View source for NRC-2009-0283, 2022b-06-30-2022 Public WCS Request for Superseding NRC Order for SNM

{{Adams
| number = ML22200A046
| issue date = 06/30/2022
| title = 2022b-06-30-2022 Public WCS Request for Superseding NRC Order for SNM
| author name = Cartwright J
| author affiliation = Waste Control Specialists, LLC
| addressee name = Lubinski J
| addressee affiliation = NRC/Document Control Desk, NRC/NMSS
| docket = 07007005
| license number = 
| contact person = 
| case reference number = EA-14-104, NRC-2009-0283
| document type = Legal-Affidavit, Letter type:NRC, Report, Technical
| page count = 140
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:June 30, 2022                                                                          VIA EMAIL and FEDEX Mr. John Lubinski, Director Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Mail Stop T-4A12 Washington, DC 20555-0001

==References:==
: 1) Texas Commission on Environmental Quality (TCEQ), Radioactive Material License No. R04100, Amendment 38, CN6006616890, RN101702439
: 2) NRC Issuance of New Order (Superseding a Previously Issued Order of October 20, 2009 (2009 Order)) in Response to a July 18, 2014 Request by Letter from J. Scott Kirk (WCS) to Catherine Haney (NRC), Order dated December 3, 2014. Docket No. 70-7005; NRC-2009-0283; EA-14-104
: 3) Agreed Order between the TCEQ and WCS, TCEQ Docket No. 2015-0514-RAW-E; License R04100; dated December 9, 2015, signed December 10, 2015
: 4) Letter from Rod Baltzer (WCS) to Richard Hyde (TCEQ), re: Agreed Order Docket No. 2015-0514-RAW-E ("WCS Agreed Order") Enclosing the Plan for Disposition of LANL TRU Waste in Storage at WCS (Confidential Information), dated February 19, 2016
: 5) Letter from WCS to NRC regarding: Request for Storage Time Extension in NRC Exemption Order (ML14238A268), Order Condition 8.B.4 for WIPP-Bound LANL Waste in Storage at WCS, dated March 28, 2016 (Accession No. ML16097A265)
: 6) NRC Response to WCS Request for Possession Time Extension dated September 23, 2016 (Accession No. ML16097A265)
: 7) Letter from WCS to NRC regarding: Request to Extend Storage Timeframe in NRC Exemption Order (ML14238A268), Order Condition 8.B.4 for Transuranic LANL Waste in Storage at WCS, dated August 30, 2018 (Accession No. ML18250A289)
: 8) NRC Response to WCS Request for Possession Time Extension dated December 19, 2018 (Accession No. ML18269A318)
Dallas Office                                                                       Andrews Facility Waste Control Specialists LLC                                                       Waste Control Specialists LLC 17103 Preston Road, Suite 200                                                       P.O. Box 1129 Dallas, TX 75240                                                                    Andrews, TX 79714 P. 682-503-0030                                                                     P. 432-525-8500 F. 214-853-5720                                                                     F. 432-203-2359

Mr. Lubinski June 30, 2022 Page 2 of 3
: 9) Letter from WCS to NRC regarding: Request to Extend Storage Timeframe in NRC Exemption Order (ML14238A268), Order Condition 8.B.4 for Transuranic LANL Waste in Storage at WCS, dated August 24, 2020 (Accession No. ML14238A268)
: 10) NRC Response to WCS Request for Possession Time Extension dated December 7, 2020 (Accession No. ML20252A182)
: 11) Letter from WCS to NRC regarding: Docket No. 070-7005 Request to Extend Storage Timeframe in NRC Exemption Order (ML14238A268), Order Condition 8.B.4 for Transuranic LANL Waste in Storage at WCS, dated March 18, 2022 (Accession No. ML22081A181)
: 12) NRC Response to WCS Request for Possession Time Extension dated December 19, 2018 (Accession No. ML22094A131)

==Subject:==
Docket No. 070-7005 - Request for Transfer of Transuranic LANL Waste in Storage from WCS FWF to WCS TSDF

==Dear Mr. Lubinski:==

Waste Control Specialists, LLC (WCS) respectfully requests a transfer of the Los Alamos Nuclear Lab (LANL)
Transuranic (TRU) Waste from storage at the WCS Federal Waste Facility (FWF) to storage in the WCS Treatment Storage Disposal Facility (TSDF). The following Appendices are provided in this submittal package:
Appendix 1 - Technical Summary Appendix 2 - Draft Conditions 8.c and 8.d Appendix 3 -Documented Safety Analysis (DSA)
Appendix 4 - Project Plan - CONFIDENTIAL o Appendix 4.A - Project Schedule - CONFIDENTIAL Appendix 5 - Design of Radiological Containment Enclosure - CONFIDENTIAL Appendix 6 - Work Instruction - CONFIDENTIAL o Appendix 6.A - Referenced Procedures - CONFIDENTIAL

Mr. Lubinski June 30, 2022 Page 3 of 3 WCS requests that a copy of all correspondences regarding this matter be directly emailed to my attention (jcartwright@wcstexas.com) as soon as practicable after issuance. If you have any questions or need additional information, please call me at 432-525-8698.
Sincerely, Jay B. Cartwright Director of ESH&Q/RSO

==Enclosure:==

Cc:     Electronic Copy Only Jane Marshall, NRC Harry Felsher, NRC David S. Carlson, WCS Jay Britten, WCS Chris Shaw, M.S., CHP, RRPT, WCS Ryan Williams, WCS Gregory G. DiCarlo, WCS WCS Regulatory Compliance WCS Records

WASTE CONTROL SPECIALISTS LLC AFFIDAVIT 1, Jay B. Cartwright, Director of ESH&Q and Radiation Safety Officer at Waste Control Specialists LLC (WCS), am makingthe following representationsthat to the best of my knowledgeand beliefs:
: 1.        The following documentsWCSwishesto have withheld from public disclosure, are supporting documents of the WCS Request for Transfer of Transuranic LANLWaste in Storage from WCS' FWFto WCS' TSDF, in the NRC Exemption Order (ML14238A268):
a) Appendix4 - Project Plan b) Appendix4.A - Project Schedule c) Appendix 5 - Designof RadiologicalContainment Enclosure d) Appendix 6 - Work Instruction e) Appendix 6.A - Referenced Procedures
: 2.        The information contained in the document cited in 1 above is considered confidential information pursuant to Title 10of the Code of Federal Regulations (CFR), Part 2.390(a)(4) and is thereby protected from public disclosure by regulation.
: 3.        Pursuant to 10 CFR 2.390, the information contained in the document cited in 1 above is protected from public disclosure by regulation because it includes correspondences and reports to the NRCwhich contain trade secrets or commercial information pursuant to 10 CFR
: 2. 390(a)(4).
: 4.        The information contained in the document cited in 1 above has not been made available to public sources by WCS, nor has WCS authorized that it be made available.
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WASTE CONTROL SPECIALISTS LLC Agreed Order 2015-0514-RAW-E Docket No. 070-7005 June 30, 2022 APPENDIX 1 Technical Summary

Appendix 1 Technical Summary Waste Control Specialists LLC (WCS) is presenting this Technical Summary and supporting documents as a request to amend its Nuclear Regulatory Commission (NRC) Special Nuclear Material (SNM) Exemption Order. WCS is requesting this amendment to transfer all 74 Standard Waste Boxes (SWB) of Los Alamos National Laboratory (LANL) transuranic (TRU) waste from the Federal Waste Facility (FWF) to the WCS Treatment Storage and Disposal Facility (TSDF) for temporary storage.
As part of this request, WCS is providing the following supporting documents with descriptions of each in this summary.
Appendix 2 - Draft Conditions 8.c and 8.d Appendix 3 - Documented Safety Analysis (DSA)
Appendix 4 - Project Plan Appendix 5 - Design of Radiological Containment Enclosure Appendix 6 - Work Instruction and Procedures

===Background===
In early 2014, the Department of Energy (DOE) sent TRU mixed waste from LANL to the WCS site in Andrews County, Texas. This decision was made after the February 2014 radiological release event caused waste acceptance at the Waste Isolation Pilot Plant (WIPP) facility to be suspended, but before the cause of the event was understood to be a container from LANL. At that time, the decision to ship the TRU waste to the WCS site was intended to be a short-term, interim step that would allow the waste to be transferred promptly to WIPP when it recovered from the event and began accepting waste. However, the cause of the radiological event was determined to be an exothermic reaction between organic materials and nitrate salts inside a LANL TRU waste drum. The DOE subsequently determined that a portion of the TRU waste at WCS was from the same population that produced the reactive drum at WIPP.
After a detailed technical analysis to confirm that the majority of the waste at WCS was not chemically similar to the waste container that had affected WIPP operations, DOE was able to remove the above ground portion of TRU waste packages that were not of a similar chemical composition as the container involved in the WIPP incident. This was completed on February 4, 2021 and reduced the initial inventory at WCS from 230 to 74 total containers. Historical records were not sufficient to confirm the stability of 74 waste boxes that remain at WCS. These containers have been stored in a below-grade configuration within the WCS FWF since 2014. The metal boxes were placed into modular concrete containers (MCCs) and the remaining space between the waste container and the inside walls of the MCC was filled with pea gravel. A concrete lid was placed on top of the MCC after it was placed in position in the FWF, and an additional 1-2-foot layer of sand was placed over the array of MCCs to provide additional thermal stability to the waste itself. There are generally two waste boxes inside each MCC, but several of the boxes were loaded into rectangular MCCs that could hold up to four waste boxes.

Authorization WCS was authorized to possess the LANL waste for two years as specified in Order Condition 8.B.4 of NRC Exemption Order (ML14238A268), dated December 3, 2014, through December 23, 2016. WCS then requested an extension to the original order for an additional two years, until December 23, 2018, which was authorized in the NRC extension authorization {{letter dated|date=September 23, 2016|text=letter dated September 23, 2016}}. As DOE continued to study and analyze this waste stream, the NRC authorized another two-year extension until December 23, 2020, in the {{letter dated|date=December 19, 2019|text=letter dated December 19, 2019}}. Most recently, the NRC authorized another two-year extension until December 23, 2022, in the {{letter dated|date=September 2, 2020|text=letter dated September 2, 2020}}, as WCS and DOE continue to plan and develop plans for removal and relocation within the WCS licensed and permitted areas.
The Texas Commission on Environmental Quality (TCEQ) incorporated the conditions of the 2014 SNM Order into License Condition (LC) 206 of Radioactive Material License (RML) No. R04100. Pursuant to LC 206.b.iv, of RML R04100, WCS is similarly limited to storage of this waste by the NRC until the specified date of December 31, 2024.
Extension Request History On March 28, 2016, WCS submitted a request to the NRC for the storage time, in the exemption order, to be extended through December 2018 (ML14238A268). The NRC approved WCS extension request on September 23, 2016 (ML16097A265).
On August 30, 2018, WCS submitted a request to the NRC for the storage time, in the exemption order, to be extended through December 2020 (ML14238A268). The NRC approved WCS extension request on December 19, 2018 (ML18269A318).
On August 24, 2020, WCS submitted a request to the NRC for the storage time, in the exemption order, to be extended through December 2022 (ML14238A268). The NRC approved WCS extension request on December 7, 2020 (ML20252A182).
Lastly, on March 18, 2022, WCS submitted a request to the NRC for the storage time, in the exemption order, to be extended through December 2024 (ML22081A181). The NRC approved WCS extension request on June 8, 2022 (ML22094A131).
Draft Conditions 8.c and 8.d In this appendix, WCS is providing proposed language to the NRC for the requested changes and additions to the conditions in the NRC SNM Exemption order.
Documented Safety Analysis As required by the Code of Federal Regulations (CFR) 10 CFR Part 830, Subpart B in this appendix, the Documented Safety Analysis (DSA) is provided to document the hazard analysis that resulted in a set of safety controls for the retrieval of the Standard Waste Boxes (SWB) from the Modular Concrete Canisters (MCCs). The DSA analyzed the removal of the MCCs from the FWF and the loading and the transportation of the MCCs on the WCS site to the WCS Treatment Storage and Disposal Facility which resulted in no

additional controls for these operations. The DSA analysis resulted in additional controls for the unloading of the SWBs from the MCCs and the temporary storage of the SWBs, which requires these operations to be performed within the temperature controlled PermaCon equipped with a HEPA filtration system within the Bin Storage Area 1 (BSA-1).
Project Plan In this appendix, the project plan defines the technical activities and decisions associated with preparation and approval to relocate the DOE TRU waste at WCS, with an overall schedule for beginning this operation.
The plan does not include the actual removal and relocation of the waste, but the plan will be updated when information about that phase of the work is available.
Design of Radiological Containment Enclosure In this appendix, WCS provides the design of the Containment Enclosure, a temperature controlled PermaCon equipped with a HEPA filtration system, that will be located within the BSA-1 unit at the Treatment Storage and Disposal Facility. The PermaCon enclosure is designed for the safe unloading of the MCCs that contain the 74 LANL TRU Waste SWBs and the temporary storage of the LANL TRU waste SWBs.
Draft Work Instruction and Procedures In this appendix, the draft work instruction and its referenced procedures are provided to document the steps from the DSA and the project plan that WCS will take to remove the LANL TRU waste from the FWF, transfer it to WCS TSDF BSA-1 PermaCon enclosure, and remove the LANL TRU waste SWBs from the MCCs within the PermaCon enclosure, and place the SWBs in temporary above-ground storage within that same enclosure.
Nuclear Criticality Safety Nuclear Criticality Safety for the storage of the LANL TRU waste was found to be a non-issue, as the LANL TRU waste as packaged in SWBs, complies with the concentration standards and conditions of WCS NRC SNM exemption and is only in its current configuration due to the hazardous characteristic of the waste designation D001.
Physical Security The Physical Security requirements for this category of waste, as required under NRC Exemption Condition 8.B(3), will continue to be met for all LANL TRU waste stored at any WCS facility.
Radiation Safety Controls and Program WCS Radiation Safety Program is in place to ensure that every reasonable effort to maintain exposures to radiation from occupational exposures is as far below the dose limits as is reasonable to ensure compliance with 30 Texas Administrative Code (TAC) &sect;336.304 Radiation Safety Program. The Radiation Safety Program serves as a primary confirmation of the adequacy of the active operational controls and the passive engineering controls for monitoring and prevention of releases.

