HWMA Storage & Treatment Permit (TPD1212011)

HWMA/RCRA PART B PERMIT FOR THE

IDAHO NATIONAL LABORATORY

BOOK 3

Volume 18 –Radioactive Waste Management Complex

ATTACHMENT 1

SUBSURFACE DISPOSAL AREA (SDA) WMF-698

WMF-1617

Section B – Facility Description And

Section D – Process Description

Revision Date: October 18, 2012

B. FACILITY DESCRIPTION

B-1   Facility Description [IDAPA 58.01.05.012; 40 CFR 270.14(b)(1)]

The Idaho National Laboratory (INL) is owned by the U.S. Department of Energy (DOE). The DOE facilities located at the INL are operated by multiple contractors designated by the DOE. Exhibit B-1 is a map of the INL that identifies the locations of the major facility areas.

The Radioactive Waste Management Complex (RWMC) is a restricted area of 166 acres located in the southwestern corner of the INL. Exhibit B-1 of this Attachment shows the location of the RWMC at the INL. The RWMC provides facilities for the management of radioactive only wastes, mixed wastes (MW), and Comprehensive Environmental Response Compensation and Liability Act (CERCLA) waste. Radioactive only wastes contain radioactive materials as defined by the Atomic Energy Act (AEA). Radioactive only wastes are not regulated as hazardous or mixed waste by the Idaho Hazardous Waste Management Act (HWMA) or by the Resource Conservation and Recovery Act (RCRA). MW is waste that is radioactive as defined by the AEA and hazardous as defined by IDAPA 58.01.05.005 (40 CFR 261). MW stored in the RWMC permitted units is not regulated under the HWMA/RCRA, Subpart CC – Air Emission Standards for Tanks, Surface Impoundments, and Containers, as MW is exempted in 40 CFR 264.1080(b)(6) because it is stored in compliance with all applicable regulations under the authority of the Atomic Energy Act and the Nuclear Waste Policy Act. Some wastes stored at the RWMC are also regulated by the Toxic Substances Control Act (TSCA). CERCLA wastes may be handled in the units regulated under this permit but are not subject to the conditions of the permit, and will be segregated from RCRA waste. Disposition of CERCLA waste will be controlled through the CERCLA process.

EXHIBIT B-1. Map of the INL Showing Major Facility Areas.

The RWMC comprises four major areas: the Administrative Area, the Operations Area, the Subsurface Disposal Area (SDA), and the Transuranic Storage Area (TSA). These areas are described below and illustrated in Exhibit B-2 of this Attachment. This Permit addresses waste management units located at the SDA. Multiple DOE contractors operate within the RWMC area.

The Administrative Area is located in the northeast section of the RWMC and consists of buildings and structures supporting administrative operations. These include office space and change rooms for workers and the security gate. It occupies approximately 3 acres of the RWMC and contains no waste management units.

The Operations Area is located in the northeast section of the RWMC adjacent to the Administrative Area and consists of buildings and structures supporting operations. These include office space, the fire and domestic water supply, and equipment storage and maintenance areas. It occupies approximately 8 acres of the RWMC, and contains a waste storage area within and adjacent to WMF-602 that is under operational control of the Idaho Treatment Group (ITG). The Operations Area also contains Satellite Accumulation Areas (SAAs) and less than 90 day storage areas (TAAs) which are under operational control of CH2M WG Idaho, LLC. (CWI).

The TSA is a fenced, 58-acre storage area located in the southeastern section of the RWMC.  This area is presently operated by the ITG, and is the location of the Advanced Mixed Waste Treatment Project (AMWTP). The major functions of the TSA are storage, examination, certification, transuranic package transporter (TRUPACT) assembly, and TRUPACT cask loading of waste which is destined for shipment to the Waste Isolation Pilot Plant (WIPP) or for treatment at an on- or off-Site facility.

The SDA is a fenced, 97-acre, shallow-land subsurface disposal site located in the western section of the RWMC. It was dedicated to the disposal of solid, low-level beta- gamma radioactive waste. The SDA contains pits, trenches, soil vaults, and an asphalt pad (Pad A). TRU waste disposal was discontinued in 1970. Pad A ceased operation in 1978. The SDA is identified as a solid waste management unit (SWMU) under the FFA/CO for the INL.

The primary work being conducted at the SDA consists of buried waste retrieval. This effort known as the Accelerated Retrieval Project (ARP), includes retrieval, identification, repackaging, and disposition of targeted transuranic waste. The waste targeted for retrieval includes plutonium-contaminated filters, graphite and process sludge, oxidized (depleted) uranium, and solvent wastes. The material originated at the Rocky Flats Plant near Denver, Colorado, during nuclear weapons production in the 1950s and 1960s.

In addition, the SDA is being used to repackage drummed waste from AMWTP for absorbtion of liquids, removal/treatment of prohibited items, and visual verification to meet acceptance criteria at the WIPP.

HWMA/RCRA regulated units at the SDA consist of Building WMF-698 which is regulated under HWMA/RCRA as a container storage unit, and Building WMF-1617 which is regulated under HWMA/RCRA for container storage and miscellaneous treatment. In addition, three outdoor trailer container storage areas are located near the treatment units for storage of waste pending return to AMWTP.

The physical conditions around these buildings are typical for the INL Site, approximately 5,000 ft above mean sea level, as shown on the topographical map, Exhibit B-3. The area is relatively flat and receives little rainfall. However, poor drainage patterns can produce localized flooding that consists of shallow puddles that form near buildings during periods of rapid snowmelt or heavy rainfall. Due to the lack of rainfall and the poor quality of the surface soils, the site has little agricultural value. Wind patterns are generally in a northeast/southwest axis, with some seasonal variability.

Exhibit B-4 shows the surface water drainage at the RWMC. There is no sanitary waste system piping within the SDA. Comfort stations are provided for personnel working in that area. There are no recreational areas present on or adjacent to the RWMC.

