Joyce L. Connery, Chair 

Thomas A. Summers, Vice Chair 

DEFENSE NUCLEAR FACILITIES 

SAFETY BOARD 

Washington, DC 20004-2901 

 January 19, 2024 

 

The Honorable Jennifer Granholm 

Secretary of Energy 

U.S. Department of Energy 

1000 Independence Avenue, SW 

Washington, DC 20585-1000 

Dear Secretary Granholm: 

The Defense Nuclear Facilities Safety Board (Board) has reviewed the chemical 

compatibility program developed by National Nuclear Security Administration (NNSA) at Los 

Alamos National Laboratory (LANL). The site uses this program to evaluate the chemical 

compatibility of radioactive wastes generated at nuclear facilities. Performing this evaluation is 

a new safety requirement for waste generator sites in U.S. Department of Energy (DOE) 

Standard 5506-2021, Preparation of Safety Basis Documents for Transuranic Waste Facilities. 

The new safety requirement is a result of lessons learned from the February 2014 accident that 

shut down the Waste Isolation Pilot Plant for an extended period. 

NNSA’s development of a formal program to evaluate the chemical compatibility of 

radioactive waste and its plans to upgrade its safety bases to implement DOE Standard 5506-

2021 are important steps toward improving the safety posture at both LANL and the Waste 

Isolation Pilot Plant. The Board encourages DOE to ensure that other defense nuclear facilities 

that process, handle, or store transuranic waste implement DOE Standard 5506-2021 

expeditiously and develop similar chemical compatibility programs. The enclosed report 

contains additional details of the notable practices of and suggestions for improvements to the 

LANL chemical compatibility evaluation program for your information and use. 

 Sincerely, 

 Joyce L. Connery 

 Chair 

Enclosure 

c: Mr. Ted Wyka 

 Mr. Joe Olencz 
DEFENSE NUCLEAR FACILITIES SAFETY BOARD 

Staff Report 

October 16, 2023 

Review of the Chemical Compatibility Program for Transuranic Waste at National 

Nuclear Security Administration Facilities at Los Alamos National Laboratory 

Summary. The Department of Energy (DOE) has experienced multiple events in the 

past decade that resulted in significant radiological releases from waste containers. One occurred 

in February 2014 at the Waste Isolation Pilot Plant (WIPP) and another in April 2018 (involving 

independent chemical reactions in four separate drums) at the Idaho National Laboratory (INL). 

In response to these events, the Defense Nuclear Facilities Safety Board (Board) evaluated how 

DOE analyzes chemical compatibility hazards and implements safety-related controls at facilities 

that generate, process, and store nuclear waste. 

In September 2020, the Board issued Technical Report 46, Potential Energetic Chemical 

Reaction Events Involving Transuranic Waste at Los Alamos National Laboratory (Tech-46). 

This report identified that “safety bases for both National Nuclear Security Administration and 

Environmental Management facilities at Los Alamos National Laboratory do not consistently or 

appropriately consider a potential energetic chemical reaction involving transuranic waste.” 

DOE strengthened its safety requirements in this area by issuing a revision to DOE 

Standard 5506, Preparation of Safety Basis Documents for Transuranic Waste Facilities, in 

August 2021. Among the new requirements is a provision that states, “The hazard analysis shall 

include an evaluation of the chemicals potentially in the waste to consider whether adverse 

chemical reactions could occur.” 

In response to Tech-46 and DOE Standard 5506-2021, Triad National Security, LLC 

(Triad), the management and operating contractor for National Nuclear Security Administration 

(NNSA) facilities at the Los Alamos National Laboratory (LANL), developed a method to 

evaluate the chemical compatibility of transuranic waste generated from various operational 

processes. 

The staff team reviewed Triad’s chemical compatibility program and found that: 

 Triad has implemented several notable process upgrades that reduce the risk of 

radiological releases that could be caused by adverse chemical reactions in 

transuranic waste. 

