1990, DOE Secretary

Watkins announced his decision not to restart the

PUREX plant for at least 2 years.42 During that

2-year period, a study will be conducted of environmental issues associated with PUREX. Although the

option of restart after 2 years still seems to be left

open, some observers interpret the decision as

indicating that PUREX will never again operate.43

Major chemical processing-reprocessing facilities

also exist at Savannah River and INEL. Late in 1989,

the ICPP, which processes fuel for naval reactors,

was put on “temporary standby” because of concerns about underground piping leading to storage

tanks. The piping is single-walled, and RCRA

requires secondary containment such as doublewalled piping. In addition, the New Waste Calcination Facility (NWCF) at the ICPP had not operated

since October 1988. Calcination was to have been

resumed, after completion of a ‘‘dissolution campaign, ” on July 9, 1989, but was postponed pending

sT~omation for MS p~~aph Was Obtied from DOE and DOE-contractor personnel dtig a tip to Hanford ~ Novemb~ 1989.

38s.P. CoVV~ op. cit., footnote 1.

39s. Sdeska and A. Mtijti, “To Reprocess or Not To Reprocess: The PUREX Questiou A Preliminary Assessment of Alternatives for the

Management of N-Reactor Irradiated Fuel at the U.S. Department of Energy’s Hanford Nuclear Weapons Production Facility,” Report prepared for

Hanford Education Action League, July 1990.

40s. s~esti and A. Mtijafi, “Hanford Cleanup: Explosive Solutio~” Bulletin of the Atondc Scientists, vol. 46, No. 8, Oct. 1990, p. 20.

411bid.

42N.K. Geranios, “Plutonium Processing Plant Won’t Reopeu Energy Secretary Says, “ Associated Press News Release, Oct. 17, 1990.

43R.J. smi@ ‘<DOE Drops Plan To Resume Making Plutonium for Bombs, ’ Washington Post, Oct. 17, 1990, p. A2.
24 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

correction of piping deficiencies. 44 Other Postponements followed.45 46 A December 1990 Associated

Press news release indicated that startup of the

NWCF was imminent and that the reprocessor might

be restarted in January 1991. In addition, no

Savannah River site fuel has been reprocessed since

1988, although some off-site fuel continued to be

processed in 1990. Although INEL and Savannah

River reprocessing facilities seem to generate less

public concern than the PUREX plant at Hanford,

presumably they all use the same basic process with

some differences in details and could be subject to

some of the same problems.

Although they have not arisen in recent years, two

other concerns may be relevant to concerns about

future waste management effectiveness:

First, given the importance of plutonium and

uranium-235 as weapons-grade materials, it is essential that they be carefully accounted for by

material balances. Past uncertainties about the amount

of plutonium and other materials in the underground

HLW storage tanks or the amount discharged into

the soil indicate that careful accounting has not

always been the case. It may be useful to audit the

current materials accounting system.

Second, U.S. experience and practice in fuel

reprocessing may not be keeping up with the state of

the art in several European countries and Japan since

they are pursuing commercial reprocessing whereas

the United States is not. In planning the modernization of weapons facilities, including minimizing

waste generation and environmental impact, nonU.S. input could prove valuable and should be

sought, consonant with U.S. security requirements.

Contamination From Strontium

and Cesium Capsules

In 1968, the ‘‘B” Plant at Hanford was converted

to remove radioisotopes of cesium and strontium

from PUREX acid waste and from supernatant

liquids in HLW tanks. Through 1985, these radioisotopes were solidified as strontium-fluoride and

cesium chloride and doubly encapsulated (10).

According to the 1989 Integrated Data Base, 1,349

cesium capsules and 597 strontium capsules are

stored in a water basin, pending additional packaging and disposal in a repository (61). The half-lives

of beta-emitting strontium-90 and beta- and gammaemitting cesium-137 are 28 and 30 years, respectively; thus disposal for several hundred years rather

than tens of thousands of years should suffice to

reduce the radioactivity to acceptable levels.

IDB 1989 estimates of the volume of strontium

and cesium capsules stored at Hanford were reduced

by roughly 10 percent over the previous year “to

reflect the fact that over the years 43 strontium

capsules and 227 cesium capsules have been dismantled and put to beneficial use outside Hanford.

These radionuclides will not be returned to Hanford” (61). Even though no problems have been

reported about the capsules stored at Hanford, some

concerns have been raised about those that have been

shipped elsewhere. For example, an Atlanta Journal

article states that (39): Some 252 cesium capsules

had been used by Radiation Sterilizers, Inc. (RSI) to

sterilize medical supplies. That operation has been

shut down since June 1988 when a leak was detected

in one of the stainless steel capsules. Some 159 of

the capsules were still in the RSI building. Removal

of the capsules to Hanford was halted when cracks

were found in nine of the lead-lined containers used

to ship the capsules. DOE is reported to have

assumed responsibility for removal of all capsules to

Hanford, in contrast to the impression given in the

IDB. That removal involves transporting the capsules from DeKalb County, Georgia to Richland,

Washington.

The Atlanta newspaper account emphasizes that

the situation at RSI poses no public danger. It

highlights the tension that has arisen between

officials of the Georgia Department of Natural

Resources and DOE officials at Hanford. It also

contains the following statement: “DOE officials

now acknowledge that the cesium-fried capsules

should never have been used for commercial purposes’ (39). An October 1988 Office of Technology

Assessment (OTA) report concludes that theft and

improper handling of sealed radiation sources have

been responsible for 14 deaths and 4 major accidents

44~omation fOr ~~ ~aa=aph ~m ~Ompiled from M*L. w~d, ‘ ‘ho Nucle~ p~ts closed: pipes Held subs~n~d,’ The New y~r~ Times, NOV.

4, 1989; and “INEL Puts Chemical Reprocessing Plant on ‘Standby’ to Make RCRA Changes,” Report on Nuclear Dq?ense Plant Wastes, Nov. 10,

1989, p. 204.

45S.P. COW~ op. cit., footnote 11.

&A~ repfied by DOE ~ Jme 1990, tie ICpp, ~~ch ~cludes the ~’(_JF, w~ not Operafig WMIC tie plant underwent aKlenvirOrMnerltal COmpfizUICe

assessment. A restart date of August-September 1990 was pro@cted. Meanwhile, no fuel dissolutio~ reprocessing, or calcination of resulting waste was

going on at ICPP. Source: S.P. COWW U.S. Department of Energy, personal communication to R.P. Morgan, June 5, 1990.
Chapter 1--High-Level Waste Management at the DOE Weapons Complex ● 25

in foreign countries over the last 25 years (47). One

of these accidents, which occurred in Goiania, Brazil

in 1987 and resulted in four deaths plus widespread

, contamination, has been called the second worst

radiation accident in history (37). The situation in

Goiania was caused by the removal of a stainless

steel cylinder containing 1,400 curies of cesium-137

from a cancer therapy machine in an abandoned

clinic (37).

Given the situation that has arisen at RSI and

concerns about more serious problems, it appears

that the strontium and cesium capsules at Hanford

will probably not be destined for future beneficial

uses but will remain as waste destined for geologic

disposal. In 1990, DOE asserts that all capsules are

accounted for. Capsules which are not disassembled

for use as material sources are to be returned for

storage pending eventual treatment prior to disposal

in a geologic repository .47

In response to a follow-on question by OTA, DOE

indicated that some strontium and cesium capsules

were sent to the Office of Isotope Sales operated by

Oak Ridge National Laboratory (ORNL). These

capsules were disassembled and the isotopes sold to

commercial ventures. Once sold, “regulating responsibility and oversight is transferred to the

Nuclear Regulatory Commission. Disposition and

accountability are then no longer the responsibility

of DOE. ’ ’48

Delays and Uncertainties About Vitrification

In November 1989, GAO completed a study of

DOE’s program to prepare HLW for final disposal

(45). GAO found that the Defense Waste Processing

Facility for vitrifying HLW at Savannah River was

2 years behind schedule, and the West Valley

Demonstration Project, also for vitrifying HLW, was

8 years behind schedule. The DWPF at Savannah

River is now scheduled to begin operation in FY

1992.49 The DWPF has been under construction for

several years and has benefited from a series of tests

on smaller scale equipment as well as full-scale

operation of similar technology in Europe. Even so,

the DWPF is a very complex facility of the type that

usually encounters startup problems. Further delays

and uncertainties may be expected at DWPF. Delays

have also been encountered at West Valley. Although it has been possible to utilize some existing

facilities left over from the time of West Valley’s

fuel reprocessing operations, decontamination added

to the burden, as opposed to the entirely new

building at Savannah River (70). It has also suffered

continually from budget shortfalls.

DOE has selected a particular waste package for

DWPF and WVDP, namely, borosilicate glass in

relatively thin-walled (3/8-inch-thick) stainless steel

canisters. If vitrification proceeds according to

schedule, some waste canisters will be produced and

stored long before a repository exists to house them.

Providing such storage at vitrification sites should

not be a major technical problem. Storage for about

5 years operation of the DWPF has already been

constructed at Savannah River. Either in on-site or

monitored retrievable storage, the waste form should

guarantee isolation from the environment for a

thousand years or more if long-term institutional

controls are in place and the waste form performs as

designed. 50 The reported design lifetime of the

DWPF canister is more than 8,000 years.51

According to present U.S. plans, no credit is

allowed for the canister as a barrier to contact

between the waste and the geologic repository in

considering the acceptability of a waste package.

The waste canister’s role is to “encapsulate the

waste glass during on-site storage, shipment, and

temporary storage at the repository prior to overpacking and final disposal. ’ ’52 The canister must be

able to withstand a drop of 7 meters without failure

and must fit in the repository overpack container, as

specified by the NRC.

The U.S. approach of placing no reliance on

engineered barriers is in marked contrast to the

Swedish approach to waste disposal. An evaluation

of the latter by the National Academy of Sciences

states that utilizing thick-walled canisters should

enable the life of the waste form package to be

47S.p. COWU op. cit., footnote 11.

~Ibid.

@At ~ October 1~() ~i~it t. tie DWPF, OTA p~r~o~~l w~e told tit operatio~ wi~ radioactivew~te m@t not beginmti] m 1993 Or 1994 due

to budget uncertainties.

flsho~d tie ~po.sitoq be de~yed, howev~, WE wo~d need to co~ider tie issues of longer.te~~ti~tiomlconhols and IOCd public aCUpt~U

of on-site storage.

51S.P. COWW op. cit., footnote 11.

%id.
26 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

extended to more than one million years (28). Some

thought is also being given in the United States to

placing more reliance on the engineered waste form.

One issue for future inquiry identified in the first

annual report of the Nuclear Waste Technical

Review Board (NWTRB) to Congress concerns the

relative importance of natural and engineered barriers.

53 Using longer-lived engineered barriers means

that less reliance would have to be placed on

geologic barriers or mathematical models of geologic performance when making licensing decisions

(34).

If this were to occur, modification of existing

designs might be required. Because the primary

focus of the repository is commercial spent fuel, the

NRC overpack container might have to be redesigned. This might have no effect on defense HLW

canister design or it could necessitate changes.

Current DOE plans and NRC requirements do not

involve changing the waste canister, overpack, or

container. If changes were anticipated, however,

they would need to be balanced against the increased

risk of delays in proceeding with vitrification of

HLW tank contents.

Releases to the Atmosphere

The facilities involved in generating HLW—

namely, nuclear reactors and reprocessing plants—

as well as the facilities used to treat them, such as

evaporators and calciners--sometimes release materials to the atmosphere. Early in the weapons

program at Hanford, large releases of volatile fission

products occurred when fuel was dissolved. More

than 500,000 curies of iodine-131 was reportedly

released to the air between 1944 and 1957 (41).

Through the introduction of air filters and other

off-gas handling equipment, releases of radionuclides have been reduced but not totally eliminated.

At Savannah River in 1984, 1.7 million curies of

radioactivity was released routinely into the atmosphere, most of which was tritium (790,000 curies)

and krypton-85 (840,000 curies) (13). Accidental

releases have also occurred. Fortunately, none has

been as large as the Kyshtym radioactive waste tank

explosion in the Soviet Union, in which an estimated

20 million curies, roughly 40 percent of the radioactivity associated with the Chernobyl accident, was

released (15).

Several panelists at an OTA Health Effects Panel

Workshop in January 1990 stated that airborne

release of both radioactive and hazardous materials

could be a greater potential health threat than

groundwater contamination. They also pointed out

that the Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA, “Superfund”) regulations focused attention on groundwater contamination but ignored air releases and that

promulgation of standards for the release of radionuclides to air has become an object of contention

between NRC and EPA.54

TECHNOLOGIES FOR

IMPROVED MANAGEMENT OF

HIGH-LEVEL WASTE

Introduction

Efforts are underway to improve the management

of HLW at the three major DOE sites and at West

Valley. A principal objective is to convert the liquid

and semisolid HLW now stored in aging tanks to

solids that can be immobilized and dispersed throughout a rigid matrix material, encased in canisters, and

placed in a deep geologic repository. This would

eliminate the threat of groundwater contamination

from tank leaks or radioactive releases from tank

explosions. The matrix material selected by DOE is

borosilicate glass and the process of choice is

vitrification. At the Idaho National Engineering

Laboratory (INEL), some liquid waste has already

been solidified into a powdery form by a process

known as calcination. INEL is considering a variety

of solid waste forms besides borosilicate glass to

immobilize the calcine for final disposal.

Three of the facilities that manage HLW pretreat55

it to some extent to reduce the volume that must be

stored as liquid and then vitrified, and hence to

53~e~ was established by a 1987 amendment to the Nuclear Waste Policy Act of 1982, as an outside panel of experts appointed by the

President to review decisions of DOE’s Office of Civilian Radioactive Waste Management (12).

54D0E provided the follofig ~omtion on standards for air releases from reprocessing and other operatiom: DOE r~uirements for con~~@

and reporting air releases are set forth in various DOE orders; emissions of both radioactive and nonradioactive air pollutants must be maintained as low

as reasonably achievable. DOE orders also spec@ the need for compliance with local, State, and Federal clean air laws or regulations where they apply.

The National Emissions Standards for Hazardous Air Pollutants (NESHAPS) in 40 CFR 61 apply to radioactive emissions from all DOE sites, and the

Prevention of Signiilcrmt Deterioration (PSD) regulations in 40 CFR 52 cover nonradioactive pollutants. In general, NESHAPS requirements are

enforced by EPA regional oftlces, whereas PSD regulations are enforced by State agencies. Source: S.P. Cow~ op. cit., footnote 11.

ss~e tem pre~a~at is US~ in ~S paper to mean those steps taken to reduce the volume of HLW to be vitritled; it does not include dcination.
Chapter I-High-Level Waste Management at the DOE Weapons Complex ● 27

reduce waste management costs. A variety of

technologies are used to treat and dispose of the

‘‘non-high-level’ fractions of what started out as

HLW. Prominent among these are grouting (immobilization in grout or concretes), followed by

near-surface or at-surface disposal.

Finally, some effort is underway at DOE to

consider how waste minimization might be applied

to all aspects of waste management operations.

HLW minimization is discussed later in this section.

Vitrification

Vitrification or, alternatively, classification, as it

is to be carried out at the Defense Waste Processing

Facility (DWPF) at Savannah River, is a process in

which high-level radioactive waste, after removal of

mercury, aluminum, and other selected nonradioactive components, is mixed with ground borosilicate

glass and sent to a melter that operates at 2,100

degrees Fahrenheit (74). The glass-waste mixture is

transformed into molten glassified waste by the

melter, which operates at a rate of 228 pounds per

hour. The molten glassified waste is poured into

stainless steel canisters with 3/8-inch-thick walls, in

which the mass cools and solidifies into a hard

glasslike substance, trapping the radioactive materials inside.

Each of the large Savannah River canisters weighs

l,100 pounds, and is 2 feet in diameter and almost 10

feet high. Each canister holds about 3,700 pounds of

glass, of which approximately 94 pounds will be

HLW; the radioactivity of the waste in an individual

canister will be as high as 234,000 curies, generating

heat at a rate of 700 watts (74). The canisters will be

sealed, welded tight, and stored in a building near the

classification plant pending shipment to a geologic

repository. It is estimated that 6,000 to 8,000 such

canisters will be required to hold existing and

projected waste at Savannah River (74).

In 1983 the decision was made by DOE to adopt

borosilicate glass as the waste form of choice for

solidifying and immobilizing HLW at Savannah

River (46). This decision, along with subsequent

decisions to use the same vitrification process and

waste form at West Valley and Hanford, has been the

basis for major investments in the DOE Nuclear

Weapons Complex. The Defense Waste Processing

Facility has been constructed at Savannah River at

a capital cost of about $930 million57 and is

scheduled to begin operation in FY 1992.

Vitrification with borosilicate glass will be used

in the West Valley Demonstration Project to immobilize HLW from commercial fuel and some Hanford fuel reprocessed at that location 20 years ago;

after a series of delays, this plant should begin

operating in FY 1995 at a cost on the order of one

billion dollars, including decontamination and other

operations (45). In November 1989, a $550 million

contract was awarded by DOE for a third borosilicate glass vitrification facility, the Hanford Waste

Vitrification Plant (HWVP), which is estimated to

cost $1.4 billion when completed and will begin

vitrifying waste around the turn of the century (6).

These plants, if successful, could go a long way

toward eliminating the threat presented by HLW

tank storage. In addition to immobilizing the waste

by locking or “fixing” the radionuclides in a glass

matrix, they substantially reduce the volume of

waste (although not the radioactivity) and, if the

waste package performs as designed, could shift

concern about contamination from the present to

hundreds or thousands of years in the future. Thus,

a great deal depends, both substantively and in terms

of financial investment, on the success of the HLW

vitrification efforts at the Savannah River, West

Valley, and Hanford sites. Furthermore, although

DOE and its critics may disagree about specific

technical decisions or factors, a general consensus is

emerging that the move from liquid to solidified

HLW is a good one.

Concerns about borosilicate glass vitrification fall

into two main categories: 1) those that question the

original decision to use borosilicate glass as the

waste form and 2) those that accept the waste form

decision and focus on improving the process. The

original waste form decision is not discussed here,

but is treated later in considering the choice of waste

form at INEL, the one site that stores HLW as both

liquid and solid (calcine) and has not yet selected a

final waste form for repository disposal.

A long-time observer of the vitrification process

has provided some insight into what might make it

fiDespite &e different terms used at different DOE facilities, this immobilization gen-y involves mixing the waste with cement and letting the

product solidify. Tenms used for the product are “saltstone” at Savannah River, “grout” at Hanford, and “cement” at West Valley.

sTpemo~ comm~cation from DOE to R.P. Morg~ during visit to DWPF, Savannah Riv@ Site, wt. 26, 19X.

292-864 0- 91 - 3
28 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear weapons Complex

work.58 The French developed a vitrification process

20 years ago based on early work in the United

States. Subsequently, the British bought and adapted

the proven French process but the United States

decided to go its own way. Two fundamental

differences between the United States and the

French approaches are: 1) the United States will use

a ceramic melter, whereas the French use a metallic

melter, and 2) the French employ three key steps one

after the other---chemical adjustment to destroy free

acid, calcining to drive off moisture, and incorporation with glass; the United States, however, incorporates all three steps in one operation within the

melter itself. The ceramic melter would appear to

have advantages over the metallic one in terms of

operating temperature and useful lifetime. However,

performing all three operations in the melter offers

a difficult technical challenge; if something were to

go wrong, difficult repair work could lead to

considerable delay compared with the French approach. One specific problem that must be guarded

against is plugging of the melter due to settling of

heavy, noble metals (palladium, platinum, etc.) that

can short out the electrodes.

Concern has been expressed that the waste

processing facility at Savannah River will be operated without sufficient pilot-plant experience, and

arguments have been made for running the plant

initially like a pilot plant, with sufficient instrumentation to fully understand and carefully evaluate the

operation (l). DOE contends it has sufficient experience, particularly with a key piece of equipment—

the melter—to achieve successful operation.59 The

only question still to be resolved, according to the

1989 DOE Research, Development, Demonstration,

Testing, and Evaluation Plan (48), was how to

dispose of the melter, a large piece of equipment that

will operate for only 2 or 3 years and become highly

radioactive. In October 1990 a storage vault was

being constructed for the melter.60

DOE has provided some insight into developmental decisions and work on the DWPF as follows:61

Savannah River built and operated a l/10th-scale

joule-heated radioactive melter in 1977 and a

half-scale melter in 1979. In 1980, a slurry rather

than calcine was chosen as feed material, based on

savings achieved through elimination of the calcine

and significant canyon space reduction. A second

l/10th-scale DWPF melter began operating in 1988

to test the full system. A replica half-scale melter

was built and operated at Savannah River between

1980 and 1983, and a second half-scale melter was

tested with simulated waste from 1986 to 1988.

According to Savannah River Site personnel, the

largest melter that had been demonstrated with

radioactive materials was l/100th scale. Overall

system tests with radioactive materials had been

demonstrated at l/200th scale; these tests established the equivalence of radioactive and nonradioactive processing. Larger- scale radioactive tests

were not pursued because of cost; the smaller-scale

tests fit within existing high-level radioactivity cave

cells. The l/10th-scale Integrated DWPF Melter

System (IDMS) (nonradioactive) was started up in

December 1988. Tests involving mercury removal

began in December 1989, and work on noble metals

started in June 1990; deposition of noble metals has

caused problems in German and Japanese tests but

problems are not expected at DWPF. The IDMS will

be operated during startup of the DWPF to test

system elements and serve as an ‘‘early warning

system’ for possible problems. Some modifications

of the DWPF design were made as a result of IDMS

tests. 62

West Valley has operated a Ml-scale melter at

temperature (but without radioactivity) for 5 years,

producing about 100 canisters of glass logs.63

WVDP officials also state that in one way or another,

they have tested the whole system, including a

l/6th-scale test of the tricky sludge mobilization

step. The West Valley melter is about half the size

of the Savannah River melter. In the last year or two,

increasing exchange of information has occurred

among DOE’s HLW vitrification projects, facilitated by a technical review group and a “glass

producers’ club.”

513A. Scheider, Georgia htitute of Technology, personal communication to R.p. Morgm Mach 19X.

f@pemo~ comm~cation d- hi@-hxel waste briefing, U.S. Department of Energy, Germ~to~ MD, ~tober 1989.

~pe~o~ comm~cation during visit of R.P. Morgan and P.A. Johnson to DWPF at Savannah River Site, October 26, lm.

GIs.P. COWU op. cit., footnotes 11 ~d 46.

62B=ed on conver~atiom ~~ ~E ad we~tingho~se Savd Wver personnel d-g visit to DWF, Savm River Site, by R.P. Morgan ~d

P.A. JOhnSOW Oct. 26, 1989.

63Pemo~ com~cation dtig trip to West Valley Site, Feb. 21, 1990.
Chapter 1--High-Level Waste Management at the DOE Weapons Complex . 29

Figure 1-8-Storage Capacity for DWPF Glass Canisters

10/23/10

-t

7500

buildings

s

k

4

2500

e

z

2286

1 Ref

building

1

radioactivity in

canisters

5172

Feed equal

to waste

1/1/08

4595 ‘r”du’t’onl

6/1/97

2187 dA/L

Empty old

tanks 1 #///// ~ —————

Total canisters 12/31/20

produced 5747

—-

~_ ---

- v -----

4/r

00 Canisters/Yr

————————

9128114

1990 2000 2010 2020

Yea r

SOURCE: U.S. Department of Energy, April 11, 1990.

Vitrification plants are large facilities and will assumptions about an opening date for a deep

handle very large amounts of radioactivity. Some of

the operations will involve transferring molten

liquids, transporting slurries of radioactive waste,

and mixing waste with glass. Some equipment will

become highly contaminated, with radioactivity.

Equipment breakdown could occur. Given the nature of the facility, the health and safety of workers

involved in plant operations-both routine operation or maintenance and unanticipated shutdowns or

emergency procedures-must be protected. According to DOE, all major operations will be performed

by remote control, and if equipment breaks down, it

will be repaired in place with mechanical arms or

removed and replaced with an overhead crane.

Thorough equipment testing; reinforced concrete

walls separating the process, maintenance, and

control areas to provide radiation shielding; and

personnel training during 2 years of simulated

(nonradioactive) operation are some of the elements

being employed to ensure worker safety and protection from radiation (74).

Requirements for interim storage of glass canisters at Savannah River have been based on certain

geologic repository (see figure 1-8). Figure 1-8 was

prepared in April 1989; as of March 1990, some

changes had been reported by DOE.64 The start date

had been delayed from January 31 to June 30, 1992;

production rates had been reduced from 800 to 400

canisters per year from 2012 through 2020. Furthermore, shipments to a Federal repository are now not

anticipated by DOE and NRC to begin before 2010.

Therefore, HLW storage capacity may need to be

expanded beyond that currently planned. The one

existing Savannah River storage building cost $55

million in 1983 dollars.65 66

If and when vitrified waste is placed in a deep

geological repository, the waste form and canister

offer lines of defense against radionuclides escaping

into the environment. The resistance of the waste

form to leaching and the ability of the canister to

withstand infiltration or penetration over long periods of time (10,000 years or more) are important

considerations. The Swedish approach to disposal

gives more weight to the engineered barrier (i.e., the

canister or overpack container) than the U.S. approach; the much thicker Swedish canister is de64s.P. COW- op. cit., footnote 11.

‘sIbid.

66At West Vwey, glass logs will be stored in a decon~“ ted cell area of the old plant. Source: Personal Communication during trip to West Valley

site, Feb. 21, 1990.
30 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

signed to last 1 million years or longer, compared

with several hundred to 1,000 years for the U.S.

canister. The United States could also consider

increasing the design lifetime required for the

canisters or overpack containers. Currently, no

standards are in place for long-term disposal of

HLW since previous Environmental Protection Agency

(EPA) standards were remanded by a court in part

due to concern that disposal standards for HLW were

not consistent with more restrictive drinkin“ g water

standards. Further, a recent National Academy of

Sciences report questions whether HLW disposal

standards can be met with the current approach.67

If canisters or overpack containers with a longer

design lifetime prove to be an attractive option, one

question is when they should be redone. At this time,

it is not clear whether canister designs for one or

more of the three planned vitrification facilities can

be changed, without considerable effort and cost.68

Certain approaches could be studied, however, such

as keeping the existing canisters but redesigning the

overpack containers to provide greater assurance of

long-term isolation of waste via engineered barriers.

Finally, the management structure for the vitrification activity could be questioned. One major

corporation, Westinghouse, with its associated companies, is the contractor for work at all four HLW

vitrification sites. This should facilitate communication and result in the experience gained at one

facility being readily available to the others; in fact,

cost projections for the Hanford Waste Vitrification

Facility (HWVF) assume savings based on utilizing

experience gained at Savannah River. However, this

also means that one company has a monopoly on the

technology and might be less willing to innovate and

less receptive to learning about advances in vitrification technology outside the United States.

Calcination

Calcination of HLW has occurred at the Idaho

National Engineering Laboratory periodically for

over 25 years. This is a process in which liquid waste

solutions are sprayed as a fine mist into a vessel

containing heated granules about the size of coarse

sand. The granules and waste solution are brought in

contact with air that flows through and circulates the

material in the vessel, an operation known as

fluidization. In the hot fluidized bed, heat evaporates

water and deposits dissolved aluminum and fission

product nitrates as coatings on the granules. Small

fragments chip off from the granules during agitation as particle size increases. Some fragments are

carried aloft where they enter an off-gas cleanup

system consisting of scrubbers, silica gel absorbers,

and falters. Other fragments remain in the vessel to

nucleate new granules. The solid, nonfragmented

granules, or “calcine”—a dry, white, powdery

substance that contains most of the radioactive

material-is blown by air through a shielded underground tube to be stored in stainless steel bins inside

reinforced concrete vaults (73).

Calcination began in the Waste Calcining Facility

(WCF) in December 1963, following developmental

work at two pilot plants in the 1950s; the WCF

operated intermittently until March 1981, calcining

approximately 3.9 million gallons of radioactive

liquid waste. In October 1982 the New Waste

Calcining Facility (NWCF) began operating; this

facility, built at a cost of $92 million, can handle

3,000 gallons of waste per day. It has calcined at

least 2 million gallons of HLW since it began

operation (73). In December 1989 the NWCF, which

had not operated since October 1988, was placed on

a longer “temporary standby’ condition, pending a

review of ways to bring single-wall piping from

some older storage tanks into compliance with

Resource Conservation and Recovery Act (RCRA)

standards (35). Calcination was not expected to

resume at INEL until late 1990.

Calcination might be considered an intermediate

step between liquid HLW and vitrified waste. The

solid form of the calcine renders it less prone to tank

leaks than liquid waste; furthermore, the volume of

calcine, one-eighth that of the liquid, requires less

storage space. The design lifetime of stainless steel

storage bins for the calcine, 400 to 500 years, is

perhaps an order of magnitude longer than that of the

liquid HLW storage tanks, but perhaps two orders of

magnitude shorter than required for a repository. All

of the factors that caused INEL to pursue calcination, whereas Hanford, Savannah River, and West

Valley chose vitrification, are not clear, but different

bv’’ReWngfigh-Level Radioactive Waste Disposal: A Position Statement by the Board on Radioactive Waste Management’ Natiomd Resmch

council, 1990.

@Although an@to&r 1989 prti~isional draft of the DOE Research, Development Demonstration Testing, and Evaluation (RDDT&E) plan

included a discussion of the advantages of increased waste loading and canister redesign (50), the November 1989 DOE RDDT&E Plan (48) omitted

these matters.
Chapter l-High-Level Waste Management at the DOE Weapons Complex ● 31

organizations may simply have developed their own

approaches.69

Given the seemingly modest cost and the proven

nature of calcining compared with vitrification,

what—if any—are its liabilities? First, gases from

the calcining step must be cleaned up to meet EPA

standards before release. Second, the powdery

nature of the calcine could result in airborne

dissemination if it is not handled properly or if

storage bins are breached. In response to an inquiry

about storage of calcine, DOE stated, ‘‘We know of

no technical problems at this time to preclude

long-term storage of calcine in the bins, based on

their design and on measured corrosion coupon

results. Observed corrosion rates support the design

lifetime of 500 years. However, the calcine is a

radioactive hazardous mixed waste whose long-term

storage may not meet regulatory requirements such

as the Land Disposal Restrictions (LDR). ’70 If DOE

will be producing more HLW in the future, more

attention should be given to the relative merits of the

calcination process compared with tank storage

followed by vitrification.

Alternative Waste Forms for the Idaho

National Engineering Laboratory

Final choice of the longer-term solid form for

HLW at INEL has not yet been made (49). Figure 1-9

shows some of the alternatives being considered in

October 1989. Among these are the use of a

glass-ceramic material for the matrix of the waste

form in which the radioactive calcine would be

embedded; that should permit higher radioactive

waste loading (i.e., immobilization of a larger

amount of radioactive material per canister) than

borosilicate glass. The cost for disposal of one

canister in a repository is cited by DOE as $350,000

(49). During a visit to INEL in July 1989, the

following information was obtained: INEL anticipates a large increase in the fuel processing rate,

resulting in a large HLW volume. If borosilicate

glass vitrification is used to immobilize the calcine,

production of 38,800 canisters is projected by the

year 2020, corresponding to a disposal cost of $14

billion. However, if a glass-ceramic matrix being

developed is used, an increase in the radioactive

material loading will reduce the number of canisters

by 2020 to 16,300, at a disposal cost of $6 billion.

That cost might be lowered to $4 billion by changing

the geometry of the canisters. INEL anticipates that

the durability of the glass-ceramic will be similar to

that of glass.71 72

At present, given the economic incentive, most

research and development on the long-term form for

INEL HLW seems to be devoted to glass-ceramic.

However, one alternative is not immobilizing the

calcine in a glass-ceramic matrix but hardening it in

storage bins, that is, using the hardened calcine itself

within an engineered barrier as the final waste form.

Such an alternative might not prove attractive for

repository disposal, given the large volume of

calcine, but if delays in opening the repository

become lengthy, necessitating a de facto shift to

on-site, monitored retrievable storage, or if problems

arise in vitrification efforts, bin hardening of the

calcine might well be worth a harder look. A March

1990 DOE communication considers bin hardening

a ‘‘subordinate alternative for long-term storage of

calcine. . . . Based on current calcine leach data and

the fact that the Snake River aquifer is located below

the INEL, the bin hardening option is not feasible.

Bin hardening will be addressed as the No Disposal

Action option in an EIS (Environmental Impact

Statement) for the immobilization project.”73 A

decision on a reference strategy and form for Idaho

Chemical Processing Plant HLW is currently

planned for FY 1993-94.74

69Evidenfly, INEL fiels rq~ lmge ~omts of chem.ic~s, including hydrofluoric acid @F) to get them to dissolve. A subs~~ ~o~t of

aluminum is required to protect the tanks from HF. Thus, in hindsight it could be argued that calcination might best have been employed at Hanford

or Savannah Riveron acid liquid waste stored in stainless steel tanks, thus elimina ting the diffkmlties in dealing with neutralized waste sludge and slurry;

instead it was used on the more dilute waste at INJ3L (Source: A.G. Croff, Oak Ridge National Laboratory, personrd communication to R.P. Morg~

June 28, 1990.). Such an approach was seriously considered in the late 1950s at Hanford. Idaho (and also the French and British) had the proper foresight

not to neutralize the HLW and store it in acidic form in stainless steel tanks, thus greatly simplifying the subsequent selection of a solidification process.

By contrast, the neutralized HLW at the three other U.S. sites cannot be calcined without complicated pretreatment processes.

70S.p. COW- op. cit., footnote 11.

71’IM.s S@temen$ Of co~se, will n-d to be vefiled, probably by means of an extensive test program similar to that done VVith borosilicate glms ovm

the past decade. Glass-ceramic and other cemmic materials had their supportem at the time the decision was made to use borosilicateglass for vitrification

at Savannah River. A synthetic rocklike material called Synroc, also received attention about a decade ago.

72J. solec~, op. cit., footnote 12.

73S.P. COW~ op. cit.,footnote 11.

74J. Solecfi, op. cit., fOOt.IIOte 12.
32 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

Figure 1-9—Alternative Long-Term High-Level Waste Management

Strategies for the ICPP

Process Option s

Alternative

Strategies Waste Immobilization Shipment Disposal

Process

1. Dispose of waste

HM

..,’.: .:,’. ’’.’, ‘.. . ~,

in a geologic . . . ... .. . . . ,.,.

repository Calcine and Volume reduction

liquid waste ~

and glass / ceramic

L& e

!J?;:o::::;:::e MM ~~

Rti

or

facility Calcine and Calcination and

liquid waste bin hardening

or glass / ceramic Near surface

M

,;.

3. Dispose of annually

generated waste in a Annually generated Volume reduction geologic repository liquid waste ~

and glass / ceramic and dispose of

` L b e

Repository

existing calcine in a

near surface

H

,., , .,..

facility ..,,..,...:,. ..,., ,

Existing calcine

Bin hardening

Near surface

SOURCE: U.S. Department of Energy briefing, October 1989.