EXHIBIT B-2. RWMC Area Map

EXHIBIT B-3. Topographical map of the RWMC

EXHIBIT B-4. RWMC Surface Water Drainage

RWMC Waste Handling Operations

Waste is received at the RWMC SDA from the AMWTP. Shipment of the waste to the RWMC SDA is the responsibility of the AMWTP. All waste must be packaged by the generator according to INL waste packaging requirements. Shipments must be approved by the RWMC prior to shipment to the RWMC SDA. All waste received at the RWMC must meet the applicable waste acceptance criteria contained in Attachment 1, Section D-1a(2).

Waste is received from the AMWTP and transferred to appropriate storage at either WMF-698 or WMF-1617. WMF-1617 provides areas for sorting and segregating waste, repackaging waste, and performing absorbent addition. Trailer loading and unloading operations will be completed at both WMF-698 and WMF-1617. Containers will remain on the transport trailers for no more than 24 hours at any given time during unloading operations.

Because the HWMA/RCRA-regulated wastes managed at the SDA are MW, references to radiological and radiochemical data are made throughout this Permit. Information on radiological and radiochemical characteristics is provided for informational purposes only, as HWMA/RCRA applies only to the chemical constituents of the MW. TSCA-regulated wastes and CERCLA waste stored at the TSA are not addressed in this Permit as they are not subject to HWMA/RCRA regulation.

WMF-698

Storage Enclosure Building WMF-698 is an existing building that was established to store CERCLA generated waste from the ongoing Accelerated Retrieval Project operations. WMF-698 is a tension-membrane building, measuring 130 ft x 160 ft with a 20-ft-minimum interior clearance at the eaves. The building is located at the RWMC SDA, north of Pit 4 between Pad A and Pit 3. Exhibit B-5 presents a cutaway view of Building WMF-698.

WMF-698 is constructed of a prefabricated steel frame covered with an outer fabric membrane. The fabric membrane meets NFPA 701 standards for fire resistance. The membrane meets the flame-resistant requirements of the IBC. The structural frame is designed to support seismic, snow, and wind loads in accordance with the applicable loading requirements. An anchoring system is provided to resist the horizontal or uplift forces imposed by seismic and wind loads. The perimeter foundation frame sits on existing grade, leveled to obtain a weather seal. The interior floor consists of a concrete slab. Secondary containment within WMF-698 is provided by drum storage secondary containment pans. The 4’-2” by 8’-2” by 7” pan is constructed of 1/8” carbon steel, all corners and seams are seal welded. A support grate to elevate the drums is also included. The capacity of the drum storage secondary containment pans is 149 gallons, which provides adequate capacity for the storage of sixteen drums (2-wide, 2- high, 4-long. A metal warming hut is located inside the east entrance of WMF-698. The hut contains an electric heater that provides personnel working in the area a location to warm up. Mechanical and electrical equipment supporting WMF-698 may be housed external to the enclosure. Drawings for WMF-698 are located in Book 3, Appendix I of this Permit.

Ventilation for WMF-698 is provided by a draw-through system to prevent the accumulation of volatile organic compounds (VOCs). Dust filters are installed at various locations in the walls to filter the air drawn into the enclosure. The exhaust is not filtered.

Traditional fixed lighting is installed to provide adequate illumination for operations such as waste container transport, storage, and inspection. Emergency lighting is provided as required by NFPA 101. The lighting is fastened to the metal framework or located on stands. The lighting is supplied with flexible cable. A limited number of receptacles are positioned within WMF-698 to support operations and maintenance activities.

Electrical power is supplied from a pad-mounted transformer at the northeast corner of the SDA. This transformer supports lighting, ventilation, and a limited number of receptacles that are positioned within the enclosure to support operations and maintenance. Lightning protection meets the applicable provisions of NFPA 780.

EXHIBIT B-5. Building WMF-698 Storage Enclosure Plan

WMF-1617

Building WMF-1617 is an existing building that was established to excavate and repackage CERCLA generated waste as part of the Accelerated Retrieval Project operations. WMF-1617 is a tension-membrane building (referred to as a Retrieval Enclosure) that covers the exhumation footprint in Pit 9. This enclosure measures approximately 380 ft x 165 ft and 53 ft in height at the tallest point. WMF-1617 housed the excavation, waste retrieval, waste packaging, sampling, decontamination, vehicle service, and personnel ingress/egress for the remediation of Pit 9 under CERCLA. Exhibits B-6 and B-7 provide schematics of WMF-1617. WMF-1617 has an attached air lock used for drum packaging, a service-bay to support equipment maintenance, and radiological control support areas.

The Retrieval Enclosure provides weather protection for year-round operations. The physical boundary of the fabric structure affords a barrier to the spread of radioactive contamination. The Retrieval Enclosures have sufficient space and interior height to house excavator operations and waste container movements.

The Retrieval Enclosure includes the following systems: structure frame; membrane covering (with inner and outer fabric enclosing an insulating layer); exhaust ventilation (including area-based emissions monitoring, high-efficiency particulate air (HEPA) filters, and supporting electrical systems); propane heating system (and associated piping and equipment); and a fire detection and alarm system.

The fabric membrane is insulated and meets National Fire Protection Association (NFPA) 701 standards for fire resistance. The membrane material for the Retrieval Enclosure structure is a polyvinyl chloride (PVC)-impregnated textile. The PVC is formulated with flame-resistant compounds. The fabric material meets applicable International Building Code (IBC) flame-spread performance criteria for a limited combustible material.

WMF-1617 has steel trusses that attach to a cast-in place foundation and utilizes piles driven to bedrock to stabilize the foundation. WMF-1617 is designed to withstand seismic, snow, and wind loads in accordance with the applicable requirements. Drawings for WMF-1617 are located in Book 3, Appendix I of this Permit.

HEPA-filtered exhaust ventilation is provided for ARP V and the negative pressure induces ventilation through the attached Airlock #5. The exhaust ducts and fans are located to draw air from the least contaminated areas into the most potentially contaminated areas. Fixed filter air samplers are located around the perimeter of the building and continuous air monitors (CAMs) with alarms are also provided for each discharge path (local filter/fan exhaust) to monitor for airborne radioactivity. Radiological control technicians (RCTs) routinely count the perimeter sampler filters for radioactive contamination. If airborne radiation above normal background levels is detected, the results will be evaluated and remedial actions are taken as appropriate to minimize the spread of contamination and to ensure operational control, worker protection, and environmental protection.

