1 Tyahla, Stephen

From: Martin, Richard William <MartinRW@oro.doe.gov>

Sent: Wednesday, April 30, 2014 7:00 AM

To: Tyahla, Stephen

Cc: DeMonia, Brian Craig

Subject: FW: Clarifying Questions on DOE Oak Ri dge 07 April 2014 Petition for LDR Variance

Attachments: M&EC MACRO.doc; Hg table rev 1.xlsx

Stephen

‐ Included below are responses to your questions.

Regarding question 8, the Table in question was included for supplementary information not addressed in the

petition. However, our response to question 8 attempts to address the issue of why this waste is considered to be

radioactively contaminated. If you have any additional or follow up questions, please let me know.

Richard

From: Tyahla, Stephen [ mailto:Tyahla.Stephen@epa.gov ]

Sent: Thursday, April 24, 2014 4:27 PM

To: DeMonia, Brian Craig

Subject: Clarifying Questions on DOE Oak Ridge 07 April 2014 Petition for LDR Variance

Brian,

I have reviewed the 7 April 2014 DOE Petition for a site

‐ specific, one

‐ time LDR treatment standards variance

and have the below questions.

Please provide a written response via email at your convenience.

1) The EPA ID# for the generating facility (DOE East Tennessee Technology Park) is not given. Our records

indicate that the EPA ID# is TN0890090004. Please confirm. That is the correct EPA ID #.

2) In the last paragraph of the second page of the petition, it indicates that 37,985 kg of amalgamated mercury

was produced of which 7,094 kg did not meet the LDR treatment standards. How many containers were there

for the 37,985 kg? (An approximate number is fine.) Approximately 500 containers of amalgam were produced

in a variety of sizes, from small drums to dumpster

‐ type containers.

3) The proposed disposal facility name, based on our records and the EPA ID # NV3890090001 should be the

Nevada National Security Site ("NNSS"), not Nevada Nuclear Security Site. That was an error on our part. The

correct name is as you suggest.

4) Where, and who will perform the "macroencapsulation" for the 6 drums that were above the universal

treatment standards for metals? It is correct to presume it will be Perma

‐ Fix’s Materials and Energy

Corporation (M&EC) facility located at the East Tennessee Technology Park? Macroencapsulation will be

performed by M&EC, which is located at the ETTP. Please see the attached file M&EC MACRO for the

treatment details. The file describes a container welding process and a grouting process. The container welding

process will be used on the subject waste.2 5) Can you provide brief description/fact sheet of the specific macroencapsulation process to be used for the 6

containers? See attached file M&EC MACRO.

6) Under the "Treatment Options" section on page 3 of the petition, it refers to "Stream M1781." Does this

refer specifically to the 34 drums of treatment residue? Yes. Unique identifiers are applied to each waste

stream when added on our Site Treatment Plan inventory. When these drums were returned from the

treatment vendor after failing to meet the RCRA LDRs, this identifier was assigned to this “new” waste stream

being added to the inventory.

7) Is MLLW Cell #18 of the NNSS within what is referred to as "Area 5" of the NNSS? (See attached DOE Fact

Sheet that refers to Area 5.) Cell 18 is the RCRA Permitted Mixed Low

‐ Level Waste Disposal Unit in the Area

‐ 5

Radioactive Waste Management Complex at the Nevada National Security Site. This was confirmed with the

DOE site representative.

8) The table provided entitled "Mercury and Organically Contaminated MLLW Radiological Data" requires

explanation. The table is not referred to in the text. The table was provided to indicate that the waste meets

the NNSS WAC criteria for fissile mass limits. This table is not an indication of the concentration of radioactive

constituents but shows the degree of enrichment. Since the waste was generated within DOE controlled

radiological facilities and has been determined to contain elevated levels of radioactive materials as well as

RCRA hazardous waste codes, it is classified as mixed low

‐ level waste in accordance with DOE policy. The

original waste was generated from remediation activities on the DOE Oak Ridge Reservation, primarily from

uranium processing facilities at the Y

‐ 12 National Nuclear Security Complex. These wastes included materials

such as uranium

‐ contaminated and mercury

‐ contaminated floor sweepings, tank clean

‐ out residues, sludges,

soils, PPE, and bulked laboratory samples. Available characterization data indicate uranium contamination to

be primarily in the form of depleted or natural uranium, demonstrating that the fissile material content of the

waste is within acceptable limits for NNSS.

