Annual Update for the Nevada Test Site Site Treatment Plan - April 1997

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Nevada Test Site Site Treatment Plan U.S. Department of Energy Nevada Operations Office

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Table of Contents 1 1 Purpose and Scope of the Draft Annual Update for the Nevada Test Site—Site 1.2 Framework for Developing the Annual Update............................................................1 2.1.1 PCB Soil STP Interim Activity Dates and Milestones ............................2 2.1.2 PCB Soil FFC Act Consent Order Deadlines ............................................. 3 2.2.1 Lead-Contaminated Soil STP Interim Activity Dates and Milestones . 4 2.3 Bulk Lead Waste .................................................................................................................. 4 2.3 1 Bulk Lead Waste STP Interim Activity Dates and Milestones ...............5 2.3.1.1 STP Schedule for Processing Backlogged 2.3.1.2 STP Schedule for Processing Backlogged 2.3.2 Bulk Lead Waste FFCAct Consent Order Deadlines .............................. 6 2.3 2.1 FFCAct Consent Order Schedule for Processing Backlogged Waste: Spent Batteries..............6 2.12.2 FFCAct Consent Order Schedule for Processing Backlogged Waste: T2 Lead Cylinders ... 6 2.4 Area 12 Solvent Sludge .................................................................•..................................6 2.4.1 Solvent Sludge STP Interim Activity Dates and Milestones....................7 2.4.2 Solvent Sludge FFCAct Consent Order Deadlines................................... 7 2.6.1 TTF Solvent STP Interim Activity Dates and Milestones........................ 8 2.6.2 TTF Solvent FFCAct Consent Order Deadlines........................ 8 2.7.1 Cotter Concentrate (Population A) STP Interim Activity Dates and 2.8.1 Cotter Concentrate (Population B) STP Interim Activity Dates and 2.9 Mixed Transuranic Waste............................................................................................... ,12 2.9.1 Mixed Transuranic Waste STP Interim Activity Dates and 2.9.2 Mixed Transuranic Waste FFCAct Consent Order Deadlines............13

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1.1 Purpose and Scope of the Annual Update for the Nevada Test Site-Site Treatment The U.S. Department of Energy, Nevada Operations Office (DOE/NV) is required by the Federal Facility Compliance Act (FFCAct) Consent Order negotiated between the Nevada Division of Environmental Protection (NDEP) and DOE/NV to submit a draft annual update of the Nevada Test Site—Site Treatment Plan (STP) to the NDEP for review and comment by January 15 of each year. DOE/NV is then required to finalize the draft update by April 30 of each year. In accordance with the FFCAct Consent Order, dated March 6, 1996, each Annual Update will bring the STP current to the end of the previous federal fiscal year. The Annual Update will provide a summary of the current status of DOE’s progress in implementing the STP as required by the Consent Order, including proposed revisions, technology development, funding and other concerns that may affect the implementation of the STP. The following are waste streams at the Nevada Test Site (NTS) that are discussed in the Annual c. Bulk Lead Waste i. Mixed Transuranic Waste The following are waste streams that were originally believed to be mixed waste streams requiring treatment, but are no longer mixed wastes. They were reported in the Background Volume of the STP for future reference. They are not included in the Annual Update. b. Analytical Services Department Solvent c. Basic Environmental Compliance and Monitoring Program (BECAMP) Scintillation Vials Information reported in the Annual Update for the mixed transuranic waste meets the annual reporting requirement set forth in the Settlement Agreement between the NDEP and DOE/NV. 1.2 Framework for Developing the Annual Update The framework for developing the Annual Update generally follows the framework of the STP. Information reported in the STP is divided into two volumes. The Background Volume provides a detailed discussion of the preferred waste treatment option or options, identifies the waste stream the option addresses, and gives explanatory information for the Plan Volume. The Plan