The Retrieval Enclosure (Retrieval Area and air lock) is provided with direct-fired, draw- through, propane fired gas furnaces. To the extent practical, the heating systems for the retrieval area is designed to maintain 32°F at an ambient temperature of -20°F to limit wear and tear on equipment caused by extreme cold weather, and are not intended for human comfort. The installation of the heating systems is in accordance with the applicable NFPA requlations. These systems are operated independently of the HEPA-filtered exhaust, except for an interlock that shuts the inlet dampers when facility exhaust flow is interrupted (back flow through the outdoor intake is prevented when the system is shut down). Depending on the operating configuration of the system or possible lower ambient temperatures, interior temperatures below freezing can occur. Such conditions are monitored, and actions are taken as needed (such as allowing waste to warm in the airlock area prior to visual inspection for free liquids).

ARP V fire protection is provided through an underground fire water distribution system that was installed within the SDA. The system was designed, installed, and tested in accordance with the National Fire Protection Association (NFPA) 20, 22, and 24.  The system was designed to supply fire water at a minimum of 1,500 gpm at 20 psi.  There are adequate fire hydrants located at ARP V.

ARP V has fire alarm and occupant notification systems to notify occupants and the INL Fire Department in case of emergency. There are traditional smoke and heat detectors installed throughout the airlock. Linear heat sensor cable is installed in the DPS to actuate the dry chemical suppression systems. A listed automatic video fire/smoke detection system is provided in the Retrieval Enclosure. The system provides primary detection during non-operational periods.

Operations personnel have the primary responsibility for fire detection in the Retrieval Enclosure during operational periods.  The video fire/smoke detection system is taken out of service during normal operations as necessary to prevent spurious alarms and placed back in service on the backshift. Other accepted means of fire detection, should the video fire/smoke detection system be impaired, include monitoring of fire watch cameras in the control room, at the INL Fire Alarm Center, and/or a manned two-hour fire watch.

ARP V has no fixed building fire suppression systems. There are automatic dry-chemical fire suppression systems installed within each Drum Packaging Station and in the mobile equipment to include the excavators, telehandlers, and front end loaders.

There are traditional portable fire extinguishers located throughout ARP V as shown on

Exhibit G-2 in Attachement 7.

All fire protection systems and equipment are inspected, tested, and maintained in accordance with NFPA codes/standards and the inspection, testing, and maintenance equivalency as approved by the Department of Energy Idaho Falls Field Office.

The Airlock #5 structure is attached to the ARP V Retrieval Area. The airlock is separated from the Retrieval Area and provides a buffer area for workers to package retrieved waste, perform decontamination activities, service vehicles, and provide for personal protective equipment (PPE) change-out. The air lock is an insulated, tensioned-membrane, fabric structure. The air lock meets the same natural phenomena requirements as the main Retrieval Area. The fabric membranes are attached to a steel truss structure which is attached to a concrete slab and foundation. The interior rooms of the air lock are constructed independently of the tensioned- membrane structure. Interior wall and ceiling surfaces are lined with galvanized metal, except in contamination areas where stainless steel is used. The air lock is equipped with supplementary air heating, ventilating, and air conditioning (HVAC) to supply conditioned air for human comfort. Ventilation is drawn from the occupied, uncontaminated area of the air locks, through contaminated areas, into the Retrieval Area, and out through HEPA filters in the Retrieval Area by exhaust fans. This ventilation flow path is designed to minimize the spread of contamination. Ventilation flow that is adequate for contamination control is maintained in occupied areas during facility operations.

The air lock has a partitioned service bay used for servicing the equipment and a contamination reduction corridor to allow vehicle operators to enter and exit their vehicles in a controlled, low-contamination area. These support structures are included within the descriptive title “air locks” and are considered to be part of the Retrieval Enclosure, but not part of the Retrieval Area. Pass-through boxes are installed in the walls for transferring contamination smears and small equipment and tools between the air locks and the clean area. Overhead equipment doors allow equipment access into the air lock from the Retrieval Area and into the air lock from outside. Dust suppressant storage and fill, diesel fueling, water, electrical cords, breathing-air manifolds, and breathing-air fill systems are installed to support operations. The air lock also has an operation corridor that houses support equipment (tanks, pumps, and other equipment).

Dust suppression liquid is applied on the soil travel paths within the WMF-1617 facility to minimize airborne dust/contamination from previous CERCLA operations. If not controlled, the vehicle traffic creates significant dust and can affect the facility ventilation system and worker safety from airborne contamination. Commercially-available, non-hazardous dust suppression liquid (e.g., water, WetJet, Durasoil) is applied on an as-needed basis. Application of dust suppression liquid may result in minor puddling of the liquid which is allowed to absorb into surface soils.

Room 105 Drum Packaging in WMF-1617

The WMF-1617 airlock contains a drum packaging room (Room 105 which is entered through Room 106 Utility Area), with four drum packaging stations (DPSs) that are used to reduce contamination exposure during drum packaging, weighing, and staging activities. Double doors provide access to drum packaging rooms.

Room 106 Utility Area in WMF-1617

WMF-1617, Room 106 (Utility Area), (reference drawing 761194 – See Book 3, Appendix I of this Permit) will be used to store drums that have been processed out of the drum packaging stations before loading on a trailer for transfer back to the WMF-698 storage building or return to AMWTP. The Utility Area is located in the front (west) portion of the WMF-1617 airlock and encompasses approximately 3,200 square ft. The Utility Area is accessed by a 14 ft X 14 ft metal door, a 16 ft X 16 ft metal door, and two personnel doors to provide for equipment and personnel egress.  The area has a reinforced concrete floor.  Drums would be removed from the DPS area using hand-operated drum handling equipment and removed from the Utility Area using a forklift with a drum handling attachment.