Technologies for Pretreatment of

High-Level Waste

At the three sites gearing up to vitrify HLW,

Savannah River, Hanford, and West Valley, the

HLW streams coming from the reprocessing plants

are subjected to one or more steps before vitrification, which OTA has referred to as pretreatment.

Two objectives of pretreatment are to reduce the

volume of liquid that must be stored in tanks and to

remove that portion of the streams that can be

disposed of as other than vitrified HLW. Both these

actions are driven in part by economic incentives; in

their absence, the cost of waste management would

increase because of the need for additional storage

tanks and because of the high cost of vitrification

relative to cemented waste forms disposed of near

the surface.

Figure 1-10 illustrates treatment methods for

HLW in tanks and canisters at Savannah River. Note

that evaporation is an important element in the

system, reducing the volume of liquid in the tanks.

According to a 1988 document, without evaporation, 69 additional waste tanks valued at more than

$33 million each would have been required (65).

Prior to 1989, some water from the evaporator, not

totally free of radioactivity, was discharged to

seepage basins; in 1989, OTA staff observed operation of the new effluent treatment facility, which

uses filtration, reverse osmosis, and ion exchange to

clean up evaporator discharge (66).

Two main operations emerge after a series of

pretreatment steps, as illustrated on the right-hand

side of figure 1-10. One is the vitrification operation

itself. The other involves mixing a decontaminated

salt solution from the waste streams with cement to

form a substance called “saltstone,” which will be

disposed of in above-grade vaults. Making the

saltstone is essentially a grouting or cementing

operation of the kind used or planned for the disposal

of some low-level waste (LLW). An approach that is

similar overall but has some different steps to

separate low-level streams is planned for Hanford

HLW.

Various chemical operations plus radioactive

decay with the passage of time are utilized to achieve

low levels of radioactivity in the solution to be

mixed with cement; some 99.9 percent of the aged

waste supernatant will reportedly be removed (67).

Among factors of interest to appropriate regulatory

agencies are the amount and nature of the remaining
Chapter 1--High-Level Waste Management at the DOE Weapons Complex ● 33

Figure I-l O-Treatment Methods for High-Level Waste

in Tanks and Canisters at Savannah River

t a 1- — --—-— -h

Ti!il :

LIQUID SLURRY

WATER

45 LUDG>

I

I

I

I

I

I

I

I

I

I

r

---—.

. DISPOSE OF

I!i!Fi3DISSOLVED coN:y-j--:J--:N~N~ rSALT CAKE—

LIQUID I

II I I

SALT CAKE 1-L – J .Dl:::~v:Aj:~J[:M7 ‘

r DEFENSE WASTE

-— ---- -

I I ,1 I PROCESSING FACILITY

—DISSOLVENT~ [

I

WATER

I_

‘

- ““”’D--’m--Isti+-

—SLURRIED 

SLUDGE

I~

– —GLASS FRIT- — — — — - i

.—— 1

I

WASTE

CANISTERS

r

---- + -

DISPOSE OF IN

I HLW GEOLOGIC

~ REPOSITORY

~ PRESENT OPERATIONS

- — — + ADDED FUTURE OPERATIONS

SOURCE: U.S. Department of Energy, “Integrated Data Base for 1989,” DOE-EW4008, November 1989.

radioactivity, and the mixed (i.e., hazardous plus

radioactive) nature of the saltstone. The amount of

saltstone to be produced at Savannah River is very

large, about 3 million tons over 28 years; long-lived

isotopes include 60,000 curies of technetium-99

(14). DOE reports that the saltstone facility started

operating in the summer of 1990, all necessary

permits having been granted by EPA and the State of

South Carolina.75 76 Furthermore, saltstone has evidently been ruled a nonhazardous waste form;77 that

is, in contrast to Hanford grout (see below), it is not

considered a mixed waste. According to Savannah

River officials, the saltstone contains much lower

concentrations of organic material compared with

the Hanford grout. This may account for the

markedly different regulatory treatment.

The saltstone developmental process has not been

without problems. In late 1987 it became evident

that the organic chemicals used to decontaminate the

salt solution created a flammability hazard; furthermore, the amount of benzene in the decontaminated

filtrate sent to the saltstone facility did not meet new

environmental standards. Modifications were made

that should be in place (68). Further insight into the

complex number of steps required prior to and in

parallel with vitrification is given in the Savannah

River Waste Management Operations Program Plan

of 1988 (69).

The saltstone facility at Savannah River began

operation in June 1990. As of that date, the only

radioactive materials that had been immobilized and

placed in the saltstone facility were streams from the

75P. Washer, U.S. Department of Energy, personal communication to R.P. Morgaq J~Y 18, 1~.

76s.P. Coww op. cit., footnote 11.

TTIbid.
34 ● ivedfigaq: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

Effluent Treatment Facility and some wastes from

tests of the in-tank precipitation (ITP) process that

were carried out in 1983 and 1984. It will take about

one year to fill one vault of the saltstone facility once

operation of the pretreatment operations begins on

the HLW tank wastes.

One key technical step that is new and has been

the cause of some problems is precipitate hydrolysis,

to be carried out within specially designated waste

tanks, and referred to as ITP. The purpose of this

process is primarily to remove radioactive cesium

from the waste stream that will be sent to the

saltstone facility. As of October 1990, Savannah

River personnel were hopeful that radioactive operations of ITP would begin in April 1991; this would

signal the start of pretreatment of HLW tank waste

and immobilization of a non-high-level component

in the saltstone facility.

The precipitate hydrolysis process at Savannah

River involves the use of benzene, which emerges as

a radioactive mixed waste. Plans call for building an

incinerator to burn the benzene; until this occurs, it

will be necessary to store the benzene in tanks.78

At other DOE HLW sites, there are some parallels

to, and differences from, what is planned for

Savannah River. At Hanford, the double-shell tank

wastes are complex mixtures from a variety of

operations, including a plutonium finishing plant

(62). In 1990, Hanford began producing grout in the

facility to be used in connection with the vitrification

plant. The grout for the first run was “low-level”

waste that was not ‘‘mixed’ in nature. The grout

facility is designed for mixing 1 million gallons of

liquid with cement and producing 1.4 million

gallons of grout;79 the conversion actually increases

waste volume. Like Savannah River, Hanford has

been concerned about obtaining the necessary permits for grouting a portion of what started out as

HLW. It has also shut down a key evaporator

because of the presence of hazardous wastes in

process condensates and the disposal of hazardous

wastes directly in cribs, which violated either EPA

or Washington State Department of Ecology regulations. 80 Mixed-waste regulatory issues are being

addressed through the process of obtaining a RCRA

Part B permit from the State of Washington Department of Ecology .81

At West Valley, processing of high-level alkaline

liquid waste began in May 1988 to remove cesium137 from the supernatant by ion exchange so that

some of the waste can be treated as low-level waste

(62). As of February 1990, more than 99.9 percent of

the cesium-137 had been removed from more than

half of the liquid in the larger of the two West Valley

waste tanks; the liquid with the cesium removed had

then been mixed with portland cement and stored on

site in specially designed, easily stackable 7 l-gallon

square drums in a storage building about 200 yards

from a public road.82 The cesium is captured by

inorganic ion exchange on zeolite, which is stored

for subsequent vitrification. Thus, West Valley leads

other sites in the pretreatment of waste destined for

vitrification by grouting a low-level fraction. The

regulatory basis cited by DOE for this pretreatment

is the West Valley Demonstration Act of 1980; the

NRC is accorded special status in this act because of

the commercial origin of the fuel that was processed

into HLW. NRC does not have such a role in

weapons sites such as Hanford and Savannah River.

At West Valley, DOE sought and obtained NRC

approval for the immobilized waste form from the

pretreatment process.

The West Valley Demonstration Project was sued

by citizens groups when it attempted to convert the

building containing the drums with grouted waste

into a permanent disposal facility. According to

DOE, that building is the only “certified Class-C

(low-level waste) cement farm in the country.”83

From the DOE-WVDP point of view, radiation at

drum surfaces was lower than anticipated because of

better than anticipated cesium removal. Nevertheless, in an out-of-court settlement, DOE and WVDP

agreed to study the matter and use the National

Environmental Policy Act84 (NEPA) process to

decide upon disposal by preparing an Environmental

Impact Statement (EIS) not only for the drum

building but also for the entire West Valley site. In

78pemo~ communication during trip to Savannah River Site, Oct. 26, 1990.

Wpemoti com~cation during visit to Hanford, November 1990.

mview~ph ob~ed during visit to Hanford, November 1989.

81s.P. COWq op. cit., footnote 11.

gzpemo~ com~cation during trip to West Valley site, Feb. 21, 1990.

8%id.

~pub. L. No. 91-190, 83 Smt. 852 (197o) (codified as amended at 42 U. S.C.A. $$4321-47) (West 1983 and supp. 1990).
Chapter 1--High-Level Waste Management at the DOE Weapons Complex ● 35

the meantime, on-site disposal is precluded; presumably, temporary storage is not. The EIS process

should provide a forum for those concerned about

above-ground storage of Class C low-level waste

(38). Issues that might be scrutinized include the

presence of technetium-99, a very long-lived, somewhat mobile, radionuclide in the grout at levels of 30

nanocuries per gram85; the integrity of the grout; and

its ability to contain radionuclides over time.

At INEL, examination of a simplified flow sheet

depicting HLW treatment indicates that to date, acid

HLW flows directly to the calciner without pretreatment (60). An elaborate off-gas treatment system

operates to control the radioactivity of effluent from

the calciner. In planning further treatment of the

calcine, consideration is being given to removing

‘‘inerts’ (nonradioactive materials) from the calcine

prior to immobilization (48). The efficiency, environmental impact, and regulatory requirements of

this separation must all be considered; such a

separation would appear to be somewhat analogous

to HLW-LLW pretreatment separations being implemented at other sites.

Waste Minimization

Waste minimization is receiving increased attention at DOE. The charter of DOE’s Waste Reduction

Steering Committee defines waste minimization as

‘‘any action that minimizes the volume or toxicity of

waste by: 1) avoiding its generation, or 2) recycling” (60). Given this definition, if defense HLW

alone is considered, minimization is intimately

involved with production levels and methods for

producing plutonium and tritium.

Several scenarios might be considered. If no more

plutonium or tritium is produced, no more HLW will

be generated.86 If one or more of the Savannah River

reactors is restarted to produce plutonium or tritium,

the radioactivity generated should probably be

compared with the radioactivity that would be

created if the same amount of material were produced in a new reactor designed to maximize the

ratio of plutonium or tritium production to that of

fission. If only tritium is produced in a reactor, DOE

might consider whether a higher ratio can be

achieved by producing only tritium.

Although an examination of reactor technologies

could indicate possible HLW minimization, the

savings are unlikely to be significant. Major reductions in HLW generation for this case appear to be

possible only through reduction in plutonium and

tritium production in nuclear reactors, production of

tritium by a radically different method such as a

linear accelerator, or substitution of uranium-235 for

plutonium.87 This conclusion arises because HLW is

an inevitable outcome of producing weapons fuel in

a nuclear fission reactor.

However, for the second case in which spent fuel

is not included within the definition of HLW, then

one way of minimizing HLW generation is to

reprocess only the lithium targets used to produce

tritium and not to reprocess either the driver fuel

elements or the depleted uranium targets used for

plutonium production. According to this definition,

processing to recover plutonium produces HLW

whereas processing to recover tritium does not. An

argument for proceeding in this manner is that the

material more likely to be in short supply, namely

tritium, could be produced in this manner without

creating additional liquid HLW tank waste that must

be dealt with. Furthermore, it might be argued that

although both HLW and spent fuel will eventually

be disposed of in deep geologic repositories, spent

fuel is more cheaply, easily and safely treated and/or

stored than HLW on an interim basis. On the other

hand, the cost of running reactors fueled with

enriched uranium for tritium production might

increase if the fuel elements were not reprocessed.

Furthermore, whether or not the spent fuel is

reprocessed, the radioactivity to be dealt with will be

the same.

At the next step in production-reprocessing—

certain advantages may be derived from the use,

reuse, and handling of hazardous materials because

it could possibly make the waste management

system simpler. Despite modernization of certain

components and subsystems, most reprocessing

plants and technology in the United States are 30 to

40 years old. New approaches that build on experience in other fields and possibly outside the United

States, where commercial reprocessing activity has

been pursued that utilizes smaller and more modern

equipment, might well be possible.

sspC~O~ ~o~~cation (luring trip to West Valley Site, Feb. 21, 1~.

86~s i~ores tie fact that mw could sw be produ~d from spent fuel that has not k reprocessed at C* ~E sits.

87~s *-= tit ~afim.zss is ob~~ by a pr~ess ~ch ~ g~eous ~sion or cen&gation tit do= not involve its recovery frOIIl SptXlt

fuel in a nuclear reactor.
36 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

Any efforts that minimize the generation of HLW

have intrinsic merit because of the threat posed by

the intense radioactivity associated with it. Moreover, because HLW and spent fuel are at the top of

a pyramid that broadens to include other waste types

(i.e., low-level, mixed, and transuranic), decreasing

HLW generation will also reduce the problems

created by waste in these other categories.88

REGULATORY FRAMEWORK

Introduction

Historically, the regulatory framework and standards for high-level waste (HLW) at Department of

Energy (DOE) weapons sites have long been the

province of DOE and its predecessor agencies under

the Atomic Energy Act.89 The primary vehicle for

specifying the definition, handling, and treatment of

defense HLW has been by DOE order, in which the

Secretary of Energy has the final authority. However, the Nuclear Regulatory Commission (NRC)

becomes a factor in establishing licensing criteria for

disposal of defense HLW. According to current

plans, vitrified HLW is to be placed in the same deep

repository as spent fuel from commercial reactors;

criteria for the repository and for the waste forms to

be placed therein are governed by the NRC.90

Environmental standards for repository disposal of

HLW are the responsibility of the Environmental

Protection Agency (EPA). Furthermore, EPA’s role

in radiation protection standard setting has been

growing and affects DOE’s HLW management

activities. EPA is the lead agency in a Federal

interagency committee to prepare Federal guidance

on radiation protection of the public. EPA is also

primarily responsible for setting environmental radiation standards for specific practices or sources,

although criteria developed by NRC for the commercial sector or DOE for the defense sector can apply

if they are more stringent than EPA standards (23).

EPA regulates waste management practices at

DOE weapons sites through its jurisdiction over

hazardous wastes and the application of the Resource Conservation and Recovery Act (RCRA) and

the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Its role in

regulating hazardous waste and the hazardous components of mixed waste is broadly based. It is mainly

with regard to hazardous materials that regulatory

pressure and actions are being brought to bear on

DOE. Two examples at Hanford are: 1) shutdown of

the 242-A evaporator in April 1989 because process

condensates contained hazardous ‘‘listed wastes’ ’91

(e.g., acetone) and 2) prolongation of the shutdown

of the Plutonium Production and Extraction (PUREX)

reprocessing plant, beginning in December 1988, in

part because acetone and other listed wastes were

being used and discarded. The latter two actions are

in response to RCRA, which governs ongoing waste

management operations.

Strictly speaking, all HLW is mixed waste; that is,

it has both hazardous and radioactive components. It

might be argued that because the health threat

represented by the radioactivity of HLW far outweighs the health threat associated with the hazardous component of that waste, any actions that DOE

takes to provide adequate protection against radioactivity would provide more than adequate protection

against the hazardous component. However, this

argument does not appear to be accepted in the

regulatory sense, nor need it prove correct in all

situations having to do with storage, treatment,

transport, and disposal of HLW.

State agencies have also become factors in

regulation through interagency agreements. For

example, at Hanford, the Federal Facility Agreement

and Consent Order, the so-called tri-party agreement, entered into in May 1989 by the Washington

State Department of Ecology, EPA, and DOE,

governs the Hanford cleanup (71). In the Hanford

tri-party agreement, milestones are set forth for

vitrification of HLW from double-shell tanks, and a

more expanded schedule involves further study

before any action is taken for single-shell tanks. A

1989 report sets forth the very complex set of

gg~s discussion of HLW minimhtion focuses on radioactivity, the overwhelming contributor to its toxicity. Ofie~ analyses of waste minimimtion

concentrate on reducing the volume of the waste; accordingly, the volume reductiom achieved by vitr@ing or calcining a given amount of HLW might

have been compared. However, reducing the volume after the waste has been generated does not fit the concept of waste minimkation as defined by

the DOE Waste Mhimiza tion Steering Committee; nor, in the case of HLW, does it really get to the heart of the problem. Volume reduction

considerations are relevant to pollution prevention and cost savings, and appear throughout DOE planning and this report.

S91n 197o, tie fiit re~tov deffition of high-level waste was developed by the U.S. Atomic Energy Commission in 10 CFR Pm 50, WP. F.

%s authority is vested in the NRC by the Nuclear W~te Policy Act (NWPA) [Pub. L. 91-190, 96 Stat. 2201 (1983) (codified) at 42 U.S.C.

$$10101-10226] and also applies to the case where defense HLW is not comingled with spent fuel but placed in a separate repository.

91’ ‘List~ wmtes” me Substances that have been placed on the RCRA-based list of hazardous materials and aft? thus subject to EPA retition. ~

this repo~ the term “hazardous” is used in this sense; in other words, radioactivity, although a hazar~ is not “hamrdous.”
Chapter 1--High-Level Waste Management at the DOE Weapons Complex .37

regulations that might govern the treatment of

single-shell tanks and tank wastes (22).

Definition of High-Level Waste

The definition of high-level waste contained in

both the DOE 1989 Five-Year Plan (55) and the draft

DOE Order No. 5820.2A (63) is as follows:

. . . the highly radioactive waste material that results

from the reprocessing of spent nuclear fuel, including liquid waste produced directly in reprocessing

and any solid waste derived from the liquid, that

contains a combination of transuranic waste and

fission products in concentrations requiring permanent isolation.

The last five words of this definition introduce the

idea of a definition based on the concentration of

radionuclides in the waste and not solely on the

source of the waste, namely, liquid waste produced

directly in reprocessing. In recent years, the issue of

a source-based v. a concentration-based definition

has arisen because strict application of the former

would require the treatment and disposal of much

larger amounts of liquid HLW currently stored in

tanks, thus greatly increasing overall costs. If some

waste of lower radioactivity could be separated and

treated as low-level waste, costs would decrease not

only because of reduced disposal costs but also

because of more effective use of existing HLW tank

storage space. On the other hand, if such a redefinition is not allowed and a strict interpretation of the

existing source-based definition promulgated by the

NRC and listed in the Code of Federal Regulations

is adhered to,92 DOE’s cleanup plans could be

affected very substantially. Presumably, the definition is based not only upon cost considerations but

also upon consideration of health effects and potential health risks.

The issue is particularly relevant to the waste at

Hanford and Savannah River. Both of these facilities

expect to reduce the amount of HLW by separating

a large “low-level” waste component from the

reprocessing streams prior to vitrification. At Savannah River, this involves separation of a salt solution

that has been decontaminated of at least 99.9 percent

of its radioactivity; the salt solution will then be

mixed with cement to form saltstone and disposed of

on-site in above-grade vaults (see figure 1-10). At

Hanford, HLW is to be pretreated by a series of steps

that will separate “low-level” liquid streams to be

grouted and then disposed of on-site in near-surface

vaults. The specific technical steps differ, but the net

result is the same. Figure 1-11 illustrates the reason

for interest in this approach: the cost of HLW

treatment and disposal by vitrification is about two

orders of magnitude greater than the cost of LLW

treatment and disposal.

In November 1989, the NRC gave tentative

approval to a DOE plan to grout and then pump into

concrete vaults some of the high-level tank waste at

Hanford. According to a State of Washington

estimate, “As much as 10 percent of Hanford’s

HLW could be put in low-level vaults because

technical difficulties prevent the separation of all the

high-level material from less radioactive components . . .’ (3). Officials of the State of Washington

called for an independent assessment of that decision. However, a DOE spokesman said that DOE has

a reasonable, cost-effective plan for dealing with the

waste (3).

These conflicting views can be interpreted in the

context of how HLW is defined and who has

regulatory authority over it. NRC is involved

because of its responsibility for the HLW repository.

Evidently DOE argued, and NRC concurred, that the

material to be grouted, regardless of its source, had

concentrations that resemble low-level waste and

should be governed as “incidental waste” under a

rule from the 1970s.93

The HLW definitional issue, as perceived by

environmental groups, arose in what they viewed as

a DOE effort to redefine Hanford single-shell tank

waste so that it could be left in the tanks as a

cost-saving but potentially dangerous means of

disposal.94

The source-based definition of HLW still appears

to be the official one, and the NRC interpretation

does not appear to permit redefinition of the Hanford

single-shell tank waste. However, it does appear to

~Code of Fede~ Regulations. 10 CFR O.735-I, Title 10, Energy, Chapter I, Nuclear Regulatory Commissio% Part 60, Subpti A P. 542.

Sspersoml Comuication during visit to Hanford, Nov~bm 1989.

Wwhat DOE may have had in fid is @eating single-she~ tank waste in situ, that is, at the site by vltilcation or some Other means. h Situ treatment

is believed by some to have two major advantages over removal and tmatrnent: namely, it should be considerably less costly and should pose less of

a health risk to workers. Whereas this maybe an appealing alternative technically, the political difilculties associated with it are significant.
38 ● Long-Lived Legacy: Managing High Level and Transuranic Waste at the DOE Nuclear Weapons Complex

Figure 1-1 l—Economics of Pretreating Hanford Waste

Why Bother With Pretreating Waste ?

1 liter

150 grams

of

waste

oxides

Glass $250

Yes

No

Grout $3

SOURCE: U.S. Department of Energy, Hanford Plant, November 1989.

Wow redefinition of a portion of Hanford HLW for

disposal as low-level waste by grouting.95

The grouting of a “low-level” fraction of highlevel tank waste is currently underway. As of

mid- 1990, more than half of the low-level fraction at

West Valley had been grouted. The Savannah River

saltstone operation has begun operating with waste

from the effluent treatment facility. The low-level

fraction of Savannah River tank waste is expected to

be treated at the saltstone facility starting in rnid1991. Hanford is also proceeding to get necessary

approval, in accordance with the tri-party agreement, to grout portions of tank waste. Thus the

definitional issue may be of only academic interest.

It could resurface, however, if questions arise about

disposal of the grouted “Class C low-level waste”

resulting from the current approach, which appears

to be happening at West Valley.

At West Valley DOE moved vigorously forward

with a program of pretreating the HLW to reduce the

HLW disposal burden. There was at least one

attempt in the mid- 1980s to redefine the various

waste categories (2). That effort did not succeed

however and pretreatment is now being carried out

as planned.

In December 1990, the States of Washington and

Oregon petitioned the NRC to initiate rulemaking to

redefine HLW as follows:96

HLW means: (1) Irradiated reactor fuel, (2)

Liquid wastes resulting from the operation of the

first cycle solvent extraction system, or equivalent,

and the concentrated wastes from subsequent extraction cycles, or equivalent, in a facility for reprocessing irradiated reactor fuel, and (3) Solids into which

such liquid wastes have been converted; provided

that if, prior to disposal, defense reprocessing tank

wastes are treated to remove the largest technically

achievable amount of radioactivity on a tank-by-tank

basis ..., the treated residual fraction shall be

considered an incidental waste and therefore not

HLW.

The States apparently took this action because

they feared that wastes in the Hanford tanks could be

designated as low-level waste and disposed of in a

facility conforming to EPA requirements but unlicensed by the NRC.97

95~e ~ue.tion fi@t ~ ~~Sed ~ t. ~~t aufiofi~ NRC ~S over ~s ~tter. mere appears to be no explicit autiority as in the Cue Of West Vdey.

96Fede~ Register, vol. 55, No. 242, Dec. 17, 1990.

~weapons complex Monitor, Dec. 31, 1990, p. 3.
Chapter 1--High-Level Waste Management at the DOE Weapons Complex ● 39

Regulations Affecting Single-Shell Tanks

Regulatory requirements important to waste management decisions for the Hanford single-shell tanks

are summarized in a Pacific Northwest Laboratory

report (22). The number of regulations and regulatory bodies that will govern tank cleanup is large,

and the process is complex (see figure 1-12 and table

1-2). Uncertainties and conflicts could very well

arise, some of which may be resolved as tank

contents are better characterized. Many issues have

not yet been resolved, involving waste definitions,

mixed-waste disposal, and groundwater protection

requirements. 98 RCRA may not provide sufficient

quantitative criteria to assess the performance of

proposed disposal systems, and variances from some

applicable RCRA regulations for tank storage systems may be needed to remain in compliance. Some

emphasis is needed to determine quantitative criteria, other than those in RCRA, that can be used for

guidance in areas such as groundwater protection

(22). Attention should be paid to regulatory requirements as the waste characterization process continues.

Taking core samples from tanks to characterize

the waste and analyzing these samples can expose

workers to radiation that exceeds ALARA (as low as

reasonably achievable) limits. Modifications have

been proposed to the EPA guidelines for testing

methods to be used in the evaluation of solid

hazardous waste (21). These modifications specifically focused on sampling and analysis procedures

for the highly radioactive single-shell tank waste. In

early 1990, EPA did propose to amend testing and

monitoring regulations for hazardous wastes under

Subtitle C of RCRA.99

Regulations Affecting Restart of PUREX

The regulations external to DOE that affect restart

of the PUREX plant are concerned mainly with

hazardous wastes. First, a major waste management

evaporator at Hanford, the A-242 evaporator, was

placed on temporary standby because hazardous

waste was being disposed of in cribs and because

process condensates contained hazardous waste, as

defined by the State of Washington Department of

Ecology regulations. DOE and WestinghouseHanford believe that restart of the evaporator is

essential in reducing the volume of liquid waste to

be accommodated in double-shell tanks so that new

waste from the PUREX restart can be pumped to

those tanks.

The PUREX plant itself is shut down for a variety

of reasons. The initiating event in December 1988

was a‘ ‘limiting condition of operation’ violation in

which the steam pressure in a line fell below the 185

pounds per square inch required for operation.l00 In

addition, the PUREX process uses a variety of

organic materials and solvents that are hazardous

wastes regulated under RCRA.

Concerns were expressed about how the plant and

its aging components might behave during restart,

after having been shut down for an extended period

in mid-campaign. In December 1989, DOE undertook to operate the plant for several weeks to clean

out materials that had lodged in the system during

shutdown and to stabilize the plant for an extended

shutdown of about a year, prior to restart for normal

operations (75). In October 1990 DOE announced

that it would not restart PUREX for at least 2 years

but would prepare an Environmental Impact Statement to evaluate a variety of treatment and disposal

methods for stored N reactor fuel.l0l

Finally, it should be noted that the regulation of

hazardous wastes at DOE sites under RCRA gives

EPA and authorized States a mechanism whereby

they can exert some regulatory control over DOE’s

waste management activities. In certain instances,

the conditions involving hazardous waste that need

correction may not appear very threatening, compared with the dangers “posed by the radioactive

components of the system. Nevertheless, the regulatory agencies have used the only authority available

to exercise control over these DOE activities.

Regulations Affecting Vitrification

It seems reasonable to assume that under the

current framework, DOE will have major regulatory

authority for the vitrification process itself. However, there is an important interface with the NRC

which, in turn, interfaces with EPA. NRC is

9SAS of March 1991, there are no gro~dwater protection standards for radionuclides. EPA has stated thiit they kt~d to propose Wch s~~s by

June 1991 and would expect to promulgate them by mid-1993. (Personal communications with EPA, Mar. 21, 1991.)

9S.p. COW- op. cit., footnote 11.

l~s event w= of co~iderable concern because the plant was not shut down immediately when the li.mithg condition of opemtion w= detwted.

101N.K. Geranios, op. cit., footnote 6.
Figure 1-12—Regulations for Management and Disposal of Nuclear and Hazardous Waste

(Hanford Single-Shell Tanks)

Abbreviations;

) 1 1 1 CFR: Code of Federal Regulations. v

Executive

Orders (CFR)

Regulations

Affecting

Activities at

Federal

Agencies

(CFR)

Federal Environmental Pollution Control

and Radiation Protection Statutes (USC)

State “Flowdown”

Statutes (RCW)

I fEPA Ecology DSHS NRC

Regulations Regulations Regulations Regulations

(CFR) (WAC) (WAC) (CFR)

DSHS: (Washington State) Department of Social

and Health Services.

RCW: Revised Code of Washington.

USC: United States Code.

WAC: Washington Administrative Code.

Nonflowdown State

Statutes (RCW)

1

I 1’

I 1 I

Ecology DSHS

Regulations Regulations

(WAC) (WAC)

Q

Formalize DOE

Policy and Interpret

DOE EPA and NRC

Orders Regulations as They

Apply to DOE

Facilities

hLocal

Regulations

FIFIPI

SOURCE: Pacific Northwest Laboratory, “Regulatory Requirements Important to Hanford Single-Shell Tank Waste Management Decisions,” Report

PNL-8821, June 1989.
Chapter 1--High-Level Waste Management at the DOE Weapons Complex ● 41

responsible for overseeing performance testing of

the HLW form in the repository. DOE is responsible

for setting preliminary specifications for this waste

form and for ensuring that it will comply with the

repository requirements-the so-called ‘‘waste acceptance process." l02 Thus, coordination and cooperation between the two agencies are called for.

The performance of the waste form in the

repository will be governed by standards promulgated by EPA for the management and disposal of

spent fuel and of transuranic and HLW. Such

standards were established in 1985 (40 CFR Part

191); however, they were vacated by the First

Circuit Court in 1987 and remanded to EPA for

further proceedings (16). At present, no new formal

proposal has been published by EPA. Disposal

standards for HLW were expected to have appeared

for public comment late in 1990.

At a briefing at Savannah River in October 1990,

the following information about oversight and

monitoring of the vitrified waste form was obtained.103 The DOE’s Office of Civilian Radioactive

Waste Management (OCRWM) has setup specifications for acceptance of the vitrified glass product. A

Waste Form Compliance Plan has been submitted to

the OCRWM and a Waste Form Qualification

Report is being prepared; these reports are reviewed

by an internal DOE Technical Review Group. Later,

a Production Records report will be written to

provide data as to whether the glass form complies

with specifications. The OCRWM is the organization that interfaces with the NRC in connection with

the repository; OCRWM will transmit these reports

to the NRC.

The glass specifications are being based on the

NRC technical criteria for the repository under 10

CFR 60 rather than the EPA disposal standards for

the repository promulgated at 40 CFR 191. New

methods are being developed to obtain and characterize product samples; these methods are being

submitted for review by the American Society for

Testing Materials, a national certification organization. l04

EPA’s role in regulating the waste form is, at the

moment, unclear. The HLW to be vitrified has

RCRA hazardous materials and is therefore a mixed

Table 1-2—Legislation and Regulations Applicable

to Hanford Single-Shell Tanks

Directly applicable legislation:

. The Resource, Conservation and Recovery Act (RCRA), the

Washington Hazardous Waste Management Act, the Washington Solid Waste Management Act, and their implementing

regulations.

. The Clean Air Act (CAA), the Washington Clean Air Act, the

Washington Statute on Nuclear Energy and Radiation, and

their implementing regulations.

. The Atomic Energy Act (AEA) and applicable implementing

regulations.

Other legislation and implementing regulations:

●

●

●

●

●

●

●

The Comprehensive Environmental Response, Compensation

and Liability Act (CERCLA), the Superfund Amendments and

Reauthorization Act (SARA), the Emergency Planning and

Community Right-to-Know Act (EPCRA).

The Safe Drinking Water Act (SDWA).

The Federal Water Pollution Control Act (FWPCA), as amended

by the Clean Water Act (CWA); the Washington Water Pollution

Control Act.

The Nuclear Waste Policy Act (NWPA) and the Low-Level

Radioactive Waste Policy Act (LLRWPA).

The Washington Water Well Construction Act.

The Washington Pollution Disclosure Act.

The Washington Regulation of Public Groundwaters statute.

DOE orders relevant to waste management, environmental

●

b

●

●

●

●

●

●

●

pollution control, and radiation protection:

DOE Order 5400.1, General Environmental Protection Program (November 9, 1988).

DOE Order 5820.2A, Radioactive Waste Management (September 26, 1988).

DOE Order 5480.1 A, Change 6, Environmental Protection,

Safety, and Health Protection Program for DOE Operations

(August 13, 1981).

DOE Order 5480.1 B, Environmental Protection, Safety, and

Health Protection Program for DOE Operation (September 23,

1986).

DOE Order 5481.1 B, Change 1, Safety Analysis and Review

System (May 19, 1987).

DOE Order 5480.11, Radiation Protection for Occupational

Workers (December 21, 1988).

DOE Order 5480.1 1A, Requirements for Radiation Protection

(September 17, 1986).

DOE Order 5490.1 A, Chapter Xl, Requirements for Radiation

Protection (August 13, 1981), updated by DOE Order 5480.1,

Change 6 (August 13, 1981).

DOE Order 5480.4, Environmental Protection, Safety and

Health Protection Standards (May 15, 1984), updated by DOE

Order 5480.4, Change 1 (May 16, 1988).

SOURCE: Pacific Northwest Laboratory, 1989.

waste. In mid-1990, EPA designated vitrification as

Best Demonstrated Available Technology (BDAT)

for mixed HLW.105 Although DOE and Westinghouse-Savannah River officials have met with EPA

officials to discuss the matter, it still appears to be an

open question as to whether or not EPA will require

lozperso~ comrn~mtion at high-level waste briefing, U.S. Department of Energy, Germantom ~, October 1989.

losperso~ comm~mtion d- visit to Savannah River Site, Oct. 26, 1990.

l~perso~ comm~cation during visit to Savannah River Site, Oct. 26, 1990.

los~d Dispos~ Restrictio~ for Third Third Scheduled Wastes, 55 Fed. Reg. 22520, 22627 (1990).
42 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

proof of vitrification. DOE seems to be proceeding

on the basis that EPA may be a factor in monitoring

the waste form and is developing a test that might be

substituted for the EPA Toxics Characterization and

Testing Protocol (TCTP); the latter can not be

performed in a hot cell.l06

Whether or not EPA monitors the vitrified waste

form after production and during storage appears to

be an open question. The answer may depend more

upon the inclination and actions of the principal

organizational players, namely DOE, EPA, and

perhaps NRC, than on clear-cut existing regulatory

requirements.

Associated with the vitrification process and

usually one step ahead of it is the production of an

immobilized grout or “saltstone.” The saltstone

facility at Savannah River has been granted a permit

by the State of South Carolina as a nonhazardous

waste facility. Thus, it is apparently not subject to

EPA regulation. This is in contrast to the Hanford

grout facility where continuing EPA presence seems

assured by the larger component of hazardous

materials in the waste. DOE monitors the saltstone

product and produces monthly reports. Internal

oversight is provided by DOE’s Office of Environment, Safety and Health.107

DISCUSSION

Definition of High-Level Waste

In recent years, attempts to redefine high-level

waste (HLW), moving from a source-based to a

concentration-based definition, have occurred and

have caused some controversy. The definition used

can have a substantial impact on cleanup and waste

management operations and costs. The Department

of Energy (DOE) has proceeded to follow a concentration-based definition in pretreating HLW prior to

vitrification so that a portion of tank waste can be

disposed of as low-level waste. The current DOE

definition of HLW uses the qualitative phrase “in

concentrations requiring permanent isolation. ’ Because this definition could lead to several different

interpretations, it may need reexamination. Also,

any concentration-based definition may need to be

reexamined in view of the fact that the Nuclear

Regulatory Commission (NRC) source-based definition remains part of U.S. Code. Finally, it maybe

desirable to arrive at a single, consistent definition of

HLW and other waste categories that is adopted by

DOE, NRC, and the Environmental Protection

Agency (EPA) and is acceptable to State agencies

and public interest groups. However, irrespective of

definition, the waste must meet EPA disposal

standards that have to be reissued; the definition and

standards are interrelated.