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Volume of the STP identifies the treatment methods selected and the schedules that have been negotiated for compliance with the FFCAct. In accordance with the FFCAct Consent Order, the Annual Update to the Background Volume will quantify_the amount of each covered waste remaining in storage at the NTS, and the volume treated, shipped off site or otherwise reduced in quantity during the previous fiscal year. The Annual Update to the Background Volume will also include any potential alternative commercial treatment, and off-site DOE treatment capacity or technology development being considered for potential plan revision. The Annual Update to the Plan Volume requires a progress report from the end of the previous year, describing treatment progress and treatment technology development for each treatment facility and activity scheduled in the Plan Volume of the STP. The status of the interim activity dates and milestones listed in the Plan Volume for each waste stream, along with the deadlines listed in the FFCAct Consent Order, have been updated. For clarity, the information required in both the Background and Plan Volumes to the Annual Update has been combined. This section includes the current inventory of mixed waste covered under the STP and the FFCAct Consent Order and stored at the NTS. A 30-gallon container holding less than 0.05 cubic meters of PCB Soil is currently in storage on the Transuranic Waste Storage Pad (TRU Pad). Approximately three liters of waste, which constituted all of the soil portion of the waste stream, was shipped to the DOE Oak Ridge Toxic Substance Control Act (TSCA) Incinerator facility for analysis on November 19, 1996. The three-liter sample was analyzed and managed by the DOE Oak Ridge approved-laboratory, eliminating this portion of the waste stream. The remaining portion of the PCB Soil waste stream consists of personal protective equipment and rags, which will be treated at the DOE Oak Ridge TSCA Incinerator. Treatment of this portion of the PCB Soil at the TSCA Incinerator is on schedule. DOE Oak Ridge has reviewed the waste application and provided comments. The application is currently being revised and will be resubmitted to DOE Oak Ridge for their approval prior to the June 30, 1997 deadline to receive written approval of acceptance. 2.1.1 PCB Soil STP Interim Activity Dates and Milestones Complete All Additional Waste Characterization December 31. 1996 Required by Receiving Site's WAC (milestone) COMPLETED: November 19, 1996 Receive Written Approval of Acceptance from June 30. 1997

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If Waste Rejected. Initiate Revision Process Initiate Preparation of Waste for Shipment, if Approved In accordance with receiving site Complete Shipment of Waste (interim activity date) Dependent upon outcome of negotiations with appropriate parties 2.1.2 PCB Soil FFCAct Consent Order Deadlines Complete All Additional Waste Characterization Required by Receiving Site Receive Written Approval of Acceptance from If Waste Rejected. Initiate Revision Process July 31, 1997 Initiate Waste Shipment Deadline shall be in accordance with receiving site approved schedule The lead-contaminated soil waste stream consists of soil contaminated with lead, radionuclides and barium, and soil contaminated with just lead and radionuclides. The soil contaminated with lead; radionuclides and barium consists of one 55-gallon drum of waste from the Area 27 Explosive Ordnance Disposal (EOD) Unit, which is currently stored on the TRU Pad. The soil contaminated with lead and radionuclides consists of approximately 31.6 cubic meters of the lead-contaminated soil reported in the STP that were combined with the lead-contaminated soil from the Federal Facility Agreement Consent Order corrective action units (CAU) 08-26-02 and 25-26-15 now covered under the Mutual Consent Agreement. The lead and radionuclidecontaminated waste stream was stored on the TRU Pad in 17 containers. In an attempt to remove the lead shot from the soil, the waste stream was screened for several weeks. The screening process was completed on August 22, 1996, and the waste was repackaged into fifteen B-25 boxes. A Toxicity Characteristic Leaching Procedure (TCLP) analysis was performed on the waste following screening to determine if it still exhibited the characteristic of toxicity due to the presence of lead. Of the fifteen B-25 boxes of waste, eight boxes passed TCLP for lead and are merely low-level waste In a letter to DOE/NV dated March 18, 1997, NDEP concurred with DOE/NV* s assertion that these eight boxes were no longer mixed waste and agreed to delete this portion of the waste stream from the FFCAct Consent Order. Seven of the fifteen boxes have been verified as mixed waste with lead above the TCLP limits established by the Resource Conservation and Recovery Act (RCRA). Treatment at Envirocare had been the preferred option for treatment of this waste stream. However, the seven boxes of mixed waste contain lead shot, lead.fines, and soil, which do not meet the waste acceptance