 Triad has not yet defined the interface between its safety bases and the chemical 

compatibility evaluations (CCE). As a result, it is unclear how Triad will upgrade its 

safety bases to: (1) identify and evaluate specific chemical reactions in waste, 

(2) estimate the consequences from chemical reactions in waste, and (3) determine 
2 

whether safety-related controls need to be identified to protect the worker and off-site 

public from high consequence events. 

 Triad’s CCE process could be improved in several areas, including: 

o Revising the CCEs to clearly describe the methods, assumptions, and references 

used, such that the CCEs are reviewable and maintainable; 

o Ensuring that any safety-related controls relied upon by the CCEs are 

implemented (i.e., required per procedure) and are effective at preventing or 

mitigating an adverse chemical reaction event; 

o Documenting the technical basis for excluding materials from further evaluation 

in the CCE (e.g., chemicals used in incidental quantities); 

o Developing a process to identify and evaluate changes to the ingredients of 

commercial off-the-shelf items; 

o Acknowledging the limitations of the CCE methodology in CCE reports and 

considering development of improvements to the CCE methodology; and 

o Updating the Plutonium Facility (PF-4) documented safety analysis (DSA) to 

ensure it accurately reflects the chemicals currently used in processes. 

Background. Over the past decade, DOE experienced multiple significant events—one 

in February 2014 at WIPP and another in April 2018 (involving independent chemical reactions 

in four separate drums) at INL—in which waste drums released radiological materials due to 

energetic chemical reactions involving the waste [1] [2] [3]. As a result, the Board evaluated 

how DOE analyzes chemical compatibility hazards and implements controls at facilities that 

generate, process, and store nuclear waste. 

In September 2020, the Board issued Tech-46 [4]. This report identified that “safety 

bases for both National Nuclear Security Administration and Environmental Management 

facilities at Los Alamos National Laboratory do not consistently or appropriately consider a 

potential energetic chemical reaction involving transuranic waste.” Specifically, Tech-46 stated: 

 “Hazard analyses lack systematic evaluations of the chemical compatibility of 

transuranic waste streams. These analyses are needed to fully identify potential 

chemical reaction hazards associated with waste constituents. 

 “Accident analyses are not bounding, assume inappropriate initial conditions, and do 

not defensibly estimate the quantity of radioactive material that may be released due 

to an energetic chemical reaction. As such, additional credited safety-related controls 

may be necessary to protect workers and the public. 

 “Some facilities store transuranic waste without any engineered controls beyond the 
3 

waste container. The radiological release events that occurred at the WIPP and INL 

demonstrated the importance of incorporating multiple layers of protection to 

reduce the consequences of an accident.” 

DOE strengthened its requirements in this area by issuing a revision to DOE Standard 

5506 in August 2021 [5]. Among the new requirements is a provision that states, “The hazard 

analysis shall include an evaluation of the chemicals potentially in the waste to consider whether 

adverse chemical reactions could occur.” DOE and its contractors that operate transuranic waste 

facilities have been discussing implementation approaches for the newly revised standard. Triad 

plans to implement the revised standard for the PF-4 DSA within the next year. 

In response to Tech-46 and DOE Standard 5506-2021, Triad developed a method to 

evaluate the chemical compatibility of transuranic waste generated from its various operational 

processes. This evaluation will help ensure that no adverse reactions will occur between 

different chemical components in the waste. These CCEs identify all chemicals used in a 

specific process at each NNSA-owned LANL facility and then evaluate combinations of these 

chemicals that can end up in the waste by using a methodology outlined in EPA-600/2-80-076, A 

Method for Determining Compatibility of Hazardous Waste [6]. The EPA methodology was 

developed in 1980 and evaluates the compatibility of binary combinations of materials. Triad 

enters the new information process for each completed CCE to determine whether an unreviewed 

safety question (USQ) exists. No positive USQ determinations have yet resulted from Triad’s 

CCE development. 

Separately, the Central Characterization Project (CCP), a different entity overseen by the 

DOE Carlsbad Field Office rather than Los Alamos, also performs CCEs on waste at LANL. 