Routine operations and Health Physics programs provide controls for limiting potential releases of radioactive material from the immediate facility during operations. Routine monitoring of work areas gives an early indication of any potential environmental concerns. Specific job coverage sampling and monitoring will be performed throughout the movements of the MCCs from the FWF to BSA-1 and in the work/storage area in BSA-1. Once the lid of each MCC is removed, WCS will verify using smears and direct monitoring to verify that there is no contamination around the top of the MCCs. After transfer and during gravel removal, WCS will continue to verify contamination levels via smears and direct monitoring of the material being removed is below background levels. Once the SWBs are removed, they will be smeared and surveyed to verify the conditions of the SWBs prior to being placed into storage. There will be alarming continuous air monitors in place to ensure that nothing has happened during storage inside the MCCs in the FWF cell. Air sampling will also be in place during removal of SWBs from the MCCs in BSA-1 and temporary storage in the same BSA-1 enclosure until shipment offsite. BSA-1 will also have HEPA filtration running at all times in the work area and storage area within the PermaCon while LANL TRU waste is present. The detailed Radiation Safety job coverage plan will be finalized during mock-ups and documented in the formal ALARA review which will be reviewed and approved by the WCS Radiation Safety Committee.
Environmental Monitoring Program WCS comprehensive environmental monitoring program has been in place for over 20 years at its Andrews County site. The environmental monitoring program provides for the confirmation of the adequacy of the active and passive operational specific controls and monitoring of the Radiation Safety Program. The specific monitoring that will be performed in support of this request is outlined in the Radiation Safety Program section of this document.
The environmental monitoring program involves the collection of samples for measurement of radiological constituents in various environmental media and effluents and then compares those results to historical data. Media and effluents monitored around the WCS site in accordance with this program include ambient gamma radiation, gases and vapor, air particulate, soil, sediment, fauna, vegetation, surface water when present, wastewaters, and groundwater from multiple strata. A comprehensive meteorological monitoring program is also maintained in support of the environmental monitoring program.

WASTE CONTROL SPECIALISTS LLC Agreed Order 2015-0514-RAW-E Docket No. 070-7005 June 30, 2022 APPENDIX 2 Draft Conditions 8.c and 8.d

Page 1 of 2 Appendix 2 Draft Conditions
: 8. The WIPP incident is the February 14, 2014, unplanned radiation release event at the DOE WIPP facility in New Mexico. The following relate to WCS storing DOE transuranic waste that originated at the LANL, which are destined to be disposed of at the DOE WIPP facility (i.e., LANL waste), at either the WCS Treatment, Storage, and Disposal Facility (TSDF) or the WCS Federal Waste Disposal Facility (FWF):
A. The following conditions are applicable to LANL waste stored at the Federal Waste Disposal Facility (FWF) and other SNM bearing waste stored or disposed of at the FWF:
: 1. The following waste is allowed to be stored at the WCS FWF: LANL waste in accordance with the concentration-based limits specified in Conditions 1 through 7, provided that it is in Standardized Waste Boxes (SWBs) analyzed to be safe in the DOE Nuclear Critical Safety Evaluation, WIPP-016, Rev. 4. The lids of the SWBs shall be bolted or similarly secured to the body and the SWBs shall be placed inside Modular Concrete Canisters (MCCs) consistent with the configurations analyzed in WIPP-016.
: 2. The LANL waste shall be isolated from other SNM-bearing waste by a minimum of 6.096 meters (20 feet).
: 3. The LANL waste in MCCs shall be stacked no more than one MCC high.
B. The following conditions are applicable to all the LANL waste stored at either the TSDF or the FWF:
: 1. WCS shall follow the general reporting and recordkeeping requirements of 10 CFR part 73 that are applicable to those who possess SNM of 1 gram or more. Those requirements are: (1) notification to the NRC within 1 hour of discovery of any unauthorized removal of SNM which WCS is authorized to possess; and (2) maintenance of a recordkeeping program showing the receipt, inventory, acquisition, transfer, and disposal of all SNM in WCS' possession.
: 2. The contents and matrices of the LANL waste in the inner containers shall conform to the description in the WCS non-public information.
: 3. The physical security plan for the LANL waste shall be maintained to specifically include detection, assessment, and response methods and procedures for the LANL waste for as long as the LANL waste is at the WCS facility.
: 4. WCS is allowed to possess the LANL waste for a maximum of 2 years.
: 5. The LANL waste shall remain unopened in the inner container in which it was shipped, unless WCS needs to take an action on one of the inner containers based on knowledge from DOE's investigation of the WIPP incident. Only one inner container may be open at a time.
: 6. WCS shall keep NRC informed of the status of the DOE investigation of the WIPP incident. If DOE determines that some of LANL waste at WCS was similar to the

Page 2 of 2 Appendix 2 Draft Conditions waste that DOE determines to have contributed to the WIPP incident, then WCS will notify the NRC.
C. The Following conditions are applicable to the LANL waste stored at the FWF
: 1. WCS is authorized to remove the LANL TRU waste containers from the FWF and transfer to the TSDF BSA 1 enclosure under the following general steps:
: i. Remove protective sand layer within the FWF ii. Remove the MCC lids iii. Remove the MCC from its FWF storage location and place on transport equipment and transfer to the TSDF BSA-1 enclosure facility iv. Remove the pea gravel from the MCC
: v. Replace the lifting straps of the SWBs vi. Remove the SWBs from the MCC vii. Replace existing filters in the SWB viii. Place SWB in storage within the BSA 1 enclosure D. The Following conditions are applicable for all the LANL waste preparing for shipment offsite.
: 1. The DOE may conduct additional activities associated with non-destructive inspection and samples such as bora scope or head space gas sampling, filter replacement, or adding additional filters and may do so under DOE approved procedure and authority but may not open and remove SWB lids or remove inner containers from SWB prior to notifying NRC. TCEQ approval may be required to approve this action as well.

WASTE CONTROL SPECIALISTS LLC Agreed Order 2015-0514-RAW-E Docket No. 070-7005 June 30, 2022 APPENDIX 3 Documented Safety Analysis

Documented Safety Analysis for Waste Control Specialist TRU Waste Handling and Disposal Draft Final Prepared by:
Wayne Gaul, Ph.D., CHP, CHMM Reviewed by:
James Reese, CHP, RRPT Tidewater 6625 Selnick Drive, Suite A Elkridge, MD 21075

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                                                             Draft Final Table of Contents LIST OF ACRONYMS...1 1    BACKGROUND ................................................................................................................... 4 2    INTRODUCTION................................................................................................................. 6 2.1    Purpose ............................................................................................................................. 6 2.2    Site and Facility Characteristics ....................................................................................... 7 2.2.1    Geographic Location ................................................................................................. 7 2.2.2    Location of the Nearest Off- site Member of the Public .......................................... 9 2.2.3    Location and Description of any Population Centers ............................................... 9 2.2.4    Meteorology ............................................................................................................ 10 2.3    

==Background:==
 ................................................................................................................... 12 2.4    Scope of Work, Process and Operational Characteristics .............................................. 13 3    HAZARD CATEGORIZATION....................................................................................... 15 3.1    Initial Hazard Categorization ......................................................................................... 15 4    Hazard Evaluation .............................................................................................................. 18 4.1    Common Hazards ........................................................................................................... 19 4.2    Specific Administrative Controls ................................................................................... 20 4.3    Safety Significant Controls ............................................................................................ 20 4.3.1    Fires......................................................................................................................... 21 4.3.2    Explosion/energetic events ..................................................................................... 21 4.3.3    Loss of Confinement/containment .......................................................................... 21 4.3.4    Direct exposure to radiation .................................................................................... 22 4.3.5    Criticality events ..................................................................................................... 22 4.3.6    External events ........................................................................................................ 22 4.3.7    Natural phenomenon hazards .................................................................................. 22 4.4    Initial Conditions ............................................................................................................ 22 4.4.1    SWB Overpack of the Drums (DESIGN FEATURE) ............................................ 23 4.4.2    Fuel and Oil Storage Locations (DESIGN FEATURE) ......................................... 23 4.4.3    Bin Storage Area 1(BSA-1) (DESIGN FEATURE) ............................................... 23 Page ii

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                                                              Draft Final 4.4.4    Enclosed Containment Structure (DESIGN FEATURE) ....................................... 23 4.4.5    Noncombustible Construction and Curbing. (DESIGN FEATURE) ..................... 24 4.4.6    Roof Loading. (DESIGN FEATURE) .................................................................... 24 4.4.7    Seismic. (DESIGN FEATURE).............................................................................. 24 4.4.8    Container (Drums or boxes) Integrity. (DESIGN FEATURE) .............................. 24 5    Source Term ........................................................................................................................ 26 5.1    Airborne Pathway ........................................................................................................... 27 5.1.1    Material-at-Risk ...................................................................................................... 27 5.1.2    Damage Ratio (DR) ................................................................................................ 27 5.1.3    Airborne Release Fraction (ARF) ........................................................................... 32 5.1.4    Respirable Fraction (RF)......................................................................................... 32 5.1.5    Leakpath Factor (LPF) ............................................................................................ 33 5.1.6    Source Term and Dose Calculations ....................................................................... 34 5.2    Accident Stresses .......................................................................................................... 37

====5.2.1 Spill====
........................................................................................................................ 37 5.2.2    Fire: ......................................................................................................................... 38

====5.2.3 Explosion====
............................................................................................................... 38 5.3    Gaseous Releases ........................................................................................................... 38 5.4    Liquids............................................................................................................................ 39 5.4.1    Explosive Stress ...................................................................................................... 39 5.4.2    Thermal Stress: Plutonium ...................................................................................... 39 6    Identification and Evaluation of TRU Waste Events ...................................................... 41 6.1    Fire Events...................................................................................................................... 43 6.1.1    Fuel Pool Fires (Event 1) ........................................................................................ 43 6.1.2    Small Fire (Event 2) ................................................................................................ 43 6.1.3    Enclosure Fire (Event 3) ......................................................................................... 43 6.1.4    Large Fire (Event 4) ................................................................................................ 43 6.2    Explosion Events ............................................................................................................ 43 6.2.1    Ignition of Fumes Results in an Explosion (external to container) (Event 5) ........ 43 6.2.2    Waste Container Deflagration (Event 6)................................................................. 43 Page iii

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                                                              Draft Final 6.2.3   Multiple Waste Container Deflagration (Event 7) .................................................. 44 6.2.4   Enclosure Deflagration (Event 8) ........................................................................... 44 6.3    Loss of Confinement/Containment ................................................................................ 44 6.3.1   Vehicle/Equipment Impacts Waste/Waste Containers (Event 9) ........................... 44 6.3.2   Drop/Impact/Spill Due to Improperly Handled Container, etc. (Event 10) ............ 45 6.3.3   Collapse of Stacked Containers (Event 11) ............................................................ 45 6.3.4   Waste Container Over-Pressurization (Event 12) ................................................... 45 6.3.5   Direct Exposure to Radiation Events (Event 13) .................................................... 45 6.3.6   Criticality Events (Event 14) .................................................................................. 45 6.4    Externally Initiated Events ............................................................................................. 45 6.4.1   Aircraft Impact with Fire (Event 15) ...................................................................... 45 6.4.2   External Vehicle Accident (Event 16) .................................................................... 45 6.4.3   External Vehicle Accident with Fire (Combustible or Pool) (Event 17) ................ 46 6.4.4   External Explosion (Event 18) ................................................................................ 46 6.4.5   External Fire (Event 19).......................................................................................... 46 6.5    Natural Phenomenon Hazard (NPH) Initiated Events.................................................... 46 6.5.1   Lightning (Event 20) ............................................................................................... 46 6.5.2   High Wind (Event 21) ............................................................................................. 46 6.5.3   Tornado (Event 22) ................................................................................................. 46 6.5.4   Snow/Ice/Volcanic Ash Build-up (Event 23) ......................................................... 47 6.5.5   Seismic Event (Impact Only) (Event 24) ................................................................ 47 6.5.6   Seismic Event with Fire (Event 25) ........................................................................ 47 7     Hazard Analysis .................................................................................................................. 48 7.1    TRU Waste Handling Steps ........................................................................................... 52 7.2    Hazard Description ......................................................................................................... 54 7.3    Security........................................................................................................................... 60 8     Alternate scenario Analysis ................................................................................................ 61 9     Conclusions .......................................................................................................................... 68 10    REFERENCES.................................................................................................................... 69 Appendix 1, General Resuspension ........................................................................................... 71 Page iv

