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SAVANNAH RIVER SITE Solid Waste Management System Plan

SRNS-RP-2016-00638

Solid Waste Management System Plan 2017 SRNS-RP-2016-00638, Rev. 0 Page iv

TABLE OF CONTENTS Section Page LIST OF FIGURES ............................................................................................................................................ VI

LIST OF APPENDICES .................................................................................................................................... VI

LIST OF ABBREVIATIONS AND ACRONYMS ....................................................................................... VII

EXECUTIVE SUMMARY ................................................................................................................................ IX

1.0 INTRODUCTION ................................................................................................................................... 1 1.1 Background ...................................................................................................................... 1 1.2 Mission and Goals ............................................................................................................ 2 1.3 Risks and Critical Success Factors ................................................................................... 3 1.4 Definition and Purpose ..................................................................................................... 3

2.0 PLANNING BASES ................................................................................................................................ 4 2.1 Planning Method .............................................................................................................. 4 2.2 Funding............................................................................................................................. 5 2.3 Regulatory Drivers and Constraints ................................................................................. 6

2.3.1 DOE Order 435.1, Radioactive Waste Management ....................................................... 6 2.3.2 Off-SRS Transportation, Treatment and Disposal Permits ............................................ 7 2.3.3 Federal Facility Agreement (FFA) .................................................................................... 7 2.3.4 National Environmental Policy Act (NEPA) .................................................................... 8 2.3.5 SRS Site Treatment Plan (STP) ......................................................................................... 9 2.3.6 South Carolina Environmental Laws .............................................................................. 10 2.3.7 Operating Constraints ...................................................................................................... 11

2.4 Waste Forecasts and Planning ........................................................................................ 13 2.4.1 Solid Waste Integrated Forecast Tracking (SWIFT)..................................................... 13 2.4.2 Waste With No Identified Path to Disposal .................................................................... 14 2.4.3 LLW Disposition Planning ............................................................................................... 15 2.4.4 HW Disposition Planning ................................................................................................. 16 2.4.5 MW Disposition Planning ................................................................................................ 17 2.4.6 TRU and Mixed TRU Disposition Planning ................................................................... 18

2.5 Priority Scope ................................................................................................................. 19 3.0 LOW LEVEL WASTE (LLW) ............................................................................................................ 20

3.1 LLW Integrated Operations ........................................................................................... 20 3.2 LLW Facilities ................................................................................................................ 20

3.2.1 Engineered Trenches (ET) ............................................................................................... 21 3.2.2 Slit Trenches (ST) .............................................................................................................. 22 3.2.3 Components-In-Grout (CIG) Trenches .......................................................................... 22 3.2.4 Low Activity Waste Vault (LAWV) ................................................................................ 22 3.2.5 Intermediate Level Vault (ILV) ....................................................................................... 22 3.2.6 Naval Reactor Component Disposal Area (NRCDA) .................................................... 22

4.0 HAZARDOUS WASTE (HW) ............................................................................................................. 26 4.1 HW Integrated Operations ............................................................................................. 26 4.2 HW Facilities.................................................................................................................. 27

4.2.1 Buildings 643-29E and 643-43E ....................................................................................... 27

Solid Waste Management System Plan 2017 SRNS-RP-2016-00638, Rev. 0 Page v

5.0 MIXED LOW LEVEL WASTE (MLLW) ......................................................................................... 29 5.1 MLLW Integrated Operations ........................................................................................ 29 5.2 Mixed Waste Storage Facilities ...................................................................................... 30

6.0 TRU AND MIXED TRU WASTE ....................................................................................................... 31 6.1 TRU and Mixed TRU Waste Integrated Operations ...................................................... 31 6.2 TRU Waste Facilities ..................................................................................................... 32

6.2.1 TRU Waste Storage Pads ................................................................................................. 32 6.2.2 TRUPACT-II and TRUPACT-III Loading Facilities .................................................... 33

6.3 Central Characterization Project (CCP) ......................................................................... 33 7.0 SANITARY WASTE ............................................................................................................................. 35

7.1 Sanitary Waste Program Operations .............................................................................. 35 7.1.1 Routine Sanitary Waste .................................................................................................... 35 7.1.2 Sanitary C&D Waste ........................................................................................................ 35

7.2 Sanitary Waste Facilities ................................................................................................ 36 7.2.1 SRS Construction and Demolition (C&D) Landfill ....................................................... 36 7.2.2 Three Rivers Regional Landfill ....................................................................................... 36 7.2.3 North Augusta Material Recovery Facility (NAMRF) .................................................. 36

7.3 Sanitary Waste Streams Reduction and Recycling ........................................................ 37 8.0 POLLUTION PREVENTION ............................................................................................................. 38

8.1 Pollution Prevention (P2) Program ................................................................................ 38 8.2 Pollution Prevention Vision ............................................................................................. 39

9.0 REFERENCES ....................................................................................................................................... 40

Solid Waste Management System Plan 2017 SRNS-RP-2016-00638, Rev. 0 Page vi

LIST OF FIGURES Figure Page

Figure 1. Hierarchy of SRS Planning Documents ....................................................................... 4

Figure 2. General Breakdown of SWM Funding ......................................................................... 5

Figure 3. General Breakdown of Volumes of Waste Managed by SWM.................................. 14

Figure 4. Mixed Waste Disposition Decision Tree .................................................................... 18

Figure 5. Summary of SWM Priority Scope .............................................................................. 19

Figure 6. Hierarchy of Onsite LLW Disposal Options .............................................................. 21

Figure 7. Disposition of Hazardous Waste ................................................................................ 27

Figure 8. Disposition of Mixed Low Level Waste ..................................................................... 30

LIST OF APPENDICES Appendix Page Appendix A: List of Assumptions Applicable to this System Plan ..............................................41

Solid Waste Management System Plan 2017 SRNS-RP-2016-00638, Rev. 0 Page vii

LIST OF ABBREVIATIONS AND ACRONYMS

AEA Atomic Energy Act BOA Basic Order Agreement CA Composite Analysis C&D Construction and Demolition CCO Criticality Control Overpack CCP Central Characterization Project CERCLA Comprehensive Environmental Response, Compensation and Liability Act CIF Consolidated Incineration Facility CIG Component-In-Grout CFR Code of Federal Regulations D&D Decontamination and Decommissioning DAS Disposal Authorization Statement DOE U.S. Department of Energy DOE-SR U.S. Department of Energy-Savannah River Operations Office DOT Department of Transportation DSA Documented Safety Analysis EAV E-Area Vaults EIS Environmental Impact Statement ELLWF E-Area Low Level Waste Facility EM Environmental Management EPA U. S. Environmental Protection Agency ESU Energy Solutions (Utah) ET Engineered Trench FFA Federal Facility Agreement FFCA Federal Facilities Compliance Act FONSI Finding of No Significant Impact FY Fiscal Year GCO Generator Certification Official HLW High Level Waste HW Hazardous Waste HW/MW Hazardous Waste / Mixed Waste IDIQ Indefinite Delivery / Indefinite Quantity ILV Intermediate Level Vault IROD Interim Record of Decision IPABS Integrated Planning, Accountability, and Budget System LAWV Low Activity Waste Vault LDR Land Disposal Requirements LLW Low Level Waste MOX Mixed Oxide MFFF Mixed Oxide (MOX) Fuel Fabrication Facility MW Mixed Waste MLLW Mixed Low Level Waste MTRU Mixed Transuranic

Solid Waste Management System Plan 2017 SRNS-RP-2016-00638, Rev. 0 Page viii

NAMRF North Augusta Material Recovery Facility NDA Non-destructive Assay NDE Non-destructive Examination NR Naval Reactor NEPA National Environmental Policy Act NFPA National Fire Protection Act NNSS Nevada National Security Site NPDES National Pollutant Discharge Elimination System NRC U.S. Nuclear Regulatory Commission NRCDA Naval Reactor Component Disposal Area PA Performance Assessment PBS Program Baseline Summaries PCB Polychlorinated Bi-phenyls PECMC Portable Equipment Commodity Management Center PEIS Programmatic Environmental Impact Statement PESI Perma-Fix Environmental Services, Inc. POC Pipe Overpack Container P2 Pollution Prevention RCRA Resource Conservation and Recovery Act ROD Record of Decision RWMB Radioactive Waste Management Basis SCDHEC South Carolina Department of Health and Environmental Control SCHWMR South Carolina Hazardous Waste Management Regulations SLB Standard Large Box SNF Spent Nuclear Fuel SRS Savannah River Site SRNS Savannah River Nuclear Solutions SST Solvent Storage Tank ST Slit Trench STP Site Treatment Plan SWB Standard Waste Box SWDF Solid Waste Disposal Facility SWIFT Solid Waste Integrated Forecast Tracking SWM Solid Waste Management SWMF Solid Waste Management Facility TEF Tritium Extraction Facility TRU Transuranic TRUPACT Transuranic Package Transporter TSD Treatment, Storage and Disposal WAC Waste Acceptance Criteria WCS Waste Control Specialists WSB Waste Solidification Building WIPP Waste Isolation Pilot Plant WITS Waste Information Tracking System

Solid Waste Management System Plan 2017 SRNS-RP-2016-00638, Rev. 0 Page ix

EXECUTIVE SUMMARY

The System Plan provides a management tool to assist the Solid Waste Management (SWM) Project in determining where to allocate resources. This is part of the SWM Radioactive Waste Management Basis. The purpose of this plan is to integrate and document the activities associated with the scope under the SWM project and to provide the scoping information necessary to support future solid waste budgetary requirements.

This plan highlights the disposal planning process and identifies preferred disposal options by assessing all feasible treatment and disposal possibilities against a set of discriminating criteria. Options that have significant obstacles or are considered not to be feasible are excluded from the analysis process. The option that is determined to be the "best" based on these criteria and an engineering assessment is then selected as the preferred option for that specific treatability group. Normally, the preferred option is incorporated into the baseline budget development as the path forward; however another option may be identified as the path forward depending on the circumstances. By incorporating the preferred option into the baseline budget, the objective of providing a scoping document for SWM is accomplished.

SRS has developed a hierarchy of planning documents that shows the relationship of the System Plan to the other planning documents (see Figure 1). Special efforts have been taken to align the System Plan with the Ten Year Site Plan, the SRS Strategic Plan, and current operational activities to ensure SRS has an integrated approach to the management of its solid waste. The System Plan is a document that provides general overall direction to accomplish the goals of the Strategic Plan, but does not include the "nuts and bolts" detailed cost, schedules, and actions. These details are provided by lower tier documents.

