### EPA DOCKET NO. A-98-49, II-A4-127

Tier 1 Evaluation Eligibility of Hanford's Contact-Handled Legacy Debris Waste Streams:

MPFPD, RLM231ZD, RLM325D, and RLMPFPCD for Inclusion in AMWTP's BN510 (Super-Compacted) Debris Waste Stream

U.S. Environmental Protection Agency Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

June2010TABLE OF CONTENTS

Section Paae
1.0 EXECUTIVE SUMMARY ................................................................................................ 1
2.0 BACKGROUND ................................................................................................................ 1 2.1 MPFPD, Mixed Plutonium Finishing Plant Debris Waste (AK Report HNF-6489)

: ............................................................................................................. 2 2.2 RLM231ZD, 231 Z Building Waste (AK Report HNF-32128)

: ............................ 3 2.3 RLM325D, Hanford 325 Building Radiochemical Processing Laboratory Waste (AK Report HNF-30810) ............................................................................. 3 2.4 RLMPFPCD, Mixed PFP Comprehensive Debris (AK Report HNF-36515) ........ 3 3.0 EPA ASSESSMENT .......................................................................................................... 4 3.1 EPA Evaluation of MPFPD, M231 ZD, and M325D Waste Streams ..................... 4 3.2 EPA Analysis of the RLMPFPCD Waste Stream ................................................... 4 3.3 Comparison of Hanford AK Documentation with AMWTP's AK Documentation for BN510 Waste ........................................................................... 5 3.4 Need for EPA to Verify AMWTP's Processing of Four Hanford Waste Streams.................................................................................................................... 7 4.0 CONCLUSION ...................................................................................................................71.0 EXECUTIVE SUMMARY

This report supports U.S. Environmental Protection Agency's (EPA) approval of a Tier 1(T1) change request submitted on March 2, 2010, by the U.S. Department of Energy's (DOE) Carlsbad Field Offace (CBFO). The request is to include the following four Hanford'stransuranic (TRU) contact-handled (CH) legacy debris waste streams in the BN510 (supercompacted debris) waste stream at the Advanced Mixed Waste Project (AMWTP):
• MPFPD, Mixed Plutonium Finishing Plant (PFP) debris (AK Report HNF-6489); • RLM231ZD, Mixed 231Z Building debris (AK Report HNF-32218); • RLM325D, Mixed 325 Building debris (AK Report HNF-30810); and • RLMPFPCD, Mixed PFP comprehensive debris (AK Report HNF-36515)
The T1 change request was followed by submission of the acceptable knowledge (AK) documentation for the proposed waste streams.
The T1 change approval will result in the following two outcomes. First, the Hanford-generated legacy debris waste in approximately 1,034 85-gallon overpacks can be shipped to the AMWTP for processing. Second, AMWTP will repackage the waste into new 55-gallon crushable drums and repackage the waste from damaged 55-gallon drum overpacks into the 85-gallon containers.In addition, AMWTP, using the EPA-approved waste characterization processes for contacthandled transuranic (TRU) waste, will recharacterize these new drums as newly-generated waste BN510 waste. Once characterized, AMWTP will crush the drums into "pucks" and load the "pucks" in 100-gallon drums for shipment to and disposal at the Waste isolation Pilot Plant (WIPP). Since October 2006, AMWTP has been shipping the BN510, super-compacted debris waste stream to WIPP for disposal.

2.0 BACKGROUND
Until August 2009, Hanford characterized CH TRU waste using the CH TRU waste characterization processes with the origina12002 EPA approval and the subsequent baseline approval dated June 2008. (See the EPA Inspection Reports with an EPA Docket Nos. A-98-49, II-A4-25 and A-98-49, II-A4-106 respectively.) Upon termination of the Hanford program, the Central Characterization Project (CCP) took over Hanford's TRU waste characterization program. In April, 2410, EPA performed a baseline inspection of CCP's implementation of their CH TRU waste characterization program at Hanford and the EPA decision will be announced later 2010. Since the end of 2009, Hanford-CCP has been disposing of the remaining Hanford-certified CH debris containers at WIPP. Hanford-CCP will ship to AMWTP the above-mentioned 1,034 85- gallon overpacks for processing the waste contents as the BN510 waste.
EPA's baseline approval of the AMWTP's CH TRU waste characterization program (Docket No: A-98-49, II-A4-66, September 2006) states that addition of any waste streams to theapproved waste stream BN510 outside of those already included' is a Tier 1 change requiring