Repository Delays and Contingency Planning

DOE’s Five-Year Plan is predicated in part upon

the availability, starting about 2010, of a deep

geologic repository for disposal of HLW, as mandated by Federal legislation. In accordance with this

. . thinking, DOE is moving forward, at three of four

sites that have HLW, with vitrification facilities for

converting HLW from a liquid to a glasslike solid in

a form acceptable for repository disposal. This

strategy has the major advantage of reducing the

potential threat to public health and the environment, in the short term, that is posed by more mobile

tank waste, albeit at some increased occupational

risk. However, more consideration must be given to

facilities and requirements for storing solid waste if

the repository opening is delayed.

For several decades, or even longer, de facto,

on-site, monitored, retrievable storage of vitrified

waste should not be technically prohibitive, provided vitrification goes well.108 However, the institutional controls and monitoring needed for such

storage require further attention. There appears to be

no substantial contingency planning underway to

allow for the possibility that vitrification might not

succeed or might encounter major delays; the

calcination work at the Idaho National Engineering

Laboratory (INEL), which produces a powdery solid

that is stored in bins with a lifetime of 400 to 500

years is an alternative that could be examined. The

political trade-offs associated with planning for

various contingencies must also be considered. For

example, shipment of canisters with vitrified HLW

to a geologic repository may be opposed by some

along the transport route; on the other hand, longterm on-site storage of those waste canisters may not

l~perso~ Comunimtion during visit to Savannah River Site, oct. 26, 1990.

loTfiid+

IOSEurOpeanCOU~eS p~n to allow their vitild high-level waste to cool on-site for 50 years before further action is tien. The benefit Of le~the

waste cool (i.e., undergo some radioactive decay prior to repository disposal) merits consideration in the United States, which has not planned for such

a long cooling period but may, in fact, be accommodating to one.
Chapter 1--High-Level Waste Management at the DOE Weapons Complex ● 43

be acceptable to residents and officials of the State

in which the site is located. In addition, changing

from the current policy of building a deep repository

in favor of monitored retrievable storage at the

weapons sites would require extensive study and

debate. These issues could be scrutinized further in

the Programmatic Environmental Impact Statement

(EIS) that DOE now has underway.

Urgency of High-Level Tank Waste Treatment

The urgency of solidifying high-level tank waste

is difficult to quantify. For example, although DOE

generally asserts that HLW currently stored in tanks

at Hanford, Savannah River, Idaho, and West Valley

poses no imminent threat to public health, current or

potential groundwater contamination due to tank

leakage is a matter of debate. Concerns about the

possibility of tank explosions with ensuing large

releases of radioactivity also continue to arise.

Accurate characterization will require time and

money—perhaps a decade and hundreds of millions

of dollars-if current regulatory guidelines are

adhered to. The characterization process might be

speeded up by more focused sampling and attention

to suspected environmental pathways.

Current DOE plans indicate that vitrification of

liquid waste from double-shell tanks at Savannah

River will begin in FY 1992 or 1993, followed by

vitrification of Hanford double-shell tank waste

commencing in FY 1999. Decisions about the

treatment or disposal of single-shell tank waste at

Hanford have been deferred. The tri-party agreement

calls for closure of single-shell Hanford tanks during

the period 2005 to 2018; the agreement also calls for

the removal of all pumpable liquid waste from these

tanks by 1996 (42). A General Accounting Office

(GAO) report advises that this latter date should not

deter DOE from removing the liquid sooner, if

possible, given GAO’s conclusion that DOE’s

current monitoring efforts do not provide sufficient

data to adequately trace the migration of leaks or to

fully assess their effects (42). GAO also advises

placement of new ground cover material over the

tank farms to slow water drainage through the soil.

The major concern is the danger of contamination, of

groundwater and the Columbia River by leaking

high-level tank waste.

At Hanford, priority was given to early treatment

of liquid HLW in double-shell tanks, in response to

a number of factors, possibly including the relative

ease of treatment of double-shell waste compared

with single-shell waste; the less mobile condition of

single-shell waste; and the fact that the double-shell

tanks are required for new waste storage. This

priority is now codified in the tri-party agreement.

While it is important to move ahead with a treatment

system for the double-shell tank waste, it is also

important to give attention to the single-shell tank

problem and to reach a decision on how to improve

conditions of waste storage there as soon as possible.

At a December 1989 meeting of the National

Academy of Sciences Panel on Hanford Single-Shell

Tanks, panel members urged DOE and WestinghouseHanford to take a more systematic overall approach

to exploring alternatives for treatment and disposal

of single-shell tank waste rather than simply focusing on specific tasks, such as taking core samples,

without any concept of the “big picture” for

treatment and disposal. The panel also called for

more evaluation of the potential for tank explosions

due to the ferrocyanide that had been added to some

single-shell tanks, as well as a determination of other

tank contents that might constitute an explosive

hazard. If this evaluation should reveal the possibility of tank explosion, immediate corrective action

would have to be considered. Indications, based in

part on DOE statements to date, are that the

possibility of explosions involving ferrocyanide will

be of greater concern during treatment operations

than during storage.

More recently, reports of the presence of hydrogen gas in some of the HLW tanks at Hanford have

raised the possibility of frees or explosions. The

matter is under more intensive study by DOE

following a number of oversight investigations and

hearings in 1990. This situation increases the

urgency of proceeding with the solidification of

high-level tank waste. However, the trade-offs

between moving ahead with dispatch and moving

ahead too precipitously require careful consideration. In early 1991, Secretary of Energy Watkins

indicated that a two-year delay in the start of

construction of the Hanford Waste Vitrification

Plant was needed; two reasons were to complete a

risk assessment and to develop more data on the

contents of the tanks to ensure safe pretreatment.

Such a delay would require modification of the

Tri-Part Agreement.l09

109C ‘Secmq Delays Constriction of Hanford Waste Vitilcation pl~t,’ Weapons Complex Monitor, Feb. 25, 1991, p. 11.

292-864 0 - 91 - 4
44 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

Technologies for High-Level Waste Treatment

Two technologies are central to DOE’s plans for

treatment of liquid high-level tank waste over the

next decade: 1) vitrification of the “high-level”

component of the waste with borosilicate glass,

followed by placement in canisters and disposal in

a deep repository, and 2) immobilization in grout or

concrete of the ‘‘low-level’ component of the

waste, followed by on-site disposal either at or near

the surface. Both of these technologies require major

financial investments, especially vitrification. It is

important that technical work be performed well and

monitored carefully.

Vitrification of the HLW component is scheduled

to commence in the Defense Waste Processing

Facility (DWPF) at Savannah River in 1992 or 1993.

The technology will have to be carefully demonstrated over a period of time, first with cold runs (i.e.,

with no radioactive waste). These cold run tests

began in the fall of 1990. Careful balance is required

between the need to move as rapidly as possible in

getting high-level tank waste into the more stable

vitrified form, and the need to proceed carefully and

cautiously. If all goes reasonably well at Savannah

River, the Hanford Waste Vitrification Plant (HWVP)

should be less problematic because it will use a

technology similar to that of the DWPF.

The operation of grout facilities at both Savannah

River and Hanford could reduce the volume of high

level tank wastes to be managed in the future. Grout

or concrete has the advantage of being a solid form,

in contrast to current tank waste liquids and sludges.

However, given the concerns that have been raised

about treating some fraction of the high-level tank

waste in a “low-level” reamer, some questions

concerning this practice must be resolved. A key

question is how long will the grout last (i.e., keep

radioactive or hazardous components contained)?

DOE may need to investigate the lifetime of these

waste forms more extensively.

Rethinking the Waste Form and Package

DOE has decided to use a waste form and package

for the disposal of vitrified HLW that involves using

borosilicate glass and relatively thin-walled (about

l-centimeter-thick) stainless steel canisters. Whereas

this approach was chosen to assure a lifetime range

of several hundred to 1,000 years, the canister itself

is not expected to last the 10,000 or more years

required to isolate the long-lived transuranic and

other radionuclides from the environment. Therefore

the current approach provides for long-term integrity

to be ensured in large part by the integrity of the deep

geologic repository.

In contrast, Sweden places more reliance on the

waste package to ensure that radionuclides will not

escape into the environment. Plans call for the

Swedish waste package to be thick walled (about 10

centimeters) and for the copper canisters to be filled

with either molten lead or copper surrounding the

spent fuel. A National Academy of Sciences panel

that reviewed the Swedish plans believes that, in this

manner, canister lifetimes of 1 million years or more

can be achieved (28). This means that less reliance

has to be placed on the geologic repository.

The need to achieve a 10,000-year or 100,000-

year lifetime for waste isolation in a repository has

created a difficult regulatory problem. EPA’s HLW

disposal standards were struck down by a court in

part because some controls were not deemed to

assure control for a sufficient length of time (16).

Also, there is the possibility that stricter radiation

protection standards may be needed in response to

the findings of increased risks of cancer from

radiation (29). Finally, if a deep geologic repository

for HLW disposal is delayed for a long time, and

monitored retrievable storage were required during

that time, a waste package with a long design life

could be useful.

Given the delays in repository development in the

United States, it might be useful to review storage

and disposal options for defense HLW with particular attention given to strengthening the engineered

barrier performance of the waste package.ll0 Although some elements of DOE’s HLW management

strategy (such as the DWPF vitrification plant at

Savannah River) may be too far along to change,

others (such as the HWVP) may not be. Also, since

DOE’s canister must fit in the same NRC-approved

container as commercial spent fuel before being

placed in the repository, the canister design might

not have to be changed; instead, the overpack

ll%July of 1990 the National Rese~h Council issued a report that indirectly supports this statement (30): “.. . there area number of Unresolved

issues in the U.S. radioactive waste dispos~ program, as well as (and in part because of) high levels of uncertainty and public unease about the

performance of the repository. . . the proper response to uncertainty is greater knowledge and flexibility, as well as redundancy of barriers to nuclide

transport.”
Chapter 1-High-Level Waste Management at the DOE Weapons Complex . 45

container could be modified to provide additional

barrier performance.

A key question to be considered is whether the

major additional cost of proceeding with engineered

barriers is justified by the benefits to be derived.

Another question is whether current performance

assessment methodology for the combination of

engineered barriers and repository allow assessments to be made in which one can have confidence.

This may depend on whether knowledge of interaction between the engineered barrier and the repository environment is sufficiently advanced so that a

barrier can be designed that will perform its function

for the required period of time.

The choice of borosilicate glass as the waste form

for vitrification of HLW is consistent with the waste

form selected in other countries. OTA found that a

high level of confidence in this choice was held by

DOE and its contractors; however, this view is not

shared by all. Concerns have been raised about the

long-term performance of borosilicate glass in the

Yucca Mountain repository environment, the adequacy of the scientific program to demonstrate that

borosilicate glass will retain defense HLW for the

necessary durational,111 and the lack of adequate R&D

on second generation waste forms after DWFP.112

Producing a qualified waste form from the wide

range of input waste feed to the vitrification process

is a challenging technical assignment. The development of a theoretical framework with which to

predict long-term waste form performance appears

to be an ongoing process and DOE, in cooperation

with the regulatory agencies, will be participating in

this process for many years to come.

Waste Form for the Idaho National

Engineering Laboratory

Cost reduction appears to be a major factor in the

search for a waste form other than borosilicate glass

at INEL; each canister of vitrified borosilicate HLW

is very expensive to produce and dispose of in a

repository (50). If more waste can be loaded onto the

matrix by the use of glass-ceramic instead of

borosilicate glass, costs for immobilizing the HLW

at Idaho might be reduced by billions of dollars.

Idaho also has 25 years of experience in calcining

HLW. Currently, the HLW calcine at INEL is stored

in stainless steel bins within reinforced concrete

vaults having design lifetimes of 400 to 500 years.

The possibility of hardening the calcine within the

existing storage bins could be an alternative under

consideration.

The INEL waste form decision represents an

opportunity to reexamine this area in light of what

has been learned since the decision in favor of

borosilicate glass a decade ago. Such reexamination

could include economic, environmental and political factors. An independent technical review panel

might be useful in this regard if it had the resources

to do the level of evaluation needed.

Releases to the Atmosphere

Nuclear reactors, reprocessing plants, and facilities such as evaporators and calciners for treating

HLW sometimes release radioactive or hazardous

materials to the atmosphere. Through the introduction of air filters and other off-gas handling equipment, releases of radionuclides have been greatly

reduced, but not totally eliminated, since the early

days of the weapons program. In addition to releases

from routine operations, concern persists about

potential releases during accidents such as HLW

tank explosions of the kind that occurred in 1957 in

the Soviet Union. Air emissions, including radioactivity, from DOE sites are subject to National

Emissions Standards for Hazardous Air Pollutants

(NESHAPS) 113 promulgated by EPA under the

Clean Air Act.

Unlike groundwater, the air exposure pathway of

the offending materials is direct and known. At the

Office of Technology Assessment (OTA) Health

Effects Panel Workshop in January 1990, several

panelists stated that they believed airborne release of

both radioactive and hazardous materials to be a

greater potential health threat than groundwater

, contamination. Further, they pointed out that the

Resource Conservation and Recovery Act (RCRA)

and the Comprehensive Environmental Response,

Compensation and Liability Act (CERCLA) regulations focus attention on groundwater contamination

but ignore air releases. Setting standards for the

release of radionuclides to air has been the object of

] 1‘Matuse~ J. M., “Issues of Glass Waste-Form Reformance: Summary, “ Waste Form/Repository Meeting, U.S. Department of Energy, Dec. 20,

1990, p. 1.

l12Etig,R.,~rsonal communication to R.P. Morgan, -h 5, 1991.

1 lsNatio~ Emission Standards for Hazardous Air Pollutants, ~ C.F.R. $61 (1990).
46 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons complex

contention between NRC and EPA (33), and the

monitoring of emissions presents some technical

difficulties. Although EPA has authority to set air

release standards for radioactivity from DOE sites,

implementation and enforcement remain with DOE.

It maybe useful to pay more attention to regulating

air emissions, to implementing and enforcing air

release standards, and to monitoring DOE activity in

this area.

Future of the PUREX Plant at Hanford

In December 1988, the PUREX fuel reprocessing

plant at Hanford was shut down in mid-campaign

due to a low steam pressure condition. The plant has

caused concern because of its age, the large amounts

of hazardous and radioactive wastes it produces, past

atmospheric releases, and continued release of liquid

effluents to the soil even in its shutdown condition.

In December 1989 the plant was restarted for a short

time to stabilize the situation by flushing out

material that had settled in pipes and other equipment during the sudden shutdown. After this stabilization run, DOE had planned to restart PUREX in

late 1990 to reprocess the backlog of spent defense

fuel over a 5-year period and then permanently to

close the facility. However, a decision was made in

1990 not to restart PUREX for at least 2 years but to

prepare an EIS and evaluate options for handling the

stored fuel.

The decision not to restart PUREX may have been

reached for a number of reasons, including: 1) the

U.S. plutonium stockpile is widely reported to be

sufficient; 2) citizen groups and state officials had

increasingly raised questions and expressed concern

about environmental impacts of operating PUREX;

3) regulatory constraints imposed by RCRA had

already shut down the plant and there was also the

threat of pending legal action if restart was attempted; and 4) outside independent analysis coupled with DOE’s own work suggested that encapsulation and storage of spent N-reactor fuel could be an

alternative to reprocessing with environmental benefits.

The future of PUREX will continue to be an issue

of intense public concern as well as requiring sound

technical analysis. It will be a challenge for DOE to

resolve while actively involving the public in the

EIS process.

Waste Minimization; Tritium Production;

International Cooperation

The radioactivity of HLW generated from reprocessing spent fuel and irradiated uranium targets is

strongly related to weapons material production

requirements. Within current production practice, it

will be difficult to reduce HLW other than by

reducing production. However, it maybe possible to

produce tritium without producing HLW if no

reprocessing of the spent driver fuel elements is

performed. There is no minimization of radioactivity

if such a change in operations were to be adopted; to

a first approximation, the total radioactivity associated with the fission process should be the same,

whether the radionuclides are contained in the spent

fuel elements or released from those elements and

contained in waste tanks, or eventually, in glass logs.

Hazardous waste and certain types of radioactive

and mixed waste other than HLW might well be

reduced by technological improvements to reprocessing. The U.S. decided in the 1970s not to pursue

reprocessing of commercial nuclear fuels. Other

nations may have acquired certain expertise in

reprocessing that might prove useful to DOE’s

efforts at waste minimization. DOE has already

supported several important programs in international technology exchange. Since the DOE waste

minimization program is currently in a very early

stage, its design could profit by a wide range of

input. Learning from international experience and

expertise should be a strong element of the DOE

effort.

Scenarios for Future HLW Production

HLW is an inevitable consequence of the fission

process that occurs in current nuclear weapons

production practices. At present, no DOE weapons

production reactors are operating. This pause in

reactor operations provides an opportunity to pursue

cleanup at the Weapons Complex during a time of

reduced levels of HLW generation. The Department

of Energy has recently begun to prepare an Environmental Impact Statement of its plans for modernizing the Weapons Complex. Such an analysis should

provide valuable insights and help DOE in its efforts

to focus greater attention on the environmental

consequences of various production scenarios.

In January 1991, DOE issued a Reconfiguration

Study for the Weapons Complex which appears to

represent a useful step towards facilitating the PEIS

process. In that study, alternative configurations
Chapter 1--High-Level Waste Management at the DOE Weapons Complex ● 47

were outlined for four different production scenarios, ranging from 15 to 70 percent of current

production levels.114 Among the issues that could

usefully be addressed in the PEIS on modernization

is how effective a waste minimization program

could be accomplished under each of the alternative

configurations.

1.

2.

3.

4.

5.

6.

‘7.

8.

9.

10.

11.

12.

13.

14.

15.

16.

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Associated Press News Release, “Experts Arrive To

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Associated Press News Release, “International Waste,’

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Associated Press News Release, “Nuclear Waste,”

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Blumenthal, L., ‘‘Glenn Calls for Review of Possible

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Burns, R., “Flaws in Radiation Protection Cited at

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Dec. 13, 1989.

Cochran, W.M. et al., Nuclear Weapons Databook:

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(Cambridge, MA: Ballinger Publishing Co., 1987), p.

24.

Cochran, W.M. et al., Nuclear Weapons Databook:

Volume III, U.S. Nuclear Warhead Facility Profiles

(Cambridge, MA: Ballinger Publishing Co., 1987), p.

26.

Connor, T, “Hot Water: Groundwater Contamination at the Hanford Reservation,’ Hanford Education

Action League, undated.

Cook, B.J. et al., “Organizing and Managing Radioactive Waste Disposal as an Experiment, ’ Journal of

Policy Analysis and Management, vol. 9, No. 3, p.

350, 1990.

Coyle, D. et al., Deadly Defense: Military Radioactive Landfills (New York NY: Radioactive Waste

Campaign, 1988), p. 100.

Coyle, D. et al., Deadly Defense: Military Radioactive Landfills (New York NY: Radioactive Waste

Campaign, 1988), p. 98.

Dickson, D., “Kyshtym: Almost as Bad as Chernobyl,” New Scientist, December 1989, p. 3.

First Circuit Court, Natural Resources Defense

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18.

19.

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vol. 18, 1988, pp. 20088-20106.

Geranios, N.K., “Cost of Ending Discharges Rises,”

Associated Press News Release, Nov. 15, 1989.

Geranios, N. K., “Safety Board Says Little Risk to

Public,” Associated Press News Release, Apr. 12,

1990.

Geranios, N. K., “Study Says Hydrogen Could Explode in Nuke Waste Tanks,’ Associated Press News

Release, Mar. 24, 1990.

Holcomb, W.F., and Gruhlke, J.M., “EPA’s Proposed Environmental Standards for Low-Level Radioactive Waste Disposal and Criteria for Below

Regulatory Concern,” paper presented at Residual

Radioactivity and Recycling Criteria Workshop, St.

Michaels, MD, Sept. 27-28, 1989.

International Technology Corp., ‘Radioactive Mixed

Waste: Sampling and Analysis,” Addendum to EPA

Guideline SW-846, Test Methods for Evaluating

Solid Waste, Rev. 1.2, Oct. 9, 1989.

Keller, J. F., “Regulatory Requirements Important to

Hanford Single-Shell Tank Waste Management Decisions” Report No. PNL-6821 (Richland, WA:

Pacific Northwest Laboratory, June 1989), p. iv.

Kocher, D. C., ‘‘Review of Radiation Protection and

Environmental Radiation Standards for the Public,”

Nuclear Safety, vol. 29, No. 4, October-December

1988, p. 465.

Kocher, D. C., and Croff, A. G., ‘A Proposed Classification System for High-Level and Other Radioactive

Wastes,” Report ORNL/TM-10289, June 1987.

Lippman, T. W., “Energy Department to Assess

A-Weapons Plant,’ Washington Post, Jan. 13,1990,

p. AlO.

Makhijani, A., and Blackwelder, B., Deadly Crop in

the Tank Farm (Washington, DC: Environmental

Policy Institute, July 1986), pp. 1-7.

Makhijani, A., Alvarez, R., and Blackwelder, B.,

Evading the Deadly Issues: Corporate Mismanagement of America’s Nuclear Weapons Production

(Washington, DC: Environmental Policy Institute,

September 1987), pp. 17-18.

National Academy of Sciences, A Review of the

Swedish KBS-3 Plan for Final Storage of Spent

Nuclear Fuel (Washington, DC: National Academy

Press, 1984), p. 3,

National Research Council, Committee on Biological

Effects of Ionizing Radiations, Health Effects of

Exposure to Low Levels of Ionizing Radiation:

BEIR-V (Washington, DC: National Academy Press,

1990).

National Research Council, Rethinking High-Level

Radioactive Waste Disposal (Washington, DC: National Academy Press, 1990), p. 26.

114u.s. Department of Energy, “Nuclear Weapons Complex Recon@uration Study,” Report DOE/DP-0083, January 1991.
48 . Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

31.

32.

33.

34.

35.

36.

37.

38.

39.

40.

41.

42.

43.

44.

45.

46.

47.

48.

National Research Council, The Nuclear Weapons

Complex: Management for Health, Safety and the

Environment (Washington, DC: National Academy

Press, 1989).

Nuclear News, March 1990, p. 19.

Nuclear News, “The Senate Favors EPA Authority

on Airborne Radionuclides, ’ April 1990, p. 19.

Radioactive Exchange, “Nuclear Waste Technical

Review Board Report to Congress,” vol. 9, Nos. 5

and 6, Mar. 31, 1990, pp. 16-17.

Report on Defense Plant Wastes, “INEL Puts

Chemical Reprocessing Plant on ‘Standby’ to Make

RCRA Changes,’ NOV. 10, 1989, pp. 204-205.

Report on Defense Plant Wastes, “Radiation Threat

Three Times Previous Assumptions,” July 6, 1990,

p. 38.

Roberts, L., “Radiation Accident Grips Goiania,”

Science, vol. 238, Nov. 20, 1987, pp. 1028-1031.

Saleska, S., “Low-LevelRadioactive Waste: Gamma

Rays in the Garbage,’ Bulletin of Atomic Scientists,

vol. 46, No. 3, April 1990, pp. 18-25.

Seabrook, C., ‘‘Radioactive Cleanup Delay May Be

Costly,” Atlanta Journal and Constitution, Dec. 29,

1989.

Steele, K.D., “Hanford: America’s Nuclear Graveyard,’ Bulletin of Atomic Scientists, October 1989, p.

18.

Thomas, J., “A Summary of Radiation Releases

From Hanford,” Hanford Education Action League,

May 18, 1989.

U.S. Congress, General Accounting Office, ‘Nuclear

Waste: DOE Management of Single-Shell Tanks at

Hanford, Washington,” Report GAO/RCED-89-

157, Ju1y 1989, pp. 2-3.

U.S. Congress, General Accounting Office, “Nuclear

Waste: DOE Management of Single-Shell Tanks at

Hanford, Washington,” Report GAO/RCED-89-

157, July 1989, p. 5.

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Waste: DOE Management of Single-Shell Tanks at

Hanford, Washington,” Report GAO/RCED-89-

157, July 1989, pp. 6,9.

U.S. Congress, General Accounting Office, “Nuclear

Waste: DOE’s Program to Prepare High-Level Radioactive Waste for Disposal,’ Report GAO/RCED-90-

46FS, November 1989, p. 3.

U.S. Congress, House Committee on Energy and

Commerce, Subcommittee on Energy Conservation

and Power, Achieving Performance Objectives for

the Engineered Barrier System, 1984.

U.S. Congress, Office of Technology Assessment,

“An Evaluation of Options for Managing GreaterThan-Class C Low-Level Radioactive Waste,’ background paper, October 1988.

U.S. Department of Energy, “Applied Research,

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49.

50.

51.

52.

53.

54.

55.

56.

57.

58.

59.

60.

61.

62.

63.

64.

65.

66.

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144-145.

U.S. Department of Energy, “Compliance Assessment of the Savannah River Site, ’ Draft, March

1990, vol. 1, p. Es-1.

U.S. Department of Energy, ‘‘Environmental Restoration and Waste Management: Five-Year Plan,”

DOE S-0070, 1989. p. 154.

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DOE S-0070, 1989. p. 166.

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DOE S-0070, 1989. p. 167.

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DOE S-0070, 1989. p. 372.

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Fiscal Years 1992-1996,” June 1990, p. 16.

U.S. Department of Energy, “Environmental Restoration and Waste Management: Five-Year Plan,

Fiscal Years 1992-19%,” June 1990, p. 519.

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U.S. Department of Energy, “Final; Waste Reduction Steering Committee; Charter,” DOE document,

undated, p. 42.

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for 1989,” DOE/RW-0006, November 1989, p. 62.

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U.S. Department of Energy, Savannah River Operations Office, “Savannah River Waste Management
Chapter l----High-Level Waste Management at the DOE Weapons Complex ● 49

67.

68.

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70.

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.

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tions Office, “Savannah River Waste Management 74

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ICPP: A 25-Year Success Story,’ brochure, undated.

Wicks, G., and Bickford, D., “Doing Something

About High-Level Waste,” Technology Review,

November-December 1989, p. 54.

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1989.
Chapter 2

Managing Transuranic

Waste at the DOE

Nuclear Weapons Complex

Contents

Page SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...............53

Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . .,.,++. 53 Data and Projections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

The Definition of TRU Waste . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . ...... . . . . . . . ● . . . . . . . . . . . . . . 54 Buried Transuranic Waste . . . . . . . . . . . . . . . .

. . . . . . . ,.

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ++...... . . . . . . . 54

Storage and Treatment of Retrievably Stored Transuranic Waste . . . . . . . . . . . . . . . . . 55

The Waste Isolation Pilot Plant . . . . . . . . . . . . . . . . . . . . .

..,.+.. . . .

. . . . . . . . . . . . . . . . . . . . . .++.,.. . 56

Standards,Regulations, and Oversight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ..,........,,..++.. 57

. . . . . .

Research and Development, Waste Minimization, Transmutation . . . . . . . . . . . . . . . . . . . . . . . . . . 57

TRANSURANIC WASTE AT DEPARTMENT OF ENERGY SITES . . . . . . . . . . . . .

. . . . . . . . . . . 58 Definition and Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

...... ● . . . . . . . . . . . . . . . . . . . 58 Amount and Distribution . . . . . . . . . . . . . . . . . . . . .. ........4......+,.- . .. .. .. .., , ..,,,+.+. . 59

Waste Management Present and Planned . . . . . . . . . . . . . . 64 Current and Potential Problems . . . . . . . . . ....... . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . . ...*..+ . . . . . . . . . . . . . . . . . ...+..., . . . . . . . . . 66 TECHNOLOGIES FOR IMPROVED MANAGEMENT OF TRANSURANIC WASTEURANIC WASTE . . . . . . . . 80

Introduction .. ......................,......,.4 . ..,,..+..

. . . . . . . . . . . . . . ,,...... . . . . . . . 80 Three Technologies for Treating Retrievable Stored Transuranic Waste . . . . . . . . . . . . . . . . . . . . 80

In Situ Vitrification . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83

The Applied Research, Development Demonstration, Testing,

and Evaluation Plan (RDDT&E) ..+.... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ....++...,,.. 85

Actinide Conversion (Transmutation).+......... .

. . . . . . . 85 Waste Minimization . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87
THE REGULATORY FRAMEWORK .. ... +.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88

Definition of Transuranic Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88

Regulations Affecting Transuranic Waste .. .. + . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89

Regulations Affecting the Waste Isolation Pilot Plant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91

DISCUSSION ... .,,+..... .. .. .. .. .. .. ., ... ..+. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93

Definition of, and Standards for, Disposal of Transuranic Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . 93

Repository Delays; Alternative Storage and Disposal Strategies . . . . . . . . . . . . . . . . . . . . . . . . . . . 93

Remediation of Buried Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .................+.. . . 94

The Waste Isolation Pilot Plant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 94

Waste Minimization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95

Scenarios for Future Transuranic Waste Production . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96

CHAPTER 2 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96

APPENDIX 2-A: CONDITIONS OF NO-MIGRATION DETERMINATION .. .. .. ... ... .....98

Box

Box Page

2-A. Definition of Transuranic Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., ..+..... 58

Figures

Figure Page

2-1. Total Volume of Retrievable Stored DOE Transuranic Waste Through 1988..,.......,..59

2-2, Points of Origin and Storage Sites of DOE Transuranic Waste . . . . . . . . . . . . . . . . . . . . . . . . . . 60

2-3. Volume of Retrievably Stored Contact-Handled(CH) and Remote-Handled (RH)

Transuranic Waste Accumulated Through 1988 ,.....,. . . . . . . . . . . . . . . . . . . . . . . . . . . . ,... 61

2-4. Total System Inventories, Projections, and characteristics of All Buried

and Stored DOE Transuranic Waste.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62

2-5. Planned Facilities To Process, Treat, and Certify Transuranic Waste for Shipment

to the Waste Isolation Pilot Plant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .,, .++.... 66

2-6. DOE Rocky Flats Tiger Team Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70

2-7. Proposed Shipping Routes to the Waste Isolation Pilot Plant . . . . . . . . . . . . . . . . . . .. .+..... 72

2-8. Bringing Trucks of TRU Waste Drums to the WIPP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73

2-9. The Waste Isolation Pilot Plant: Its Capacity,

Estimated Operational Cost, and Estimated Lifetime . . . . . . . . . . . . . . . . . . . .. .. . .. .,..+.... 74

2-10. Characterization of Transuranic Waste To Determine Disposal Option .. .. .. ... +.. . . . . . . . 86

Tables

Table Page

2-1. Some Transuranic Radionuclides and Their Half-Lives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58

2-2. Inventories and Characteristics of Soil Contaminated With

DOE Transuranic Waste Through 1988 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .,.+4... 64

2-3. Inventories and Characteristics of DOE BuriedTransuranic Waste Through 1988 . . . . . . . . . . 67

2-4. Summary of Transuranic Waste Incinerators at DOE Weapons Complex

as of July 1990 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81

2-5. Potential ARARs for Assessment of Buried Waste at the Subsurface

Disposal Area at INEL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .90
Chapter 2

Managing Transuranic Waste at the

DOE Nuclear Weapons Complex

SUMMARY

Overview

It has been only 50 years since elements heavier

than uranium-hence, the term Transuranic-were

created. These elements do not occur in nature and

were first produced in nuclear reactors as part of the

World War II effort by the United States to develop

the atomic bomb. An isotope of one of these

elements, plutonium-239, has physical and nuclear

properties that make it a desirable material for

atomic weapons-only a few kilograms or tens of

kilograms are required. Plutonium was the explosive

material in the bomb dropped on Nagasaki. It is

found in the “triggers” of tens of thousands of

modern thermonuclear weapons in the arsenals of

the United States and the Soviet Union. Whereas in

the early 1940s, scientists working on the wartime

Manhattan Project struggled to produce microgram

quantities of plutonium-239, tons of it exist today.

Threats to human health from plutonium and

other Transuranics do not arise solely from the

possibility of their use in a thermonuclear conflict.

Most Transuranic radionuclides decay by emitting

helium nuclei—that is, alpha particles, a heavily

ionizing form of matter. These alpha particles make

plutonium toxic to humans in very small quantities

when inhaled or ingested. Furthermore, some transuranic radionuclides are very long-lived and tend to

persist rather than decay rapidly to other nuclides. A

principal concern is plutonium-239, which has a

half-life of 24,400 years; thiS means that half of the

plutonium-239 in existence in 1990 will still exist in

the year 26,390.

Plutonium-239 is produced via capture of neutrons by uranium-238 in nuclear reactors. This

process goes on continually in commercial nuclear

power reactors, as it did in the Hanford reactors for

weapons production purposes during and after

World War II. While in the U.S. commercial sector,

almost all of the plutonium is contained within the

solid structure of spent fuel elements removed from

reactors, in the defense sector, plutonium is spread

more widely in the environment because fuel

elements and targets have been reprocessed, by

using aqueous and organic liquids, to unlock and

separate the plutonium for recovery and incorporation into weapons. Reprocessing has resulted in

, contamination by plutonium of soil and sediments in

the vicinity of certain sites in the Nuclear Weapons

Complex. In addition, ,contamination of workers and

workplaces from various plutonium handling and

machining operations is a constant concern. One

example of this is the report in 1990 that enough

plutonium had accumulated in the ducts at the

Department of Energy Rocky Flats Plant to fuel

several nuclear weapons.

Transuranic (TRU) waste arises in the U.S.

defense program primarily as a consequence of

reprocessing plutonium-bearing fuel and irradiated

targets, and from operations required to prepare the

recovered plutonium for weapons use. TRU waste

includes TRU metal scraps as well as glassware,

process equipment, soil, laboratory waste, ionexchange resins, clothing, filters, glove boxes, and

paper products contaminated with TRU materials.

Until 1970, TRU waste was handled in a reamer

similar to low-level waste (LLW): it was dumped

into trenches or pits and covered over or buried; such

waste is referred to as buried TRU waste. Pre-1970

practices have resulted in great uncertainty in the

estimates and location of buried TRU waste and

TRU-contaminated, soil. Subsequently, in accordance with a 1970 Atomic Energy Commission

(AEC) decision, TRU waste was stored, usually in

metal drums, in a manner to permit easy recovery

and treatment, because of the growing realization

that long-lived radionuclides such as plutonium-239

require more careful handling, storage, and longterm disposal than previously recognized; such

waste is referred to as retrievable stored TRU waste.

