ML20151A060

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Tru Waste Compliance Program for WIPP-WAC (U)
ML20151A060
Person / Time
Site: 07109218
Issue date: 07/31/1987
From:
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:
References
WO-4500-G-O, NUDOCS 8804060232
Download: ML20151A060 (160)


Text

0216(2)

Reviewed for classification by:

R. 5. Hof rman, Manager Classification Office f

D TRU WASTE COMPLIANCE PROGRAM FOR WIPP-WAC (U)

WC-450C -G/0 Document enJ Procedure No.

Revisen WO Eg R&D Quality thews om asM D EW %L&

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DISTRIBUTION 1

thru A. E. Whiteman (for AL) 00E RFAO 6

1 7

A. E. Whiteman 00E-RFA0 8

L. A. Abila RF 776

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9 R. P. Brugger RF-T334B 10 R. D. Mullet RF-750 11 Destroyed 12 Destroyed 13 Destroyed i

14 L. E. Dingman RF-707 15 A. C. Ficklin RF 750 16 N. Askins l

RF-371 17 G. L. Hickle RF-374 18 J. J. Glasmann RF-T750C 19 D. M. Krieg RF-111

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20 R. G. Kurtz RF-750 21 J. D. McCarthy RF-886

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22 J. A. Detamore JIO Al

)

23 W. D. Reinhart RF T3348

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24 R. T. Scott RF-776 25 J. D. Weaver RF-771 26 D. L. Gorman RF-881 27 C. E. Wickland RF-750 i

TRU WASTE COMPLIANCE PROGRAM WO 45u0-2 FOR WIPP WAC (U) 00S AM

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DISTRIBUTION (Contd) 28 R. J. Nau, Jr.

RF-771 29 R. P. Bradley RF 707 30 L. E. Dingman RF-707 31 P. R. Shoemaker RF 707 32 G. T. Hewitt RF 374

)

33 W. D. Reinhart (for E. W. Kendall, N&S) (Rev F only) 34 F. P. McMenus RF-774 35 E. R. Naimon RF-374 36 L. H. Brugger RF-750

)

37 J. K. Paynter RF-776 38 J. M. Alexander RF-776 1

l 39 P. Robledo, Jr. (For J. Guon, Canoga Park, CA)

RF 776 40 G. L. Aguero RF-371

)

41 B. A. Reynolds RF-750 42 R. T. Scott (For J. D. Wells, EG&G, Idaho) (Rev. E only) 43 R. T. Scott (For J. D. Wells, EG1G, Idaho) (Rev. E only) 44 C. E. Wickland (For B. Harris, EG1G, Idaho) (Rev. E only) l F

TRU WASTE COMPLIANCE PROGRAM WO 4500 3

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I CONT m s Sheet 1.

INTRODUCTION 6

1.1 TRU Waste Certification Plan 7

1.2 Waste Generating Activities 12 1.3 Quality Control 15 1.4 Operating Procedures References in WO 4500 TRU t

Waste Compliance Program for WIPP WAC 15 1

2.

TRU WASTE FORM IDENTIFICATION 18 2.1 Introduction 18 2.2 Item Description Codes (IDC) 21 3.

WASTE CONTAINER COMPLIANCE AND PACKAGE CERTIFICATION 25 3.1 Waste Container Compliance 25

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3.2 Waste Package Certification 28 i

3.3 Waste Package Control Methods 33 4.

ATTACHMENT I: CERTIFICATION OF TRU COMBUSTIBLE WASTE (WF-115) 40 l

i 5.

ATTACHMENT II: CERTIFICATION OF TRU METAL WASTE (WF-ll7) 52 6.

ATTACHMENT !!!: CERTIFICATION OF TRU GLASS WASTE (WF-118) 69 7.

ATTACHMENT IV: CERTIFICATION OF TRU SOLIDIFIED AQUEOUS WASTE (WF-lll) 82 8.

ATTACHMENT V: CERTIFICATION OF TRU SOLIDIFIED ORGANIC WASTE (WF-ll2) 89 9.

ATTACMENT VI: CERTIFICATION OF TRU SOLIDIFIED LABORATORY WASTE (WF-ll3) 96 2

10. ATTACMENT VII: CERTIFICATION OF TRU GRAPHITE WASTE (WF ll5) 104
11. ATTACHMENT VIII: CERTIFICATION OF TRU ORGANIC SOLIO WASTE (WF 121) 111 i

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C TRU WASTE COMPLIANCE PROGRAM WO 4500 4 ggpy FOR WIPP WAC (U)

{

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v CONTENTS (contd)

Sheet

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12. ATTACHMENT IX: CERTIFICATION OF TRU INORGANIC SOLID WASTE (WF-122) 117 l
13. ATTACHMENT X: CFRT!FICATION OF TRU FILTER WASTE (WF-119) 128
14. ATTACHMENT XI: CERTIFICATION OF TRU LEADED RUB 8ER (WF-123)139
15. ATTACHMENT XII: CERTIFICATION OF SOLIDIFIED PROCESS SOLIDS (WF-ll4) 145
16. ATTACHMENT XIII: CERTIFICATION OF TRU PYR0 CHEMICAL SALT (WF-124) 153 l

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0 TRU WASTE COMPLIAMCE PROGRAM WO-4500 5 7/l5/f7 FOR WIPP WAC (U) pos AM

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l 1.

INTRODUCTION The Rocky Flats TRU Waste Certification Plan is comprised of two pri-nary parts:

(1) TRU Waste Compliance--the responsibility of the Weste Operations Department, and (2) Quality Assurance for TRU Waste--the responsibility of the Quality Engineering and Control group.

l This document describes the measures necessary to implement a waste compliance progran which produces waste forms and waste packages which consistently meet the requirements of the Waste Isolation Pilot Plant (WIPP), Waste Acceptance Criteria (WAC) for newly generated, contact handled, Transuranic (TRU) Waste.

A Quality Assurance Progran Plan for WIPP Certified TRU Waste is con-tained in a separate, independent document.

It provides for inspection, documentation, and final certification of newly generated, contact-handled, TRU waste, it also provides for review and auditing of the TRU Waste Compliance Progran.

Guidance for neeting these requirenents has been provided by the

]

i following documents:

)

)

(1) 00E 5480.3, "Safety Requirements for the Packaging and Trans-portation of Hazardous Materials, Hazardous Substances, and Hazardous Wastes."

(2) WIPP-00E-114. "TRU Waste Certification Compliar'.- Requirements for Newly-Generated-Contact-Handled Waste for SLpnent to the WIPP," as updated.

(3) WIPP-00E-120 "Quality Assurance Measures for Certification of TRU Weste for Shipnent to the WIPP," as updated.

(4) WIPP-00E-15'i, "Data Package Format for Certified Transuranic 4

J Waste for the Warte Isolation Pilot Plant (WIPP), as updated.

)

(5) 00E-5820.2, "Radioactive Waste Management " as updated.

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4 B

TRU WASTE COMPLIANC5 PROGRAM WO-4500-6 N 4-ff FOR WIPP-WAC (U)

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(6) DOE AL Order 5700.6B, "Quality Assurance ' as updated.

(7) WIPP 00E 069, 'TRU Waste Acceptance Criteria for the Waste Isolation Pilot Plant," as updated.

Sections within this program plan may refer to the above mentioned documents by number.

)

1.1 TRU Waste Certification Plan 1.1.1 General Description j

The plant's mission is the fabrication of radioactive and nonradioactive parts uf nuclear weapons in support of the country's natio al defense program. As a result of fabrication, assembly, chemical processing, analytical, and research activities, transuranic wastes are produced that fall under the control of the certification program.

Approximately 95 percent of the radioactively contaminated wastes I

generated are the result of processing plutonium with the majority of the remaining 5 percent generated by the processing of depleted uranium.

(See Solid TRU Waste Process Flow Diagram, Figure 1.) After processing, 70 percent of the waste shipped is low level waste (LLW) and the remaining 30 percent is transuranic (TRU).

i POLICIES AFFECTING THE TRU WASTE CERTIFICATION PROGRAM (1) Radioactive Waste Management RFPM MAT 20 001 IT IS THE POLICY OF THE COMPANY TO CONDUCT PLANT OPERATIONS IN SUCH A MANNER AS TO MINIMIZE, OR EllF.INATE, THE GENERATION OF BOTH LIQUID AND SOLID RADIOACTIVE WASTES kNICH MUST BE SHIPPED OFFSITE.

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TRU WASTE COMPLIANCE PROGRAM WO 4500 7 I

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g A large contaminated equipment Paper, plastic, miss. metal, glass Precipitation sludges, 4

is sectioned in place organic sludges, graphite, a

or sent to Size Reduction and other misc, wastes a

y 3

Collected in drums C

in the process area l

V Collected in drums in the Drums are identified and serialized process area Material is scanned, inspected, and placed directly into boxes Y

P Drums are identified and Assayed in the drum counter serialized Y

r Drumsarei}ispected, sealed, C

y

,,h Sent to Size Reduction to be monitored, and weighed 2M repackaged into waste boxes 18 m2 1r 7,"

The package is identified, l

ss weighed, serialized, and c Drums are assayed or a lab "M

monitored analysis is taken to determing 2

radioactive m) terial content 7 8

=

y W ste package is assayed

-Staging area-m g

v g

Load transporter E

1r o

En Ship Figure 1.

Solid TRU Wste Process Flow Diagram I

)

(2)

Transuranic (TRU) Waste Certification RFPM MAT 20-002 IT IS THE POLICY OF THE PLANT TO CONDUCT PLANT OPERATIONS IN SUCH A MANNER AS TO PROVIDE A CERTIFICATION PROGRAM FOR TRU WASTE.

THE PROGRAM IS DESIGNED TO MEET ALL APPLICABLE ACCEPTf1CE CRITERIA SET BY THE DEPARTMENT OF ENERGY (DGE) AND ALSO TO MINIMlZE ADVERSE IMPACTS ON PRODUCTION ACTIVITIES.

l in keeping with the Radioactive Waste Management Policy (RFPM MAT 20-001),

Rocky Flats emphasizes the TRU waste compliance program to maintain an j

ef ficient, effective, and auditable program that will comply with all existing orders, guidelines, and regulations.

1.1.2 Responsibilitles for Certification Prog.am i

i The current Rocky' Flats organizational structure is shown in Figure 2. The Waste Operations Department, under Plutonium Operations, is responsible i

for the TRU Waste Compliance Program; the Waste Certification Department, under Quality Engineering & Control, is responsible for the TRU Waste Certification Program.

Departmental responsibilities for im'plementing a Plant certification program are outlined in Plant Policy RFPM MAT 20-00, ' Transuranic Waste i

Certification." The Rocky Flats Organization Manual details a current description of the plant organization.

C TRU WASTE COMPLIANCE PROGRAM WO-4500-9 FOR WIPP-WAC (V) g, g

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v ee ER vx General Manager' t

Plutonium Research &

Health, Safety

~ Qua li ty Support Operations Engineering

& Environment Engineering Operations

& Control Y

C m-oM Production Special Process Control Procurement Waste

  • Analytical 7

Opera tions Recovery Operations

]uality Engr.

Certificationi Labs Gy 7,

l EC PuRecover7 I

Waste **

Standards

]

371/771

[ Operations Labs em o

R I

Manager has authority and responsibility for inspection and final certification of wastes.

Manager has responsibility of TRU Waste Compliance Program.

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E?g figure 2.

Rocky Flats Plant Organization J

V 1.1.2.1 Plutonium Operations (Waste Op' rations)

The Waste Operations Department in Plutonium Operations is responsible for providing assistance to waste generators, and for the promulgation of TRU waste compliance operating programs, policies, and procedures.

The Waste Operations Department is also responsible for the effective imple-i mentation of an operator training program and performance evaluations of internal departmental programs.

A training program has been instituted for all employees, including supervisors, involved in generation, i

inspection, and handling of TRU waste.

Involved personnel are tested biennially and test results are kept on file.

i 1.1.2.2 Quality Engineering & Control Quality Engineering & Control contains three departments which directly support the Waste Certification Program.

I Waste Certification (WC):

WC is responsible for writing Quality Assurance procedures, performinc independent verification and inspection of waste compliance criteria, "erating, collecting and maintaining dccumented j

evidence of compliance and certification activities, and certifying the final waste packages and data package to WIPP criteria.

Procurement Quality Engineering (PQE):

PQE is responsible for all aspects of waste packaging and container procurement, and vendor manufuturing quality assurance.

Quality Improvement:

Quality Improvem t Department performs internal l

audits to ensure that quality procedures are adequately maintained and fully implemented.

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1 TRU WASTE COMPLIANCE PROGRAM WO 4500-11

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1.1.2.3 Supervisors Each supervisor responsible for generating or handling radioactive wastes must comply with Waste Operations' waste compliance procedures.

1.1.2.4 Employees Each employee handling radioactive materials is responsible for knowing and following Plant waste compliance procedo,re's that apply to his/her operation.

i 1.2 Waste Generating Activities 5tte return metal is extracted in a molten salt medium for americium removal. Subsequent aqueous processes separate the americium from the i

salt.

This operation generates the following wastes: chloride effluents, spent ton exchange resins, and combustibles.

Considerable americium is discarded through the various waste streams to waste treatment.

The plutonium metal is melted in tantalum crucibles, cast in graphite or steel molds, and sent to the fabrication area. Oil-based coolants and fluids contact the plutonium in the fabrication process.

Scrap plutonium metal from the fabrication and assembly process is recycled through the foundry for reuse in the casting operation.

Intermediate steps required before casting include degreasing and briquetting (Figure 3).

Residues which cannot be recycled as metal (such as casting skull, glove-box sweepings, and impure metal) are sent to the Plutonium Operations Plutonium Recovery Plant in either metal or oxide form. These residues, after being converted to oxide, are dissolved in nitric acid containing small amounts of fluoride.

The dissolver solutions, if sufficiently

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0 TRU WASTE COMPLIANCE PROG' NAM WO 4500,12 W/5/97 FOR WIPP-WAC (U)

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34-l Ed Metal From Offsite

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n ch Y

Product Product Building 707 Buildings 707 &

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Buildings 707 Foundry 776 Fabrication

& 777 Assembly Residue Residue Residue v

Residue Product M

Organic Waste C

(Oils) 5 4

Lab Waste (misc) 1 5%

Product 58 (Netal) 44 LC EE2 Pu Residue Aqueous Waste Waste Treatment

> Solid Waste to Of fsite 5o Recovery Building 774 h

E Bldgs 371 & 771 n

i E

h Y

Aqueous Waste Waste Treatment 5

Building 374 E

NOTE: Solid waste is generated and packaged in all buildings o

for shipment offsite.

w Figure 3.

Solid Waste

1 pure, undergo a precipitation process in which plutonium is converted to peroxide.

The peroxide is then calcined and hydrofluorinated to pluto-nium tetrafluoride (PuF ).

The PuF is then reduced to metal, using 4

4 calcium as a reductant. The plutonium metal produced is recycled in the foundry.

Filtrates from the peroxide precipitation process are evaporated and the concentrate is processed through anion exchange to purify the plutonium before recycling to peroxide precipitation.

The evaporator condensate and scrubber solutions from hydrofluorination off-gas streams are sent to Liquid Waste Treatment.

In the manufacturing, fabrication, recovery processes, and Analytical and R&D Laboratories, additional residues are generated which require pretreatment before peroxide precipitation. These include car. ting crucibles and molds, reduction residues, gloves and plastics, paper and other combustible waste, and a variety of miscellaneous residues such as glass, scrap metal, and insulation.

These residues are incinerated, leached, dissolved, 1

scraped, and/or hand-washed to remove as much plutonium as possible.

The treatment used depends upon the type of residue to be processed.

In processing these residues (e.g., the incineration of combustibles),

secondary residues are generated.

Items such as firebrick, soot, and off-gas filters become loaded with plutonium and must also be processed for plutonium recovery. The soluble plutonium in these residues, after l

being dissolved through repeated contact with nitric acid, is adsorbed on anion exchange columns for purification and concentration.

If the effluents are below the discard limit, they are sent to the Liquid Waste Treatment Plant for plutonium decontamination and conversion to a solid form.

The adsorbed plutonium is stripped from the ion columns and sent to peroxide precipitation for further purification and conversion to metal.

The insolubles from the leaching and dissolution operations are recycled through dissolution until the plutonium concentration is below the economic discard limit.

C TRU WASTE COMPLIANCE PROGRAM WO-4500-14

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s l.3 Quality Control 1.3.1 Waste Certification Department personnel will inspect and certify TRU waste.

1.3.2 Packages containing nonconforming wastes or having incomplete information on the labeling, as determined by Waste Certification (WC) or RTR examination, are returned to the generator for corrective action with a copy of a Waste Rejection Report (WRR) RF-47042, which identifies the specific reason for rejection.

The generator must take corrective action which is acceptable to Quality Engineering (see Figure 4).

Data for each TRU waste packaae is reviewed by QE personnel who verify the information is complete and correct.

The QE representative then approves WIPP certification for that waste package.

l 1.4 Operating Procedures Referenced in WO-4500 TRU Waste Compliance Program for WIPP-WAC t

Document Number Title WO-4005 1.oading Transuranic Waste into ATMX Railcars (U)

WO-4016 Handling Miscellaneous Wastes in the Size Reduction Area, Building 776 (U)

WO-4020 Organic and Sludge Imobilization System (U)

WO-4021 Miscellaneous Aqueous Waste Handling and Solidification (U)

WO-4033 Segregation of Plutonium-Contaminated Solid Waste (U)

WO 4034 Packaging Wastes for Shipment Offsite (V)

WO-4040 Waste Operations Supplies (U)

E TRU WASTE COMPLIANCE PROGRAM WO-4500-15 9pf,";

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NDT Examination Visual Inspection Quality Engineering Acceptable Yes Verification of Data Yes or No Package Information i

No U

u Waste Package cceptable and WRR Returned to No Yes or Generator Waste Assayed Yes and Surveyed 4

y Corrective Certification Action Taken and n

Recorded on WRR WC Inspection v

WRR Returned to QE for Review, Acceptance, and File Figure 4.

Corrective Action for Nonconforming I; ems E

TRU WASTE COMPLIANCE PROGRAM WO 4500 16

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6 Document Number Title WO-5014 Filtering, Drying, Conveying, Cementing, and Packaging Sludge (U)

C0-1009 Operating South Drum Counter (U)

C0-loll North Drum Counter Ge (Li) System (U)

CO-1039 Sorting and Scarfing Firebrick (Line 48) (U)

C0-1103 Segmented Drum Scan Counter, Building 771 (U)

CO-1106 Segmented Drum Scan Counter, Building 707 (U)

C0-1107 Passive / Active Crate Counter II, Building 664 (U)

C0-1112 LOSAC Segmented Drum Counter, Building 776 (U)

C0-1113 Salt Scrub Process, Building 776 (U)

CO-3001 Removal and Replacement of Raschig Rings (V)

C0-4001 I

Liquid Waste Processing (First Stage) (U)

C0-5017 I

Waste Collection System for Building 371 Recevery Operations (U)

C0-6017 HSA Incineration System Scarfing and Grinding (U)

CO-6069 Residue Cementing (U)

C0-7006 Operating the Crate Counter (U)

C0-9999 Master List of C0 Procedures (U)

)

WC-4004 Waste item Description Code Manual (U)

WC-4003 Solid Waste Inspection Procedure (U)

Traffic Proce-Procedure for Labeling and Marking Unclassified dure T-300-1 TRU Waste Containers for Shipment to INEL (V)

L-3007 Analysis of Low Level Plutonium and Americium in Discard Solution FO-707-1000 Coolant Oil System, Building 707 (U)

FO-707-1012 Graphite Process Operations, Building 707 (U)

E TRU WASTE COMPLIANCE PROGRAM WO-4500-17 g/jg FOR WIPP-WAC (U) 00:

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2.

TRU WASTE FORM IDENTIFICATION 2.1 Jntroduction All Rocky Flats TRU wntes and residues are segregated and classified into unique groups based on ine physical characteristics of the material, and in some instances, the area in which the material is generated or processed.

This is done to obtain accurate assay results based on a uniform matrix.

These assays determine whether the material is recoverable residue, transuranic waste, or low-level waste. These groups are identified by an Item Description Code (IDC), sometimes referred to as

)

"Content Code Number." All waste item descriptions are. listed in WC-4004, Waste Item Description Code Manual.

t i

f Rocky Flats TRU Waste Forms are made up of similar IDC's based on mode of generation (line or nonline-generated), processing similarities, or other similar control methods.

Each waste form is assigned a Waste Form Number (WFN) which appears in the data package under Content Code.

In Table 2-1 the waste form identifications and numbers are listed with the current waste form component IOC's.

The specific IOC's are listed and described in Subsection 2.2.

This list is not exclusive and may vary l

to accommodate process identificatton requirements or waste compliance processing requirements.

NOTE Certification procedures for each waste form are documented in attachments located at the end of this procedure.

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TRU WASTE COMPLIANCE PROGRAM WO-4500-18 l

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v TABLE 2-1.

TRU WASTE FORMS Waste Form IOC Number Waste Fom Name Number IOC Name 111 Solidified Aqueous Waste 800 Solidified Sludge, Building 774 803 Solidified Sludge, Building 374 (OCP) 1 807 Solidified Bypass Sludge, Building 374 112 Solidified Organics 801 Solidified Organics, Buildir.3 774 113 Solidified Laboratory Waste 802 Special Setups, Building 774 114 Solidified Process Solids 806 Solidified Process Solids 115 TRU Graphite Waste 300 Graphite Molds 303 Scarfed Graphite Chunks 312 Graphite, Coarse 116 TRU Combustible Waste 330 Combustibles, Dry 336 Combustibles, Wet 337 Plastic (Teflon, PVC, Poly,etc.)

491 Plenum Prefilters 117 TRU Metal Waste 320 Heavy Metal (Ta, W, etc.)

321 Lead 480 Light Metal 488 Glovebox Parts with Lead C

TRU WASTE COMPLIANCE PROGRAM WO 4500 19 7/g FOR WIPP-WAC (U) o v' AM

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TABLE 2-1.