EPA approval prior to including them in the BN510 waste stream. Therefore, EPA's approval is necessary as a Tl change to allow inclusion of waste from the approximately 1,034 Hanford debris overpacks in the BN-510 waste stream.
BN510 is a newly-generated S5000 waste stream composed of waste from multiple sites (including Mound, RF, BCL and BAPL) and managed in the AMWTP facility. In this facility, retrievably-stored or pre-existing CH TRU debris in standard waste boxes or compromised 55-gallon drums are combined within the site box line facility, repackaged, while simultaneously being visually examined for estimating physical content weights, and then placed in new 55- gallon drums as newly-generated debris.
These new drums are characterized for radiological contents within the facility. The drums are then reduced in size by crushing in the facility supercompactor. The crushed drums that result from this process are referred to as "pucks". Depending on the weight and TRU content of individual drums, up to nine pucks of supercompacted 55-gallon drums of debris waste can be loaded into a single 100-gallon overpack container for disposal at the WIPP.
The following four waste streams are the subject of the Tl change request.
• MPFPD, Mixed Plutonium Finishing Plant (PFP) debris (AK Report HNF-6489); • RLM231ZD, Mixed 231Z Building debris (AK Report HNF-32218); • RLM325D, Mixed 325 Building debris (AK Report HNF-30810); and • RLMPFPCD, Mixed PFP comprehensive debris (AK Report HNF-36515)

2.1 MPFPD, Mixed Plutonium Finishing Plant Debris Waste (AK Report HNF-6489):
The MPFPD waste stream is TRU mixed heterogeneous debris created by various production, maintenance, cleanout, stabilization, decontamination, and decommissioning (D&D) activities at PFP. This waste stream consists of mixed TRU debris waste generated between 1970 and the present in support of plutonium metal production operations and glove box activities associated with PFP. The glove boxes were used for defense and non-defense work, which was processed during the same time periods, and the waste stream is considered commingled. The waste consists of in-process and D&D waste, including inorganic and organic debris (S5400) and wastes from several buildings or facilities, i.e., PFP Building 234-5Z (including Remote Mechanical Line A, Remote Mechanical Line C, Laboratories), Building 236-Z-Plutonium Reclamation Facility (PRF), Building 232-Z (Incinerator), and Building 2736-ZB Repackaging and Assaying. The radionuclides associated with this waste are primarily 241 Am, 238 Pu, 239 Pu, zaoPu, 242 Pu, and 24 l Pu generated from weapons and fuel- 

### ~ rade plutonium processing. The two most prevalent radionuclides by mass are expected to be 39 Pu and 240 Pu. The waste in 55-gallon drums was generated from July 7, 1972 through December 29, 1989. The EPA originally approved the S5000 Summary Category Group (SCG) that includes this

'[Mound, Rocky Flats (RF), Battelle Columbus Laboratory (BCL), and Bettis Atomic Power Laboratory (BAPL)waste stream in 2002 and again in 2008. A waste stream profile form (WSPF) for the MPFPD

waste stream was approved by CBFO in July 2002.
2.2 RLM231ZD, 231 Z Building Waste (AK Report HNF-32128):
This waste stream was generated by metallurgical research and plutonium fabrication, D&D, technology development, and facility cleanout activities within Building 231-Z between 1970 and the present. It is composed of various metal, combustible, non-combustible, glass, and other debris. The radionuclides potentially p resent include weapons-grade plutonium (WG Pu) 

### an d 238 239 24b 241 242 232 233 234 235 236 fuel- 

### ~ rade plutonium { Pu, Pu, Pu, Pu, 

### an d Pu), ur 

### an ium ( U, U, U, U, U, and 2 8 U), trace amounts of americium (241Am and 243 Am), and 237 Np. Mixed f ssion/activation products such as 137 Cs, 90 Sr, I54 Eu and 60 Co, would be expected in trace amounts because the plutonium was purified prior to receipt at the facility. Plutonium and americium oxide residues remaining from metallurgical studies with plutonium and D&D of contaminated ec

~ uipment are also assumed to be in the waste. The two predominant radionuclides by mass are 238 U and 239 Pu, and 241 Pu and 239 Pu are the two predominant radionuclides by activity.
The EPA initially approved the S5000 SCG that includes this waste stream in 2002 and again in 2008. A WSPF for the Hanford 231 Z Building waste stream was approved by CBFO in July 2007.