The airlock will be used to support interim storage of drums from the DPSs until sufficient quantity of drums is accumulated to support shipment to AMWTP or back to WMF- 698. Drums processed out of a DPS have had visual examination performed to verify removal of free liquids; consequently, secondary containment will not generally be required. The area will also be used to receive drums directly from AMWTP (i.e., if storage in WMF-698 does not occur). In this case, the drums would require storage on drum storage secondarycontainment pans for secondary containment before entry into the equipment airlock and processing in the retrieval area.

Trailer Storage Areas

Storage of containers that have completed treatment in WMF-1617 and are ready for transfer back to AMWTP, may be stored on trailers located next to the treatment units. This storage will be relatively short-term, as the drums will remain in these locations only until a full trailer of drums is loaded for return to AMWTP. Since these drums have been through visual examination following the treatment process, there is no concern with liquids or prohibited items.

Storage Area for Secondary Wastes

Secondary waste (e.g., drum carcasses/liners, PPE, plastic sheeting, filters, etc.) may be stored in WMF-698, after packaging, and prior to transfer to AMWTP or to an off-site TSDF for disposal. In addition, temporary accumulation areas (i.e., less than 90 day storage areas) may be established for storage of secondary waste streams.

Storage of Prohibited Items

WIPP prohibited items (e.g., liquids, etc.) will normally be treated on the sorting table as part of the repackaging process. If removal from the waste is required, prohibited items may be staged within the retrieval area in waste trays pending packaging into a new container via the DPS.  Once packaged through a DPS, prohibited items will be stored in permitted storage areas, separated by distance or barrier as needed depending upon waste characteristics, before being returned to AMWTP. The discovery of prohibited items that must be removed from the waste stream will be reported to the DEQ, and will be included in the semiannual non-compliance report as required by Permit Condition I.U.

Decontamination of Equipment

It is a recognized situation that within the ARP V waste exhumation facility, contaminated soils are present from previous CERCLA operations. Periodic equipment decontamination may be performed within the retrieval area to achieve acceptable radiological

conditions on the equipment for required maintenance. Any portion of the equipment (e.g., excavator, telehandler forklift, loader) that is contaminated with CERCLA materials, such as contaminated soils, may require that the material be removed through spray washing, brushing, or other means, and the associated wastes placed within the CERCLA contaminated area. Equipment surfaces may also come in contact with RCRA waste (e.g., excavator bucket or thumb) and require decontamination. Waste material will be removed through spray washing, brushing, or other means. The waste material will be collected in the excavator secondary containment bucket, or other secondary containment pan described in this permit. The excavator secondary containment bucket is a 4’-6” by 3’ by 2’-6” carbon steel container with a crossbar for the excavator to lift. Waste from decontamination of RCRA contaminated equipment will be contained within the bucket or secondary containment pan, and then packaged out of the facility as RCRA waste, or included in the waste stream destined for WIPP.

DPSs provide a means for workers to safely package waste materials out of the Retrieval Area and into clean 55-gal drums. The DPSs provide contamination control and serve as radiological workstations.

A structural steel framework anchored to the air lock floor supports each packaging station. The panels, penetrations, interfaces, and ports are sealed and secured to the frame or panels. Each station has multiple glove ports and scratch-resistant Lexan windows. Slides are installed under the trolley rails to funnel materials (predominantly soil) to the side of each DPS entrance to allow mechanical removal of the fallen material. Airflow through each station is induced by the Retrieval Enclosure exhaust ventilation system to ensure contaminated air is drawn away from the packaging station worker.

Room 104 Equipment Airlock in WMF-1617

The room 104 Equipment Airlock, located in WMF-1617 (reference drawing 761194 – see Book 3, Appendix I of this Permit) will be used to transfer drums into the radiologically- controlled Retrieval Area (RA) for processing from storage in WMF-698, or unloaded directly from the transport trailer from AMWTP. The equipment airlock is an area that is approximately 20 ft wide X 40 ft in length. The steel-framed airlock is accessed by 16 ft X 16 ft doors on each end to provide for equipment egress and has a reinforced concrete floor. Drums would normally be introduced into the area using a manual drum hauler or a telehandler (forklift) with extending boom and drum handling attachment.

Typically, the airlock will be used as a transfer bay to support same-day transfer of wastes into the RA; however, drums may be stored in the airlock area for a longer period based on operational need or to accommodate unusual circumstances (e.g., loss of commercial power and operational shutdown). Secondary containment within Room 104 is provided by drum storage secondary containment pans. The 4’-2” by 8’-2” by 7” pan is constructed of 1/8” carbon steel, all corners and seams are seal welded. A support grate to elevate the drums is also included. The capacity of the drum storage secondary containment pans is 149 gallons, which provides adequate capacity for the storage of sixteen drums.

EXHIBIT B-6. Schematic of WMF-1617

EXHIBIT B-7. Schematic of Airlock 5 Plan

RWMC Location Information

The RWMC occupies approximately 166 acres in the southwestern corner of the INL. The INL is located along the western edge of the eastern Snake River Plain in southeastern Idaho, approximately between latitudes N 43°28′ to N 44°02′ and longitudes E 112°26′ to E 113°15′. The following sections describe how the RWMC complies with the seismic and floodplain standards under 40 CFR 270, 40 CFR 264.18, IDAPA 58.01.05.012, and IDAPA 58.01.05.008.

Seismic Standard [IDAPA 58.01.05.008 and 58.01.05.012; 40 CFR 264.18(a) and 40

CFR 270.14(b)(11)(i-ii)]

The RWMC is located in Butte County, Idaho. Butte County is not listed in IDAPA 58.01.05.008 (Appendix VI to 40 CFR 264), and, therefore, does not require demonstration of compliance with the seismic standard.

Floodplain Standard [IDAPA 58.01.05.008; 40 CFR 264.18(b); IDAPA 58.01.05.012; 40 CFR 270.14(b)(11)(iii-iv)]

A 2001 flood evaluation study (“100-Year Floodplain and 25-Year Runoff Analyses for the Radioactive Waste Management Complex Area at the Idaho National Engineering and Environmental Laboratory,” T. Mitchell, S. Mitchell, J. Humphrey, D. Kennedy, and T. Funderburg, December 2001), provided in Book 3, Appendix 2 of this Permit, analyzed the extent of a 100-year floodplain. Based on this analysis, there are no mixed waste management areas located within the 100-year floodplain at the RWMC. The requirements of this section are, therefore, not applicable.