TRU WASTE FORMS (contd)

Waste Form IDC Number Waste Form Name Number IDC Name 118 TRU Glass Waste 368 Mg0 Ceramic Crucibles, not Leco 370 Leco Crucibles 440 Glass, Except Raschig Rings 442 Leached Raschig Rings 119 TRU Filter Waste 335 Absolute Dry Box Filters (not acid contaminated) 376 Processed Filter Media 490 HEPA Filters 121 TRU Organic Solid Waste 302 Benelex and Plexiglas 122 TRU Inorganic Solid Waste 371 Firebrick 374 Blacktop, Concrete, Dirt, Sand 375 Oil-Dri 377 Firebrick, Coarse 379 Firebrick, Scarfed 438 Insulation, including Fire Blankets 123 TRU Leaded Rubber 339 Leaded Drybox gloves, not acid contaminated 124 TRU Pyrochemical Salt Waste 411 Electrorefining Salt, final Disposition 429 Scrub Alloy Spent Salt 454 Direct 0xide Reduction Salt (oxidized Ca) k E

TRU WASTE COMPLIANCE PROGRAM WC-4500-20 ggg FOR WIPP-WAC (U) 0 05 AM

V 2.2 Item Description Codes (IOC)

IOC Name and Description Origin 800 Solidified Sludge -

All Pu Areas Building 774 Waste consists of a solidified sludge produced by treatment of aqueous process wastes in Building 774. A cement / adsorbent mixture is added to the drum with a feed auger.

j 801 Solidified Organics - Building 774 F&brication Consists of solidified coolant oil, and Area and various halogenated solvents.

The Laboratories majority of this stream is carbon tetrachloride and oil from the fabrication machining facility.

Processed in Building 774.

802 Solidified Laboratory Waste - Building 774 Laboratories i

Consists of various aqueous solids which result from analyses performed by the Analytical Laboratories.

Processed in

}

Building 774.

803 Solidified Sludge - Building 374 (DCP)

All Pu Areas 807 Solidified Bypass Sludge - Building 374 (DCP)

All Pu Areas A wet sludge produced in Building 374 by treatment of process wastes.

292 Incinerator Sludge Pu Recovery Sludge collected from the recovery incinerator Areas in Building 771.

Below discard, 292 sludge must be processed into 10C-806.

300 Graphite Molds Plutonium Molds used for casting plutonium metal.

Foundries Also, graphite spacers or liners used in high temperature furnaces or ovens.

Limited to 200 pounds net per drum.

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TRU WASTE COMPLIANCE PROGRAM WO 4500-21 FOR WIPP-WAC (U) ca AM

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l IDC N_ame and Description Origin 302 Benelex and Plexiglass All plantsite l

Benelex is a very dense organic composite areas where j

i material used for radiation shielding gloveboxes are around gloveboxes and tanks.

Benelex used laminated with lead must have written approval from Safeguards before packaging.

Plexiglas is a trade name used to describe a family of polycarbonate-type materials used for j

radiation shielding, glovebox windows and equipment enclosures.

311 Graphite Heels Pu Recovery Graphite heels contain the insoluble components Area of graphite fines which have been processed for plutonium recovery. Graphite heels must be solidified with portland cement when they are below the discard limit to become 10C-806, 320 Heavy Non-SS Metal (Ta, W, etc.)

Foundry and i

Scrap metals which are heavier than iron and Molten Salt steel. Metal above Cu on the periodic chart.

Areas Mainly used tantalum crucibles. Does not include lead.

328 Filters, Ful-Flo from Building 771 Incinerator Plutonium Onl Process Areas i

u -Flo Filters from the recovery incinerator in Building 771. Must be processed to become IDC-376.

330 Combustibles, Dry All Pu Areas Dry combustibles such as paper, cloth, wood, etc.

Must not contain more than 50 percent plastic.

335 Absolute Drybox Filters, Not Acid Contaminated All Pu Areas High efficiency particulate air filters used on glovebox air intake and exhaust.

336 Combustibles, Wet 1.11 Pu Areas Wet combustibles are paper, cloth, etc.,

which contain a discernible amount of moisture.

Must be drained or wrung out to prevent the accumulation of free liquid.

337 Plastic (Teflon, PVC, Poly, etc.1 All Pu Areas PVC sheeting, poly bottles, supp11ed air suits and other plastics.

E TRU WASTE COMPLIANCE PROGRAM WO 4500 22

'YlW FOR WIPP WAC (U) t-AM

I i

V IDC Name and Description Origin 338 Insulation and Filter Media All Pu Areas Pipe and furnace insulation, fire blankets, and HEPA filter media. This waste should not be cemented unless it is wet or has been exposed to corrosive fumes.

341 Leaded Drybox Gloves, Acid Contaminated Production Leaded drybox gloves from all acid lines.

This Areas waste must be processed in Size Reduction.

339 Leaded Drybox Gloves, Not Acid Contaminated All Pu Areas Leaded drybox gloves and leaded aprons.

See 10C-341 if nitric acid contaminated.

370 Leco Crucibles Plutonium Crucibles from the Leco analytical process.

Laboratories 371 Fire Brick Pu Recovery All refractory clay products used to line an Area i

incinerator firebox or high temperature furnace.

372 Grit Pu Recovery 8

Grit blasting medium in all forms. Must be Areas processed into 10C-806 for disposal.

373 Fire Brick Heel Pu Recovery Insoluble components remaining after chemical Area processing of fire brick residues. Must be processed into IDC-806 for disposal.

375 Oil-Dri Recovery An adsorbent clay material.

Incinerator 376 Processed Insulation a Filter Media Size Reduction Wastes from IDC's 328, 5 5, and 338 which have been processed wit ortland cement.

393 Sand, Slag, and Crucible Heels Pu Recovery Insoluble components of IDC-398 after Area chemical processing. Must be processed into 10C-806 for disposal.

409 Molten Salt (not a waste) 776, MSE Area Waste consists primarily of a fused halide salt mixture of Nacl, kcl, and MgCl pyrochemicallyremoveamericiumfro$usedto plutonium metal.

O TRU WASTE COMPLIANCE PROGRAM WO-4500-23 g7 FOR WIPP-WAC (U) vo:

AM

V IDC Name and Description Origin 411 Electrorefining Salt - Final Disposition 371, ER Spent salt from the electrorefining process Facility in Building 371. All ER Salt IDC's become i

IDC-411 for disposal.

414 Direct Oxide Reduction Salt - Unoxidized Ca 776, Pyro-Must be processed (oxidized) into IDC-454 chemical for disposal.

Operations 421 Ash Heel Pu Recovery Must be processed into 10C-806 for disposal.

Area 422 Soot Pu Recovery Must be processed into 10C 806 for disposal.

Area 423 Soot Heels Pu Recovery Must be processed into 10C-806 for disposal.

Area 429 Scrub Alloy Spent Salt 776, MSE Area Spent salt from the Molten Salt Extraction Process in Building 776. All MSE salts must i

become IDC-429 disposal.

432 Cemented Resin lon column resin that has been water washed Pu Recovery Area and mixed with a cementing agent to solidify the material (then described as 10C-806).

440 Glass (except Raschig Rings)

All Pu Areas Primarily glassware from the Analytical Laboratory and glass vessels from the recovery facility gloveboxes.

Includes ceramic materials.

441 Unleached Raschia Rings All Pu Artas High boron content glass rings.

Used as a neutron poison in storage tanks which contain plutonium solution.

442 Leached Raschig Rings All Pu Areas High boron content glass rings.

Used as a neutron poison in-storage tanks which contain plutonium solution.

E TRU WASTE COMPLIANCE PROGRAM WO 4500-24 9Ath7 FOR WIPP-WAC (U) u t; 5 AM

I

~

800 Solidified Sludge - Building 774 801 Solidified Organics - Building 774 802 Solidified Laboratory Waste - Building 774 803 Solidified Sludge - Building 374 (DCP) (Special Setups) 804 Salterete - LLW 805 Ponderete - LLW 806 Solidified Process Solids All particulate and sludgy waste must be immobilized by processing into a solid and identified as 10C-806.

Building 371 has the only approved process to produce 10C-805, E

TRV WASTE COMPLIANCE PROGRAM WO 4500 25 SgfA /

FOR WIPP-WAC (U) ou:

AM

3.

WASTE CONTAINER COMPLIANCE AND PACKAGE CERTIFICATION 3.1 Waste Container Compliance This section describes the procedures and evidence which ensure that TRU waste containers used at Rocky Flats meet the compliance requirements for shipment to the Waste Isolation Pilot Plant.

The container requirements described in WIPP-D0E-Il4 for DOT-17C drums and DOT-7A metal waste boxes are addressed.

As appropriate, QA measures outlined in WIPP-D0E-120 are identified.

3.1.1 00T-17C Drums Drums are inspected and procured according to Rocky Flats Plant Standard SX-200 and instructions from Quality Engineering.

3.1.1.1 Waste Container Compliance Requirements (1)

Combustibility:

DOT-17C drums are constructed from 16-gauge steel and are noncombustible.

(2) 00T-7A:

00T-17C drums were shown to meet Type A requirements during testing at Mound Facility.

(See Mound Report MLM-3245, June 1985.)

(3)

Venting:

DOT-17C drums ara constructed with flowed-in gaskets according to Rocky Flats Plant Standard SX-205.

This gasket allows venting of the drums (see Rocky Flats Report 3739).

Other WIPP approved venting methods may be used.

l (4)

Design Life:

Improvements to the DOT-17C drums have been incorporated by Rocky Flats to ensure that drums can be retrieved, contamination-free, from storage.

Durability requirements of 20 years after certification, as required by the criteria, are met.

(See Rocky Flats Report CRDL 950703 001, December 1972.)

E TRU WASTE COMPLIANCE PROGRAM WO 4500-26 7/d/y1 FOR WIPP WAC (V)

Oh!

AM

~

(5)

Labeling:

Research in durability of paints used for waste containers has been performed at Rocky Flats and is documented in Reports CRD-78102, November 1978 and CSE-80-0031, July 1981. Several paints have been identified which are expected to meet the desired design life. Any additional paints procured will meet performance specification to ensure adequate compliance.

(6) Container The drums are inspected at the manufacturing Inspections:

site for compliance with Rocky Flats Plant Standard SX-200.

Before filling, drums are inspected for damage by the waste generator according to WO-4034.

3.1.1.2 Size Compliance Requirements 00T-17C 55-gallon drum, procurec to Rocky Flats Plant Standard SX-200, meet all WIPP size requirements.

3.1.1.3 Handling Compliance Requirements DOT-17C 55-gallon drums are manufactured with rolling hoops as specified by Rocky Flats Plant Standard SX-200.

Rolling hoops are an approved WIPP handling device.

3.1.2 00T-7A Type A Boxes l

Boxes are inspected and procured according to Rocky Flats Plant Standard SX-231 and instructions from Quality Engineering.

3.1.2.1 Waste Container Compliance Requirements

~t (1) Combustibility: The metal waste box is constructed from 14-gauge steel and has no combustible parts (See Rocky Flats Drawing 0-26383-1).

C TRU WASTE COMPLIANCE PROGRAM WO 4500-27 FOR WIPP-WAC (V)

gjg /

I)M AM

(2) DOT-7A:

The metal waste box was shown to meet Type A requirements during testing at the Rocky Flats Plant.

Results of these tests are documented in Rocky Flats Reports CSE 82-0003 and SARP 3345, and Mound Report MLM-3245.

(3) Venting:

A carbon composite filter (Rocky Flats Plant Standard SX-233) is installed in each 00T-7A, Type A, metal waste box. This filter allows venting of the box (see Rocky Flats Report RFP-3739).

(4) Design Life:

The metal waste box can be expected to remain intact and contamination-free for 20 years after certification because of all-metal construction which is externally protected by paint.

Performance standards for external coatings used with the Sand Box are explained in Rocky Flats Report CSE-82-0014, March 1982.

(5) Labeling:

Research in durability of paints used for waste containers has been performed at Rocky Flats.

(See Reports CRO-78102, November 1978, and CSE-80-0031, July 1981.)

Several paints have been identified which are expected to meet the desired design life.

Any additional paints procured will meet performance specification to ensure adequate compliance.

(6) Container The boxes are inspected at the manufacturing Inspections:

site for compliance with Rocky Flats Plant Standard SX-231. Before filling, boxes are inspected for damage by Waste Operations a

f.ersonnel according to WO-4034.

3.1.2.2 Size Compliance Requirements The metal waste box is procured to Rocky Flats Plant Standard SX-231 and meets all WIPP size requirements.

3y TRU WASTE COMPLIANCE PROGRAM WO-4500 28 D

FOR WIPP-WAC (V) gp

&M AM

,_,----__.s

,y-

3.1.2.3 Handling Compliance Requirements The metal waste box is manufactured with the WIPP-approved Sandia Lifting Lugs as shown in Rocky Flats Plant Standard SX-231.

3.1.2.4 Waste Packaging Complience Requirements l

Waste box liners and a certified filter / vent unit are installed by Waste Operations personnel (WO-4040).

The liners and filter / vent unit are inspected by WC inspectors (WC-4003).

)

3.2 Waste Package Certification This section describes the controls used to ensure that TRU waste packages meet the Waste Package Compliance Requirements identified in the WIPP WAC, for shipment to the Waste Isolation Pilot Plant.

3.2.1 Description of Waste Package Flow and Flow Chart i

l 3.2.1.1 Drums (See Figure 5) 1 (1) Drum Drum numbers are issued from Building 668.

Serialization:

Each drum is assigned a unique identification number. A serialized label is affixed to the l

drum and the number is recorded by Waste Operations and entered into the nuclear i

materials control system.

(2) Generator Empty drums are transported to the generator.

(WO 4034):

The generator is responsible for the correct packaging and labeling of the wastes.

See attachments for control of specific waste forms.

0 TRU WASTE COMPLIANCE PROGRAM WO 4500-20 9gjy FOR WIPP-WAC (U) 40 AM

Drum Serialization WO-4040 i

MTRI I

I h

(

Drum Counter Ship Midgs 707 & 771 Inspection &

Generator CO-1009 Repackaging

~

Shipping WO-4034 CO-1011 Bldg 776

Bldg 664 C0-1103 C0-1106 WC-4003

' WO-4005 Label

---e-


m-WO-4016 6ft'a' Orum f

A oad Label i

L i

I MTDR l 1 List i

8 Labeli I

Assay y

I )>

Printout

-A WIS NMC -- z;;;p Diig-- J Conputer i

\\s_.

I I

i

= Physical transport of containers l


= Da ta t ranspo rt h

Data Package D

Figure 5.

Waste Drum and Data Cullection C

TRU WASTE COMPLIANCE PROGRAM WO 4500-30

lN '

FOR WIPP-WAC (U) o D.

Aid I

(3) Drum Counter Waste drums are assayed in the 707/771 drum (CO-1009, counter. A computer printout which contains C0-1011, the following information is sent to Nuclear CO-1103, or Material Control (NMC):

container number, CO-1106):

prefix number, serial number, IDC, prirr.ary element (Chem symbol, weight, units) and secondary element (Chem symbol, weight, units).

Drum counting, as currently performed, separates scrap and residues from waste.

Other assay operations will be performed to separate TRU from LLW by assaying at the 100nC1/g level.

(4) Waste Drum A Waste Drum Count label contains the date Count label:

(month, day, year) in addition to the information listed above.

This form is sent to content verification / repackaging / size reduction (Building 776) with the drum.

(5) Content The waste package is inspected and undergoes a Verification /

final Quality Assurance verification, con-Repackaging /

sisting of a physial container inspection, Size Reduction content verification, free liquid detection, (WO-4016 and and a final waste package conformance check.

WO-4034):

The conformance check includes gaskets, welds, and high-efficiency filters.

All necessary data is compiled and entered on the Waste Drum Count label.

The waste container is transported to Waste Shipping, Building 664.

(6) Waste Shipping:

Waste packages are staged for shipment in Building 664.

Building 371 issues a computerized warehouse inventory to the shipping area. A shipping list is generated and sent to the 371 computer.

The following information is included on the shipping list:

container number, prefax number, serial number, container type, content code, gross weight, primary element (symbols, mass weight - g), secondary element (symbol, mass weight - g), total container curies, and penetrating radiation.

i D

TRU WASTE COMPLIANCE PROGRAM WO 4500-31 g

FOR WIPP-WAC (U)

DDS AM

l l

The 371 computer generates a waste shipment data package.

The computer calculates the total alpha curie, PE curies, Pu-239 gram equivalent values, and also checks for errors and/or unallowable items.

3.2.1.2 Boxes (See Figure 6)

(1) Repackaged Waste that is collected in drums and prepared Wastes:

for repackaging into a waste box follows the Figure 5 flow chart, from the "drum serialization" step to the "content verification / repackaging" step.

(2) Size Reduction Size reduction generates waste that is pl i

Waste:

in boxes from two sources:

(1) waste to resackaged (e.g., paper, plastic, nonleaded rubber, glass, metal), and (2) waste that is disassembled, cut, or crushed to improve packaging efficiency (e.g., gloveboxes, large equipment, HEPA filters).

As these items an:

taken from the vault and packaged ;nto waste boxes, a WC inspector inspects them for com-pliance with the acceptance criteria.

Each item and its radiometric survey value is logged on the Waste Box log Sheet (WBLS)

RF-46487.

The waste generator is identified by a prefix number whic't, is entered on the WBLS.

This logsheet is then used to determine the value of radioactive material being discarded. The box and the logsheet are sent to the waste shipping building where the box is weighed, assayed in the crate counter, and readied for shipment.

The weight is recorded on the logsheet. WC reviews the logsheet for completeness.

WO inputs the logsheet information on the Waste Inf3rmation System 4

(WIS).

The labels and logsheet contain all of the information for the data package required by the acceptance criteria. A box is shipped only after the computer checks the information l

and prepares a shipping load list, and after Quality Engineering has approved certification for the waste package.

D TRU WASTE COMPLIANCE PROGRAM WO 4500 32 pf/f7 FOR WIPP-WAC (U) 0 01 AM

Drum Box Serialization Preparation WO-4040 WO-4016 WO-4034 i

MTR I

Box l

Number

(

y y

u

~

Ship Drum Counter Genera tor Bldgs 707 & 771

~

Inspection &

~

CO-1009 Repackaging Shipping Waste C0-1011 Bldg 776 Bldg 664 Collect.

CO-1103 C0-1106 WC-4003 Box WO-4005 WO-4034 Drum WO-4016 Report label f

and l

oxlfLoad Label List I

Report !

l n out u

9

)

i WIS i

Assay Data Computer)

../

1

= Physical transport of containers I

. --.......... = Da ta t ra ns po rt Da ta Package

%/

Figure 6.

Waste Box and Data Collection 0

TRU WASTE COMPLIANCE PROGRAM WO-4500-33

<M FOR WIPP WAC (U)

1) { b

%M

(3) Directly-Placed Waste boxes are issued to waste generators Waste:

who have waste from decomissioning projects (i.e., waste that has been size reduced in place) and/or waste that is too large to fit into a drum, yet small enough to fit into a box.

A WC inspector is present to unlock the box, inspect, and log the waste as it is loaded into the box. The box and the logsheet follow the same routing as described for Size Reduction Waste.

i 3.3 Waste Package Control Methods l

NOTE Instruments, scales, and assay equipment mentioned in the following subsections are covered by the Rocky Flats documented and auditable calibration program.

3.3.1 Waste Package Weight (1) Drams - Packaging procedures for TRU waste drums (WO-4034) do not allow drums to exceed 800 pounds gross weight.

This meets the WIPP criterion for waste package weight.

Waste drums are weighed by the assay operator and the weight is recorded on the drum label and subsequently transferred to the 371 computer. Scales are calibrated and checked accordina to the Rocky Flats Plant Quality Program Manual.

Compliance is assured by Quality Engineering.

Waste drums are inspected (WC 4003) by WC inspection personnel uho check the label to ensure that the package has been weighed

,.nd recorded.

(2) Boxes - Packaging procedures for TRU waste boxes (WO-4034) do not allow boxes to exceed 6000 pounds.

This meets the WIPP criterion for waste package weight.

Waste boxes are weighed by WO personnel in Building 664 and the weight is recorded on the WBLS.

Compliance is assured by the immediate supervisor with frequent periodic verifications by Quality Engineering. The WBLS is transferred to the 371 computer.

O TRU WASTE COMPLIANCE PROGRAM WO 4500 34 7/jt/y /

FOR WIPP-WAC (U) 001 AM

(3) All Containers - Before shipment, data packages are reviewed by a computer program which flags any overweight packages.

3.3.2 Nuclear Criticality (1) Drums - All drums are required to be assayed for fissile material according to WO-4034.

Drum counting is performed according to CO-1009 and C0-1011, and fissile content is recorded on the Drum Count label.

These procedures will be updated for the new assay equipment, or new procedures will be written.

Calibration at the drum counters is performed in accordance with the RFP Quality Manual.

Compliance is assured by the innediate supervisor with periodic verification by Quality Engineering.

Drum information is inspected according to WC-4003.

The fissile content recorded on the label is checked to ensure that the drum contains not more than the 200-gram limit.

(2) Boxes - The fissile material of TRU boxes is determined for directly packaged, repackaged, and size-reduced waste as follows:

Directly packeged and size-reduced waste is assayed with a detector to determine the fissile material content.

This value is recorded on the WBLS.

Boxes are also assayed in the crate counter at Building 664 (CO-7006 and CO-1107).

Orumed waste, designated for repackaging, is assayed for fissile material content in the drum counter.

The fissile material content assigned to these drums is reassigned to the waste box into which the drums were repackaged.

In accordance with WIPP Acceptance Criteria, WO-4034 limits the amount of fissile material in a 4 x 4-x 7-foot waste box, to 350 grams.

(3) All Containers - Before shipment, data packages are reviewed by a computer program which flags any packages not meeting specifications. The computer calculates Pu-239 equivalent grams, total alpha curies, and thermal activity.