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                                                                    Draft Final Appendix 2, Plutonium Resuspension ....................................................................................... 79 Appendix 3, General Fire ........................................................................................................... 87 Appendix 4, General Plume ....................................................................................................... 95 Appendix 5, Plutonium Fire ..................................................................................................... 103 List of Figures Figure 1, WCS Location in Texas................................................................................................... 7 Figure 2, WCS Facility Locations .................................................................................................. 8 Figure 3, WCS Wind Rose Locations ........................................................................................... 11 List of Tables Table 1: Clarification of Table 1 in Appendix A of Subpart B of 10 CFR Part 830 .................... 15 Table 2: Statistical Data on the WCS LANL Waste Drums, grams ............................................. 16 Table 3: Hazard Category Threshold Quantity, grams ................................................................. 17 Table 4: Qualitative Risk Ranking Bins1 ...................................................................................... 18 Table 5, Container Drop and Impact Damage Ratios ................................................................... 30 Table 6, ARF*RF Value Applicable to TRU Waste Accidents, Combustible Cellulose and Plastics .......................................................................................................................................... 33 Table 7, Plutonium Equivalent Activity, Curies ........................................................................... 35 Table 8, MAR Limits for TRU Waste Operations ........................................................................ 35 Table 9, HotSpot Results Multiple Drums Accident Scenarios, rem ........................................... 36 Table 10, HotSpot Results from Accident Scenarios.................................................................... 37 Table 11, Minimum TRU Waste Activity/Hazard Evaluation Event Matrix ............................... 42 Table 12, Screened Out Events ..................................................................................................... 49 Table 13, Hazard Evaluation Events Requiring Safety Controls .................................................. 56 Table 14, BSA-1 Hazard Evaluation Events Requiring Safety Controls...................................... 63 Table 15, Summary of Safety Significant Controls (SSCs) .......................................................... 66 Page v

Documented Safety Analysis for WCS TRU Waste Handling and Disposal Draft Final List of Acronyms A           Anticipated (Occurrence likelihood)
AC          Administrative Controls AED         Aerodynamic Equivalent Diameter AMAD        Activity Median Aerodynamic Diameter ARF         Airborne Release Fraction BEU         Beyond Extremely Unlikely (Occurrence likelihood)
BSA         Bin Storage Area CFR         Code of Federal Regulations CH          Contact Handled CWF         Compact Waste Facility DOE         Department of Energy DOEEM       DOE's Office of Environmental Management DOE-LA      DOE-Environmental Management at LANL DR          Damage Ratio DSA         Documented Safety Analysis ECS         Enclosed Containment Structure EIS         Environmental Impact Statement EM-LA       Environmental Management Los Alamos Field Office EPA         Environmental Protection Agency ER          Emergency Response EU          Extremely Unlikely (Occurrence likelihood)
FWF         Federal Waste Facility H           High (Occurrence consequence)
HC          Hazard Class or Characterization HGS         Head Gas Space HVAC        Heating, Ventilation, and Air Conditioning IC          Initial Condition (Type of control)
L           Low (Occurrence consequence)
LANL        Los Alamos National Laboratory LFL         Lower Flammability Limit LES         Louisiana Energy Services LLRW        Low Level Radioactive Waste LPF         Leakpath Factor M           Mitigation (Type of control)
M           Moderate (Occurrence consequence)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal Draft Final MAR         Material at Risk MCC         Modular Concrete Canister MEI         Maximally Exposed Individual MLLRW       Mixed Low Level Radioactive Waste NEF         National Enrichment Facility NEPA        National Environmental Policy Act NNSA        National Nuclear Security Administration NOAA        National Oceanic and Atmospheric Administration NPH         Natural Phenomenon Hazard OM          Operations Manager OS          Operations Supervisor P           Preventative (Type of control)
PE-Ci       Plutonium Equivalent Curies PSO         Program Secretarial Officer Pu          plutonium QA          Quality Assurance RC          Risk Class I = major concern II = concern III = minor concern IV = minimal concern RCRA        Resource Conservation and Recovery Act RF          Release Fraction RH          Relative Humidity RML         Radioactive Materials License RNS         Remediated nitrate salt RS          Radiological Survey RSS         Radiation Safety Supervisor RST         Radiation Safety Technician SA          Safety Analysis SAC         Specific Administrative Controls SER         Safety Evaluation Report SNM         Special Nuclear Material SOP         Standard Operating Procedure SOR         Sum of Ratios SOW         Scope of Work SRNL        Savannah River National Laboratory SS          Safety Significant Page 2

Documented Safety Analysis for WCS TRU Waste Handling and Disposal      Draft Final SSC         Safety Significant Control ST          Source Term STD         Standard sWheat      Wheat hull absorbent (Kitty litter)
SWB         Standard waste box SWEIS       Site-Wide Environmental Impact Statement TAT         Technical Assessment Team TCEQ        Texas Commission of Environmental Quality TED         Total Effective Dose TQ          Threshold Quantity TRT         Technical Review Team TRU         Transuranic TRUPACT     Transuranic Package shipping container TSCA        Toxic Substances Control Act U           Unlikely (Occurrence likelihood)
UNS         Unremeditated nitrate salt VOC         Volatile Organic Vapors WCRRF       Waste Characterization, Reduction, and Repackaging Facility Page 3

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                                          Draft Final 1     BACKGROUND The U.S. Department of Energy (DOE) has treated, repackaged, transport onsite, and stored transuranic (TRU)1 waste drums. These drums contain nitrate salts waste generated from 1979 through 1991 at Los Alamos National Laboratory (LANL). These drums were packaged into standard waste boxes (SWB) which are approved for disposal at the Waste Isolation Pilot Plant (WIPP). 74 of these SWBs have improperly treated materials from the 2012 to 2014 processing campaign. These wastes are referred to as remediated nitrate salts (RNS) drums. There are also drums of un-remediated nitrate salts (UNS) not included in this proposed action.
In the 2008 a Site-Wide Environmental Impact Statement (SWEIS) for Continued Operations at Los Alamos National Laboratory, Los Alamos, New Mexico (DOE 2008), DOE analyzed treatment, repackaging, onsite transportation, and storage of legacy TRU waste. However, the radiological release event2 that occurred on February 14, 2014, at the WIPP was unanticipated and resulted in the need to further evaluate these actions to determine if the 2008 SWEIS provides adequate National Environmental Policy Act (NEPA) coverage for the proposed action.
In September/October 2016, Subject Matter Experts from DOE's National Nuclear Security Administration (NNSA) and DOE's Office of Environmental Management (DOEEM), reviewed and provided approval of the relevant LANL safety basis documents that support de-nesting, cooling, loading, transportation, and processing of containers with RNS remaining at LANL. The resulting Safety Evaluation Report (SER) (DOE 2016a), prepared and executed by the National Nuclear Security Administration (NNSA) and DOE-Environmental Management at LANL (DOE-LA), concluded that the supplemental pressure relief device and other requisite controls identified within the SER would ensure that the maximally exposed individual (MEI) doses from any potential runaway event would not exceed the 25 rem Evaluation Guideline cited within DOE Standard 3009-2014 (DOE 2014a) and would remain below the MEI doses evaluated within the 2008 SWEIS.
The DOE concluded that the SER and referenced LANL safety basis documents provided an adequate basis to understand the proposed RNS activities, sufficiently analyzed the hazards associated with planned activities (including a self-heating and various operational scenarios) and issued sufficient controls to provide adequate protection for the public, workers and the environment. The controls were addressed for bulk processing and had items such as a HEPA filtered temperature controlled negative pressure room and a water fire suppression system in the complex where the repackaging was done. Other controls were similar to the ones addressed in this Documented Safety Analysis (DSA). Pursuant to DOE NEPA implementing procedures in 10 Code of Federal Regulations (CFR) 1021.314(c), a Supplement Analysis (SA) was developed (DOE 2016b) containing information to determine whether:
1 TRU waste containing more than 100 Nano curies of alpha-emitting transuranic isotopes per gram of waste with half-lives greater than 20 years, except for (a) high-level radioactive waste, (b) waste that the Secretary of Energy has determined, with concurrence of the Administrator of the Environmental Protection Agency, does not need the degree of isolation required by the disposal regulations, or (c) waste that the Nuclear Regulatory Commission has approved for disposal on a case-by-case basis in accordance with 10 Code of Federal Regulations Part 61.
2 The radiological release event is described in DOE's Phase 2 Accident Investigation Report (DOE 2015).
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                                     Draft Final
* the 2008 SWEIS should be supplemented,
* a new environmental impact statement (EIS) should be prepared, or
* that no further NEPA documentation is required.3 DOE reviewed various environmental and technical documents, NEPA analyses, and updated accident analyses. Based on these reviews and additional analyses, DOE has determined that the evaluation and analysis within the 2008 SWEIS sufficiently bounds the potential environmental impacts from the proposed action and no further NEPA documentation is required.
This DSA will cover the actions needed to unearth, access, remove, load, transport, unload, and place Modular Concrete Containers (MCC)s and/or Standard Waste Box (SWB, boxes) in above ground storage at the Bin Storage Area 1 (BSA-1) where headspace gas sampling and inspections within the storage area prior to final loading and shipment of SWBs in TRUPACT shipping containers to WIPP.
The graded approach was used to eliminate or minimize the discussion of resources not affected and focuses the analysis upon resources where changes are anticipated (DOE 2016b). DOE has determined that there were no substantial changes in the proposed action relevant to the environmental concerns listed below and will not be addressed:
* Land Use
* Visual Resources
* Geology and Soils
* Water Resources
* Air Quality
* Noise
* Ecological Resources
* Cultural Resources
* Socioeconomics
* Infrastructure
* Environmental Justice
* Emergency Preparedness and Security 3
In addition, 10 CFR 1021.314(c) states the DSA "shall discuss the circumstances that are pertinent to deciding whether to prepare a supplemental EIS, pursuant to 40 CFR 1502.9(c)." The Council on Environmental Quality NEPA regulations (40 CFR 1502.9(c)) require Federal agencies to prepare supplements to either draft or final EISs if "(i) the agency makes substantial changes in the proposed action that are relevant to environmental concerns" or "(ii) there are significant new circumstances or information relevant to environmental concerns and bearing on the proposed action or its impacts."
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                          Draft Final 2     INTRODUCTION 2.1     Purpose As required by the Code of Federal Regulations (CFR) 10 CFR. Part 830, Subpart B this documented safety analysis (DSA) is to document the safety of handling in preparation for disposal of 74 SWBs. These SWBs are currently in storage at Waste Control Specialists (WCS) in the Federal Waste Facility (FWF). The SWBs have been loaded into the MCCs, covered in gravel, and the MCCs were placed in a separate storage area of the FWF and covered with soil. The MCCs will be removed from the FWF and taken to the Bin Storage Area 1 (BSA-1) and staged within an Enclosed Containment Structure (ECS) equipped with a High Efficiency Particulate Air (HEPA) filtration system to control any potential contamination and Heating, Ventilation, and Air Conditioning (HVAC) system to regulate temperature (roughly below 80o F) during SWB handling. The SWBs will be removed from the MCCs within the process area of the ECS and staged in the storage area of the ECS pending DOE headspace gas sampling, inspections, and disposition at WIPP or other DOE provided location.
Waste Control Specialists is considering this operation to be defined as a Below Hazard Category 3 Nuclear Facility/Activity which means the only consequences are less than those that provide a basis for categorization as a Hazard Category 1, 2, or 3 Nuclear Facility/Activity. In DOE-STD-1027, these facilities/activities are categorized as having no potential for significant offsite, onsite, or localized consequences. Below Hazard Category 3 Nuclear Facility/Activity is defined as a DOE facility or activity that meets the definition of a Nuclear Facility/Activity but is below the Hazard Category 3 threshold in DOE-STD-1027. A Below Hazard Category 3 Nuclear Facility/Activity is sometimes referred to as Radiological Facility/Activity.
This DSA will progress through five (5) basic steps:
(1) a facility and work description, (2) a systematic identification of natural and man-made hazards associated with the scope of work (SOW),
(3) an evaluation of normal, abnormal and accident conditions, (4) a derivation of hazard controls; and (5) a description of safety management program characteristics, excluding criticality safety.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                      Draft Final 2.2    Site and Facility Characteristics 2.2.1 Geographic Location WCS controls approximately 14,000 acres of land in northwestern Andrews County. WCS operates a licensed 1,338-acre facility located on a 14,900-acre site in western Andrews County, Texas, Figure 1. WCS offers a comprehensive solution for the treatment, storage and disposal of Class A, B, and C low-level radioactive waste, hazardous waste and byproduct materials. The co-located treatment, storage, disposal, and cask services offer customers the most comprehensive, full-service, complete radioactive waste services in the nation. The WCS site has two approved Resource Conservation and Recovery Act (RCRA) permits from the Texas Commission of Environmental Quality (TCEQ) (HW-50398[2-33] and HW-50397[2-32]) and a Toxic Substances Control Act (TSCA) authorization from the United States Environmental Protection Agency (EPA). WCS also possesses radioactive material license (RML) R04100[2-30] and R05807[2-31]
for low-level radioactive wastes (LLRW) and byproduct material, respectively, Figure 2.
The Texas Compact Waste Facility (CWF) is owned and licensed by TCEQ, operated by Waste Control Specialists. It is the only commercial facility in the United States licensed to dispose of Class A, B, and C low-level radioactive waste from both compact and non-compact generators.
The CWF has a licensed capacity of 2,310,000 cubic feet and 3,890,000 curies of disposal space.
A key component of the CWF is a seven-foot thick liner system which includes a one-foot thick layer of reinforced concrete.
WCS Figure 1, WCS Location in Texas Page 7

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                      Draft Final FWF CWF Figure 2, WCS Facility Locations WCS byproduct facility is comprised of an approximately 16-acre landfill with engineered liner, associated support structures on the surface, and a buffer zone, and provides disposal capacity for approximately one million cubic yards. Disposal in the landfill will occur completely below the top of the Triassic Dockum red beds, which is a laterally extensive and very thick massive clay and sandstone/siltstone formation.
The WCS FWF was designed, permitted and constructed for disposal of Class A, B, and C -LLRW) and Mixed Low-level Radioactive Waste (MLLRW). Upon completion, the FWF has a licensed disposal capacity of up to 26,000,000 cubic feet and 5,600,000 curies total. Upon closure, the federal government takes title to the waste. A key component in the FWF includes a seven-foot-thick-liner system which includes a one-foot-thick layer of reinforced concrete and an-RCRA compliant geosynthetic layer.
The WCS RCRA Waste Facility is capable of processing and disposing of several different forms of radioactive, hazardous and toxic wastes. WCS is authorized to use this facility to dispose of low-activity radioactive waste (LAW or exempt waste) that is less than 10% of the Class A disposal limit as well as RCRA waste and TSCA waste such as PCBs and asbestos.
WCS provides vital disposal services at its Compact Waste Facility (CWF) for Texas generators of LLRW and generators in 34 other states that do not have an operating compact facility. Those generators include nuclear power plants, hospitals and research centers. WCS provides similar Page 8