Traffic Information [IDAPA 58.01.05.012; 40 CFR 270.14(b)(10)]

U.S. Route 20/26 is the general access route to the RWMC and the SDA. Van Buren Boulevard intersects U.S. 20/26 northeast of the RWMC and is the direct access road leading to the Experimental Breeder Reactor I (EBR-I). Adams Boulevard intersects Van Buren Boulevard just north of EBR-I and is the direct access road leading to the RWMC. Employee-owned vehicles are not allowed to enter the SDA. Personnel travelling in the SDA either walk or are transported by contractor vehicles/equipment, federally owned vehicles, or vendor vehicles.Waste transfers to/from AMWTP and the SDA are completed via the access gates between theTSA and SDA areas.

Traffic control procedures within the SDA area support facility operations, maintenance, and waste transfers. These traffic procedures are implemented using standard highway traffic control and informational signs.  The typical sign types that may be used in the SDA are: Stop signs (at access gates and some road intersections); Clearance signs (where electrical lines pass over the roadway and restrict traffic); Speed Limit signs (various signs on roadways as necessary); Directional signs (various roadways to indicate traffic flow direction); and Informational signs (various roadways to indicate facility locations, loading/unloading areas, etc.). Example locations of stop signs and speed limit signs for the SDA are shown in Exhibit B-8.

EXHIBIT B-8. Example of Traffic Sign Plan/Location

D. PROCESS INFORMATION

This section provides process information for the Radioactive Waste Management Complex (RWMC) Subsurface Disposal Area (SDA) Accelerated Retrieval Project (ARP) waste management units addressed in this permit: container storage (S01) in buildings WMF-698 and WMF-1617 and at the trailer storage areas, and miscellaneous treatment (X99 and X02) –in Building WMF-1617. Miscellaneous treatment will be conducted in three miscellaneous units; the retrieval area, the DPSs, and the drum compactor. includes any/all of the following, opening waste containers, staging waste in the retrieval area associated with waste processing activities, removing waste from the container, segregating/sorting waste, opening/crushing inner containers with liquid content, absorbent addition for liquids, segregation/ treatment of WIPP prohibited items, sizing waste to fit into containers, and subsequently placing the waste into new containers. Sizing/compaction/crushing of drum carcasses and/or liners may also be performed.

Container Storage in WMF-698

WMF-698 will be used for storing waste drums received from the AMWTP. Waste drums may be stored in WMF-698 until being transferred to WMF-1617 for further processing. Once these drums have been processed at WMF-1617, they may either be returned to WMF-698 for interim storage or returned directly to the AMWTP.  WMF-698 is permitted to store up to 1,728 drums (95,040 gallons).  The storage configuration consists of storing the drums in a standard RCRA 2-wide by 2-high configuration. Drums with liquids are stored on drum storage secondary containment pans to provide secondary containment for free liquids. Waste boxes may also be used at WMF-698. Aisle space is provided for inspection personnel and emergency equipment (minimum of 3 feet between drum or box rows, and a 20 foot main aisle to allow removal and inspector egress). The drum configuration is shown in Exhibit B-5. Evaluation of the waste to be received from AMWTP shows no compatibility, reactivity, or ignitability concerns.  Weekly inspections of the storage area within the building, and daily inspections of the loading/unloading areas (when in use), are performed by trained personnel, as required by RCRA. CERCLA waste stored in WMF-698 will be segregated from the RCRA waste, and is managed in accordance with the CERCLA protocols. CERCLA waste is not subject to the RCRA permit requirements.

Container Storage in WMF-1617

WMF-1617 will be used for storing and processing waste drums received from AMWTP. Container storage areas are located within Room 103 Service Bay (2 solid waste boxes and 4 drums, or1,567 gallons), Room 104 Equipment Airlock (128 drums or 7,040 gallon capacity), Room 105 Drum Packaging Stations (4 drums or 220 gallons capacity), and Room 106 Utility Area (384 drums or 21,120 gallon capacity). The standard RCRA storage configuration (2-wide by 2-high) will be used. These areas are shown in Exhibits B-6 and B-7. Drums that may contain liquids (i.e., before repackaging and absorbent addition is completed) will be stored on drum storage secondary containment pans to provide secondary containment. Aisle space is maintained for inspection personnel and emergency equipment. Aisle space is not required in Room 105 as the waste is contained in single drums located beneath each of the drum packaging stations. Inspections are completed via visual or camera inspections or viewing areas through windows. If personnel in PPE are required to enter the RA, inspection of the RCRA areas will be completed by direct visual inspection. The RCRA areas within the Retrieval Area are shown on Exhibit B-6.

Miscellaneous Treatment (X99) and Mechanical Processing Treatment (X02) – in WMF-1617

Processing the waste at WMF-1617 is performed in three miscellaneous treatment units: the Retrieval Area (X99), the DPS stations (X99), and the drum compactor (X99 and X02). The Retrieval Area includes the following activities: opening waste containers, staging waste in the retrieval area associated with waste processing activities, removing waste from the container onto the sorting table, segregating/sorting waste, opening/crushing inner containers with liquid content, absorbent addition for liquids, segregation/treatment of WIPP prohibited items, compacting/crushing empty containers with the excavator, and sizing waste to fit into containers.  The Drum Packaging Stations activities include segregation of prohibited items, addition of absorbents to the waste in the tray as necessary, visual examination by WIPP-qualified visual examiners to document compliance with the WIPP WAC, and placing the waste into new containers. The Drum Compactor is used to compact drum carcasses and/or liners, and includes absorbent addition for any liquids from the compaction process. These activities will allow the repackaged waste to meet the WIPP WAC.

Drum lids/rings will be loosened and removed in either the equipment airlock (Room 104), the service bay (Room 103) or in the ARP V retrieval area, depending upon operational needs. The lids and drum ancillaries (e.g., rings and bolts) will be staged for separate management as secondary waste.