O TRU WASTE COMPLIANCE PROGRAM WO 4S00 35

';/di) 1 FOR WIPP4.'AC (U)

DD !

iM

. - ~. - - -. -

3.3.3 Surface Dose Rate All Waste Containers - All items leaving controlled areas at Rocky Flats must be monitored by Radiation Monitoring, using gamma and neutron assay instrumentation. Maximum surface dose rates are recorded on the container label. The information is transferred to the WIS computer. Waste packages with significant neutron emissions (>20 mrem /br) have the nectron contribution noted on the drum label.

Surface dose rate must not exceed 200 mrem /hr.

Monitoring is performed according to the Radiatior Monitoring Policy Manual, Subsections 3.2 and 3.2A.

Compliance is assured by the immediate supervisor with periodic verification by Quality Eigineering.

Radiation Monitoring, in conjunction with the Standards Laboratory and Instrumentation Management Group, calibrate monitoring equipment.

3.3.4 Surface Contamination All Containers - All items leaving controlled areas at Rocky Flats must be surveyed for surface contamination by Radiation Monitoring according to the Radiation Monitoring Policy Manual, Subsection 3.2.

Removable alpha contamination is determined by smearing the item in accordance with controlled Radiation Monitoring procedures, and by counting the smear in a scintillator smear counter. Direct alpha contamination is surveyed using air proportional direct alpha assay instrumentation.

This survey is performed in accordance with controlled radiation monitoring procedures.

Compliance is :ssured by the immediate supervisor with periodic verification by Quality r gineering.

Calibration n

is performed by Radiation Monitoring personnel in conjunction with the Standards Laboratory and Instrumentation Management Group.

O TRU WASTE COMPLIANCE PROGRAM WO 4500 36 7pgf FOR WIPP-WAC (V)

DM AM

No item leaves a controlled area unless the removable alpha contamination is less than 20 disintegrations per minute per 100 cm2 (i.e., 10 pCi/100 2

2 [227 pCi/100 cm )) total alpha activity.

The 2

)

cm and 250 cpm /55 cm 2

250 cpm /55 cm is the minimum detection range of current instruments.

2 This satisfies the WIPP waste acceptance criterion of 50 pC1/100 cm maximum alpha contamination.

If isotopes that are primary beta emitters are present in a waste container, the generator notifies Waste Operations i

with a Waste Processing Request form, RF 46367.

This waste is then processed according to WO 4021 for liquid waste, or WO 4016 for solid waste.

i l

Because of the restrictive internal limit on alpha contamination, and j

the infrequent use of isotopes that are primary beta emitters, waste i

containers are not checked for beta surface contamination.

3.3.5 Thermal Power l

)

The thermal output of each waste package is calculated by the WIS computer, u: ng the assay information obtained in Step 3.3.2.

Thermal 3

powers in excess of 0.1 watt /ft are recorded, as appropriate, in the data package.

3.3.6 Gas Generation Organic content weight factors are determined for each waste content code.

)

The orpnic content of each package is calculated by the SWIMS computer sys;ex Mich Nultiplies the gross weight of the package by the organic weight factor. This organic mass and volume percent are included with the container data package, l

0 TRU WASTE COMPLIANCE PROGRAM WO-4500-37 7gyy FOR WIPP WAC (U)

QM AM

' 3.3.7 Labels (1) All Containers - Waste package identification numbers are assigned at Rocky Flats to include the account number of the waste generator and a unique serial number for the package.

The generator maintains a logbook to ensure that serial numbers are not duplicated.

(2) Drums - Prefix numbers and Letters (lbs) are stenciled on drums by the maintenance painter.

SWO stamps the serial number and weight in pounds.

Recorded on the drum label is the following:

(a)

Identity and assay values of the TRU contaminants (b)

Surface dose readings (c) Waste form identification (IDC)

(d)

Inspection date and inspector identification (e) Weight of the drum and contents (f)

Identifying code (prefix) for the waste generator (3)

Boxes - Serial numbers and weight in pounds are stenciled on boxes by Waste Operations in Building 654.

Recorded on the WBLS is the following:

(a)

Surface dose readings (b) Waste form identification (IOC)

(c)

Inspection date and inspector identification i

(d) Weight of the box ard contents (e)

Identity and assay values of the TRU contaminants (f)

Identifying code (prefix and drum number) for the generator of each drum repackaged into the box, if the box is filled 4

with repackaged waste I

~

TRU WASTE COHPLIANCE PROGRAM WO-4500-38 D

.jyjy j FOR WIPP WAC (U)

DD!

AM 4

(4)

All Containers - All containers are checked for adequate labels before loading for shipment by WC inspection.

3.3.8 Data Packages (1) Drums - Required information on TRU waste drums is collected using the drum label. This information is transferred to the WIS computere (2)

Boxes - Required information on TRU waste boxes is collected on the Waste Box Logsheet, and is transferred to the WIS computer.

)

(3) All Containers - The WIS computer checks each data package for completeness before finalizing the load list for that shipment.

This program checks for erroneous entries and for packages out of compliance.

Designated QE personnel signs a Certificate of Compliance attesting that all compliance requirements have been met. Copies of this statement are included in the shipping manifest and kept on file in the Waste Certification office.

1 The transmitted data package follows the format specified by "Data Package Format for Certified Transuranic Waste for the Waste Isolation Pilot Plant (WIPP)" (

Reference:

WIPPDOE-157).

M TRU WASTE COMPLIANCE PROGRAM WO 4500-39 D

FOR WIPP-WAC (U) pg,p7 JS AM

I V

i l

3.3.9 Mixing Certified Waste Forms Certified waste forms may be mixed at the final repackaging before shipment to maximize packaging efficiency and reduce the volume of TRU waste shipped.

The assay values for the plutonium, americium, and any other TRU contaminants from each waste drum will be recorded on the WBLS and the total assay value will be recorded in the data package according to WC-4003.

Certified waste forms may be mixed according to the following guidelines:

10C-330:

Line and nonline generated waste may be mixed, provided the nonline waste has been counted by the LOSAC and determined to be TRU waste.

Four (maximum) drums of 10C 336, or -337 waste may be mixed with 10C-330 waste.

10C-336:

Plastic drum liners and drum liner lid, ',1D0-337) may be used to "top-off" crates of 10C-336.

i IDC-480: Drum counted metal waste, with a value of zero grams, may l

be mixed with scanned materials that is less than one gram.

10C-480 and -488:

Line generated and nonline generated drum counted waste may be mixed, providing the Drum Count Sheet shows at least one gram of fissile material present in the nonline generated drum.

There i.ill be a final assay check of the waste crate on the Crate Counter and a final verification by RTR of compliance with the WIPP-WAC for each waste package (see Subsection 3.3, Waste Package Control Methods).

TRU WASTE COMPLIANCE PROGRAM WO 4500 40 0

FOR WIPP WAC (U) 1M/y1 uct AM

4.

ATTACIMENT 1: CERTIFICATION OF TRU COMBUSTIBLE WASTE (WF ll6)

Contents 4.1 Introduction j

4.2 Waste Form Description 4.3 Waste Flow Description 4.3.1 Line-Generated Cor.bustibles 4.3.2 Nonline-Generated Combustibles 4.3.3 Repackaging Combustibles 4.3.4 Specially Handled Combustible Waste 4.4 Waste Form Controls 4.4.1 Imobilization (Particulates) 4.4.2 Free Liquids 4.4.3 Pyrophories and Explosives 4.4.4 Compressed Gases 4.4.5 Radioactive Mixed Wastes 1

I TFU WASTE COMPLIANCE PROGRAM WO-4500-41 7jff/y7 FOR WIPP-WAC (V) vo!

AM

4.1 Introduction All TRU Combustible Wastes are repackaged and inspected in Building 776 Size Reduction and Repackaging Facility (with the exception noted in Step 4.3.4 of this attachment).

Decontamination workers repackage according to WO-4016. WC inspectors, who continually monitor the repackaging according to WC-4003, independently inspect all materials.

The "combustibles" waste container is a DOT-7A, steel box (SX 231) with an 11-mil polyvinyl chloride (PVC) liner (SX-209). The waste package

]

will have all other required markings and labels (see Section 3).

Rocky Flats line-generated and nonlit.2 generated wastes are handled and packaged separately according to WO-4034.

4.2 Waste Form Description "Combustibles," Waste Form (WF) 116, consists of paper, rags, cloth coveralls, plastic, rubber, wood, and other similar items.

wF-ii' is comprised of the following IDC's:

330-dry combustibles, j

336-wet combustibles, and 337-plastic and non-leaded rubber.

This waste form has demonstrated stability in extended storage (e.g.,

examination of 3-year-old waste retrieved from storage) and will remain certifiable during the period of interim storage anct 1ransportation to WIPP.

i l

0 TRU WASTE COMPLIANCE PROGRAM WO-4500 42

</pff y */

FOR WIPP-WAC (U) pDS AM i

4.3 Waste Flow Description 4.3.1 Line-Generated Combustibles The combustible waste is segregated from all other materials, especially removing all free liquids, particulates, and process residues. The waste is then collected (often prepackaged at this point) and bagged out of the glovebox line (see Figure 7).

All line-generated waste is double bagged and monitored for contamination before being placed into the waste collection drum.

Collection drums are clearly marked "Line-Generated Combustibles."

Full collection drums are closed and labeled by the generator, surveyed for contamination and radiation by Radiation Monitoring personnel, and then transferred to the drum counter (WO-4034).

Nondestructive Assay and Material Control (NDA&MC) from Process Planning and Control, determines the nuclear material content by Or!-approved assay methods (C0-1009, CO 1103, or CO-1106); they determine whe';her the drum contents are recoverable residue or TRU waste.

If the contents are TRU waste, the NDA&NC operator enters the assay value on the Ortm Count label and tapes the label to the drum lid (WO-4034).

The drum is then surveyed for surface contamination and transferred to Size Reduction and Repackaging (SRR) in Building 776.

C TRU WASTE COMPLIANCE PROGRAM WO 4500-43

yg//7 FOR WIPP-WAC (U) l) U AM

Pu Moncomplying Material Processing

~

Area (Subsection 1.3)

F y

Pu Repackage, Recovery Segregate Inspect h

V Y

Crate t

Bagout Counter Assay Below Discard TRU Y

Place in

label, Collection Mark, RTR Drum Noncomplying Material (Subsection 1.3) u 1

Above Drum D i,s c a rd Counter Certification Assay

/

Below Discard TRU l

Figure 7.

Line-Generated Combustible TRU Waste D

TRU WASTE COMPLIANCE PROGRAM WO-4500 44

'//dy 7 FOR WIPP WAC (U) nDi AM

l

' 4.3.2 Nonline Generated Combustibles Combustible wastes generated within the Pu processing area, but outside of a glovebox line, are termed "nonline-generated wastes." These wastes are collected in 55 gallon drums located in all Pu areas.

The drum covers are clearly marked "Nonline Combustibles." Normally, according to WO 4034, nonline waste is not bagged before being placed in the collection drum (see Figure 8).

When the drum is full, the two "barrel bag' liners are sealkJ and the drum is closed. The drum label, completed with all necessary information, is then taped to the drum lid.

The drum is surveyed for surface contamination and radiation and then transferred to the LOSAC counter for assay (WO-4034).

The Low Specific Activity Counter (LOSAC) determines if the waste is TRU or Low Level Waste (LLW).

If the waste is TRU, the 10 SAC counter can assign an accurate Pu gram value up to 20 grams.

If the waste contains greater than 20 grams of Pu, it is assayed by the Building 707 or 771 drum counter (CO-1009, CO-1103, CO 1106).

The Drum Count label is taped to the drum lid, and the assay results are recorded on the label.

If the waste is LLW, the LLW label is used (C0-1112).

The drum is then transferred to the Size Reduction and Repackaging Facility.

4.3.3 Repackaging Combustibles At Building 776 the drums are held until approximately 20 drums of either line-generated or nonline generated combustibles have accumulated. The line generated or nonline-generated wastes are reptekaged separately into

)

boxes (WO-4016). The waste box liners and a certified filter / vent unit are installed by Waste Operations personnel (WO-4034). The liners and

)

filter / vent unit are inspected by a WC inspector (WC-4003).

TRU WASTE COMPLIANCE PROGRAM WO-4500 45 D

FOR WIPP-WAC (U) yta/0 DDS AM

n Nonline Waste Collection Drum Recovery L

r Above Discard Drum

>20g LLW Count LOSAC m

s Assa f'

~

TRU <20G

(

Unacceptable Material Below Discard Repackage (Subsection 1.3)

Inspection Crate Counter Assay Below Discard TRU o

Label, Mark, RTR Unacceptable Material (Subsection 1.3)

Certification Figure 8.

Nonline Generated Combustible TRU Waste 0

TRU WASTE COMPLIANCE PROGRAM WO 4500-46 7dh/

FOR WIPP-WAC (U)

PD AM

Repackaging is performed under controlled conditions in the earlock of the Size Reduction and Repackaging Facil$ty. The data from each drum is transferred to a WBLS when the drum is opened and the waste is transferred to the box (WO-4034 and WC-4003).

Each bag of waste is opened, inspected by a WC inspector, and distributed in the box to obtain greater packing density. This inspection detects j

and eliminates noncomplying materials (WC-4003). Noncomplying materials 1

are returned to the generator with a Waste Rejection Report RF 47042 this form is forwarded to QE with the corrective action documented by the generator. QE reviews and approves the corrective action (Subsection 1.3).

When the box is full, the liner is closed and sealed.

The box is surveyed for surface contamination.

Radiation readings are taken at the surface and at 1 meter and are recorded on the WBLS. The lid is welded, providing a tamper-proof seal. The box is then transferred to Building 664.

Final assay is performed in the crate counter (C0 7006 and C01107).

This assay must t 'ee with the cumulative assays of the drums which have been consolidated into the box, within the limits of error established j

for the counters.

A waste review board determines actions to be taken on assay discrepancies.

The alpha curies, PE curies, and thermal activity are calculated based on the gran quntities of the TRU contaminants from the drum counter assay (Steps 3.3. ' and 3.3.5).

The box is then marked and labeled, based on the information on the WBLS (Traffic Procedure T-300-1).

TRU WASTE COMPLIANCE PROGRAM WO-4500 47 Eg FOR WIPP-WAC (U)

DDS AM

NOT personnel perform RTR inspection of the box. These trained personnel, who are certified to Rocky Flats Plant (RFP) procedures that implement the Level II SNT-TC-1A standards, use the information on the WBLS (Step 3.3.7, Labels) to detect and document the following:

(1) Nonconforming items in the packa;)

(2) Utilization of fiberboard and polyethylene liners (3) Correct waste form description (4) Presence of free liquid Nonconfoming waste packages are returned to the generator for corrective action with a copy of a Waste Repetion Report RF-47042, which identifies the specific reason for rejection (see Subsection 1.3).

Data from each of the above operations is reviewed by QE personnel who verify that the information is complete and correct. WIPP certification for that waste package is approved by QE, and Computer Operations is notified that the waste package can be added to the shipment load list and that the information has been verified and can be included in the data package, 4.3.4 Specially Handled Combustible Waste Specially handled combustible waste is packaged in a DOT-17C, 55 gallon drum with a 90-mil polyethylene liner and will not be repackaged. The waste will be contaminated with either americium which will require lead shielding or with reportable toxic material (WO-4034).

~

E TRU WASTE COMPLIANCE PROGRAM WO-4500-48 7//5h/

FOR WIPP-WAC (U) ppS AM

' Specially handled combustible waste is inspected by a WC Inspector at the generator site before the waste drum is closed. After the waste has been inspected, the liners are sealed and the drum is closed.

The inspector i

then installs a tamper proof seal on the bolted closure ring and records the required data on the drum label (WC-4003 and WO 4034).

The alpha curies, PE curies, and thermal activity are calculated based on gram quantities of the TRU contaminants from the drum counter assay (Steps 3.3.2 and 3.3.5).

The waste drum is then processed as shown in Figure 9.

4.4 Waste Form Contrcls 4.4.1

!amobilization (Particulates)

All of the components of this waste form are nonparticulate and have demonstrated stability in long-term storage.

Combustibles must be segregated from unacceptable particulates when packaged as waste (WO-4034). During repackaging in SRR combustibles receive 100 percent inspection for particulates by WC independent inspection (WC-4003).

These procedures are audited annually by Rocky Flats QA audit schedules and periodically by DOE auditors.

4.4.2 Free Liquids Liquids are prohibited from being placed in the waste package (WO-4034).

Also,100 percent inspection of this waste form during repackaging ensures that no free liquids are present (WC-4003).

E TRU WASTE COMPLIANCE PROGRAM WO-4500 49 9/g/p FOR WIPP-WAC (U)

DOS AM

Segregate Generator and Prepackage Below Discard TRU a

4 7

Place in LOSAC ow level Waste Drum with Assay /

Liners

/

TRU Waste

[

o u

Noncomplying Material WC

Label, (Subsection 1.3)

Inspection Mark, RTR Noncomplying Material (Subsection 1.3L Close and Certification Seal TRU

(

rum Above Discard Caunter ssa Figure 9.

Specially Handled Combustible TRU Waste D

TRU WASTE COMPLIANCE PROGRAM WO-4500- 50 7/5h/

FOR WIPP WAC (U) 0 05 AM

In addition, Rocky Flats waste generators are instructed to package damp or moist materials to avoid the accumulation of free liquids which could occur as a result of draining or evaporation and recondensation (WO 4034).

The damp combustibles are wrung out, drained, or dried whenever possible.

Alternatively, sufficient adsorbent is added directly to damp waste to imobilize sny liquid that may be desorbed during shipment and storage (WO-4034).

RTR examination of the sealed waste package is performed as a conclusive verification that no unacceptable free liquids are present.

4.4.3 Pyrophorics and Explosives

)

Evaluation of kocky Flats TRU waste, retrieved from storage after 12 years, showed no signs of pyrophorics or explosives.

4.4.4 Compressed Gases Pressure vessels are excluded from combustible waste by proper packaging (WO-4034) and by 100 percent inspection at the time of repackaging (WC 4003).

RTR examination of all TRU waste packages provides backup verification that no pressurized vessels are present.

The waste box container is fitted with a high efficiency filter-vent which allows the internal pressure to remain ambient.

t TRU WASTE COMPLIANCE PROGRAM WO-4500-51 E

?/6/p7 FOR WIPP-WAC (U) 00S AM

4.4.5 Radioactive Mixed Wastes i

All combustible wastes which have contacted corrosive material must be segregated and/or neutralized before packaging (WO 4034). Corrosive action would be detected and eliminated at the point of repackaging because complete inspection is performed (WC 4003). All TRU Waste packages have a corrosion resistant liner.

Examination of Rocky Flats stored TRU waste revealed no signs of corrosive action, Occasionally, some hazardous materials could be present in waste as contaminants with the transuranic material.

However, the Rocky Flats Health, Safety, and Environment Manual ensures that all hazardous materials are handled and disposed of safely (HS&E, Chapters 1.02 and 2.32). Waste packages with reportable toxics, ignitible, reactive, or corrosive wastes are identified by type and amount in the data packages.

1 i

TRU WASTE COMPLIANCE PROGRArt WO-4500 52 D

FOR WIPP WAC (U)

,g,y UDS AM

\\

' 5.

ATTACMENT II:

CERTIFICATION OF TRU METAL WASTE (WF-ll7)

Contents 5.1 Introduction 5.2 Waste Form Description 5.3 Waste Flow Description 5.3.1 Line-Generated Metal Waste to be Repackaged 5.3.2 Nonline Generated Metal Waste to be Repackaged 5.3.3 Repackaging Metal Waste 5.3.4 Metal Waste Packaged Directly Into a Waste Box 5.3.5 Metal Waste Packaged Directly Into a Drum 5.4 Waste Form Compliance 5.4.1

! mobilization (Particulates) 5.4.2 Free Liquids 5.4.3 Pyrophorics and Explosives 5.4.4 Compressed Gases 5.4.5 Radioactive Mixed Wastes 4

l E

TRU WASTE COMPLIANCE PROGRAM WO 4500 53 77,gjg FOR WIPP WAC (U)

DD:

AM

5.1 Introduction TRU metal waste is packaged in either 00T-17C, 55-gallon steel drums or DOT-7A, steel boxes. Line generated and nonline generated wastes are

)

handled and packaged separately (WO 4034), with the exception of final packaging operations as described in Step 3.3.9.

Approximately 75 percent of TRU Metal Waste is repackaged in the Size Reduction and Repackaging (SRR) facility, 24 percent packaged directly into waste boxes, and 1 percent packaged in 55 gallon drums.

TRU Metal Waste (WF-ll7) requires only careful segregation and inspection to comply with WIPP Waste F(,1n Criteria.

5.2 Waste Form Description TRU Metal Waste, WF-117, consists of 10C's 320 Heavy Metal, 480 Light Metal (not leached), and 481 Light Metal (leached).

This waste form has demonstrated stability in extended storage (3 years) and will remain certifiable during the period of interim storage and transportation to WIPP.

1 Typical metal waste contains iron, copper, aluminum, stainless steel, tungsten, lead, and tantalum.

Pyrophoric metals are specifically excluded.

Metal containers, especially pressure vessels, must have an obvious opening which makes the container incapable of containing hidden liquid or gas pressure (WO-4034).

0 TRU WASTE COMPLIANCE PROGRAM WO 4500 54 1

g/g/g/

FOR WIPP-WAC (U)

OM AM

5.3 Waste Flow Description 5.3.1 Line-Generated Metal Waste to be Repackaged (see Figure 10)

The metal waste is first segregated from all other materials, especially removing particulates, liquids, and process residues. The waste is then prepackaged to prevent cutting the 0-ring bag as it is removed from the line (WO 4034).

All line generated metal waste is double bagged and then surveyed for contamination and radiation (Radiation Monitoring Procedure Manual, Subsection 2.5).

The waste is then placed in the proper waste collection drum which is marked for line-generated metal waste only (WO 4034).

When the drun is full, the liners are taped closed, the lid is secured with a bolted ring and the Drum Count label is completed and taped to the drum lid by the generator (WO-4034).

The drum is then surveyed for contamination and radiation by Radiation Monitoring personnel. After radiation readings are entered on the drum label, the drum is sent to the drum counter for assay.