In general, the Department of Energy (DOE) views

retrievable stored and yet-to-be-generated waste as

a waste management problem, whereas buried waste

is an environmental restoration problem; the two

may require different technological, evaluative, and

administrative approaches. Since the mid-1970s,

plans for long-term disposal of TRU waste have

centered upon the availability of a deep geologic

repository, paralleling earlier “thinking about disposal of high-level waste (HLW).

–53–
54 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

DOE’s policy is that retrievable stored and

yet-to-be-generated TRU waste will be disposed of

in a geologic repository. The Waste Isolation Pilot

Plant (WIPP) near Carlsbad, NM, was authorized by

Congress in 1980 to serve as a research and

development facility for disposal of such TRU waste

in bedded salt. Upon completion of the test phase,

WIPP might then serve as the first deep geologic

repository for defense TRU waste. WIPP has now

been built. To date, no waste packages have been

placed in WIPP. A positive decision by Secretary of

Energy James D. Watkins on DOE’s readiness to

proceed with the experimental phase was made in

June 1990. The earliest date for disposal of TRU

waste in the WIPP facility on a regular, operational

basis is 1995. Other scenarios foresee WIPP opening

much later.

Data and Projections

DOE collects information on various waste types

in its Integrated Data Base (IDB), which is updated

annually. According to the 1989 IDB (77), both

retrievable stored and buried TRU waste are distributed over six sites: the Idaho National Engineering

Laboratory (INEL) has 61 percent of the retrievable

stored waste, and Hanford has 57 percent of the

buried waste by volume. The volume of buried TRU

waste is estimated to be three times that of retrievable stored TRU waste.1 A seventh site, the Rocky

Flats Plant, also has been storing TRU waste since

late 1989 when the State of Idaho refused to accept

further shipments. Most of the stored TRU waste by

volume is contact-handled; that is, its radioactivity

is sufficiently low that it is considered safe for

workers to manipulate the drums. Smaller volumes

of TRU waste at Oak Ridge and other sites have

radioactivity levels sufficiently high, due to fission

products mixed with the waste, to require that waste

packages be handled remotely—hence, the term

remote-handled waste.

The 1989 IDB (77) projects a large increase in

radioactivity associated with total stored TRU waste

by the year 2013, growing to 3.5 times the 1988

value (74).2 Much of the growth appears to be

associated with activities at the Savannah River

Plant. The scaledown in growth indicated by the

projections in the 1988 and 1989 IDBs could reflect

some downward adjustment in weapons material

requirements due to the improved arms control

outlook. Nevertheless, existing projections indicate

a growing burden of TRU waste to be managed over

the next 25 years.

The Definition of TRU Waste

Transuranic (TRU) waste is defined as waste

contaminated with alpha-emitting transuranium radionuclides with half-lives of more than 20 years and

concentrations higher than 100 nanocuries per gram.

This limit was raised from 10 nanocuries per gram

in 1984. It permits DOE to reclassify and dispose of

some of what used to be TRU waste as LLW.

However, regardless of definition, the waste must

meet appropriate disposal standards. At present,

Environmental Protection Agency (EPA) standards

for disposing of plutonium waste are either nonexistent or in need of review, and important elements of

EPA radiation protection standards for disposal of

TRU waste also need to be reissued.

Buried Transuranic Waste

Characterization of, and strategies for, handling

buried TRU waste or remediating TRU-contaminated soil are in the very early stages. Thus,

knowledge of buried waste sites and soil contamination is far from complete. A National Academy of

Sciences panel is monitoring efforts by DOE and its

contractor, EG&G-Idaho, to determine how to deal

with buried TRU waste at INEL. Among the issues

under consideration are better delineation of waste

migration; the risks and benefits associated with in

situ treatment of waste versus digging it up and

treating it; and sites for disposal of the waste, if and

when it is retrieved. Remediation of the Subsurface

Disposal Area (SDA) at INEL where buried TRU

waste is located has been governed by a Consent

Order and Compliance Agreement (COCA), based

on the Resource Conservation and Recovery Act3

(RCRA), involving EPA Region X, DOE, and the

IIDB es~tes of b~ed TRU waste are subjeet to considerable uncertainty. Stored TRU waste estimates should be somewhat more re~ble, ~tio@

large variations occur from year to year. In general, the IDB does not show ranges of estimates to provide some measure of their uncertainty.

2A s~~pmjection made ~~dab ~m he 1$)88 IDB shows a go~to &ost e@t times he 1987 v~ue.However, the most KWd prOjtXtiOIl

in the 1990 IDB indicates a growth by the year 2013 to only 1.9 times the 1989 value.

q~b+ L. No. 94_580, 90 Stat. 2795 (1976) (c~l~ ~ mended at 42 us-c. 69014)7 (1982); 42 U,S<C. 6911.16, 6921-31, 694149, 6951.54,

6961-64,6971-79,6981-86 (1982)); amended by Solid Waste Disposal Act Amendments of 1980, Pub. L. No. 96-482,94 Stat. 2334 (1980) (cdtled

at 42 U.S.C. 6901-91 (i) (1982)); Hazardous and Solid Waste Amendments of 1984, Pub. L. No. 98-616,98 Stat. 3221 (codified at 42 U.S.C. 6924 (1984)).
Chapter 2--Managing Transuranic Waste at the DOE Nuclear Weapons Complex ● 55

U.S. Geological Survey (USGS). An interagency

agreement based on the Comprehensive Environmental Response, Compensation, and Liability Act4

(CERCLA) addressing remediation of nonoperating

disposal sites is awaiting Secretary Watkins’ approval. Studies of alternative remediation techniques will undoubtedly continue for some time.

Some technologies used for cleanup of buried

TRU waste sites could prove to be similar to those

used for LLW sites. However, EPA disposal requirements equate TRU waste with HLW and both are

currently slated for disposal in deep geologic repositories. A major effort is still required to sort out

which technology will be useful and cost-effective

for each waste situation, both for remediation of

buried TRU waste sites and for treatment of stored

TRU waste. The presence of hazardous components

mixed with radioactive materials must also be taken

into account.

In situ vitrification (ISV) is being investigated for

use in immobilizing radionuclides and hazardous

materials in contaminated soil or in buried drums.

Electrodes placed in the soil melt and then harden

the soil and its contents into a glasslike substance.

This technology, while promising, also has limitations, including high operating (energy) costs, applicability to relatively shallow soil depth and dry soil,

and possible worker hazards from strong electric

fields and from generated vapors. Economic analyses of the projected costs of ISV as a function of the

amount and nature of material to be immobilized are

necessary. The first full-scale ISV test has been

underway in a waste crib at Hanford that is a

high-priority cleanup site. Demonstration tests are

also being carried out at INEL.

One problem being studied at INEL in connection

with buried TRU waste is the development of

plumes of volatile organic compounds beneath the

surface that might accelerate the migration of

radionuclides to groundwater. Efforts are underway

to characterize the carbon tetrachloride plume under

the SDA and in the vadose zone. A vapor vacuum

extraction process for removing organic vapor from

subsurface areas is also being tested.

Storage and Treatment of Retrievable Stored

Transuranic Waste

Currently, stored TRU waste is usually found in

55-gallon drums placed on concrete or asphalt pads,

awaiting assay, treatment, and certification for

shipment to and disposal at the WIPP. The waste in

these drums is soluble, respirable, and not generally

fried in an immobilized matrix. The drums were

designed for a lifetime of 20 years, and some drums

have held TRU waste for that period. Six of eight

drums retrieved from a pad at INEL in late 1989 had

rust holes up to 4 inches in diameter; no leakage is

reported to have occurred because the waste was

contained in internal polyethylene bags. The duration of waste drum storage for TRU waste mixed

with contaminants considered hazardous under RCRA

is also limited by EPA land disposal restrictions.

According to the 1989 Five-Year Plan, six new

DOE facilities were scheduled to begin operation

during FY 1992-99 for processing, treating, and

certifying retrievable stored or newly generated

TRU waste for shipment to WIPP. Among the

technologies to be used in one or more of these

facilities are shredding, incineration, compaction,

and immobilization in grout or concrete. The first

facility that was scheduled to begin operation, the

Processing Experimental Pilot Plant (PREPP) at

INEL, has encountered both technical and regulatory problems and its future is uncertain. PREPP

incorporates rotary kiln incineration and an elaborate off-gas cleanup system to reduce radioactive

and hazardous gas releases. Although incineration as

a treatment technology has received considerable

attention from EPA, it has generally encountered

considerable public opposition.

A short-term problem facing DOE is what to do

about the mixed TRU waste at the Rocky Flats Plant.

The State of Idaho stopped accepting Rocky Flats

waste in late 1989, and Colorado, using its RCRA

authority set a limit of 1,601 cubic yards on the

amount of mixed TRU waste that can be stored. That

limit could be exceeded in 1991 or 1992. A further

problem involves a Federal District judge’s April

1990 ruling reclassifying some Rocky Flats residues

as waste. DOE and State officials have been

negotiating an Order of Consent to reflect the court

ruling; the conditions of the order will then be

d~b. L. Nc). 96-510, 94 Stit. 2’767 (1980) (codf:ed as amended in scattered sections of the I.R.C. and 33, 42, and 49 U. S.C.). Any reference to

CERCLA made throughout this paper should be construed as a reference to the 1980 statute, as amended by the 1986 Superfund Amendments and

Reauthorization Act and codified at 42 U. S.C.A. %01-11050 (West 1983 and Supp. 1990).
56 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

incorporated as part of the permit application for the

facility. DOE has also submitted a permit request

seeking approval for the operation of a volume

reduction unit (or supercompactor) to compact

certain existing wastes and improve current capacity.5

The Waste Isolation Pilot Plant

As of early 1991, the experimental phase at WIPP

still had not begun, and some obstacles remained to

be overcome. In 1990 legislation was proposed in

Congress to withdraw land from the public domain

for WIPP use but it did not pass. The legislative

debate on land withdrawal provided an opportunity

for those with concerns about WIPP to express them

and to attempt to build into the legislation certain

conditions to which DOE must adhere. Among the

concerns expressed were the need for compensation

to the State of New Mexico in the form of funds for

highway construction to bypass certain areas; limitation of the amount of waste that can be placed in

WIPP until DOE can demonstrate that EPA’s

disposal and no-migration standards for mixed TRU

waste can be met; resolution of certain technical and

safety issues related to the experiments; and debate

about the merits of providing independent, nonDOE regulation of the WIPP facility. However,

DOE bypassed the legislative route and land withdrawal was accomplished administratively in early

1991, even though the Department had stated that it

would prefer not to pursue this course of action.

In 1987, EPA standards for geologic disposal

were remanded by the court and may not be in effect

when the WIPP experimental phase begins. If so,

DOE might have to remove the waste at some future

date either to comply with new standards when they

are issued or because tests fail to support a determination that the standards can be met. Alternatively,

DOE could defer moving waste to WIPP, but then it

would continue to be stored on sites in States where

it is not welcome. The General Accounting Office

(GAO) has called for more contingency planning on

DOE’s part for waste storage. GAO has also

suggested that Congress consider placing some

restrictive requirements, such as limiting the amount

of waste that can be emplaced prior to issuance of

EPA disposal standards, in any legislation that may

be proposed to withdraw public lands for the WIPP

repository. The State of New Mexico has agreed to

DOE conforming, with the disposal standards vacated by the courts until new standards are issued.

The generation of gas in drums containing TRU

waste, in the form now planned for placement in

WIPP, is a problem that must be addressed. Some

have used currently available information on gas

generation rates to predict that within 50 to 100 years

after disposal in WIPP, the buildup of gas due to

corrosion of the carbon steel drums and to radiolytic

and biological degradation of organic materials

could reach pressures at which salt might be

fractured or pushed back and radioactive or hazardous materials might escape from the repository.

Although DOE and its contractors are studying the

problem and hope to obtain additional information

from the initial tests at WIPP to supplement earlier

information, some experts feel that modifying the

current waste form to either reduce or eliminate gas

generation will be necessary. By treating the waste

with methods ranging from compaction to immobilization, to reduce or eliminate gas generation, uncertainty concerning long-term repository behavior and

the vulnerability of the repository to both undisturbed and human intrusion scenarios could be

lessened. However, treating TRU waste, particularly

by methods that should be most effective in eliminating gas generation (i.e., incineration or vitrification) would require a substantial increase in funding

as well significant changes in DOE waste management plans and facilities, would cause commensurate delays, and could increase worker radiation

exposures.

Interested parties disagree on the value of the

WIPP experimental phase as it is presently defined.

Questions have arisen as to whether certain experiments will provide the information required to

determine whether EPA disposal standards can be

met, or whether some experiments might be performed more expeditiously outside of WIPP. In

addition, although a task force created by DOE is

studying alternative forms, as of late 1990, the initial

experiments planned for WIPP did not appear to

include certain alternative waste forms that would

generate less gas than the existing preferred form.

WIPP was authorized by Congress as a research and

development facility to demonstrate safe disposal of

TRU waste; yet, as it is now constituted, the program

proposed by DOE does not appear to have convinced

its critics that all important concerns have or will be

addressed.

SF. Dowset~ Colorado Department of Health, personal commticatiou Jm. 4, 1991.
Chapter 2-Managing Transuranic Waste at the DOE Nuclear Weapons Complex ● 57

Standards, Regulations, and Oversight

EPA disposal standards represent the primary line

of defense for public health and safety against

radioactivity from TRU waste. These standards,

promulgated in 1985, are being reformulated because they were vacated in June 1987 following a

court challenge. New standards were expected to be

proposed by EPA in late 1990 (they were not) and

finalized by 1992. Concern has been expressed

about DOE’s ability to meet these standards without

changing the waste form or using engineered barriers, particularly under human intrusion scenarios.

DOE does not expect to be in a position to

demonstrate compliance until the performance assessment is completed in 1995; it views the WIPP

experimental phase as not requiring such compliance because the waste for the experiments will be

retrievable. EPA concurs with this positioned Efforts

to weaken the standards have been opposed by the

Environmental Evaluation Group (EEG), the federally mandated WIPP oversight group associated

with the State of New Mexico.

Independent technical oversight of WIPP by EEG

is valuable to the process of developing a viable

disposal facility and enhances DOE’s credibility.

Although other oversight mechanisms utilized by

DOE provide useful inputs, EEG’s full-time, longterm presence, permanent staff and consistent resources are unique elements that contribute to its

effectiveness. Also of importance is EEG’s ability to

remain independent of DOE, even though its funding comes from the Department,

Much TRU waste is mixed (radioactive and

hazardous) waste to which RCRA regulations apply.

DOE has requested a no-migration variance for

waste to be placed in WIPP, arguing that hazardous

waste will not move off-site. In April 1990, EPA

proposed to grant DOE’s request for the experimental phase only, with a decision on the operational

phase to be made later. EPA approval of the WIPP

no-migration petition for the test phase followed on

November 1, 1990, subject to several conditions,

including testing of gases from each of the waste

drums to be placed in WIPP during the test phase.

With regard to mixed TRU waste stored at DOE

facilities, storage or disposal of such waste is

generally prohibited by EPA under land ban restrictions unless the waste has been treated in an

EPA-approved manner. However, in light of the

limited capacity available nationwide to treat mixed

TRU waste, EPA issued a 2-year variance on June 1,

1990, to provide sufficient time for building the

capacity required to treat the mixed waste generated

and stored at facilities in the DOE Weapons Complex. As a result, DOE is not required to comply with

the treatment and disposal requirements applicable

to mixed waste under RCRA until 1992.

Research and Development, Waste

Minimization, Transmutation

The DOE Applied Research, Development, Demonstration, Testing, and Evaluation Plan (47) singles

out three specific areas for TRU (retrievable stored

or newly generated) waste management: better

waste treatment to meet WIPP certification requirements; disposal options for waste not certifiable for

WIPP; and better characterization of RCRA components in waste for certification. The plan lists a

number of technologies that might prove useful for

the buried waste remediation effort but does not

evaluate them. A process for doing so may be

underway in connection with updates of the FiveYear Plan.

Minimizing waste from plutonium manufacturing

and processing can reduce the amount and radioactivity of TRU waste. Among the opportunities for

such minimization, according to DOE, are forming

blanks closer to final size, improving machining

precision, using robotics and automation in handling, and improving plutonium recovery by using

fewer chemicals and producing less plutoniumbearing waste. However, to date, DOE is not very far

along in the TRU waste minimization area. The most

substantial TRU waste minimization has likely been

a result of the shutdown of operations at Rocky Flats

since late 1989.

Transmutation is believed by some to be an

attractive concept for minimizing TRU waste.7 It

involves separating (partitioning) long-lived TRU

and other radionuclides from the waste stream for

recycling and subsequent conversion (transmutation) to shorter-lived radionuclides by nuclear reactions in a reactor or an accelerator, thereby reducing

the time required for the radioactive wastes to decay

~s position is inconsistent with tbe parallel case of the Yucca Mountain, NV, HLW repository. There, the NRC requires demonstrated compliance

with long-term disposaJ standards before construction can begin.

T~e p~~e ac~de conv~sion is used by some to Ctictefi~ WS Promss.
58 . Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

to acceptable levels after disposal. One reason given

for continued finding of the Fast Flux Test Facility

at Hanford is for just this purpose. However,

transmutation is still in the research stage; it is not a

part of recent DOE 5-year waste management

operations plans, nor is it likely to prove useful for

TRU waste management over the next 10 years.

These are also significant obstacles to transmutation

becoming a major factor in TRU waste management

over the long-term.

Transuranic WASTE AT

DEPARTMENT OF ENERGY SITES

Definition and Background

In the United States, TRU waste is largely unique

to the defense program and arises primarily through

reprocessing of plutonium-bearing fuel and irradiated targets, and from the many operations required

to manufacture plutonium in the form and grade

required for use in nuclear weapons.8 Some TRUcontaminated waste is also generated by remedial

action projects as well as by decommissioning and

decontamination n activities. TRU waste includes

metal, glassware, process equipment, tools, soil,

laboratory waste, rubber gloves, ion-exchange resins, filters, clothing, rags, and paper products

(55,77). Among the TRU waste forms are absorbed

liquid or sludge, combustibles, dirt, gravel or

asphalt, and concreted or cemented sludge. Much

TRU waste is mixed waste, containing both radioactive and hazardous components. Box 2-A contains

current definitions of TRU waste.

TRU waste clearly is managed much more

carefully now than it was 20 years ago. Until that

time, it had been handled in a fashion similar to

LLW---dumped into trenches or pits and covered

with earth. In 1970 the Federal Government began to

store TRU waste for easy retrieval rather than

burying it in pits and trenches (77). One reason for

the earlier lack of rigor in handling certain forms of

Transuranics might have been that the radioactivity

associated with items such as contaminated clothing

was not very large compared with the radioactivity

associated with liquids from reprocessing plants.

According to table 2-1, the TRU radionuclide that

is preferred as a nuclear weapons material, plutonium239, has a half-life of 24,400 years. Plutonium-239

is toxic in very low concentrations, with the primary

health threat coming from the inhalation of material

that lodges in the lungs and emits heavily ionizing

alpha particles that are readily absorbed and could

produce carcinogenic effects. The staying power of

the long-lived, radioactive Transuranics, coupled

with their toxicity when inhaled or ingested, necessitates their careful handling, treatment, and disposal.

Table 2-l-Some Transuranic Radionuclides and

Their Half-Lives

Element Atomic weight Half-life (years)

Neptunium . . . . . . . . . . 237

Plutonium . . . . . . . . . . 238

239

240

241

242

Americium . . . . . . . . . . 241

243

Curium . . . . . . . . . . . . . 244

245

2.14 X 106

86

24,400

6,580

13.2

3.79 x 105

458

7,950

17.6

9,300

SOURCE: M. Benedict, T.H. Pigford, and H.W. Levi, Nuclear Chemkd

Engineering, 2d ed. (New York: McGraw-Hill, 1981), pp. 976-

977.

Sone exception t. ws s~tment is TRU waste produced during reprocessing of commercial reactor fuel at West Valley, NY, between 1966 and 1972.
Chapter 2--Managing Transuranic Waste at the DOE Nuclear Weapons Complex . 59

Figure 2-l—Total Volume of Retrievable Stored DOE Transuranic Waste Through 1988

Nevada(l .0%)

Oak Ridge(3.2%)

Savannah River (5.50/0)—,

Los Alamos( 12.1%

Hanford( 16.8%)

Site Volume

(thousand cubic

meters)

Nevada 0.60

Oak Ridge 1.91

Savannah River 3.30

Los Alamos 7.19

Hanford 10,00

Idaho 36.70

Total 59.50

ldaho(61.4%)

SOURCE: U.S. Department of Energy, “Integrated Data Base for 1989,” DOE/RW4006, November 1989.

In 1984, the level defining the lower concentration limit for TRU waste was increased from 10 to

100 nanocuries per gram. Waste that contains

Transuranics below this level can be treated as LLW.

The latter level was reportedly chosen ‘‘because it is

similar to the level of the naturally occurring TRU in

ore’ (17). Another consideration may have been the

cost savings for treatment and disposal. In addition,

new assay techniques permitted determining TRU

concentrations down to the 100 but not the 10

nanocuries per gram level. Some issues concerning

the definition of TRU waste are discussed later.

Amount and Distribution

Some Integrated Data Base Estimates

The 1989 DOE Integrated Data Base provides the

following information on TRU waste at DOE

weapons sites at the end of 1988. TRU waste

radioactivity, estimated at 3.94 million curies, is

about 0.34 percent that of defense HLW and about

30 percent of defense LLW (76). On the other hand,

its volume, 251,000 cubic meters, is 65 percent that

of HLW and 10 percent of LLW (76).

TRU waste is more widely distributed geographically than high-level waste. Figure 2-1 shows the

total volume of retrievable stored9 TRU waste

through 1988 (78). This waste is spread over six

sites, ranging from the Idaho National Engineering

Laboratory (INEL) with 61 percent of the total to the

Nevada Test Site with 1 percent of the total. The

estimated volume of buried TRU waste is more than

three times the volume of retrievable stored TRU

waste (80). Buried TRU waste is also located at six

sites, five of which contain retrievable stored TRU

waste. Hanford has the largest share of buried TRU

waste by volume (57 percent) followed by INEL (30

percent). The IDB estimates that the radioactivity of

buried TRU waste is less than 2 percent that of

retrievable stored TRU waste (83). However, buried

waste estimates are subject to great uncertainty.

Figure 2-2 shows both points of origin and storage

sites of DOE TRU waste. Although five sites are

-U waste is divided in the IDB into retrievable stored waste and buried waste. Estimates of the amounts of retrievable stored waste are likely to

be the more accurate because some buried waste locations may not be known or characterized. No TRU waste was buried aftex 1978 (78). Presumably,

buried waste volumes are educated guesses, aided in part by some historical inquiry and records. Less uncertainty is associated with the amounts of

retrievable stored waste. In the pas~ DOE designated all waste tbat contained Transuranic materials as TRU waste, whether or not significant separable

amounts of LLW waste were also present. However, more recently, driven by limitations on storage of mixed waste at Rocky Flats, DOE has been

increasing its use of nondestructive assay techniques to segregate TRU waste horn LLW. Sampling efforts have led DOE to estimate that 38 percent

of all stored waste originally categorized as TRU waste is in fact LLW, and TRU waste inventories have been lowered accordingly (80). Further changes

can be expected.
60 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

Figure 2-2—Points of Origin and Storage Sites of DOE Transuranic Waste

Engineering Laboratory @

National Laboratory

Savannah River Site

O Generators of TRU

x Storage site

■ R&D Facility

SOURCE: U.S. Department of Energy, “Integrated Data Base for 1989,” DOE/RW-0006, November 1989.

indicated as waste generators only, some interim

storage of TRU waste is taking place at the Rocky

Flats Plant as a result of a decision in September

1989 by the Governor of Idaho not to accept any

more shipments of TRU waste from Rocky Flats.

Other generator locations shown on figure 2-2 but

not included in figure 2-1, also have TRU waste

on-site.

Figure 2-3 shows the distribution among sites of

contact-handled versus remote-handled TRU waste.

According to table 3.5 of the 1989 IDB, 88 percent

by volume (62 percent by radioactivity) of the

“hotter,’ remotely handled stored waste is at Oak

Ridge National Laboratory (ORNL) (81). From that

table, remote-handled stored waste can be estimated

at 1.6 percent of the total volume (3.6 percent of the

radioactivity) of stored TRU waste (81). In contrast

to contact-handled TRU waste, which emits predominantly alpha radiation, remote-handled TRU

waste has significant amounts of the more penetrating non-alpha radiation (garoma, beta, or neutrons).

More than half (56.5 percent) of the total 1988 alpha

radioactivity of retrievable stored, contact-handled

waste is at Savannah River, some 653,000 curies.

The alpha radioactivity at INEL, 73,000 curies,

constitutes about 60 percent of all buried TRU alpha

radioactivity (82).

Figure 2-4 shows total system inventories, projections, and characteristics of all buried and stored

TRU waste as of 1988, projected in 5-year increments through the year 2013.10 Several items should

be noted: buried waste in 1988 is indicated as having

l~e use of different estimating metio~ in the IDB leads to considerable Mlcldty b s~”mg TRU waste inventory information. Values of

radioactivity in figure 2-4 were calculated by using estimated isotopic compositions for TRU waste and a computer model. Volumes of stored waste

are stated to be “certified TRU waste” and to exclude waste mamged as LLW. On the other hand, values for figure 2-3 were derived from data provided

by the field offices that include estimates of volume and alpba radioactivity for waste certi.fkd as TRU waste plus stored waste to be managed as LLW.

Using figure 24 to compute the percentage of radioactivity associated with remote-handled waste gives results very different from figure 2-3.
Chapter 2--Managing Transuranic Waste at the DOE Nuclear Weapons Complex . 61

Figure 2-3—Volume of Retrievable Stored Contact-Handled (CH) and Remote-Handled (RH)

Transuranic Waste Accumulated Through 1988

CONTACT-HANDLED TRU WASTE REMOTE-HANDLED TRU WASTE

TOTAL: 58,196 CUBIC METERS TOTAL: 1,485 CUBIC METERS

Oak Ridge(l .OO/~) Los Alamos(l.0%)

r(6.0°/0)

.0%)

Ida Oak Ridge(88.0%)

SOURCE: U.S. Department of Energy, “Integrated Data Base for

only 1.6 percent the radioactivity of total

1989,” DOE/RW-0006, November 1989.

TRU

waste, ll although its volume is more than three times

that of stored TRU waste; large annual increases in

the radioactivity of stored, contact-handled waste

are projected through the year 2013; there is a very

large projected increase in the radioactivity of total

stored waste to the year 2013, to more than 3.5 times

the 1987 value. The last item is in marked contrast

to the current projections of little or no change in

total radioactivity of stored high-level waste over the

same time period. (See ch. 1.)

Changes in Estimated Amounts

The 1989 IDB contains some major changes in

TRU waste estimates (77). The value given there for

the radioactivity of buried TRU is only 25 percent

that given in the IDB for the previous year (74). This

major reduction in radioactivity is due primarily to

a drastic change in the reported radionuclide composition of Hanford buried waste from almost all

plutonium-239 to almost all uranium.12 The change

may be indicative of uncertainties in the IDB.

A highly significant change took place in estimates of TRU retrievable stored waste between the

1987 and 1988 IDB. Some 38 percent of what had

been classified as TRU waste was reclassified as

LLW. There were also some substantial upward

revisions of estimates of the radioactivity of contacthandled TRU waste at Hanford and Savannah River,

as well as a drop in the radioactivity of remotehandled waste at ORNL. By contrast with the

relatively minor changes from year to year in HLW

inventories, the large changes in TRU inventories

appear to reflect greater uncertainties in these

estimates.13 The uncertainties are probably greater

for buried waste, although information on stored

llIt should be noted that radioactivity estimates of buried TRU waste are highly Unce*.

jz~e~, J. A., oak Ridge National Laboratory, personal communication Apr. 16, 19W.

13~~ bwomes pfic~aly fipo~t fi ~c~g the ~omt of waste sched~~ to be shipped to tie Waste Isolation Pilot Plant (WIPP). It haS been

pointed out that a tenfold reduction in the total radioactivity of remote-handled TRIJ waste destined for WIPP occurred fi-om the final WIPP

Environmental Impact Statement (EIS) to the supplementary EIS (23). Because this amount includes waste yet to be generated as well as stored waste,

the reduction could be due to changes in the projected amount of waste to be generated, changes in the estimates of existing waste, or some combination

of both. The IDB is of no help in sorting this out.
62 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

Figure 2-4—TotaI System Inventories, Projections, and Characteristics of All Buried

and Stored DOE Transuranic Waste

L

350

300

250

200

150

100

50

0

6

i

.

Notes:

a. Annual rate is for the indicated Year only. ❑ Buried

b. No TRU waste was buried after 1978. -

c. All TRU waste is certified and excludes waste managed as LLW.

d. The destination of TRU waste after 2013 will not be defined until 2002.

e. Total mass does not include values for Hanford. k
Chapter 2--Managing Transuranic Waste at the DOE Nuclear Weapons Complex ● 63

Figure 2-4—Total System Inventories, Projections, and Characteristics of All Buried

and Stored DOE Transuranic Waste-Continued

u

c

CD

14

12

10

8

6

4

2

0

Notes:

a. Annual rate is for the indicated year only.

b. No TRU waste was buried after 1978.

c. All TRU waste is certified and excludes waste managed as LLW.

d. The destination of TRU waste after 2013 will not be defined until 2002.

e. Total radioactivity and thermal power do not include values for Hanford.

Ilii!il. Buried

❑ Stored CH

❑ Stored RH

KEY: CH==contact-handled; RH-remote-handied.

SOURCE: Adapted from U.S. Department of Energy, “integrated Data Base for 1989,” DOE/RW-0008, November 1989.
64 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

Table 2-2—lnventories and Characteristics of Soil Contaminated With

DOE Transuranic Waste Through 1988

Mass of TRU TRU alpha

Volume nuclides radioactivity y

Site (cubic meters) (kilograms) (curies)

Hanford Plant . . . . . . . . . . . . . . . . . . . . . . . . 31,960 190.2 16,706

Idaho National Engineering Laboratory . . . 56,000-156,000 a a

Los Alamos . . . . . . . . . . . . . . . . . . . . . . . . . . 1,140 a a

Mound Plant . . . . . . . . . . . . . . . . . . . . . . . . . 300-1,000 0.009-0.029 150-526

Oak Ridge National Laboratory. . . . . . . . . . 13,000-61 ,000b a a

Savannah River Site . . . . . . . . . . . . . . . . . . 38,000 a a

Total . . . . . . . . . . . . . . . . . . . . . ........140,400-289,100 a a

aRep@~ as unknown.

blf soil ~ntaining TRUwa~te an be isolated from 1,~o,ooo cubic meters of soil mntaining TRLJ and IJY/waste. Total

also includes 1,000 cubic meters of contaminated soil around tanks.

SOURCE: U.S. Department of Energy, “Integrated Data Base for 1989,” DOE/RW41008, November 1989.

waste is also difficult to interpret. The stored waste

appears to be undergoing systematic assay, which

will result in reclassifying some TRU waste as LLW.

In the meantime, attempts to utilize data in the IDB

should be viewed with caution; the data lend

themselves to manipulation because some waste

may not have been identified and documented; in the

past, different facilities have used different data

gathering procedures. Some improvements have

taken place in the IDB; hopefully, more will be

forthcoming.

Table 2-2 provides a partial estimate of inventories and characteristics of soil contaminated, with

DOE defense TRU waste through 1988, Only the

radioactivity at Hanford and Mound are estimated,

with the latter reporting a large range whereas

Hanford provides a specific number estimate to five

significant figures. A range of volumes is given for

the Idaho National Engineering Laboratory (INEL)

and the Oak Ridge National Laboratory (ORNL),

indicating great uncertainty in the estimates; furthermore, at least for Oak Ridge, the volumes are

predicated on being able to separate TRU waste from

a much larger volume of soil containing both TRU

and LLW. The values of volume and mass in table

2-2 are characterized as ‘‘very difficult to accurately

determine“ (77).

Waste Management: Present and Planned

Major changes in the management of TRU waste

are underway at DOE facilities. Prior to 1970, TRU

waste was disposed of by shallow land burial and not

distinguished from LLW. By the end of this century,

DOE plans to begin to dispose of TRU waste by

placement of “certified’ packages in a deep geologic repository. The transition from pre-1970 to

21st century practices involves a complicated set of

technical and regulatory developments.

Beginning. in 1970 (61), a policy was implemented that is characterized by monitored retrievable (interim) storage. For contact-handled TRU

waste, the approach taken by DOE and its predecessor agencies was construction of large concrete or

asphalt pads on which drums or boxes of waste could

be stacked, protected with weatherproofing material,

and, in some cases, periodically covered with earth.

Sumps were provided for collecting any moisture

present, and air sampling equipment measured

humidity and radioactivity. Six of its operations

offices are reported by DOE to manage such

facilities: Albuquerque, NM; Richland, WA; Idaho;

Nevada; Oak Ridge, TN; and Savannah River, GA.

Also stored are relatively small quantities of remotehandled TRU waste under conditions that provide

shielding from radiation. DOE asserts in the 1989

Five-Year Plan that no migration of radioactive or

chemical contaminants, has occurred (61). The

retrievable stored TRU waste packages were designed to last for at least 20 years (55); some of these

packages are now 20 years old.

It is DOE’s current policy that all stored or

yet-to-be-generated TRU waste, both contact- and

remote-handled, will be disposed of in a geologic

repository. According to the 1989 Five-Year Plan,

“the Waste Isolation Pilot Plant (WIPP) near

Carlsbad, New Mexico, will be the disposal facility

for TRU waste. A Waste Acceptance Criteria

Certification Committee, consisting of representatives from the Environmental Protection Agency

(EPA), the State of New Mexico, and DOE negotiated and established stringent criteria on the form of

waste acceptable at the Waste Isolation Pilot Plant’
Chapter 2-Managing Transuranic Waste at the DOE Nuclear Weapons Complex ● 65

(60). 14 Although some waste may be certified

acceptable at the point of generation, other waste

must be treated because it is known to be noncertifiable or because there is uncertainty about its

contents (60). Plans call for a five-year test phase at

WIPP, followed by a decision as to whether or not

the disposal phase should proceed.

WIPP was not designed to serve as a repository for

disposal of pre-1970 buried TRU waste, and DOE

has no plan yet for the disposal of that waste, should

it be removed from any existing sites. Some form of

treatment of buried TRU waste in place (in situ) is a

distinct possibility.

WlPP15 was originally scheduled to begin accepting waste in 1988. As of July 1990, although

construction of the facility was essentially complete,

no TRU waste had been placed in WIPP on any

basis, experimental or otherwise. In June 1990,

Secretary of Energy James Watkins made a positive

‘‘readiness decision, asserting that DOE was ready

to move ahead with a test phase that would involve

placement of a small amount of the contact-handled

TRU waste eventually planned for disposal. The

experimental phase is expected to begin in 1991. If

a positive decision is made to utilize WIPP as a

disposal facility, such operations could probably not

begin until 1995 or later. Many obstacles must be

overcome before WIPP can fulfill its mission and the

outcome remains uncertain. WIPP is discussed later

in this section.