Assumptions used in the System Plan are provided in Appendix A. Noteworthy assumptions are also identified throughout the plan for convenience. The assumptions are applied, where appropriate, across waste streams for consistency.

Section 1.0 - Introduction

Solid Waste Management System Plan 2017 SRNS-RP-2016-00638, Rev. 0 Page 1

1.0 INTRODUCTION

1.1 Background

From the early 1950's until the end of the Cold War, the mission at the Savannah River Site (SRS) was to produce and process nuclear materials to support defense programs in the United States. These activities resulted in the generation of large quantities of liquid and solid wastes that in many cases were radioactive and/or hazardous. Legacy wastes were stored over the years waiting on appropriate disposal methods. While most of these legacy wastes have been disposed, new wastes continue to be generated across the SRS as it has moved from a mission of defense programs to a mission of environmental restoration/clean-up and nuclear material stabilization.

Solid Waste Management (SWM) is an operating facility with the primary responsibility for management of solid waste. SWM receives waste from onsite and offsite sources and dispositions the bulk of the waste at the E-Area Low Level Waste Facility (ELLWF). SWM is also responsible for the site’s Sanitary Waste Program and the Pollution Prevention (P2) program for reducing the site’s waste generation. In addition to waste management, the SWM program includes the Environmental Management (EM) Historic Preservation curatorial activities. The SWM program also includes the surveillance and maintenance of SWM operational facilities through deactivation until they are transferred for decommissioning.

All waste facilities will be deactivated with the possible exception of portions of the Solid Waste Disposal Facility (SWDF), as portions of SWDF may be needed after FY2065 to support waste generation from other site programs. If determined to be needed, the SWDF will be transferred to another DOE program office upon completion of the EM cleanup project. Any ongoing site infrastructure or other site support required for DOE users will also be transferred to the appropriate DOE program office.

Wastes managed by SWM fall into two main categories: DOE Order 435.1 wastes and non 435.1 wastes. Wastes managed under DOE Order 435.1 include low level waste

(LLW), transuranic (TRU) waste, and high level waste (HLW), though SWM does not manage HLW. Sanitary and hazardous waste (HW) are non 435.1 wastes. If LLW and TRU waste have a hazardous component present in the waste form, then the waste is identified as mixed waste (i.e., mixed low level waste (MLLW) or mixed TRU (MTRU) waste).

SWM manages LLW (including legacy), TRU waste (including legacy), MLLW, HW and sanitary waste, to include storage, treatment and disposal.

DOE O 435.1 Waste

Low Level

Transuranic

Mixed

HLW

Non 435.1 Waste

CERCLA

Hazardous

Sanitary



SWM also receives CERCLA (Comprehensive Environmental Response, Compensation and Liability Act) waste from Area Completion Projects (ACP) and other EM funded projects, and offsite LLW waste from the Naval Reactor program for disposal at ELLWF.

Though the primary focus of this System Plan is LLW, the following programs are briefly addressed as they have existing well-defined treatment and disposal paths: TRU waste, HW, MLLW, and Sanitary Waste. In addition, the P2 Program is briefly mentioned.

1.2 Mission and Goals

The mission of SWM is to provide an exemplary, high quality and cost effective service to manage solid waste in support of Department of Energy (DOE) missions at SRS and across the DOE complex. SWM is committed to managing these wastes in a manner that is protective of human health and the environment, that complies with all applicable regulations, and that minimizes waste generation while using cost effective and commercially available technologies.

The intention is to meet these commitments while focusing on achieving an end-state condition for each waste stream. End-state is defined as the point at which SWM services at SRS cease and all waste in the custody of the SWM program has been treated and disposed, including disposition of all LLW, HW, MLLW, and TRU wastes in compliance with applicable regulations and requirements. Newly generated SRS wastes resulting from EM cleanup projects will be dispositioned as the waste is generated to prevent legacy waste.

Additionally, SWM is dedicated to the safe operations and maintenance of SWM facilities through the end of operations and until decommissioning has commenced. Real-time treatment and disposal of wastes is anticipated to complete by the end of FY2065 per the 2015 SRS Site Ten Year Plan (Reference 1).

The SWM program is key to meeting the DOE goals such as:

Protecting the workers and environment

Reducing the volume and generation of all SRS waste types

Protecting the public from exposure to hazards associated with solid waste

Cooperating across the DOE Complex in optimizing the treatment, storage, and disposal of DOE wastes

Driving down the unit cost of waste disposal operations at SRS

Establishing paths for the treatment, storage, and disposal of all SRS waste streams

DOE EM Primary Objectives

Mitigate or eliminate risks through stabilization, treatment and disposition of EM-owned nuclear materials, spent nuclear fuel (SNF), and waste

Reduce the costs of continuing operations, surveillance and maintenance

Decommission all EM-owned facilities except those identified for transfer to another Program Secretarial Office (PSO) and remediate surface water, groundwater and contaminated soil, using an Area Completion approach.



1.3 Risks and Critical Success Factors

The most recent PBS SR-0013 “Risk and Opportunity Analysis Report” (Reference 2) identifies technical and programmatic risks that may have an adverse impact on meeting the PBS SR-0013 work scope and identifies opportunities for positive outcomes for the work scope. The report also identifies handling strategies to manage the risks and realize the opportunities, and estimates the potential cost and schedule impacts and reserves needed. The “Near Term Active” risks identified in the report are summarized below.

In order for SWM to manage the above risks and to achieve its overall mission and goals, the following critical success factors have been identified:

Technical competence to manage wastes safely using existing and emerging technology

Transparent cost effectiveness achieved through waste minimization and life-cycle optimization of waste management strategies in the DOE Complex

Development of a versatile and competent workforce

Public confidence in the long-term safety of waste management plans and practices

Open relationships with regulators and advisory boards

Adequate funding provided by DOE to effectively and timely address waste treatment and disposal

1.4 Definition and Purpose

The System Plan is the primary planning and out-year scoping document for the SWM baseline, which supports the Integrated Planning, Accountability and Budgeting System (IPABS). The System Plan outlines the SWM plans to support the primary objectives of the DOE EM program. The System Plan:

Is consistent with the SRS Strategic Plan (Reference 3)

Defines existing Solid Waste Management Facilities

Identifies and defines the selected waste management path forward

The purpose of the System Plan is to determine the preferred SWM operational scope through a proven system engineering approach. This historically has been accomplished through an options analysis. Due to the effort to eliminate legacy wastes throughout the site, the large number of waste treatability groups discussed in previous System Plans has been reduced to a small number of waste streams which have well-defined disposal paths.

Near Term Active RisksReference

ID

Current

Risk Level

Target

Risk LevelLoss of Waste Tracking and Implications for Shipping and Disposal 1956 High Moderate

Critical Solid Waste Equipment Failure 1957 Moderate Moderate

SWA‐047 Major Safety or Radiological Incident 97 Low Low

SWA‐035 Waste Mischaracterized 85 Low Low

SWA‐041 Incorrect Waste Forecasts (Volume, Ci, Category) 91 Low Low

Loss of E‐Area TRU Waste Pads 2192 Low Low

Section 2.0 – Planning Bases


2.0 PLANNING BASES

2.1 Planning Method

SRS has a management planning process integrating the Project's planning needs from strategic planning down to detailed plans and source documents. The planning process, which integrates these various levels of planning and source documents, provides a coordinated planning program for SWM. The hierarchy chart of planning documents for SRS is shown in Figure 1. It consists of planning documents integrated to provide guidance at all levels of the organization. This approach minimizes the number of plans developed, assures plans have value added to the process, and supports those initiatives funded in the budget as well as providing an integrated program structured to provide consistent guidance and direction.

Figure 1. Hierarchy of SRS Planning Documents



2.2 Funding

Management and disposal of wastes is highly dependent on available funding. Likewise, SWM operations and maintenance is also dependent on available funding. This System Plan was developed based on assumed funding, with input provided by DOE, at the time of development. Upon approval of scope, cost and schedule baselines, modifications to this Plan may be needed. Percentage estimates for the SWM scope is provided in Figure 2 to illustrate the general breakdown of funding for a typical fiscal year and do not reflect an actual budget. This information is provided for comparison of the major programs supported by SWM, though actual budgets from year to year might deviate from this substantially. The majority of the PBS SR-0013 funding is related to the direct operations of the ELLWF which includes disposal activities, facility maintenance, monitoring, and regulatory support needed for continued operations. The remaining waste programs account for another significant portion, while the Consolidated Incineration Facility (CIF) and Historic Preservation programs account for a minor fraction of the total.

Figure 2. General Breakdown of SWM Funding



2.3 Regulatory Drivers and Constraints

Numerous laws, constraints and commitments influence the management of wastes at SRS, and the operations at SWM. Not all of these are identified herein, though the major components for management of waste on and offsite, and onsite disposal activities are briefly mentioned. Other constraints or commitments may be identified at future dates.

2.3.1 DOE Order 435.1, Radioactive Waste Management

The Atomic Energy Act (AEA) of 1954 (Reference 4) authorizes the DOE to self-regulate activities associated with radioactive materials. As such, DOE Order 435.1, “Radioactive Waste Management” (Reference 5), defines the requirements for the management, including the treatment, storage and disposal, of DOE owned and/or generated radioactive waste (i.e., LLW, MLLW, TRU waste and HLW). All SRS facilities that generate or manage DOE radioactive wastes comply with this Order and maintain a DOE approved Radioactive Waste Management Basis (RWMB).

For disposal facilities, a Disposal Authorization Statement (DAS) is required, issued by DOE Headquarters. The latest SWM DAS was issued in 2008 after an update to and approval of the ELLWF Performance Assessment (PA). This site-specific ELLWF PA fulfills the DOE Order 435.1 requirement that such an assessment be prepared and maintained for DOE LLW disposed after September 26, 1988 (DOE M 435.1-1. IV.P.(2)). The PA provides reasonable assurance that the facility design and method of disposal will comply with the performance objectives of the Order, which are concerned with protection of public health and safety, limiting doses to members of the public, and limiting releases of radon. The PA also establishes disposal limits on radionuclides that may be buried near-surface, assesses impacts to hypothetical inadvertent intruders, and evaluates impacts to water resources.

The SRS 1S Manual incorporates the PA derived disposal limits and is considered the DOE Order 435.1 Waste Acceptance Criteria (WAC) for the ELLWF. A review is conducted annually to ensure operations were within the bounds of the PA.