Drums will be transferred from the service bay into the retrieval area to begin processing. Drums staged in the retrieval area will be placed in waste tray secondary containment pans. The locations of the 20’ by 60’ staging areas within the RA are shown in Exhibit B-6. The waste tray secondary containment pans are 9’-0” by 9’-0” by 6”, made of 1/4” carbon steel, and capable of holding 300 gallons of liquid. The pans have a 6” high frame underneath with forklift pockets to allow for movement within the identified staging areas. The waste tray secondary containment pans also have an 8’-0” by 8’-0” by 12’ support grate made of 1/4” carbon steel. The support grate allows for inspection of the secondary containment, and elevates the drums or waste trays to prevent contact with accumulated liquids.  Up to nine waste drums and/or four waste trays may be placed on the waste tray secondary containment pans.

The location of the 30’ by 34’ drum processing area, including the sorting table, is shown in Exhibit B-6. Exhibit D-1 provides a schematic of the sorting table. The sorting table is made of carbon steel, is 9’-2” by 6’-0” with a 1/2” floor and 1/4” sides. The floor and sides are reinforced to allow safe mixing of the waste and absorbent. The sorting table is capable of holding greater than 130 gallons of liquid. The sorting table is located inside a 14’-0” by 18’-0” by 6” secondary containment, constructed of 1/4” carbon steel, which has a capacity of 500 gallons. The secondary containment also has an 8” high frame with lifting lugs and skid plates for movement within the drum processing area if necessary for operational reasons.

Treatment activities conducted on the sorting table include any/all of the following activities. The excavator will take the sludge drum from the waste tray secondary containment pan and empty the contents onto the sorting table through use of the excavator to empty the contents. The contents of up to 3 drums may be processed on the sorting table at one time. The waste is then segregated/sortedto determine the presence of liquids and identify/remove any prohibited items. Any inner containers that may have liquid content are opened/crushed with the excavator thumb or bucket to allow absorbtion of the liquid to take place.  The excavator is used to add absorbent materials (identified in Attachment 2) to the waste on the sorting table. The absorbent material is staged in the RA within a 4’-6” by 3’-0” by 2’-6” bin that has a capacity of 250 gallons. The waste/absorbent is mixed on the sorting table with the excavator bucket to ensure absorption of the liquids. Once mixing is completed, the waste is scraped from the sorting table into the lined ARP waste trays that have been placed in front of the sorting table.. Care will be taken not to overfill the ARP waste tray, as additional absorbent may be added in the DPS. The filled ARP waste tray will then be staged on a waste tray secondary containment pan or transported to the DPS for further processing, depending on DPS availability.

The sorting table activities performed inside the retrieval enclosure are observed through either excavator mounted cameras or cameras located within the facility (see Exhibit D-2 for camera locations) that broadcast a video feed to the operations control room. The operations foreman directs the operation through viewing these camera feeds and communicates by radio with the equipment operator.

WIPP prohibited items will be treated on the sorting table or will be segregated using the excavator at this point and staged in a waste tray located within a waste tray secondary containment pan. If segregation is not practical within the retrieval area via the excavator, segregation of prohibited items will be performed in the DPS. If consistent with the facility safety basis, prohibited items will be packaged into drums through the DPS and transferred to AMWTP for processing and disposition. In some cases, prohibited items may be staged in waste trays in the retrieval area after segregation in the DPS to provide operational flexibility. Prohibited items staged inside the retrieval area in a waste tray, will be separated from other waste by distance and/or barriers, and handled as appropriate.

Drums (and associated liners, if any) that are emptied will undergo visual verification (via video camera feed described above). Operations personnel will view the inside of a waste container that has been emptied on the video feed or direct visual observation (through the windows) and determine through operational experience and training if the container meets the regulatory definition to be considered RCRA empty. The operational process does not allow a person to be inside the facility during waste handling operations due to the potential for radiological contamination, therefore, the video systems are utilized. The RCRA empty determination will be documented on FRM-1367 which is maintained in the Operating Record. Drums that are verified as empty will be staged for separate management as non- RCRA secondary waste. In instances where the sludge is not readily removed from a container, the excavator will be used to dismantle the drum (sizing) to remove the sludge, or the sludge may be removed in the DPS. In these cases, the drum carcasses will likely not support a RCRA empty determination; consequently, the non-intact drum carcasses may be crushed (sizing) by the excavator in a waste tray secondary containment pan (without grate), or the sorting table secondary containment pan, or in the drum compactor and staged/packaged for management as RCRA secondary waste (i.e., hazardous debris). Secondary wastes will be placed into drums, standard waste boxes, or other waste boxes.

A drum compactor is located in Room 103 to compact empty drums. Exhibit D-3 provides a schematic of the drum compactor. The compacted drums will be direct loaded into a container (drum or standard waste box) in Room 103, or passed through a radiological portal into a container in Room 106 for disposition.

EXHIBIT D-1. Sorting Table Schematic

EXHIBIT D-2. Retrieval Enclosure Camera Plan

The drum compactor (Exhibit D-3) is constructed of carbon steel. The empty drum carcass is placed in the compactor either vertically upright or upside down. During compaction, a large diameter mast head presses down on the drum, causing it to collapse downward as it is compacted. Total time for the compaction cycle on each drum is approximately 55 seconds. Drum compaction will be performed with the door of the compactor closed and latched, for purposes of safety.

EXHIBIT D-3. Schematic of Drum Compactor

26 for: Container loading and unloading activities are conducted according to established procedures

• Work Control
• Receipt, inspection, and documentation of waste
• Operations at WMF-698 and WMF-1617
• Non-destructive assay
• Log keeping practices and checklists
• Radiation and contamination control
• Industrial and fire safety
• As low as reasonably achievable (ALARA) radiation protection program
• Truck waste container unloading
• General waste movement within RWMC.