Because TRU waste is stored at a minimum of six

Weapons Complex sites, a variety of facilities and

equipment exist for its handling and interim storage.

Some of these facilities were developed after the

1970 decision to retrievable store TRU waste but

before the 1980 decision to proceed with WFP.

Several sites began certifying waste for WIPP in the

mid 1980s. Existing facilities include the Stored

Waste Examination Pilot Plant at INEL; the TRU

Storage and Assay Facility at Hanford; the Size

Reduction Facility, Treatment Development Facility, and three other facilities at Los Alamos; the TRU

Waste Examination, Assay Facility at Oak Ridge;

and the Waste Certification Facility at Savannah

River. The Rocky Flats Plant also certifies virtually

all of its TRU waste at its own facility (56).

Figure 2-5 from the 1989 Five-Year Plan summarizes the six new facilities planned to begin operation during 1992-99 for processing, treating, and

certifying TRU waste-both retrievable and newly

generated—for shipment to WIPP. According to the

1989 Five-Year Plan, the Processing Experimental

Pilot Plant (PREPP) in Idaho will be the first facility

to process currently uncertifiable TRU waste;l6 it

will shred, incinerate, grout, and produce 55-gallon

drum packages. Also at INEL, the Retrieval Con-

,tainment Building (RCB) will allow for year-round

storage of drums in weathertight containment; the

Transuranic Waste Treatment and Storage Facility

will provide for examination, handling, shredding,

compaction, and repackaging of container contents.

The Transuranic Waste Facility at Savannah River

will retrieve waste from storage and will vent, purge,

shred, and repackage drums; reduce the size of and

repackage bulky waste; and solidify liquid waste.

The Waste Receiving and Processing Facility at

Hanford will inspect packages and perform assaying, repackaging, size reduction, compaction, sorting, shredding, and waste immobilization in grout. If

DOE decides it is necessary, incineration will be

included between the shredding and grouting operations. The Waste Handling and Packaging Plant at

Oak Ridge will process retrievable stored and newly

generated TRU waste into a WIPP-acceptable waste

form; it will also process remotely handled TRU

waste (60).

A June 1987 DOE document estimates that TRU

waste management costs for stored and newly

generated waste will be $3 billion through the year

2013; this figure is subject to modification. Cost

estimates of remedial action for buried TRUcontaminated waste and soil range from between

$200 million and $2 billion if waste and soil are left

in place, to between $6 billion and $10 billion if they

are exhumed and disposed of in a repository (57).

Figure 2-2 shows the points of origin and storage

sites for TRU waste. Note that there are more

generators than storage locations. Of particular

interest is the movement of TRU waste from Rocky

Flats to INEL, a path that has been blocked by the

Governor of Idaho since September 1, 1989, leading

ldEstablis~g the criteria appears to have been solely a DOE responsibility because both EPA and New Mexico’s Environmental Evaluation Group

have served on the committee in an advisory capacity only.

ls~e Waste Isolation pilot plant was authorized by the Department of Energy National Security and Military Applications of Nuc1= Energy Act

of 1980 (Pub. L. No. 96-164).

IGA~ough PREPp is shown with a 1992 start date in the 1990 Five-Year PlaQ its future, as of 1ate 1990, iS uncertain.
66 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

Figure 2-5-Planned Facilities To Process, Treat, and Certify Transuranic Waste for Shipment to the

Waste Isolation Pilot Plant

Processing Experimental

Pilot Plant (PREPP)

Idaho

Retrieval Containment

Building (RCB)

Idaho

Transuranic Waste Treatment

and Storage Facility (TWTSF)

Idaho

Transuranic Waste

Facility (TWF)

Savannah River

Waste Receiving and

Processing Facility (WRAP)

Hanford

Waste Handling and

Packaging Plant (WHPP)

Oak Ridge

Start

*

- ---- 7-

*-

----- -

*“

----- -

+-

----- -

+------ -

*“

----- -

Modifications Begin

Complete Operation

------------- 4 - -1- - - - - - - - - - - - - - - - - - - - - - -

Construction Construction Begin

Start Complete Operation

----------- 7 i--i -----------------------

Construction Construction Begin

Start Complete Operation

-------- ------------------- ---------- !

Construction Construction

M

Begin

Start Complete Operation

--------------- ----------- Y -r- -1------

Construction Construction Begin

Start Complete Operation

---------- .-. — ------------------- 7 7 - Y----

Construction

Start ---V ------------------- ------------------ -1 -

-------

-------

-------

-------

-------

Construction

Complete

------!

--

--

--

--

--

Begin

Operation

-- . 7

1

I I I I I I I I I

89 90 91 92 93 94 95 96 97 98 99

Fiscal Year

SOURCE: U.S. Department of Energy, “Environmental Restoration and Waste Management: Five-Year Plan,r’ DOf3S-0070, 1989.

to what has been called a storage crisis for Rocky

Flats TRU mixed waste.

Current and Potential Problems

Buried Waste and Contaminated Soil

During the roughly 25 years of the nuclear era

prior to 1970, waste ,contaminated with TRU elements was not distinguished from LLW and was

disposed of in the same manner. Such disposal

usually consisted of dumping contaminated clothing, metal, glass, other objects, and liquids into the

soil or into solid trenches that were covered with

soil. Information on how much, and where, such

waste is located at DOE weapons sites is incomplete.

The Integrated Data Base (77) indicates that the

largest volume of buried TRU waste is located at

Hanford, whereas the highest radioactivity of TRU

waste is buried at INEL (see table 2-3). In addition,

the IDB also gives some inventories and characteristics of soil contaminated. with TRU waste, with

INEL having the largest volume (see table 2-2);

however, the degree of uncertainty is evident from

the manner in which the volume is listed, ranging

from 56,000 to 156,000 cubic meters. Furthermore,

values of radioactivity for four of the six sites listed

in table 2-2 are said to be unknown.

Information about buried TRU waste sites and

TRU contaminated soil is far from complete. Information is scarce about the location of these sites, the

extent and makeup of contamination, and the extent

of migration of radioactive nuclides. A coordinated

effort to explore the history of the sites, employing—

among other techniques-inter-views with retired

workers, could aid in locating and characterizing

buried TRU waste.

Throughout the DOE Nuclear Weapons Complex,

TRU waste was buried prior to 1970 under conditions that led to the uncontrolled release and

migration of radionuclides into the environment.

Various DOE Environmental Survey reports indicate that buried TRU waste has caused environmental contamination in at least three facilities: the

Savannah River Site, INEL, and Los Alamos National Laboratory. Data on the extent of contamination from buried TRU waste at these and other sites

are sketchy, but the following examples provide

some insight into possible risks.

1. Idaho National Engineering Laboratory: At

INEL, TRU waste was received for nonretriev-
Chapter 2---Managing Transuranic Waste at the DOE Nuclear Weapons Complex ● 67

Table 2-3—lnventories and Characteristics of DOE Buried Transuranic Waste

Through 1988

Values reported by storage site as of Dec. 31, 1988

Mass of TRU TRU alpha

volume nuclides radioactivity

Site (cubic meters) (kilograms) (curies) b

Hanford a. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109,000 346 29,200

Idaho National Engineering Laboratory . . . 57,100 357 73,267

Lawrence Livermore . . . . . . . . . . . . . . . . . . . 14,000 53.5 9,230

Oak Ridge National Laboratory. . . . . . . . . . 6,200 5.6 270c

Sandia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 1 1

Savannah River Site . . . . . . . . . . . . . . . . . . 4,534 9.1 9,831

Total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 190,837 771.2 121,799

a[ncludes soil mixed with buried waste.

b~ reP@ed by storage sit=, it does not i~lude beta and gamma radioactivity or radiation from decay products.

cTotal of all radioactivity.

SOURCE: U.S. Department of Energy, “Integrated Data Base for 1989,” DOE/RW4008, November 1989.

able burial in shallow pits from 1954 to the

1960s at the Radioactive Waste Management

Complex (RWMC), an area that expanded from

13 to 88 acres during this period. An environmental survey performed in 1987 included a

review of monitoring records; interviews with

EPA, DOE, and State personnel; and sampling

and analysis of selected media. According to

preliminary DOE survey results (66), plutonium238 and 239 and americium-241 were detected

at above-background levels in the RWMC,

with the highest concentrations in surface soil

at the perimeter drainage area where water

drains from the top of the subsurface disposal

area (SDA). Plutonium contamination was

detected and americium contamination, was

estimated to have moved thousands of feet from

the burial site. High concentrations of contaminants near the perimeter of the site were

believed due to floods in 1962 and 1969, as well

as to localized drainage of water from the

surface. Lower concentrations away from the

site perimeter were believed to result from wind

transport. On completion of these studies,

portions of the burial ground were covered with

additional topsoil from noncontaminated areas

and seeded for ground cover. Other improvements were also made, such as grading to

improve drainage and to lower the potential

spread of contamination.

According to the INEL survey, studies indicate the presence of plutonium-238 and 239 at

the 110-foot interbed beneath the RWMC. The

present contractor, EG&G, claims that the

concentrations involved do not present a health

concern for the near future, because the plutonium is strongly bound to soil particles in the

sediment of the interbed layer. This contrasts

with the relative ease of plutonium transport

through fissured lava. Groundwater is located

some 200 feet beneath the RWMC and is

contaminated with volatile organic compounds.

The survey expressed concern that plutonium

could have migrated with these organics but to

OTA’s knowledge, no evidence of this has been

reported.

2. Los Alamos National Laboratory (LANL): At

LANL, the first solid waste disposal area, a

6-acre landfill known as MDA-B, opened in

1945 and closed in 1950. DOE has stated that

radioactive waste in the landfill is likely to

include plutonium, polonium, uranium, americium, curium, lanthanum, actinium, and mixed

fission products. Waste was reportedly packaged in cardboard boxes or wrapped in paper;

an inventory of waste volume and radioactivity

is not available. Hazardous waste chemicals

placed in MDA-B include organics, perchlorates, ethers, solvents, and corrosive gases.

It is uncertain whether the landfill is one

large, continuous pit or a series of six pits.

During its operation, waste was probably not

covered daily and spontaneous fires also occurred. These past operational practices could

have allowed contaminants to migrate beyond

the present fenced portion of the landfill, which

is located very close to the edge of a mesa top;

therefore, the canyon wall on the downslope

side of MDA-B may have received contaminated runoff. In addition, waste placed in

MDA-B may be a continuing source of contamination to subsurface soil and the vadose zone

(67).
68 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

Similar contamination may have occurred

from the MDA-C inactive landfill, which

operated from 1948 to 1974 for disposal of both

radioactive and chemical waste. As of January

1973, approximately 50,000 curies of radioactive material was present, including uranium

isotopes, plutonium-239, americium-241, tritium, fission products, and induced radioactivity; chemical waste included pyrophoric metals, hydrides, powders, and compressed gases.

Waste pits and most of the waste shafts were

unlined. Only in 1984 were surface stabilization measures completed at MDA-C, which

may help to reduce the potential for downward

migration of contaminants.

3. Savannah River: Here, the Radioactive Waste

Burial Grounds are used for disposal of a

variety of waste, including TRU waste. Until

1965, TRU waste was loaded into plastic bags

and cardboard boxes that were buried in earthen

trenches. Between 1965 and 1974, TRU waste

was segregated into two categories: waste with

a radioactivity level of 0.1 curie per package or

higher was either buried in retrievable concrete

containers or encapsulated in concrete; waste

with radioactivity lower than 0.1 curie per

package was buried unencapsulated in trenches.

Since 1974, TRU waste with radioactivity

higher than 10 nanocuries per gram has been

stored on an interim basis in watertight containers that can be retrieved intact up to 20 years

from the time of storage. DOE monitoring

wells have detected contaminated groundwater

within and at the edges of the burial ground.

The gross alpha levels measured are several

times those permitted by drinking water standards. According to the DOE 1987 Environmental Survey for the site, monitoring and

characterization are quite incomplete (68,93).

In 1987, DOE set forth, in general terms, a plan for

buried TRU-contaminated waste and soil as follows:

“to characterize the disposal units; assess the

potential impacts from the waste on workers, the

surrounding population, and the environment; evaluate the need for remedial actions alternatives; and

implement and verify the remedial actions as appropriate” (57). However, DOE has just begun this

process. Characterization of, and strategies for

dealing with, buried TRU waste and contaminated

soil are in the very early stages.

A panel of the National Academy of Sciences is

monitoring the DOE environmental restoration program dealing with buried TRU waste at INEL. At a

November 1989 meeting of the panel, some of the

problems encountered were summarized by DOE as

follows: “site characterization needs to be much

more developed;” ‘‘waste migration needs better

definition;” “ a decision process [for what to do with

the buried waste] with well-developed evaluation

criteria needs to be implemented;” and “where the

waste would be placed, once retrieved, is open to

question." 17 With regard to the last point, it was also

stated that DOE may not want to set a precedent by

removing buried waste from Idaho.

A number of specific technical studies conducted

for DOE were reported at the National Academy of

Sciences meeting. One of these highlights a problem

associated with buried waste, namely, the development of volatile organic compound plumes beneath

the surface that might serve to accelerate the

movement of radionuclides beneath the soil to

groundwater. Efforts are underway to characterize

the carbon tetrachloride plume in the vadose zone

under the RWMC area at Idaho and to demonstrate

a technology known as vapor vacuum extraction for

removal of subsurface organic vapors.l8

Waste Storage

Implementation of the 1970 decision to store

TRU-contaminated waste so it would be retrievable

for future disposal in a geologic repository has

resulted in waste being stored at several DOE sites,

usually in 55-gallon steel drums placed on concrete

or asphalt pads. The integrity of the drums is of

concern for two reasons: drum storage was meant to

bean interim measure, and some drums have already

held TRU waste for 20 years, the nominal design

lifetime for these packages (55); and the WIPP

repository is not expected to accept TRU waste for

disposal until 1995 at the earliest, and possibly much

later. Furthermore, after WIPP does open, it will take

20 to 30 years to fill the repository and a significant

portion of DOE’s TRU waste will still have to be

stored for long periods of time pending shipment to

WIPP.

ITS@tements made by a U.S. Depzutrnent of Energy representative d~gs ummation at National Academy of Sciences Panel to Review the DOE

Assessment of Pre-1970 Buried Waste at the Idaho National Engineering Laboratory, Nov. 14, 1989.

18R.R. Piscitefla, EG&G-I&&o, “vapor Vacuum Extraction Demonstration Update, ” presentation with view graphs to National Academy of Scimces

Panel to Review the DOE Assessment of Pre-1970 Buried Waste at the Idaho National Engineering Laboratory, Nov.13, 1989.
Chapter 2--Managing Transuranic Waste at the DOE Nuclear Weapons Complex ● 69

The Pad A Initial Retrieval Project at INEL was

defined as part of a Resource Conservation and

Recovery Act (RCRA) Facility Investigation Work

Plan to determine, among other things, waste

container integrity for drums of TRU waste received

from Rocky Flats and stored at INEL in 1970-77, as

well as associated radiological or hazardous contamination of the soil. In 1989, eight drums were

reportedly retrieved from Pad A, of which six had

rust holes up to 4 inches long; an EG&G project

engineer is quoted as saying that even where the

drums have corroded, internal polyethylene bags

have contained the waste, mostly contaminated

clothes, tools, and rags (12).

Along with the obvious technical concerns about

container integrity, there are also regulatory problems. Much of DOE’s stored TRU waste is mixed

waste; that is, it has both radioactive and hazardous

components. The duration of TRU waste storage at

a particular DOE site is limited by EPA land disposal

restrictions for mixed waste.

State governments are a major factor in regulating

stored TRU waste. A situation that received a great

deal of attention during 1989-1990 began on September 1, 1989, when the Governor of Idaho refused

to permit further shipment of TRU waste from

Rocky Flats to INEL (42).19 The State of Colorado

had established a limit to the amount of mixed TRU

waste that could be stored at Rocky Flats. At first,

DOE was quite concerned that the limit would be

exceeded rapidly, forcing shutdown of Rocky Flats

plutonium fabrication operations. However, the

situation eased somewhat as a result of several

factors: Rocky Flats has been shut down since late

1989 for various safety reviews and is thus generating less waste; efforts are moving ahead to assay or

reassay stored TRU waste; both waste minimization

and efforts to separate the hazardous and radioactive

components of TRU mixed waste have reduced

storage space requirements.

20 In April 1990, the

situation took another dramatic turn when a Federal

District judge in Denver ruled that thousands of

drums of plutonium-containing material that DOE

had considered “residue’ (i.e., material from which

plutonium would be recovered for future use) was in

fact mixed waste subject to the State of Colorado

imposed storage limit under RCRA (88). If this

ruling were to be implemented, the Colorado storage

limit for mixed TRU waste would have been

exceeded. However, to date, the State of Colorado

has not pursued implementation of this ruling and,

instead, has been negotiating an agreement with

DOE to resolve this matter.

DOE is pursuing several alternatives, mostly in

response to the Rocky Flats situation for storage of

mixed TRU waste. These include persuading the

Governors of several States with weapons sites to

accept some portion of the Rocky Flats waste;

storing the waste at Department of Defense facilities; and storing the waste at a privately owned

facility .21 In February 1990, DOE announced that it

was seeking proposals of plans for a privately owned

and licensed facility for interim storage of TRU

waste, including transportation from DOE generator

sites and subsequent shipment to WIPP for disposal

(91);22 the waste would remain the property of the

Federal Government.

Plutonium Handling and Contamination

at Rocky Flats

The Rocky Flats Plant is DOE’s facility for

fabricating, assembling, and quality testing components to be placed in the triggers of thermonuclear

weapons. As such, it carries out various plutonium,

uranium, and beryllium production activities, as

well as recovery by chemical processing of plutonium and americium from retired weapons and

fabrication process residues (21). Its plutonium

mission makes Rocky Flats a major generator of

TRU waste.

Problems reported to have occurred at Rocky

Flats since it began operating in 1952 include

contamination, injury, and death of workers, attributed to accidents, spills, and fires (l). Retired Rocky

Flats workers are suing for compensation, alleging

that their cancers were due to radiation exposure. A

1957 fire resulted in release of an unknown amount

of plutonium to the air; soil was also contaminated.

In January 1990, eight current Rocky Flats workers

and four retired workers had reportedly tested

19GA0 ~~ ~onclud~ ~ ~ Jue 1, 1989, letter Opfiion to Representative SW tit mere was no ]eg~au~ority for the Governor’s action. However,

DOE has not pursued legal action to reverse it.

T.S. Department of Energy congressional briefing on WIPP Decision Plan and Alternative Storage for Rocky Flats Plant Tramuranic Waste, Feb.

22, 1990.

21~ido

%id., viewgraphs.
70 ● Long-Lived Legacy: Managing High--Level and Transuranic Waste at the DOE Nuclear Weapons Complex

positive for berylliosis, an incurable disease that

results from exposure to beryllium dust and is fatal

to about 30 percent of those who contract it (9). Also

in January 1990, two labor unions and Rocky Flats

area residents filed two class-action lawsuits against

Rockwell International Corp. and Dow Chemical

Co., the two primary operating contractors at Rocky

Flats prior to EG&G, alleging that careless and

negligent treatment of hazardous waste had threatened their health and hurt them financially (10). In

1988, the State of Colorado cited Rocky Flats for

nine violations of hazardous waste disposal laws.

There has been persistent concern about plutonium releases to the air, as well as plutonium

contamination of soil and groundwater. These concerns have received increased attention because 1.4

million people live within 50 miles downwind of the

plant.

A 1989 report by Scientech, Inc., indicated the

presence of plutonium in ventilation pipes downstream from certain falters that should have prevented it from getting there. The Scientech team

concluded that a criticality23 incident had not taken

place but indicated that such an occurrence was not

impossible under certain circumstances; the report

was critical of Rockwell management practices (41).

More recently, EG&G revealed that ventilation

piping and ducts contain 28 kilograms of plutonium,

more than twice that estimated by the Scientech

team and enough to make six or seven nuclear

weapons (38).

The DOE ‘‘Tiger Team"24 report on Rocky Flats

was released in August 1989 (54). Figure 2-6 is a

summary of the principal observations listed in the

executive summary of the report. The seriousness of

the Rocky Flats situation is evident from the

information presented above as well as the following: a June 1989 raid on the plant by the Federal

Bureau of Investigation to investigate various violations, including the alleged running of an incinerator

to burn hazardous waste against orders (7); withdrawal of Rockwell International as the principal

operating contractor for the plant, with EG&G

assuming responsibility; extended curtailment and

Figure 2-6-DOE Rocky Flats Tiger Team Report

Observations

No situations that pose an imminent threat to public health or

the environment were observed.

Implementation of the environmental programs lacks coordination and is hindered by poor communication. The lines of

authority and responsibility are fragmented and not clearly

defined. A strategy that integrates the existing management

and information systems needs to be developed and implemented.

Environmental monitoring programs require improvements to

more accurately characterize and monitor plant-related emissions, discharges, and ambient renditions.

Effective implementation of the site remediation program has

been adversely impacted by poor communications, coordination, planning, and scheduling.

The quality and reliability of sample collection, laboratory

analyses, and other information generated in support of the

environmental monitoring and restoration programs are not

adequate to achieve program goals.

Management and maintenance of the sewage treatment plant

has low priority, resulting in inefficient operation, which could

create problems in meeting future permit requirements.

The 1987 Waste Stream Characterization Study, which is used

to support waste management activities (e.g., permits and

waste classification), does not reflect current waste processes

at the plant. The study has never been fully reviewed.

Consequently, internal inconsistencies exist. The scope of the

study was not broad enough to serve as an effective waste

management tool.

A comprehensive strategy needs to be developed and implemented for performing ‘activities required by the National

Environmental Policy Act.

SOURCE: Summarized from U.S. Department of Energy, “Assessment of

Environmental Conditions at the Rocky Flats Plant,” DOWEH107, August 1989.

shutdown of Rocky Flats operations, beginning in

November 1989, followed by a series of safety

reviews and evaluations (3); and the fact that Rocky

Flats was considered by newspaper editors and

broadcast directors to be the most important news

story in Colorado for 1989 (6).

Waste Assay, Treatment, and Certification

DOE is faced with the task of assaying its stored

waste to determine what portion may properly be

classified as TRU waste. Previously, DOE had

assumed that if there was any uncertainty about the

nature of stored waste, it would be handled as TRU

waste. More recently, because of concerns about

finding suitable interim storage for TRU waste,

coupled with advances in assay technology, DOE

has been assaying previously stored TRU waste to

23A ~ntic~i~ ~cident~volve~ he ~tentio~ bufidup of fissile matefi~ such ~ plutonium-zsg ~ SII amount and georne~ that would fOMl a

critical mass, in a piece of equipment not designed to contain neutron chain reactions. Consequences could include a major uncontrolled release of

radioactivity. “A criticality accident at the Rocky Flats Plant could produce a potentially lethal dose of neutron and gamma radiation to workers at close

range, could generate heat and fission products, and, in extreme but low probability circumstances, could result in the release of radioactivity to the

environment” (41).

~Dfig 1989 ~d 1990, DOE ~ conducted ~vestigatiom$ of he~~ s~ety ad env~~en~ problem at each site utdhklg MI ad-hoc ~OUp

specially selected by DOE headquarte~. These groups are known as Tiger Teams.
Chapter 2-Managing Transuranic Waste at the DOE Nuclear Weapons Complex ● 71

determine if some portion of that waste can be

reclassified, treated if necessary, and disposed of

less expensively as LLW. An additional factor

driving reclassification was the redefinition of the

lower radioactivity limit for TRU waste from 10 to

100 nanocuries per gram in 1982. Based on sampling

procedures and work to date, DOE estimates that 38

percent of its current inventory of retrievable stored

TRU waste will be reclassifiable as LLW (79).

In November 1989 DOE reached agreement with

the State of Colorado to assess the substantial

quantities of plutonium ‘residues’ from incinerator

operations at Rocky Flats to determine whether they

have been properly classified or whether some

portion should be considered TRU waste (37). In

April 1990, a Federal district judge ruled that the

materials in question did in fact constitute waste;

DOE acknowledged that plutonium had been recovered from less than 10 percent of these residues

during the past 5 years (88).

The certification of TRU waste involves two

major steps. First, the waste must correspond to the

definition of TRU waste, which currently excludes

TRU-contaminated materials with alpha radioactivity lower than 100 nanocuries per gram. Second,

according to current DOE plans, the waste package

must meet Waste Acceptance Criteria for disposal in

WIPP. Criteria for contact-handled TRU waste and

remote-handled TRU waste were established in

1980 and are listed in the 1990 final supplement to

the Environmental Impact Statement (EIS) for WIPP

(69). Some of the existing stored TRU waste drums

are or will be certifiable for shipment to WIPP as is.

Others will have to be treated at one of the facilities

planned to be developed by DOE.

The Waste Acceptance Criteria now in effect

would allow a variety of waste contents and forms

within the package to be placed in the WIPP

repository. In general, TRU contaminants would not

be immobilized in either the contact-or the remotehandled packages, and thus would be respirable and

soluble if released. This is in marked contrast to the

more uniform vitrified packages of high-level waste

with immobilized radionuclides planned for emplacement in the high-level waste repository. Some

of the remote-handled TRU waste packages for

WIPP can have external dose rates as high as 1,000

rem per hour, exceeding that of some HLW vitrified

glass logs. Even though only a small portion of the

TRU waste is classified as remote-handled, it may be

prudent to investigate the integrity of this waste

package in more depth.

In preparation for WIPP operations, DOE is

examining engineering alternatives for the WIPP

waste package, driven in part by concern about gas

generation after it is in the repository. It may be both

necessary and desirable to modify the WIPP waste

package to reduce or eliminate gas generation. Two

possible classes of alternatives are: to shred, compact, and perhaps grout the waste; and to incinerate,

calcine, or vitrify it.25 The latter alternative would

represent a major departure from current plans.

Vitrification could eliminate gas generation in the

repository and result in a more stable waste form.

Disadvantages of vitrification are that it would

require a major overhaul of current plans and

treatment facilities at considerable expense and

could possibly increase occupational exposure. A

thorough analysis of these alternatives would be

required before an informed choice could be made.

Transportation of Waste

Figure 2-7 shows the proposed transportation

routes to WIPP. TRU waste is currently located at

the DOE sites identified in the figure and must be

transported over relatively long distances. Transportation of waste packages to WIPP represents the area

of greatest public concern, as measured by the

number of comments received about this topic in

connection with the WIPP Supplemental Environmental Impact Statement (SEIS) (70).

The transportation option chosen by DOE is a

fleet of trucks carrying the waste in specially

designed “TRUPACT II” containers (see figure

2-8). The container design has been certified by the

Nuclear Regulatory Commission (NRC) as suitable

for shipping contact-handled TRU waste drums to

WIPP.26 A number of concerns have been expressed

about the shipping plans including preparation for

emergency response to traffic accidents, qualifications of the trucking contractors, specific routes used

by the trucks, validity of accident analyses and

structural integrity of the container (70). In addition

to addressing these concerns in the SEIS, DOE has

attempted to enhance safe transport by: developing

a program to train State, local, and Indian tribal

police and emergency personnel in proper proce-

~Nefll, R., Environment Evaluation Group, personal communimtiou w. 26, 19N.

26For ~~ut a d=ade, DOE pwsu~ ~ ~ececon~~ desi~ tit was ab~doned after f~me to meet DC)E’S OWII smd~s.
72 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

Figure 2-7—Proposed Shipping Routes to the Waste Isolation Pilot Plant

EHANFOF

1 .

A

Z@

/

LAWRENCE

LIVERMORE

NATIONAL

LABORATORY

(LLNL)

PLANT (SRP)

rU. S. INTERSTATE “GHwAyLEGENi=-lhT ~ x#-

I FEDERAL ROUTE

1 J

I u

SOURCE: U.S. Department of Energy, “Environmental Restoration and Waste Management: Five Year Ptan,” DOE/S-0070, 1989, P.144.

dures following an accident; developing a satellite

tracking and communication system for the trucks;

and providing an extensive public information

program for persons and officials in the 23 affected

States and Indian tribal governments along the

WIPP route (71).

Despite DOE statements that the containers and

trucks are safe, opposition to the transportation of

TRU waste to WIPP is likely to continue. Among the

concerns expressed at April 1990 hearings of the

New Mexico State Environmental Improvement

Board was a distrust of statements that there is little,

if any, risk to public health and safety from the

radioactive waste, either during transport or in WIPP

itself (2,1 1). Transportation will bring the waste

close to many people, and expressions of opposition

have ranged from signs in Santa Fe reading “Another Business Against WIPP” to threats of civil

disobedience.

In a March 1990 analysis of the risk of transporting contact-handled TRU waste to WIPP, the

Environmental Evaluation Group (EEG) concluded

that “the currently identified routes do not pose a

statistically significant health risk to New Mexico

residents, and it is not expected that any other routes

which may be so designated for this purpose will

pose a significant health risk” (25). EEG recommends that truck crew members be closely monitored to ensure exposures less than 2 millirems per

hour, that selection of truck stopping places be

carefully studied to minimize unnecessary exposure,

and that bypasses around communities be used when

possible (25).

To minimize the possibility of confrontation and

avoid taking waste through urban areas, the State of

New Mexico has sought funds to build a bypass

around Santa Fe and other communities. At an April

1990 Senate Energy Committee hearing on WIPP,

Secretary of Energy James D. Watkins and Senator

Peter Domenici of New Mexico disagreed on

whether the DOE was reneging on a commitment to
Chapter 2--Managing Transuranic Waste at the DOE Nuclear Weapons Complex ● 73

Figure 2-8-Bringing Trucks of TRU Waste Drums to the WIPP

During Full Operation of Repository:

Each Truck: 3 TRUPACT-II Containers

Each TRUPACT-II Container: 2 Layers, 7 Drums per Layer

Total: 42 Drums per Truck

23 Trucks per week: about 1200 Trucks per Year

42 Drums per truck: 966 Drums per Week

Total: about 50,000 Drums per Year I

1 I E

. . . . . . . . .

n 4P. . . .

. . — :.; ;, , , : : .-. . ...

— . . . . . . .

. . .

—. .— —— SOURCE: Office of Technology Assessment, 1991.

provide $250 million for New Mexico road con- specifically, rooms mined in bedded salt 2,150 feet

struction. 27 New Mexico officials believe they had

such a commitment of funds from DOE, whereas

Secretary Watkins asserts that the commitment was

to help obtain funds and not to provide them. States

other than New Mexico through which the waste

will pass are interested in the outcome of this

controversy because they have road-building needs

and desires of their own.

Finally, the question arises, what should be done

if waste packages arrived at WIPP that were either

damaged or uncertifiable for placement in the

repository? WIPP appears to have very limited

capability for handling damaged packages, as well

as limited storage capacity. Also, there is no

approved, above-ground storage facility at WIPP for

mixed TRU waste.

The Waste Isolation Pilot Plant

The Waste Isolation Pilot Plant near Carlsbad,

NM, is a key element in DOE’s management

strategy to dispose of retrievable stored and yet-to-begenerated TRU waste in a deep geologic repository,

below the-surface (see figure 2-9). The DOE 1989

Five-Year Plan calls for a 5-year demonstration or

test phase to prove the WIPP concept will be

undertaken. At the end of this demonstration phase,

a decision will be made as to WIPP's acceptability

as a permanent, operational, disposal facility for

TRU waste. According to the Five-Year Plan, the

5-year test phase has two main objectives: to

demonstrate that there is reasonable assurance of

compliance of the WIPP disposal system with

long-term EPA disposal standards, and to demonstrate the ability of DOE’s TRU waste management

system to safely and effectively certify, package,

transport, and emplace waste at WIPP. After the test

phase, the plan indicates that DOE will evaluate

whether WIPP should proceed to the disposal stage

(62).

Construction of the WIPP facility is essentially

complete and WIPP was originally scheduled to

open in 1988. It now appears that the first test phase

could begin sometime in 1991 but opening date

predictions are very difficult to make. Although

zTFrom Senate Ener~ COmmitt~ hearing on WIPP, Apr. 3, 1990. See iiko Weapons Comph?-xklo?titor, ‘‘EPA Proposes to OK DOE WIPP Test Phase

No-Migration Petitio~” Apr. 18, 1990, pp. 2-3.
74 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

Figure 2-9-The Waste Isolation Pilot Plant: Its Capacity, Estimated Operational Cost,

and Estimated Lifetime

WASTE HANDLING BUILDINGS

. ,’ :... ,,, . ;,?”: .:, .?.. L’ :., . . . ,. ,:. , . . . . ..

., >;-, !..::. <::,,,,...:.... .+:.

SALT HANDLING

SHAFT

Total waste capacity: 6 million cubic feet

Current accumulated waste volume: 2.12 million cubic feet

Construction cost to date: $700 million

Estimated cost for 25-year operation: $2.5 billion

Estimated total time to fill the WIPP repository: 20-30 year s

SOURCE: Office of Technology Assessment, U.S. Department of Energy.

considerable progress has been made in overcoming

a sizable number of technical, regulatory, safety, and

procedural obstacles, further obstacles and questions

concerning the opening of WIPP remain to be

addressed.

WIPP’s importance extends beyond its role as a

repository for TRU defense waste. To DOE Secretary Watkins, it represents an opportunity to makeup

for past mistakes and prove the competence of U.S.

28 For others, it represents science and technology.

moving forward with the long-term disposal of

radioactive (TRU) waste in an existing facility,

whereas a high-level waste repository seems a more

distant possibility. Some undoubtedly see the successful outcome of WIPP, not withstanding its

defense mission, as a giant step forward for civilian

nuclear power by demonstrating that radioactive

waste can be disposed of somewhere and need not

accumulate at reactor sites. Thus, a variety of

pressures may make it difficult for DOE to determine fairly and objectively at the end of a test phase

whether or not TRU waste can be deposited safely in

WIPP. DOE’S thrust is summarized in the following

statement in the 1989 Five-Year Plan: “A positive

determination by DOE and continuing shipments to

WIPP . . . would mean fulfillment of a major DOE

objective” (62).

A variety of mechanisms have been put in place

that provide useful technical advice and a measure of

oversight for WIPP. They include a DOE Blue

Ribbon Panel, a National Academy of Sciences

panel, a subcommittee of the DOE Advisory Committee on Nuclear Facility Safeguards, and the EEG.

Of these, EEG is the only organization with a

substantial full-time technical staff; it has been a

continuing source of valuable technical advice and

oversight for WIPP since its inception. Although

EEG’s funds come from DOE, it is associated with

~Seme~ of Energy James D. Wati, testimony at hearing on WIPP before Senate Energy Committee, Apr. 3, 1990.
Chapter 2---Managing Transuranic Waste at the DOE Nuclear Weapons Complex . 75

the State of New Mexico.29 Other oversight groups

have also provided important technical advice but

because they are either volunteer panels with minimal staff that only meet occasionally or because

their scope and duration of oversight is limited, their

ability to make in-depth evaluations is limited.

Problems With WIPP--Some of the technical

problems confronting WIPP were summarized at the

1989 Waste Management Conference. At that time,

according to EEG, DOE had not published a single

report to document WIPP’s progress toward compliance with EPA Standards for the Management and

Disposal of Spent Nuclear Fuel, High Level and

Transuranic Radioactive Wastes (40 CFR Part 191).