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                      Draft Final disposal options for the U.S. Department of Energy at its Federal Waste Facility and at its Byproduct Waste Facility.
2.2.2 Location of the Nearest Off- site Member of the Public The National Enrichment Facility (NEF) is a plant for the enrichment of uranium. It is located just across the New Mexico border and is operated 24 hours a day. The plant uses a gas centrifuge technology known as Zippe-type centrifuges. It is located 5 miles (8.0 km) east of Eunice, New Mexico. The NEF is operated by Louisiana Energy Services (LES), which is in turn owned by the URENCO Group.
Permian Basin Materials operates a quarry and crushing operation, wherein caliche, sand and gravel are mined, crushed and screened for commercial sales and used in making concrete.
Sundance Services, Inc. provides oilfield waste disposal services. Sundance Services is authorized by the New Mexico Energy, Minerals and Natural Resources Department to operate the waste oil treating plant, and also manages produced water, solids and drilling muds. Sundance Services is also authorized to land farm solids.
The Lea County (New Mexico) Municipal Landfill is located to the southwest and across New Mexico Highway 234 from WCS. The Lea County Landfill is within 1 mile of WCS. This landfill disposes of municipal solid waste for the Lea County Solid Waste Authority under New Mexico Environmental Department Permit Number SW98-08(P). The landfill services Lea County and its municipalities. The Lea County Municipal Landfill does not generate or receive hazardous waste.
DD Land farm, a non-hazardous oilfield waste disposal facility that closed in August 2013 and is undergoing decommissioning and post-closure monitoring, is located approximately 4 km (2.5 miles) west of WCS.
2.2.3 Location and Description of any Population Centers Eunice, the closest population center (population 3,200), is located approximately 8 kilometers (5 miles) west at the cross-junction of New Mexico Highway 207 and 234. The closest residence from the center of the WCS is approximately 6 km (3.8 mi) away on the east side of Eunice, New Mexico. WCS is about 51 kilometers (32 miles) northwest of Andrews, Texas (population 13,762),
and approximately 32 kilometers (20 miles) south of Hobbs, New Mexico (population 38,277).
The nearest population center with an international airport is Midland-Odessa, located 103 kilometers (64 miles) southeast of WCS (combined population 251,935).
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                      Draft Final 2.2.4 Meteorology Meteorological data have been collected on the WCS property from four (4) meteorological towers stations shown in Figure 3. However as of March 2019 the only tower that is in use for meteorological reasons is Tower 1, RML, R04100, LC173. WCS stations on-site include Tower 1 (Southwest corner), which has been collecting data since March 2009, and it measures temperature, wind direction, wind speed, relative humidity at 2 and 10 meters, barometric pressure, solar radiation, and rain at 2 meters only. WCS has sensors at both the 2-meter (lower) and 10-meter (upper) height intervals. The Emergency Response (ER) Tower (Northeast corner) has been collecting data since July 2009 and it measures temperature, wind direction, wind speed, relative humidity at 2 and 10 meters, barometric pressure, solar radiation, and rain at 2 meters only. WCS has sensors at both the 2-meter (lower) and 10-meter (upper) height intervals. The WeatherHawk West Tower (Northwest corner) has been collecting data since March 2009 and it measures temperature, wind direction, wind speed, relative humidity, barometric pressure, solar radiation, and rain at roughly 10 feet. The WeatherHawk East Tower (Southeast corner) has been collecting data since March 2009 and it measures temperature, wind direction, wind speed, relative humidity, barometric pressure, solar radiation, and rain at roughly 10 feet.
Regionally wind speeds are usually more moderate, although relatively strong winds often accompany occasional frontal activity during late winter and spring months and sometimes occur just in advance of thunderstorms. Frontal winds may exceed 13 meters per second (m/s) (30 miles per hour) for several hours and reach peak speeds of more than 22 m/s (50 miles per hour). Wind speed and direction data measured at the on-site WCS meteorological stations from 2010 to 2015 is shown on wind rose diagrams in Figure 3. The wind roses show the percent of the time (rings) that the wind blows from each of the 16 directions (N, NNE, NE,  NNW) by the length of the bars. The shading of the bars also indicates the frequency of occurrence of wind speeds within the wind speed classes shown on the figures. The on-site data indicates that for this period from 2010 to 2015 the average wind speed ranged from 6.07 knots (3.1 m/s) to 10.53 knots (5.4 m/s). The wind direction is predominantly from the south. The diagrams indicate that wind gusts in excess of 22 mph generally blow from the southwest or northeast, Figure 3.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                      Draft Final Figure 3, WCS Wind Rose Locations The Weather Forecast Office at Midland, Texas covers the High Plains where WCS is located. The climate of WCS in Andrews County, TX can best be described as semi-arid continental marked with four seasons. Summers are typically hot, dry weather with the relative humidity being generally low. July is the hottest month with high temperatures occasionally reaching above 100 degrees Fahrenheit. January is the coldest month, although the winters are not generally severe.
Temperatures occasionally dip below 32 degrees Fahrenheit. Precipitation levels are generally very low in this arid climate. The precipitation tends to be heavier in the summer and fall. During the winter, the regional weather is often dominated by a high-pressure system in the central part of the western United States and a low-pressure system in northcentral Mexico.
The Midland-Odessa monitoring station is the closest first-order National Weather Service station to WCS. First-order weather stations record a complete range of meteorological parameters for 24-hour periods, and they are usually fully instrumental and is operated by the National Weather Service (http://www.ncdc.noaa.gov/homr/).
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                            Draft Final The Western Regional Climate Center (www.wrcc.dri.edu) has historic temperature data for Andrews, TX. The temperature data currently available spans from 1962 until 2010. In Andrews, TX the average annual maximum temperature is 77.5 degrees Fahrenheit, and the average annual minimum temperature is 49.6 degrees Fahrenheit. The normal temperature range for WCS is 44.1 degrees Fahrenheit to 81.5 degrees Fahrenheit (mean monthly temperature). The off-normal maximum and minimum temperature is 30.1 degrees Fahrenheit and 94.6 degrees Fahrenheit (mean daily temperature). The extreme temperature minimum is degree Fahrenheit, and the maximum is 113 degrees Fahrenheit.
Two F2 Class (wind speed from 113 to 157 mph) tornadoes have been recorded in Andrews County, TX from 1950 through 2015 according to data reported by the National Oceanic and Atmospheric Administration (NOAA). NOAA reports there were eight F1 Class (wind speed 73 to 112 mph) tornadoes recorded in Andrews County since 1950. No F4 or F5 tornados have ever been reported in the vicinity of WCS.
Blowing sand or dust may occur occasionally in the area due to the combination of strong winds, sparse vegetation, and the semi-arid climate. High winds associated with thunderstorms are frequently a source of localized blowing dust. Most episodes of dust prevail for only six hours or less, when visibility is restricted to less than 0.5 mile. Statistical information is lacking on seasonal distribution intensity and duration of dust storms for the region.
2.3    

==Background:==

The DOE sent TRU mixed waste from LANL to WCS in Andrews County, Texas for temporary storage before final disposition at the WIPP. After the February 2014 salt truck fire and radiological release events caused WIPP to be shutdown (DOE 2015). At the time, the decision to ship the waste to WCS was intended to be a short-term step that would allow the waste to be delivered to WIPP when recovery from the events were complete and WIPP was accepting waste, but the cause of the radiological event was determined to be due to an exothermic reaction between organic materials and nitrate salts inside a LANL drum. DOE confirmed that some of the LANL TRU waste received for storage by WCS was from the same population that produced the reactive drum at WIPP, eliminating the option to transfer the WCS drums to the WIPP as originally planned.
There were drums with a remediated nitrate salt (RNS) and absorbent (sWheat) mixture, in the 74 SWBs and are referred to as Type 3 waste drums, and have an EPA RCRA Waste Code D001, ignitability. This was assigned specifically due to definition in 40 CFR 261.21 regarding oxidizers and are over packed into SWBs. WCS placed the SWBs into MCCs and placed in the FWF. The void space of the MCC was filled with pea gravel, the lid was put on then covered with sand in an Page 12

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                        Draft Final effort to minimize exposure to the heat. Because they are comingled in a manner that meets WCS special nuclear material (SNM) exemption, the waste drums within each SWB cannot be segregated into their respective categories and all SWBs shall remain intact.
The waste in Type 3 drums have both nitrate salts and organic sorbent which has made them potentially subject to exothermic reaction under specific conditions. Subsequent studies of the potential reactions involving the Type 3 drums were done at Savanah River National Laboratories (SRNL) and a consensus was achieved that the hazardous condition of the waste has changed and is no longer ignitable or corrosive.
2.4    Scope of Work, Process and Operational Characteristics Retrieval of the 35 MCCs containing the 74 SWBs with the drums will begin with the dismantlement of the shade structure and disconnection and removal of all temperature monitoring leads. Ancillary equipment and structures that would preclude removal of the cover material will be removed. Once this is completed, a systematic approach to the removal of the cover material will begin. Starting from the north face of the array and working south the MCCs will be uncovered with the use of heavy equipment for the bulk of the material. Radiation surveys will be performed and if no contamination is found manual removal of the remaining cover material will occur. As the MCCs are uncovered, an inspection and radiological survey of the exterior surfaces will be performed. Next, the MCC lid will be removed and placed aside, and another radiological survey of the exposed surfaces will be performed. Work will stop if any unusual radiation is encountered throughout these steps. A sample of the pea gravel may be taken for gamma spectroscopy analysis. At this time, a thermal temperature gun will be used to validate the temperature of the pea gravel within the MCC is not elevated. The temperature of the pea gravel should be below 100o F (SRNL, 2018). Upon approval of the project manager (PM) activity can continue. The lid must be removed to allow for movement from the FWF using the Kalmar lifting and handling equipment.
It is possible that water intrusion has occurred into the MCCs. If any water is visible above the pea gravel level, it will be collected in a tote and taken to the TSDF for sampling, treatment, and disposal as appropriate. The Kalmar will be used to transfer the MCC to the top of the FWF where the MCC will be loaded onto the Goldhoffer remote controlled transport trailer. Two (2) MCCs will be loaded on the Goldhoffer for transfer the BSA-1.
The MCCs will then be moved on the Goldhoffer from the top of the FWF into the temperature controlled BSA-1 processing area in an ECS. The MCCs will remain on the Goldhoffer during removal of the SWBs. Continuous air monitors will be setup to sample the air in the ECS. A vacuum truck, trailer, or skid mounted system equipped with HEPA filtration system will be utilized, including a sealed, lined waste container for the removal of the pea gravel that covers the SWBs. The vacuum system equipped with a HEPA ventilation system will be setup to handle any Page 13