D-1a(3) Secondary Containment System Design and Operation [IDAPA 58.01.05.012 and 58.01.05.008; 40 CFR 270.15(a) and (b), 264.175(a) through 264.175(d)]

Secondary containment for the containers that may contain free liquids (e.g., prior to processing) in WMF-698 storage area is provided by drum storage secondary containment pans described earlier in this section. All containers will be elevated on agrate within the drum storage secondary containment pans so that should a leak/spill occur, the primary container will not be in contact with any released material. The drum storage secondary containment pan capacity is greater than the required 10 percent of the maximum container capacity.

Secondary containment for the container storage areas of WMF-1617 is also provided through the use of drum storage secondary containment pans described earlier in this section for those containers that may contain liquids (e.g., prior to processing). Containers are elevated within the pans, and the pans provide sufficient capacity greater than the required 10 percent of the maximum container capacity. Containers that have completed processing through the drum packaging stations and have been visually verified to not contain liquids, may be stored without secondary containment.

If liquid is observed in the drum storage secondary containment pan, the leaking drum will be identified and either be overpacked into an 83-gallon drum, or transferred into WMF-1617 for immediate processing. Liquids will be removed from the spill containment pans through addition of absorbent and removal of the solidified material in a timely manner. The storage of waste in drums or waste trays and treatment of the waste on the sorting table, DPSs or drum compactor is conducted inside the WMF-698 and WMF-1617 structures which prevent run-on of precipitation.

D-1b. Containers without Free Liquids

D-1b(1) Test for Free Liquids [IDAPA 58.01.05.012; 40 CFR 270.15(b)(1)]

Wastes without free liquids to be stored in the container storage areas in WMF-1617 Room 106 and WMF-698 will have completed visual verification of the contents through the drum packaging station. Waste in lined ARP waste trays within the RA will have also undergone visual verification on the sorting table to ensure that no free liquids are present in the waste tray. All other wastes will be managed as containing liquids.

D-1b(2) Description of Containers [IDAPA 58.01.05.008; 40 CFR 264.171 and 264.172]

Containers to be used for waste storage include 55-gallon drums, 83-gallon drums, 85-gallon drums, 110-gallon drums, standard waste boxes, or other waste boxes.  If a container holding waste or debris is not in good condition, the waste or debris will be either overpacked or taken to the retrieval area for immediate processing.

Operating personnel visually inspect the container storage/staging areas in WMF-698 and WMF-1617 through direct visual examination, or by using cameras within the retrieval area. Inspections are recorded and maintained at the facility for at least three years. Details on inspections are provided in Attachment 4, Section F of this permit.

D-8.     Miscellaneous Units [IDAPA 58.01.05.012 and 58.01.05.008; 40 CFR 270.23 and 264.601]

Processing the waste at WMF-1617 is performed in three miscellaneous treatment units: the Retrieval Area (X99), the DPS stations (X99), and the drum compactor (X99 and X02). The Retrieval Area includes the following activities: opening waste containers, staging waste in the retrieval area associated with waste processing activities, removing waste from the container onto the sorting table, segregating/sorting waste, opening/crushing inner containers with liquid content, absorbent addition for liquids, segregation/treatment of WIPP prohibited items, compacting/crushing empty containers with the excavator, and sizing waste to fit into containers. The Drum Packaging Stations activities include segregation of prohibited, addition of absorbents to the waste in the tray as necessary, visual examination by WIPP-qualified visual examiners to document compliance with the WIPP WAC and placing the waste into new containers. The Drum Compactor is used to compact drum carcasses and/or liners and includes absorbent addition for any liquids from the compaction process. These activities will allow the repackaged waste to meet the WIPP WAC.

D-8a.   Description of Miscellaneous Units [IDAPA 58.01.05.012; 40 CFR 270.23(a)(1) and (2)]

The description of the WMF-1617 building and miscellaneous unit processes are detailed earlier in this section.

D-8b.   Environmental Performance Standards for Miscellaneous Units [IDAPA 58.01.05.008 and 58.01.05.012; 40 CFR 264.601 and 270.23(c)]

The miscellaneous treatment processes located in WMF-1617 (RA, DPSs, and drum compactor) are located, designed, and operated in a manner to preclude the release of hazardous waste or hazardous constituents that may have adverse effects on human health or the environment. The WMF-1617 structure, and secondary containment pans (waste tray secondary containment pans, sorting table secondary containment pan, drum compactor secondary containment pan, DPSs), are configured, including a ventilation system for confinement of radioactive and hazardous constituents, to prevent particulate releases to the environment. Administrative/engineering controls for WMF- 1617 provide additional assurance that hazardous materials are not released to the environment.

No viable pathway exists for migration of hazardous waste or hazardous constituents from the mixed waste treated in the miscellaneous treatment units located in WMF-1617 to ground water, and/or surface water, as all treatment is conducted within areas that have impervious secondary containment. During HWMA/RCRA waste processing, any spilled waste will be cleaned up at the time the spill occurs. Procedural steps mandate removal of all spilled material and any surrounding stained soils. Soils approximately 4” beyond the extent of visible soil staining will be removed in the event of a liquid spill to ensure that all spilled material is removed. The waste/soil will be removed using the excavator equipment, or personnel in PPE with shovels. The collected material is returned to the sorting table or the lined ARP waste tray.

A potential pathway for release of waste constituents is through the exhaust air of the WMF- 1617 ventilation system. However, since all the waste to be processed is radioactive mixed waste IDAPA 58.01.05.008 (40 CFR 264 Subpart CC) is not applicable. Any radiological release would be limited to the period during which waste is being actively treated. The minimization of release of radiological constituents through the HEPA-filtered exhaust air system that potentially could have adverse effects on human health or the environment is accomplished by the following:

(1)        The treatment processes are controlled to minimize dust and airborne particles.

(2)        As a second stage of entrapment, any escaping waste constituents would then have to pass through banks of HEPA filters. HEPA filters would trap any particulate that may contain hazardous constituents.

(3)        The ventilation systems have been proven effective in seven years of ARP operations.