Among the technical problems were brine inflow

and associated scenarios, the need to designate

backfill materials, and the need to carry out a WIPP

performance assessment, including experiments as

opposed to pure modeling. Operational readiness

issues were also unresolved. In addition, waste

handling dose criteria were said to be less stringent

than for commercial operations because they were

essentially DOE self-regulated rather than NRCregulated. 30

EEG has monitored a variety of WIPP activities.

For example, in 1989, in observations pertaining to

the WIPP Phase II Preoperational Appraisal, EEG

found significant programmatic deficiencies in the

WIPP operational health physics program. 31 Among

the issues that needed to be addressed were technical

staffing, control of potential contamination events,

training of health physics technicians, improved

radiological calibration and maintenance, use of

controlled areas for nonradiological functions, internal audits, accreditation of the external dosimetry

program, establishment of an internal dosimetry

program, establishment of a health physics respiratory protection program, and resolution of effluent

monitoring and air monitoring issues. Many of these

issues were reiterated a year later.32 While DOE

continues to make progress addressing these issues,

it appears that EEG oversight provides a valuable

mechanism for checking on such progress.

Brine and Gas Generation-The choice of WIPP

as a deep geologic repository for TRU waste was

predicated upon making use of a salt bed as the

medium for isolating the waste from the environment. The salt would plastically deform and close in

on the waste, keeping it isolated from the environment for a sufficiently long period to conform with

EPA disposal requirements. Theoretically, one of

the virtues of salt was its undisturbed nature; that is,

it was initially thought to be dry. An earlier choice

of a salt mine in Lyons, KS, as a repository for

high-level waste was abandoned after discovery that

the area had been extensively mined and that a

significant number of boreholes penetrated the

supposedly isolated repository (33). At WIPP, although there was no prior intrusion, some water and

brine were evident in the repository. The water or

brine was not in great evidence during an OTA site

visit at the repository in March 1990 because of

evaporation, due in part to the ventilation system;

however, the brine could be a factor in certain

scenarios following closure of the facility.

More recently, the concern about brine has been

replaced by a concern about gas generation in TRU

waste packages. Given current WIPP waste acceptance criteria, gas generated in the vented drums by

a combination of metal corrosion and microbial

activity will probably build up in the repository. Gas

pressure could reach the point at which it will push

outward on the surrounding salt bed;33 developments beyond that are matters for both analysis and

speculation. The analysis is being done by DOE’s

Sandia National Laboratory (SNL), the principal

scientific contractor for the WIPP operation. Speculation at a March 1990 meeting of WIPP advisory

and oversight groups convened by the National

Academy of Sciences ranged from an optimistic

“hoop stresses will hold things together” to a

2~e ~WoSe of the Enviro~en~ Eval~tion &OUp (EEG) is to conduct an independent tdmkd evtihM.iOn of tie Wrote rso~tion pilot ‘tit

(WIPP) Project to ensure protection of the public health and safety and the environment. The EEG was established in 1978 with funds provided by the

U.S. Department of Energy (DOE) to the State of New Mexico. Pub. L. No. 100-456, the National Defense Authorization Act FY 1989, Seztion 1433,

assigned EEG to the New Mexico Institute of Mining and Technology and provided for continued funding from DOE through a contract

(DE-AC04-89AL58309).

W1.H. Neill, Environmental Evaluation Group, paper presented at Waste Management Conference, llcso~ AZ, Februq 1989.

31R.H. Nefil, Environmen@JEv~~tion Group, letter to JackB. Tillmar+ U.S. Department of Energy, WIPPprojeCt Office, Cmlbad, NM, Apr. 7,1989.

SZR.H. Neal, Environmen~ Evaluation Group, personal communication to R.P. Morga@ My 1990.

ss~cording to a 1989 Sandia report, gas pressure in the mine could inCreaSe tO a “lithostatic” pressure of 2,150 pounds per square inch in 65 to 70

years (30).
76 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

pessimistic “radioactive materials will be released

into the environment. ’

A June 1990 report of Sandia National Laboratory

concluded that “SNL has reasonable confidence

that compliance is achievable with the (EPA disposal) Standard as first promulgated.”34 However,

the report goes on to state that it is “not a formal

evaluation of compliance; available data and models

are insufficient for a full-scale assessment. ’ According to the report: ‘‘The major question remaining is not whether the WIPP can comply with the

Standard but rather how it should comply.’ Among

the options being examined for how to comply are

identification of alternatives for the waste form and

repository design to improve WIPP’s ability to

reduce potential releases.

OTA has not analyzed the Sandia Report in detail.

The Environmental Evaluation Group finds the

report’s primary deficiency to be that ‘‘it does not

present analyses of breach scenarios involving gas

pressurization in the repository. Since the experiments with the waste focus on measuring the rate of

gas generation, it is necessary to present analysis of

breaches involving this phenomenon, including a

determination of the threshold of unacceptable gas

generation rate and an assessment of the likelihood

of meeting compliance with the standards with or

without planned modifications. ’ ’35 As a consequence of this and other aspects of the report, EEG

finds that the report does not provide “sufficient

basis for high confidence that WIPP can demonstrate

compliance with the . . . . Standards. ”

Another aspect of the Sandia Report is troubling.

In the foreword, it is argued that although some

readers may disagree, Sandia’s positive finding of

“reasonable confidence that compliance is achievable without demonstrating compliance” is “logical

and must be made at this time. ’ The reason given is

that predictions of feasibility are essential for R&D

projects and must invariably anticipate achieving

project objectives. ‘‘National Air and Space Administration was able to predict the achievability of a

manned moon landing years before they could

demonstrate it. Had realistic predictions of ultimate

success not been available in advance, the task might

never have been undertaken. ’ What is troubling

about the NASA analogy is that it equates a

relatively high-risk task in space exploration with a

task that seeks to ensure the safe disposal of

radioactive and hazardous wastes in a manner that

minimizes risk to the public and the environment—

two very different activities with very different

levels of public support and understanding. Furthermore, this philosophy clearly indicates Sandia’s role

in support of the objectives of the DOE mission;

thus, Sandia’s conclusion of compliance with the

standard, no matter how soundly based, is likely to

be questioned. A related question is whether or not

there is sufficient independent oversight and analysis capability outside of DOE and its contractor

network to scrutinize such analyses and perform

them independently, primarily from the viewpoint of

public health and safety.

Two approaches might be hypothesized to deal

with the problem of gas generation that illustrate the

range of possible choices. One is to stay with the

current waste form, learn as much as possible about

gas generation, assuming that compliance with

disposal standards can be demonstrated. The other is

to alter the waste form now to reduce or even

eliminate the generation of gas; processes for this

range from shredding, compaction, and grouting on

one hand, to incineration, calcining, or vitrification

on the other.36 As mentioned previously, the latter

alternatives could be very disruptive of current DOE

plans and could add considerably to the cost and the

occupational risk.

Studies of alternative engineering waste forms are

part of DOE’s decision plan for WIPP. DOE appears

to be pursuing somewhat of a middle course in that

although we know of no firm plans as of this writing

to test alternative waste forms in or for WIPP, such

forms represent a fall-back position in case the

untreated waste form does not comply with the

Standard.

An Engineered Alternatives Task Force (EATF)

has been created by International Technology Corp.

for Westinghouse, the management and operating

contractor for WIPP. The EATF has made preliminary recommendations of 15 possible waste-form

treatments for inclusion in WIPP’s test program. Six

basic forms on the list include glassified vitrified

34S.G. Be~m.HoweV, and p.pJ. swif$ c(s~~s Report: potenti~ for ~ng-Terrn Isolation by the Wrote Isolation Pklt Disposal SyStellL” !hndia

Report SAND90-0616, Albuquerque, NhL June 1990.

35R.H. Nei.11, EEG, letter to L.P. DuffY, DOE Aug. 24, 1~.

36E1* ting steel drums would avoid anoxic corrosion.
Chapter 2--Managing Transuranic Waste at the DOE Nuclear Weapons Complex ● 77

waste, cemented waste, compacted waste, shredded

waste with bentonite filler, metal waste melted into

ingots, and pH-buffered waste packages. Final

recommendations are due in 1991.37

The gas generation issue is central to current

. . thinking about the WIPP experimental phase. DOE

wishes to move ahead with a series of bin experiments in which gas generation rates will be measured in the repository with real TRU waste. Objections to these experiments include the following:

previous measurements indicate that gas generation

rates will be unacceptably high; the experiments can

be done outside the repository; and WIPP was not

designed for handling liquid samples with radioactive Transuranics. Counterarguments for moving

ahead include: if the experiments are performed

outside of WIPP, it will be argued that they were not

done under real-world conditions; and WIPP exists,

so it is cheaper and better to do the bin experiments

there than elsewhere.

Alcove experiments to test gas generation and

brine inflow in somewhat larger spaces are also

planned. The bin and alcove experiments will

employ about 0.5 percent of all of the waste

eventually destined for WIPP, roughly 4,500 waste

drums or 100 TRUPACT trailers full of waste. As of

June 1990, a proper seal for the alcove experiment

had not been achieved.38 Finally, in April 1990,

DOE indicated that, at EPA’s suggestion, it would

evaluate the possibility of filling two rooms with

waste during the test phase, raising the possible

emplacement from 0.5 to 2 percent of design

capacity and from 100 to 400 TRUPACT trailers .39

Disposal Standards; “No Migration”; Land

Withdrawal—Two other aspects of WIPP that deserve examination are its performance assessment

and its ability to meet EPA disposal standards for

TRU waste. At present, assessment of the performance of WIPP is not expected to be completed before

the end of 1994. This assessment is likely to be

important in determining whether or not WIPP will

meet the EPA disposal standards and whether the

waste form will have to be changed in order to do so.

DOE hopes to proceed with the experiments without

having to demonstrate compliance with EPA disposal standards, arguing that the standards should

apply only to the operational phase; EPA concurs

with this. The relevant EPA standards have been

remanded by the courts, and new standards are not

expected to be finalized before 1992. At a March

1990 meeting of four WIPP oversight committees,

concern was expressed about the ability of WIPP to

meet the standards under a human intrusion scenario; although less concern existed about a undisturbed scenario, there was concern nevertheless.40

An important step toward proceeding with the

WIPP experimental phase occurred when EPA

proposed to rule positively on DOE’s request for a

no-migration variance that would allow emplacement of mixed TRU waste in WIPP for “testing and

experimentation to determine whether the site is

appropriate for the long-term disposal of mixed

waste’ (90). The proposed EPA ruling, which was

followed by a 60-day public comment period,41

prohibits DOE from moving ahead with the operational phase and requires it to remove the waste if a

‘‘no-migration’ condition of hazardous waste cannot be demonstrated for the long term (90). The

proposed ruling indicates that EPA basically supports DOE efforts at WIPP.42 According to EPA,

“Given the geologic stability of the area; the depth,

thickness, and the very low permeability of the salt

formations in which the repository has been mined;

and the properties of rock salt as the encapsulating

medium . . . the WIPP is a promising site for a

SVS.G. Ber@am.Howe~, and P.N. SWif~ “StatUS Report: Potential for Long-Term Isolation by the Waste Isolation Plant Disposal SySte~” Sandia

Report SAND90-0616, Albuquerque, m June, 1990.

38 Subsquafly, fi Octokr 1990, DOE ~ormed EEG that these tests are not scheduled to start until 1992. ~e’y~ not be carri~ out ~ess an

adequate seal can redemonstrated. (See R.H. Neill, EEG, testimony before New Mexico legislative Committee on Radioactive andHazardous Materials,

Carlsbad,~ Oct. 4, 1990.)

Sgsemte Energy Committee, hearing on mp, Apr. 3, 1990.

@Natio~ Academy of Sciences meeting on public Cordldence in WIPP, Mar. 5, 1990.

41~ong me coment5 Wm a jo~t~bmission bymeAttorney Gen@ of Te~, fie _dous Waste T~tment COWICil, and four etWhOlmleIMld

organizations opposing the proposed variance. (See “Joint Comments on the Proposed Conditional ‘No-Migration’ Variance From Land Disposal

Restrictions to the Department of Energy’s Waste Isolation Pilot Plan~” submitted by the Natural Resources Defense Council, The Hazardous Waste

Treatment Council, The Attorney General of Texas, Southwest Research and Information Center, Concerned Citizens for Nuclear Safety, and the

Environmental Defense Fund, June 5, 1990.)

42some concern ~s been expressed tit EPA w= too a~o~odating to ME pressure and too ~~ in is favorable response to the no-migration

petition. In addition, Representative Mike Synar of Oklahoma has criticized EPA for proposing to grant the variance without having disposal standards

in place. (See “Synar Says EPA Pressured To Waive Rules, ” Associated Press News Release, May 9, 1990.)
78 ● Long-Lived Legacy: Managing High--Level and Transuranic Waste at the DOE Nuclear Weapons Complex

permanent mixed-waste repository” (90). In November 1990, EPA approved DOE’s WIPP nomigration petition for the test phase, but imposed

several conditions (see app. A).

One hurdle that still remained as 1991 began was

withdrawal of the land on which WIPP is located

from the public domain. DOE had been pursuing two

options in this regard: the preferred option was for

Congress to pass a law authorizing such land

withdrawal; the other was for the land withdrawal to

be handled administratively by the Department of

the Interior. However, as Secretary of the Interior

Manuel Lujan pointed out, such administrative

withdrawal would be for only 20 years; at the end of

that time the land would have to be restored to its

original condition. 43 Such restoration would be a

nearly impossible requirement for a fully operational

long-term geologic repository to meet, but it would

be sufficient for the test phase for which the waste

must be retrievable.

A land withdrawal bill that presumably reflected

DOE’s position was introduced in Congress during

1990. This legislation placed certain conditions on

DOE, some of which had been met (e.g., completion

of the Supplemental Environmental Impact Statement) or were in the process of being met (e.g.,

granting of the no-migration variance).44 Benefits to

the State of New Mexico include the use of local

workers and the potential development of local

businesses, as well as DOE payments to local

governments in lieu of taxes that would have

accrued if the land were privately owned (90).

Conditions in the land withdrawal bill seemed to

provide DOE with some leeway to move beyond the

experimental phase. There was no limit on the

volume of waste that could be placed in WIPP;

restraints to doing so appear to be mainly verbal

assurances from the Secretary of Energy (90). Land

disposal legislation could serve as a vehicle for

imposing additional conditions on DOE. However,

no such legislation was passed during 1990. In

January 1991, the Department of the Interior transferred control of 16 acres including WIPP to DOE by

the process of administrative withdrawal.45

At present, DOE is pushing vigorously to get the

first waste for the experimental phase into WIPP.

The symbolic value of emplacement of the first

waste package could be of equal or greater value

than specific technical information likely to emerge

from this phase. DOE’s technical oversight groups

generally support proceeding with the bin and

alcove experiments, although substantial sentiment

exists in EEG for moving ahead with plans to alter

the waste form to reduce or eliminate gas generation

and make the waste package more analogous to that

for high-level waste, given the parallel disposal

approaches for these two categories implied by EPA

standards. 46 If the experimental phase is initiated,

the performance assessment, including analysis of

whether an operational WIPP repository can meet

EPA long-term disposal standards not yet promulgated, will be very important during the next 3 or 4

years. The following issues could arise if waste is

placed in WIPP before disposal standards are in

place.

Analysis of Storage Issues at WIPP—In December 1989, the General Accounting Office (GAO)

reviewed DOE’s proposed experiments and storage

operations at WIPP, in response to a request from

Representative Mike Synar prompted by the discovery of brine in what was expected to be a dry

repository. GAO summarizes its results as follows

(45):

WIPP is a key part of DOE’s plan to clean up its

aging defense facilities. By moving TRU wastes

from these facilities to WIPP, DOE would be able to

address what has become a contentious issue in

federal-state relation--continued “temporary” storage of the wastes. However, by storing waste in

WIPP years before determining compliance with

disposal standards that are as yet uncertain, DOE

might have to either abandon WIPP, if it does not

comply with the new standards, or remove and/or

rehandle wastes in order to comply with the standards. In making a decision on DOE’s request to

withdraw the land and permit storage to begin, the

Congress’ choices range from authorizing waste

storage in WIPP either with or without restrictions to

deferring action until DOE has determined that

WIPP complies with EPA’s revised standards. The

Congress needs to weigh several factors:

43&.me~ of the ~tenor Manuel LUJa~ testimony at he~gon WJpp before Senate Energy Committee, Apr. 3, 1990.

44~e no-mi~ation ~~mce for ~p was pubfished byEPA intheFe&ra/Register onNov. 14, 1990. The determina tion to allow DOE to dispose

of RCRA-regalated hazardous constituents at WIPP will be limited to testing and experimentation purposes for a period of 10 years.

4SK. Schneider, ‘Cplm on Stming Nuclew Waste Clears Big Hurdle,” The New York Times, J~. 23, 1991.

MEEG recommended pursuing only the bin and alcove experiments, nOt the ‘‘two-room’ or operations demonstration, until DOE proves it can meet

the disposal standards.
Chapter 2--Managing Transuranic Waste at the DOE Nuclear Weapons Complex . 79

—If WIPP does not comply with EPA’s standards,

DOE would either have to remove the wastes from

the site, retrieve them for additional processing, or

rehandle them to modify the facility and achieve

compliance. DOE, however, has not addressed

these contingencies in its draft test plan.

—DOE could defer a demonstration of waste storage

operations. Deferring the demonstration, however, would delay DOE’s removal of TRU waste

from other facilities, and states hosting these

facilities vigorously oppose additional storage at

the facilities.

—The National Academy of Sciences agrees that

DOE’s planned-gas generation experiments are

warranted and should begin but recommends

deferring the demonstration of storage operations.

GAO recommended that DOE provide Congress

with three categories of information: technical

justification for waste storage in WIPP, including

the amount to be stored, ‘‘in advance of determining

if the facility can be used as a repository’; contingency plans for disposing of waste, experimental or

operational, stored in WIPP if the facility does not

comply with EPA disposal standards;47 and options

for continuing to store waste at other Weapons

Complex sites while DOE assesses WIPP’s compliance with standards. GAO also suggested that

Congress consider: including a provision in any

eventual legislation limiting the amount of waste

that could be stored at WIPP until compliance with

the standards is achieved; and making permanent

land withdrawal for WIPP conditional upon a

positive determination of compliance with standards.

The Future of Plutonium Operations

at Rocky Flats

According to reports early in 1990, DOE was

committed to repairing Building 371 at Rocky Flats,

which was opened in 1981 to replace two older

facilities (Buildings 771 and 776) and then shut

down in 1984 (40). Building 371 has been plagued

with problems from the outset; evidently, up to $600

million will be required to make the necessary

repairs and additions.

Rocky Flats is the only “source of the plutonium

parts that trigger thermonuclear reactions” (40).

Arguments for the repair of Building 371 are that

existing facilities are getting old, that Rocky Flats is

the only place currently reprocessing old warheads

(a necessity even with arms control agreements),

that plans for a Special Isotope Separation (SIS)

plant for plutonium isotopes at Idaho have been

abandoned by DOE at least for now, and that

opposition exists to the idea of expanding plutonium

operations at Los Alamos from research to production. On the other hand, Colorado Senator Tim Wirth

has expressed the case against renovating Building

371 as follows: ‘‘The idea of extending the life of a

plutonium processing plant in the middle of a major

metropolitan area makes absolutely no sense. We are

not exactly living at the height of the cold war. What

is the rush to build a new facility at Rocky Flats?”

(40)

Of immediate concern is whether it will be safe to

restart the Rocky Flats Plant after a shutdown for

repairs, safety inspections and evaluation, and management changes that began in November 1989. One

of the concerns is whether the plant will be allowed

to reopen with some or all of the 28 kilograms of

plutonium dust in the vents and ducts (38). DOE has

stated that the plant will not reopen until it can do so

safely; in making this assessment, DOE is receiving

input from the Defense Facilities Nuclear Safety

Board. However, Congresswoman Patricia Schroeder of Colorado has expressed concern that pressure

was being exerted by the defense establishment to

restart the plant promptly .48 This debate illustrates

the tension between perceived defense production

needs on one hand and environmental or safety

concerns on the other.

In a report on modernizing the DOE Weapons

Complex submitted to Congress in January 1989,

DOE suggested eventually shutting down Rocky

Flats and moving its operations to another weapons

site. This subject was subsequently reviewed in a

September 1989 OTA report (46). More recently, in

January 1991, DOE issued a report that supersedes

its earlier study and proposes reconfiguring the

Weapons Complex into one that “would be smaller,

less diverse, and less expensive to operate than the

Complex of today.’ ’49 In the Reconfiguration Study,

dTrn Nevada tie NRC r~fies DOE to show compliance with long-term disposal standards for high-level waste before receiving a license to @@

construction of the Yucca Mountain repository. This requirement exists even though it is very likely that disposal standards will be ia place long before

a HLW repository opens.

48Conwesswomn pa~cia sc~~eder, tes~ony at hearing of Defense Nucl~ Facfities Safety Bo~d, House committee on Armed Services, Mm.

22, 1990.

4~.s. Dep~ment of Ener~, Nucl~ WeaPn5 Complex Reco~@ation Smdy, Report DOE/DP-(K)*q, JMNIary 1991, Foreword.
8o ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

relocation of the Rocky Flats Plant is a preferred

option of the Secretary of Energy although the time

frame for the relocation is not specified and restart

prior to relocation is anticipated. Although no

reactor production of plutonium is required for any

of the weapons stockpile scenarios considered in the

study, DOE deems “a modern plutonium recycle

and recovery capacity to be essential to extract

plutonium from retired weapons and to minimize

wastes .50 As DOE continues to study the question of

modernizing the Weapons Complex and building

new facilities or moving certain functions, it will

need to consider carefully the implications for safe

waste disposal in the future.

TECHNOLOGIES FOR

IMPROVED MANAGEMENT OF

Transuranic WASTE

Introduction

This section discusses three treatment technologies that could prove useful for managing retrievable

stored TRU waste-incineration, immobilization in

grout or concrete, and compaction—as well as one

technology for managing buried TRU waste, namely,

in situ vitrification. The purpose of improved

treatment technologies is to reduce some or all of the

following TRU waste characteristics: volubility,

respirability, mobility, volume of gas produced,

volume of waste, and uncertainty in predicting its

behavior in a repository. The three technologies

discussed are receiving considerable attention because of their potential or proven utility. One of

these, incineration, also tends to be visible because

it often meets with public opposition. In situ

vitrification probably receives more attention within

the Department of Energy (DOE) than any other

technology as a relatively new, innovative approach

for in-place immobilization of buried waste. DOE’s

plans for overcoming problems in the management

of TRU waste are also outlined in this section.

Finally, actinide conversion (transmutation) and

waste minimization, as they pertain to TRU waste,

are discussed.

Three Technologies for Treating Retrievably

Stored Transuranic Waste

Incineration

Incineration (i.e., the burning of hazardous or

radioactive materials) is potentially very useful for

reducing waste volume and destroying the hazardous component of mixed waste. Because the hazardous component is often an organic material, incineration can greatly reduce or eliminate gas buildup in

a repository caused by the radiolysis of organic

compounds and bacterial decomposition.51 Furthermore, the ash from incinerated waste lends itself to

immobilization by incorporation with cement into

grout or concrete. In addition, incineration as a

treatment method has been approved for certain uses

by EPA. However, DOE has encountered both

technical and regulatory (licensing) problems with

some incinerators already constructed. In addition,

incinerators unrelated to DOE Weapons Complex

activity have been opposed by citizens groups in

various communities. As a result, DOE seems to be

somewhat wary of incineration as a future waste

treatment method.

Table 2-4summarizes the TRU waste incinerators

in the Nuclear Weapons Complex. None of these

incinerators is currently operational as of late 1990.

According to Benedict et al. (13), ‘‘concentration

of burnable solid waste can be very effectively

achieved by incineration. The ashes are handled as

radioactive waste. This is a rather costly technique

because of much effort spent for off-gas filtration

and safe handling of the ashes. . . . A much simpler

technique is baling of the waste under high pressure. The latter reference is presumably to compaction and "supercompactors," discussed below. Unlike incineration, compaction or immobilization in

grout or concrete does not destroy hazardous components. Finally, these authors suggest complete decontamination of large, bulky equipment that is

contaminated at the surface by rinsing with acids or

other solvents, ultrasonic treatment, and sandblasting. There remains, however, the question of what to

do with the radioactive solvent or dust generated

during decontamination.

Some specific DOE experience with incinerators

at Weapons Complex sites designed for use with

TRU waste is now reviewed.

Wid., p. 65.

sl~ese W. components accowt for about half of the total gas generated. The rest is the result of metal cmosion.
Chapter 2--Managing Transuranic Waste at the DOE Nuclear Weapons Complex ● 81

Table 2-4-Summary of Transuranic Waste Incinerators at DOE Weapons Complex as of July 1990

Sitea Nameb

Type StartcFeed typed Status

Hanford Plant . . . . . . . . . . . . . . . . WRAP Plasma arc 1999 T Planned

INEL . . . . . . . . . . . . . . . . . . . . . . . PREPP Rotary kiln 1985 L, T, R, M Testing

INEL . . . . . . . . . . . . . . . . . . . . . . . WED Plasma arc 1996 L, T, R, M Proposed

LANL . . . . . . . . . . . . . . . . . . . . . . . CAI Controlled air 1976 L, T, R, P, M Standby

Rocky Flats Plant . . . . . . . . . . . . FBU/PP Fluidized bed 1974 L, T, R, P Standby

Rocky Flats Plant . . . . . . . . . . . . FBU/PROD Fluidized bed 1978 L, T Standby

Savannah River Site. . . . . . . . . . PWI Wire conveyor 1986 T Standby

a lNEL = Idaho National Engineering Laboratory; LANL = Los Alamos National Laboratory.

b WRAP - waste Receiving and Processing Facility; PREPP - Process Experimental pilot plant; WED _ Waste Engineering Development Facility; CAI =

Controlled Air Incinerator; FBU/PP = Fluidized Bed Unit/Pilot Plant; FBU/PROD _ Fluidized Bed Unit/Production; PWI = Plutonium Waste Incinerator.

c Future start dates are estimated.

d Feed type code: L= low-level waste: T= TRU waste: H = high-level waste: R = Resource Conservation and Recovery Act waste: P= Toxic Substances Control

Act waste (polychlorinated biphenyls); M = mixed waste.”

SOURCE: Office of Technology Assessment, 1991.

The Process Experimental Pilot Plant (PREPP) at

the Idaho National Engineering Laboratory (INEL)

was ‘‘to demonstrate fill-scale methods for processing the uncertifiable stored TRU waste into a form

acceptable at the WIPP [Waste Isolation Pilot

Plant]” (28). Rotary kiln incineration is one of

several steps that include low-speed shredding and

immobilization by cementing.52 PREPP was built

and underwent debugging after some initial tests.

DOE had many technical problems with the process,

and as of September 1989, PREPP was a year or so

away from completion and further testing. The

rotary kiln incinerator appears to be primarily

responsible for the delays encountered in the startup

of PREPP. Both technical and regulatory obstacles

must be overcome before operation can begin. In late

1990 it was uncertain when or whether PREPP will

become operational.

PREPP has an elaborate off-gas system for the

kiln that includes a quencher, venturi scrubber,

entrainment eliminator, mist eliminator, reheaters,

and HEPA (high-efficiency particulate arrestor)

filters.53 The system is necessary because after final

filtration by two banks of HEPA falters, the off-gas

will be released from the stack. Hot ash and other

inert materials from the kiln will be separated and

then grouted with cement in drums.

The Controlled-Air Incinerator (CAI) at Los

Alamos has burned both radioactive (TRU) and

chemical wastes in an experimental mode and has

been modified for future use to burn TRU waste on

a continuing operational basis, subject to preparation and approval of an Environmental Impact

Statement. The CAI is licensed to burn polychlorinated biphenyls (PCBs) under the Toxic Substances

Control Act (TSCA), and in November 1989 received a Resource Conservation and Recovery Act

(RCRA) permit to burn hazardous waste. The

primary combustion chamber (PCC) of the incinerator can accept up to 125 pounds per hour of solid

waste or 200 pounds per hour of liquid waste (32).

An elaborate off-gas system is said to reduce

radioactive emissions to well below permissible

limits under the Clean Air Act.54 Plutonium throughput is limited because some of the processing vessels

do not have the intrinsically safe geometry needed to

prevent criticality accidents. No good estimates

appear to be available on incineration costs during

future operations.

The question of what to do with the ash after

incineration is still being explored. Immobilization

in cement may not be viable if cadmium or lead is

present because the leachability may be too high.

One alternative is microwave vitrification of the ash;

such a process is being developed in Japan. A

regulatory issue still to be resolved concerns some

limitations that the State of New Mexico has placed

on air emissions, which DOE contends should not be

subject to State regulation. Finally, the incinerator at

Los Alamos National Laboratory (LANL) has been

a source of considerable concern to some members

of the community, and certain efforts by LANL to

S2AS an ~temative to Cementfig, restich is proceeding on a plasma reactor that could turn waste into unreachable rock. A demonstration test of tie

plasma reactor is being conducted in Butte, MT under the sponsorship of DOE, the EPA Superfund Innovative Technology Evaluation (SITE) program,

and a private company, RETECH; tests were scheduled to be completed by 1991.

Sssome problems associated with the use of HEPA fiiters have been described (27).

MD. Hutcti, brieffig during visit to LOS Alamos National Laboratory, Mar. 27, 1990.
82 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

win support for the incinerator may have had the

opposite effect (23).55

Plans for incineration of low-level mixed waste at

Roe@ Flats in a fluidized-bed incinerator have met

with considerable opposition. By 1988, 10 city

councils had gone on record as opposing a trial burn

with the incinerator, and a lawsuit had halted its use

(22). Allegation of illegal use of the incinerator was

one element that prompted a 1989 raid by the

Federal Bureau of Investigation on Rocky Flats (88).

This particular situation is not pursued further here

because the incinerator in question is for low-level,

not TRU, waste. However, the situation at Rocky

Flats illustrates the depth of resistance to be expected when incineration is raised as a treatment

option. Also, the residue from incineration, the ash,

may well be TRU waste even if the input to the

incinerator is not.

Immobilization in Grout or Concrete56

The range of products for immobilizing TRU

waste is wider than for high-level waste (HLW)

because heat generation will be significantly less.

Possibilities include glass, cement, bitumen, and

polymers. Hydraulic cement has been used for many

years.

57 Additives to improve setting properties and

fission product retention include sodium silicate.

Polymer impregnation of cement is also being

developed. Benedict et al. conclude that “in spite of

experience, solidification with cement is still an art.

Each new waste application must be considered

individually because of possible interactions between cement and the waste constituents” (13).

Bitumen, or asphalt, is another possibility. It is

“highly leach-resistant, it has good coating properties, and it possesses a certain degree of plasticity”

(13). An advantage of bitumen over cement is that it

permits almost total removal of water through

evaporation, resulting in a volume reduction up to

fivefold greater than cement. The disadvantages of

bitumen compared to cement include its potential

fire hazard and its tendency to release hydrogen and

other gases in a radiation environment (13).

For TRU waste of high radioactivity, glass maybe

the immobilization medium of choice (13). It has

superior radiation stability, and its leach rates are

lower than for cement. It is the most expensive

choice, followed by bitumen and then cement, but

because large-scale vitrification facilities are coming on-line, the marginal cost of immobilizing some

TRU waste ash by vitrification, particularly remotehandled TRU waste, might be acceptable. Although

TRU waste volumes are large, incineration results in

a volume reduction of the order of 100:1 (32).

Current DOE plans for treatment of TRU waste

include some immobilization in grout or concrete,

although such immobilization is not a general

requirement for the acceptance of waste packages at

WIPP. Some concerns about immobilization in

concrete or grout include the following: What is the

longevity of the grout? How long will it retain its

structural integrity? How long will it keep the

Transuranics, as well as any hazardous components,

freed in place and isolated from the environment?

What reactions, if any, will take place between the

grout and the container?

Compaction

Compaction reduces waste volume by compressing dry solid waste into disposal or shipping

containers (18). In general, it has been used more

widely in the commercial sector than at DOE sites,

primarily for LLW. Supercompaction also appears

to be in favor in the European commercial nuclear

industry, bringing about LLW volume reduction

ratios ranging from 3:1 to 10:1 (36). Recent concerns

about storage limits for mixed waste have sparked

interest in compaction at DOE.

One limitation of compaction is that the process

tends to concentrate radionuclides. Care must be

exercised to ensure that the final waste package does

not exceed the radioactivity limits of the particular

waste category. For TRU waste, there is an upper

limit to the radioactivity of waste packages under

current WIPP acceptance criteria. Also, plutonium

concentrations must not exceed those at which

criticality becomes a concern.58

5sIbid.

56Concrete is ~ene~y defi~ ~ ~ ~d ~ub~~ce ~de of sad, gravel, mmen~ ~d water. Grout is no~ydefined as a thin mortar used to fdl

chinks or cracks. Grou4 concrete, and “saltstone’ are used interchangeably by DOE; sometimes a specitlc term refers to a particular site. They all refer

to products formed by immobilizing waste with cement and various other constituents.

57~e British me very positive about the use of ‘cements, “ i.e. concrete. (Source: R. Webster, United Kingdom Atomic Energy Authority, personal

COInmUId~tiO~ Dec. 15, 1989.)

58For ~mote-~n~~ mu waste, ~p wrote accep~~ critefi limit r~ioactivity to 23 c~es Wr liter, or about 5,(KKI curies per 55 gallon dll.lm.

Containers are limited to 1,000 plutonium-equivalent curies eac4 and drums cannot have more than 200 grams of fissile material (69).
Chapter 2--Managing Transuranic Waste at the DOE Nuclear Weapons Complex ● 83

A “supercompactor” that received considerable

attention in 1989-90 is being readied for operation at

Rocky Flats. Because of a limit imposed by the State

of Colorado on the volume of TRU mixed waste that

can be temporarily stored at Rocky Flats, DOE plans

to employ compaction in an effort to defer the date

on which that limit is exceeded. According to a

General Accounting Office (GAO) report, a Rocky

Flats official estimated that the supercompactor

would reduce by 50 percent the volume of TRU

mixed waste generated and stored on-site (44).

The Rocky Flats supercompactor was planned to

begin operating in the fall of 1990. However, delays

occurred due to both regulatory and technical

obstacles. On the technical side, supercompactor

components were purchased from several international vendors and had not been tested as a unit.

Connection of a glove box to a supercompactor was

to be done for the first time; however, the supercompactor press was dropped during shipment from

West Germany and found to be rusted, with some

electrical wiring vandalized (44). However, DOE

reportedly believed that the physical condition of the

supercompactor would not be a limiting factor in

moving ahead with installation and operation (89).

After an environmental assessment (89), a 30-day

period of public comment followed. DOE issued a

proposed “Finding of No Significant Impact”

(FONSI) for construction and operation of the

Rocky Flats Supercompactor and Repackaging Facility and the Transuranic Waste Shredder.