2.3 RLM325D, Hanford 325 Building Radiochemical Processing Laboratory Waste (AK Report HNF-30810)
This waste stream is CH debris (S5400) generated at the 325 Building Radiochemical Processing Laboratory. It was generated from September 28, 1972 through February 12, 1990 and is composed of laboratory-generated waste from glove boxes, fume hoods, and hot cells, and may contain inorganic debris, organic debris, various metals, protective clothing, filters, and other materials. All of the WIPP-tracked radionuclides ( 24i Am, 238 pu, 239 Pu, 240 Pu, 242 Pu, 233 U, 234 U, 238 U, 137 Cs, and 90 Sr) are expected to be present in this waste stream. Isotopic distributions for Pu, U and Am are assumed to be contaminated by PUREX 2 -derived waste, so isotopic distributions associated with PUREX tank waste were representative of this waste stream. The two predominant radionuclides by mass are 238 U and 239 Pu, and 241 Pu and 241 Am are the two predominant radionuclides by activity.
The EPA originally approved the S5000 SCG that includes this waste stream in 2002 and again in 2008. A WSPF for the 325 Building Radiochemical Processing Laboratory Waste was approved by CBFO in May 2007.
2.4 RLMPFPCD, Mixed PFP Comprehensive Debris (AK Report HNF-36515)
This is a mixed, heterogeneous S5400 debris waste stream generated from 1970 through the end of Hanford site's waste characterization program in support of PFP's plutonium production and stabilization activities. It is composed of a variety of inorganic, organic metal, and other debris

' PUREX is the name given to a plutonium-uranium extraction process whereby plutonium and uranium for weapons production was chemically separated from the irradiated fuel from the Hanford production reactors.materials, and includes both process and D&D waste. All of the facilities included in the

MPFPD waste stream are also in RLMPFPCD, which also includes the Building 242-Z- Waste Treatment Facility, 291-Z- Ventilation/Exhaust Air Stack Building, and PFP Ancillary Facilities. Plutonium (241P u, 238P u, 239P u, 240Pu, 242 Pu) is the main radionuclide in this waste, but there are 232 233 234 235 236 238 241 237 137 90 also trace amounts of uranium ( U, U, U, U, U, U), Am, Np, Cs, and Sr. This waste stream may contain WG Pu ( 240 Pu weight percentage 0.9% to 7%) and fuel grade Pu (240Pu weight percentage 8% to 27%). Based on historical


### ~ rocessing loads, a major po rt ion of the plutonium processed in PFP was approximately 12% 24 Pu. The two most prevalent TRU radionuclides by weight in this waste stream are 239 Pu and 240 Pu.
EPA did not receive any AK documentation for this waste stream while the Hanford's TRU program was still active. An AK Summary Report HNF-36515 was approved by CBFO in May 2009. No WSPF was approved for this waste stream.