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                    Draft Final water encountered in the MCCs. As each SWB is exposed, they will be visually inspected for any damage or defects and a thermal temperature gun will be used to validate the temperature of the SWB within the MCC is not elevated. Radiological monitoring and surveys will be ongoing during this process. Once the pea gravel has been removed to the extent practicable around the top tier of SWBs the original rigging that was used to place the SWBs will be replaced with new slings unless a similar approved lifting device is available. The SWB will then be withdrawn from the MCC with the use of a crane and moved to a temperature-controlled laydown area where it will be radiologically surveyed and fully inspected. Each SWB will be placed into storage in the BSA-1 ECS. This process will continue until all MCCs are emptied and all SWBs are relocated in the BSA-1 pending shipment offsite by DOE.
With the SWBs in the BSA-1 the DOE will perform headspace gas sampling and analysis and replace the four (4) filter vents in the SWBs within the BSA-1 ECS, and perform a borescope inspection of the drums within the SWB through the filter vent locations. Based on this action, if DOE EM-LA determines the waste meets the WIPP waste acceptance criteria (WAC) it will be shipped from WCS to WIPP via TRUPACT for permanent disposal. It should be noted that removal of the lid on the SWBs is not a part of this operation. The headspace gas analysis and borescope inspections will be performed through existing penetrations on the SWB. The drums inside will not be opened, therefore the amount of activity available outside the drum should be essentially zero. If activity is found on the drum inside the SWB, this will be documented and communicated to the appropriate personnel for further evaluation, as needed. The contamination control limit for all SWBs loaded into TRUPACT II/III and/or HalfPACTs per the DOE Contract, 30 TAC &sect;336.364 Appendix G, WCS Radiation Work Permit and WCS Procedures is 20 dpm/100 cm2 Alpha and 200 dpm/100 cm2 Beta/Gamma. If contamination is found above these limits, work is paused, and notifications are made to the WCS Radiation Safety Supervisor and Managers for direction and process to proceed per WCS Procedures.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                           Draft Final 3    HAZARD CATEGORIZATION Table 1 in Appendix A to Subpart B of 10 CFR Part 830, defines the nuclear facility hazard categories (HC). This table is clarified below.
Table 1: Clarification of Table 1 in Appendix A of Subpart B of 10 CFR Part 830 A DOE nuclear facility categorized as             Has the potential for Significant off-site consequences.
Category A reactor or DOE nonreactor nuclear Hazard Category 1 facilities designated by the Program Secretarial Officer (PSO).
Significant on-site consequences beyond localized consequences. DOE nonreactor nuclear facilities with the potential for nuclear criticality events or DOE nuclear facility, including Hazard Category 2                                  Category B reactors, with sufficient quantities of hazardous radioactive material and energy (i.e.,
greater than HC-2 Threshold Quantities (TQ) in Attachment 1, DOE 2018), which would require on-site emergency planning activities.
Only local significant consequences.
DOE nonreactor nuclear facilities with quantities of Hazard Category 3 hazardous radioactive materials which meet or exceed the HC-3 TQs.
Only consequences less than those that provide a basis for categorization as a hazard category 1, 2, or 3 nuclear facility. DOE nonreactor nuclear Below Hazard Category 3                            facilities with quantities of hazardous radioactive materials less than the HC-3 TQs. These facilities are not required to comply with the requirements of 10 CFR Part 830, Subpart B.
3.1    Initial Hazard Categorization Initial hazard categorization is intended to be a simple screening step that does not involve detailed computations, which will enable facility managers to quickly determine the likely facility hazard categorization. The consideration of material form, location, dispersibility and interaction with available energy sources called for in final hazard categorization is not applicable to initial hazard categorization.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                        Draft Final For mixtures or combinations of radioactive materials, the sum of ratios (SOR) is determined by dividing each radionuclide's activity or mass by the appropriate threshold quantity (TQ) and adding the resulting values.
n Q   Q          Q SOR =   1  +  2  +        +  N i =1  TQ1   TQ2      TQN Where:
n       =      Number of radionuclides Q       =      Quantity of nuclear material (Ci or grams)
TQ      =      Threshold quantity relative to radionuclide species (Ci or gm)
If the SOR is greater than or equal to a value of 1.0, the facility shall be initially categorized as HC-2 or HC-3 depending upon the TQs used in the calculation. If the SOR is less than 1.0, when compared to the HC-3 TQs, the facility is categorized as Below HC-3. Criticality is not a concern with this material.
The radionuclide inventory present in the waste was taken from the Shipping Requests and Manifests describing the content of the waste shipped to WCS on the inventory of radionuclides from the 74 SWBs. The fission products Cs-137 and Sr-90 have much higher TQs and are not included. The data was tabulated, and the summary statistics of this population is given in Table
: 2. The TQs for Category 2 and 3 are given in Table 3 along with the number of drums in each category.
Table 2: Statistical Data on the WCS LANL Waste Drums, grams Parameter            Am-241        Am-243          U-233      U-234         U-235         U-238 Average                6.18          0.010           3.32       0.04        10.32         571.19 Std Dev                4.27          0.013           2.09       0.12        12.96          2,730 Median                 4.36          0.006           2.93       0.00         4.61           180 Maximum               28.34          0.080          10.22       0.58        68.25         20,190 Minimum                0.28          0.000           0.00       0.00         0.00           48.7 95th Percentile       15.19            0.03          8.07       0.18        35.59          1393 99th Percentile       21.81            0.06          9.19       0.55        53.56          7713 Parameter            Total Pu       Pu-238         Pu-239     Pu-240       Pu-241         Pu-242 Average                126             0.04          116        8.54         0.19           0.71 Std Dev                54.4            0.18          49.4       4.67         0.14           4.69 Median                 119             0.02          112        7.69         0.17           0.05 Page 16

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                      Draft Final Parameter           Am-241       Am-243         U-233       U-234         U-235         U-238 Maximum                235         1.32           214         27.8         0.91          33.8 Minimum                18.0        0.00          15.9         2.03         0.04          0.01 95th Percentile        210         0.06           194        16.99         0.41          1.57 99th Percentile        233         0.66           211        20.05         0.64          15.9 Table 3: Hazard Category Threshold Quantity, grams Parameter               Am-241      Am-243        U-233       U-234        U-235        U-238 Average                   6.18        0.010         3.32        0.04       10.32        571.19 Median                    4.36        0.006         2.93        0.00        4.61        179.58 Maximum                  28.34        0.080        10.22        0.58       68.25       20,190.8 Category 2 TQ             24.6         424        87,300    1.38E+05     4.41E+08     3.02E+09 Category 3 TQ            0.835         14.4        1,330       2,100     6.71E+06     4.55E+07 Parameter               Pu-238       Pu-239       Pu-240     Pu-241       Pu-242 Average                   0.04       116.27         8.54        0.19        0.71 Median                    0.02       111.60         7.69        0.17        0.05 Maximum                   1.32       214.48        27.84        0.91       33.81 Category 2 TQ             4.31        1,093         297         34.2      18,800 Category 3 TQ            0.152         38.2         10.4        1.28        647 Using the activity for each radionuclide in each of the 74 SWBs and dividing it by the TQ for each radionuclide then taking the sum of fractions for all nuclides results in are seven (7) SWBs in Category 2. The remaining SWBs are at the Category 3 level.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                            Draft Final 4     HAZARD EVALUATION The initial analytical effort is a hazard analysis that systematically identifies and evaluates facility hazards and accident potentials. The hazard evaluation identifies the initiating event, scenario development, associated controls, consequences, and likelihood. The latter two parameters are often used to specify risk ranking for a given event. Risk ranking in this context is a simple mechanism to summarize the events significance in terms such as low, moderate, and high consequences and anticipated, unlikely, extremely unlikely, and beyond extremely unlikely likelihoods.
Beyond the qualitative application of consequences and likelihoods (or supplemented with quantitative perspectives) for the hazard evaluation, risk ranking serves the broader purpose of confirming that the overall mitigated risk of facility operation is low. Risk ranking can also highlight a given scenario whose mitigated risk remains significant. Table 4 gives an example risk-ranking table that combines likelihood and consequence.
Table 4: Qualitative Risk Ranking Bins1 Consequence          Beyond              Extremely            Unlikely             Anticipated Level                Extremely           Unlikely             10-2 to 10-4/yr      Above 10-2/yr Unlikely2           10-4 to 10-6/yr Below 10-6/yr High III                    II                   I                  I Consequence Moderate IV                    III                   II                 II Consequence Low IV                   IV                    III                III Consequence I = Combination of conclusions from risk analysis that identify situations of major concern II = Combination of conclusions from risk analysis that identify situations of concern III = Combination of conclusions from risk analysis that identify situations of minor concern IV = Combination of conclusions from risk analysis that identify situations of minimal concern 1
  . Industrial events that are not initiators or contributors to postulated events are addressed as standard industrial hazards in the hazard analysis.
2
  . For external events, likelihood below 10-6/yr conservatively calculated is Beyond Extremely Unlikely.
Preventive or mitigative controls are selected using a judgment-based process considering a hierarchy of control preferences.
* Control selection strategy to address hazardous material release events is based on the following order of preference at all stages of design development.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                         Draft Final
* Minimization of hazardous materials, including radioactive and non-radioactive, is the first priority.
* Safety significant (SS) structures, systems, and safety significant controls (SSCs) are preferred over specific Administrative Controls and other administrative controls.
* Passive SSCs are preferred over-active SSCs.
* Preventative controls are preferred over mitigative controls.
* Facility safety SSCs are preferred over personal protective equipment.
* Controls closest to the hazard may provide protection to the largest population of potential receptors, including workers and the public.
* Controls that are effective for multiple hazards can be resource-effective.
4.1    Common Hazards In accordance with DOE-2014, the DSA is not intended to deal extensively with chemicals that can be safely handled by implementation of a HAZMAT protection program. A screening process is established to select for DSA evaluation only those chemicals of concern (i.e., type and quantity that have the potential for significant health effect on the facility worker, co-located worker, or public) that are present in the facility or activity and present hazard potentials outside the routine scope of the HAZMAT protection program. Chemicals that could otherwise be screened out but have the potential to be an accident initiator involving radioactive or HAZMAT releases or could compromise the ability of the facility operators to safely manage the facility, are retained as part of the DSA hazard evaluation.
Examples of chemicals that may be excluded from the DSA hazard evaluation include:
* Chemicals with no known or suspected toxic properties. This exclusion may be claimed when a chemical is not listed in OSHA or U.S. Environmental Protection Agency (EPA) toxic chemical regulations or is not assigned a Protective Action Criteria (PAC) 2 or 3 value on the website of the Subcommittee on Consequence Assessment and Protective Actions (SCAPA).
* Materials that have a health hazard rating of 0 or 1, based on NFPA 704, Standard System for the Identification of the Hazards of Materials for Emergency Response, or equivalent ratings from Global Harmonization System of Classification and Labeling of Chemicals.
* Materials that are commonly available and used by the general public, including any substance to the extent it is used for personal, family, or household purposes and that is present in the same form, quantity, and concentration as a product distributed for use by the general public (e.g., bleach, motor oil).
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                            Draft Final
* Small-scale use quantities of chemicals similar to the intent of 29 CFR 1910.1450, Occupational Exposure to Hazardous Chemicals in Laboratories (i.e., containers that are designed to be easily and safely manipulated by one person). A general guideline, as described in DOE Guide 151.1-2, Technical Planning Basis, is individual containers with capacities less than approximately 5 gallons (19 liters) for liquids with densities near that of water, 40 pounds (18 kg) for solids (or heavy liquids), or 10 pounds (4.5 kg) for compressed gases, that are handled under the provisions of an identified Safety Management Program (SMP) such as the HAZMAT protection program.
4.2   Specific Administrative Controls Specific administrative controls (SACs) are administrative controls (ACs) identified in the safety analysis as a control needed to prevent or mitigate an accident scenario and has a safety function that would be safety structures or safety controls if the function were provided by an SSC. SACs have safety importance equivalent to engineered controls that would be classified as SS if the engineered controls were available and selected. In general, SSCs are preferable to administrative controls (ACs) or SACs due to the inherent uncertainty of human performance. However, SACs may be used to help implement a specific aspect of a programmatic AC that is credited in the safety analysis and therefore has a higher level of importance. In some cases, supporting SSCs (e.g.,
instrumentation, controls, and equipment) may need to be identified and credited in conjunction with the SAC.
4.3     Safety Significant Controls Safety significant (SS) and safety significant control (SSC) designation shall be made based on the controls contribution to:
(1) defense-in-depth, (2) protection of the public from release of hazardous chemicals, (3) protection of co-located workers from hazardous chemicals and radioactive materials, and (4) protection of in-facility workers from fatality, serious injury, or significant radiological or chemical exposure.
The applicable quantitative and qualitative criteria for these various categories of affected persons or areas may have increased controls. Controls that provide a major contribution to defense-in-depth shall be designated as SS. These controls (SSs and SSCs) should be technically defensible, based on candidate controls in the hazard evaluation or accident analysis. The ECS inside the BSA-1 is considered an SSC for controlling the exposure to the worker and member of the public safety.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                         Draft Final The principal hazard analyzed for is the potential for the release of radiological material associated with the TRU waste resulting from fires, deflagrations/over-pressurizations, and loss of confinement events due to in-process activities, external initiation, or Natural Phenomena Hazard (NPH) initiated events. Hazard identification characterized the hazards, both man-made and natural, in terms of type, quantity, and form of radioactive and other hazardous materials, and included screening of standard industrial hazards and chemical hazards. The hazard evaluation considered how those hazards not screened out can lead to hazardous conditions or events that may cause release of radioactive or hazardous materials, and addressed the following seven (7) event types from DOE-2007:
* Fires
* Explosion/energetic events
* Loss of confinement/containment
* Direct exposure to radiation
* Criticality events
* Externally initiated events
* Natural phenomenon hazard (NPH) events The events that are carried forward into the DSA for control selection include:
4.3.1 Fires
* Fires from collision of vehicles
* Fires from leaks of fuel or hydraulic fluids
* Ordinary combustible fires adjacent to waste, including fire propagation in waste materials involving combustible materials
* Fires initiated within non-compliant waste 4.3.2 Explosion/energetic events
* Deflagration within non-compliant waste
* Over-pressurization within non-compliant waste
* Waste container (drum or box) deflagration 4.3.3 Loss of Confinement/containment
* Vehicle/equipment impact with waste container
* Drop/Impact/Spill
* Collapse of stacked containers
* Waste container over-pressurization
* Puncture of waste container
* crushing of waste container due to collisions with vehicles or equipment Page 21

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                        Draft Final 4.3.4 Direct exposure to radiation
* External
* Internal 4.3.5 Criticality events These are considered beyond extremely unlikely due to limitations on quantities of fissile material in the handling at WCS.
4.3.6 External events
* Wildland fire penetrates building
* External vehicle accident with fire
* Exothermic chemical reaction within non-compliant waste
* External explosion 4.3.7   Natural phenomenon hazards
* Tornado
* Lightning strikes
* Seismic events
* Snow/Ice buildup
* Aircraft impact Other events/event types (e.g., criticality events, tornado/high winds, aircraft impact, seismic event, and chemical exposure) did not carry forward into the DSA for control selection (screened out) because they were:
* Risk Class III/IV
* Low consequence to all receptors
* Not plausible per DOE-2014 (not physically possible)
* External event frequency of occurrence less than 1E-6/yr Further evaluation and control selection is not required for hazard events that are screened out.
Their screening may be based on credited Initial Conditions (ICs), design specific assumptions, calculations, and/or physical characteristics of the site. The DSA states that these events were reviewed to determine whether any associated controls warranted safety classification even though the event was unmitigated Risk Class III or IV.
4.4   Initial Conditions As indicated above, in some cases, events were not carried forward (i.e., did not have an unmitigated Risk Class of I or II) based on identified passive initial conditions which are permitted Page 22