The following is provided, though not a comprehensive list of required documents, as a summary of the critical components of the ELLWF DAS:

“E-Area Low-Level Waste Facility DOE 435.1 Performance Assessment”, WSRC-STI-2007-00306 (2008)

“Savannah River Site DOE 435.1 Composite Analysis”, SRNL-STI-2009-00512 (2010)

“SRS Radioactive Waste Requirements Manual”, SRS 1S Manual, latest approved

“Performance Assessment Monitoring Plan for the E-Area Low Level Waste Facility”, SRNL-RP-2009-00534, Rev. 1 (2012)



“Closure Plan for the E-Area Low-Level Waste Facility”, SRNL-RP-2009-00075 (2009)

“Savannah River Nuclear Solutions (SRNS) Solid Waste Management (SWM) Radioactive Waste Management Basis (RWMB) (U)”, Q-RWM-E-00001, Latest approved

2.3.2 Off-SRS Transportation, Treatment and Disposal Permits

SRS transports waste off SRS for various treatment and disposal options. Transport permits are generally obtained and maintained by the transporter; however, some states require the generator (i.e., SRNS) to obtain the permit. As such, SRNS maintains transport permits with Mississippi and South Carolina.

State of Mississippi, Mississippi Emergency Management Agency, “Transport Permit”, issued to SRNS, latest issued

State of South Carolina, Department of Health and Environmental Control, “S.C. Radioactive Waste Transport Permit”, issued to SRNS, latest issued

For off-SRS disposal, many states require approval to ship or a disposal permit prior to shipment of waste to the state. Some states provide the approval or permit to ship for a specified time period, while other states may require a permit for each shipment. Similar to transport permits, some vendors maintain these disposal permits / agreements while some states require the generator (i.e., SRNS) to obtain the disposal approval. As such, SRNS maintains disposal permits or site access approvals with Texas and Utah. Though the agreement with the state of Tennessee is maintained by the vendor (i.e., Materials and Energy Corporation), it is identified here for completeness.

State of Texas, Texas Department of State Health Services, acknowledging SRNS as a Licensed Generator approved to ship to Texas, issued to SRNS, latest issued

State of Utah, Department of Environmental Quality, Division of Waste Management and Radiation Control, “Generator Site Access Permit Accessing a Land Disposal Facility in Utah”, issued to SRNS, latest issued

State of Tennessee, Department of Environment and Conservation, Division of Radiological Health, issued to Materials and Energy Corporation in Oak Ridge, TN, providing approval to ship radioactive material to a TN disposal facility, latest issued

2.3.3 Federal Facility Agreement (FFA)

Through tri-party agreement with EPA, SCDHEC and DOE, ELLWF can accept CERCLA waste as long as the waste meets the ELLWF WAC (disposal units approved for CERCLA waste are identified in Figure 6). Though EPA does not regulate DOE radioactive facilities (with exception of cleanup activities), as part of the agreement, the entire ELLWF has been added to Appendix C “RCRA/CERCLA Units” of the SRS



Federal Facility Agreement (FFA) to ensure EPA has some regulatory authority and enforceable agreement during final closure of the facilities. As part of the closure strategy, an Interim Record of Decision (IROD) was approved in 2009, requiring that upon operational closure (when curie limit or volume capacity is reached) of each Slit Trench, that interim, operational stormwater runoff covers will be installed.

“Federal Facility Agreement for the Savannah River Site”, Administrative Docket No. 89-05-FF, WSRC-OS-94-42, Latest Revision

“Interim Record of Decision, Remedial Alternative Selection for the E-Area Low-Level Waste Facility, 643-26E”, SRNS-RP-2009-00538, Rev. 1 (2009)

2.3.4 National Environmental Policy Act (NEPA)

The National Environmental Policy Act (NEPA) (Reference 6) requires federal agencies to assess the potential environmental impacts of proposed actions. The NEPA requirements are addressed in complex-wide programmatic documents as well as site specific documents. Relevant, higher tier documents have been identified below, though these lists are not all inclusive.

DOE has prepared a final Programmatic Environmental Impact Statement (PEIS) (DOE/EIS-200F) for waste management activities across multiple sites around the US. SRS is included in this complex wide PEIS, identified as the WM PEIS. The WM PEIS studied the potential nation-wide impacts of managing four types of radioactive waste (LLW, MLLW, TRU waste and HLW) and non-wastewater hazardous wastes generated by defense and research activities. Many Record of Decisions (ROD) have been issued under the WM PEIS.

“Final Waste Management Programmatic Environmental Impact Statement for Managing Treatment, Storage, and Disposal of Radioactive and Hazardous Waste”, DOE/EIS-0200F, US DOE (1997)

“Identification of Preferred Alternatives for the Department of Energy’s Waste Management Program: Low-Level Waste and Mixed Low-Level Waste Disposal Sites”, DOE/EIS-0200 Notice of Preferred Alternatives (1999)

“Record of Decision for the Department of Energy’s Waste Management Program: Treatment and Disposal of Low-Level Waste and Mixed Low-Level Waste; Amendment of the Record of Decision for the Nevada Test Site”, DOE/EIS-0200 ROD (2000)

DOE has prepared an Environmental Assessment (EA) (DOE/EA-1229) to analyze the potential environmental impacts associated with the construction, operation and decommissioning of the waste segregation facility. Based on this analysis, DOE-SR issued a Finding of No Significant Impact (FONSI) noting that the action is not a major federal action significantly affecting the quality of the human environment and therefore, no Environmental Impact Statement (EIS) for this activity is required.



“Environmental Assessment for the Construction, Operation, and Decommissioning of the Waste Segregation Facility at the Savannah River Site”, DOE/EA-1229 (1998)

“Finding of No Significant Impact for the Waste Segregation Facility at the Savannah River Site”, DOE-SR, DOE/EA-1229 FONSI (1998)

DOE has prepared an Environmental Assessment (EA) (DOE/EA-1308) to analyze the potential environmental impacts associated with the proposed offsite transportation of certain LLW and MLLW from SRS to commercial and government facilities. Based on this analysis, DOE-SR issued a Finding of No Significant Impact (FONSI) noting that the action is not a major federal action significantly affecting the quality of the human environment and therefore, no Environmental Impact Statement (EIS) for this activity is required.

“Environmental Assessment for the Offsite Transportation of Certain Low-Level and Mixed Radioactive Waste from the Savannah River Site for Treatment and Disposal at Commercial and Government Facilities”, DOE/EA-1308 (2001)

“Finding of No Significant Impact for the Offsite Transportation of Certain Low-Level and Mixed Radioactive Waste from the Savannah River Site for Treatment and Disposal at Commercial and Government Facilities”, DOE-SR, DOE/EA-1308 FONSI (2001)

The SRS Waste Management Environmental Impact Statement (WM EIS) was prepared to evaluate the environmental impact of alternative approaches to managing wastes at SRS, including onsite disposal. It provides guidance as to preferred alternative for treatment, storage and disposal of wastes.

“Savannah River Site Waste Management Final Environmental Impact Statement”, DOE/EIS-0217 (1995)

“Record of Decision; Savannah River Site Waste Management”, DOE/EIS-0217 ROD, FR Vol. 60, 55249 (1995)

“Supplemental Record of Decision; Savannah River Site Waste Management”, DOE/EIS-0217 Supplemental ROD, FR Vol. 62, 27241 (1997)

“Amended Record of Decision; Savannah River Site Waste Management”, DOE/EIS-0217 Amended ROD, FR Vol. 66, 34431 (2001)

2.3.5 SRS Site Treatment Plan (STP)

The Federal Facility Compliance Act of 1992 (FFCA) (Reference 7), waived sovereign immunity from fines and penalties for Resource Conservations and Recovery Act (RCRA) (Reference 8) violations at federal facilities. One of the provisions of the FFCA required DOE to prepare plans for developing the required treatment capacity for its mixed wastes at each site where it stores or generates mixed wastes. SRS has complied with this provision and has developed the SRS Site Treatment Plan which identifies all



the treatment technologies considered for mixed waste. The original STP was approved by the SCDHEC in 1995, through issuance of a Consent Order (SCDHEC 95-22-HW). The last SCDHEC approval was obtained in 2011. The STP is currently being updated on a five year schedule. The STP contains DOE's preferred options and treatment milestones for each mixed waste stream that requires extended storage prior to treatment. Deviations to the STP are not made without following the change process stipulated in Consent Order 95-22-HW or by written approval from SCDHEC.

This System Plan is consistent with the approved STP. The vast majority of mixed waste managed by SWM is excluded from the STP. Chapter 2 of Volume I of the approved STP excludes from the STP any mixed waste being stored or generated that meets LDR requirements and mixed waste being stored, or will be stored, when generated solely for the purpose of accumulating sufficient quantities of mixed waste as necessary to facilitate proper recovery, treatment, or disposal. In the event a new onsite mixed waste stream (not excluded from the STP per Chapter 2) is generated, SRS shall notify SCDHEC in writing within thirty (30) days of discovery. Within twelve (12) months of notification to SCDHEC of a new onsite generated mixed waste stream, SRS shall submit to SCDHEC a treatment strategy in either a modification request or revision request or an Annual Update.

“Savannah River Site, Site Treatment Plan, 2016 Update”, SRNS-TR-2008-00101, Rev. 4 (2016)

2.3.6 South Carolina Environmental Laws

Under the South Carolina Pollution Control Act, South Carolina Department of Health and Environmental Control (SCDHEC) is the delegated authority for air pollution control and water pollution control. The State has empowered SCDHEC to adopt standards for protection of water and air quality, and to issue permits for pollutant discharges. Further, SCDHEC is authorized to administer both the Federal Clean Water Act and the Clean Air Act. Under South Carolina’s Hazardous Waste Management Act, SCDHEC is granted the authority to manage hazardous waste under the SC Hazardous Waste Management Regulations (SCHWMR) (Reference 9). The following have been approved by SCDHEC which includes operations at the SWM facilities.

“Part 70 Air Quality Permit” for Savannah River Site, Permit No. TV-0080-0041

“NPDES General Permit for Stormwater Discharges Associated with Industrial Activities (Except Construction)”, Permit No. SCR000000

“National Pollutant Discharge Elimination System Permit for Discharges to Surface Waters”, Permit No. SC0000175

“2013 RCRA Permit Application, Mixed Waste Storage Buildings”, Volume VIII, SRNS-IM-2012-00002

“2013 RCRA Permit Application, TRU Pads”, Volume XIII, SRNS-IM-2012-00002



“2013 RCRA Permit Application, Solvent Storage Tanks (S33-S36)”, Volume XXV, SRNS-IM-2012-00002

“Lead Bearing Equipment”, SCDHEC letter of approval, April 2001 (ref. ESH-FSS-2002-00014) in response to SRS letter of request, October 2000 (ref. ESH-FSS-2000-00201)

2.3.7 Operating Constraints

Operating constraints are waste stream specific and fall mostly in the areas of time, budget, and resources such as equipment and facilities. Establishing treatment and disposal contracts are subject to procurement regulations. Treatment and disposal options with other DOE sites are subject to State's and stakeholder's rights and establishing agreements with other sites. Therefore, any vendors or sites identified in this plan for potential treatment or disposal, and subsequent costs, are estimates only. Constraints that impact the ability to disposition waste in the most cost-effective manner are summarized below.