NDA&MC determines the nuclear material content of the drum, using DOE-approved assay methods (C0-1009, CO-1011, CO-1103, C0 1106); they determine whether the drum contents are recoverable, TRU waste, or LLW.

The NOA&MC operator enters the assay value on the Drum Count label.

The drum is then surveyed for surface contamination and transferred to SRR in Building 776.

TRU WASTE COMPLIANCE PROGRAM WO 4500 55 FOR WIPP WAC (U) j 00S AM

i I

7 Pu Noncomplying Material Area (Subsection 1.3)

Processing y

y Pu Repackage, Recovery Segregate Inspect h

\\

u Crate Bagout Counter Assay Below Discard TRU U

V Place in

Label, Collection Mark, RTR Drum N'oncomplying Material (Subsection 1.3)

U p

Orum Above Discard Counter Certification Assay Below Discard TRU Figure 10. Line-Generated Metal Waste to be Repackaged i

TRU WASTE COMPLIANCE PROGRAM WO-4500-56 D

FOR WIPP WAC (U)

WD '

pt:

AM

5.3.2 Nonline Generated Metal Waste to be Repackaged (See Figure 11)

Metal wastes generated within the plutonium processing area, but outside of a glovebox line, are termed "nonline-generated wastes."

These wastes are collected in 55-gallon drums located in all Pu areas.

The collection drums are clearly marked for nonline metal waste only.

Normally, nonline waste is not bagged before being placed in the collection drum.

When the drum is full, the two ' barrel bag' liners are sealed and the drum is closed. The generator completes the Drum Count label with all necessary information and tapes it to the drum lid. The drum is then surveyed for surface contamination and for radiation; radiation readings are entered on the drum label.

The drum is then transferred to the drum counter for assay (WO-4034).

NDA&MC determines the nuclear material content by appropriate assay methods (CO 1009, CO 1103, CO-1106); the determination is made whether the drum contents are recoverable, TRU waste, or LLW.

The NDA operator enters the assay value on the Drum Count label and tapes the label to the drum lid (WO 4034).

The drum is then surveyed for surface contamination and transferred to SRR in Building 776.

5.3.3 Repackaging Metal Waste At the SRR facility in Building 776, the drums of waste are collected until enough waste, either line-generated or nonline-generated, has

)

accumulated to fill one waste box (see Figures 11 and 12).

TRU WASTE COMPLIANCE PROGRAM WO 4500 57 D

7jg/yy FOR WIPP WAC (U)

GM 2.

i

\\

Waste is Placed in Collection Drum v

Orum Above Discar Count ow level Waste.~~

's Assay s

elow Discard TRU U

Repackage, Unacceptable Material Inspect (Subsection 1.3)

Crate Counter Assay Below Discard TRU 1

Label, i

Mark, RTR l

l Unacceptable Material (Subsection 1.3)

=

v Certification l

Figure 11.

Nonline-Generated Metal Waste to be Repackaged i

i D

TRU WASTE COMPLIANCE PROGRAM WO 4500 58

'#g/f /

FOR WIPP WAC (U) f> D :

i AJS 2

r Waste Collection i

Drum i

i A

OrumNt I

law Level Waite Coun ihme Ditcard Assay Below Discard Lev _el Repackage Noncomplying Material in SRR (Subsection 1.31 w

'(

Inspect and Seal l

' Crate Counter Assa N

g s

Label, 1

Mark, RTR Noncomplying Material 1

(Subsection 1.11 T

. Certification I

Figure 12. Line-Generated Metal Waste to be Repackaged i

TRU WASTE COMPLIANCE PROGRAM WO 4500 59 D

j 7fg/g FOR WIPP WAC (U)

]

00:

AM

) ' Repackaging is performed under controlled conditions in the airlock of the SRR vault.

The data from each drum is transferred to a WBLS when the drums are opened and the waste transferred to the waste box (WC-4003 and WO-4016).

Each bag of waste is opened, inspected by a WC inspector, and distributed in the waste box to obtain greater packing density.

This inspection detects and eliminates all noncomp' lying materials (WC 4003).

Noncomplying materials (Subsection 1.3) which require processing are returned to the generator with a Waste Rejection Report RF-47042. A copy of the WRR, stating the corrective action taken, must be returned to Quality Engineering (WC-4003).

The waste box liners and a certified filter / vent unit are installed by Waste Operations personnel (WO-4034).

The liners and filter / vent unit are inspected by a WC inspector (WC-4003).

When the box is full, the liners are closed and sealed, and the box is surveyed for surface contamination.

Radiation readings are taken at the surface and at 1 meter and are recorded on the WBLS.

The lid is welded on, providing a tamper-proof seal.

The waste package is then sent to Building 664 with the WBLS which has been approved by the WC inspector (WC-4003).

At Building 664 the box is weighed and the weight is stenciled on the box and entered on the WBLS. The box then receives final assay in the crate counter (CO-7006 and CO 1107). This assay must agree with the cumulative assays obtained by drum count, within the limits of error assigned to each assay method. A waste review board determines actions to be taken on assay discrepancies, l

D TRU WASTE COMPLIANCE PROGRAM WO 4500 60 gjg/g FOR WIPP WAC (U)

OY AM

1 The proper ' Radioactive' shipping labels and all other required marking and labeling are then affixed to the box (Traffic Procedure T-300-1).

The alpha curies, PE curies, and thermal activity are calculated based on gram quantities of the TRU contaminants from the drum counter assay (Steps 3.3.2 and 3.3.5).

NOT personnel perforn RTR examination of the box. These trained personnel who are certified to Rocky Flats Plant (RFP) procedures that implemnt the Level !! SNT-TC-1A standards, use the information on the WBLS (Step 3.3.7, Labels) to detect and documcat the following:

(1) Nonconforming items in the package (2) Utilization of fiberboard and polyethylene liners (3) Correct waste fora description (4) Presence of free liquid Nonconforming waste packages are returned to the generator for corrective action with a copy of a Waste Rejection Report RF-47042, which identifies the specific reason for rejection (see Subsection 1.3).

There will be 100 percent inspection of this waste by RTR until data has been established showing control can be maintained through statistical sampling.

Data from each of the above operations is reviewed by QE personnel who verifies that the information is complete and correct.

The QE personnel then (1) approves WIPP certification for the waste package and (2) notifies Computer Operations that the waste package can be added to the shipment load list, and that tne information on the Drum Count label has been verified and can be included in the data package, j

E TRU WASTE COMPLIANCE PROGRAM WO 4500 61 7/es/v7 FOR WIPP WAC (U) vM AM

5.3.4 Metal Waste Packaged Directly Into a Waste Box Line-generated metal waste which is too large to fit into a 55 gallon drum, but does not require size reduction, decontamination, or disassembly to meet WIPP/WAC, is placed directly into an approved waste box (see Figure 13).

All waste boxes remain locked and a WC inspector retains possession of the waste box key (s).

This waste is equipment, tanks, or machinery in or attached to a glovebox.

The items for disposal are inspected before removal from the line.

Gearbox oil, hydraulic fluid, etc., must be removed. All electrical equipment must be checked to ensure that electrical potential has been discharged.

After all WIPP/WAC requirements have been met and verified by a WC inspector, the item can be removed from the line, packaged so as to contain all radioactive contamination, and surveyed for nuclear material content.

The waste is then placed in the box and the lid is locked in place.

The data for each item is recorded on a WBLS (WC-4003).

Nonline metal waste may also be placed in the same box if the waste has been determined to be contaminated greater than 100 nanocuries per gram (WO 4034).

i 1

E TRU WASTE COMPLIANCE PROGRAM WO 4500 62 7hth7 FOR WIPP WAC (U) 0 05 AM

N v

l I

Pu Repackaged Size s,

Gram Reduction

)

Survey Segregate Below Discard i

I p

Place in Box II_

and Weld WC Lid inspection n

Crate Counter Y

Assa Remove from,'

Line Below Discard l

Label, Mark, RTR I

Prepackage Noncon;? lying Material (subsection 1.3)

Certification 1

Figure 13. Metal Waste Packaged Directly Into a Waste Box C

TRU WASTE COMPLIANCE PROGRAM WO-4500- 63 gjf,rj)'

FOR WIPP WAC (U)

CD:

AM

i

~ Waste box liners and a certified filter / vent unit are installed by Waste Operations personnel ( 4 4034).

The liners and filter / vent unit are inspected by a WC inspector (WC 4003). When the box is full, the liners l

are closed and sealed and a temporary lid is secured (locked) in place for transfer to the welding station.

The box is then surveyed for contami-nation and radiation.

Radiation readings are entered on the WBLS.

The box is then shipped to the welding station. After welding, the waste box follows the flow path described in Step 5.3.3.

5.3.5 etal Waste Packaged Directly Into a Drum Metal waste which will not be repackaged into a box is packaged in a 00T-17C, 55 gallon drum with a 90 m11 pol, ethylene liner (WO 4034).

Metal waste contaminated with h'.gh radiation isotopes is packaged, according to WO 4034, in a DOT 17C, 55 gallon drum with a 90 mil polyethylene liner and a lead liner (see Figure 14).

The waste is first segregated from all noncomplying materials, inspected by a WC inspector, prepackaged, and bagged out of the glovebox.

The waste is double bagged, surveyed for contamination and radiation, identified by the WC inspector, and placed in the drum.

The data for that package is recorded on the drum contents logsheet.

i I

i i

0 TRU WASTE COMPLIANCE PROGRAM WO 4500 64 7jgjy7 FOR WIPP WAC (U)

FA:

j

=

Jegregate

?

3 1

2 r

o 1I

.8 WC Drum Inspection Count Assay Below Discard Y

U Label Bagout g

and Mark I

3 y

i y

3 Place in Line) Drum RTR Noncomplying Material (Subsection 1.3)

~

y y

Seal (WC)

Certification and Inspect Figure 14. Metal Waste Packaged Directly Into a Drum D

TRU WASTE COMPLIANCE PROGRAM WO-4500-65 7/c7 FOR WIPP-WAC (U) vo:

AM

, _ - ~. _.

Metal waste is packaged as efficiently as possible to minimize the possibility of container rupture due to waste shifting.

If a single piece of heavy metal is packaged, it is braced to prevent shifting. When the drum is full, the WC inspector chei:ks the drum for proper packaging.

The liners are then closed and sealed and the lid is bolted on.

The WC inspector then installs a tamperproof aeal on the closure bolt.

The data from the drum contents logsheet is transferred to the Drum Count label (WO-4034 and WC-4003).

The drum is then sent to the drum counter.

NDA&MC weighs the drum and determines the nuclear materi-content by DOE-approved assay methods; drum conterts are detemined to be either i

recoverable residue or TRU waste.

The NDAUIC operetor enters the drum weight and assay value on the Drum Count label.

The drum is then surveyed for contamination and radiation.

The radiation readings are recorded on the Drum Count label.

If the radiation at the surface is greater than 200 mrem /hr, the drum is returned te the generator for more lead shielding (WO-4034).

If the drum is less than 200 mrem /hr at the surface, it is sent to Waste Operations in Building 664. The proper ' Radioactive" shipping labels are then affixed to the drum (T: affic Procedure T-300-1).

The alpha curies, PE curies, and thermal activity are calculated based on gram quantities of the TRU contaminants from the drum counter assay (Steps 3.3.2 and 3.3.5).

NDT personnel perform RTR inspection of the drum contents.

These trained personnel, who are certified to Rocky Flats Plant (RFP) procedures that implement the Level II SNT-TC-1A standards, use the information on the drum label (see Step 3.3.7) to detect and document the following:

E TRU WASTE COMPLIANCE PROGRAM WO 4500 66 7/6/y7 FOR WIPP-WAC (U)

DOS AM

(1) Use of polyethylene and 90 mil rigid liners (2) Correct waste form description (3)

Presence of free liquid (4)

Identification of other extraneous forbidden articles Nonconforming waste packages are returned to the generator for corrective action with a copy of a Waste Rejection Report RF-47042, which identifies the specified reason for rejection (see Subsection 1.3).

The data from each of the previous operations is reviewed by QE personnel who verifies that the informatio1 is complete and correct. WIPP cert:fication for that waste package is approved by QE personnel and Computer Operations is notified that this waste package can be added to the shipment load list and that the information has been verified and can be included in the data package.

5.4 Waste Form Compliance 5.4.1 Immobilization (Particulates)

The metal waste matrix is, by definition, nonparticulate. Metal fines generated by conventional working operations such as sawing, grinding, and filirg have been evaluated for particle size. The particle size distribution, based on five random samples of Rocky Flats waste metal fines, has less than 1 percent of the particles less than 200 microns,'

and less than 0.01 percent of the particles less than 10 microns. Thus, metal working fines associated with WF-117 are well within the required limits for particulates.

l TRU WASTE COMPLIANCE PROGRAM WO-4500-67 D

9ggg FOR WIPP-WAC (U)

()CS AM

  • l

' Particulate metal waste, such as 10C 372 Grit, is u s! into a cement matrix and is not part of TRU Metal Waste WF-117 ( E 4034).

TRU Metal Waste is segregated from all particulate material as much as is reasonably possible (WO 4034) and is independently inspected for unacceptable particulates by a WC inspector (WC-4003).

Packaging and inspection operations are audited periodically, per the QA audit schedule.

5.4.2 Free Liquids Liquid of all types is prohibited from being packagmj in TRU waste (WO-4034). One hundred percent inspection of TRV Metal Waste, by a WC inspector, during repackaging assures that no free liquid is present in the waste (WC-4003).

Waste generators are instructed to thoroughly drain all fluid reservoirs, lines, gearboxes, etc., before disposing of metal equipment (WO 4034).

Radiographic examination of the waste package is performed as a conclusive determination that no unacceptable free liquid is present in the waste.

5.4.3 Pyrophories and Explosives 1

Reactive pyrophorics and all explosives are strictly prohibited from 1

j TRU waste (WO-4034). These materials are controlled and monitored very i

closely under several RFP safety policies.

E TRU WASTE COMPLIANCE PROGRAM Wo.4500-68 7//#Y7 FOR WIPP-WAC (U) 0 05 AM

' One hundred percent inspection by Waste Certification Ir.spection (WC-4003) and periodic audits, per the QA audit schedule, ensure that these materials are excluded from TRU waste.

5.4.4 Compressed Gases All closed containers and pressure vessels (including acrosol cans) must have an opening which makes it obvious that the container is not pressurized (WO-4034).

The WC inspector must be able to visually determine that closed containers are not pressurized (WC-4003).

5.4.5 Radioactive Mixed Wastes All corrosive materials must be neutralized or removed from TRU metal waste before packaging (WO-4034).

Thorough WC inspection (WC-4003) and periodically, per the QA audit schedule, ensure thst corrosive material is excluded from TRU waste.

Examination of Rocky Flats stored TRU metal waste showed no evidence of corrosive action up to 12 years after packa.ging.

All Rocky Flats TRU Waste packages have either a 90-mil polyethylene liner or an 11-mil polyvinyl chloride (PVC) liner for corrosion protection.

Waste packages with reportable toxies, ignitible, reactive, or corrosive wastes are identified by type and amount in the data package.

WC inspection allows toxics in waste as co-contaminants if it is properly identified.

TRU WASTE COMPLIANCE PROGRAM WO 4500-69 E

g/gg FOR WIPP-WAC (U) 005 AM

6.

ATTACl#4ENT III: CERTIFICATION OF TRU GLASS WASTE (WF-118)

Contents 6.1 Introduction 6.2 Waste Fona Description 6.3 Waste Flow DescH otion 6.3.1 Raschig Rings 6.3.2 Line-Generated Glass Waste to be Repackaged 6.3.3 Repackaging Glass Waste in the SRR Facility f.3.4 Line-Generated Glass Waste Packaged Directly Into a Drum 6.4 Waste Form Compliance 6.4.1 Imobilization (Particulates) 6.4.2 Free Liquids 6.4.3 Pyrophorics and Explosives 6.4.4 Compressed Gases 6.4.5 Radioactive Mixed Wastes i

v TRU WASTE COMPLIANCE PROGRAM WO 4500-70 g

FOR WIPP-WAC (U) 0U AM i

6.1 Introduction TRU Glass Waste is packaged in either DOT-17C, 55-gallon steel drums or DOT-7A, steel boxes.

Line-generated and nonline-generated wastes are handled and packaged separately.

Approximately 95 percent of TRU Glass Waste is repackaged in the SRR facility and 5 percent is packaged directly into 55-gallon drums.

TRU Glass Waste requires only careful segregation and inspection to comply wita WIPP waste form criteria.

I

~

6.2 Waste For1n Description i

TRU Glass Waste (WF-ll8) consists of IDC's 370 Leco Crucibles, 440 Glass

)

(except Raschig rings), and 442 Raschig rings (leached) and other similar glass or ceramic ware. This waste form has shown to be stable in extended storage (3 years) and will remain certifiable during the period of interim storage acti transportation to WIPP.

Glass waste consists of approximately 50 percent Raschig rings and 50 percent other glass, such as laboratory glassware, process equipment, and glovebox windows. Ceramic ware and equipment are included in this waste form.

Line-generated glass waste is generally prepackaged in 1-gallon metal paint cans or poly bottles before removal from the glovebox.

l raschig rings are tutular borosilicate glass rings approximately 1.5 inches in diameter and 2 inches in length.

They are used as a nuclear poison in process tanks which contain radioactively contaminated liquid.

.a I

D TRU WASTE COMPLIANCE PROGRAM WO-4500-71 7/d/Y7 FOR WIPP-WAC (U) 00' AM

.,_.-L

6.3 Waste Flow Description 6.3.1 Raschig Rings Raschig rings are segregated from noncomplying materials as they are removed from tanks.

The rings are placed in plastic bags and all other material is collected in 2-liter poly bottles (C0-3001 and Nuclear Safety Manual) (see Figure 15).

The Raschig rings are then double bagged and placed in waste collection drums which have been prepared specifically for that ring change job.

When a drum is full, the liners are taped closed and the drum lid is secured with a bolted ring.

i The TRU Waste drum count label is completed and taped to the lid. The drum is then surveyed for contamination and radia. tion by Radiation Monitoring personnel. Radiation readings are entered on the drum label and the drum is sent to the drum counter for assay (WO-4034).

NDA&MC weighs the drum and determines the nuclear material content of the drum using DOE-approved assay methods (C0-1009, C0-1011, C0-1103, C0-1106); they determine whether the drum contents are recoverable residue or TRU waste. The NDA&MC operator enters the assay value on the Drum Count label.

The waste collection drum is then surveyed for surface contsmination and sent to the SRR facility in Building 776.

v 0

TRU WASTE CONDLIANCE PROGRAM WO-4500-72 7//5/Y1 FOR WIPP WAC (U) 005 AM

l Rings Removed from Tanks o

Drum Segregate Above Discard, Count Assay elow Discard y

y Honcomplying Material' Repackage, Double Ba9 (Subsection 1.3 Inspect y

1P Place in Crate Collection Counter Drum Assay Selow Discard TRU o

Label, Pu Recovery Mark, RTR

=

Noncompl.ying Material (Subsection 1.3) u Certification Figure 15. Raschig Rings C

TRU WASTE COMPLIANCE PROGRAM WO-4500-73 7jgjyf FOR WIPP-WAC (U)

I)UA

'AM

6.3.2 Line-Generated Glass Waste to be Repackaged (see Figure 16)

The glass waste is first segregated from all other materials, especially removing particulates, liquids, and process residues.

The waste is then prepackaged so as to prevent cutting the 0-ring bag as it is removed from the line (WO-4034).

All line-generated glass waste is double bagged and then surveyed for contamination and radiation (Radiation Monitoring Procedure Manual, Subsection 2.5).

The waste is then placed in the proper waste collection drum which is marked for line-generated glass waste only (WO-4034).

When the drum is full, the liners are taped closed, the l'.d a secured with a bolted ring, and the Drum Count label is completed and taped to the drum lid by the generator (WO-4034).

The drum is then surveyed for contamination and radiation by Radiation Monitoring personnel.

Radiation readings are entered on the drum label, and the drum is sent to the drum counter for assay.

HDA&MC weighs the drum and detemines the nuclear material content of the drum using 00E-approved assay methods (C0-1009, C0-1011, C0-1103, C0-1106); the drum contents are determined to be either recoverable residue or TRU waste. The NDA&MC operator enters the assay value on the Drum Count label.

The waste collection drum is then surveyed for surface contamination andsent to the SRR facility in Building 776.

6.3.3 Repackaging Glass Waste in the SRR Facility (see Figure 16)

At SRR in Building 776, the drums of waste are collected until enough waste has accumulated to fill one waste box.

I h

TRU WASTE COMPLIANCE PROGRAM WO-4500 74 0

FOR WIPD WAC (U) gy 00S AM

1 l

Pu Moncomplying Material Processing (Subsection 1.3)

Area

~

y y

Pu Repackage, Recovery Segregate Inspect h

r

)

Y Crate Bagout Counter Assay Below Discard TRU l'

F Place in

Label, Collection Mark, RTR Drum No' complying Material n

(Subsection 1.3)

V Above Discard Drum Counter Certification Assay Below Discard TRU Figure 16. Line-Generated TRU Glass Waste s

0 TRU WASTE COMPLIANCE PROGRAM WO-4500-75

'//i f />

FOR WIPP-WAC (U) li ' S l

AM

~

' Repackaging is performed under controlled conditions in the oarlock of the SRR vault.

The data from each drum label is transferred to a WBLS when the drums are opened and the waste is transferred to the waste box (WC-4003 and WO-4016).

Each bag of waste is opened, inspected by a WC inspector, and distributed in the waste box to obtain greater packing density.

This inspection detects and eliminates al' noncomplying materials (WC-4003). Noncomplying materials (Subsection 1.3) which require processing are returned to the generator with a Waste Rejection Report (RF-47042). A copy of the WRR, stating the corrective action taken, must be returned to Quality Engineering (WC-4003). Noncomplying waste which does not require processing (mixed waste form) is held in the SRR vault and packaged properly at a later time.

The waste box liners and a certified filter / vent unit are installed by Waste Operations personnel (WO 4034).