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                        Draft Final to be included in unmitigated analyses. Even though these event types were not carried forward, their initial conditions relied upon for their exclusion are required to be specifically protected in the safety basis. Initial conditions relied upon for event exclusion but protected by safety significant (SS) controls are:
4.4.1 SWB Overpack of the Drums (DESIGN FEATURE)
The drums are overpacked in a sealed SWB and will not be removed. The integrity of the SWB is expected to be in good condition given the short duration within the MCC; however, until inspections can be performed, the SWB overpack will only be credited for protection of the worker once a thorough inspection has occurred when removed from the MCC. The integrity of the SWB and drums will be inspected as discussed in &sect; 2.4.
ADMINISTRATIVE CONTROL No worker will be allowed to lean (head or torso) over the top of the SWB until the inspection is complete.
4.4.2 Fuel and Oil Storage Locations (DESIGN FEATURE)
The placement of and controls of flammable materials is controlled by WCS to lower risks by design.
* Located away from waste handling and storage areas.
* Defined in the configuration of the site.
* Reduces the likelihood that fires and/or explosions at fuel or oil storage locations could affect the handling and storage of waste.
4.4.3    Bin Storage Area 1(BSA-1) (DESIGN FEATURE)
The BSA-1 serves as a confinement area by having barriers to control the potential for release of hazardous and/or radioactive material. Concrete floors with containment curbs all around the building. Metal panels and roll-up doors.
* High Wind Protection.
* Constructed as Type II per the Standard on Types of Building Construction (NFPA 220).
* Commercial grade building designed to standard building code wind gusts (90 mph).
* Reduces the likelihood for impacts to Waste Containers located in the BSA-1.
4.4.4    Enclosed Containment Structure (DESIGN FEATURE)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                        Draft Final An ECS will be built inside the BSA where all work will be performed within this sealed structure.
This structure will be the primary control measure as the barrier in the event of an unlikely release of radioactive material. It will be temperature controlled with HEPA ventilation to maintain the structure at a negative pressure during movement, inspection, and handling of the SWBs. The design will allow the MCC to be placed inside it for SWB removal.
ADMINISTRATIVE CONTROL Workers within the ECS that ae handling the SWBs will be suited in protective PPE as required by the WCS radiation safety program radiation work permit (RWP). Workers may wear a positive pressure respirator within a hood. Lapel air samplers will be used to monitor the breathing air around the worker. Area continuous air monitors (CAM) will be placed within the structure as a monitoring precaution. If considered necessary, an alarming CAM may be used.
4.4.5 Noncombustible Construction and Curbing. (DESIGN FEATURE)
* Constructed primarily of metal and concrete with exterior surfaces and
* Roofing consisting of noncombustible material.
* Curbing extending approximately 9 above the floor.
* Reduces the likelihood for small fires propagating into a large fire.
* Reduces the likelihood for a fire originating external to the BSA-1 to penetrate the outer wall.
4.4.6   Roof Loading. (DESIGN FEATURE)
* Roof designed to withstand 20 pounds per square foot (lb/ft2) of snow load.
* Roof designed for snow load for Andrews County Texas of 10 lb/ft2.
* Reduces the likelihood for collapse of the roof that could result in the loss of confinement of radiological material.
4.4.7 Seismic. (DESIGN FEATURE)
Designed and constructed to International Building Code Standards at 0.294g for short periods and 0.074g for 1 second periods.
4.4.8 Container (Drums or boxes) Integrity. (DESIGN FEATURE)
U.S. Department of Transportation (DOT) 7A or equivalent drums purchased for the packaging and storage of TRU waste provide containment of radioactive materials and minimize release of radioactive material to the public and workers. DOT 7A drums must meet the performance testing requirements specified in 49 CFR Part 173.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                        Draft Final When purchased, TRU waste drums are certified to DOT specifications. Legacy TRU waste drums greater than one year, therefore, have lost their DOT certification, but have not stopped performing their intended function. Type 7A drums that meet DOT specifications and conditions most applicable to DOE TRU waste activities are qualified to withstand an impact from a 4-ft drop onto a hard surface without being breached.
It is not reasonable to assume that the structural capability of SWBs and drums, exceeding one year, has diminished significantly or that these drums will split open upon any impact. This is supported by field experience during handling, movement and storage evolutions. Although handling activities do not subject the drums to the same loads as does an impact from a drop, these activities, along with regular inspections, do provide some evidence that most of the drums have maintained structural capability.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                           Draft Final 5    SOURCE TERM The source term (ST) is the amount of radioactive material, in grams or curies, released to the air and environment. The initial source term is the amount of radioactive material driven airborne at the accident source. The initial respirable source term, a subset of the initial source term, is the amount of radioactive material driven airborne at the accident source that is effectively inhalable.
The dose from the inhalation pathway will dominate the overall dose because the external exposure rate of the material is low.
The ST will be used in an unmitigated analysis with unmitigated meaning no credit is given to preventive and mitigative controls to reduce the frequency or consequence of potential accidents.
The unmitigated accident scenario is intended to represent a reasonably conservative bounding analysis of potential consequences independent of their likelihood of occurrence (as long as these are physically plausible). A general unmitigated analysis requires:
* Consider material quantity, form, location, dispersibility, and interaction with available energy sources. The unmitigated release calculation represents a theoretical limit to scenario consequences if all safety features including administrative controls have failed, so that the physical release potential of a given process or operation is conservatively estimated. The unmitigated release should characterize the energies driving the release and the release fractions in accordance with the physical realities of the accident phenomena at a given facility or process.
* Take no credit for active safety features such as ventilation, filtration systems, and process controls. In addition, do not credit passive safety features producing a leakpath reduction in building source term, such as building filtration.
* Do not credit building wake in calculating the public or worker doses unless shown to yield more conservative or bounding results. There is considerable uncertainty associated with such analysis, e.g., concentration within the recirculation cavity or immediately downwind from the cavity depends on the release location from the building, size of building and structures around the facility, wind speed and direction, etc.
* The analysis may take credit for passive safety features where the capability is necessary to define a physically meaningful scenario. The effect of acknowledging passive features to define a meaningful accident scenario in the unmitigated analysis means that the unmitigated analysis is not necessarily a parking lot release expectation.
* In general, credit must not be taken for administrative controls (e.g., combustible controls or restrictions). Based on experience within the DOE complex, an exception is application Page 26

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                             Draft Final of a material at risk (MAR) control as an initial condition to preserve a Hazard Categorization (HC)-3 designation (e.g., for low-level waste storage).
5.1    Airborne Pathway The airborne pathway is of primary interest for nonreactor nuclear facilities. DOE-STD1027-92 quotes observations of the NRC to the effect that "for all materials of greatest interest for fuel cycle and other radioactive material licenses, the dose from the inhalation pathway will dominate the (overall) dose" (NUREG-1140). As specified in DOE-2013, the airborne source term is estimated by the following five-component linear equation:
Source Term = MAR x DR x ARF x RF x LPF where:
MAR     = Material-at-Risk (curies or grams),
DR      = Damage Ratio, ARF     = Airborne Release Fraction (or Airborne Release Rate for continuous release),
RF      = Respirable Fraction, and LPF      = Leakpath Factor.
The initial source term and initial respirable source term are products of the first three factors and first four factors respectively.
5.1.1 Material-at-Risk The material-at-risk is the amount of radionuclides (in grams or curies of activity for each radionuclide) available to be acted on by a given physical stress. For this process the MAR is a value representing some maximum quantity of radionuclide(s) present or reasonably anticipated for the process or structure being analyzed. Different MARs may be assigned for different accidents as it is only necessary to define the material in those discrete physical locations that are exposed to a given stress.
For example, a spill may involve only the contents of one box or drum. Conversely, a seismic event may involve all the material in a building.
5.1.2 Damage Ratio (DR)
The damage ratio is the fraction of the MAR actually impacted by the accident-generated conditions.
A degree of interdependence exists between the definitions of MAR and DR. If it is predetermined that certain types of material would not be affected by a given accident, some analysts will exclude this material from the MAR. The DR is estimated based upon engineering analysis of the response of structural materials and materials-of-construction for containment to the type and level of stress/force generated by the event. Standard engineering approximations are typically used. These approximations often include a degree of conservatism due to simplification of phenomena to obtain a useable model, Page 27

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                          Draft Final but the purpose of the approximation is to obtain, to the degree possible, a realistic understanding of potential effects.
In accordance with DOE-2007 the following DRs for deflagrations within a drum must be used, unless otherwise justified, for TRU wastes in metal drums:
5.1.2.1 Single, SWB with 4 55 Gallon Drums Drum deflagration is discussed in DOE-2007 under Container Deflagration Events (&sect; 4.4.2) and states:
* For a SWB, lid loss will not occur for a container deflagration, because the lid is very heavy and bolted onto the body of the box.
* Overpacking a metal drum of sound integrity with a larger metal drum, a SWB, with nested metal drums can be credited to prevent lid loss and ejection of contents.
* For the SWB and the overpacked drum, a significant release from potential venting through the outer container seal is not expected. Any potential release from venting through the outer container would be bounded by mechanical impact evaluations (e.g., spill-type release). Additionally, a subsequent fire will be limited by the availability of oxygen remaining after the deflagration or in leakage through damaged seals.
5.1.2.2 Flammable Liquid Pool Fire To simplify the modeling approach, drum contents are assumed to be 100% combustible contaminated solid wastes. The response of metal containers to fire depends on whether the heat transfer is through direct flame impingement or only through radiation. Lid loss can occur only if specific conditions are met (e.g., a fast fire growth rate, direct flame impingement, etc.).
Engulfing fires are those fires in which burning liquid fuel (including melted drum liners) passes beneath the container (e.g., on a pallet) or surrounds it. These fires can cause lid loss to a fraction of the engulfed drums, which may expel a portion of the contents.
For drums that experience lid loss, one-third of the contents (33%) are assumed to be ejected from the drum and burn as unconfined materials. The other two-thirds of the MAR are assumed to stay inside the drum and burn as confined materials. The DR is 1.0 for each portion, or this could be thought of as a DR of 0.33 of the total MAR for the expelled portion and 0.67 for the remainder in the drum.
Although SWB lids are bolted in place and are not expected to be lost, they are evaluated for releases from seal failure. A similar DR for seal failures of SWBs is established based on physical consideration that four drums are approximately equivalent to one SWB. This results in a DR of Page 28

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                          Draft Final 0.5 for more than two SWBs involved in a fire (i.e., 10 drums divided by 4 and rounded up).
However, a DR of 1.0 is assumed for one or two SWBs involved in the fire.
5.1.2.3 Ordinary Combustible Fire Non-pool fires are those that involve ordinary combustibles such as trash, wooden boxes, clothing, etc. This type of fire has a moderate fire growth rate. Fire experiments have demonstrated that lid loss and ejection of contents is not expected, so for modeling purposes, only seal failures are evaluated. This could include trash fires and wooden crate fires. For direct flame impingement on only one side of a container from an adjacent ordinary combustible fire, the container is not heated rapidly enough to cause lid loss and ejection of contents. When heat transfer is only through radiation, fires involving non-liquid fuel packages (e.g., trash) were determined to not result in lid loss. The heat output of the fire is insufficient to increase temperature and pressure inside the drum quickly enough to eject the lid before venting (seal failure) occurs. The container must be close enough to the fire such that it is exposed to a sufficient heat flux. If room flashover is possible for the DSA unmitigated analysis, then all containers are subject to seal failures. A DR of 1.0 is assumed for less than 10 drums due to this uncertainty regarding the amount burned and whether there is uniform contamination. If the contents are radioactive flammable or combustible liquids and no combustible solid wastes, the release must be modeled assuming a DR of 1.0 for lid loss and subsequent burning of the liquid inside or outside the drum.
The dimensions of the SWB are nominally 5 ft long, 4 ft wide, and 3 ft tall, with rounded sides to fit within the TRUPACT-II container for shipments to WIPP. The walls are typically 10- to 12-gauge (about 0.1 in.) sheet metal, and the drum is sealed with a gasket and lid with 42 bolts. Both the outer box and inner drums in an overpack assembly must have vents installed. For a radioactive material release to occur, the fire has to heat up the inside of the SWB and also heat the inner contents of the 55-gal drums resulting in pyrolization of the drum contents and subsequent venting from both containers. The SWB configuration presents a significant heat sink and pyrolization of drum contents would require a very long-lasting fire or a very large fire. Another consideration is that the SWB is large, therefore, it is not expected that all of the waste will be affected by a fire.
Therefore, a DR of 0.1 is assumed for overpacked drums of sound integrity whether overpacked in a larger drum or a SWB. This applies to a single or multiple overpacked containers exposed to the radiant heat flux that causes seal failures.
5.1.2.4 Mechanical Insults Based on extrapolations and interpretation of the test data as well as DOE Complex precedence for container drops or impacts the following (from DOE 2007) must be used, unless otherwise justified, for TRU waste operations. These DR recommendations apply a gradation based on energy imparted and container robustness for the range of container breaches presented, Table 5.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                     Draft Final Table 5, Container Drop and Impact Damage Ratios Damage Ratio (DR)
Accident Stress                                           Comments Drum (SWB)
Containers of sound integrity
: 1. Stress within container qualifications          0.0 (0.0) dropped from 4 ft or less (e.g.,
2nd tier in stacked array).
: 2. Minor stress causes breach, e.g.:
 - Single container or unbanded palletized containers dropped from 3rd tier in stacked array
 - Multiple containers impacted by low-speed           0.01 Considered a spill event vehicle (e.g., less than ~10 mph in congested        (0.01) or tight areas)
 - Containers containing closed pipes or welded containers that are dropped from 4th or 5th tier in stacked array
: 3. Container(s) punctured by forklift tines:                 Considered a spill or "low-
 - Contaminated solids                             0.1 (0.05) energy impact" event. Forklift
 - Sand-like materials                              1.0 (0.5) could puncture two drums.
: 4. Single container or un-banded palletized                  4th tier falls are considered a containers dropped from 4th or 5th tier in                   low-energy impact event.
stacked array:                                                5th tier falls are considered a
 - Contaminated solids                              0.1 (0.1) "high energy impact" even.t
 - Sand-like materials                             0.5 (0.25)
: 5. Moderate to severe stress causes breach, e.g.:
 - Multiple containers impacted by a vehicle whose speed may be restricted by physical                    Considered a low-energy layout of the facility/site and associated             0.1   impact event unless containers obstacles, but whose speed can't reasonably           (0.1)  could be crushed as defined due be assumed to be < ~10 mph                                   to site-specific circumstances.
 - Vehicle crash affecting multiple containers, but not in the first row directly crushed by the vehicle (low or high speeds)
: 6. Catastrophic stress causes breach, e.g.:                  Containers crushed by > ~25%
1.0
 - Containers directly impacted by highspeed                  volume reduction are considered (1.0) vehicle with crushing force                                  a "high energy impact" event.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                       Draft Final Damage Ratio (DR)
Accident Stress                                               Comments Drum (SWB)
 - Container(s) impacted by compressed gas cylinder traveling long distance and/or                           Cylinder and missiles are airborne                                                          considered a low energy
 - Container(s) impacted by tornado- or wind-                      impact event.
generated missile For a SWB, lid loss will not occur for a container deflagration, because the lid is very heavy and bolted onto the body of the box, DOE-2007.
5.1.2.5 Natural Phenomena Damage Ratios The natural phenomena hazards (NPH) discussion focuses on seismic events affecting existing TRU waste container storage facilities because they usually dominate the extent of potential damage and amount of material released, thus, the radiological consequences. High wind events and tornadoes may also cause extensive damage, including collapse of a structure. However, their radiological dose is much lower due to the higher winds causing dispersion of releases.
The general approach is to estimate DRs based on whether or not a facility structure survives the event or collapses. For collapse events, a footprint of damage is defined to determine the number of drums impacted, and effect on stacked drums. If the facility does not collapse, waste containers may be impacted and breached by falling objects (e.g., lights, fire suppression sprinkler lines) and other overhead equipment not seismically rated in the structure that are not qualified earthquake design codes.
The BSA-1 includes structural steel framing with sheet metal siding and roof. An earthquake that causes collapse of the structure is called a Collapse Earthquake for the purposes of this DR discussion. During a Collapse Earthquake, 100% of the exposed packages may be assumed impacted by falling debris in a facility of this construction. This debris would include massive chunks of steel from a ceiling or roof. All waste containers inside buildings are affected, because of impact from falling objects and collapsing building components such as walls, roofs, and structural I-beams.
However, as discussed next, not all impacted containers are assumed to be breached. For both medium and substantial construction facilities, the amount of damage to an impacted package depends on its construction, as follows.
* A DR of 0.1 is considered reasonably conservative given the various mechanisms by which containers may be compromised (uplift, toppling, rolling and impact, equipment or Page 31