LLW operating constraints:

limited operations staff to support pre-treatment and/or treatment activities

limited budget to construct new facilities onsite for pre-treatment / treatment activities

limited ability to treat low level liquid wastes onsite

waste identified for offsite disposal must meet the disposal site’s WAC

transportation of LLW from or to SRS is typically by truck, but railcars may be used

HW operating constraints:

limited onsite storage capacity (greatly driven by National Fire Protection Association requirements) results in additional shipments per year

changing site priorities and funding uncertainties

Safe, efficient management of solid waste

DOE Order 435.1

DAS for LLW• PA & CA• WAC• Disposal Limits• Monitoring Plan• Closure PlanState Permits and

Agreements

US EPA

FFA• Final closure• IROD (covers)NEPA• WM PEIS / ROD• EA / FONSI• SRS WM EIS / ROD

South Carolina

SCDHEC Permits• MW Permit• TRU Waste Permit• Air Permit• SST PermitSite Treatment Plan



MLLW operating constraints:

establishing treatment and disposal contracts are subject to regulations governing procurement of services

treatment and disposal options with other DOE sites are subject to the different states' and stakeholders' rights and establishing appropriate agreements with those other sites

limited onsite storage capacity which results in additional shipments per year

long lead time to prepare a treatment permit and obtain approval from SCDHEC before treatment can begin onsite

limited number of permitted commercial treatment vendors

limited number of operating MLLW disposal facilities (it is assumed that Nevada National Security Site (NNSS) maintains its RCRA MLLW Permit, allowing disposal of out-of-state MLLW greater than NRC 10 CFR 61 Class A Limits)

transportation of MLLW from SRS to offsite treatment, storage and disposal (TSD) facilities is typically by truck or rail

limited budget to construct new facilities onsite for pre-treatment / treatment activities

changing site priorities and funding uncertainties

TRU and Mixed TRU waste operating constraints:

government furnished systems and equipment required for non-destructive assay (NDA) and nondestructive examination (NDE) of containers

government furnished transportation to and operational status of WIPP

government furnished services such “Acceptable Knowledge” development and certification resources (equipment and human resources)

Sanitary Waste operating constraints

none identified



2.4 Waste Forecasts and Planning

Waste generators are responsible for the generated waste throughout the full life cycle of their project. Generators must designate a Generator Certification Official (GCO) for facilities/projects that generate LLW, MLLW and TRU waste. The GCO is the interface between the generator’s project personnel and SWM. The generator maintains documentation to substantiate acceptable knowledge (process knowledge). Generators must allocate adequate funding and resources to support the waste certification process and any costs incurred as a result of noncompliance. They must develop, implement and maintain a waste certification program in accordance with the 1S Manual. In addition, each generator must establish a pollution prevention (P2)/waste minimization program meeting the requirements of the SRS Pollution Prevention Program.

“Pollution Prevention Program”, SRS Manual 3Q Environmental Compliance, Procedure 6.11 (2016)

2.4.1 Solid Waste Integrated Forecast Tracking (SWIFT)

Each generator provides SWM with a waste generation forecast delineated by waste generating activity, waste category, and waste stream. This waste forecast information, as required by the SRS 1S Manual, is provided through the Solid Waste Integrated Forecast Tracking (SWIFT) process and is used to support the planning process. SWIFT is a web-based application accessible by all generators. Generators are required to use SWIFT to document and maintain facility-specific forecast of solid radioactive, hazardous, and polychlorinated biphenyl (PCB) wastes to be shipped from an SRS facility or waste unit. SWIFT is managed by SWM. This system will continue to be used as the definitive guidance for waste forecast volumes. Forecasts for LLW, HW, TRU waste, and Mixed Waste (MW) including both MLLW and MTRU waste, are all included in the SWIFT forecast. SWIFT reports are used by SWM for LLW planning and for forecasting provided to DOE (e.g., SWIFT feeds the DOE forecast system for LLW, MLLW and liquid LLW).

Forecast variances are highly dependent on project work. Routine operations, surveillance and preventative maintenance programs are generally consistent in forecast levels. There is more potential for variation in forecasted waste generation associated with project activities, such as decontamination and decommissioning (D&D), environmental restoration, etc. SWIFT provides the ability to adjust waste forecasts as scope evolves.

Estimated waste volumes for the past five years are provided in Figure 3 as an overview of waste managed by SWM. This information is provided for comparison of the major waste programs supported by SWM, though volumes managed in subsequent years may look substantially different. The graph is intended to illustrate the general breakdown of the waste programs and the relative volumes of waste managed under the respective program. The data for the Sanitary Waste Program was originally reported in metric tons (tonnes), and has been converted using an average density of 200 pounds/yard3.



Figure 3. General Breakdown of Volumes of Waste Managed by SWM

2.4.2 Waste With No Identified Path to Disposal

DOE Order 435.1 has requirements related to the disposition of waste material and prescribes specific time frames for waste staging, storage and disposal. The Order also provides specific guidance concerning wastes or materials generated with "No Identified Path to Disposal”. "Waste with No Path to Disposal” is defined as waste where there is a major issue impacting treatment, storage or disposal such as a lack of a treatment technology or no authorized facilities for treatment or disposal, or the waste does not meet the disposal facility’s acceptance criteria. An annual review and request for approval to generate waste with no identified path to disposal is issued to DOE annually (latest referenced below). Waste generators are required to notify SWM if waste generation is forecasted that does not comply with Manual 1S. No path TRU and no path MLLW is forecasted in SWIFT.

“SRS Annual Review and Request for Approval to Generate Waste With No Identified Path to Disposal for Fiscal Year 2016 (FY16)”, SRNS-J2000-2015-00774, December 2015; DOE approval obtained February 2016



2.4.3 LLW Disposition Planning

For planning purposes, it is assumed that if LLW is treated offsite (e.g., liquid LLW solidified offsite), it is returned to SRS for disposal unless otherwise specified. For the majority of forecasted LLW, it is assumed that the existing or planned TSD facilities are adequate, for example:

Tritium Extraction Facility (TEF) waste will be disposed using existing or planned TSD facilities. The first waste shipment began in FY2010. Current plans include disposing TEF waste in the ILV.

Decharacterized LLW from the Salt Waste Processing Facility must be sent offsite for disposal and will be handled by using one or more of the existing treatment/disposal options.

SWM Engineering develops an annual LLW plan that estimates the operational life of each LLW facility and identifies upcoming project needs (e.g., permits and equipment). The LLW plan considers actual data from past disposals and the forecasts provided in SWIFT.

“FY16 SWMF Low Level Waste Plan and Disposal Strategies”, SRNS-RP-2016-00162, Rev. 0 (2016)

Based on the LLW plan, the current and long-term projected status of each LLW facility is as follows (the hierarchy for the onsite LLW disposal options is provided in Figure 5):

Engineered Trenches (ET) (requires forklift or crane for stacking containers)

– ET1: Close FY2017

– ET2: Operating through FY2025

– ET3: Close FY2020

– ET4: Open FY2019, operating through FY2025

Slit Trenches (ST) (requires crane for containers, front end loader for pushing uncontainerized waste into trenches)

– ST1 - 5: Closed, stormwater runoff cover installed (2010)

– ST6, 7, 11 and 14: Operating through FY2025

– ST8, 9 and 10: Expected to be full by FY2025 (cover installed after the adjacent ST11 is full)

Components-In-Grout (CIG) Trenches (requires crane for placing containers): Operating through FY2025

Low Activity Waste Vault (LAWV) (requires forklift for stacking containers): Operating through FY2025; based on the assumption that Cells 1, 2, 9, 10, 11 and 12 are available.



Intermediate Level Vault (ILV) (requires crane for placing waste in vault): Operating through FY2025

Naval Reactor Component Disposal Area (NRCDA)

– 643-7E: Closed, partially covered with interim soil cover (2004)

– 643-26E: Operating through FY2025

2.4.4 HW Disposition Planning

The forecasts provided in SWIFT are used by SWM for planning the disposition of HW. In general, SRS open bids a global contract with a vendor who can handle SRS waste to obtain the best pricing and to minimize the regulatory and legal risks associated with the treatment and disposal of HW. Currently, the primary path for disposition of HW is per an established potential 5 year contract with Clean Harbors. This contract was based on the best pricing available at the time the contract was written, and costs have been determined to be consistent with existing DOE complex-wide treatment/disposal costs. Labpacks are shipped under the contract with Clean Harbors.

Contract with Clean Harbors: Contract Number 0000132300, “Hazardous Waste Disposal”, expires in 2020

In addition to the existing contract, SRS has the option of negotiating new pricing with the current vendor for large volume estimates and/or competitively bidding specific work scopes such as unique hazardous wastes to obtain either the best pricing and/or ability to meet required regulatory schedules.

For planning purposes, it is assumed that all shipments to TSD facilities will be by truck transportation. The total number of annual HW shipments is dependent on the unique characteristics of the waste and the volume generated. However, for planning purposes, it is assumed that the annual shipment rate for lead recycling, labpaks, and compressed gas cylinders is two shipments, six shipments, and one shipment, respectively.

Treatment and disposal can be greatly affected by changes in waste characterization and forecasting quantities which normally occur after actual waste generation. Final waste sampling and characterization may affect final treatment and disposal costs. Examples of how characterization affects final treatment and disposal costs are as follows:

Mercury in a waste stream can increase costs from $100 to $400 per 55-gallon drum to almost $2,000 per 55-gallon drum.

Levels of organics, solids, cyanides, sulfides, PCBs and various other characteristics in incinerable waste can vary costs from $100 per 55-gallon drum to approximately $800 per 55-gallon drum.

Having to overpack a 55-gallon drum due to a leak or to meet Department of Transportation (DOT) Regulations can double costs.



2.4.5 MW Disposition Planning

The forecasts provided in SWIFT are used by SWM for planning the disposition of MW. Like HW, disposition of MW is primarily per an existing contract that was globally bid to obtain the best pricing and minimize regulatory and legal risks. The current MW contract, a potential 5 year contract, is with PermaFix (to be rebid in late 2016).