The liners and filter / vent unit are inspected by a WC inspector (WC-4003). When the box is full, the liners are closed and sealed, and the box is surveyed for surface contamination. Radiation readings are taken at the surface and at I meter and are recorded on the WBLS.

The lid is then welded on, providing a tamper-proof seal.

The waste package is then sent to Building 664 along with the WBLS which has been approved by the WC inspector (WC-4003).

The alpha curies, PE curies, and thermal activity are calculated based on gran quantities of the TRU contaminants from the drum counter assay (Steps 3.3.2 and 3.3.5).

At Building 664 the waste package receives final assay in the crate counter (C0-7006andCO-1107).

It is marked and labeled according to th!

information on the WBLS (Traffic Procedure T-300-1). A waste review board determines actions to be taken on assay discrepancies.

1

'J D

TRU WASTE COMPLIANCE PROGRAM WO 4500-76 7/dfy7 FOR WIPP-WAC (L')

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AM l

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Real-Time Re.diographic (RTR) inspection is performed by NOT personnel.

These trained personnel, who are certified to Rocky Flats Plant (RFP) procedures that implement Level II SNT-TC-1A standards, use the information on the WBLS (Section 3.3.7, Labels) to detect and document the following:

(1) Nonconforming items in the package (2) Use of fiberboard and polyethylene liners (3) Correct waste fora description (4)

Presence of free liquid Nonconforming waste packages are returned to SRR for corrective action

)

with a copy of a Waste Rejection Report RF-47042, which identifies the specific reason for rejection (see Subsection 1.3).

Data from each of the above operations is reviewed by QE personnel who verifies that the information is complete and correct.

The QE representative then approves WIPP certification for that waste package and notifies the Computer Operations group that the waste package can be added to the shipment load list, and that the information has been verified and can be included in the data package.

6.3.4 Line-Generated Glass Waste Packaged Directly Into a Drum (See Figure 17)

Glass waste which will not be repackaged into a box is packaged in a DOT-17C, SS-gallon drum with a 90-mil polyethylene liner.

Glass waste contaminated with high radiation isotopes is packaged in a DOT-17C, 55-gallon drum with a 90-mil polyethylene liner and a lead liner (WO-4034).

E TRU WASTE COMPLIANCE PROGRAM WO 4500-77 pp FOR WIPP-WAC (U)

CDS AM

T o

Close and Segregate Seal (WC) 7 U

y WC Orum Inspection Count Above Discard Assay Below Discard TRU T

U Bagout Mark

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y U

Place in Lined Drum Label, RTR Noncomplying Material (Subsection 1.3)

,U Certification i

Figure 17. Line-Generated Glass Waste Packaged Directly into a Drum i

E TRU WASTE COMPLIMCE PROGRAM WO-4500 78 7//5// /

FOR WIPP-WAC (U) 06:

AM l

, = _ -

The waste is first segregated from all noncomplying materials, inspected by a WC inspector, prepackaged, and bagged out of the glovebox.

The waste is double bagged, surveyed for contamination and radiation, identified by the WC inspector, and placed in the lead-lined drum. The data for that package is recorded on the drum contents logsheet.

I When the drum is full, the WC inspector checks the drue for proper contents. The liners are then closed and sealed and the lid is bolted on.

The WC inspector then installs a tamper-proof seal on the closure bolt.

The data from the drum contents logsheet is transferred to the Drum Count label (WO-4034 and WC-4003). The drum is then sent to the drum counter.

NDA weighs the drums and determines the nuclear material content by DOE-approved assay methods; the drum contents are determined to be either recoverable residue or TRU waste.

The NDA operator enters the weight and assay va:Je identified as Below Discard on the Drum Count label.

The drum is then surveyed for contamination and radiation. The radiation readings are recorded on the Drum Count label.

If the radiation at the surface is greater than 200 mrem /hr, the drum is returned to the generator for more lead shielding (WO-4034).

I If the drum is less than 200 mrem /hr at the surface, it is sent to Waste Operations in Building 664.

The proper "Radioactive" shipping labels are affixed to the drum (Traffic Procedure 300-1).

)

5 The alpha curies, PE curies, and thermal activity are calculated based on gras quantities of the TRU contaminants from the drum counter assay (Steps 3.3.2 and 3.3.5).

~

TRU WASTE COMPLIANCE PROGRAM 90 4500-79 r

ejy/y 1 FOR WIPP-WAC (U)

ODS AM

NOT personnel perforn RTR inspection of the drum contents. These trained personnel, who are certified to Rocky Flats Plant (RFP) procedures that implement the Level II SNT-TC-1A standards, use the information on the drum label (Step 3.3.7, Labels), tc detect and document the following:

i (1) Use of polyethylene and 90-mil rigid liners (2) Co? rect waste form description (3) Presence of free liquid (4)

Identification of any other extraneous forbidden articles Nonconforming waste packages are returned to the generator for corrective action with a copy of a Waste Rejection Report, RF-47042, which identifies the specific reason for rejection (see Subsection 1.3).

The data from each of the previous operations, is reviewed by QE personnel who verifies that the information is complete and correct. WIPP certification for that waste package is approved by QE personnel and Computer Operations is notified that the waste package can be added to the load list for shipment and that the information has been verified and can be included in the data package.

6.4 Waste Form Compliance 6.4.1 Imobilization (Particulates)

The components of glass waste are nonparticulate by definition and must be segregated from all o+her unacceptable particulate fines before final packaging (WO-4034 and CO-3001).

Complete inspection by Waste Certification ensures that glass waste meets WIPP/WAC for particulates (WC-4003).

TRU WASTE COMPLIANCE PROGRAM WO 4500-80 D

,jpg/p 7 FOR WIPP-WAC (U) 905 AM

' Examination of TRU Glass Waste after exposurr. to the transportation environment (shipment from RFP to INEL and return) has shown that glass waste remains certifiable during the period of storage and transportation to WIPP.

6.4.2 Free Liquids TRU Glass Waste must be dried, drained, or otherwise segregated from all free liquids (WO-4034 and CO-3001).

In addition, sufficient absorbent is added directly to the waste whenever wet glass is observed to imobilize any liquid that may be desorbed during shipment and storage.

Complete inspection by Waste Certification Inspection and examination of the waste by RTR verify that no unacceptable free liquid is present in the final waste package (WC-4003).

6.4.3 Pyrophorics and Explosives Reactive pyrophories and all explosives are strictly prohibited from TRU waste (WO-4034). These materials are closely controlled and monitored under several RFP safety policies.

Complete inspection by Waste Certification Inspection (WC-4003) and periodic audits per the QA audit schedule ensures that these materials are excluded from TRU waste.

6.4.4 Compressed Gases Closed glass containers which could have internal gas pressure must have an opening through which the gas can be vented and verified by a WC inspector (WO-4034 and WC-4003).

L D

TRU WASTE COMPLIANCE PROGRAM WO-4500-81 7/d/f7 FOR WIPP WAC (U)

DU AM

6.4.5 Radioactive Mixed Waste All corrosive materials must be neutralized or removed from TRU waste (WO-4034). Complete WC inspection ensures that corrosives are excluded j

from TRU waste. All TRU waste packages have either a 90-mil polyethylene liner or an 11-mil PVC liner for corrosion protection.

Toxics can occasionally be co-contaminants in TRU waste. Waste packages with reportable toxies, ignitible, reactive, or corrosive wastes are identified by type and amount in the data package.

l E

TRU WASTE COMPLIANCE PROGRAM WO 4500 82 7/fg/f /

FOR WIPP WAC (U) 00S AM

7.

ATTACHMENT IV: CERTIFICATION OF TRU SOLIDIFIED AQUEOUS WASTE (WF-111)

Contents

)

7.1 Introduction 7.2 Waste Foru Description 7.3 Waste Flow Description 7.4 Wasto Form Compliance 7.4.1 Immobilization (Particulates) 7.4.2 Free Liquids 7.4.3 Pyrophorics and Explosives 7.4.4 Compressed Gases 7.4.5 Radioactive Mixed Wastes i

i 0

TRU WASTE COMPLIANCE PROGRAM WO-4500 83 7/t/y1 FOR WIPP-WAC (U) 00:

AM

' 7.1 Introduction TRU Solidified Aqueous Waste, Waste Fons 111 (WF-111), is composed of IDC-800 (Solidified Sludge, Building 774) and 10C-807 (Solidified Bypass Sludge, Building 374).

These wastes are the product of aqueous waste treatment from all radioactively contaminated waste water streams at Rocky Flats.

Waste Form 111 is the final waste product obtained by mixing the wet sludge with approximately 30 percent portland cement, to form a solid monolithic cast in a lined 55-gallon drum. WF-111 is packaged and shipped in DOT-17C 55-gallon steel dru. s (SX-200) with a 90 mil rigid polyethylene liner (SX-202).

7.2 Waste Fons Description Solidified Apaous Waste (WF-111) is produced by vacuum filtration of solids from pretreated acueous waste slurry.

The filter agent is an inert diatomaceous earth medium that accumulates on a rotating drum.

Solids are trapped on the surface of the filter medium as the pretreated waste solution passes through.

The surface of the filter medium with entrapped filtrate solids is skimmed eff and collected as wet sludge.

The decontaminated effluent is disposed of by an evaporation process.

The wet sludge is blended with portland cement and diatomite mixture (Building 774) in a lined Si, gallon drum (CO-4001 and CO-5014) and forms a solid monolith after curing.

E TRU WASTE COMPl.IANCE PROGRAM WO 4500-84

'/)5/y7 FOR WIPP-WAC (U) pos AM

l The aqueous waste stream is composed of the following (see Subsection 1.2, Waste Generating Activities):

Plutonium Recovery Operations Ion column effluent Evaporator distillates Process filtrates Process condensates Process raffinates Process caustic solutions Support Operations Process sink and drain waste Decontamination and wash solutions 7.3 Waste Flow Description (See Figure 18)

The waste solutions are collected near the point of origin in appropriate tanks as they are generated. The solution is then sampled and analyzed for discardable radioactive content and other controlled components (L-3007).

if the analysis shows the waste is below the discard limit, it is transferred to the liquid waate treatment facility where it is processed j

and converted to wet sludge. The wet sludge is then mixed with portland cement and diatomite mixture (Building 774) in a lined 55-gallon drum.

(C0-9999 lists numerous transfer procedures.)

After the solidified waste has been allowed to obtain initial cure, it is insoected by a WC Inspector (WC-4003). The drum is then closed a.1d sealed. A completed Drum Count label is attached to the lid.

O TRU WASTE COMPLIANCE PROGRAM WO 4500 85 7//5h 7 FOR WIPP WAC (U)

Dul AM

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Recovery Aqueous Operation Waste Gen 1

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Building 771 All Other Buildings Above Discard Lab.

Above Discard

Lab, Assay Assay Below Discard Below Discard v

y Liquid Waste Liquid Waste Treatment Treatment Building 774 Building 374 1

Y Solidification Solidification (In Drum)

(In Drum)

V 1

Inspect Inspect And And Seal Seal V

U Mark, Label, RTR Noncomplying Material (Subsection 1.3) l 9

Certification i

Figure 18. TRU Solidified Aqueous Waste O

TRU WASTE COMPLIANCE PROGRAM WO 4500 86 7/gn,

FOR WIPP-WAC (U) as AM

The concentrations of plutonium and americium in the individual drums is obtained by dividing the batch concentration of plutonium and americium by the number of waste drums produced from that batch (CO 4001, CO-5017, and WO-4034). The total plutonium content for the batch is controlled to 1ess than 200 grams.

For every drus or mixture produced far the Direct Cementation Process (DCP), a dry sludge sample must be taken from Hopper H-3.

A sample vial must be used and be given a number.

The computer printout, drum label, drum number, sampla vial number, and sample results must be recorded in j

the logbook, Room 3801, Building 374.

The Grum is surveyed for surface contamination and radiation dose levels, then sent to Building 664.

The proper "Radioactive" shipping labels and all other required marking and labeling are then affixed to the drum (WO-4034 and Traffic Procedure T-300-1).

The alpha curies, PE curies, and thermal activity are calculated based on gram quantities of the TRU contaminants from the distribution assay based on batch concentrations.

NDT personnel then perform RTR examination of the drum.

These trained personnel, who are certified to Rocky Flats Plant (RFP) procedures that implement Level II SNT-TC-1A standards, use the information on the drum l

label (Step 3.3.7, Labels) to detect and document the following:

(1) Nonconforming items in the package (2) Use of polyethylene and 90 mil rigid liners

)

(3) Correct waste form description (4) Presence of free liquid TRU WASTE COMPLIANCE PROGRAM WO 4500-87 E

FOR WIPP WAC (U)

,7j ops AM

l l

l Rejected Maste packages are returned to the generator for corrective action with a copy of a Waste Rejection Report, RF-47042, which identifies the specific reason for rejection (see Subsection 1.3) There will be 100 percent waste inspection by RTR personnel until data has been established showing control can be maintained through statistical sampling.

Data from each of the above operations is fonvarded to QE personnel who Verify the information is complete and correct.

The QE representative then (1) approves WIPP certification for the waste package, and (2) notifies Computer Operations the waste package can be added to the shipment load list, and the information has been verified and can be l

l included in the data package.

{

7.4 Waste Form Compliance 7.4.1 Immobilization (Particulates)

TRU Solidified Aqueous Waste is cast into a solid monolith according to Procedures CO-4001 and CO-5014.

WC Inspection ensures that operational controls have produced a solid or the moist sludge meets the WIPP Immobilizatien Criterion (WC-4003). WC inspection consists of reviewing i

the microprocessor printout of process parameters, waste, water, and cement amounts for each drum to ensure they are within the established parameters for the cementation process. There will be 100 percent inspection of the processes until data has been established showing control can be maintained through statistical sampling.

Packaging and inspection operations are audited periodically, per the QA audit schedule.

E TRU WASTE COMPLIANCE PROGRAM WO 4500 88 Tdh7 FOR WIPP-WAC (U)

OM AM

' 7.4.2 Free Liquids TRU solidified aqueous waste is cast into a solid monolith according to Procedures CO-4001 and CO-5017. WC inspection of process parameters ensures that operational controls have produced a solid cast without free liquids for the direct cementation process (WC-4003). There will be 100 percent inspection of the processes until data has been established showing control can be maintained through statistical sampling.

RTR examination by NDT personnel ensures that free liquids have not been overlooked in visual examination and that free liquid has not developed after the waste package was closed.

7.4.3 Pyrophorics and Explosives Pyrophoric and explosive materials have not been found in this waste for..

7.4.4 Compressed Gases WF-111 is produced in a closed system which precludes the introduction of extraneous materials such as pressure vessels. Procedures CO-4001, CO-5014, WO-4034, and WC-4003 prohibit pressure vessels from WF-lll.

7.4.5 Radioactive Mixed Wastes No toxic materials (40 CFR 261, Subparts C and D) have been identified in this waste. This waste form is packaged in a DOT-17C, 55-gallon drum with a M-mil polyethylene liner and an ll-mil PVC liner for corrosion protection.

0 TRV WASTE COMPLIANCE PROGRAM WO 4500-89

'745/y /

FOR WIPP-WAC (V) pH AM

8.

ATTACMENT V: CERTIFICATION OF TRU SOLIDIFIED ORGANIC WASTE (WF-112)

Contents 8.1 Introduction 8.2 Waste Fom Description j

8.3 Waste Flow Description 8.4 Waste Fom Compliance 8.4.1 Imobiliation (Particulates) 8.4.2 Free Liquids 8.4.3 Pyrophorics and Explosives 8.4.4 Compressed Gases 8.4.5 Radioactive Mixed Wastes i

i i

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E TRU WASTE COMPLIANCE PROGRAM WO 4500 90 7//5/y7 FOR WIPP-WAC (U) ov AM

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8.1 Introductior.

TRU Solidified Organic Waste, Waste Form 112 (WF-ll2), is a waste form

)

produced by converting liquid organic waste (IDC-801) to a solid by crystallization with Envirostone gypsum cement.

Waste Form 112 is mixed in a DOT-17C, 55-gallon drum with a 90-mil, rigid polyethylen'e liner. The mix sets up and cures in the drum, which is the shipping container.

8.2 Waste Fors Description TRU Solidified Organic Waste (WF-ll2) is produced from liquid or ganics such as oils, solvents, carbon tetrachloride, and lathe coolants

)

(IDC-801).

The liquid organic waste is solidified with a suitable binder (WO-4020).

The organic waste and TRU contaminants are bound in the structure of the binder.

8.3 Waste Flow Description (Figure 19)

The TRU contaminated liquid organics are collected at or near the point of origin in appropriate tanks or containers as they are generated.

The liquid organics are then sampled and an:iyzed for discardable concentrations of plutonium, americium, and other controlled components (L-3007 and FO-707-1000).

E TRU WASTE COMPLIANCE PROGRAM WO-4500 91 ejjfjp FOR WIPP-WAC (U) 00:

AM

\\

l Liquid Organic Waste Generation l

Lab.

Above Discard y Assay Below Discard P

Building 774 Liquid i

Waste Treatment Y

Solidification (in Drum) 1 l

Inspect and Seal I

'l RTR, Mark, and Label Noncomplying Material (Subsectton 1.3)

)

m 1

P Certification l

Figure 19. TRU Solidified Organic Waste E

TRU WASTE COMPLIANCE PROGRAM WO-4500-92 7/g/y i FOR WIPP-WAC (U) yes AM

,.,-__m.

=

If examination of the analysis shows that the waste is below the aiscard limit, it is transferred to ti.e liquid waste treatment facility (Building 774) where it is collected in tanks until enough wasta is accumulated for a "run."

The batch is then homogenized ir preparation for solidification. The total plutonium content for the batch is contred to less than 200 grams.

The waste is then transferred by pipeline to a 55-gallon diam, with rigid liner, which is attached to the mixing box by an 1!-mil PVC 0-ring bag.

Each 32-gallon batch of liquid organic waste is then mixed with the appropriate binder (WO 4020).

Mixing by the high shear impeller contins.es tatil the batch begins to stiffen. The mixer is then removed and the drum of waste is cut off from the mixing box at the 0-ring bag and placed aside for setup to occur (WO-4020).

A WC inspector verifies that solidification has occurred by checking the microprocessor printout of process parameters, and waste and binder amounts for each drum to ensure they are within the established parameters. There will be 100 percent inspection of the process until data has been established 'howing control can be maintained through statistical sampling. The liner and drum arr closed and sealed (WC-003).

A completed Drum Count label is attached to the lid. Data on radioactive content is obtained of dividing the batch radioactive content by the number of waste drums produced from that batch. The drum is surveyed for surface contamination and radiation dor,e levels, then sent to Building 664. The proper ' Radioactive" shipping labels and all other required marking, labeling, are then affixed to the drum (Traffic

? TceJure T-300-1).

t

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a TRU WASTE COMPLIANCE PROGRAM WO-4500 93 FORWIPPWA'(U) 0 05 l

"A4

l The alpha curies, PE curies, and thermal activity are calculated based on the radioactive content assigned to each drum (Steps 3.3.2 and 3.3.5).

NOT personnel then perfom RTR examination of the drum.

These trained personnel, who are certified to Rocky F1;:s Plant (RFP) procedures that implement Level II SNT-TC-1A standards, use the information on the drum label (Step 3.3.7, Labels) to detect and document the following:

(1) Nonconfoming items in the packaga (2) Use of polyethylene and 90 mil rigid liners (3) Correct waste fann description (4)

Presence of free liquid i

Rejected waste packages are returned to the generator for corrective action with a copy of a Waste Rejection Report RF-47042, which identifies the specific reason for rejection (Subsection 1.3).

Data from each of the above operations is fonearded to QE personnel, who verify the information is complete and correct.

The QE representative then (1) approves WIPP certification for the waste package, and (2) notifies Computer Operations that the waste package can be added to the shipment load list, and that the infonnation has been verified and can be included in the data package.

V E

TRU WASTE COMPLIANCE PROGRAM WO 4500-94

,j/jg/y ;

FOR WIPP-WAC (U) ops

8.4 Waste Fom Coseliance 8.4.1 Immobilization (Particulates)

TRU Solidified Organic Wasta is cast into a solid monolith according to Procedure WO 4020. WC Inspection of process parameters ensures that operational controls have produced a solid which meets the WIPP Imobilization Criterion (WC-4003).

There will be 100 percent inspection of the process until data has been established showing control can be maintained through statistical sampling.

Packaging and inspection operations are audited periodically, per the QA audit schedule.

8.4.2 Free Liquids TRU Solidified Organic Waste is cast into a solid monolith according to Procedure WO-4020.

WC Inspection of precess parameters ensures that operational controls have produced a solid cast with no unacceptable free liquids (WC-4003). There will be 100 percent inspection of the process until data has been established showing control can be maintained through statistical sampling.

RTR examination by NDT personnel ensures that free liquids have not been overlooked in visual examinations and that free liquids have not developed after the waste packagt was closed.

8.4.3 Pyrophories and Explosives Pyrophoric and explosive materials have not been found in this waste form. However, any such products would be rendered innocuotis by the solidified matrix of this waste.

I TRU WASTE COEPLIANCE PROGRAM WO-4500 95 7

FOR WIPP-WAC (U) 06!

AM

8.4.4 Compressed Gases WF-112 is produced in a closed system which precludes the introduction i

of extraneous material such as pressure vessels.

Procedures WO-4020, WO-4034, and WC-4003 prohibit pressure vessels from this waste.

J 8.4.5 Radioactive Mixed Waste No toxic materials (40 CFR 261, Subparts C and D) have been identified in this waste. All TRU organic wastes have a 90-mil polyethylene liner and an 11 mil PVC liner for corrosion protection.

4 1

l i

ROGRAM WO-4500-96 8I/5/f7 FOR W PP W C (U i)DJ AM

' 9.