CCP is responsible for safety at WIPP, while Triad is responsible for the safety of NNSA’s 

facilities at LANL. Prior to shipments of waste to WIPP, CCP must develop a CCE for the waste 

to ensure chemical compatibility. Both Triad and CCP use the methodology outlined in EPA600/2-80-076. However, CCP CCEs simultaneously analyze waste produced by several 

operational processes, while the Triad CCEs only analyze one process at a time. 

The staff team has three broad observations from its review of Triad’s chemical 

compatibility program, related to: (1) implementation of notable process upgrades; (2) the 

interface between safety bases and CCEs; and (3) potential improvements to the CCE process. 

Process Upgrades. Over the past few years, Triad has implemented several notable 

process improvements that reduce the risk of radiological releases caused by adverse chemical 

reactions in transuranic waste. These upgrades include the following: 

Documented Safety Analysis Update—Triad is in the process of developing a new PF-4 

DSA [7] that will meet the guidance and requirements in DOE Standard 3009-2014, Preparation 

of Nonreactor Nuclear Facility Documented Safety Analysis [8], and DOE Standard 5506-2021. 

This effort is expected to finish in fiscal year 2024. 

 

Process-specific CCEs—In response to Tech-46 and DOE Standard 5506-2021, Triad has 

begun developing comprehensive CCEs for all radioactive waste generating processes at its 
4 

LANL facilities. Triad is one of the first DOE contractors at a generator site to develop processspecific CCEs, which will improve the safety of operations that generate radioactive waste. To 

date, Triad has completed CCEs for all the waste generating processes at PF-4 and is working to 

complete CCEs for the remaining Triad facilities at LANL. The CCEs identify potential adverse 

reactions that could occur in waste and allow Triad to identify controls to prevent or mitigate 

these reactions. 

Configuration Control of Chemical Absorbents—Triad has developed a specific process 

to ensure configuration control of chemical absorbents. When an operator needs to absorb 

transuranic liquids to create WIPP-compliant waste, they must follow PA-DOP-01665, 

Characterization and Absorption of Liquids [9]. This procedure requires a hazardous waste 

management acceptable knowledge specialist (AKS) to evaluate the compatibility of the liquid, 

sorbent, and packaging, and recommend a specific absorbent and quantity of absorbent to be 

used. The AKS then observes the transuranic liquid being absorbed. This improvement will 

help prevent non-compliant absorbents from being used within waste. If this control had been in 

place earlier, it may have prevented the 2014 WIPP event [1], which was caused in part by the 

use of an inappropriate absorbent.

Integration of Waste Management Specialists with Operational Processes—Triad has 

better integrated AKS personnel with operational processes. Specifically, AKS personnel 

perform annual walkdowns of each process and must review all process and procedural changes. 

Further, Triad has a dedicated acceptable knowledge technologist for each process. This 

integration will help ensure that potential hazards are properly analyzed and controlled.

New Procedural Control—Triad has implemented a new procedural control that ensures 

materials that originate from an inert glovebox spend at least seven days in an air environment 

before being disposed of as waste. This control helps ensure that any materials that are 

potentially reactive with air will complete such reactions before being disposed of as waste, 

especially for fines that are directly exposed to air. This control was developed in response to a 

February 2021 event in which Triad personnel observed sparks emanating from a waste drum 

attached to a glovebox [10]. Personnel were emplacing waste items into the drum as part of a 

drum-out evolution. The sparks were caused by unreacted titanium metal fines that had been 

removed from an inert glovebox and were being disposed of as waste in an air glovebox.

Procurement of Real-Time Radiography Trailer—Triad has procured a new real-time 

radiography trailer for placement at the Transuranic Waste Facility to improve its ability to 

analyze waste containers. Triad expects to have this trailer operational within the next few years. 

Interface between CCEs and Documented Safety Analyses. Triad has not yet defined 

what the interface between facility safety bases and CCEs will be. As a result, the staff team 

could not determine how Triad will: (1) comprehensively identify chemical hazards in the 

waste, and (2) perform a DSA hazard evaluation (including evaluation of consequences) for 

potential chemical reactions in waste. As a result, it is unclear what, if any, controls will be 

designated as safety-related to prevent or mitigate potential chemical reaction events in waste. 
5 

Hazard Identification—DOE Standard 3009-2014 states that the “methodology used for 

hazard identification shall ensure comprehensive identification of the hazards.” Triad’s CCEs 

identify potential chemical reactions that, in the absence of controls, could lead to adverse 

consequences. However, these reactions are not specifically listed in the PF-4 DSA hazard 

identification section. In other words, there is currently no formal link between CCEs and the 

PF-4 DSA. Without this link, it is not yet clear how Triad will ensure that the DSA’s hazard 

identification is comprehensive. 