Contract with PermaFix: Contract Number 0000037341, “Treatment and Disposal of Low Level Waste, Mixed Low Level Waste and Radioactive PCBs”, expires in 2016

In addition to the existing contract, SRS has the option of negotiating new pricing with the current vendor for large volume estimates and/or competitively bidding specific work scopes such as unique mixed wastes to obtain either the best pricing and/or ability to meet required regulatory schedules. Though the process is similar to the HW options, the process has been streamlined for MW via the use of Basic Order Agreements (BOAs) and the Indefinite Delivery / Indefinite Quantity (IDIQ) process. BOAs are site established agreements with vendors for treatment and disposal of MW. The IDIQ contracts are maintained by DOE Headquarters and are used for disposal options for MW. These options are shown in Figure 4.

For planning purposes, it is assumed that all shipments to TSD facilities will be by truck transportation. The total number of MW shipments is dependent on the unique characteristics of the waste and the volume generated.

Costs associated with treatment and disposal can be greatly affected by changes in waste characterization and forecasting quantities which normally occur after actual waste generation and final waste sampling and characterization of the waste. Some examples of how characterization affects final treatment and disposal costs are as follows:

For waste containing tritium and/or carbon-14, surcharge costs can vary from $1,000 to over $20,000 per container based on the levels of these isotopes in the waste.

Changes in the metals concentrations within the waste increase costs based upon the blending factor that may be needed during treatment. Costs per container are then increased base upon this blending factor.

The levels of mercury within the waste can increase surcharge costs as much as $100 per kilogram of waste.

Having to overpack a 55-gallon drum due to a leak or to meet Department of Transportation (DOT) Regulations can double costs.



Figure 4. Mixed Waste Disposition Decision Tree

2.4.6 TRU and Mixed TRU Disposition Planning

The TRU Program is an on-going waste function within the normal operations of SRS and will continue as long as TRU waste is generated at SRS. The TRU Program is anticipated to continue without interruption beyond FY2030. Planning activities associated with the TRU Program are based on forecasts provided in SWIFT and on future project estimates. Though not an inclusive list, the following projects are examples of SRS projects that generate or will generate TRU waste.

PU Blend Down Project: The PU Blend Down Project is one of the newer TRU waste programs. It involves the shipment of plutonium-239 oxide to WIPP after the material has been blended down to meet safeguards and security requirements.

Mixed Oxide (MOX) Fuel Fabrication Facility (MFFF): The MFFF will generate job and equipment waste directly from their operations forecasted at an average of 212 m3 per year. This waste will consist of plastic/paper/metal job waste, pre-filters and High Efficiency Particle Air (HEPA) filters, contaminated metals, and miscellaneous equipment. The MFFF will also generate a high-alpha liquid waste stream that will be piped to the Waste Solidification Building (WSB) to be solidified. The scheduled date to begin radiological operations at MFFF is currently uncertain and will be noted when a date becomes known.

Waste Solidification Building (WSB): The WSB is forecasted to generate approximately 180 m3 per year of TRU waste, including the solidified MFFF liquid waste and associated job control waste.



2.5 Priority Scope

In addition to the waste generation annual forecasts noted above, SWM tracks major activities that require additional resources, beyond base scope for LLW operations, to accomplish. Figure 5 provides a summary of the items identified that will require additional personnel, equipment or assets, or regulatory / documentation development. This list is not comprehensive but provides the items identified during development of this System Plan. Performance Based Incentive activities are identified with an asterisk.

Figure 5. Summary of SWM Priority Scope

FY17 FY18 FY19 FY20 FY21

* Waste Database Specification & Design Document

Waste Database Development

Crane S1 Replacement

Big Red Fork Lift Replacement

Close Solvent Storage Tanks (SSTs)

Dispose of Cadmium Rod Cask

* Dispose of 150 Culverts

Close ET1

Unreviewed Disposal Question Evaluation for ST to ET4

Install New Lysimeters

Grout ILV Cells

Dispose of 150 Culverts

Replace CIG Stormwater Runoff Cover

Construct ET4

Close ET3

High Activity Waste Tank Trailer (HAWTT)

DSA Addendum to DOE for SLB2

DSA Update for CCOs

* RCRA Closure Plan for SSTs (plan to SCDHEC)

DSA Update for CCO Storage 2000/pad

DSA Total Revision ‐ Consolidated Hazard Analysis (CHA)

Performance Assessment Update

* RCRA Closure of TRU Pad 2, Closure Report to SCDHEC

Ship 8 TRUPACT II's to WIPP ‐ POCs

Ship 7 TRUPACT III's to WIPP ‐ SLB2s

Ship Loading Equip TRUPACT‐III for Reuse

Receive K‐Area Complex CCOs

Install Safeguard & Security Measures for CCOs

Install Characterization Equipment for CCOs

CCP Characterization of CCOs

Ship CCOs to WIPP

Capital Improvements / Asset Management

Regulatory

SWM Priority Scope

TRU Waste Program (assumes WIPP start in FY17)

Recycling Program (Lead)

LLW Program (Operations & Disposal)

HW/MW Program

Section 3.0 – Low Level Waste


3.0 LOW LEVEL WASTE (LLW)

3.1 LLW Integrated Operations

LLW is radioactive waste that is not classified as high-level waste, TRU waste, spent fuel, or byproduct material as defined in DOE Order 435.1, and does not contain RCRA regulated hazardous waste. It consists of radioactively contaminated materials such as miscellaneous job control waste, equipment, plastic sheeting, gloves, and soil. Lead bearing equipment may be disposed in ELLWF as noted in Section 5.0. Most onsite organizations generate LLW. LLW is also received from offsite generators, primarily from the Naval Reactors Program. Both onsite and offsite generators are responsible for segregating, characterizing, packaging, and shipping waste once certified to the waste acceptance criteria (WAC) of the receiving facility. The WAC data is entered into the Waste Information Tracking System (WITS). Generators may request deviations from WAC requirements and approval to use non-standard containers.

SWM is responsible for receiving waste from onsite and applicable offsite generators and verifying the waste, as characterized, complies with the receiving facility WAC. The primary isotopes of concern are tritium, iodine-129, carbon-14, technetium-99, strontium-90, uranium-234, uranium-235 and neptunium-237. SWM is also responsible for shipping waste offsite (DOE and commercial facilities) for treatment and disposal (if applicable); verifying waste is acceptable for disposal; storing waste pending treatment and disposal; and disposing waste in appropriate facilities. SWM further ensures that facilities comply with environmental and safety requirements through a system of procedures and standard operating practices.

3.2 LLW Facilities

Most newly generated LLW is disposed directly in the SWM LLW facilities which include the trenches (Engineered Trenches (ET), Slit Trenches (ST), and Components-In-Grout (CIG) Trenches), the E-Area Vaults (EAV) (Low Activity Waste Vault (LAWV) and the Intermediate Level Vault (ILV)), and the Naval Reactor Component Disposal Areas (NRCDA). Brief descriptions and images of each facility are provided below.

Typically, SWM follows the progression pathway in Figure 6 for onsite disposal of LLW. If waste exceeds all of the disposal limits, or if the waste will adversely impact the LLW facilities’ disposal inventories, and it can be shipped to an approved offsite facility for disposal, then the waste is disposed offsite. Naval Reactor (NR) components that do not meet the disposal progression pathway are placed in the NRCDA.

LLW Program

Receipt and interim storage (surveillance & maintenance)

Receipt of waste from onsite and approved offsite generators

Shipment from storage or direct shipment from generators to TSD facilities

Disposal onsite for waste meeting ELLWF WAC



Engineered Trench

• Containerized waste which can be stacked

• Lowest radiological activity

• Below “high rad” threshold (200 mR/hr at 5 cm)

Slit Trench

• Uncontainerized wastes (i.e., skid pans, roll‐off pans)

• Contaminated Large Equipment disposals

• Higher fissile containers (> 50 fissile gram equivalent)

• High dose activity waste

• CERCLA waste

• Classified waste

Components‐In‐Grout

• Containers that cannot be stacked or placed in LAWV

• Contaminated Large Equipment disposals

• Higher fissile containers (> 50 fissile gram equivalent)


• Classified Waste

Low Activity Waste Vault

• Stackable waste containers

• Tritium waste containers with lower activity levels

• Below “high rad” dose threshold (200 mR/hr at 5 cm)

• Leachable polychlorinated bi‐phenyls (PCB) waste

• CERCLA waste

Intermediate Level Vault

• Containers which exceed the LAW Vault limits

• Tritium waste containers with higher activity

• Leachable PCB waste


• CERCLA Waste

• Classified waste

Figure 6. Hierarchy of Onsite LLW Disposal Options

3.2.1 Engineered Trenches (ET)

ETs receive primarily LLW in B-12 and B-25 boxes and Sealands. An ET has a design capacity of about 46,805 m3 (1,652,900 ft3). The effective capacity is about 35,300 m3 (1,250,000 ft3) based on an efficiency factor of 0.76. The typical trench has a sump to collect stormwater run-off for analysis prior to releasing. Once filled the ET is backfilled and covered with a minimum of four feet of clean soil to reduce surface radiation dose rate. ETs can accommodate B-25s stacked four high or Sealands two high.



3.2.2 Slit Trenches (ST)

To conserve concrete vault space in the EAVs, the Slit Trenches, which are below-grade trenches, are designated for construction/decontamination and decommissioning debris, contaminated vegetation and contaminated soil disposal. The gross disposal capacity of each set of Slit Trenches (i.e., 5 segments equal 1 set) is about 28,900 m3 (1,020,000 ft3). The effective capacity is about 16,464 m3 (581,500 ft3) based on an efficiency factor of 0.57. Once a trench is filled with waste, the trench is backfilled and covered with a minimum of four feet of clean soil to reduce surface radiation dose rate. In accordance with the FFA, stormwater run-off covers are installed over each Slit Trench.

3.2.3 Components-In-Grout (CIG) Trenches

The CIG Trenches are similar in construction to the Slit Trenches. However, the components disposed in the CIG Trenches are encapsulated in grout. Encapsulation occurs after placement of the component in the trench. The CIG Trenches are used to dispose of bulky and containerized low level radioactive waste items that have higher radioactive inventories compared to the waste in a standard Slit Trench. A CIG Trench has a gross capacity of about 16,500 m3 (583,000 ft3) with an effective capacity of about 6,500 m3 (233,200 ft3) based on an efficiency factor of 0.40. The disposal cost for CIG is significantly higher compared to disposal in other LLW disposal options.

3.2.4 Low Activity Waste Vault (LAWV)

The LAWV is an at grade concrete structure. The vault has a design-capacity of about 30,600 m3 (1,080,500 ft3) which is equivalent to about 12,000 B-25 boxes. The LAWV is designed to receive, store, and dispose of LLW radiating less than or equal to 200 millirem per hour at five centimeters from the surface of the box.