ATTACIMENT VI: CERTIFICATION OF TRU SOLIDIFIED LAB 0kATORY WASTE (WF-113)

Contents 9.1 Introduction 9.2 Waste Form Description 9.3 Waste Flow Description 9.4 Waste Form Compliance 9.4.1 Immobilization (Particulates) 9.4.2 Free Liquids 9.4.3 Pyrophorics and Explosives 3.4.4 Compressed Gases 9.4.5 Radioactive Mixed Wastes

\\

l I

TRU WASTE COMPLIANCE PROGRAM WO 4500 97 E

, g fy7 FOR WIPP-WAC (U) 001 AM

' 9.1 Introduction TRU solidified laboratory waste, Waste Form 113 (WF-113), is composed of aqueous wastes which are not compatible with the primary liquid waste stream. WF-113 (IDC 802, special setups) is solidified with a mixture of portland cement and magnesia cement in Waste Treatment Building 774 by a batch method.

WF-ll3 is packaged and shipped in Type A, 007-17C, 55 gallon drums (SX 200) with 90 mil rigid polyethylene 16ers (SX-202).

9.2 Waste Form Oescription Solidified laboratory waste specifically means the processing of those l

aqueous wastes which are intentionally excluded from the normal liquid waste treatment process and which are imobilized and rendered innocuous by a process which is tailored for each batch.

A batch may be as little as I liter, or as much as several hundred liters of waste solution.

Each batch must be accompanied by a Waste Processing Request Form and a Laboratory Analysis Form.

The WPRF is completed by the waste generator.

The WPRF sust describe the origin and composition of the waste and give any special instructions for safe handling of the waste (if appropriate).

The laboratory analysis will provide information on the amount and isotope of discarded radioactive material and additional chemical inforeation if requested.

E TRU WASTE COMPLIANCE PROGRAM WO 4500 98

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FOR WIPP WAC (U) 06:

1 Inl

~

i

TRU laboratory wastes are generated in the Analytical laboratories, Research and Development laboratories, and occasionally in special project operations.

Laboratory wastes z.e not discarded into the primary aqueous waste stream because they contain complexing agents and other chemicals which could disrupt normal waste treatment operations.

)

Special setups (IDC-802) are made by adding 80 - 100 liters of lab waste to a previously prepared drum containing 188 pounds of portland cement and approximately 130 pounds of magnesia cement (WO 4021).

The cement mixture has proven to oe an excellent media for the imobilization of these wastes.

This combination of cements allows complete absorption and solidification to occur in the the waste form.

9.3 Waste Flow Description (See Figure 20)

TRU laboratory wastes are collected in a 4-liter (poly) bottle at the point of origin. When enough waste has accumulated to make a transfer, each bottle is identified by serial number and sampled.

The sample is analyzed for plutonium and americium content and other TRU materials, if known to be present.

The grams per liter radioactive content is recorded and rerified as being below the discard limit. The total grams of plutonium and/or americium is then recorded on the WPRF for the batch. The total plutonium content for the batch is controlled to less than 200 grams.

D 1P.0 WASTE COMPLIANCE PROGRAM WO-4500 99 7/g/p FOR WIPP WAC (U)

ODS AM

Special Laboratory Recovery Operations Above Discard S wple Antlysis Below Discard v

Liquid Waste Treatment Building 774 P

Solidification (In Drum) 1 Inspect and Seal Y

Mark Label, RTR Noncomplying Material (Subsection 1.3)

Y Certification Figure 20. TRU Solidified Laboratory Waste m v.

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TRU WASTE COMPLIANCE PROGRAM W0 4500-100 14/7??

FOR WIPP-WAC (U)

(JDJ

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  • The batch, with each container identified, is then transferred to Waste Operations, Building 774.

The Waste Operations supervisor then reviews the WPRF and assay information and accepts the transfer.

Each container is then entered into a logbook by serial number and batch.

When enough waste has been accumulated to make a "run," the batches are grouped together in 80 - 100 liter drum batches.

The drum number is then entered in the logbook for each drum batch.

The drum batch is then neutralized if necessary, and "poured" by emptying the contents of each container assigned to that drum batch into the premixed cement.

Procedure WO-4021, Miscellaneous Aqueous Waste Handling and Solidification, specifies the amount of cement and liquid waste which is added to the drum to ensure a waste form complying with the WIPP-WAC.

The drum of immobilized waste is then disconnected from the glovebox via the bag cut-off procedure.

After the waste has been allowed to obtain initial cure, it is inspected by a WC inspector (WC-4003).

The drum is then :losed and sealed.

A completed Drum Count label is attached to the lid. Radioactive content is obtained by adding the content of each batch which was placed in the drum.

l

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E TRU WASTE COMPLIANCE PROGRAM WO 4500 101 p/jg:/y-1 FOR WIPP WAC (U) j Q DS Aid J

i

E The drum is surveyed for surface contamination and radiation dose levels.

The alpha curies, PE curies, and thermal activity are calculated based on gram quantities of the TRU contaminants from the total assay of each batch added to the drum. All required informatiot. is entered on a Drum Count label and is then sent to Building 664.

The proper "Radioactive" shipping labels and all other required marking and labeling are then affixed to the drum (Traffic Procedure T-300-1).

NDT personnel then perform RTR examination of the drum.

These trained personnel, who are certified to Rocky Flats Plant (RFP) procedures that implement the level 11 SNT-TC-1A standards, use the information on the drum label (Step 3.3.7, Labels) to detect and document the following:

(1) Nonconforming items in the package (2) Use of polyethylene and 90-mil rigid liners (3) Correct waste form description (4) Presence of free liquid Rejected waste packages are returned to the generator for corrective action with a copy of a Waste Rejection Report RF 47042 which identifies the specific reason for rejection (see Step 1.3.2).

There will be 100 percent inspection of the waste by RTR until data has been established showing control can be maintained through statistical sampling.

Data from each of the above operations is forwarded to QE personnel who verify the information is complete and correct.

The QE representative then (1) approves WIPP certification for the waste package, and (2) notifies Computer Operations the waste package can be added to the shipment load list, and the infomation has been verified and can be included in the data package.

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TRU WASTE COMPLIANCE PROGRAM WO-4500 102

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FOR WIPP-WAC (U)

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' 9.4 Waste Fors Compliance 9.4.1 Issnobilization (Particulates)

TRU solidified laboratory waste is cast into a solidified waste forn according to Procedure WO 4021.

WC inspection ensures that operational i

controls have produced a solid which meets the WIPP Inunobilization Criterion (WC-4003). There will be 100 percent inspection of the process until data has been established showing control can be maintained through statistical sampling. Packaging and inspection operations are audited periodically per the QA audit schedule, i

l 9.4.2 Free Liquids TRU solidified laboratory waste is cast into a solidified waste form according to Procedure WO-4021. WC inspection ensures that operational controls havs produced a solid which meets the WIPP Imobilization Criterion (WC-4003).

There will be 100 percent inspection of the process until data has been established showing control can be maintained through statistical sampling.

RTR examination by NDT personnel ensures that free liquids have not been overlooked in visual examination and that free liquid has not developed after the waste package was closed.

9.4.3 Pyrophories and Explosives Pyrophoric and explosive materials have not been found in this waste 4

fona. However, any such products would be rendered innocuous by the solidified u trix of this waste.

O TRU WASTE COMPLIANCE PROGRAM WO-4500-103 r//pf7 FOR WIPP WAC (U) r>M AM

1 i

I 9.4.4 Compressed Gases WF-ll3 is produced in a closed system which precludes the introduction of extraneous material such as pressure vessels.

Procedures WO 4021, WO-4034, and WC 4003 prohibit pressure vessels from WF-ll3.

j 9.4.5 Radioactive Mixed Waste TRU solidified laboratory waste has been processed so that potentially corrosive liquids are permanently fixed. This waste form is packaged in a DOT-17C, 55-gallon drum with a 90-mil polyethylene liner and an ll mil

~

PVC liner for corrosion protection.

Toxics as defined in 40 CFR 261, Subparts C and D in reportable quantities, ignitible, reactive, or corrosive waste are identified by type and amount in the data package.

1 1

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TRU WASTE COMPLIANCE PROGRAM WO-4500-104 FOR WIPP WAC (U)

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I 10.

ATTACHMENT VII: CERTIFICATION OF TRU GRAPHITE WASTE (WF-115)

Contents 10.1 Introduction 10.2 Waste Form Description 10.3 Waste Flow Description 10.4 Waste Form Compliance 10.4.1 Immobilization (Particulates) 10.4.2 Free Liquids 10.4.3 Pyrophorics and Explosives 10.4.4 Compressed Gases 10.4.5 Radioactive Mixed Waste l

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D TRU WASTE COMPLIANCE PROGRAM WO 4500 105

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FOR WIPP WAC (U)

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10.1 Introduction TRU graphite waste is generated by the plutonium foundry (Building 707) and by plutonium metallurgy, R&D (Building 771). The waste is identified as IDC 300-graphite molds. TRU graphite waste is packaged in DOT-17C, 55-gallon steel drums with a rigid liner.

Graphite waste packages arc.

limited to 200 pounds net graphite and 200 grams of plutonium (WO 4034).

10.2 Waste Form Description TRU graphite waste consists of graphite molds, Scarfed graphite chunks, and coarse graphite pieces which have been used for casting molten plutonium (10C 300).

Graphite molds are cut from solid bit.cks, logs, or slabs which have high mechanical strength. The mechanical strength of sold graphite is I

sufficient to prevent the formation of fines and particulates during normal handling.

Graphite molds may be used several times before they become unusable and are discarded as waste. Discarded molds are cleaned to remove plutonium metal which may be stuck to the surface or embedded in the mold (FO-707-1012).

Classified graphite molds must be processed in such a way as to obliterate the mold shape and identification (WO-4034 and FO-707-1012).

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D TRU WASTE COMPLIANCE PROGRAM WO 4500 106 yfff} /

FOR WIPP-WAC (U) pos g

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i' 10.3 Waste Flow Description (See Figure 21) l l

TRU graphite waste molds are cleaned and inspected in the glovebox to ensure that recoverable plutonius has been removed from the molds.

This operation is performed b,w foundry personnel (WO 4034 and FO-707-1012).

The waste molds are segregated from all noncomplying mates ti s,

prepackaged, and removed from the glovebox via a routine bagout ope,ation and placed into a 55-gallon waste drum or placed directly into a 55 gallon l

waste drum which is connected to the glovebox by an ll mil PVC 0-ring bag.

The drum is inspected by a WC Inspector then closed and sealed.

There will be 100 percent inspection of the process until data has been established showing control can be maintained through statistical l

sampling.

A completed Drum Count label is attached to the lid.

The drum is then transferred to the drum counter for assay. The results of this assay determine if the contents are above or below the discard level (C01103 and C0-1106). The fissile gram values are entered on the Drum Count label for each radionuclide.

The gram values fcr plutonius, americium, and any other TRU materials determined by the drum counter assay are entered into the computer. The computer is used to calculate the alpha curies, PE curies, and thermal activity of the waste package based on these gram quantities.

This information is reported in the data package along with the gram quantities j

plutonium, americium, and any other TRU materials (Steps 3.3.2 and 3.3.5).

1 V TRU WASTE COMPLIMfCE PROGRAM WO 4500-107 D

FOR WIPP-WAC l)

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m Foundry Operetion I

Drum - WC Inspect, Close, and Seal j

l run m m w. niteard Count Below Discard Building 776 Shred Class.'

Repkg - WC Inspect, Yes Yes or Close, and Seal

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Drum t.atel and Assay Data -

Drum Count Assay

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Enter in Comp.

9 Printout of Calculated Alpha Curies, PE Curies, and Thermal Activity T

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Mark, Label, RTR Honcomplying Material (Subsection 1.3)

I Data Package Insp.

y Certification Figure 21. TRU Graphite Waste

.,4 TRU WASTE COMPLIANCE PROGRAM WO 4500108 E

77, FOR WIPP WAC (U) ou AM

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l The computer is programmed to flag any waste having an excess of the allowed fissile material limit. The waste package will then be rejected for shipment.

If the drum contains classified graphite shapes, it is sent to Size Reduction, Building 776, for shredding to declassify the waste, and then repackaged into a drum.

This waste is inspected by WC Inspection as it is repackaged. The drum is assayed again by the drum counter to verify the radionuclide content.

The container is surveyed for surface contamination, surface dose rate, and radiation reading at 1 meter.

These survey results are entered on the Drum Count label. Radiation Monitoring signs the fonns verifying the infermation is correct (Radiation Monitoring Manual).

The waste package is sent to Building 664 with the Drum Count label which has been approved by a WC inspector (WC-4003 and WO-4034).

The drum will be labeled with any required shipping labels (Traffic Procedure T-300-1). Real-time radiographic examination is then performed by NDT personnel. These trained personnel, who are certified to Rocky Flats Plant (RFP) procedures that implement the level II SNT-TC-1A standards, use the information on the drum label (Step 3.3.7, Labels) to detect and document the following:

j (1) Nonconforming items (2) Use of polyethylene and 30-mil rigid liners (3) Correct waste form description (4) Presence of free liquid i

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l TRU WASTE COMPLIANCE PROGRAM WO 4500 109

)

FCR WIPP WAC (U) j DOS "A3

4 1

Nonconfoming waste packages are returned to the generator for corrective action with a copy of a Waste Rejection Report RF 47042, which identifies the specific reason for rejection (see Step 1.3.2).

There will be 100 percent inspection of the waste by RTR until data has been established showing control can be maintained through statistical sampling.

Data from each of the above operations is reviewed by QE personnel who verify that the information is correct and complete.

The QE representative then approves WIPP certification for that waste package and notifies the Computer Operations group that the waste package can be added to the shipment load list and that the information has been verified and can be included in the data package.

10.4 Waste Form Compliance 10.4.1 Immobilization (Particulates) 1 TRU graphite waste is a nonparticulate waste form. Structural strength of the graphite is sufficient to resist the fematicn of particulates during shipping and handling, as demonstrated by the examination of graphite waste as part of the INEL Examination of Stored Waste Project.

Shrtdded graphite has been shown to meet the WIPP ! mobilization Criterion j

in an internal report. WC inspections at the waste bagout ensure that unacceptable particulates have not Leen added to the waste package (WO-4034 and WC-4003).

10.4.2 Fres Liquids

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TRu graphite waste contains no free liquid. Direct inspection of the waste by WC inspectors and RTR examination of the waste package ensure that no free liquid is present in the waste package (WO 4034 and WC-4003),

v TRU WASTE COMPLIANCE PROGRAM WO 4500 110 l

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10.4.3 Pyrophorics and Explosives TRU graphite waste contains no pyrophoric material other than discard levels of radionuclides.

Pyrophorics and explosives are prohibited from all waste packages (WO-4034). WC inspection of each container and periodic QA audits ensure that pyrophorics and exolosives are excluded from the waste package.

10.4.4 Compressed Gases Pressure vessels may not be packaged with TRU graphite waste (WO 4034).

WC inspection and RTR examination of each waste package ensures that pressure vessels are excludet from the waste (WC-4003).

10.4.5 Radioactive Mixed Waste TRU graphite waste contains no hazardous materials (WO-4034). WC inspection of each waste container and routine audits by Quality Engineering ensure that hazardous materials are ' excluded from graphite waste (WC 4003).

O TRU WASTE COMPLIANCE PROGRAM WO 4500 Ill 1Ar/y1 FOR WIPP WAC (U)

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11.

ATTACIMENT VI!!: CERTIFICATION OF TRU ORGANIC SOLID WASTE (WF-121) l r

Contents 11.1 Introduction i

11.2 Waste Form Description j

11.3 Waste Flow Description i

11.4 Waste Form Compliance l

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' 11.1 Introduction Waste Form 121, TRU Organic Solid Waste, consists of materials identified as 10C-302, Benelex and Plexiglas.

10C-302, Benelex and Plexiglas, are massive sheets or slabs of material used as radiation shielding around gloveboxes, tanks, and equipment.

Benelex and Plexiglas are packaged in DOT-7A, Type A, steel boxes lined with fiberboard and an 11-mil PVC liner (SX-209).

11.2 Waste Form Description TRU Organic Solid Waste (WF 121) refers specifically to large, massive (2-or 4-inch thick) sheets or slabs of solid organic material used as neutron shielding around gloveboxes, tanks, or high radiation equipment.

I Benelex and Plexiglas are manufacturer's trade names; however, those terms are generically used here to describe materials of the same or similar composition.

Experience has confirmed that gas generation from Benelex and Plexiglass is negligible.

Benelex and Plexiglas are not combustible materials (as defined) because they will not support combustion when the heat source is removed.

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TRU WASTE COMPLIANCE PROGRAM WO 4500 ll3 1)s/97 FOR WIPP WAC (U) 00J

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l 11.3 Waste Flow Description (See Figure 22)

Benelex and Plexiglas waste is generated during strip out (D&D) cperations. This waste is considered TRU waste only if the Radiation Monitoring survey results indicate high enough contamination levels (WO-4034, WO-4033, WC-4003, and Radiation Monitoring Manual).

The waste is gamma-scanned to determine the assay gram value to be assigned to the waste (WC-4003).

The waste is then placed directly into a waste box and the data for that item is entered on the WBLS.

The waste box is locked closed at all times. Waste is placed into the waste box only in the presence of a WC inspector who has cu tody of the waste box keys.

The waste box liners and a certified filter / vent unit are installed by Waste Operations personnel (WO 4034). The liners and filter / vent unit are inspected by a WC inspector (WC-4003). When the box

)

is full, the liners are closed and sealed, and the box is surveyed for surface contamination.

Radiation readings are taken at the surface and at 1 meter and are recorded on the WBLS. All required data is then entered on the WBLS which accompanies the waste box to the lid welding station in Building 776.

The lid is then welded on the waste box, providing a tamper-proof seal.

The waste box is leak-tested and inspected (WC-4003). The waste package is then sent to Building 664 along with the WBLS which has been approved by a WC inspector (WC-4003).

At Building 664, the wkste pxckage receives final assay in the crate counter (C0-7006).

It is marked and labeled according to the information on the WBLS (WO 4034 and Traffic Procedure T-300-1). A waste review board determines actions to be taken on assay discrepancies, i

D TRU WASTE COMPLIANCE PROGRAM WO-4500 Il4 3

7/d/p7 FOR WIPP WAC (U) pH AM

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Stripout Operation e

i R.M.*

LLW Survey Survey i

TRU Below Discard P

Packaged in Waste Box Y

WC Inspect, I

Close, and Seal Box Y

Crate Assay e

Mark, Label, RTR Noncomplying Material (Subsection 1.3) n Certification

  • R4distion Monitoring i

Figure 22. TRU Benelex and Plexiglas Waste i

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TRU WASTE COMPLIANCE PA0 GRAM WO 4500 Il5 j

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NOT personnel then perfom RTR examination of t!e package.

These trained personnel, who are certified to Rocky Flats Plant (RFP) procedures that implement the Level !! SNT-TC 1A standards, use the information on the WBLS (Step 3.3.7, Labels) to detect and docueent the following-(1) Nonconforming items in the package (2) Use of fiberboard and polyethylene liners (3) Correct waste form description (4)

Presence of free liquid Nonconforming waste packages are returned to Size Reduction for corrective action with a copy of a Waste Rejection Report RF-47042, which identifies the specific reason for rejection (see Step 1.3.2).

Data from each of the above operations is reviewed by QE personnel who verify that the information is complete and corract. The QE l

representative then (1) approves WIPP certification for the waste package, and (2) notifies Computer Operations that the waste package can be added to the shipment load list and that the information has been verified and can be 11cluded in the data package.

11.4 Waste Form Compliance TRU organic solid waste (Benelex and Plexiglas) meets all of the waste form requirements in such an obvious and straightforward manner that it is unntcessary to list each one separately.

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.g TRU WASTE COMPLIANCE PROGRAM WO-4500-Il6 7/g/y7 FOR WIPP-WAC (U) 00S AM

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Benelex and Plexiglas are not particulate, liquid, sludge, pyrophoric, explosive, or toxic. This waste form may not be packaged with particulates, liquids, pyrophorics, explosives, pressure vessels. toxies, ignitible, reactive, or corrosive waste (WO 4034 and WC 4003).

WC inspection and RTR examination verify TRU solid organic waste compliance (WC-4003),

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TRU WASTE COMPLIANCE PROGRAM WO 4500 Il7 i

E 7h5//7 FOR WIPP WAC (U) i ops mag

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12.

ATTACHMENT IX: CERTIFICATION OF TRil INORGANIC SOLID WASTE (WF-122)

Contents 12.1 Introduction 12.2 Waste Forn Description 12.2.1 Firebrick (IDC-371) 12.2.2 Oil Dri (IDC-375) 12.3 Waste Flow Description 12.4 Waste Form Compliance 12.4.1 Inmobilization (Particulates) 12.4.2 Free Liquids 12.4.3 Pyrophorics and Explosives 12.4.4 Compressed Gases 12.4.5 Radioactive Mixed Wastes q

D TRU WASTE COMPLIANCE PROGRAM WO-4500-118 yyg/yy FOR WIPP-WAC (U)

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F 12.1 Introduction TRU inorgani: solid waste (WF-122) is coverised of Firebrick (IDC-371) and Oil Dri (IDC-375). These materials do not require processing in order to meet WIPP Waste Acceptance Criteria.

Examination of retrieved waste shows that this waste is unaffected by the transportation environment.

TRU inorganic solid waste is packaged in DOT-17C 55 gallon steel drums with a 90 mil, rigid polyethylene liner (SX-202) or repackaged into a DOT-7A steel box (SX-231) with an 11-mil PVC liner (SX-209).

12.2 Waste Fora Description 12.2.1 Firebrick (IDC-371) refers to high-density refractory clay insulating materials.

Firebrick becomet TRU waste when plutonium processing furnaces or incinerators are dismantled or repaired.

Firebrick is cleaned and Scarfed be. fore disposal (CO-1039 and CO-6017).

12.2.2 Oil-Dri (IDC-375) is an absorbent clay which is placed in waste packages containing damp materials.

Oil-Dri becomes a specific waste item when it is collected and packaged by itself. Oil-Dri is collected when waste is put back into the glovebox system for repackaging or reprocessing.