Hazard Evaluation Events—As part of its PF-4 DSA upgrade effort, Triad is developing a 

method for determining when specific chemical reactions should be evaluated as a unique hazard 

event in the DSA instead of being captured as part of a generic chemical reaction event. 

Analyzing specific reactions can be important for understanding the unmitigated consequences 

for those reactions and for identifying whether safety-related controls are needed for that 

scenario. The hazard evaluation in the PF-4 DSA [7] currently lists a few events that are tied to a 

specific chemical reaction, such as SW-2-002 (reaction of polysaccharides and nitric acid). The 

hazard evaluation also has events such as SW-3-003 (chemical decomposition of waste) that 

broadly apply to unspecified chemical reactions. Both the specific and the generic events play an 

important role in the hazard evaluation. 

It is important to note that DOE Standard 3009-2014 has a process for screening some 

chemicals from the hazard analysis. However, chemicals that “have the potential to be an 

accident initiator involving radioactive or hazardous material releases...are retained as part of the 

DSA hazard evaluation.” Accordingly, all incompatible chemical combinations that can cause a 

release of radioactive materials from a waste container are required to be analyzed in the DSA. 

Consequence Determination—When Triad integrates the CCE into the safety basis, it will 

need to determine the unmitigated consequences of different reaction scenarios. Chemical 

reactions can lead to different outcomes, ranging from cases with no radiological release to overpressurizations with large releases. When analyzing over-pressurization events involving finely 

divided waste, DOE Standard 5506-2021 lists several airborne release fraction (ARF) and 

respirable fraction (RF) values depending on the release pressure. However, the standard does 

not provide guidance for determining how much pressure a given chemical reaction would cause 

in a waste container. As a result, selecting appropriate and bounding ARF and RF values for 

chemical reactions involving finely divided waste requires careful consideration. Triad has not 

yet determined how it will select specific ARF and RF values when performing the unmitigated 

consequence analysis for specific adverse chemical reaction events. 

Safety-related Control Selection—In its CCEs, Triad assumes procedural controls are in 

place and function to prevent or mitigate adverse chemical reactions. For example: 

 The Analytical Chemistry Laboratory (ACL) CCE [11] assumes that absorbed acids 

are dried and/or neutralized prior to being disposed of as waste to rule out potential 

adverse chemical reactions. 

 The impact test facility CCE [12] lists a trinitrotoluene (commonly known as TNT) 

based propellant as a unique hazard. While not explicitly documented in a CCE, 
6 

Triad personnel stated that this highly reactive material is screened out of the CCE 

because the hazard would be recognized by operators per their operating procedure 

and would not end up in the waste. 

 While not explicitly documented in a CCE, Triad stated that (per the new procedural 

controls mentioned above) materials that originate from an inert glovebox are placed 

in an air glovebox for at least seven days prior to waste packaging to reduce the 

likelihood of adverse interactions with air after packaging as waste [13]. 

Given that Triad is relying on such controls to avoid adverse chemical reactions, the 

controls should be considered in the DSA hazard evaluation. If the unmitigated consequences of 

an event are found to be high, then safety-related controls would need to be identified for those 

events. 

Opportunities to Improve Triad’s CCE Program. During its review, the staff team 

identified several opportunities for improving Triad’s CCE program, as documented below: 

Formality of CCEs—Triad’s CCEs are not formally documented. Specifically, Triad’s 

CCEs do not include the purpose and scope of the evaluations, the methods and assumptions 

used to generate the evaluations, report titles, revision numbers, signatures, or references. For 

example, Triad’s CCE reports do not mention that they apply the methodology from EPA-600/2-

80-076. Triad’s CCE reports also do not mention key assumptions, such as the fact that Triad 

assigned the same reactivity group numbers (RGN) and material quantities as assumed in CCP’s 

CCEs [14]1

. As another example, Triad’s CCEs use the term “debris” without explaining the 

meaning of the term. Triad personnel verbally explained that “debris” in a CCE represented a 

group of materials that was assumed to be present in all processes. 