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                            Draft Final building falling on the containers, missile strike). This value does not apply if only a couple of drums are impacted, where a 1.0 breach fraction must be assumed. For SWBs, a DR of 0.1 applies.
* For SWBs, the same 10% assumption as for drums applies.
* Based on the engineering evaluations stacks of SWBs payloads are not expected to topple (i.e., the DR would be zero) unless the site-specific engineering analysis determines otherwise.
5.1.3 Airborne Release Fraction (ARF)
The ARF is the coefficient used to estimate the amount of a radioactive material suspended in air as an aerosol and thus available for transport and potential intake due to physical stresses from a specific accident. For discrete events, the ARF is a fraction of the material affected. For mechanisms that continuously act to suspend radionuclides (e.g., aerodynamic entrainment/resuspension), a release rate is required to estimate the potential airborne release from postulated accident conditions. Generally, accident release rates (ARRs) are based upon measurements over some extended period to encompass most release situations for a particular mechanism. The rates are average rates for the broad spectrum of situations and, as such, the most typically meaningful time unit to reflect average conditions is 1 hour. There is evidence that in some situations (e.g., aerodynamic entrainment of sparse powder deposits on a heterogeneous surface), the rate of release is not uniform with time. Even in the situations where the rates are relatively uniform, the source is depleted by the removal of particles from the surface by aerodynamic forces, and the amount of material airborne decreases with time unless the source is continuously replenished.
5.1.4 Respirable Fraction (RF)
The RF is the fraction of airborne radionuclides as particles that can be transported through air and inhaled into the human respiratory system and is commonly assumed to include particles 10-m Aerodynamic Equivalent Diameter (AED) and less. The U. S. Environmental Protection Agency defines "inhalable dust" (particles penetrating the upper respiratory airway and entering the thorax) with a 50% cutoff at 15-m AED. Accordingly, use of a 10-m AED cut-size for respirable particles is considered conservative, and may even be overly conservative since the mass is a cube function of particle diameter.
RFs for particles made airborne under accident-induced stresses are dependent upon a variety of factors, such as the bulk density (i.e., how well the powder at rest compacts), the presence of moisture, how effectively the type and level of stress deagglomerates the powder or subdivides the solid/liquid, the efficiency with which the stress suspends the powder/fragments of solid over varying size ranges, and the degree of immediate proximity of surfaces on which airborne particles may impact/settle.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                            Draft Final The ARF*RF values that were used in the analysis of postulated events were taken directly from DOE-2007 (&sect; 4.5, Table 4-5.1) and are summarized in Table 6.
Table 6, ARF*RF Value Applicable to TRU Waste Accidents, Combustible Cellulose and Plastics Waste Form                                                                 Mechanical Insults Over-(surface             Explosion                              Fire Pressure                        Spill          Impact contaminated)
Ambient Atm.              (see fire)             --            1E-2            --             --
In Container             (see fire)           1E-4            5E-4          1E-4         1E-4/2E-3 In-flight                 1E-4                --              --            --             --
5.1.5 Leakpath Factor (LPF)
The LPF is the fraction of the radionuclides in the aerosol transported through some confinement deposition of filtration mechanism. There can be many LPFs for some accident conditions (e.g., the fraction transported from the package, such as a shipping container, to the surrounding area; the fraction leaked from the enclosure, cell, or glovebox to the operating area around the enclosure or room; the fraction leaked from the room to the building-atmosphere interface). Where multiple leakpaths are involved, their cumulative effect is often expressed as one value that is the product of all leakpath multiples. The LPF is a calculated or standard value based upon:
(1) established relationships between size of the particulate material, airborne transport mechanisms, and losses by deposition mechanisms, or (2) specified filtration efficiencies.
A final emphasis is necessary regarding application of this data. Data developed for the NRC and DOE has never been intended to be used as absolute proof of anything. Special attention has been given to understanding suspension phenomena, ranges of relevant parameters covered in experimental studies, artifacts or limitations of the data that may have been induced by experimental conditions, and possible effects of relevant parameters that may not have been controlled or monitored. As noted, this has resulted in development of bounding ARFs and RFs.
The purpose of developing these values was:
(1) to better understand the potential bounding hazards presented by nonreactor nuclear facilities, (2) to provide information to support general bases of decision making.
The interpretation of data does not consider material momentarily airborne from substrate mass ejection due to physical stresses acting on the substrate mass as an aerosol suspended in air. For Page 33

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                        Draft Final example, in fire and boiling events, fuel mass and volumes of solution may be observed to splatter or launch from the experimental substrate and land on surfaces in the local vicinity. The radioactive contamination carried with this material that deposits and is measured on the adjacent surfaces is not an aerosol suspended in air and does not travel on air currents. It represents a source of highly localized migration that is not amenable to meaningful prediction and is not relevant to the issue of how much material might be expected to escape the immediate area and disperse in air.
5.1.6 Source Term and Dose Calculations The equation in &sect;5.1 was used to set up the ST for calculations of dose to workers and the public.
To be consistent with the WIPP-WAC methodology the Pu-239 plutonium equivalent Curies (PE-Ci) were calculated, (DOE/WIPP 2003). For a known radioactivity quantity and radionuclide distribution, the Pu-239 equivalent activity is determined using radionuclide specific weighting factors. The Pu-239 equivalent activity (AM) can be calculated by:
k Ai AM =
i =1 WFi Where k is the number of TRU radionuclides, Ai is the activity of radionuclide i and WFi is the PE-CI weighting factor for radionuclide i.
WFi is further defined as the ratio:
WFi = Eo/Ei where, Eo (rem/Ci) is the 50-year effective whole-body dose commitment due to the inhalation of Pu-239 particulates with a 1.0 m Activity Median Aerodynamic Diameter (AMAD) and a W pulmonary clearance class, and Ei (rem/Ci) is the 50-year effective whole-body dose commitment due to the inhalation of radionuclide particulates with a 1.0 m AMAD and the pulmonary clearance class resulting in the highest 50-year effective whole-body dose commitment. The values of Eo and Ei may be obtained from DOE/EH-1988.
The activity given in Table 2 for the radionuclides that contributed the most activity was divided by the WF for the nuclide, which was used to generate the PE-Ci, Page 34

Documented Safety Analysis for WCS TRU Waste Handling and Disposal Draft Final Table 7.Table 7 Page 35

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                    Draft Final Table 7, Plutonium Equivalent Activity, Curies Am-241 Pu-238        Pu-239 Pu-240 Pu-241          Pu-242 PE-Ci uCi/m2 Average       19.8     0.0066      7.21      1.96      4.19E-5 2.53E-3 28.9         92.1 Median        13.9     0.0023      6.92      1.77      3.58E-5 1.73E-4 22.6         72.0 Maximum         90.7      0.205     13.30      6.40      1.97E-4 1.20E-1 111         3,520 Minimum        0.89    5.87E-4      0.99      0.47      9.35E-6 2.54E-5 2.34         74.4 95 % tile      15.2     0.0588      194       17.0     8.08E-03   1.42      227      7230 99 % tile      21.8      0.597      211       20.1     1.25E-02   14.4      268      8520 The MAR for a particular scenario is expressed as a summation of the number of waste containers involved in the postulated event and the bounding activity associated with the waste containers.
Guidance from DOE-2007, Table 4.3.2.1 for fully characterized waste are reproduced below, Table 8. The radionuclide concentrations in Table 7 above have been used to fulfill the MAR for a single drum, two (2) drums, three (3) drums and the SWB containing four (4) drums.
Table 8, MAR Limits for TRU Waste Operations MAR description            Fully Characterized Waste          PE-Ci &#xb5;Ci/m2 Single Drum                One at Maximum activity              3.52E+03 One at Minimum activity                 74.4 One at Maximum activity 1.08E+04 One at 95th percentile Two Drums One at Minimum activity 7.31E+03 One at 95th percentile One at Maximum activity One at 95th percentile               1.17E+04 One at mean Three Drums One at Minimum activity One at 95th percentile               8.23E+03 One at mean One at Maximum activity, one at 95th percentile,              1.26E+04 two at mean Four Drums One at Minimum activity, one at 95th percentile,              9.13E+03 two at mean Page 36

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                       Draft Final The PE-Ci activity was used as the source term in the HotSpot computer code, version 3.1.2, HotSpot-2020. HotSpot is a Gaussian straight-line plume model used to calculate atmospheric dispersion and dose. The code was run using the average, median, maximum and minimum PE-Ci activities in grams or &#xb5;Ci/m2. HotSpot uses General programs address the release of any radionuclide or mixture in the HotSpot library (ICRP 30, ICRP60, and Acute). These models estimate the short-range less than 10 km, downwind radiological impact following the release of radioactive material resulting from a short-term release (less than a few hours), explosive release, fuel fire, or an area contamination event. The results of the Total Effective Dose (TED) are given in Table 9.
Table 9, HotSpot Results Multiple Drums Accident Scenarios, rem
                       #    Activity  Max TED      Distance     0.01       0.1        6 Model                                                                                         8 km drum    &#xb5;Ci/m2       rem          km         km        km        km General 1      3,520     4.6E-3                 1.0E-4    1.2E-3    1.7E-9    5.2E-10 Resuspension Max activity          2     1.08E+4    1.4E-2       0.38      3.1E-4    3.7E-3    5.1E-9     1.6E-9 3     1.17E+4    1.5E-2                 3.4E-4    4.0E-3    5.5E-9     1.7E-9 4     1.26E+4    1.6E-2                 3.6E-4    4.3E-3    6.0E-9     1.9E-9 General 1       74.4     1.3E-5                 3.9E-7    3.4E-6   4.7E-12    1.5E-12 Resuspension Min activity          2     7.31E+3    7.4E-3       0.38      1.6E-4    1.9E-3    1.5E-8    8.4E-10 3     8.23E+3    8.3E-3                 1.8E-4    2.2E-3    3.0E-9    9.4E-10 4     9.16E+3    9.2E-3                 2.0E-4    2.4E-3    3.4E-9     1.0E-9 In the General Resuspension, Plutonium Resuspension, General Fire, General Plume and Plutonium Fire models, the Resuspension Factor was chosen as 1.0E-06 /m as recommended in National Council on Radiation Protection and Measurements (NCRP-129), Report Number 129.
The dose conversion factors were taken from Federal Guidance Report number 13, EPA-1999.
The terrain was set at Standard/Rural with a sample time of 10 minutes. The release radius was set to 1 meter.
The following factors from DOE-2007 were used:
Deposition velocity 1 cm/s Surface roughness 3 cm Breathing rate 3.3E-04 m3/s Stability class was set to F Wind speed of 1 m/s, Wind input height 10 m Page 37