3.2.5 Intermediate Level Vault (ILV)

The ILV is a subsurface concrete structure designed for waste that radiates greater than 200 millirem per hour at five centimeters from an unshielded container or waste that contains significant quantities of tritium. The ILV is top-loaded and has removable rain covers, and the cells are encapsulated with grout in layers as waste is placed for disposal. The ILV has eight bulk waste cells and one cell with a silo system designed to house tritium crucibles. The ILV has a design capacity of about 4,284 m3 (150,000 ft3).

3.2.6 Naval Reactor Component Disposal Area (NRCDA)

The NRCDAs, with a total capacity of 6,700 m3 (236,600 ft3), are at-grade laydown areas designed for permanent disposal of activated metal or surface-contaminated NR components (typically encased in shielded shipping containers) from the NR program. NR components consist of core barrels, adapter flanges, closure heads, pumps, and other similar equipment. One NRCDA, located near TRU Pad 6, is closed for all future NR components. The other NRCDA is located just north of the 664-E Green-Is-Clean (GIC) Building, and contains the NR components that are to be disposed in place.



• Unlined, earthen trench

• Primarily boxed LLW (B‐25s 4 high or Sealands 2 high)

• ~35K m3 capacity

• Backfilled with 4’ clean soil

Engineered Trench

• Unlined, below grade, earthen trench

• Primarily for construction and D&D debris, vegetation & soil

• ~16K m3 capacity

• Backfilled with 4' clean soil

Slit Trench



• Similar to Slit Trenches but waste is encapsulated in grout

• For bulky or containerized waste with relatively higher radioactivity

• ~6.5K m3 capacity

Components‐In‐Grout Trench

• At‐grade concrete structure

• 12 cells

• For LLW <= 200 mrem/hr at 5 cm

• ~30K m3 capacity (~12K B‐25s)

Low Activity Waste Vault



• Subsurface concrete structure

• Waste is encapsulated with grout

• 8 bulk waste cells and 1 silo system

• For > 200 mrem/hr at5 cm or significant H‐3

• ~4K m3 capacity

Intermediate Level Vault

• At‐grade laydownareas

• For activated metal or surface contaminated NR components

• ~6,000 m3 capacity

NR Component Disposal Area

Section 4.0 – Hazardous Waste


4.0 HAZARDOUS WASTE (HW)

4.1 HW Integrated Operations

HW are wastes specifically identified by the EPA as HW (i.e., listed wastes contained in 40 CFR 261, Subpart D) or wastes that meet one of four HW characteristics identified in 40 CFR 261, Subpart C. The four HW characteristics are ignitability, corrosivity, reactivity, or toxicity. HW has been generated at SRS as a result of past operations and continues to be generated as a result of current operations including material stabilization, waste management, environmental restoration, and D&D activities. Typical HW includes materials such as RCRA metals, solvents, paints, pesticides, and hydrocarbons. Also handled under the HW program is PCB waste regulated under 40 CFR 761.

The HW Program involves four primary operations: receipt and interim storage; shipment from storage or direct shipment from the generating facility; treatment either onsite or offsite; and disposal offsite. Once characterized, HW is either received and stored at the SWM facility and then sent to a treatment, storage and disposal (TSD) facility or a direct shipment is made from the generating site to the TSD facility (Figure 7). Waste receipt and interim storage activities include receipt of newly generated waste, placement of the waste in storage and subsequent surveillance and maintenance of the stored waste. The surveillance and maintenance activities at the HW facilities require an on-going effort to inspect containers; verify secondary containment features; maintain grounds and equipment; and, in some cases, conduct remedial actions to prevent releases from degraded containers.

HW is released from radiological controls in accordance with the SRS Radioactive Material Management Area program. This program assures that RCRA-hazardous, state-hazardous and Toxic Substances Control Act (TSCA) regulated wastes shipped from DOE facilities to commercial TSDs have no bulk or volume radioactive contamination added as a result of DOE operations, and are in compliance with DOE criteria for unrestricted release unless the receiving facility is specifically licensed to manage radioactive waste. The TSD facility treats, if needed, and disposes of waste in accordance with Federal and State Regulations. HW is treated in accordance with RCRA regulations. Treatment of HW is an ongoing established process with multiple vendors/facilities available.

The main waste minimization and P2 measures for HW, conducted at the generating facility, are to avoid unnecessary waste generation and reduce the volume and toxicity of the waste through substituting non-hazardous materials in place of hazardous materials at the source. In an effort to eliminate or substantially reduce the generation of this type of waste, SRS modified procedures and practices regarding the use of hazardous materials across the Site substituting non-regulated materials as much as practical.

HW Program

Receipt and interim storage (including surveillance & maintenance)


Treatment (onsite and/or offsite)

Disposal offsite



Figure 7. Disposition of Hazardous Waste

4.2 HW Facilities

The HW facilities are part of the Hazardous Waste/Mixed Waste (HW/MW) facilities within SWM which consist of two primary storage buildings, 643-29E and 643-43E, and various TRU RCRA permitted storage facilities. Limited storage space increases the number of shipments required to remain in compliance with National Fire Protection Association (NFPA) storage restrictions.

4.2.1 Buildings 643-29E and 643-43E

These buildings are operating under a RCRA Permit (see Section 2.3.2). Each building is an above-grade facility that consists of a concrete storage slab covered by a pre-engineered building. Each building has structural steel frames with sheet metal roofing and partial sheet metal siding. The sides of the buildings from grade to about five feet above grade are chain link fences. Each building has a 6-inch-wide by 4-inch-high concrete curb, which drains to a collection sump surrounding the storage area.

Building 643-29E contains multi-container, 2-hour fire rated storage lockers equipped with secondary containment that help facilitate segregation, spacing and containment of waste in a manner that allow permit and NFPA requirements to be met. Building 643-43E was used to support the TRU Program as the Non-Destructive Assay (NDA) Facility, but currently is empty and may be transitioned back to a storage facility for small quantities of HW/MW.



• RCRA Permited for HW/MW storage

• Above grade, curbed concrete floor, collection sump

• Meets NFPA requirements

• 78,091 gallon capacity

• Combustible & oxidizer separation shown (25')

643‐29E

• RCRA Permited for HW/MW storage

• Above grade, curbed concrete floor, collection sump

• 280,051 gallon capacity

• Empty

643‐43E

Section 5.0 – Mixed Low Level Waste


5.0 MIXED LOW LEVEL WASTE (MLLW)

5.1 MLLW Integrated Operations

MW is defined as waste containing both hazardous and radioactive constituents as defined by the RCRA, 40 CFR 261, Subparts C and D and SCHWMR, and the Atomic Energy Act (AEA) of 1954. MW may be further classified as MLLW or MTRU waste. This section only addresses MLLW and includes liquid MLLW stored in H-Area, i.e., the Solvent Storage Tanks (SSTs). MTRU is addressed in Section 6.0 “TRU and Mixed TRU Waste (TRU & MTRU)”. MLLW is managed in accordance with DOE Orders, RCRA, and SCHWMR. Treatment options must meet Land Disposal Restrictions (LDR). In December 2010, NNSS opened a new RCRA-permitted MLLW disposal unit. This allows NNSS to receive waste generated by cleanup activities across the DOE complex. Newly generated mixed waste is dispositioned within one year.

The MLLW Program involves four primary operations: receipt and interim storage; shipment from storage or direct from the generating facility; treatment onsite or offsite; and disposal offsite. Waste in storage is subject to surveillance and maintenance which is an ongoing effort to inspect containers to ensure that container integrity is maintained. This includes verifying secondary containment, maintaining facility grounds and equipment, and conducting remedial operations to prevent releases from degraded containers.

MLLW streams are generated at SRS by various activities and operations, environmental cleanup, D&D, and construction activities. MLLW includes job control waste such as solvent-contaminated wipes, cleanup and

construction debris, soils from spill remediation, RCRA metals, and laboratory samples. MLLW treatment options are available onsite and through offsite commercial facilities. Pre-treatment and treatment activities are necessary to ensure the waste meets RCRA disposal requirements.

In addition to the generator’s certification program, prior to receipt SWM personnel verifies that the waste is packaged correctly and is categorized in the appropriate treatability group to meet LDRs. Some MLLW may be identified with no path for disposal. If a treatment or disposal option is not identified or there are other factors that prevent treatment or disposal, those conditions are identified. MLLW identified with no path to disposal, highly radioactive, or problematic will be evaluated on a case-by-case basis for treatment onsite or shipped to a commercial facility for treatment and then disposal at NNSS. A summary of the disposition process is provided in Figure 8.

Waste minimization and pollution prevention (P2) are equally important and are conducted mainly at the generating facility. The main waste minimization and P2

MLLW Program

Receipt and interim or long term storage (surveillance & maintenance)


Treatment (onsite and offsite)

Disposal offsite / NNSS

Section 5.0 – Mixed Low Level Waste


measures for MLLW are to avoid unnecessary generation, reduce the volume and toxicity of waste through substitution of non-hazardous materials in place of hazardous materials at the source, and decontaminate and recycle materials including RCRA metals (e.g., lead).

Waste in Long Term Storage for Radioactive Decay: Per the STP, some MLLW can be kept in long-term storage prior to treatment for radioactive decay. Waste in long term storage may need to be repackaged prior to shipment.

Recyclable Lead: At the commercial recycling TSD facility, the waste is either recycled into usable materials for the Nuclear Industry or is treated and disposed in accordance with Federal and State Regulations. SRS strives to recycle lead in lieu of disposal.

Lead Bearing Equipment: SCDHEC has concurred that lead shielding and counterweights being used for their intended purpose, which are not radioactively contaminated or activated, is not waste (i.e., LLW with uncontaminated lead shielding or counterweights is not a MW). As such, SCDHEC has approved the disposal of up to a lifetime of 100,000 pounds of uncontaminated lead used as shielding or counterweights in ELLWF. Of the available 100,000 pounds, approximately 89,000 pounds of lead has been disposed as LLW in ELLWF.

Figure 8. Disposition of Mixed Low Level Waste

5.2 Mixed Waste Storage Facilities

MLLW is stored in the HW/MW storage facilities described in Section 4.2. Four Solvent Storage Tanks (SST) are located in H-Area (607-33H through 607-36H). The H-Area SSTs are used for the storage of radiologically contaminated organic solvent waste. These SSTs (SST S33 - S36) are permitted under RCRA with closure planned in the near future.