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TRU WASTE COMPLIANCE PROGRAM WO 4500-119

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V 12.3 Waste Flow Description I

12.3.1 Waste Flow Description for Drums (See Figure 23)

TRU inorganic solid waste is first segregated from all noncomplying materials inspected by WC waste inspectors, as it is removed from the glovebox by a standard bagout operation, placed in a drum, and sealed with a tamper-proof seal (WC-4003).

There will be 100 percent inspection 1

of the process until data has been established showing control can be maintained through statistical sampling.

1 A completed Drum Count label is then attached to the lid.

The drum is l

then surveyed for surface contamination and surface dose rate. These survey results are entered on the label and then verified by the signature of a Radiation Monitor (WO-4034 and Radiation Monitoring Manual).

}

l The drum is then transferred to the drum counter for assay.

The results of this assay determine if the contents are above or below the discard level (C0-1103 and C0 1106).

The gram values are entered on the TRU Drum Count label for each radionuclide.

The gram values for plutonium, americium, and any other TRU materials, as determined by the drum counter assay, are entered into the computer. The computer is used to calculate the alpha curies, PE curies, and themal activity of the waste package based on these gram quantities. This information is reported in the data package along with the gram quantities of plutonius, americium, and any other TRU materials (Steps 3.3.2 and 3.3.5).

O TRU WASTE COMPLIANCE PROGRAM WO-4500-120

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FOR WIPP-WAC (U) op

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Segregate Y

Bagout into Drum -

WC Inspect and Seal Drum Count Above Discard Assay Below Discard v

Enter Assay and Drum Label Informa-tion into Computer Y

Printout of Calculated Alpha Curies, PE Curies, and Thermal Activity Y

Mark, Label, RTR Noncomplying Material (Subsection 1.3),

m Data Pkg Inspected Y

Cert!fication Figure 23. TRU Inorganic Solid Waste E

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TRU WASTE COMPLIANCE PROGRAM WO-4500-121 FORWIPPWAC(U) yM AM

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The computer is programmed to flag any waste having an excess of the allowed fissile material limit.

This waste package will then be rejected for shipment.

Quality Engineering will inspect the data package for each waste container to ensure completeness prior to certification and transmission to the WIPP.

The inspected and sealed waste drum is then sent to Building 664 (WC-4003 and WO-4034) if the waste is not to be repackaged into a box.

)

The drum will be labeled with any required shipping labels (WO 4034 and Traffic Procedure T-300 1).

Real-time radiographic examination is then performed by NDT personnel.

These trained personnel, who ar,e certified to Rocky Flats Plant (RFP) procedures that implement Level II SNT-TC-1A standards, use the information on the drum label (Step 3.3.7, Labels) to detect and document the following:

6 (1) Nonconforming items (2) Use of polyethylene and 90-mil rigid liners (3) Correct waste form description (4)

Presence of free liquid Nonconforming waste packages are returned to the generator for corrective action with a copy of a Waste Rejection Report RF-47042, which identifies the specific reason for rejection (see Step 1.3.2).

There will be 100 percent inspection of the waste by RTR until data has been established showing control can be maintained through statistical sampling.

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TRU WASTE COMPLIANCE PROGRAM WO-4500-122 ggg/y1 FOR WIPP-WAC (U)

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Data from each of the above operations is reviewed by QE personnel who verify that the information is correct and complete. The QE representative then approves WIPP certification for that waste package and notifies the Computer Operations group that the waste package can be added to the shipment load list and that the informatior has been verified and can be included in the data package.

12.3.2 Waste Flow Description for Boxes (See Figure 24)

If the TRU inorganic solid waste is to be repackaged into a box, then it is first segregated from all noncomplying materials, prepackaged, and removed from the glovebox by a standard bagout operation.

The waste is then placed in a DOT-17C 55-gallon steel drum with two "barrel bag" liners.

l When the waste drum is full, the liners are closed and sealed and the steel drum lid is attached with a bolted closure ring.

A completed Drum Count label is then attached to the lid. The drum is then surveyed for surface contamination and surface dose rate.

These survey results are entered on the label and then verified by the signature of a Radiation Monitor (WO-4034 and Radiation Monitoring Manual).

The drum is then transferred to the drum counter for assay.

The results of this assay determine 'f the contents are above or below the discard level (CO-1103 and CO-1106). The gram values are entued on the Drum Count label for each radionuclide.

l i

E TRU WASTE COMPLIANCE PROGRAM WO 4500 123 7/6// '

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Segregate P

Bagout into Drum o

Drum Count Above Discard Assay Below Discard Unacceptable Material Bldg 776 Repkg, insp.

Subsection 1.3 v

Enter Assay and Drum t.abe) Information into Computer F

Printout of Calculated Alpha Curies. PE Curies, and Thermal Activity v

Mark, Label, RTR Unacceptable Material subsection 1.3 Data Pkg Inspected o

Certification Figure 24. TRU Inorganic Solid Waste E

D TRU WASTE COMPLIANCE PROGRAM WO-4500-124 l

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' The gram values for plutonium, americium, and any other TRU materials, as determined by the drum counter assay, are entered int: the computer. The computer is used to calculate the alpha curies, PE curies, and thermal activity of the waste package based on these gram quantities.

This information is reported in the data package along with the gram quantities of plutonium, americium, ar:d any other TRU materials (Steps 3.3.2 and 3.3.5).

The waste drum and a completed Drum Count label are then sent to Size Reduction in Building 776.

The waste is repackaged into a lined box under controlled conditions in the oarlock of the SRR vault.

The data from each drum are transferred to a WBLS when the drums are opened, and the waste is transferred to the waste box (WO-4016 and WC-4003).

Each fiberpack or bag is opened, inspected by a WC inspector, and distributed in the waste box to obtain greater packing density.

This inspection detects and eliminates all noncomplying materials (WC 4003).

Noncomplying materials which require processing are retvrned to the generator with the Waste Rejection Report (RF-47042). A copy of the WRR stating the corrective action taken must be returned to Qaality Engineering (Subsection 1.3).

Waste box liners and a certified filter / vent unit are installed by Waste Operation personnel (WO 4034).

The liners and filter / vent unit are inspected by a WC inspector (WC-40C3).

When the box is full, the liners are closed and sealed, and the box is surveyed for surface contamination.

Radiation readings are taken at the surface and at 1 meter, and are recorded cn the WBLS.

j 1

o TRU WASTE COMPLIANCE PROGRAM WO 4500-125 gjgjyy FOR WIPP-WAC (U) i UU AM

l The lid is welded on, providing a tamper-proof seal. The waste package is then sent to Building 664 with the TRU waste label and the WBLS which has been approved by the WC inspector (WC 4003).

At Building 664, the box is weighed and the weight is stenciled on the box.

The box then receives final assay in the crate counter (CO-7006).

This assay must agree with the cumulative assays obtained by the drum count, within the limits of error assigned to each assay method. A waste review board determines actions to be taken on assay discrepancies.

The proper "Radioactive" shipping labels and all other required marking and labeling are then affixed to the box (Traffic Procedure T-300-1).

Real time radiographic examination is then performed by NDT personnel.

These trained personnel, who are certified to Rocky Flats Plant (RFP) procedures that implement the Level II SNT-TC-1A standards, use the information on the WBLS (Step 3.3.7, Labels) to detect at d document the following.

(1) Nonconforming items (2) Use of fiberboard and polyethylene liners (3) Correct waste form description (4) Presence of free liquid Nonconforming waste packages are returned to the generator for corrective action with a copy of Waste Rejection Report RF-47042, which identifies the specific reason for rejection (see Step 1.3.2).

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TRU WASTE COMPLIANCE PROGRAM WO-4500-126 7/d/p FOR WIPP WAC (U) i ON AM

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Data from each of the above operations is reviewed by QE personnel who verify that the information is correct and complete. The QE representative then approves WIPP certification for that waste package and notifies the Computer Operations group that the waste package can be added to the shipment load list and that the information has been verified and can be included in the data package.

12.4 Waste Form Compliance 12.4.1 Immobilization (Particulates)

TRU Inorganic solid waste does not require processing to imobilize i

particulates.

Firebrick is not a particulate weste and must be segregated from particulates during packaging (WO-4034).

Oil Dri is a particulate waste; however, particle size analysis shows that this waste is well within the limits of the WIPP waste acceptance criteria and must be segregated from other particulate material before packaging (WO 4034).

12.4.2 Free Liquids TRU inorganic solid waste contains no free liquid. Direct inspection of the waste by WC inspectors and RTR examination of the waste package ensures that no free liquid is present (WO-4034 and WC-4003).

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4 12.4.3 Pyrophorics and Explosives TRU inorganic solid waste contains no pyrophoric or explosive materials.

i Pyrophorics and explosives are prohibited from all waste packages (WO 4034).

WC inspection of each package and periodic audits per the QA audit schedule ensures that pyrophorics and explosives are excluded from the waste package (WC 4003).

12.4.4 Compressed Gases Pressure vessels may not be packaged with TRU waste (WO-4034). WC inspection and RTR examination of each waste package ensures that pressure vessels are excluded from the waste (WC-4003).

l 12.4.5 Radioactive Mixed Waste TRU inorganic solid waste contains no hazardous or corrosive materials (WO 4034).

WC inspection of each waste package and periodic audits per the QA audit schedule ensures that hazardous and corrosive materials are excluded from the waste (WC-4003).

0 TRU WASTE COMPLIANCE PROGRAM WO 4500-128

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  • 13.

ATTACHMENT X: CERTIFICATION OF TRU FILTER WASTE (WF-119)

Contents 13.1 Introduction 13.2 Waste Form Description 13.2.1 Absolute Dry Box Filters (IDC 335) 13.2.2 HEPA Filters (IDC-490) 13.2.3 Ful-Flo Filters (IDC-328) s, I?.2.4 Filter Media (IDC-338) 13.2.5 Processed Filter Media (10C-376)

)>

13.2.6 Plenum Prefilters (IOC-491) 13.3 Waste Flow Description 13.4 Waste Form Compliance 13.4.1 Innobilization (Particulates) 13.4.2 Free Liquids 13.4.3 Pyrophorics and Explosives 13.4.4 Compressed Gases 13.4.5 Radioactive Mixed Wastes l

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13.1 Introduction i

TRU Filter Waste (WF-119) is comprised of absolute dry box filters (IDC-335), high efficiency particulate air (hEPA) filters (IDC-490),

filter media (IDC-338), Ful Flo filters (IDC 328), and processed filter media (IDC-376), and plenum prefilters (IDC 191).

The absolute dry box filters (IDC-335), Ful-Flo filters (IDC-328), and filter media (IDC-338) are mixed with portland cement which neutralizes acid and adsorbs any residual liquid to meet the WIPP Waste Acceptance Criterion. Waste forms of IDC's 335, 328, and 338 are identified as

)

processed filter media (100-376) after mixing with dry portland cement.

l HEPA filters (IDC 490) are crushed and placed directly into a waste box.

TRU Filter Waste is packaged in DOT-17C, 55 gallon steel drums (SX 200) with a 90 mil rigid polyethylene liner (SX-202) or a DOT-7A steel box (SX-231) with an ll-mil PVC liner (SX-209).

13.2 Waste Form Description 13.2.1 Absolute dry box filters (IDC-335) refer to filters approximately 8 x 8 x 6 inches which are used at the gloveboxes for filtering intake and exhaust air. Other filter sizes include 8 x 8 x 4 inches and 12 x 12 x 6 inches.

The filters are composed of wood or particle board frames and a fiberglass-type filter media. The absolute filters are processed as

)

Content Code 376 (Processed filter media) or Content Code 490 (HEPA Filters).

The filter is mixed with portland cement to neutralize the residual acid and adsorb any residual liquid.

TRU WASTE COMPLIANCE PROGRAM WO-4500-130 I

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' 13.2.2 HEPA (10C-490) filters are used on all ventilation intake and exhaust systaas. Only the filters from the first stage of the four-stage exhaust system in plutonium processing areas are considered TRU waste and are segregated during processing and packaging from the second, third, and fourth stage filters, The Size 5 filter frames (2-x 2-x l-foot) can be either wood or aluminum.

Filter media is fiberglass-type (Nomex) media.

13.2.3 Ful-Flo filters (IDC-328) consist of fibrous polypropylene filter media and are used to remove particulates from liquid streams.

The waste is bagged out of the glovebox and placed in a prepared 55 gallon drum.

13.2.4 Filter media (10C-338) consists of filter media (fiberglass).

The filter media is generated from splitting absolute and HEPA filters l

apart in the process areas.

Any loose particulate materials are dislodged from the filter during this process and disposed of separately.

Filter media is packaged by placing the media into a 1-gallon polyethylene bottle or in a polyethylene bag and double bagged out of the glovebox.

Each bottle or bag is placed in a prepared 55 gallon drum.

13.2.5 Processed filter media (IDC-376) consists of Ful-Flo, filter media, and whole filters, portland cement is added to all waste packages as a precautionary measure to neutralize any residual nitric acid that may be present in the waste.

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  • The waste is initially packaged into drums by each waste generating area (as Content Codes 335, 328, and 338 wastes) and then assayed for plutonium content in Building 771. Waste contaminated with discardable amounts of plutonium are then transported to Size Reduction (Building 776). All

)

filter media wastes are processed by Size Reduction. After the waste is processed, it is relabeled as Content Code 376. An exception: Absolute dry box filters (100 335) from nonacid lines may be packaged into boxes with first stage HEPA filters (10C-490).

)

13.2.6 Plenum prefilters (IDG-491) are positioned in front of the HEPA filters on the same exhaust system.

Plenum prefilters are bagged out of a plenum and placed into a prepared 55-gallon drum.

13.3 Waste Flow Description (See Figures 25 and 26)

Each absolute dry-box filter removed from a glovebox is double contained in plastic bags, sealed with tape, and placed in a 55-gallon drum.

Generally, absolute filters are dry when packaged. Adsorbent (Oil-Dri) is added to any bags containing damp filters. A completed drum label is attached to the lid.

HEPA filters, removed from plutonium process area filter plenums, are double bagged and placed in cardboard cartons.

The cardboard cartons are then placed in appropriate metal containers for transfer to the drum countae for assay.

The cartons are surveyed for surface contamination and surface dose rate.

The stage each HEPA filter is taken from is marked on the cardboard carton. The first stage filters are segregated from the second, third, and fourth stage filters. The second, third, and fourth stage filters are identified as "nonline generated' and assayed on the Passive / Active Crate Counter (C0-1107) to verify they are LLW.

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TRU WASTE COMPLIANCE PROGRAM WO 4500-132 7//f/f7 FOR WIPP WAC (U) 00:

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i Remove from Plenum y

Placement in a Cardboard Box / Metal Container o

2nd, 3rd Segregation of 1st Stage LLW :

from 2nd, 3rd, 4 4th Stage 4 4th Stage (10C-490)

Orum Above Discar Count Assay Below Discard Repackage Inspect i

Y Enter Assay and WBLS Information into Computer 1

Printout of Calculated Alpha and P. E. Curies, and Thermal Activity V

Crate Counter Assay Verification Y

Mark, Label, RTR Noncomplying Material (Subsection 1,3)

Data Pkg Inspected 0

Certification Figure 25. Boxed TRU Filter Waste O

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3 Remove from Glovebox Y

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Placement in Drum Orum Count Above Discard _

Assay i

Below Discard Y

Processing, Packaging, and Inspection Y

Drum Counter Assay Verification Y

Enter Assay and Drum label information into Computer v

Printout of Calculated Alpha and P. E. Curies and Thermal Activity v

Mark, Label, RTR Noncomplying Material (Subsection 1.3)

Data Pkg Inspected If Certification Figure 26. Drummed TRU Filter Waste 0

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  • As filter media is removed from the glovebox line, it is either double contained in plastic bags and placed directly into prepared 55 gallon drums or placed in 1 gallon polyethylene bottles, double bagged out of the glovebox in PVC and polyethylene bags, and placed into prepared 55 gallon drums.

i The metal containers and drums are then transferred to the drum counter for assay. The results of this assay determine if the contents are above or below the discard level (CO-1103 and C0 1106). The gram values are entered on the drum label for each radionuclide.

The gram values for plutonium, americium, and any other TRU materials, as determined by the drum counter assay, are entered into the computer. The computer is used to calculate the alpha curies, PE curies, and thermal activity of the waste package based on these gram quantities. This infor-mation is reported in the data package along with the gram quantities of plutonium, americium, and any other TRU materials (Steps 3.3.2 and 3.3.5).

If the HEPA filters (!DC's 490 and 335), Ful-Flo filters (10C-328), filter

)

media (100-338) and plenum prefilters (IDC 491) are waste, they are sent to the Size Reduction (SR) facility in Building 776.

Processing and repackaging are performed under controlled conditions in the SR vault.

l Each plastic bag of filter waste (IDC-328, -335, -338, and 491) is opened by Waste Operations personnel and inspected by a Waste Certification inspector. The Waste Certification personnel log the identification number and assay values of each drum or carton on a WBLS.

a a

Waste Operations personnel mix the filters with dry portland cement to neutralize any residual acid and adsorb any residual liquid. The mixture is placed in double polyethylene bags, taped shut, and packaged into a 55-gallon drum with a rigid poly liner.

The waste is identified as processed filter media (IDC 376).

The drum is sent to the drum counter to verify the assay,

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TRU WASTE COMPLIANCE PROGRAM WO 4500 135 9p/g FOR WIPP WAC (U)

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6

' HEPA filters (IDC-490) are crushed in a press after being removed from the cardboard carton. The crushed filter is then placed into a prepared waste box.

The cardboard boxes used for transporting the filters are cut flat and placed on top of the filters before the box is closed and sealed. WC inspection personnel inspects the crushing and packaging of HEPA filters.

Waste is inspected by E inspection as it is placed into druas.

Drums are sealed by E Inspection (E 4003).

Lids are welded on waste boxes by Maintenance personnel, providing a tamper proof seal.

The waste box weld is leak-tested and inspected by E inspection (WC 4003). A completed Drum Count label is attached to the drum or a WBLS for boxes.

The container is surveyed for surface contamination, surface dose rate, and radiation readings at 1 ineter by Radiation Monitoring.

These survey results are entered on the Drum Count label or WBLS by Waste Opsrations personnel, and then verified by the signature of a Radiation Monitor (WO 4034 and Radiation Monitoring Manual).

L The waste package is then sent to Building 664 with the Drum Count label or WBLS which has been approved by a WC inspector (WC 4003).

The drum or box will be labeled and marked with the required shipping labels and markings (Traffic Procedure T-300 1).

Real-time radiographic examination is then performed by NDT personnel.

These trained personnel, who are certified to Rocky Flats Plant (RFP)

)

procedures that implement Level 11 SNT-TC-1A standards, use the information on the drum label or WBLS (Step 3.3.7, Labels) to detect and document the following:

(1) Nonconforming items (2) Use of polyethylene and 90-mil rigid liners for drums or fiberboard and polyethylene liners for boxes (3) Correct waste form description (4) Presence of free liquid

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TRU WASTE COMPLIANCE PROGRAM WO-4500 136

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t Nonconforming waste packages are returned to the generator for corrective action with a copy of a Waste Rejection Report, RF 47042, which identifies the specific reason for rejection (see Step 1.3.2).

There will be 100 percent inspection of the waste by RTR until data have been accumulated showing control can be maintained through statistical sampling.

Waste boxes receive final assay in the crate counter (C0-7006 and CO-1107). A waste review board determines actions to be taken on assay discrepancies.

Data from each of the above operations are reviewed by QE personnel who verify that the information is correct and complete.

The QE representative then approves WIPP certification for that waste package and notifies Waste Operations that the waste package can be added to the shipment load list and that the information on all labels has been verified and can be included in the data package.

I e

13.4 Waste Form Compliance i

13.4.1 Imebilization (Particulates)

First stage HEPA filters (10C-490) and Absolute Dry Box filters (IDC-335) from several plutonium process areas were shaken and then crushed in an 85,000 pound drum crusher. All particulate material was collected, weighed, and sized.

In all cases, the particulate material was within the WIPP-WAC criteria for innobilization (HEPA Filter Evaluation, August 1985, Internal Report).

Additional studies were conducted during 1986 with similar results. Worst case results were obtained from filters in which the filter frame was not included in the waste matrix weight. The results averaged 5.33 wt/%

particulate material less than 200 microns and 0.12 wt/% particulate material less than 10 microns.

Results would have been approximately 2/3 l

lower had the frames been included as part of the waste matrix, Results r

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from other filter plenums indicate that the filters average less than 1.0 wt/% particulate material less than 200 microns and less than 0.01 wt/%

particulate material less than 10 microns.

These results art presented in an internal report, Characterization of Spent HEPA Filters from Rocky Flats Plant, PSD66 056, P. M. Arnold, September 1986.

This waste form may be packaged without any further treatment.

Any loose particulate material will be dislodged from the filter media (IDC-338) when it is separated from the frames in the process areas.

Insulation (also 10C-338) and Ful-Flo filters (IDC 328) are not particulate waste forms and Waste Certification Inspection ensures no particulate material is mixed with the waste as it is packaged for shipment.

l 13.4.2 Free liquids

)

HEPA filters, absolute filters, filter media, and plenum filters must be dried, drained, or otherwise segregated from all liquids (WO 4034) in addition, sufficient adsorbent (Oil Dri) is added to the bottom of the 3

waste crate to imobilize any liquid that may be desorbed during shipment or storage. The only filters that may contain liquid are the acid environment filters, and they are neutralized with dry cuent.

Inspection by Waste Certification and RTR examination of the waste by NDT verify that no free liquid is present in the final waste package (WC 4003).

13.4.3 Pyrophorics and Explosives HEPA filters, absolute filters, filter media, and plenum prefilters contain no pyrophoric or explosive materials.

Pyrophorics and explosives are prohibited from all waste packages (WO 4034). WC inspection of each l

package and periodic audits per the QA audit schedule ensures that pyrophorics and explosives are excluded from the waste package (WC 4003).

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TRU WASTE COMPLIANCE PROGRAM WO 4500 138 745/y7 FOR WIPP WAC (U) pos AM

t 13.4.4 Compressed Gases Pressure vessels may not be' packaged with TRU waste (WO 4034). WC inspection and RTR examination of each waste package ensures that pressure vessels are excluded from the waste (WC-4003).