D-8b(1)   Miscellaneous Unit Wastes [IDAPA 58.01.05.008; 40 CFR 264.601(a)(1), 264.601(b)(1), and 264.601(c)(1)]

The wastes to be treated in WMF-1617 miscellaneous treatment units are sludge wastes that are currently managed at the AMWTP. The sludge waste may contain free liquids or WIPP-prohibited items. The miscellaneous treatments are designed to make the final waste package acceptable for disposition to WIPP or other acceptable waste disposal sites after return to AMWTP. The chemical characteristics of the wastes are described in Attachment 2, Section C of this permit.

D-8b(2) Containment System [IDAPA 58.01.05.008 and 58.01.05.012; 40 CFR 264.601(b)(2) and 270.23(a)(2)]

The WMF-1617 structure and miscellaneous units (RA, DPSs and drum compactor) are designed and operated to prevent the spread of contamination during treatment activities. The building is designed to operate under negative pressure drawing air from less to more contaminated areas. The ventilation air is filtered through HEPA filters prior to exhaust. Secondary containment (waste tray secondary containment pans, sorting table secondary containment pan, drum compactor secondary containment pan, DPSs) are used to contain any liquids present within the waste during treatment.

D-8b(3) Site Air Conditions [IDAPA 58.01.05.008 and 58.01.05.012; 40 CFR 264.601(c)(4) and (5), and 270.23(b)]

The climatology and meteorology at the INL is described in DOE Programmatic Spent Nuclear Fuel Management and INEEL Environmental Restoration and Waste Management Programs Final Environmental Impact Statement (DOE/EIS – 0203F, Volume 1, Appendix B). A copy of this document has already been provided to DEQ.

D-8b(4) Prevention of Air Emissions [IDAPA 58.01.05.008 and 58.01.05.012; 40 CFR 264.601(c)(2) and 270.23(a)(2)]

The WMF-1617 miscellaneous units are designed to prevent the spread of radiological contamination during treatment activities, and are located within secondary containment pans. HEPA-filtered exhaust ventilation is provided for ARP V and the negative pressure induces ventilation through the attached Airlock #5. The exhaust ducts and fans are located to draw air from the least contaminated areas into the most potentially contaminated areas. Fixed filter air samplers are located around the perimeter of the building and continuous air monitors (CAMs) with alarms are also provided for each discharge path (local filter/fan exhaust) to monitor for airborne radioactivity. Radiological control technicians (RCTs) routinely count the perimeter sampler filters for radioactive contamination. If airborne radiation above normal background levels is detected, the results will be evaluated and remedial actions are taken as appropriate to minimize the spread of contamination and to ensure operational control, worker protection, and environmental protection.

The HEPA filters remove approximately 99% of the particles in the exhaust air. The differential pressure across the HEPA filters is recorded. The filters are changed due to radiological loading and pressure drop. The filtered exhaust air is then released to the atmosphere. Since the waste to be treated/stored is a radioactive mixed waste, it is exempt from the requirements of IDAPA 58.01.05.008 (40 CFR 264, Subpart CC).

D-8b(5) Operating Standards [IDAPA 58.01.05.008 and 58.01.05.012; 40 CFR 264.601(c)(3) and 270.23(a)(2)]

For information on the operating characteristics of the retrieval area, drum packaging stations, and drum compactor see Section D above.

D-8b(6) Site Hydrogeologic Conditions [IDAPA 58.01.05.008 and 58.01.05.012; 40 CFR 264.601(a)(2), (3), and (4), 264.601(b)(3) and (5), and 270.23(b)]

The hydrology conditions at the INL are addressed in the DOE Programmatic Spent Nuclear Fuel Management and INEEL Environmental Restoration and Waste Management Programs Final Environmental Impact Statement (DOE/EIS – 0203F, Volume 1, Appendix B). A copy of this document has already been provided to DEQ.

D-8b(7) Site Precipitation [IDAPA 58.01.05.008; 40 CFR 264.601(b)(4)]

Site precipitation is addressed in the DOE Programmatic Spent Nuclear Fuel Management and INEEL Environmental Restoration and Waste Management Programs Final Environmental Impact Statement (DOE/EIS – 0203F, Volume 1, Appendix B). A copy of this document has already been provided to DEQ.

D-8b(8) Groundwater Usage [IDAPA 58.01.05.008; 40 CFR 264.601(a)(5)]

Groundwater usage at the INL is addressed the DOE Programmatic Spent Nuclear Fuel Management and INEEL Environmental Restoration and Waste Management Programs Final Environmental Impact Statement (DOE/EIS – 0203F, Volume 1, Appendix B).  A copy of this document has already been provided to DEQ.

D-8b(9) Surface Waters and Surface Soils [IDAPA 58.01.05.008; 40 CFR 264.601(b)(6), (7), and (8)]

Surface water and surface soils at the INL are addressed in the DOE Programmatic Spent Nuclear Fuel Management and INEEL Environmental Restoration and Waste Management Programs Final Environmental Impact Statement (DOE/EIS – 0203DF, Volume 1, Appendix B). A copy of this document has already been provided to DEQ.

D-8b(10) Area Land Use [IDAPA 58.01.05.008 and 58.01.05.012; 40 CFR 264.601(a)(6) and (b)(9), and 270.23(b)]

The area land use is addressed in the DOE Programmatic Spent Nuclear Fuel Management and INEEL Environmental Restoration and Waste Management Programs Final Environmental Impact Statement (DOE/EIS – 0203F, Volume 1, Appendix B). A copy of this document has already been provided to DEQ.

D-8b(11) Migration of Waste Constituents [IDAPA 58.01.05.008; 40 CFR 264.601(a)(7)]

For reasons discussed in Sections D-8b, D-8b(1), D-8b(2), and D-8b(4), the potential is extremely small for deposition or migration of waste constituents into subsurface physical structures and into the root zone of food chain crops and other vegetation.

D-8b(12) Evaluation of Risk to Human Health and the Environment [IDAPA 58.01.05.008; 40 CFR 264.601(a)(8) and (9), 264.601(b)(10) and (11), and 264.601(c)(6) and (7)]

For reasons discussed in Sections D-8b, D-8b(2), and D-8b(4), the potential is extremely small for any of the waste constituents to be a risk to human health or the environment.