3.0 EPA ASSESSMENT

3.1 EPA Evaluation of MPFPD, M231ZD, and M325D Waste Streams
EPA evaluated the four waste streams based upon AK information provided by CBFO. In addition, EPA referred to documentation obtained and reviewed during past Hanford site inspections performed between 2001 and 2007 for additional information. In particular, EPA examined EPA's original approval and baseline approval reports and some of the related references. EPA examined the MPFPD waste stream as part of the origina12002 Inspection, and the RLM325D and RLM231ZD waste streams were approved as part of EPA's S5000 Summary Category Group approval under both Hanford's original approval and EPA's later baseline approval. The drums belonging to these waste streams have been certified and disposed of at the WIPP. At the termination of the Hanford TRU program, a portion of certified drums from these three waste streams still remain at Hanford. The 55-gallon drums are being shipped to WIPP by Hanford-CCP. Some 85-gallon overpacks, however, remain at Hanford which will be sent to the AMWTP for managing the contents as the B510 waste.
3.2 EPA Analysis of the RI,MPFPCD Waste Stream
During EPA's 2001-2008 data review, mentioned previously in Section 2.0 of this report, EPA did not identify any information pertaining to waste stream RLMPFPCD. EPA recently learned that Hanford had prepared AK Summary Report HNF-36515 which CBFO approved in May 2009. CBFO had provided an AK report for this waste stream as part of a Tier 2 change submission at the end of the 3` d quarter of fiscal year 2009, after Hanford's original characterization program had been terminated. No WSPF is available for this waste stream. The RLMPFPCD waste is presently contained in approximately 4,130 55-gal drums (859 m 3) and 317 various-sized boxes (4,720 m 3 ) for a total volume of 5,579 m 3

. Hanford-CCP is currently responsible for characterizing CH TRU debris waste at Hanford and EPA inspected the program in late Apri12010. As part of the proposed baseline approval, EPA is reviewing debris waste stream MPFPDD. This waste stream includes debris from the MPFPD and RLMPFPCD waste stream, so the origin and content of the CCP waste stream requiredclarification and discussion with CBFO and CCP. EPA sent a series of emails to convey EPA's

understanding and had a conference call to obtain fiuther clarification. In addition, EPA and Hanford-CCP staff inet to decipher the waste generation and AK specific to the RLMPFPCD waste stream. This discussion was useful and EPA learned the following details about RLMPFPCD waste stream:

• This waste stream: o Is a composite consisting of legacy debris from several locations within the PFP complex; o Has thousands of certified 55-gallon containers of legacy debris including the MPFPD waste stream from various PFP location; and o Has 617 certified 55-gallon containers overpacked into 85-gallon containers that do not include containers from the Building 242-Z- Waste Treatment Facility, 291-Z- Ventilation/Exhaust Air Stack Building, and PFP Ancillary Facilities. In other words, Hanford-CCP indicates that the 617 containers include only those that also fall under the MPFPD waste stream. • The 617 85-gallon overpacks have debris waste from Building 234-5Z • These 617 are the candidate containers for shipment to AMWTP. • The debris from other PFP locations constituting the RLMPFPCD waste stream do not have waste drums in 85-gallon overpacks. In addition, more importantly, • Hanford-CCP's new MCPFPDD waste stream does not include any overpacked legacy debris waste from either the MPFPD or RLMPFPCD waste streams. • Hanford-CCP is processing mostly newly-generated debris at this time.• Hanford-CCP will continue to ship to WIPP the rest of the population of the Hanfordcertified waste to WIPP for disposal that are not overpacked. • Hanford-CCP will characterize for WIPP disposal debris drums from RLMPFPCD and MPFPD waste streams that are included into the new waste stream MPFPDD along with debris from other buildings within the PFP complex.
The above information was crucial in clarifying EPA's understanding of the RLMPFPCD waste stream as proposed in the Tier 1 request.
3.3 Comparison of Hanford AK Documentation with AMWTP's AK Documentation for BN510 Waste
EPA reviewed the following documents for this T1 evaluation:
• WIPP WSPF for RLM231ZD.001, dated July 30, 2007, and related attachments • WIPP WSPF for RLM325D.001, dated May 16, 2007, and related attachments• WIPP WSPF for RLMPDT.001 dated July 31, 2002, and related attachments, including