9) The reference made to the TSCA regulations under "Disposal Site" on page 5 of the petition is incorrect, as it

does not exist (possible typo). Did you mean to cite 40 CFR 761.61(a)(5)(i)(B) concerning the disposal of "bulk

PCB remediation waste?" The reference in the petition is incorrect. Your reference is correct.

10) In the “Constituents Not Meeting LOR Standards” table, for container with the waste ID (WID)# K209754,

there is no analytical value for PCB and the bis(2

‐ ethylhexyl phthalate) concentration of 5.6 mg/kg is below the

UTS of 28 mg/kg. Please provide the missing data and explain why the bis(2

‐ ethylhexyl phthalate) is listed as

not meeting the treatment standard. The missing PCB concentration is 21.9 mg/kg. The inclusion of bis (2

‐ ethylhexyl) phthalate on the table is in error. The attached revision of the table includes the corrected

information.

Thanks,

Stephen F. Tyahla, P.E., CHMM

Project Manager, RCRA Corrective Action Office

Land Division (note new Divison Name)

U.S. EPA Region IX (LND-4-1)

75 Hawthorne St., San Francisco, CA 94105

415.972.3466 / tyahla.stephen@epa.gov

[This email, including any attachments, may contain non

‐ public, privileged and/or confidential information solely intended to be

conveyed to the designated recipient(s). If you receive this email and are not an intended recipient, please delete this email and its3 attachments immediately. The unauthorized use, dissemination, distribution, or reproduction of this email and its attachments is

strictly prohibited by law.]Page 1 of 1 East Tennessee Materials and Energy Corporation

Macroencapsulation; Stainless Steel Welded Boxes and Grout performed in accordance

with SOP-WTC-232

Macroencapsulation (40 CFR 268.45 Table 1)

Application of surface coating mate rials such as polymeric organics (e.g., resins and plastics) or

use of a jacket of iner t inorganic materials to substantiall y reduce surface exposure to potential

leaching media.

Performance and/or design and operating standard

Encapsulating material must completely encapsulate debris and be resistan t to degradation by the

debris and its contaminants and materials into which it may come into contact after placement

(leachate, other waste, microbes).

M&EC Macroencaspulation Method Details

M&EC performs macroencapsulatio n of mixed waste debris within DOT IP2 reinforced stainless

steel containers. The stainless st eel jacket provides de gradation resistance to the debris and its

contaminants and reduces disposal cell exposure. The debris solids ar e placed within the box

until full. To ensure the waste container is ≥ 90% filled, an approved product (e.g. inert clay,

perlite, or other) is added throughou t and on top of the mixed waste. Once the container is filled,

operations will place a refractory ceramic fiber (e .g. aluminum silicate) blanket on top of the

waste. The container cover is welded closed. The weld is continuous and performed by certified

welding per AWS D1.6.

M&EC also performs grout macroencapsulation of mixed waste debris and radioactive lead

solids. The cementitious grout formulation is re sistant to degradation from the debris and

reduces its exposure to disposal cell conditions. M&EC typica lly uses a 55 gallon container

inside an 85 gallon for the process. The appr oved grout mixture is pou red inside an 85 gallon

drum to form a ≥ 2” thick puck in the bottom of the container. Once th e pour has fully set, the 55

gallon drum is set inside the 85 gallon drum a nd filled with the debris. More grout is poured

over and into the debris allowing th e grout to fill the inte rstitial voids around the waste. As the