Section 6.0 – TRU and Mixed TRU Waste


6.0 TRU AND MIXED TRU WASTE

6.1 TRU and Mixed TRU Waste Integrated Operations

TRU waste is defined in DOE Order 435.1 as waste contaminated with alpha-emitting transuranic radionuclides (radionuclides with atomic numbers greater than 92) with half-lives greater than twenty (20) years in concentrations greater than 100 nanocuries per gram (nCi/g) of waste matrix. TRU Waste at the SRS that also contains hazardous constituents as defined in 40 CFR 261 and the SCHWMR R.61-79.261 is managed in accordance with both DOE Orders and SCHWMR and is referred to as Mixed TRU waste. Typically, mixed and non-mix TRU waste is stored, characterized and disposed in the same manner.

There are two categories of TRU waste: contact handled and remote handled. Contact handled waste is defined as anything less than or equal to 200 mrem/hr. Contact handled waste makes up the vast majority of the SRS TRU waste. Remote handled waste is defined as having a surface dose rate greater than 200 mrem/hr. Containers for remote handled waste must be either a 15 gallon, a 30 gallon or a 55 gallon 7A Type A, DOT package. Special consideration is taken when characterizing and shipping these containers to protect the worker and the public from unnecessary exposure.

TRU waste streams are, and have been, generated primarily by plutonium (Pu) separations facilities and analytical laboratories. In the 1970's, SRS received TRU waste from offsite generators including the Los Alamos National Laboratory and the DOE Mound Site. SRS also received TRU waste from the DOE Mound Site and the DOE Battelle West Jefferson Site to support closure of these sites. Past SRS generators of small volumes of TRU waste included the Reactor Facilities, the Fuel Fabrication Facility, and the High Level Waste Tank Farms.

TRU Waste continues to be generated in small amounts from current SRS operations, which consists primarily of job control waste and debris (e.g., plastic, paper, rubber, glassware, metal items, lead-lined gloves, filters, used equipment and other contaminated materials from routine processing). In addition, PU Blend Down Project, MFFF and the WSB are expected to generate appreciable quantities of TRU waste.

The TRU Program is highly impacted by the operating status of the WIPP facility and is managed overall by the National TRU Program. DOE-CBFO (Carlsbad Field Office) leads this organization and obtains input from all TRU generating sites and DOE-HQ.

TRU waste operations include waste receipt, storage, characterization, certification, and shipment for disposal at the WIPP facility. The TRU Waste Program involves safe management of 10 active TRU waste storage pads in E Area. TRU waste packages are received from generators in accordance with the SRS Procedure Manual 1S, SRS

TRU Waste Program

Receipt and interim storage (including surveillance & maintenance)

Shipment from storage to TSD facilities

Disposal offsite / WIPP



Radioactive Waste Requirements. Waste is segregated and stored on concrete pads based on the type of packaging, total curie inventory or external dose rate. Drums and other containers with higher activity may be placed in concrete culverts for safe storage. Containers with high radiation rates are placed inside controlled radiation areas for personnel protection in accordance with Manual 5Q, Radiological Controls.

Newly Generated TRU Waste: Newly generated TRU waste is defined as waste not certified by the WIPP program before February 2014. Due to an accident at the WIPP site, changes to the waste acceptance program have been made. Newly generated waste must meet the more stringent criteria. These new requirements include an Interface Waste Management Documents List that identifies SRS plans, procedures and reports associated with waste management. These documents give the complete history of generation, packaging and characterization of the waste. Also a chemical compatibility evaluation and acceptable knowledge assessment, utilizing the Basis of Knowledge Review, will be performed before containers are added to a waste stream and certified. These changes are being added to the SRS Procedure Manual 1S requirements.

Legacy TRU Waste: SRS implemented an aggressive program over the past 15 years to remediate, repackage and ship the legacy TRU waste to the WIPP. Under the American Recovery and Reinvestment Act, all of the legacy TRU waste remaining at SRS was repackaged and characterized. Most of the legacy waste was shipped to the WIPP site. The remaining 600 m3 will be shipped when WIPP starts taking waste again. A small portion of the legacy TRU waste requires changes to the Documented Safety Analysis at the WIPP Site and SRS. Once completed, the waste containers will be allowed to ship and be disposed at the WIPP Site.

6.2 TRU Waste Facilities

6.2.1 TRU Waste Storage Pads

TRU Pads 3-6, 14-15, 17-19 and 26 are at-grade concrete TRU pads. Note that Pad 2 is not permitted and is interim capacity; it is not used for TRU waste storage. TRU Pads are used to provide storage of waste in containers as specified in the current RCRA Permit and have weather enclosures erected over them.

TRU waste is stored on the TRU pads within various types of WIPP compliant containers, such as steel drums, standard waste boxes (SWB) or standard large boxes (SLB). Containers of waste are either stored directly on a TRU pad or inside an overpack container, which is then stored on a TRU pad. The primary overpack container is the concrete culvert. Up to fourteen 55-gallon drums (two layers of seven drums each) can be stored in a concrete culvert.



• Shows SWB storage

• Capacity up to ~2,000, 55 gallon drums

Typical TRU Pad Storage

6.2.2 TRUPACT-II and TRUPACT-III Loading Facilities

The TRUPACT-II Loading Facility is located on Pad 3. This facility is used to load WIPP compliant containers, 55-gallon drums and SWBs into TRUPACT-II shipping casks and to certify the TRUPACT-II casks for shipment.

The TRUPACT-III Loading Facility is located on Pad 26. This facility is used to load WIPP compliant standard large boxes into TRUPACT-III shipping casks and to certify the TRUPACT-III casks for shipment.

6.3 Central Characterization Project (CCP)

CCP, an organization within the WIPP Management & Operations Contractor “Nuclear Waste Partnership”, provides acceptable knowledge document development and the certified program allowing SRS to ship TRU waste to the WIPP site. CCP typically provides the equipment and personnel for the physical container characterization and the container certification program required to meet the WIPP waste acceptance criteria. Requirements include NDA and NDE, and headspace gas analysis.



• Loading shrink wrapped payload of 14, 55 gallon drums

• TRU Pad 3

TRUPACT‐II Loading Facility

• Loading SLB‐2 payload

• 7 SLB‐2s remain to be shipped

• Equipment to be relocated to another DOE site after use

• TRU Pad 26

TRUPACT‐III Loading Facility

Section 7.0 – Sanitary Waste


7.0 SANITARY WASTE

7.1 Sanitary Waste Program Operations

Sanitary Waste is solid waste that is neither radioactive nor hazardous as defined by the AEA or RCRA. Sanitary waste consists of materials that may be disposed in a municipal sanitary landfill, a Construction and Demolition (C&D) Landfill, and industrial waste such as salvageable or recyclable materials and scrap metal. The Sanitary Waste Program ensures compliance with SCDHEC regulatory requirements for the management of normal office and industrial non-hazardous debris waste streams. The Sanitary Waste Program collects, hauls, recycles, and disposes of routine solid sanitary wastes and industrial debris generated by activities at SRS. Disposal is conducted at the SRS C&D Landfill, the Three Rivers Regional Landfill, and the North Augusta Material Recovery Facility (NAMRF).

7.1.1 Routine Sanitary Waste

Routine sanitary waste consists primarily of office building and cafeteria generated wastes. This sanitary waste stream is collected and placed into front-load dumpsters that are staged as needed at generating facilities. A waste compactor truck, manned by a driver and spotter, pick up waste on typically a once-per-week schedule. When the compactor truck is full, which takes about 8-12 dumpsters, it is transported to the NAMRF for segregation into recycle and disposal streams. Wastes that are segregated as non-recyclable from NAMRF operations are transported to the Three Rivers Landfill (disposal fees for Three Rivers Landfill is included in the NAMRF contract). Cafeteria waste is collected separately from other routine waste and is sent directly to Three Rivers. Routine sanitary waste operations are provided by SRNS Site Infrastructure Services. Replacement dumpsters and waste pans are purchased to replace those that have deteriorated. Front loader compactor garbage trucks are leased through the site Portable Equipment Commodity Management Center (PECMC) for the collection and transport of routine sanitary wastes. Subcontracts provide access to the NAMRF and Three Rivers Landfill.

7.1.2 Sanitary C&D Waste

Sanitary C&D waste consists of bulky materials disposed in roll-off, skid pans and dump trucks. This type of waste is typically generated from land clearing, construction, site prep or demolition activities and includes inert debris and wood waste. Debris waste compliant with C&D Landfill acceptance criteria is collected in dump trucks and pans and transported at the generator’s expense for disposal at the SRS C&D Landfill. Non-compliant C&D waste is collected in dump trucks and pans and transported at the generator’s expense for disposal at the Three Rivers Landfill with typical disposal quantities funded by the Site Sanitary Waste Program and large project disposals at Three Rivers Landfill funded by the generating projects.



7.2 Sanitary Waste Facilities

7.2.1 SRS Construction and Demolition (C&D) Landfill

The SRS C&D Landfill is located onsite near N-Area. SRS started operating the onsite C&D landfill in November 2003. C&D Landfill operations are provided by Infrastructure Services. Sanitary program oversight is provided by one Operations Lead Specialist for program coordination and Subcontract Technical Representative (STR). Equipment, such as bulldozers, light plants, graders, is leased through PECMC for landfill operations and maintenance.

The Sanitary Waste C&D Landfill Program provides for operating a “Part III” Construction, Demolition and Land-Clearing Debris Landfill registered per SCDHEC regulation R.61-107.11, Solid Waste Management: Construction, Demolition and Land-Clearing Debris Landfills.

The SRS C&D landfill accepts inert debris and wood, avoiding Three Rivers Landfill’s transportation and disposal fees. The SRS C&D Landfill receives about 60,000 tons of waste per year. The SRS C&D Landfill avoids the transportation and disposal fee costs of using the municipal Three Rivers Landfill and also provides the flexibility of extended operating hours to support schedules. Use of the SRS C&D Landfill results in an annual savings of about $3.5 million (based on the Three Rivers Regional Landfill's tipping fee).

7.2.2 Three Rivers Regional Landfill

A section of the Site property, adjacent to Highway 125, was permitted to the Three Rivers Solid Waste Authority beginning in 1996 (leased from DOE). A 50 year permit was issued for disposing sanitary solid waste, consisting of household and commercial waste from the surrounding counties. The Three Rivers Regional Landfill, a subtitle D Landfill, is operated by the Lower Savannah Council of Governments (LSCOG).

DOE-SR and the Three Rivers Solid Waste Authority are committed to the development and use of the Three Rivers Regional Landfill, which disposes of waste from SRS and nine South Carolina counties. The 1,400 acre site with currently a 300 acre operating footprint is expected to provide safe and efficient disposal capacity for over 250,000 tons of sanitary waste a year for about a 70-year life. SRS sends about 250 tons per month of waste to this landfill. The Three Rivers Regional Landfill's current tipping fee is approximately $59 per ton of waste.