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criteria for macroencapsulation at Envirocare. In addition, Envirocare’s proposed stabilization facility is not yet available. Although the waste volume has been reduced, a viable waste treatment method is currently not available for the remaining mixed waste. Stabilization at a RCRA-permitted off-site facility is currently being pursued for the soil contaminated with lead and radionuclides, and the Area 27 EOD Unit lead soil. A revision to the STP will be initiated in June 1997 if treatment has not been determined at that time. 2.2.1 Lead-Contaminated Soil STP Interim Activity Dates and Milestones Complete Soil Screening and Initiate Sampling of Screened Soil (milestone) Complete All Additional Waste Characterization Required by Envirocare WAC Receive Written Approval of Acceptance from Envirocare (interim activity date) CANCELED: Pursuing Alternate Trcaunent CANCELED: Pursuing Alternate Treatment Submit Schedule for Processing Backlogged Waste or July 31,1997 Initiate Revision Process Detailed in NTS FFCAct Complete Shipment of Waste to Receiving Site (milestone) September 30. 1997 2.2.2 Lead-Contaminated Soil FFCAct Consent Order Deadlines Complete Soil Screening and Initiate Sampling of Screened Soil Submit Schedule for Processing Backlogged Waste or Initiate Revision Process Complete Shipment of Waste to Receiving Site September 30, 1997 2.3 Bulk Lead Waste The bulk lead waste stream has been divided into three groups. Approximately twenty-nine percent of the bulk lead waste stream, including the DNA Lead Cylinders, the Junior Hot Cell Mesh, the Area 25 Test Cell C, and a portion of T2 Lead, was shipped off site to Envirocare on September 27, 1996, for treatment and disposal.1 Fifty-three percent of the bulk lead waste includes the T2 lead cylinders which exceeded Envirocare’s size constraint for macro encapsulation. Reclamation of the T2 lead cylinders through the Scientific Ecology Group (SEG) in Tennessee is currently being pursued. The remaining 18 percent of the bulk lead waste stream 'Envirocare will formally notify DOE/NV when trcaunent and disposal have been completed.

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consisted of spent batteries. The spent batteries underwent sampling and analysis in November 1996 and were shipped to Envirocare on April 2, 1997, for treatment and disposal. Of the bulk lead waste reported in the STP, only the T2 lead cylinders remain in storage at the NTS. DOE contends the T2 lead cylinders are recyclable scrap metal and requested their redesignation as such from NDEP. NDEP concurred with DOE’s request to redesignate the FFCAct T2 lead cylinders in a letter from NDEP to DOE/NV dated April 10, 1997 As a condition of NDEP’s concurrence, DOE/NV will continue to manage the T2 bulk lead waste as a mixed waste until SEG initiates shipping procedures. The schedules for backlogged bulk lead waste, namely spent batteries and T2 lead cylinders, have been included in accordance with the STP and the FFCAct Consent Order. Of the schedules presented, all STP milestones and FFCAct Consent Order deadlines have been completed except for those associated with the T2 lead cylinders. 2.3.1 Bulk Lead Waste STP Interim Activity Dates and Milestones Complete All Additional Waste Characterization Required by Receiving Facility (milestone) Initiate Preparation of Waste for Shipment. If Approved qi Initiate Revision Process Detailed in the FFCAct CO Submit Schedule of Processing Backlogged Waste Based Upon Completion of Demonstration Project Complete Shipment of Waste (interim activity date) COMPLETED: Waste Shipped 2.3.1.1 STP Schedule for Processing Backlogged Waste: Spent Batteries Initiate Contract with Permitted Mixed Waste Treatment Facility to Treat Spent Batteries (milestone) Initiate Preparation of Spent Battery Shipment to Receiving Site After Formalizing Contract with Designated Waste Treatment Facility (milestone) Within 60 Days of Successful Negotiation Complete Spent Battery Shipment (milestone) Within 30 Days of Initiating Preparation of 2Refer to letter from DOE/NV to NDEP dated November 6. 1996, “FFCAct Site Treatment Plan Bulk Lead Status and Clarification.”