Overall, there is not enough information in Triad’s CCEs for a reader to determine how 

the analysis was performed and how conclusions were developed. While Triad provided the 

needed context to the staff team verbally, better documentation is needed to ensure that CCEs are 

enduring, reviewable, and maintainable. Triad personnel indicated that they would consider 

revising CCEs in the future to be more formal. 

Technical Justification in CCEs—Triad’s CCEs have a technical justification section that 

explains why a potential chemical reaction will not have adverse effects. These technical 

justifications list several assumptions that are not adequately supported. For example, the ACL 

CCE [11] assumes that operators will take certain actions in response to spills of hydrochloric 

and hydrofluoric acid: “Incidental spills of hydrochloric and hydrofluoric acids are sorbed onto 

non-polysaccharide wipes, and operators demonstrate that wipes that potentially came into 

contact with hydrochloric acid and hydrofluoric acid are dry prior to disposal via dual 

independent verification that is documented and signed.” However, the facility’s procedures do 

not require those specific actions for spills of those acids. Triad personnel informed the staff 

team that there are “no requirements for these chemicals to be sorbed on non-polysaccharide 

1

CCP has developed several CCEs to support characterization of waste at LANL; Reference 14 is an example of 

these CCEs. 
7 

wipes....” This discrepancy was discussed during the staff team’s interaction, and Triad 

personnel stated they would consider how to address this inconsistency in a future revision. 

As another example, the ACL CCE states, “Actions to the waste during packaging efforts 

include taping the terminals of all batteries to limit the possibility of caustic leaking.” While this 

is a best practice for preventing short circuits or sparking, taping the terminals would not prevent 

batteries from leaking and potentially causing an adverse reaction. The staff notes that the ACL 

CCE also states that the relative quantities and concentration of chemicals present from a battery 

in the waste stream would be insufficient to result in an adverse reaction. However, the 

reference2

 cited in the ACL CCE [15] asserts, “It is possible that caustic electrolytes (RGN 10) 

could leak in incidental quantities insufficient to result in an adverse reaction consequence,” but 

does not provide any technical evidence to support screening out batteries. 

Chemical Quantities—As noted earlier, when developing their own CCEs, Triad 

personnel relied on CCP’s CCEs to determine the quantity of chemicals that could end up in a 

waste container. Accordingly, if CCP’s analysis determined that a chemical was used in 

“incidental” quantities and could be excluded from analysis, so did Triad’s. The Triad analysis 

did not provide technical justification for why any given chemical was deemed incidental, and 

therefore excluded from analysis. 

 A commercially available cleaning spray is used throughout PF-4, but it is considered 

incidental in the CCEs and not further analyzed. Triad personnel clarified that they 

considered the cleaning spray to be “incidental” because most of the material 

evaporates. However, some non-volatile residue would remain. The CCEs do not 

provide a basis for whether a RGN should be assigned to the residues. Note that the 

staff team is using this specific cleaning spray as an example and is not suggesting 

that it is hazardous. 

Some processes only require small amounts of certain chemicals, and those chemicals are not 

further analyzed in the CCE. However, the storage container for these chemicals may be large. 

DOE Standard 3009-2014 calls for the evaluation of normal, abnormal, and accident conditions. 

Thus, there should be consideration of off-normal situations, such as spills of larger quantities 

that end up in radiological waste, or circumstances where operators use more of a chemical than 

is typical. If the presence of a chemical in a higher-than-usual amount could cause significant 

consequences, that is something that should be identified, understood, and controlled. 