Change Notices 1(December 4, 2003) Change Notice 2(August 22, 2005), and Change Notice 3 (March 6, 2007) • AK Summary HNF-6489, Revision 1, MPFPD, unsigned and undated • AK Summary HNF-36515, RLMPFPCD Revision 0, unsigned and undated • AK Summary HNF- 32128 Revision 2, Acceptable Knowledge Document for Richland 231-Z Mixed Debris Waste Stream RLM231 ZD, published May 2009 • AK Summary HNF-30810, Revision 1, Acceptable Knowledge Document for the 325 Building Radiochemistry Laboratory Mixed Debris Waste Stream, RLM325D, published July 2007 • RPT-TRUW-30, Revision 5, Acceptable Knowledge Summary for Supercompacted Debris Waste (BN510) Advanced Mixed Waste Treatment Project, Approved: (Signature on file. See DCR-6963.) May 6, 2008
While Hanford-CCP process knowledge transportation documents (i.e., "PK" reports) were provided as references, EPA's review focused on Hanford site documentation, namely Hanford's AK Reports, to determine whether the proposed four debris waste streams (summarized in the section above) generally fit into AMWTP's BN510 waste "envelope".
AMWTP's BN510 waste is a compilation of debris from various sites (e.g., Mound, and BCL). As stated in the AMWTP baseline approval, EPA must approve inclusion of any debris waste from a new source (e.g., Hanford) in BN510 that is outside of EPA's original AMWTP baseline approval. This section addresses only the determination that the information provided for the four waste streams generally fits the approved envelope of BN510, and does not include the adequacy of AMWTP's characterization process associated with these drums, including visual examination (VE), real time radiography (RTR), and integration of the data into the BN510 AK Summary.
EPA compared each waste stream against the original BN510 AK Summary Report RPT-TRUW-30, Revision 5, May 2008, to determine whether the four waste streams could be included in the BN510 "envelope" based on the following technical elements:

• Waste stream definition • Radiological composition • Physical composition including presence of prohibited items • Defense origin • Absence of spent nuclear fuel and high level waste • TRU waste • Load Management.
Based on the review, as indicated in Table 1, below, EPA determines that these four waste streams fit within the general definition of BN510 and are consistent with other offsite (e.g., Mound, BAPL and BCL) debris waste included in the BN510 approval as part of the AMWTP baseline approval given in September 2006.Table 1. Waste Stream Evaluation Summary Table

Waste Stream W aste

Stream Definition Radiological

Characteristics Physical

Cha racteristics and Prohibited Items Defense

Ori in SNF/ HLW TRU Waste Load Mana ementx RLM231ZD.001 Yes 

### i Yes Yes Yes Yes Yes Yes RLM325D.001 

# I Yes Yes Yes Yes Yes Yes Yes MPFPD Yes Yes Yes Yes Yes Yes Yes RLMPFPCD 

### I Yes Yes Yes Yes Yes Yes Yes *- AMWTP must inform EPA if these waste streams would be considered for load management requiring EPA revicw and approval.
3.4 Need for EPA to Verify AMWTP's Processing of Four Hanford Waste Streams
AMWTP must use EPA-approved CH TRU waste characterization program components, including VE, nondestructive assay, and AK, when incorporating the 1,034 overpacked debris containers from Hanford into the newly-generated BN510 waste stream. AMWTP must inform EPA when the characterization activities begin for the Hanford-originated debris waste and when EPA should expect to get the appropriate documents for verifieation. EPA will review physical and radiological contents information for BN510 drums characterized by AMWTP to verify completeness and technical adequacy with respect to the new BN510 waste stream upon AMWTP's incorporation of the debris from the four debris waste streams mentioned above. As part of these analyses, the AMWTP must provide to EPA for review the AK and WSPF for the new BN510.1 waste stream for technical adequacy. In addition, the AMWTP must provide a list of batch data reports (BDRs), once a sufficient number of these newly-generated waste drumsare characterized to prepare such documents. EPA will select a few BDRs from the AMWTPprovided list for technical adequacy. The EPA verification will occur in an expedient manner recognizing the legal commitments the Idaho National Laboratory has made with the State of Idaho concerning the disposition of offsite-originated TRU waste.

4.0 CONCLUSION
The data and clarification provided by CBFO and CCP pertaining to the four waste streams satisfies EPA's Tier 1 change requirement. Based on an examination of the data and information conveyed through meetings and conference calls, EPA concludes that a total of 1,034 85-gallon overpacks containing waste from the four Hanford legacy debris waste streams may be shipped to AMWTP. The breakdown of the overpacks 'into four waste streams is as follows:

• 131 containers from MPFPD; • 66 containers from M231 ZD; • 220 containers from M3251); and • 617 containers from RLMPFPCD (from 234-5Z building)
It is AM WTP's responsibility to evaluate and accept the speeified overpacks containing Hanford's legacy debris waste for further processing prior to disposal at the WIPP.

7