7.2.3 North Augusta Material Recovery Facility (NAMRF)

SRS is required by federal mandate to recycle as much material, as practical, from its routine office-type, municipal mixed waste stream. Federal Executive Order 13514, “Federal Leadership in Environmental, Energy, and Economic Performance” establishes a goal to recycle a minimum of 50% of the non-hazardous solid waste from lined landfills. In order to support attainment of this goal, North Augusta Material



Recovery Facility (NAMRF) was selected based on best value to the government with capabilities to cost-effectively remove the maximum amount of recyclable materials from its sanitary mixed waste stream while demonstrating efforts to exceed the material recovery rate goal.

7.3 Sanitary Waste Streams Reduction and Recycling

Waste minimization and pollution prevention activities conducted onsite include recycling of scrap metals (over 500 tons in FY2015) and other industrial debris through Site Salvage Operations and Construction Recycle Services (e.g., lead acid batteries, florescent bulbs and mercury containing equipment). Chemical products are reused or recycled through the Chemical Management Center. In addition, the Site shipped about 1,600 tons of office sanitary waste in FY2015 to the NAMRF to remove white office paper, newspaper, magazines, cardboard, plastics, steel cans, aluminum cans, and glass. The NAMRF removes about 46% of this waste stream for recycle.

Concrete and Asphalt: SRNS has received approval from SCDHEC to accumulate concrete and asphalt debris. Once sufficient quantity is accumulated, a vendor will be mobilized to crush the material. Crushed material will be used as clean surrogate crusher run for re-use across SRS.

Wood: Onsite reuse options for wood were explored with the US Forestry Services and the Ameresco Biomass Cogeneration Facility (Ameresco), though neither option was determined to be acceptable. No other reuse or recycle potential for this waste stream currently exists. The wood is disposed at the C&D Landfill.

Tires: Disposal of tires from leased (contracted) vehicles is not managed by SWM. Used tires from the onsite PECMC group are collected in a roll-off pan and transported to Ameresco for recycling.

Section 8.0 – Pollution Prevention


8.0 POLLUTION PREVENTION

8.1 Pollution Prevention (P2) Program

Pollution Prevention (P2) is the SRS preferred approach to reducing waste, mitigating health risks, and protecting the environment. The P2 Program provides SRS a safe, effective, and environmentally responsible strategy to implement specific waste reduction techniques based on current and projected information on waste generation, waste characterization, and ultimate waste disposal costs. The SRS P2 Program is managed to meet the requirements and expectations of EPA and State regulations, and DOE directives, policies and procedures. P2 is a key component of the SRS Environmental Management System (EMS) (Reference 10) and the site Sustainability Plan (Reference 11).

The SRS P2 Program is described in Manual 3Q, Procedure 6.11, "Pollution Prevention Program". The P2 Program’s scope includes both in-field generator programs and a site-wide coordination program. The generators’ programs are funded through each generator's operating budget to coordinate organization-specific program initiatives and to implement process modifications and new technologies. Site-wide program coordination which is managed by Solid Waste Management is separately funded and provides the following:

management support of waste minimization initiatives within the P2 Program

technical assistance for facility walk-downs, lifecycle waste cost analysis, and P2 opportunity assessments

forums for waste minimization and P2 information and technology exchanges

employee P2 awareness and training programs

mechanisms to increase waste generator accountability through the SWM Committee

management of a centralized documentation system to collect and record SRS waste reduction efforts

completion of required annual plans and reports

implementation of site-wide initiatives such as sanitary waste recycle, Green-Is-Clean (GIC) programs and other site-wide cost-cutting initiatives

establishing a P2 component into the Site's Communication Plan to increase public awareness and support

Section 8.0 – Pollution Prevention


8.2 Pollution Prevention Vision

The SRS will have a sustained commitment to P2 that encompasses all applicable organizations and functions. Acknowledged by its stakeholders as a responsible role model, the P2 Program will continue to:

reduce radioactive and hazardous solid waste generation and toxic effluent releases

reduce and recycle sanitary waste

reduce secondary waste from SRS cleanup activities

incorporate P2 into facility design activities

support specific objectives defined in Environmental Management System and the Site Sustainability Plan

reduce the cost of Site operations and environmental compliance using P2 concepts

Section 9.0 – References


9.0 REFERENCES

1. “Savannah River Site Ten Year Site Plan FY2016-2025”, SRNS-RP-2015-00001, June 2015

2. “SRNS FY17-FY21 Contract Performance Baseline: PBS SR-0013 Solid Waste

Stabilization and Disposition Risk & Opportunity Analysis Report (U)”, Y-RAR-E-00014,

Rev. 0, August 2016

3. “Savannah River Site Strategic Plan”, SRNS-IM-2011-00044

4. “Atomic Energy Act of 1954”, as Amended, US NRC

5. “Radioactive Waste Management”, DOE Order 435.1, Order, Manual and Guide, US DOE

6. “National Environmental Policy Act of 1969”, as Amended, US Public Law 91-190

7. “Federal Facility Compliance Act of 1992”, US Public Law 102-386

8. “Resource Conservation and Recovery Act of 1976”, US Public Law 94-580, Subtitles C

and D, US EPA, 40 CFR 261

9. “South Carolina Hazardous Waste Management Regulations”, R.61-79, SCDHEC

10. “Environmental Management System Implementation”, 3Q Environmental Compliance

Manual, Procedure 13.5, Revision 5, May 2014

11. “Site Sustainability Plan: Savannah River Site FY2016”, SRNS-RP-2015-01040, Rev. 0,

January 2016

Appendix A – List of Assumptions


APPENDIX A – LIST OF ASSUMPTIONS APPLICABLE TO THIS SYSTEM PLAN

General Assumptions

Newly generated HW, mixed waste (MW), and LLW will be disposed per regulatory requirements (currently within one year).

E Area will retain responsibility for certification activities.

CIF surveillance and maintenance activities will continue through the baseline period.

No LLW, MLLW, or TRU wastes from MOX or WSB (NNSA mission) were considered in this baseline.

LLW Assumptions

Existing facility capacity is adequate for planned LLW onsite disposal through the baseline period.

Waste minimization and volume reduction activities could increase the radionuclide concentrations of waste.

Disposal space in the LAWV can be shown to be adequate for at least the next 25 years, based on current waste forecasts, procedures and practices, and more effective use of the Engineered Trench, Slit Trench, and offsite facilities. This also assumes that the LAWV cells, used for other activities, are made available for disposal.

Tritium Extraction Facility (TEF) waste will be disposed using existing or planned treatment-storage-disposal (TSD) facilities. Current plans include disposing TEF waste in the ILV.

Establishing treatment and disposal contracts are subject to procurement regulations. Treatment and disposal options with other DOE sites are subject to State's and stakeholder's rights and establishing agreements with other sites. Therefore, any vendors or sites identified in this plan for potential treatment or disposal, and subsequent costs, are estimates only.

The SRS waste identified for offsite disposal must meet the disposal site's WAC.

There will be no fundamental changes to the LLW onsite disposal requirements (e.g., no liner requirements).

If LLW is treated offsite (e.g., liquid LLW solidified offsite), it is returned to SRS for disposal, unless otherwise specified.

Transportation of LLW from or to SRS is typically by truck, but railcars may also be used.



DOE suspension of commercial recycle of metals from radiological areas has increased LLW and MLLW disposal. If this suspension is lifted, some metals could be cleared for free (non-radiological) release, thus reducing LLW disposal of metals.

The Salt Waste Processing Facility will produce LLW. The volume of LLW forecasted will be handled by using one or more of the existing treatment/disposal options.

MLLW Assumptions

Establishing treatment and disposal contracts are subject to regulations governing procurement of services.

Treatment and disposal options with other DOE sites are subject to the different states' and stakeholders' rights and establishing appropriate agreements with those other sites.

If MLLW is treated offsite, the treatment residuals will be shipped directly from the treatment facility to disposal unless otherwise specified.

MLLW shipped offsite for treatment or disposal is transported by truck or rail.

Unless otherwise known, the assumption is waste identified for offsite treatment will meet the disposal site's WAC and, therefore, waste will be considered disposable at that site.

Offsite disposal of MW will be held to the minimum compliance levels to meet regulatory requirements.

The NNSS maintains its RCRA MLLW Permit allowing disposal of out-of-state MLLW greater than NRC 10 CFR 61 Class A limits.

DOE suspension of commercial recycle of metals from radiological areas has increased LLW and MLLW disposal. If this suspension is lifted, some metals could be cleared for free (non-radiological) release, thus reducing LLW disposal of metals.

There will be no fundamental changes to the regulations/permits imposed on the Site’s mixed and hazardous waste RCRA Treatment, Storage and Disposal programs.

The lead recycle program will continue (~50,000 pounds per year) vs. disposal as MW.

HW Assumptions

There will be no fundamental changes to the regulations/permits imposed on the Site’s mixed and hazardous waste RCRA Treatment, Storage and Disposal programs.

HW may continue to be stored beyond one year solely for the purpose of accumulation of such quantities necessary to facilitate proper recovery, treatment or disposal.

Offsite disposal of HW will be held to the minimum compliance levels to meet regulatory requirements.



All shipments to TSD facilities will be by truck transportation.

The number of projected lead recycling shipments per year is two (2).

The number of projected labpack shipments per year is six (6).

The number of projected of compressed gas cylinder waste shipments per year is one (1).

Total number of HW shipments is dependent on the unique characteristics of the waste being disposed.

Overall storage capacity is greatly driven by NFPA storage requirements.

TRU Waste Assumptions

Volume XIII of the Site RCRA Part B Permit Application (TRU Pad 3-6, 14-19 and 26) was revised/updated in FY2016.

Legacy TRU waste disposition will resume in FY2017 and will continue through the baseline period.

No remediation or repackaging will be required for newly generated TRU wastes.

Plutonium disposition using Criticality Control Overpacks (CCOs)/Pipe Overpack Containers (POCs) will be initiated in FY2017 and continue through the baseline period.

Government furnished services and equipment will continue to include:

– “Acceptable Knowledge” development resources

– Certification resources (equipment and human resources)

– Shipping resources

WIPP remains operational.

Sanitary Waste Assumptions

Disposal of sanitary waste will continue at the Three Rivers Landfill and the disposal of debris waste will continue at the onsite C&D Landfill.

Routine sanitary waste recycle services will continue at the North Augusta, SC Material Recovery Facility.

Where economically practical, concrete, asphalt and wood will be recycled at the C&D Landfill.