Triad personnel stated that they typically only introduce the required amount of a process 

chemical into a glovebox instead of introducing large quantities and then using only a subset of 

that material. Further, a waste questionnaire is filled out for each waste drum, and this 

questionnaire would record any abnormal events (such as a spill). Triad analysts would then 

evaluate whether the existing CCE was applicable to the waste, and if not, they would perform a 

new analysis. Finally, the visual examination and visual inspection processes compare the 

materials that will end up in a waste container against the CCE and could determine whether a 

2

 The ACL CCE states, “See correspondence from CCP, May 05, 2022.” The CCE does not have a formal reference 

list that includes a document title to allow an independent reviewer to determine what this reference is. Triad 

subsequently provided reference [15] as the basis after further discussions with the staff. 
8 

material was appropriately analyzed. While these are good practices that can help mitigate 

concerns related to unanalyzed chemicals, there should still be conservative decision-making 

regarding the categorization of chemicals as “incidental” and whether procedural controls need 

to be elevated to safety-related controls to prevent high consequences during off-normal 

circumstances. 

Overall, the DSA should consider whether abnormal conditions, including spills or other 

errors, could lead to generation of waste containing incompatible chemicals. If a CCE for the 

waste does not consider this possibility, then the DSA needs to analyze such events. Triad 

personnel stated that in future revisions to the CCE, they planned to document the technical 

justification for why various chemicals could be excluded from analysis. 

Changes to Commercial Products—Triad does not have a formal process for identifying 

and evaluating changes to ingredients in commercial off-the-shelf products. For example, 

cleaning spray (discussed previously), commercial soap, and proprietary absorbents are used in 

PF-4. If the vendor changes the ingredients of one of these products, it may not notify Triad. In 

2019, the proprietary formula for the soap used at PF-4 was changed. While Triad identified this 

ingredient change, it may not identify all ingredient changes to commercial off-the-shelf 

products without a formal process in place. Triad personnel stated that they would consider how 

to evaluate commercial off-the-shelf products going forward, including whether to add 

requirements to Triad’s procurement system. 

Limitations of Methodology—Triad’s process-level CCEs have several limitations that are 

not acknowledged in its CCE reports. Some examples of limitations include: 

 The CCEs use a methodology published by the EPA [6] to identify incompatible 

combinations of chemicals. The EPA document says it assumes that the “chemicals 

react at ambient temperature and pressure.” The document does not define what it 

meant by “ambient,” though it presumably does not apply to fire conditions. 

 Using the EPA methodology, the CCEs only consider interactions between pairs of 

chemicals. However, adverse reaction events can involve a complex sequence of 

reactions, with the overall consequences being more severe than the consequences of 

any one reaction involving two chemicals. For example, LANL researchers who 

studied the 2014 WIPP event found that the event may have initiated with unspecified 

“low-level chemical reactions,” followed by a series of reactions [16]. “Trace-metal 

impurities” may have also played a role. The Idaho Cleanup Project team that 

investigated the 2018 drum over-pressurization reactions at Idaho National 

Laboratory also found that a sequence of reactions may have occurred [2]. 

 While DOE Standard 5506-2021 recommends analysis of “slow reactions as the 

waste ages,” the CCEs do not explicitly consider how waste may chemically or 

physically change over time (e.g., peroxide-forming chemicals, eventual desorption 

of adsorbed liquids). 
9 

 Application of the EPA methodology may not identify all hazards involving 

chemicals. For example, the method will not necessarily identify pyrophoric 

materials. As another example, aqua regia is a fuming liquid mixture of nitric acid 

(RGN 2) and hydrochloric acid (RGN 1). The EPA document’s matrix does not 

report gas generation as a hazard for a combination of RGNs 1 and 2. While this 

example may not be relevant to transuranic waste, it demonstrates that the EPA 

method by itself will not identify the hazards of all interactions. 

 The EPA methodology does not evaluate the effects of ionizing radiation on chemical 

reactions and chemical species present in the waste. 

Outdated Information in the PF-4 DSA—The PF-4 DSA [7] lists several hazardous 

chemicals as being involved in analytical chemistry operations, including hydroxylamine nitrate, 

acetone, and xylene. However, the ACL CCE [11] does not include analysis of these chemicals. 

Triad personnel stated that they evaluated the process procedures and found that these chemicals 

are no longer used. Triad should update the DSA to ensure it reflects current processes. 