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2.3.1.2 STP Schedule for Processing Backlogged Waste: T2 Lead Cylinders Initiate Contract with Designated Decontamination Within 60 Days of NDEP Concurrence that Facility for T2 Lead Reclamation (milestone) Lead Cylinders can be Categorized as Recyclable Scrap Metal NDEP Concurrence: April 10, 1997 2.3.2 Bulk Lead Waste FFCAct Consent Order Deadlines Complete All Additional Waste Characterization Required by Receiving Facility Initiate Preparation of Waste Shipment or Initiate COMPLETED: Waste Shipped Submit Schedule for Processing Backlogged Waste December 31.1996 Based Upon Completion of Demonstration COMPLETED: December 31. 1996 2.3.2.1 FFCAct Consent Order Schedule for Processing Backlogged Waste: Spent Initiate Contract with Permitted Mixed Waste Treatment Apnl 1. 1997 Facility to Treat Spent Batteries Initiate Preparation of Spent Battery Shipment to Receiving Site After Formalizing Contract with Designated Waste Treatment Facility Complete Spent Battery Shipment Within 60 Days of Successful Negotiation Within 30 Days of Initiating Preparation of 2.3.2.2 FFCAct Consent Order Schedule for Processing Backlogged Waste: T2 Lead ' Initiate Contract with Designated Decontamination Facility for T2 Lead Reclamation Within 60 Days of NDEP Concurrence that Lead Cylinders can be Catcgonzcd as Recyclable Scrap Metal NDEP Concurrence: April 10, 1997 2.4 Area 12 Solvent Sludge DOE has reviewed the radioactivity data for the solvent sludge waste stream against the NTS Performance Objective for Certification (POC) of Nonradioactive Hazardous Waste and has confirmed the radioactivity exhibited by the solvent sludge falls below the POC limits. As reported in a letter to NDEP from DOE/NV dated November 29, 1996, DOE/NV contends the Area 12 solvent sludge is hazardous waste without a radioactive component and, therefore, not

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mixed waste. The NDEP concurred with DOE/NV’s assertion in their written reply to DOE/NV dated January 13, 1997. In accordance with Part XI.3 of the FFCAct CO, the solvent sludge was moved to the Hazardous Waste Storage Pad on January 30, 1997, and will be shipped off site for disposal with the next hazardous waste shipment. The waste stream also consisted of three 18x3 inch and one metal 4x6 inch filters. The analytical results for this waste have been reviewed and the waste has been determined to be hazardous waste and not mixed. While awaiting NDEP’s formal concurrence and subsequent deletion of the filters from the FFCAct Consent Order. DOE/NV will continue to manage the solvent sludge filters on the TRU Pad as mixed waste in accordance with the following schedules. 2.4.1 Solvent Sludge STP Interim Activity Dates and Milestones Complete All Additional Waste Characterization Receive Written Approval of Acceptance from If Waste Rejected. Initiate Revision Process Initiate Preparation of Waste for Shipment, if Approved Complete Shipment of Waste (interim activity date) In accordance with receiving site Dependent upon outcome of negotiations with 2.4.2 Solvent Sludge FFCAct Consent Order Deadlines Complete All Additional Waste Charactcnzation Required by Receiving Site Receive Written Approval of Acceptance from If Waste Rejected. Initiate Revision Process Initiate Waste Shipment Deadline shall be in accordance with receiving site approved schedule The shipping cask was disposed of on site in the Area 5 Radioactive Waste Management Site, Pit 3, on September 11, 1996, as documented in a letter from DOE/NV to the NDEP dated October 18, 1996. The NDEP concurred with DOE’s request to delete this waste stream from the Plan Volume of the STP and the FFCAct Consent Order in a letter from NDEP to DOE dated

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September 13, 1996. …