pouring process continues the grout will fill out over the 55 gallon drum top thus filling the

annular space around the 55 gal and the 85 gallon. Once the grout reaches 2” above and around

the waste the fill process is complete. Approved clay solids are placed on top of the pour to

absorb cure bleed and condensation water. The 85 gallon drum is closed using a standard bolted

ring gasket and cover.K209740 PCB UHC 10.00 mg/kg 33.000 mg/kg

K209741 PCB UHC 10.00 mg/kg 34.900 mg/kg

K209742 PCB UHC 10.00 mg/kg 803.000 mg/kg

K209743 PCB UHC 10.00 mg/kg 354.000 mg/kg

PCB UHC 10.00 mg/kg 121.000 mg/kg

Lead D008 0.75 mg/l 0.971 mg/l TCLP

K209746 Methanol UHC 0.75 mg/l 10.300 mg/l TCLP

PCB UHC 10.00 mg/kg 47.000 mg/kg

Lead UHC 0.75 mg/l 2.500 mg/l TCLP

PCB UHC 10.00 mg/kg 49.800 mg/kg

Lead UHC 0.75 mg/l 3.010 mg/l TCLP

PCB UHC 10.00 mg/kg 16.200 mg/kg

Thallium UHC 0.20 mg/l 0.210 mg/l TCLP

PCB UHC 10.00 mg/kg 203.000 mg/kg

Lead D008 0.75 mg/l 1.100 mg/l TCLP

K209751 PCB UHC 10.00 mg/kg 71.900 mg/kg

K209754 PCB UHC 10.00 mg/kg 21.900 mg/kg

K209765 Methanol U154 0.75 mg/l 2.720 mg/l TCLP

K209766 PCB UHC 10.00 mg/kg 33.800 mg/kg

K209767 PCB UHC 10.00 mg/kg 32.100 mg/kg

K209768 PCB UHC 10.00 mg/kg 12.900 mg/kg

PCB UHC 10.00 mg/kg 12.000 mg/kg

Fluoranthene UHC 3.40 mg/kg 5.300 mg/kg

Nickel UHC 11.00 mg/l 12.100 mg/l TCLP

K209770 PCB UHC 10.00 mg/kg 353.620 mg/kg

PCB UHC 10.00 mg/kg 11.800 mg/kg

Fluoranthene UHC 3.40 mg/kg 5.300 mg/kg

PCB UHC 10.00 mg/kg 21.900 mg/kg

Fluoranthene UHC 3.40 mg/kg 8.500 mg/kg

Phenanthrene UHC 5.60 mg/kg 5.640 mg/kg

K209773 PCB UHC 10.00 mg/kg 125.000 mg/kg

K209775 PCB UHC 10.00 mg/kg 144.000 mg/kg

K209777 PCB UHC 10.00 mg/kg 14.200 mg/kg

K209779 PCB UHC 10.00 mg/kg 12.000 mg/kg

K209780 PCB UHC 10.00 mg/kg 21.900 mg/kg

K209781 PCB UHC 10.00 mg/kg 125.000 mg/kg

K209783 PCB UHC 10.00 mg/kg 127.000 mg/kg

K209784 PCB UHC 10.00 mg/kg 111.000 mg/kg

K209785 PCB UHC 10.00 mg/kg 53.100 mg/kg

K209797 PCB UHC 10.00 mg/kg 10.600 mg/kg

K209798 PCB UHC 10.00 mg/kg 46.000 mg/kg

K209799 PCB UHC 10.00 mg/kg 125.000 mg/kg

K209801 PCB UHC 10.00 mg/kg 125.000 mg/kg

K209801 PCB UHC 10.00 mg/kg 46.000 mg/kg Constituent Units Units 34 Containers: Constituents Not Meeting LDR Standards

WID # UHC or

Code LDR limit Value Notes

K209769

K209771

K209772 K209744

K209747

K209748

K209749

K209750