Conclusion. The staff team reviewed Triad’s chemical compatibility and found that: 

 Triad has implemented several notable process upgrades that reduce the risk of 

radiological releases caused by adverse chemical reactions in transuranic waste. 

 Triad has not yet defined the interface between its safety bases and CCEs. As a 

result, the staff could not determine how Triad will upgrade its safety bases to: 

(1) identify and evaluate specific chemical reactions in waste, (2) estimate the 

consequences from chemical reactions in waste, and (3) determine whether safetyrelated controls need to be identified to protect the worker and off-site public from 

high consequence events. 

 Triad’s CCE process could be improved in several areas, including: 

o Revising the CCEs to clearly describe the methods, assumptions, and references 

used, such that the CCEs are reviewable and maintainable; 

o Ensuring that any safety-related controls relied upon by the CCEs are fully 

implemented (i.e., required per procedure) and are effective at preventing or 

mitigating an adverse chemical reaction event; 

o Documenting the technical basis for excluding materials from further evaluation 

in the CCE (e.g., chemicals used in incidental quantities); 

o Developing a process to identify and evaluate changes to the ingredients of 

commercial off-the-shelf products; 

o Acknowledging the limitations of the CCE methodology in the CCE reports and 

considering developing improvements to the CCE methodology; and 
10 

o Updating the PF-4 DSA to ensure it accurately reflects the chemicals currently 

used in processes. 
R-1 

References

[1] Department of Energy, Office of Environmental Management, Accident Investigation 

Report Phase 2, Radiological Release Event at the Waste Isolation Pilot Plant, February 

14, 2014, 2015. 

[2] Idaho Cleanup Project, Formal Cause Analysis for the ARP V (WMF-1617) Drum Event at 

RWMC, RPT-1659, Rev 1, April 2019. 

[3] Idaho Cleanup Project, Technical Analysis of Drum Lid Ejections-ARP V, RPT-1662, 

November 2018. 

[4] Defense Nuclear Facilities Safety Board, Potential Energetic Chemical Reaction Events 

Involving Transuranic Waste at Los Alamos National Laboratory, Technical Report 46,

September 2020. 

[5] Department of Energy, Preparation of Safety Basis Documents for Transuranic (TRU) 

Waste Facilities, DOE-STD-5506-2021, August 2021. 

[6] Hatayama, H.K., J.J. Chen, and E.R. de Vera, A Method for Determining the Compatibility 

of Hazardous Waste, Environmental Protection Agency, EPA-600/2-80-076, 1980. 

[7] Los Alamos National Laboratory, TA-55 Documented Safety Analysis, TA55-DSA-2020-

R1, 2021. 

[8] Department of Energy, Preparation of Nonreactor Nuclear Facility Documented Safety 

Analysis, DOE-STD-3009-2014, November 2014. 

[9] Los Alamos National Laboratory, Characterization and Absorption of Liquids, PA-DOP01665, R5-IPC1, October 2022. 

[10] Los Alamos National Laboratory, Analysis of an Unexpected Reaction Observed During 

Drumout Activities, LA-UR-21-24378, February 26, 2021. 

[11] Los Alamos National Laboratory, ACL PSC total report.pdf, no date listed. 

[12] Los Alamos National Laboratory, ITF PSC total report Rev0-email.pdf, no date listed. 

[13] Los Alamos National Laboratory, TA-55 FOD Process-Output Packaging Requirements, 

PA-AP-01241 R1, April 28, 2022. 

[14] Schoen, James M, Chemical Compatibility Evaluation for Waste Stream LA-MHD01.001 

Full Waste Stream (AK Source Document CCE18), AK-TA55-1334 Rev1, June 27, 2019. 

[15] Ams, David, Chemical Compatibility Evaluation for Waste Streams LA-MHD01.001, LACIN01.001, LA-MIN02-V.001, and LA-MIN04-S.001 (AK Source Document CCE19), AKTA55-22-015, 2022. 

[16] Funk, David John, The Path to Nitrate Salt Disposition, LA-UR-16-21760, March 16, 2016.