In August 1990 it was reported that DOE had

approved plans for ‘‘a new high-tech waste shredder

and compactor’ for use at Rocky Flats—

presumably the same device described previously.

Operation of the device is now planned for early

1991 and is expected to extend Rocky Flats mixed

TRU waste storage capacity by up to 18 months if

Rocky Flats Plant plutonium processing operations

are resumed. The shredder is reported to pulverize

graphite molds and falters while the compactor

reduces drums of waste to cylinders about 20 inches

in diameter and up to 18 inches thick.59

The history of the Rocky Flats supercompactor to

date would indicate that DOE has not devoted

enough resources to the use of this technology at

weapons sites. Given the storage situation as it

evolved at Rocky Flats, some kind of compaction

equipment should have been available or should

have been acquired from other DOE sites; evidently,

this was not possible.

Shredding and compaction represent the next

level of treatment that might be considered as an

alternative to the essentially untreated TRU waste

packages currently destined for WFP. Treatment

costs should be considerably lower than for incineration. Although such treatment would reduce waste

volume by a factor of five or so, it might not

significantly retard the rate of gas generation; in fact,

the shredding and compaction process could conceivably enhance it. Experiments with this waste

form are needed.

In Situ Vitrification

A great deal of interest has been generated in the

use of in situ vitrification (ISV) as a technology for

immobilizing buried waste or contaminated soil. A

high current flowing through giant electrodes, in or

near the media to be vitrified, melts the material,

which then hardens into a glasslike solid. The

technique was pioneered at Hanford by Battelle’s

Pacific Northwest Laboratory with DOE financial

support. Battelle then obtained a license for the

rights to ISV technology and created the Geosafe

Corp. to commercialize the process (24,26).

Geosafe’s license seems to focus on the use of ISV

for hazardous waste sites. Demonstrations at Weapons Complex sites are being carried out by DOE and

its contractors.60

The advantages of ISV include vitrification of

soils up to a depth of 30 feet, destruction of organics

and incorporation of heavy metals into the vitrified

mass, complete dissolution of cement inclusions

within the vitrified mass, and more modest off-gas

system requirements than incineration.6l Perhaps

the greatest potential advantage is the prospect of

immobilizing buried waste, thereby eliminating the

need or cost of exhumation, treatment, transport, and

disposal, as well as the health risk to workers

involved in these operations. Some consideration is

also being given to immobilizing drum and tank

waste by using ISV (24).

Y)~~DOE Approves Plan for Waste Compactor at ROCkY Flats,” Associated Press News Release, Aug. 16, 1990.

-oegler, S., BattellePaciflc Northwest Laboratory, remarks at Ofilceof Technology Assessment Workshop on Soils and GroundwaterRemediation

Technologies, May 8, 1990.

‘lIbid.
84 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

Areas requiring further investigation include the

economics and possible safety or health hazard from

ISV. According to DOE personnel, in situ vitrification requires relatively dry soil and energy costs of

1.5 to 2 cents per kilowatt-hour, to be economically

feasible.62 A cost of about $250 to $350 per ton is

estimated for most vitrification operations (24).

Unanswered health and safety questions include

performance of the off-gas system and possible

worker hazards from strong electric fields.

The first full-scale test of in situ vitrification of

mixed waste is underway at Hanford. During April

1990, researchers intended to melt in place the

contents of a waste crib and the soil surrounding the

crib in the 1OO-B area, a high-priority site for

cleanup under the Hanford tri-party agreement.

After the 9-day test, about a year would be required

for the molten waste to harden into an 800-ton mass

(28).

preliminary results of the Hanford mixed waste

ISV test were reported at a May 1990 Office of

Technology Assessment (OTA) workshop.63 Although plans were to meltdown to a depth of 20 feet,

the test was halted at a depth of 14 feet because of

concern that the horizontal spread of the melt would

exceed the limits of the hood that collects off-gases.

Roughly 75 percent of the hazardous materials in the

waste crib and 50 percent of the radioactive materials in the crib were reached. The full-scale demonstration used three semitrailers and is capable of

melting 3 to 5 tons per hour. In this mixed waste test,

the radionuclides were strontium and cesium. An

earlier full-scale test was performed about 2 years

ago on a trench in which plutonium solutions had

been dumped. That test reached a depth of 15 feet.

The ISV mixed waste test cost about $1.8 million,

with about one-third of that needed for- environmental documentation and characterization.64 The

cost of the 9-day melt period was estimated at about

$250,000. Total costs to date for the development of

in situ vitrification are on the order of $10 million.

The following evaluation of ISV was offered at

the May 1990 OTA workshop: It is effective near the

surface and ready for use on radionuclides and heavy

metals in shallow land burial sites. Hopefully, in a

few years, it will be available for use on Hanford

single-shell tanks,65 after they are fried with soil.

The grasslike product is more leach resistant than the

melt from the HLW vitrification process because

melt temperatures are higher. Some limitations

include the depth to which a melt can be carried out

and the water or moisture content of the soil; high

moisture content increases the energy costs. ISV

should be roughly comparable in cost to exhumation

and treatment, and should be very effective on tough

mixtures. Furthermore, it minimizes worker radiation exposure compared with removal and treatment

of the waste. However, ISV is not a solution for all

the buried waste and contaminated soil at all DOE

sites. It should be applied selectively to the worst

“hot spots.”

Some issues discussed, but not necessarily resolved, at the OTA workshop were the following:

How good are the off-gas systems used in connection with in situ vitrification? Can the ISV process

lead to further contamination outside the melt zone?

Is ISV likely to be acceptable to local communities

and citizens who may expect to have the waste

physically removed? What are the prospects for ISV

now that the Geosafe process has been accepted in

the Environmental Protection Agency (EPA) Superfund Innovative Technology Evaluation (SITE)

program?

In October 1989, the first INEL field test of in situ

vitrification was carried out. This test, which was on

a scale about one-tenth that of Hanford,66 involved

movable electrodes, an off-gas containment hood

made of fabric rather than metal so that equipment

could be transported by truck, and simulated TRU

waste with high buried metal content and high

buried combustible content, but without radioactivity. Below the electrodes were both stacked drums

and randomly dumped drums and boxes of waste.G7

This intermediate-scale ISV test was aborted be6ZL. D*, U.S. Dep~ment of Energy, remarks at special meeting of OTA Adviso~ Panel, M.M. 1, 1990.

63s. Koegler, op. cit., footnote 10.

~Ibid.

65~ Septefier 1990, Ba~e~e pac~lc Northwest ~boratones beg~w~tWMdescribed~the “fistfieldtest to cou~tdata to determine whether

ISV can effectively be used on tanks and their contents.” The tank contained hazardous waste but no radioactive component. (See “PNL Halts In Situ

Vitrification Test on Mock Tank Containing Wastes,“ Report on Defense Plant Wastes, Sept. 14, 1990.)

‘%bid.

6TJ.L. ~ndo~ “ti Sim Vitilcation Update,” presen~tion to National Academy of Sciences Panel on Buried Wastes at INEL, NOV. 13-14, 1989.
Chapter 2-Managing Transuranic Waste at the DOE Nuclear Weapons Complex ● 85

cause the fabric hood was ‘‘glowing’ and flames

were present. Simulated waste buried deeper than 24

inches showed no evidence of heat damage, and

glass splatter around the melt zone was uneven.68

After review of the system and revision of procedures and equipment, a second test was reported to

have been completed successfully in 1990, with a

metal rather than a fabric hood.

The Applied Research, Development,

Demonstration, Testing, and

Evaluation Plan (RDDT&E)

The draft DOE RDDT&E plan of November

1989 singles out three specific needs’ to overcome

problems in TRU waste management, in addition to

opening WIPP for its 5-year demonstration period.

These include the need for “better TRU waste

treatment to meet WIPP certification requirements,’

“better characterization of RCRA components in

TRU waste for certification,’ and ‘disposal options

for TRU waste not certifiable for WIPP” (47).

In the area of TRU waste treatment, wastes for

which treatments must be demonstrated include

“resins and sludges that release water during

storage, organic waste forms that generate excessive

gas, and reactive metals such as sodium and

sodium/potassium mixtures. ’ Technologies of interest to DOE for treating noncertifiable TRU waste

include ‘‘microwave melting, plasma decomposition, smelting, denigration, dehalogenation, incineration with the resulting ash solidified by cementation or in-can melting, and chemical oxidation by

nitrate salts’ (48). Concreting or grouting and

reactive metal neutralization are also of interest,

In the characterization area, the DOE RDDT&E

plan indicates that technologies are needed to better

characterize the containers of stored TRU waste,

which can be found at most sites, for their hazardous

RCRA components, as well as to determine which

are and which are not TRU waste. According to the

report, the ‘‘technologies to be used in this area have

not been identified’; DOE is in the review and

survey stage (49) (see figure 2-10).

Waste that is noncertifiable for WIPP will have to

be disposed of elsewhere in other ways; such waste

includes oversized packages, large pieces of equipment, waste containing high explosives, and certain

classified waste. DOE is working on a technology

called Greater Confinement Disposal (GCD) at the

Nevada Test Site (NTS); this involves placement in

a deep hole, as an alternative to WIPP disposal for

noncertifiable TRU waste. GCD has been used at

Savannah River and Oak Ridge for someGreater-thanClass C LLW (50). It has been undergoing evaluation at NTS with the goal of compliance with EPA

standards (40 CFR 191) for management and disposal of HLW and TRU waste (50).

The RDDT&E plan focuses explicitly on some

aspects of TRU waste management for retrievable

stored waste; research and development for buried

TRU waste are addressed indirectly. For example,

although buried TRU waste at Idaho is mentioned as

an example of a particular problem to be solved (51),

it is not singled out as a distinct category. Nevertheless, buried waste will clearly benefit from research

on the “Problems in Remediating Contaminated

Soils,” which is part of the plan (52).

One aspect that needs more work is setting

priorities for technologies that might be useful rather

than simply listing them. There is little information

in either the 1989 RDDT&E plan or the 1990

Five-Year Plan that would help distinguish between

what is being funded and what is not. Also WIPP is

considered to be outside these plans because it has

already been built and a 5-year demonstration phase

is planned. Nevertheless, research is needed on gas

generation in alternative TRU waste forms for

WIPP, as well as on aspects of the interaction

between waste and the surrounding WIPP medium.

Actinide Conversion (Transmutation)

The idea of separating out the actinide elements

(uranium plus the Transuranics) from high-level

waste created from spent fuel in commercial nuclear

reactors and of recycling the actinides to a reactor

has been considered for some time. Removal of

actinides from the waste could conceivably remove

a significant portion of the long-lived radioactive

hazard; putting the actinides back in a nuclear

reactor or accelerator can result in a reduction of

their radioactivity as a result of fission or conversion

~Ibid.
86 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

Figure 2-10-Characterization of Transuranic Waste To Determine Disposal Option

P

LLW

DISPOSAL

I NO

NON-RCRA

HAZARDOUS

RADIOACTIVE WASTE

NEWLY GENERATED

OR RETRIEvED CHARACTERIZATION WIPP DISPOSAL

TRU WASTE

RCRA HAZARDOUS

RADIOACTIVE WASTE

I NO

Note:

1 Curie = 1,000,000,000 nCurie Ekl

SOURCE: U.S. Department of Energy, “Applied Research, Development, Demonstration, Testing and Evaluation

Plan,” Draft, 1989.

(transmutation) 69 to shorter lived isotopes. However, as Benedict et al. point out in a 1981 book, (14)

“The reduction of the ingestion hazard after recycling equilibrium has been reached will be only

modest, and the technical effort will be enormous.

The technology for actinide partitioning is not

available as yet, and considerable development will

be required to make it available. Moreover, it has to

be considered that part of the actinides are transferred from the waste to the fuel cycle on recycling,

where they may create an even greater hazard than

the waste. ”

Although these authors are skeptical about the

benefits of actinide separation for high-level waste,

they are more optimistic about treating TRU waste

in this manner. They point out that for some forms

of TRU waste, actinide recovery could appreciably

reduce the ingestion hazard of the waste because of

the relatively low fission product concentration

compared to high-level waste.

70 Furthermore, it

should be simpler technically to accomplish this for

TRU waste than for high-level waste (15).

A more recent (1989) analysis of actinide conversion by Rockwell International is somewhat more

positive. The Rockwell authors believe that whereas

aqueous reprocessing does not lend itself well to

6~e te~s transmutaa”on and Patiitioning, or just transmutan”on, are often used to characterize what we have cdkxi acfi”nide conversion.

Transmutation involves converting one chemical element or isotope into another by a nuclear reaction. In principle, long-lived -adioisotopes in nuclear

wastes could absorb neutrons in a fission reactor or a future fusion reactor and be converted into short-lived or stable isotopes, A practical system would

need to be capable of separating or partitioning isotopes in a special reprocessing syste~ and fabricating the long-lived ones into a form for further

irradiation. (See R.L. Murray, Understanding Radioactive Waste, 3d cd., Batelle Press, 1989, p. 123.)

TO~es~bly this ~alysis aISO holds for inhalation hazards, the principal concern about alpha-emitting radionuclides such m plutorl.ium.
Chapter 2--Managing Transuranic Waste at the DOE Nuclear Weapons Complex ● 87

actinide conversional the development of a new

concept involving pyrometallurgical processing of

fuel from a metallic fast reactor could ultimately

yield economic benefits, compared to the disposal of

spent fuel in the commercial sector. In addition,

according to the Rockwell report, risks due to

accidents or environmental contamination would be

reduced. In the Rockwell concept, not only are

‘‘minor actinides” (i.e., nonplutonium actinides)

reduced at the rate of about 5 percent per year in a

dedicated facility for that purpose, but technetium99, a long-lived radionuclide that tends to follow

LLW, is also transmuted to shorter-lived radionuclides after separation and return to a reactor.

Separated strontium-90 and cesium- 137 are handled

by allowing them to decay for a hundred years or so

rather than transmuting them or putting them in a

facility for 10,000-year waste (39).

Although the Rockwell concept is directed primarily at the commercial sector, it might apply to the

defense sector. In the latter, reprocessing to recover

plutonium is an accepted practice and major goal, in

contrast to the commercial sector where concern

about the proliferation of plutonium has been a

factor in the United States not encouraging such

activity. In many ways, a facility that permits

partitioning of the waste and transmutation of

certain targeted radionuclides, which will drastically

reduce the long-lived radionuclide population, is an

appealing concept. Additional research in this direction could well be valuable, particularly if long

delays in repository opening persist.72 However, the

integrated fast reactor and pyrometallurgical fuel

processing facility are far from functional realities

and would require the development of an entirely

new nuclear fuel cycle. Both pyroprocessing and an

aqueous process known as Thorex are being worked

on by two different groups at Argonne National

Laboratory. Each must contend with the fact that

only a fraction of the TRU radionuclides loaded into

a reactor is transmuted in a given cycle.

At least a decade or two will probably be required

before actinide conversion becomes a practical

possibility and the costs could be high.73 Thus, in the

short run, actinide conversion does not appear to be

a significant factor in high-level or TRU waste

management.

74 Nevertheless, converting TRU elements in tank waste to useful elements through a

new ‘‘waste burn” technology is one of the rationales put forward in a Westinghouse report to prevent

DOE from eliminating funding for the Fast Flux Test

Facility (92).

Waste Minimization

One element of the RDDT&E plan involves

research on the minimization of waste from plutonium manufacturing and processing. TRU and

byproduct waste are generated by all plutoniumrelated operations, including raw materials, component manufacture, scrap reprocessing, or reclamation. Currently, typical reprocessing of plutonium

oxides and scrap is performed pyrochemically or via

aqueous methods involving nitric or hydrochloric

acid. Research is striving to improve plutonium

yields, reduce the quantities of scrap, reduce waste

and processing of byproducts, and reduce hazardous

chemicals and the amount of mixed waste. Among

the opportunities for minimization listed by DOE are

formin g blanks closer to final size, improving the

precision of machining operations, using robotics

and automation in handling operations, and improving plutonium recovery by employing fewer chemicals and producing less plutonium-bearing waste

(53).

Research and development on the minimization

of waste from plutonium manufacturing and processing could yield real benefits, in terms of reducing

both the amount of waste to be treated or disposed of

and the safety and health threats to workers. It should

be vigorously pursued.75

TIB~ ~onhast, it ~s ken s~t~ elsewhere titseparation by pyroprocessing is not as good as aqueous proc~sing. SO~ce: L. Lidsb* ~ofessor o

f

Nuclear Engineering, Massachusetts Institute of Technology, personal communicatio~ Apr. 30, 1990.

Tz~eJapanewUempo~ed to~ ~ovingahad~tha lo-yarewmcheffo~ the ~egaprogr~ to cr~tea system to transmute radioactive nuclides

in spent fuel using proton and electron accelerators. (See Nuclear Waste News, Nov. 29, 1990, p. 467.)

73~s view is supwfiedby Lids@, who believes that 10 years from no~,actinide convemionwo~dnot be a reality; heViewsit IIIOIW M a kChtlOIOgy

of last resort. Source: (Lidsky, L., op. cit., footnote 20.)

74~s view is Suppofled by a -h1990 s~tment by the Radioactive Waste ~nagementcomm.i~ee J3~au of the @ganization fOr Economic

Cooperation and Development/Nuclear Energy Agency.

75~ere is some ~dication of fow~d movement in ~regard at ~E+ At the Feb~ 1991 Waste -gementconference in~CSO~~,it Was

announced that DOE had reallocated 25 percent of its FY 1990 process developmetn funds, some $44 millio~ to waste minimization R&D. The fraction

allocated to TRU waste ~tion was not indicated.
88 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

THE REGULATORY

FRAMEWORK

Introduction

The regulatory framework for TRU waste is a

complicated one. There are some similarities between regulation of TRU and high-level waste and

some differences. TRU waste, as a distinct category,

was not formally defined until 1974, when the U.S.

Atomic Energy Commission (AEC) proposed new

radiation protection standards in the Federal Register (20); prior to that, it had not been distinguished

from LLW. The current definition of TRU waste

both in a Department of Energy (DOE) order and as

codified by the Environmental Protection Agency

(EPA), is quite quantitative and specific. It also

differs from the earlier definition in that the previous

lower radioactivity limit of 10 nanocuries per gram

has been increased by a factor of ten.

TRU waste is generated, buried, or stored at a

number of DOE Weapons Complex sites. Plans call

for stored and newly generated waste to be treated,

certified, and transported to the Waste Isolation Pilot

Plant (WIPP) for disposal. Thus, as many as 22

States in addition to the Federal Government have a

regulatory stake in the management of TRU waste

within or moving through their boundaries. In

addition, much TRU waste is mixed waste.76 Whereas

much high-level waste (HLW) is also mixed waste,

in tie latter case the relative hazards are believed to

be such that safe handling of the radioactive

component will in many instances ensure safe

handling of the hazardous component. For some

TRU waste, however, the hazardous component may

assume more importance. The regulatory framework

thus encompasses a wide spectrum of elements—

DOE orders; EPA and NRC standards; and various

agreements among Federal, State, and other parties.

Although the Nuclear Regulatory Commission

was given regulatory authority over civilian nuclear

power, its role in connection with defense sites is

very limited. Because TRU waste is almost exclusively a product of defense activity, DOE, through

the mechanism of DOE orders that are not codified,

retains considerable regulatory authority over its

own activities.

Definition of Transuranic Waste

In Nuclear Imperatives and Public Trust: Dealing

With Radioactive Waste, L. Carter provides some

historical background concerning the definition of

TRU waste. Evidently, TRU waste was not explicitly defined until 1974 when the Atomic Energy

Commission proposed a rule (10 CFR Parts 20 and

50) defining TRU waste as any material with 10

nanocuries of TRU radionuclides per gram (20).

Carter cites this proposed regulation as one of a

series of events that worked against the development

of a commercial reprocessing facility at Barnwell,

SC: “TO establish this threshold, at a level almost

too low to be measured, meant that large amounts of

general-process trash at Barnwell. which otherwise

might have been regarded as ordinary LLW and

disposed of as such, now would have to be kept in

retrievable storage and eventually shipped to a

geologic repository” (20). Carter points out that the

proposed rule never took effect and was superseded

by NRC regulations in 1982 setting the lower limit

for TRU waste at 100 nanocuries per gram. By that

time, the Barnwell Plant had been abandoned, in part

due to U.S. concerns about plutonium proliferation.

The new definition places TRU waste somewhere

in between HLW and LLW.77 However, at the upper

end of the TRU waste definition, there appears to be

no clear demarcation between TRU and high-level

waste. The concentration of Transuranics in Hanford

soil is reported to be as high as 40,000 nanocuries per

gram on the surface (22). According to current waste

acceptance criteria, remote-handled TRU waste

containers with surface dose rates as high as 1,000

rem per hour may be shipped to WIPP (72), equaling

or exceeding the surface dose rates estimated for

some defense high-level waste canisters.

A meeting that appears to have been instrumental

in changing the definition of TRU waste took place

at Gaithersburg, MD, in August 1982. Representatives of the program committee for that Workshop

on Management of Alpha-Contaminated Waste

were, with the exception of one EPA representative,

WI&= is illustrated by the fact that 62 percent of all retrievable stored TRU waste through 1988 was at the Idaho National Enginefig hboratory

(INEL) and, of this, approximately 95 percent was suspected to be mixed waste. (See J. Solecki, “INEL Waste Managemen~” viewgraph C8 4870,

1989.) A somewhat lower percentage, 40 pereent, of all TRU waste stored at eight sites managed by DOE Albuquerque operations (excluding INEL

and Rocky Flats) is estimated to be mixed waste as of December 31, 1989. (See R. Ortiz, U.S. Department of Energy Albuquerque Operations OffIce,

personal communication to P. Johnso~ Apr. 10, 1990.)

77~ tie ~d-198@, an effofi was ~de t. revise me def~tiom of ~@.level, mu, and low-level wastes but to no av~l. For a use~ discussio~ see

the report by Kocher and Croff (29).
Chapter 2--Managing Transuranic Waste at the DOE Nuclear Weapons Complex ● 89

all DOE employees or contractors. The program

committee concluded that ‘‘a level of 100 nCi

[nanocuries] of long-lived alpha contamination per

gram of waste, averaged over the contents of a waste

package, can be designated as a concentration of

long-lived alpha-emitting radionuclides in LLW

destined for near surface disposal that is unlikely to

result in exceeding present dose limits’ (13). In

1984, EPA codified this result in the Federal

Register by making 100 nanocuries per gram the

lower limit for the definition of TRU waste. Evidently, there were no objections during the public

comment period.

The impetus for changing the lower bound of the

TRU waste definition from 10 to 100 nanocuries per

gram could have been due to a variety of factors.

Improvements in assay techniques were making it

possible to measure Transuranics down to the 100

nCi/gm level. If it is easier and cheaper to dispose of

LLW than TRU waste, the lower bound has considerable economic importance. It could affect such

matters as how much cleanup must be done on

pre-1970 buried waste at defense sites and how

much must be packaged to go to WIPP. Thus, costs

and benefits must be considered. It has been

estimated that the redefinition of TRU waste served

to reduce the volume of plutonium-contaminated

soil at Hanford from 400 million to 100 million

cubic feet. The redefined 300 million cubic feet

would then be subject to less stringent cleanup

standards, thus reducing the cost but increasing the

risk.

The draft Environmental Impact Statement (EIS)

by EPA for disposal standards for TRU and highlevel waste (40 CFR 191) that was remanded by a

court seems to treat TRU waste as a corollary to

high-level waste: “The proposed standards [for

spent fuel and high-level waste] also apply to wastes

containing alpha-emitting TRU nuclides with halflives greater than 1 year78 at concentrations greater

than 100 nanocuries per gram” (87). After pointing

out that alpha-emitting TRU nuclides constitute a

special type of hazard because of their long halflives and high radioactivity, the draft EIS cites two

or three studies that provide some guidance as to

what the concentration level at the interface between

TRU and LLW might be and concludes that TRU

waste with concentrations higher than 100 nanocuries per gram should be included under EPA

standards. However, the scientific evidence does not

appear convincing. Based on the same data, a

different lower limit (i.e., 10 nanocuries per gram)

could have been defined.

A definition is not a safety standard. The grouping

of TRU waste with high-level waste in developing

EPA disposal standards indicates that these two

wastes have something in common that requires

somewhat similar disposal. TRU waste, unlike

LLW, is supposed to be placed in a repository rather

than disposed of at or near the surface. This is

consistent with DOE and predecessor agency policy

back to the 1970s when the WIPP idea originated.

However, regardless of the definition, waste--

whatever the category-must meet certain disposal

standards that, according to the present system, are

determined by the radiation dose and the risk to

individuals under a variety of scenarios.

Regulations Affecting Transuranic

Buried Waste

Waste

At a National Academy of Sciences meeting on

buried TRU waste at the Idaho National Engineering

Laboratory (INEL), the principal DOE contractor,

EG&G-Idaho, described the risk and performance

assessment work underway concerning alternative

methods of dealing with buried TRU waste in the

Subsurface Disposal Area (SDA) at INEL. A summary of the approach follows.79

Because of the mixed nature of the waste, both

health-based risk assessments concentrating on shortlived effects and performance assessments focusing

on long-term risks must be considered. Health-based

risk assessments conducted under the Comprehensive Environmental Response, Compensation and

Liability Act (CERCLA) involve identification of

contaminants, exposure assessment, toxicity assessment, and risk characterization.80 The health-based

risk assessment at the SDA is currently in the early

stages, as part of the Remedial Investigation/

Feasibility Study (RI/FS) process. Performance

assessment at an existing burial site raises many

questions: What requirements apply? What intrusion scenarios should be considered? What siting

Ts~e ~.~e Ifit was chnged to 20 years in the “fii” stidmd.

79RR, pi~cltella, EG&G I&&~, ‘$ovewiew of fi,+@efiomnce Assessmen~” p~sen~tion wi~ view~ap~ ~de @ tic National Academy Of

Sciences Panel to Review the DOE Assessment of Pre-1970 Buried Waste at the Idaho National Engineering Laboratory, November 1989.

~42 U. S.C.A. $$6904(i)(6)(A)-(F) (west SUPP. 1990).
90 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

criteria apply? What waste acceptance criteria apply?

What type of data are needed?

A problem associated with EG&G’s SDA performance assessment concerns the lack of appropriate regulations for old burial sites. EG&G’s approach, as presented at the National Academy of

Sciences panel meeting, was to apply regulations for

new geologic disposal sites to the old burial sites, as

illustrated by table 2-5. EG&G concluded that

“performance assessment will require using applicable parts of regulations that were written for new

disposal sites” and that “DOE orders, CFRs, and

other ARARs [applicable or relevant and appropriate requirements] that apply to SDA risk assessments will be identified in the RI/FS work plan. ’’81

However, some members of the panel objected to

applying EPA regulations for new deep repository

sites (40 CFR 191) to the old shallow land burial

sites. Furthermore, the regulations for repositories

have been remanded by a court and must be reissued.

In November 1989, INEL was placed on the

National Priorities List (NPL) under CERCLA.82

Some work on risk assessments was underway

during 1990 on certain remedial actions associated

with buried TRU waste, namely, retrieval of the

waste, vapor vacuum extraction of subsurface organic vapors, and in situ vitrification.83 Furthermore, alternative strategies for remediating the

buried TRU waste have not yet been thoroughly

evaluated.84

Waste Storage

The rules applicable to TRU waste storage

encompass the following: EPA regulations governing the hazardous component of the mixed TRU

waste (particularly those referred to as land-ban

restrictions), State imposed restrictions (e.g., the

decision by the Governor of Idaho not to accept any

more Rocky Flats waste and the decision by the

Governor of Colorado to limit the volume of mixed

TRU waste that can be stored at Rocky Flats), DOE

Table 2-5--Potential ARARs for Assessment of Buried

Waste at the Subsurface Disposal Area at INEL

Applicable or Relevant and

Appropriate Requirements (ARARs) Source

1.

2.

3.

4.

5.

For 1,000 years of groundwater protection

. 15 picocuries/liter of alpha-emitting

radionuclides

. Beta or gamma radiation, annual dose

equivalent 4 millirems

For 1,000 years of human protection-all

pathways annual dose equivalent

● 25 millirems whole body

● 75 millirems critical organ

For 10,000 years to have less than one

chance in 10 of exceeding limits defined in

this CFR

For 10,000 years to have less than one

chance in 1,000 of exceeding 10 times the

limits defined in this CFR

For protection from inadvertent intrusion at

any time after institutional control

To maintain radioactive exposures as low as

reasonably achievable (ALARA)

40 CFR 191

40 CFR 191/

10 CFR 61

40 CFR 191

40 CFR 191

10 CFR 61

10 CFR 61

SOURCE: Adapted from J. Sole&”, “INEL Waste Management, ’’viewgraph

C8 4870, 1989.

orders (particularly those dealing with purely radioactive materials), and requirements of Federal Facility Agreements, Consent Orders and interagency

agreements involving EPA, DOE, and State agencies.

EPA land disposal restrictions for hazardous and

radioactive mixed waste generally prohibit or ban

the storage or disposal of hazardous waste unless it

is treated according to EPA-approved methods. At

present, there is a 2-year variance from these

restrictions, due to a lack of treatment capacity.

Since much TRU waste is mixed waste (i.e., it has

both hazardous and radioactive components), it is

generally covered by the present variance from the

land ban rules.85

Certification and Transport of Waste to the

Waste Isolation Pilot Plant

According to the DOE 1989 Five-Year Plan,

‘‘The Waste Acceptance Criteria Certification Com81~id., viewgaph %10174.

82w.N. Sate, U.S. Dep~mt of Ener=, viewWaPh Eg@0Gs6 at Natio~ &ademy of Sciences panel Meeting On Buried TRu Waste at I&iho, Ma.

2021, 1990.

S3R.R. Piscitefla, presentation at National Academy of Sciences Panel Meeting on Buried TRU Waste at Idaho, ~. 2@21, 1~.

~~a~yz~g ~tmmtives forremediat~ b~ed Wrote atI~, historical and Political factors must be considered. According to a~EPresen@tion

made to the OTA project team during a visit to INEL in 1989, commitments were made on three separate occasions, twice in 1970 and once in 1973,

by AEC officials to remove buried waste from Idaho. (See SoleCki, J., “INEL Waste Management,” Viewgraph C9 0084, 1989.)

85~ Jwe 1990, reco@z~g lack of Emmmt capaci~ nation~de, EPA issued a a.ye~ v~~fromthe mixedw~tehnddisposal regdations. h

extension to this variance of up to 1 yew, which maybe extended for an additional year, can also be obtained upon request on a case-by-case basis. (See

Land Disposal Restrictions for Third Thirds Schedule Wastes, 44 F.R. 22320,22644 (1990); and Proeeduresfor Case-by-Case IZxtensions to an Effective

Date, CFR $268.5 (1989).)
Chapter 2--Managing Transuranic Waste at the DOE Nuclear Weapons Complex . 91

mittee (WACCC), consisting of representatives

from EPA, the State of New Mexico, and DOE,

negotiated and established stringent criteria on the

form of waste acceptable at the Waste Isolation Pilot

Plant” (60). However, this statement is contradicted

in the WIPP Supplemental EIS. The latter document

says that the Waste Acceptance Criteria (WAC) for

WIPP were “developed by a DOE-wide committee

of experts. . . .“ Furthermore, the WACCC was

established in 1979, prior to EPA becoming involved in WIPP (31). The role of a more broadly

based WACCC, involving groups outside DOE,

seems to be limited primarily to ensuring compliance with the acceptance criteria that DOE established (73). For example, even though EEG has

participated on audit teams in certification reviews,

their review can be accepted or rejected by DOE.86

This situation could be significant, if outside parties

seek to influence the outcome of the debate about

modifying the waste form for WIPP.

According to the 1989 Five-Year Plan, DOE

shipments of radioactive material are regulated

primarily by the Department of Transportation and

the NRC; EPA and the Interstate Commerce Commission also have regulatory roles. DOE also

indicates that it abides by State, Indian tribal, and

local regulations ‘‘consistent with Federal requirements. Regulations cover design and testing of the

transport package; shipment identification including

labeling, marking, placarding, and preparing shipping papers; package and vehicle inspections; and

routing and driver training for spent fuel and

high-level waste” (63).

In 1989, the NRC approved the TRUPACT-II

container design for use in shipping contact-handled

TRU waste to WFP. However, beginning late in

September 1989 and continuing into the first half of

1990, the NRC found a variety of manufacturing

defects in the initial 15 TRUPACT-II containers

during routine inspections which led the NRC to

notify DOE and the manufacturer, the Nuclear

Packaging Division of Pacific Nuclear Corporation

(NUPAC), of noncompliance. An NRC inspection in

late August 1990 of six new TRUPACT-II units in

various stages of completion revealed that the units

and manufacturing processes were inadequate. It is

alleged that earlier, NUPAC had filed a request to

the NRC “on behalf of the Department of Energy”

to amend the specifications in the standards for the

dimensions of the containers so that the 15 original

containers manufactured by NUPAC would be

acceptable; NRC turned down NUPAC’s petition.87

The issue of safe transportation of waste to WIPP

will undoubtedly continue to be an area of technical

and public concern.

Regulations Affecting the Waste Isolation

Pilot Plant

The function of WIPP, as set forth in the

Department of Energy National Security and Military Applications of Nuclear Energy Act of 1980

(Public Law 96-164), is to serve “as a defense

activity of the Department of Energy. . . for the

express purpose of providing a research and development facility to demonstrate the safe disposal of

radioactive waste resulting from the defense activities and programs of the United States exempted

from regulation by the Nuclear Regulatory Commission” (64). From the outset, certain oversight

activities were established through legislation. The

original legislation authorizing WIPP requires that

the Secretary of Energy consult and cooperate with

appropriate officials of the State of New Mexico

concerning health and safety concerns and that a

written agreement be entered into by the two parties

specifying procedures for such cooperation and

consultation. That agreement has been rnodified

several times since its enactment (69).

DOE must comply with a variety of Federal

requirements applicable to WIPP, including the

National Environmental Policy Act (NEPA), RCRA,

and EPA disposal standards for TRU waste (69).

Under NEPA, a Record of Decision must be issued

by the Secretary of Energy subsequent to having

received comments on the Supplemental Environmental Impact Statement. Under RCRA provisions,

DOE must show, in a “no-migration” petition to

EPA, that the hazardous component of the waste to

be placed in WIPP will not migrate. DOE must also

demonstrate that radioactive materials in the repository will conform to EPA disposal standards (40

CFR 191) for TRU waste.88 These standards are

86R. Neill, Environment~ Evaluation Group, personal COmmlUdMtiOIL June 29, 1990.

alweapon$ complex Monitor, Sept. 17, 1990, pp. 19-20.