13.4.5 Radioactive Mixed Wastes All corrosive materials must be neutralized or removed from TRU waste (WO4034). All TRU waste packages have either a 90-mil polyethylene liner or an Il-mil PVC liner for corrosion protection.

No toxic materials (40 CFR 261, Subparts C and D) have been identified in the waste forms.

i Waste packages with reportable toxics, ignitible, reactive, or corrosive L

wastes are identified by type and amount in the data package.

i TRU WASTE COMPLIANCE PROGRAM WO 4500 139 E

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I 14.

ATTACMENT XI: CERTIFICATION OF TRU LEADED RUB 8ER (WF-123)

Contents 14.1 Introduction and Waste Form Description 14.2 Waste Flow Description 14.3 Waste Fors Compliance 14.3.1 Innobilization (Particulates)

)

14.3.2 Free Liquids 14.3.3 Pyrophorics and Explosives 14.3.4 Compressed Gases 14.3.5 Radioactive Mixed Wastes s

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E TRU WASTE COMPLIANCE PROGRAM WO 4500 140 pj,ffy f FOR WIPP WAC (U) pr AM

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I 14.1 introduction and Waste Fors Description Leaded rubber gloves contain layers of Hypalon and lead oxide impregnated neoprene.

Leaded rubber gloves and aprons are 10C 339 and gloves contaminated with ritric acid are 10C-341.

Those leaded items from wet glovebox lines, or items above discard level, are washed to remove nitrates and contamination.

Nitric acid in contact with lead forss lead nitrate, which is a pyrophoric material.

Leaded rubber waste is packaged in DOT-17C, 55 gallon steel drums (SX-200) with a 90 mil rigid polyethylene liner (SX-202), see WO 4034.

I 14.2 Waste Flow Description (See Figure 27)

I leaded glovebox q oves and aprons are double contained in plastic and placed in prepared 55 gallon drums (see WO 4034). Absorbent material (Oil Dri) is added to the drum. A completed drum label is attached to the lid.

The drums are then transferred to the drum counter for weight and assay.

The results of this assay determine if the contents are above or below the discard level (CO-1103 and CO 1106).

The gran values and weight are entered on the drum label for each radionuclide.

The gram values for plutonium, americium, and any other TRU materials, as determined by the drum counter assay, are entered into the computer.

The computer is used to calculate the alpha curies, PE curies, and therwal l

activity of the waste package based on these gras quantities. This l

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TRU WASTE COMPLIANCE PROGRAM WO 4500-141 O

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${g Remove from Glovebo's

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P HNO3 1

Wash Water to Assay Pack as 100-341 Yes ontaminati Waste Treat Plant o

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it Wash, Repack as Pack as 10C-339, E

10C-339, inspect Inspect O

P 1f e,

A*>ove rum Above.

Dru\\m

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Discard Assay Miscard Assay 52,1,,

N Below Discard Relaar ! Harmed

'I Mark, Label, RTR Noncomplying Material (Subsection 1.3) 8 u

g Data Pkg Inspected

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0 Certification Figure 27.

TRU Leaded Rubber Waste

i

' information is reported in the data package along with the gran quantities of plutonium, americium, and any other TRU materials (Steps 3.3.2 and 3.3.5).

The waste and residue drums are sent to the Size Reduction facility, Building 776, where the leaded gloves and aprons taken from an acid environment and those that are above the discard level are washed with hot i

water in a ball mill washer to remove any nitric acid and recoverable plutonium. After washing, they are air dried, rolled up, and repackaged in a prepared 55 gallon drum (10-339). Oil-Dri is added.

Waste is inspected by Waste Certification Inspection as it is packaged into a drum.

Drums are returned to the drum counter for assay.

If the leaded gloves and aprens have never been exposed to an acid environment, the drum is opened and contents inspected.

When the drum is full, the liner is closed.

The drums are sealed with a tamper-proof sesi. The container is surveyed for surface contamination.

Radiation readings are taken at the surface and at 1-meter and tre recorded on the drum label. Drums are sent to the drum counter and the waste package is sent to Building 664 with the required drum label.

The container is labeled and marked with the required shipping labels and I

markings (Traffic Procedure T 300-1).

Real-time radiographic examination is then performed by NDT personnel.

These trained personnel, who are certified to Rocky Flats Plant (RFP) procedures that implement the SNT-TC 1A standards, use the information on the drum label (Step 3.3.7, Labels) to detect and document the following:

(1) Nonconforming items (2) Use of polyethylene and 90 mil rigid liners for drums (3) Correct waste fora description j

(4)

Preserte of free liquid

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O TRU WASTE COMPLIANCE PROGRAM WO 4500 143 7/,fh7 FOR WIPP WAC (U) l M

I i

e l

' Nonconforising waste packages are returned to the generator for corrective action with a copy of a Waste Rejection Report, RF 47042, which identifies the specific reason for rejection (see Subsection 1.3).

There will be 100 percent inspection of the waste by RTR until data have been accumulated showing control can be maintained through statistical sampling.

Data from each of the above operations are reviewed by QE personnel who verify that the information is correct and complete.

The QE representative then approves WIPP certification for that waste package and notifies Waste Operations that the information has been verified and can be included in the data package.

14.3 Waste Form Compliance i

14.3.1 Immobilization (Particulates)

All of the components of this waste form are nonparticulate and have demonstrated stability in long term storage.

Leaded rubber must be segregated from unacceptable particulates when paPaged as waste (WO 4034). During repackaging in Size Reduction, leaded rubber is inspected by WC Inspection to ensure no particulate material is added to the waste (WC 4003).

These procedures are audited periodically per the t

QA audit schedule.

14.3.2 Free Liquids j

t Leaded rubber must be dried, drained, or otherwise segregated from all free liquids (WO 4034).

In adoition, sufficient absorbent is added directly to the waste to imenbilize any liquid that may be present.

l WC inspection and RTR examination of the waste verify that no free liquid is present in the final waste package (WC 4003).

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i 14.3.3 Pyrophorics and Explosives The washing of leadt.d gloves which have been exposed to nitric acid (10C-341) removes the nitric acid and any pyrophoric lead nitrate that may have formed through the reaction of the nitric acid with lead. Leaded rubber contains no explosive materials (WO 4016).

TPU contastnated wash water is pumped into Raschig ring filled tanks and sampled. After analysis, the wash water is pumped to the liquid waste treatment plant where it is treated (see Attachment !Y:

Certification of TRU Solidified Aquous Waste).

14.3.4 Compressed Gases Pressure vessels may not be packaged with TRU waste (WO 4034).

WC inspection and RTR examination ensure that pressure vessels are excluded

}

from the waste (WC-4003).

i 14.3.5 Radioactive Mixed Waste Leaded ruober was subjected to the Environmental Protection toxicity test (EPA Manual SW 846, Section ?.l.4 Method 1310). The test results show 1

that leaded rubber waste contains no toxic materials as identified in 40 CFR 261, Subparts C and D.

(Analytical Laboratory Report, M85 2833).

All corrosive materials must be neutralized or removed froa TRU waste (WO-4034). All TRU waste packages have either a 90 sli polyethylene liner or an Il mil PVC liner for corrosion protection.

i l

l 1

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E 1RU WASTE COMPLIANCE PROGRAM WO 4500 145 pf FOR WIPP WAC (U)

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n 15.

ATTACHMENT XII:

CERTIFICATION OF SOLIDIFIED PROCESS SOLIDS (WF-ll4)

Contents 15.1 Introduction 15.2 Waste Forn Description s

15.3 Waste Flow Description 15.4 Waste Form Compliance 15.4.1 Immobilization (Particulates) 15.4.2 Free Liquids 15.4.3 Pyrophorics and Explosives 15.4.4 Compressed Gases 15.4.5 Radioactive Mixed Wastes 1

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i 15.1 Introduction i

Solidified Process Solids IDC-806 comprises Waste Form 114 (WF-114),

solidified process solids. All sludgy or particulate IDC's must be solidified before disposal.

The IDC's that comprise IDC-806 are listed below.

290 Filter Sludge 291 Dried Lab Waste Fluoride Sludge 292 Incinerator Sludge 310 Graphite Scarfing and Fines 311 Graphite Heels 340 Sludge from Size Reduction Area 369 Leco Heels 372 Grit

)

373 Fire Brick Heel 378 Fire Brick, Pulverized or Fines 393 Sand, Slag, and Crucible Heels 394 Sand from BB0 398 Pulverized Sand, Slag, and Crucible 420 Pulverized Incinerator Ash 421 Ash Heels 422 Soot 423 Soot Heels 425 Fluid Bed Ash j

431 Resin, Leached NOTE This list of IDC's is not intended to be all inclusive of WF-114.

Solidified process solids are packaged in DOT-17C, 55-gallon steel drums with a 90-mil rigid polyethylene liner.

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TRU WASTE COMPLIANCE PROGRAM WO 4500-147 7j g FOR WIPP WAC (U) oos AM

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15.2 Waste Form Description

(

All line-generated particulate and sludgy wastes are imobilized by portland cement solidification according to Procedure CO-6069. The IDC numbers listed in Section 15.1 may change to accomodate process identification or nuclear materials accountability requirements.

A formula for each waste type is used to precondition the waste (i.e.,

neutralize, thicken).

List the amount of portland cement used, the mixing method, and the cure time.

The cemented wastes are cast into 1-gallon molds and allowed to cure. The cured "pucks" are removed from the molds in the form of a solid monolith, 15.3 Waste Flow Description (See Figure 28)

Process solids are the particulate and sludgy wastes that have been I

processed to recover as much plutonium as economically feasible. After processing, the wastes are removed from the glovebox in a 4-liter (or smaller) polyethylene container and assayed for plutonium content.

Any waste above the economic discard limit (EDL) is identified as Residue and is segregated for further processing.

All waste below EDL is identified with a package number and the number of grams of plutonium to be discarded in the waste. The waste packages are collected in a 55-gallon drum for transfer to the solidification area.

The gram value and package nuober are recorded on a control card attached to the drum lid. The information on the control card is recorded on a drum count label before transfer.

Each drum of process solids is processed as a batch.

One drum of unsolidified waste will produce three drums of solidified process solids (IDC-806).

v g

TRU WASTE COMPLIANCE PROGRAM WO-4500-148 7/6/p FOR WIPP-WAC (U) pus AM

i V

Remove all Process Solids from Glovebox i

Can Count Above Discard.

l Assay

~

Below Discard Cementation Inspection Packaging U

Assay Verification by Drum Counter F

j Enter Assay and Drum Label Information into Computer P

Printout of Calculated l

Alpha Curies, PE Curies, and Thermal Activity i

U Mark, Label, RTR Noncomplying Material (Subsection 1.3) y Data Pkg Inspected U

Certi ficatio.,

4 Figure 28. Solidified Process Solids Waste V

TRU WASTE COMPT.IANCE PROGRAM WO 4500-149 E

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,v,.

_---r-,--,--

V After solidification, the "pucks" are removed from the glovebox, double bagged, and placed into a 00T-17C 55-gallon steel drum with a 90 mil rigid line (C0-6069). WC Inspection seals the drums after drum inspection.

There will be 100 percent inspection of the process until data have been established showing control can be maintained through statistical sampling.

A completed Drum Count label is attached to the lid. The drum is then surveyed for surface contamination, surface dose rate, and radiation readings at 1 meter.

These survey results are entered on the Drum Count label and then verified by the signature of a Radiation Monitor (WO-4034 and Radiation Monitoring Manual).

l The drum is transferred to the drum counter for assay vcrification, l

The gram values for plutonium, americium, and any other TRU materials, as determined by the can counter assay, are entered into the computer.

The computer is used to calculate the alpha curies, PE curies, and thermal I

activity of the waste package based on these gram quantities.

This information is reported in the data package along with the gram quantities of plutonium, americium, and any other TRU materials (Steps 3.3.2 and 3.3.5).

A completed Drum Count label is attached to the lid. The drum is then surveyed for surface contamination, surface dose rate, and radiation readings at I meter. These survey results are entered on the Drum Count label and then verified by the signature of a Radiation Monitor (WO-4034 and Radiation Mcnitoring Manual).

The drum is transferred to the drum counter for assay verification.

E TRU WASTE COMPLIANCE PROGRAM WO-4500-150 9gg 7 FOR WIPP-WAC (U)

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' The drum will be labeled and marked with the required shipping labels and markings (Traffic Procedure T-300-1).

Real-ti,a radiographic examination is then performed by NOT personnel.

These trained personnel, who are certified to Rocky Flats Plant (RFP) procedures that implement the SNT-TC-1A standards, use the information on the drum label (Step 3.3.7, labels) to detect and docut.ent the following:

(1) Nonconfonsing items (2) Use of polyethylene and 90-mil rigid liners for drums (3) Correct waste form description (4) Presence of free liquid Nonconforming waste packages are returned to the generator for corrective action with a copy of a Waste Rejection Report, RF-47042, which identifies I

the specific reason for rejection (see Step 1.3.2).

There will be 100 percent inspection of the waste by RTR until data have been accumulated showing control can be maintained through statistical sampling.

Data from each of the above operations are reviewed by QE personnel who verify that the information is correct and complete.

The QE representative then approves WIPP certification for that waste package and notifies Waste Operations that the waste package can be added to the shipment load list and that the information has been verified and can be included in the data package.

E TRU WASTE COMPLIANCE PROGRAM WO 4500-151 749 y FOR WIPP-WAC (U) om AM

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' 15.4 Waste Form Compliance 15.4.1 Immobilization (Particulates)

These wastes are particulate and do not meet the WIPP Waste Acceptance Criterion without any further treatment.

The treatment is solidification into gallon-size blocks which are inspected, wrapped in plastic, and placed in a drum according to CO-6069.

15.4.2 Free Liquids The cemented waste is inspected before being placed into a drum to ensure there is no free liquid present.

The absence of free liquids will be verified by RTR examination.

15.4.3 Pyrophorics and Explosives i

Pyrophoric or explosive materials would be rendered innocuous by the solidified cement matrix of this waste.

15.4.4 Compressed Gases Pressure vessels may not be packaged with TRU waste (WO-4034). WC inspection and RTR examination of each waste package ensures that pressure vessels are excluded from the waste (WC-4003).

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f 15.4.5 Radioactive Mixed Wastes All corrosive, ignitible, reactive, or toxic materials are rendered innocuous by the cemented matrix of this waste.

All TRU solidified process waste is packaged in a DOT-17C, 55-gallon drum with a 90 mil rigid polyethylene liner for corrosion protection.

Waste packages with reportable toxics, ignitible, reactive or corrosive wastes are identMied by type and amount in the data package.

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16.

ATTACHMENT XIII: CERTIFICATION OF TRU PYR0 CHEMICAL SALT WASTE (WF-124)

Contents 16.1 Introduction 16.2 Waste Form Description 16.2.1 Molten Salt (IDC-409/429) 16.2.?

Direct 0xide Reduction Salt (IDC-414/454) 16.3 Waste Flow Description 16.4 Waste Form Compliance 16.4.1 Immobilization (Particulates) 16.4.2 Free Liquids 16.4.3 Pyrophories and Explosives 16.4.4 Compressed Gases 16.4.5 Radioactive Mixed Wastes I

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l 16.1 Introduction

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TRU pyrochemical salt waste (WF-124) is comprised of molten salt (IDC-429) and direct oxide reduction salt (IDC-454) and other similar IDC's.

Molten salt (IDC-409) consists of a fused halide salt mixture of NaC1, kcl, and MgCl.

In a lten salt extraction (MSE), the salt serves as a 2

solvent for americium.

Plutonium and americium are removed from spent MSE salt by the salt scrub process to yield a waste salt (10C-429) and an Al-Mg-Pu-Am alloy which is processed at Savannah River Plant.

The direct oxide reduction (DOR) process is a one step reduction of plutonium oxide to plutonium metal.

The process employs a calc:ur metal reductant and a molten calcium chloride salt flux. The D0R salt (IDC-414) is the spent salt from this process.

The uncertainty in the quantities of l

unreacted calcium metal present in the salt has resulted in the need to I

process the salt by air oxidizing this calcium metal, a nonradionuclide pyrophoric material to produce a waste salt (IDC-454).

j The process is still in the research and development stage, and the facility to oxidize the calcium metal is not yet installed. The salt is being stored until this facility is operational to treat the waste. An internal report will show data to prove the process completely oxidizes the calcium metal. A new IDC will be assigned to this treated salt.

These pyrochemical salt wastes are packaged in DCT-17C, 55-gallon steel drums (SX-200j with a 90-mil rigid polyethylene liner (SX-202).

i TRU WASTE COMPLIANCE PROGRAM WO-4500-155 D<jjg FOR WIPP-WAC (U) p p:

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16.2 Waste Form Description 16.2.1 Molten salt (IDC-429) is a salt mixture of Nacl, KC1, and MgCl2 in mole percentages of 35-35-30, respectively.

16.2.2 DOR salt (IDC-414) is a calcium chloride salt containing unreacted calcium metal (1 to 3 weight percent) and calcium oxide.

16.3 Waste Flow Description (See Figure 29)

The spent salts are assayed by the "in line' can counter to determine the EDL waste / residue.

Waste molten and electrorefining salts are packaged in produce cans.

After assay, molten salts (IDC-429) are packaged in a lead-lined 55-gallon drum.

Each drum contains a 90-mil polyethylene rigid drum liner; the

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rigid liner is lined with one round-bottom polyethylene drum liner.

The gram values for the TRU waste materials are entered on the drum label for each radionuclide.

The waste is inspected before the drum is closed.

The drum is then sealed by WC Inspection (WC-4003). There will be 100 percent inspection of the process until data have been accumulated showing control can be maintained through statistical sampling.

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TRU WASTE COMPLIANCE PROGRAM WO-4500-156 E

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"In-Line" Assay Below Discara

'l Packaging Inspection Removal from Glovebox l

Drum Count for Assay Verification l

Enter Assay and Drum Label Information into Computer u

Printout of Calculated Alpha Curies, PE Curies, and Thermal Activity l

Mark, Label, RTR Noncomplying Material (Subsection 1.3) u Data Pkg Inspected U

' Certification Figure 29. Pyrochemical Salt Waste L'

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t A completed Drum Count label is attached to lid. The drum is then surveyed for surface contamination, surface dose rate, and radiation readings at 1 meter. These survey results are entered on the Drum Count label and then verified by the signature of a Radiation Monitor (WO-4034 and Radiation Monitoring Manual).

The drum is transferred to the segmented drum counter for safeguard verification.

NOTE The safeguard assay verification is for assurance of gross discrepancies in assay values; it is not for EDL determination.

The gram values for plutonium, americium, and any other TRU materials, as determined by the "in-line" counter, are entered into the computer.

The computer is used to calculate the alpha curies, PE curies, and thermal I

activity of the waste package based on these gram quantities.

This information is reported in the data package along with the gram quantities of plutonium, americium, and any other TRU materials (Steps 3.3.2 and 3.3.5).

The waste drum is sent to Building 664 with the drum label which has been approved by a WC inspector (WC-4003).

The drum will be labeled and marked with the required shipping labels and markings (Traffic Procedure T-300-1).

NOTE Drums lined with lead will not be submitted to RTR. The in-process inspections by Waste Inspection will verify compliance of the waste (WC-4003).

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TRU WASTE COMPLIANCE PROGRAM WO 4500-158 gf FOR WIPP-WAC (U)

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Real-time radiographic examination is then perfomed by NDT personnel.

These trained personnel, who are certified to Rocky Flats Plant (RFP) procedures that implement the SNT-TC-1A standards, use the information on the drum label (Step 3.3.7, Labels) to detect and document the following:

(1) Nonconforming items (2) Use of polyethylene and 90-mil rigid liners for drums (3) Correct waste form description (4)

Presence of free liquid Nonconfoming waste packages are returned to the generator for corrective action with a copy of a Waste Rejection Report, RF-47042, which identifies the specific reason for rejection (see Step 1.3.2).

Data from each of the above operations are reviewed by QE personnel who I

verify that the information is ccrrect and complete. The QE representative then approves WIPP certification for that waste package and i

notifies Waste Operations that the waste package can be added to the shipment load list and that the information has been verified and can be included in the data package.

16.4 Waste Fom Compliance 16.4.1 Immobilization (Particulates)

According to the EG&G study conducted on stored TRU pyrochemical (molten and electrorefining) salt waste, this waste consists of dry, fused salt in the form of chunks. Respirable and dispersible fines are not present in quantities that exceed the WIPP-WAC limits (Content Code Assessments for INEL Contact-Handled Stored Transuranic Wastes, October 1982, WM F1-82-021).

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6 Spent D0R Salts (100-414) are placed in a disposable crucible and sparged with oxygen to oxidize the calcium while molten. After the salts and crucible are cooled, they are packaged into drums as IDC-454. Cooled salts form large granules or chunks and do not constitute a particulate problem.

16.4.2 Free Liquids i

These waste forms are dry when packaged. WC inspection and RTR examination of the waste verify that no free liquid is present in the l

final waste package (WC-4003).

16.d.3 Pyrophorics and Explosives Molten salt (100-419) and 00R salt (IDC-454) contain no pyrophorics or explosives.

l DOR salt (IDC-414) contains free calcium which is a reactive material.

This calcium will be oxidized using an air oxidation process. When the calcium is oxidized, the 00R salt will be assigned a new IDC-454.

D0R salt contains no explosive materials.

16.4.4 Compressed Gases Pressure vessels may not be packaged with TRU waste (WO-4034). WC inspection and RTR examinatien of each waste package ensures that pressure vessels are excluded from the waste (WC-4003).

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E TRU WASTE COMPLIANCE PROGRAM WO-4500-160 r/gp FOR WIPP-WAC (U)

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l 16.4.5 Radioactive Mixed Wastes No toxic or corrosive materials (40 CFR 261, Subparts C and D) have been identified in this waste. All TRU pyrochemical salt waste packages have a 90-mil polyethylene liner for corrosion protection.

Waste packages with reportable toxies, ignitible, reactive, or corrosive wastes are identified by type and amount in the data package.

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