SS~ere is ~n~p~nt di~fiction ~~WnDOE d~onstrating ~mpli~mwi~EPA &spo~ s~nd~ds for tiioactivity and EPA-Rm S@ndds

for migration of hazardous waste. In the latter case, EPA determines whether DOE has complied, whereas for radioactivity, DOE determines compliance,

i.e., self-compliance.
92 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

being reformulated by EPA after having been

remanded by the 1st Circuit Court of Appeals in

Boston because they allowed higher levels of

radionuclide contamination of “drinking water than

in the Safe Drinkin“ g Water Act.89

In September 1990, the Board of Radioactive

Waste Management of the National Research Council (BRWM) convened a Symposium on Radioactive

Waste Repository Licensing in response to “widespread scientific concern and interest in the revisions

being made during the remand of 40 CFR Part

191. ’90 Among those concerns was a recommendation expressed to the chairman of the NRC by the

Commission’s Advisory Committee on Nuclear

Waste, that:

. . . the Commission object to the EPA standards on

the basis that

—There are no obvious ways for demonstrating

compliance of any specific repository site with the

Standards. In this sense, the Standards may be

unrealistic.

—The Standards are also overly stringent and

inconsistent. There is strong evidence that they

will be wasteful of resources with little commensurate interest.9l

The BRWM convened the Symposium shortly

after issuing a position statement entitled ‘‘Rethinking High-Level Radioactive Waste Disposal.”92

That statement indicates that, given what the BRWM

characterizes as the current highly inflexible U.S.

technical approach to high-level waste disposal

coupled with the U.S. regulatory approach, it is

unlikely that effort will succeed. The BRWM

proposes an alternative approach that they believe

will “require significant changes in laws and

regulations, as well as in program management. ’ ’93

Although the BRWM statement focuses on highlevel waste disposal, its analysis of regulations and

standards is relevant to TRU waste disposal.

At the symposium, the Environmental Evaluation

Group (EEG) defended the current approach being

used by EPA in setting the disposal standard as

follows:

Reasonable confidence in the prediction of site

behavior for 10,000 years or more is achievable

using well-established principles of geosciences.

EPA’s approach of probabilistic release limits with

flexibility in the implementation of the Standard is

a sound one. EEG believes that the numerical basis

of the Standard is set at a level that is reasonably

achievable for a good site that is properly engineered, and should not be significantly relaxed.94

In arriving at this conclusion, EEG pointed out

that any drastic change from the 1985 (remanded)

standard might delay the issuance of a final standard

for several years, causing uncertainties at WIPP. In

addition, if the new Standard were to differ significantly from the remanded one, it would greatly

increase the probability of a remand of the new

standard .95

A distinction has developed between the regulatory compliance required for a fully operational

WIPP facility and that required for an initial set of

experiments in WIPP. On November 14, 1990, EPA

published its decision to rule in favor of DOE’s

no-migration petition, conditional upon DOE activity being limited to an initial test phase.96 EPA thus

will allow DOE to emplace waste in WIPP for the

test phase without demonstrating that ultimate

disposal standards will be met. The decision is

justified by the research nature of the experiments

and the fact that the waste will be retrievable, if

necessary, during and immediately after the test

phase. However, in so doing, EPA is allowing a

different path to be taken for WIPP than for the

high-level waste repository; in the latter, current

policy is that construction cannot begin until compliance with long-term disposal standards is demonstrated.

89C ‘EPA Waste Re@ation comes Under Fire at National Research COunCd Meeting, ” Nuclear Waste News, Sept. 20, 1990, p. 366.

%tler from Frank L. Parker, BRWM, to John H. Gibbons, OTA, Aug. 22, 1990.

glrbid., p. 1.

%National Academy of Sciences, “Rethinkm“ g High-Level Radioactive Waste Disposal: A Position Statement of the Board on Radioactive Waste

Management” (Washington DC: National Academy Press, 1990).

$’31bid., p. 5.

94R.H@ Nei~, J-K. ~me~, and L, c~~~, “Ne~ Mexico fi~nmen~ Ev~~tion Group persp~tive on Transuranic and High-Level WaSte

Disposal Regulations,” paper presented at Symposium on Radioactive Waste Repository Licensing, Board on Radioactive Waste Management

Washingto~ DC, Sept. 17-18, 1990, p. 2.

g51bid., p. 11.

MConditioti No-Migration Determination for the Department of Energy Waste Isolation Pilot Plant (WIPP), 55 Fed. Reg. 47700 (1990).
Chapter 2--Managing Transuranic Waste at the DOE Nuclear Weapons Complex . 93

In an October 1989 briefing by DOE about its

plans for WIPP, the decision of whether to move

ahead with the test phase was asserted to be the

prerogative of the Secretary of Energy. In the DOE

presentation, three categories of action were listed as

being necessary to move forward: technical internal

actions for which approval rests within DOE;

technical external actions for which approval or

comment resolution is required from external organizations such as EPA or EEG; and “institutional”

issues (58). DOE has since focused considerable

attention on the latter category in order to keep the

WIPP program moving forward according to their

plans. For example, once the conditional nomigration petition was issued by EPA, the biggest

remaining obstacle to placing the first experimental

waste package in WIPP was accomplishing land

withdrawal. Since Congress did not proceed to enact

land withdrawal legislation, DOE obtained the

necessary land administratively in early 1991. Thus,

although there are some checks and balances, the

WIPP project remains to a considerable extent under

the control of the Department of Energy.

DISCUSSION

Definition of, and Standards for, Disposal of

Transuranic Waste

The change in the early 1980s of the lower limit

in the definition of TRU waste from 10 to 100

nanocuries per gram of alpha radioactivity allowed

more waste to be classified and treated as LLW. This

shift, given current disposal practice and plans that

call for LLW to be disposed of at or near the surface

(whereas TRU waste requires deep geologic repository disposal), is expected to result in tens or

hundreds of millions of dollars in savings. However,

irrespective of definition, the waste, whatever its

classification, must satisfy the standards set for its

disposal.

The Environmental Protection Agency (EPA) is

in the process of reissuing disposal standards for

spent fuel, high-level waste (HLW), and TRU (40

CFR 191); as a result of a lawsuit by several States

and environmental groups, an earlier version of the

standards was found wanting by the First Circuit

Court, Boston, and remanded.97 A second working

draft of the revised standards was issued for comment in 1990. When promulgated, these standards

will apply to the Waste Isolation Pilot Plant (WIPP)

if and when it becomes operational as a disposal

repository for TRU waste. These standards will be

subject to debate, both within the technical community and the public at large. Among the issues that

might be debated are the length of time that the waste

must be isolated from the environment and the

desirability of being able to retrieve the waste at

some future date.

Repository Delays; Alternative Storage and

Disposal Strategies

Retrievable stored TRU waste at Department of

Energy (DOE) sites is located at 10 Weapons

Complex sites, generally as loosely packed material

in 55-gallon drums stored at or near the surface. The

nominal design lifetime of the drums is about 20

years; some have already reached that limit. Current

plans call for TRU waste to be shipped to a deep

geologic repository for disposal in a form not very

different from its current form. The only possible

repository available for the stored waste is the Waste

Isolation Pilot Plant near Carlsbad, NM. Construction of WIPP is essentially complete. As of early

1991, however, no experiments have yet been

performed involving placement of waste in the

facility to aid in determining if WIPP is a suitable

facility for long-term disposal of TRU waste. In

addition, even if the earliest date-1995-for opening WIPP on an operational basis is achieved, it will

take 25 to 30 years to fill the facility with currently

stored and yet-to-be generated TRU waste.

There is thus a need to identify other alternatives

for short-, intermediate- and long-term storage of

TRU waste. In the short term, DOE is confronted

with the mixed TRU waste that has been accumulating at the Rocky Flats Plant since September 1989

when the Governor of Idaho refused to allow further

shipments to the Idaho National Engineering Laboratory (INEL). Although the start-up of a supercompactor in 1991 may ease the situation somewhat,

among the options DOE has been exploring are

sending the waste to other DOE facilities, to Federal

non-DOE facilities, or to privately owned facilities.

Each option is likely to encounter resistance from

States and citizens. The policy implications of the

privatization option, which DOE appears to be

pursuing (147), require careful scrutiny. Putting

defense TRU waste in the care of a private contractor

97-c”. wA, 824 F. Zd 1258 (l~t c~. 1987); 26 ERC 1233, J~y 17, 1987 as amended Sept. 24, 1987; “COW Remands Nuclear Waste Site Rules,

Cites Conflict with Drinking Water Law” Current Developments, Sept. 24, 1987, p. 848.
94 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

at privately owned facilities is a major break with

past U.S. Government practice.

If further significant delays occur in the opening

of a TRU waste repository, which could very well be

the case,98 retrievable stored TRU waste may have

to be treated so that it can be safely stored on-site for

longer periods than is now possible, given the

present condition of the waste. Some of the six new

TRU waste treatment facilities planned for 1992-99

could provide needed treatment capability. Planning

for extended storage and enhanced treatment could

also be compatible with the possible need to change

the waste form to prevent gas generation in packages

placed in the repository. The level of treatment

desirable requires careful study; final recommendations of the Engineered Alternatives Task Force

(EATF) for the WFP project are expected in 1991

and should provide valuable information.

Remediation of Buried Waste

The volume of buried TRU waste at Weapons

Complex sites well exceeds that of retrievable stored

TRU waste. Yet plans for remediating buried waste

at Idaho, Hanford, and other sites are not very

developed. Considerable attention is focused on one

technology-in situ vitrification-which, although

promising, may be of limited utility because of

economic and other factors. Several alternative

strategies need to be examined, with input from the

public. If, in fact, the costs and occupational

radiation exposures are considerably lower when

waste is remediated on-site without exhumation,

local communities will have to be convinced that the

waste will not contaminate local water supplies or

otherwise threaten public health. Careful research

and monitoring as well as a credible outreach

program will be necessary to provide such assurance.

The Waste Isolation Pilot Plant

In accordance with DOE planning and congressional intent, WIPP has remained a central element

in DOE strategy for managing TRU defense waste.

The WIPP geological salt bed facility has been

constructed at a cost of about $700-800 million to

serve as a research and development facility for TRU

waste disposal. After a 5-year experimental phase,

WIPP could become the final resting ground for

retrievable stored and yet-to-be generated TRU

defense waste. Secretary of Energy James D. Watkins developed a detailed decision plan, which was

revised frequently, to help him decide whether to go

ahead with WIPP; in June 1990, he made a positive

decision on WIPP’s readiness to proceed with a

limited number of experiments. At present, the

consensus of the various DOE technical oversight

bodies supports preparation for limited emplacements of TRU waste in WIPP, in an attempt to

resolve uncertainties prior to deciding whether to

proceed with full operations.

WIPP currently represents the closest the United

States has come to placing radioactive waste in a

deep geologic repository, the option currently favored by DOE, EPA, and the Congress for disposal

of both TRU and HLW. Although placement of the

frost waste package in WIPP will be for experimental

purposes only, and although the package so placed

must be retrievable (in contrast to plans for operational disposal), such placement, if it occurs, will

have symbolic importance. It could signify that after

all these years the United States is finally doing

something about TRU radioactive waste disposal. A

degree of confidence could be restored in the ability

of U.S. science and technology to eventually solve

this tough radioactive waste disposal problem.

However, at this writing WIPP is still not a

certainty. Matters that may still need attention prior

to the start of the experimental phase include: DOE’s

operational readiness for radiation protection, monitoring, and other technical matters; resolution of the

differences between DOE and the State of New

Mexico concerning funds for highway improvements related to the transport of waste to WIPP. 99

Congressional debate and legislation remain vehicles for those who either oppose WIPP entirely or

wish to place certain conditions on its operations.

For example, in 1991 the New Mexico congressional

delegation introduced legislation to cancel the administrative withdrawal of land from the DOI to

DOE.

l00

Two outstanding issues that pertain to WIPP’s

long-term performance as a repository are the

adequacy of the present waste form and the nature of

%under one ~m~o ~m~ented at ~ my ~, 1990, DOE wor~g Session on fie ~p Decision p~n ad ROC@ FkUS plant Alternative Storage

Options, WIPP’S startup is delayed until the year 2003 or 2004 due to the need to build and operate an alternative treatment facility for TRU waste.

~See aISO R.H. Neill and L. cha~edi, “StatuS of WIPP Projeq” paper presented at Waste Management ’91, lhcsoni AZ, Febmq 1991.

I%. Sckeider, “pl~ on Stig Nucleu Waste Clears Big Hurdle, ” The New York Times, Jm. 23, 1991.
Chapter 2-Managing Transuranic Waste at the DOE Nuclear Weapons Complex . 95

the final waste disposal standards for WIPP. At the

April 26, 1990 WIPP hearings, there appeared to be

a consensus among a wide spectrum of technical

oversight individuals that the present TRU waste

form could well prove unsatisfactory for two reasons: gas generation within the waste packages

could result in situations that are too uncertain to

predict with sufficient confidence; and EPA disposal

standards for TRU waste might not be achievable,

particularly under human intrusion scenarios. Disagreement centered on what to do about this situation.

On the one hand, DOE is studying alternative waste

forms and believes that the experiments will provide

useful information. On the other hand, some believe

that the experiments are not likely to shed further

light on the situation, whereas improving the waste

form will be valuable whether or not WIPP becomes

operational. There was no discussion of how the

waste form might be altered or at what cost. A study

of possible options to the present TRU waste form is

underway. It should provide a basis for evaluating

options given the limitations of existing retrievable

stored TRU waste, as well as uncertainties concerning the geologic repository.

A second broad issue concerns the disposal

standards themselves. The disposal standards are

currently being reworked. The Advisory Committee

on Nuclear Waste of the NRC believes the standards

are too strict. However, EEG has pointed out that

EPA in 1982 relaxed the standard for permissible

release of Transuranics from a repository, compared

with high-level waste, by a factor of 3, after WIPP

officials expressed concerns about meeting the

previous limit .

lO1 As a result, because a TRU

repository need comply with lower standards than a

high-level waste repository, EEG opposes any

further relaxation of the standard.

Disposal standards are an important consideration

for those concerned about health and safety. Some

have argued that no experiments should be allowed

in WIPP until DOE demonstrates compliance with

long-term disposal standards. The NRC holds that

construction of a high-level waste repository in

Yucca Mountain, NV, cannot begin until compliance with disposal standards is demonstrated. However, key decisionmaking authority for WIPP rests

with DOE, not NRC. Also, DOE’s position is that

the experiments will be retrievable--it is not yet

disposing of waste. DOE does not expect to be able

to comment on WIPP’s ability to meet disposal

standards until completion of the performance assessment in 1994 or 1995. 102

Finally, demonstrating that a geologic repository

can safely contain waste for ten thousand years or

more is a daunting task. When the WIPP facility is

operational, waste in a TRU repository, as currently

envisioned, will be irretrievable. Future generations

might not consider these acceptable conditions.

There are no easy solutions, but all options should be

considered with as much public involvement as

possible if WIPP is to receive full support.

Waste Minimization

Minimization of TRU waste is an area that might

yield dividends in terms of easing the burden of

cleanup and waste management. One promising area

identified by DOE is in plutonium processing and

manufacturing operations (53). DOE indicated in

April 1990 that approximately $26 million (annually) is budgeted for research and development

related to waste minimization103 (85). It is not clear

how much of this will be devoted to plutonium

operations.

If waste minimization is defined as reducing the

generation of new waste, then very little is being

done in the area of TRU waste minimization. As

DOE has indicated, “high-level and Transuranic

wastes have not yet been given sufficient attention

and emphasis in waste minimization planning’ (86).

Emphasis has been on reclassifying a portion of

existing TRU waste as LLW and segregating hazardous from TRU materials. These are conceptually

different from waste minimization and could increase the amount of waste of all kinds to be

disposed of. All indications are that TRU waste

minimization is just beginning to be considered at

DOE and has a long way to go before benefits are

obtained. The only substantive TRU waste minimi101J.K ~nne~, Enviro~en~ EvdWtion&oup, views on ‘Environmental Radiation Protection Standards for Management and Disposal of Spent

Nuclear Fuel, High-bvel, and Tranuranic Radioactive Wastes (40 CFR 191),’ presented to U.S. Nuclear Regulatory Commissio~ Advisory Committee

on Nuclear Wastes, Mar. 23, 1990, pp. 7-8.

IOzAlthoughOTA~s notperformedany in-depth study of congressio~ intent with regard to WIPP, the authorizing legislation would S@3m to iUdiCate

that it was meant to serve as a research and development facility although the Januafy 1981 DOE Record of Decision on WIPP states that it is intended

for disposal of waste. DOE’s 1979 Draft Environmental Impact Statement envisioned the facility as having several functions, including serving as a

full-scale repository for TRU waste as a step toward gaining experience for a high-level waste repository.

loqsubs~uently, t.his fiWe WaS increu~ to .$44 million. Source: J. Marchetti, remarks at Waste Management ’92, Tbcsom AZ, February 1991.
96 . Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

zation results to date may have come about because

of the shutdown of various facilities, particularly the

Rocky Flats Plant and Savannah River production

reactors.

Scenarios for Future Transuranic Waste

Production

Planning for TRU waste management must take

into account projections of yet-to-be-generated waste.

The DOE Integrated Data Base (IDB) indicates that

the volume and radioactivity of stored TRU waste

are expected to increase substantially; however,

there was a decrease in the amount projected in the

IDB for 1989, compared with the IDB for 1988. The

earlier volume projected an eightfold increase in

TRU waste production from 1987 to 2013, whereas

the 1989 projection is for a 3.5-fold increase from

1988 to 2013 (75,80). This trend has continued in the

latest (1990) IDB. The 1990 projection is for only a

1.9-fold increase from 1989-2013. The lower projection could reflect a scaling down of future weapons

stockpile requirements. Replacing the single scenario in the IDB by several alternative scenarios

would be helpful in planning for future management

of TRU waste.

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

CHAPTER 2 REFERENCES

Abas, B., “Rocky Flats: A Big Mistake From Day

One,” Bulletin of the Atomic Scientists, December

1989, PP. 19-24.

Associated Press News Release, “Civil Disobedience Threatened on WIPP Issue, ’ Apr. 10, 1990.

Associated Press News Release, “DOE Curtails

Plutonium Operations at Rocky Flats,” Nov. 30,

1989.

Associated Press News Release, “Judge Rules Hazardous Waste at Nuclear Plant Illegally Stored,’ Apr.

17, 1990.

Associated Press News Release, “Rocky Flats Official Says Plutonium in Air Ducts Could Kill, ’ Apr.

25, 1990.

Associated Press News Release, “Rocky Flats Top

Colorado News Story of 1989,” Dec. 27, 1989.

Associated Press News Release, “Romer, Skaggs

Conclude There Were No Midnight Burnings at

Flats,” Nov. 30, 1989.

Associated Press News Release, “Scientists Try

Again After Safety Hood Burns,” Mar. 29, 1990.

Associated Press News Release, “12 Flats Workers

Exposed to Beryllium Have Lung Disease,” Jan. 15,

1990.

Associated Press News Release, “2 Class Action

Law Suits Filed Against Rocky Flats,’ Jan. 30,1990.

11.

12.

13.

14.

15.

16.

17.

18.

19.

20.

21.

22.

23.

24.

25.

26.

27.

28.

29.

Associated Press News Release, “WIPP Hearings

Open in Albuquerque,” Apr. 13, 1990.

Associated Press News Release, “Workers Didn’t

Expect Full Holes on Drums,” Dec. 28, 1990.

Benedict, M., Pigford, T. H., and Levi, H. W., Nuclear

Chemical Engineering, 2d ed. (New York, NY:

McGraw-Hill, 1981), p. 606.

Benedict, M., Pigford, T. H., and Levi, H. W., Nuclear

Chemical Engineering, 2d ed. (New York, NY:

McGraw-H.i.11, 1981), p. 601.

Benedict, M., Pigford, T. H., and Levi, H. W., Nuclear

Chemical Engineering, 2d ed. (New York, NY:

McGraw-Hill, 1981), p. 604.

Beral, V., “Leukemia and Nuclear Installations,”

British Medical Journal, vol. 300, Feb. 17,1990, pp.

411412.

Berlin, R. E., and Stanton, C. C., Radioactive Waste

Management (New York NY: John Wiley & Sons,

1989), p. 40.

Berlin, R. E., and Stanton, C. C., Radioactive Waste

Management (New York NY: John Wiley & Sons,

1989), p. 184;

Burns, R., “Flaws in Radiation Protection Cited at

Weapons Plants,” Associated Press News Release,

Dec. 13, 1989.

Carter, L., Nuclear Imperatives and Public Trust:

Dealing With Radioactive Waste (Washington, DC:

Resources for the Future, 1987), p. 111.

Cochran, T. B., Arkin, W.M., Norris, R. S., and

Hoenig, M.M., Nuclear Weapons Databook: Vol. III,

U.S. Nuclear Warhead Facility Profiles (Cambridge

MA: Ballinger Publishing Co.,1987), p. 82.

Coyle, D., et al., Deadly Defense: Military Radioactive Landfills (New York NY: Radioactive Waste

Campaign, 1988), p. 44.

Environmental Evaluation Group, “Review of the

Draft Supplement Environmental Impact Statement,”

Report EEG-41, July 1989, p. 30.

Fitzpatrick, V. F., and Hansen, J. E., “In Situ Vitrification for Remediation of Hazardous Wastes,’ Paper

presented at 2d Annual HazMat Central Conference,

Chicago, IL, Mar. 14-16, 1989, pp. 13-15.

Gallegos, A.F., and Channell, J. K., “Risk Analysis

of the Transport of Contact Handled Transuranic

Wastes to WIPP Through Selected Highway Routes

in New Mexico Using RADTRAN IV,” Environmental Evaluation Group, March 1990, p. 46.

Geosafe Corp., “An Introduction to ISV,’ Kirkland,

WA (no date).

Goldfield, J., ‘‘High Efficiency Particulate Arrestors

(HEPA Filters) in the Nuclear Industry,” September

1988.

Idaho National Engineering Laboratory, “Waste

Management Plan: Annual Update,” EG&G Idaho,

December 1988, revision 2, pp. 4-9.

Kocher, D. C., and Croff, A. G., “A Proposed Classification System for High-Level and Other Radioac-
Chapter 2-Managing Transuranic Waste at the DOE Nuclear Weapons Complex . 97

tive Wastes,” Oak Ridge National Laboratory Report

ORNL/TM-10289, 1987.

30. Lappin, A.R., and Hunter, R.L. (editors), “Systems

Analysis, Long-Term Radionuclide Transport, and

Dose Assessments, WIPP, March 1989,” Report

SAND89-0462.UC-70, April 1989.

31. Little, M. S., “Review Comments on the Report of

the Steering Committee on Waste Acceptance Criteria for the Waste Isolation Pilot Plant,” Report

EEG-4, Environmental Evaluation Group, February

1980.

32. Los Alamos National Laboratory, “HazardousWaste

Incineration at LOS Alamos National Laboratory,”

Brochure LALP-89-30, July 1989.

33. Nelkin, D. (ed.), Controversy: The Politics of Technical Decisions, 2d ed. (Beverly Hills, CA: Sage

Publications, 1984).

34. Nuclear Waste News, ‘‘Battelle Researchers Prepare

for First Full-Scale ISV Test on Mixed Waste,” Mar.

29, 1990, P. 127.

35. OakRidge National Laboratory, Summary Statement

From Program Committee, Proceedings of AlphaContaminated Waste Management Workshop, Gaithersburg, MD, Aug. 10-13, 1982.

36. Perera, J., ‘‘Tests Convince Britain’s CEGB of Value

of Supercompaction, ’ Nuclear Waste News, Mar.

29, 1990, p. 129.

37. Report on Defense Plant Wastes, “DOE Reaches

Agreement With Colorado on Plan To Assess Residues at RFP,” Nov. 10, 1989, p. 209.

38. Report on Defense Plant Wastes, “Plutonium Dust

Accumulation at RFP Worse Than Thought, New

Assay Shows,” Mar. 30, 1990, P. 65.

39. Rockwell International, “Nuclear Waste Management With Actinide Conversion, ” Draft Report

AI-DOE-13568, Nov. 30, 1989.

40. Schneider, K., “Energy Department Says It Still

Plans To Repair Nuclear Arms Plant,’ The New York

Times, Feb. 8, 1990.

41. Scientech, Inc., “An Assessment of Criticality Safety

at the Department of Energy Roe@ Flats Plant,”

Report SCI-DOE-201-89, July-September, 1989, p.

2-1.

42. Seltzer, R., “Nuclear Arms Plants: Idaho Bars Entry

of Plutonium Wastes, ” Chemical and Engineering

News, Sept. 11, 1989, p. 4.

43. Taylor, T., “Verified Elimination of Nuclear Warheads,” Science and Global Security, vol. 1, July

1989, PP. 1-26.

44. U.S. Congress, General Accounting Office, “Nuclear

Waste: Transuranic Waste Storage Limitations at

Rocky Flats Plant,” Report GAO/RCED-90-109,

February 1990, p. 7-8.

45. U.S. Congress, General Accounting Office, “Storage

Issues at DOE’s Waste Isolation Pilot Plant in New

Mexico,’ Report GAO/RCED-90-1, December

1989.

46. U.S. Congress, Office of Technology Assessment,

“Review of the Department of Energy Modernization Plan,’ staff paper prepared by the International

Security and Commerce Program, September 1989,

p. 19.

47. U.S. Department of Energy, “Applied Research,

Development, Demonstration, Testing and Evaluation Plan,” draft, November 1989, p. 146.

48. Ibid., p. 148.

49. Ibid, p. 150.

50. Ibid, p. 152.

51. Ibid., p. xv.

52. Ibid, p. 100.

53. Ibid., pp. 184-85.

54. U.S. Department of Energy, “Assessment of Environmental Conditions at the Rocky Flats Plant,”

Special Assignment Environmental Team Report

DOE/EH-0107, August 1989.

55. U.S. Department of Energy, Defense Waste a n d

Transportation Management, “Program Implementation Plan,’ Report DOE/DP 0059, August 1988, p.

14.

56. U.S. Department of Energy, Defense Waste and

Transportation Management, “Program Implementation Plan,” Report DOE/DP 0059, August 1988,

PP. 16-19.

57. U.S. Department of Energy, “Defense Waste Management Plan for Buried Transuranic-Contaminated

Waste, Transuranic-Cent.aminated Soil and Difficultto-Certify Transuranic Waste,” Report DOE/DP0044, June 1987, p. viii.

58. U.S. Department of Energy, “Draft Decision Plan on

WIPP,” congressional briefing, October 1989.

59. U.S. Department of Energy, “Draft Environmental

Impact Statement: Waste Isolation Pilot Plant,” vol.

1, April 1979, PP. 1-1, 1-2.

60. U.S. Department of Energy, “Environmental Restoration and Waste Management: Five-Year Plan, ”

Report DOE/S-0070, 1989, p. 156.

61. Ibid., p. 168.

62. Ibid., p. 170.

63. Ibid., p. 140.

64. Ibid., p. 1-1.

65. U.S. Department of Energy, “Environmental Restoration and Waste Management: Five-Year Plan;

Fiscal Years 1992-19%,” June 1990.

66. U.S. Department of Energy, “Environmental Survey

Preliminary Report, Idaho National Engineering

Laboratory (INEL) and Component Development

and Integration Facility, Butte, Montana, ’ September 1988.

67. U.S. Department of Energy, “Environment Survey

Preliminary Report, Los Alamos National Laboratory, Los Alamos, New Mexico,” January 1988.

68. U.S. Department of Energy, “Environmental Survey

Preliminary Report, Savannah River Plant, Aiken,

South Carolina,” August 1987.
98 ● Long-Lived Legacy: Managing High-Level and Transuranic Waste at the DOE Nuclear Weapons Complex

69.

70.

71.

72.

73.

74.

75.

76.

77.

78.

79.

80.

81.

82.

83.

84.

85.

86.

87.

88.

89.

90.

91.

92.

93.

94.

U.S. Department of Energy, “Final Supplement,

Environmental Impact Statement, Waste Isolation

Pilot Plant,” Report DOE/EIS-O026-FS, January

1990, vol. 2, PP. A3-A8.

U.S. Department of Energy, “Final Supplement,

Environmental Impact Statement, Waste Isolation

Pilot Plant,” Report DOE/EIS-O026-FS, January

1990, vol. 2, PP. S6-S7.

Ibid., pp. 2-21.

Ibid., p. A-4.

Ibid., p. 81.

U.S. Department of Energy, “Integrated Data Base

for 1988: Spent Fuel and Radioactive Waste Inventories, Projections and Characteristics,” DOE/RW0006, Rev. 4, September 1988,

Ibid., p. 84.

U.S. Department of Energy, “Integrated Data Base

for 1989: Spent Fuel and Radioactive Waste Inventories, Projections and Characteristics, ” DOE/RW0006, Rev. 5, November 1989, p. 5.

Ibid, p. 77.

Ibid., p. 80.

Ibid., p. 81.

Ibid., p. 83.

Ibid., p. 86.

Ibid., pp. 87-88.

Ibid., p. 95.

U.S. Department of Energy, “Radioactive Waste

Management, “ Order DOE 5820.2A, Sept. 26,1988,

attachment 2, p. 4.

U.S. Department of Energy, “Responses to OTA

Questions on the DOE Waste Minimization Program,” draft, Apr. 12, 1990, p. 2.

Ibid., p. 5.

U.S. Environmental Protection Agency, ‘Draft Environmental Impact Statement for 40 CFR 191: Environmental Standards for Management and Disposal

of Spent Nuclear Fuel, High-Level and Transuranic

Radioactive Wastes, ” Report EPA 520/1-82-025,

December 1982.

Wald, M.L., “Barrels at Rocky Flats Plant Contain

Waste, Judge Rules,” New York Times, Apr. 17,

1990.

Weapons Complex Monitor, Apr. 18, 1990, p. 18.

Weapons Complex Monitor, “EPA Proposes To OK

DOE WIPP Test Phase No-Migration Petition,’ Apr.

18, 1990, PP. 2-4.

Weapons Complex Monitor, “Privatization of TRUWaste Storage,” Mar. 27, 1990, P. 23.

Weaver, D., “How To Keep the FFTF Alive and

Profitable,” Energy Daily, June 13, 1990, p. 3.

Westinghouse Savannah River Company, “Savannah River Site Environmental Report for 1988, ”

Report WSRC-RP-89-59-1, vol. 1 (no date).

Hancock, D., Southwest Research and Information

Center, testimony at hearing on WIPP before Senate

Energy and Natural Resources Committee, Apr. 26,

1990, P. 8.

APPENDIX 2-A:

CONDITIONS OF NO-MIGRATION

DETERMINATION

As a condition of granting DOE’s no-migration

petition, EPA is requiring that the following conditions be

met by DOE:

1.

2.

3.

4.

5.

No wastes subject to this determination may be

placed in the WIPP repository for purposes other

than testing or experimentation to determine the

long-term acceptability of the WIPP. In accordance

with 40 CFR 268.6(e), DOE must notify EPA before

it conducts any testing or experimentation not

within the scope of the “WIPP Test Phase Plan:

Performance Assessment,” April 1990 (DOE/

WIPP 89-011, Revision O), as further explained in

section IV.B.1 of this notice. Placement of waste for

the purpose of conducting an operations demonstration is prohibited.

Wastes placed in the repository may not exceed

8,500 drums or 1 percent of the total capacity of the

repository, as currently planned

All wastes placed in the WIPP must be removed if

DOE cannot demonstrate compliance with the

standards of 40 CFR 268.6, before the expiration of

this petition approval, with respect to permanent

disposal of mixed waste in the repository. DOE

must submit a detailed schedule for retrieval of the

waste, including times for completing retrieval as

quickly as reasonably feasible, no later than 6

months after a determination that the repository

cannot meet standards for long-term disposal under

40 CFR 268.6 or 6 months before the expiration of

this petition approval, whichever occurs first.

All wastes placed in the WIPP must be placed in a

readily retrievable manner, as described in section

IV.B.4 of this notice.

DOE must install and operate action adsorption

device designed to achieve a control efficiency of 95

percent in the discharge system of the bin experiment rooms. DOE must monitor the control device

outlet airstream in accordance with the monitoring

plan described in section IV.K of EPA’s proposed

decision (55 FR 13089) as amended by section

IV.B.7 of today’s notice, and it must maintain

design and operating records as described in section

IV.J of EPA’s proposed decision, as amended by

section IV.B.6 of today’s notice. Records must be

maintained at the WIPP facility for the term of this

determination or for 3 years after they are created,

whichever is longer. Records must also be main-
Chapter 2--Managing Transuranic Waste at the DOE Nuclear Weapons Complex ● 99

6.

7.

tained during the course of any enforcement actions

for which they are relevant.

DOE must implement an air monitoring plan

described in section IV.K of EPA’s proposed

decision (55 FR 13089), as amended in section

IV.B.7 of today’s notice. Records must be maintained at the WIPP facility for the term of this

determination or for 3 years after they are created,

whichever is longer. Records must be maintained

during the course of any enforcement action for

which they are relevant.

Conditions relating to waste analysis:

(a)

(b)

(c)

DOE must ensure that each waste container

emplaced underground at the WIPP has no layer

of confinement which contains flammable mixtures of gases or mixtures of gases that could

become flammable when mixed with air. This

prohibition must be implemented by analytical

testing of a representative sample of headspace

gases from each waste drum or individual

container, as described in section IV.B.7 and

V.F.l.a of today’s notice.

DOE must analyze representative samples of the

headspaces of containers to be used in the

bin-scale test and compare these results to the

estimated compositions provided in its petition

for each waste types, as detailed in IV.B.7.b of

today’s notice. If the waste is not compositionally similar, as defined in tables 2 and 3 in

IV. B.7.b, that waste cannot be shipped to the

WIPP until the waste has been treated or

modified such that it is compositionally similar

to the estimates provided in the no-migration

petition. In addition, as prescribed in IV. B.7.b,

DOE must demonstrate the comparability of

bin-scale wastes to wastes described in DOE’s

petition before placing waste in the WIPP for the

alcove tests.

Waste analysis records must be maintained for

the term of this determination or for three years

after generation, whichever is longer. Records

must also be maintained during the course of any

enforcement action for which they are relevant.

The records may be maintained at the generating

site or at the WIPP facility.

8. DOE must provide to the EPA Office of Solid

Waste and EPA Region VI annual written reports

on the status of DOE’s performance assessment

during the test phase. These reports must include: a

description of the tests to date and their results,

modifications to the test plan, a summary of DOE’s

current understanding of the repository’s performance, waste characterization data from pre-test

waste characterization, and an annual summary of

air monitoring data required in item 6 above.

Beyond these specific conditions, the wastes placed by

DOE in the WIPP and DOE’s activities under this

variance must be consistent with those described in the

petition. Under section 268.6(e), DOE must notify EPA

of ‘any changes in conditions at the unit and/or environment that significantly depart from the conditions described in the variance and affect the potential for

migration of hazardous constituents from the unit. . .“ If

the change is planned, EPA must be notified in writing 30

days in advance of the change; if it is unplanned, EPA

must be notified within ten days.

Under section 268.6(f), if DOE determines that there

has been migration of hazardous constituents from the

repository in violation of part 268, it must suspend receipt

of prohibited wastes at the unit and notify EPA within 10

days of the determination. Within 60 days, EPA is

required to determine whether DOE may continue to

receive prohibited wastes in the unit and whether the

variance should be revoked.

Finally, under section 268.6(h), the term of today’s

petition approval runs for 10 years, that is until November

14,2000.

SOURCE: 55 Federal Register 220 (Nov. 14, 1990).