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                        Draft Final The models used were General Resuspension, Plutonium Resuspension, General Fire, General Plume and Plutonium Fire at minimum (Min), average (Avg), median (Med) and maximum (Max)
PE-Ci. The closest worker is given at 10 meters, other distances are the closest residence 6 km and Eunice, NM 8 km. The results are given in Table 10. The HotSpot Output files are given as Appendices: General Resuspension, Appendix 1, Plutonium Resuspension, Appendix 2 General Fire, Appendix 3, General Plume, Appendix 4, and Plutonium Fire. Appendix 5.
Table 10, HotSpot Results from Accident Scenarios Activity    Max TED       Distance     0.01      0.1         6 Model                                                                                          8 km
                          &#xb5;Ci/m2          rem          km         km       km         km Min       74.4       9.7E-5                  2.1E-6   2.5E-5    3.5E-11    1.1E-11 General           Avg       921        1.2E-4                  2.7E-6   3.1E-5    4.4E-11    1.4E-11 0.38 Resuspension      Med       720        9.4E-5                  2.1E-6   2.5E-5    3.4E-11    1.1E-11 Max      3,520       4.6E-3                  1.0E-4   1.2E-3     1.7E-9    5.2E-10 Min       74.4       1.3E-5                  3.9E-7   3.4E-6    4.7E-12    1.5E-12 Plutonium         Avg       921        1.3E-4                  2.8E-6   3.3E-5    4.6E-11    1.2E-11 0.38 Resuspension      Med       720        1.0E-4                  2.2E-6   2.6E-5    3.6E-11    1.1E-11 Max      3,520       4.9E-4                  1.1E-5   1.3E-4    1.8E-10    5.5E-11 Ci Min       2.34         0.76                   0.76    3.8E-5     4.7E-8     1.5E-8 Avg      28.95          9.4                    9.4    4.7E-4     5.8E-7     1.8E-7 General Fire                                         0.010 Med      22.63          7.3                    7.3    3.7E-4     4.6E-7     1.4E-7 Max      110.7          36                     36     1.8E-3     2.2E-6     6.9E-7 Min       2.34        0.014                 1.3E-17   1.6E-3    6.8E-14    6.3E-15 Avg      28.95        0.172        0.043    1.6E-16   2.0E-2    8.4E-13    7.7E-14 General Plume Med      22.63        0.135                 1.3E-16   1.5E-2    6.6E-13    6.1E-14 Max      110.7        0.659                 6.2E-16   7.6E-2    3.2E-12    3.0E-13 Grams Min        29           5.4                    5.4      0.23     3.3E-7     1.0E-7 Avg       357           13                     13       0.53     7.8E-7     2.4E-7 Pu Fire                                               0.01 Med       279           9.8                    9.8      0.42     6.1E-7     1.9E-7 Max      1,367          48                     48       2.0      3.0E-6     9.3E-7 5.2   Accident Stresses The main types of accidents of common concern in nonreactor nuclear facilities are:

====5.2.1 Spill====
Material experiences instability/shear stress at the surface of the mass resulting in sub-division of the overall mass. Airflow patterns around and through the material mass, including induced Page 38

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                               Draft Final turbulence, accelerate overall sub-division. Mass breakup is further enhanced by impact with ground surface. The material sub-division can generate particles sufficiently small that they remain airborne for a significant period of time.
5.2.2 Fire:
Generates heat and combustion gases that may destroy/stress the radioactive material and/or the substrate upon which radioactive materials may be deposited, compromise barriers, and/or pressurize containers/enclosure that may lead to the airborne release of contained radioactive materials. Mass flux of vapors from the reacting surfaces suspend material in air. This material is then entrained in general convective currents that provide transport for particulate materials.

====5.2.3 Explosion====
Generates shock and blast effects with potential for gas flow subsequent to the explosive event that may subdivide/deagglomerate and entrain material. Explosive reactions may result from chemical (e.g., oxidations involving branch-chain products, oxidations of gas-oxidant mixtures) or physical (over pressurization to failure of tanks or vessel, vapor explosions) reactions. Shock waves are supersonic pressure waves (pulses) that can transmit an impulse to materials and the surrounding structures resulting in shattering of solid items. Shock waves are a true wave phenomenon and involve little gross motion of propagating medium. The potential for damage from shock waves has been extensively characterized. Explosion stress is considered.
Blast effects are typically subsonic and involve material entrained in the gas flow. Blast effects are often more damaging. Blast effects are not subject to the same reflection/amplification phenomena as shock waves because they have significant momentum and inertia. The gas expanding from the explosion zone carries material from the explosion site. If the explosion is adjacent to the MARs, then blast effects can cause damage above and beyond the initial impulse loading. Some explosive reactions may be followed by chemical reactions, material vaporization, or fires that lead to substantial gas flows following the explosive event. These gas flows may also entrain material. Deflagrations do not involve shock but can simulate blast effects. Under proper conditions (e.g., confinement, structural features that enhance turbulence), deflagrations can transition to detonations and produce shock waves.
5.3     Gaseous Releases Vapors (materials in gaseous form due to local conditions) may result from two phenomena: chemical reaction and heating. Some vapors result from chemical reactions that generate a volatile compound (e.g., halogens in an oxidizing, acidic environment). Other vapors can be generated when the local temperature exceeds the boiling point of the element or compound (e.g., evaporation of water). Under most conditions, the ARF (the fraction of vapor formed initially airborne) assumed for vapors is 1.0.
If the local conditions are not adequate for quantitative vaporization of all the material (e.g., inadequate Page 39

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                            Draft Final chemical reactants, inadequate temperature), the ARF is the fraction of the material converted to vapor form.
Many chemically volatile compounds are reactive and can be lost in transit by reaction with materials encountered along their path to the facility/environment interface or adsorption on pre-existing airborne particles. Temperature sensitive materials can condense homogeneously (particles formed directly from the vapor have been observed to be in the sub-micron range) or on pre-existing particles.
Aerosols form rapidly since entrainment of cooler air invariably accompanies the formation process.
For temperature-sensitive vapors (e.g., metal vapors generated at high temperatures, tritiated water vapors), the amount of material volatilized can be estimated by the amount of heat energy present and/or generated by the event. Similarly, condensation may also be calculated by heat transfer at the surfaces or by homo- or heterogenous condensation in air. The mass flux of vapors to a cool surface (diffusion-phoresies) can be an effective mechanism to sweep small diameter (i.e., submicron) particles from the air.
For generation of vapors plus release from physical containment, the recommended ARF is 1.0. All materials in the gaseous state can be transported and inhaled; therefore, an RF of 1.0 is assumed for the purposes of these analyses.
5.4    Liquids For a liquid to be made airborne, in most realistic situations, the bulk liquid must be subdivided into particles/droplets small enough to be entrained in the local airflow. In some cases, it may be possible for the activity coefficient of the solute to be adequately reduced so that some material may be made airborne by vaporization.
There are two mechanisms by which liquids (aqueous solutions and organic, combustible solvents) become airborne; the descriptions are based on experiments. The mechanisms discussed for aqueous solutions include thermal stress, explosive release (i.e., shock, blast, and pressurized venting effects),
free-fall spills, and aerodynamic entrainment (resuspension). Organic liquids are specifically discussed in relation to thermal effects.
5.4.1 Explosive Stress Releases are discussed for detonation shock effects, detonation or deflagration blast effects, deflagration pressurized venting effects, and general pressurized venting of liquids. The effect most closely resembling stresses in a given explosive-type accident scenario is chosen. There is no need to assume cumulative releases for all effects cited.
5.4.2 Thermal Stress: Plutonium Page 40

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                             Draft Final Airborne release of particulates formed by room temperature oxidation (corrosion). Based upon the experimental measured values, the bounding ARFs and RFs for the four situations covered are:
                                                                       -6          2 Bounding (unalloyed Pu)                         ARF (dry air) 2 x 10 g Pu/cm -hr; RF 0.7
                                                                       -3          2 ARF (100% RH) 7 x 10 g Pu/cm -hr; RF 0.7 Use of the above values are generally intended for short timeframes (i.e., < 100 hours). They are not appropriate for long-term estimation (i.e., months to years) as rate is controlled by issues such as oxide coat coherence.
Airborne release of particulates formed by oxidation at elevated temperature, greater than room temperature but less than self-sustained oxidation (ignition). The bounding values apply to static oxidation at elevated temperatures less than ignition temperatures. The MAR is the amount of oxide present under specific conditions. If oxidation is not complete, experimental data cited can provide a basis for such estimations if desired.
Bounding                        ARF 3 x 10-5 / RF 0.04 Page 41

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                       Draft Final 6    IDENTIFICATION AND EVALUATION OF TRU WASTE EVENTS The following section represents the minimum set of accident events that must be addressed in the DSA hazard evaluation when the hazard identification indicates the presence of potential initiators that could lead to the accident event. The following consolidated list of general TRU waste activities has been developed to facilitate an understanding and characterization of TRU waste accident events:
* Characterization: Borescope and Headspace Gas Sampling (HGS).
* Container Handling: Lifting and moving TRU waste containers with forklifts, cranes, drum handlers, etc.; stacking; banding; loading and unloading from waste container arrays; overpacking; and loading on transport vehicle until ready for transport.
* Venting and/or Abating/Purging: Installing vents to release gases built up within the TRU waste container, allowing gases to passively vent, and purging the TRU waste container headspace. The purpose of these activities is to reduce the potential hydrogen concentration within the TRU waste container to a level at which the hydrogen no longer presents a deflagration hazard.
* Staging and Storage: Static conditions which may include staging (temporary storage),
storage, surveillance, and maintenance. Staging and storage may take place inside a facility with features such as fire suppression and ventilation. Inside temporary structures such as tents or contained structures that protect the waste container from the elements, or inside of any physical structure.
* Retrieval and Excavation: Excavation of buried waste and/or retrieval from original storage location.
The minimum set of accident events addresses those events with the potential for consequences that could be significant enough to warrant explicit technical safety requirements. A matrix of the minimum accident events versus typical TRU waste activities discussed above is provided in Table
: 11. Areas of the table marked by Xs indicate potential applicability.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                                                 Draft Final Table 11, Minimum TRU Waste Activity/Hazard Evaluation Event Matrix Headspace gas Staging FWF to BSA- Container                     sampling -
Hazard Evaluation Event                                                                                               and 1 movement Handling1                     borescope Storage inspection Fire Events Fuel Pool Fire (Event 1)                                                     X                                         X Small Fire (Event 2)                                        X                X                      X                  X Enclosure Fire (Event 3)                                    X                                       X Large Fire (Event 4)                                        X                X                      X                  X Explosion Events Ignition of Fumes Results in a Deflagration/Detonation (external to                                         X container) (Event 5)
Waste Container Deflagration (Event 6)                      X                X                      X                  X Multiple Waste Container Deflagration X                X                      X                  X (Event 7)
Enclosure Deflagration (Event 8)                            X                                       X Loss of Confinement/Containment Vehicle/Equipment Impacts Waste/
X                                         X Containers (Event 9)
Drop/Impact/Spill Due to Improperly X
Handled Container, etc. (Event 10)
Collapse of Stacked Containers X                      X                  X (Event 11)
Waste Container Over-Pressurization X                X                      X                  X (Event 12)
Direct Exposure to Radiation Events X                X                      X                  X (Event 13)
Criticality Events (Event 14)                               X                X                      X                  X Externally Initiated Events Aircraft Impact with Fire (Event 15)                        X                X                      X                  X External Vehicle Accident (Event 16)                        X                X                      X                  X External Vehicle Accident with Fire X                X                      X                  X (Combustible or Pool) (Event 17)
External Explosion (Event 18)                               X                X                      X                  X External Fire (Event 19)                                    X                X                      X                  X NPH Initiated Events Lightning (Event 20)                                        X                X                      X                  X High Wind (Event 21)                                        X                X                      X                  X Tornado (Event 22)                                          X                X                      X                  X Snow/Ice Build-up (Event 23)                                X                X                      X                  X Seismic Event (Impact Only) (Event 24)                      X                X                      X                  X Seismic Event with Fire (Event 25)                          X                X                      X                  X 1 Movement   of TRU waste containers is considered container handling, even when it is related to the completion of another type of TRU waste activity. When analyzing these events, one must consider the waste being handled as well as other stored/staged waste that may be impacted.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                        Draft Final 6.1    Fire Events 6.1.1 Fuel Pool Fires (Event 1)
The analysis of liquid fuel fires, separate from other fires, is important because liquid fuel fires have the potential to result in pool fires that have a substantially higher source term than combustible material fires when TRU waste containers are involved in the event. Pool fires can cause rapid heating of containers. Vehicles may release 30 gallons of fuel.
6.1.2 Small Fire (Event 2)
Small fires may affect either one container during a container fire or one to several containers through exposure or direct impingement, without any facility confinement enclosure (e.g.,
glovebox). This type of fire is limited in size and is contained within a fire zone. Additionally, the intensity of a small fire may be inadequate to result in automatic Fire Suppression System (FSS) activation. These fires, in general, will cause material in containers to burn as confined material.
6.1.3 Enclosure Fire (Event 3)
For facilities using enclosures such as such as temporary structures, this fire is addressed separate from other small fire events to ensure a complete hazard evaluation. This fire covers all internally initiated fires. The ignition source may be from pyrophoric or spontaneous combustion reaction, chemical reaction, or other source of internal heat generation.
6.1.4 Large Fire (Event 4)
This is a fire that propagates from any of the proposed smaller fire events. Propagated fires of different sizes may be proposed depending on the facility configuration (e.g., a large, multi-level facility may have a room fire, a level fire, and a full-facility fire).
6.2    Explosion Events 6.2.1 Ignition of Fumes Results in an Explosion (external to container) (Event 5)
This event is caused by hazards external to the waste matrix such as vehicle fuel/fumes, battery explosions, welding gases, or other explosive gases used in the facility. In addition to explosion overpressures, an explosion could produce missiles that could impact containers of waste. For waste in containers, the release mechanism would essentially be an impact.
6.2.2 Waste Container Deflagration (Event 6)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                         Draft Final This event is due to hydrogen or other flammable/explosive gases (e.g., off-gas from Volatile Organic Compounds [VOCs]) inside the container) in a suspect container. A suspect container is unvented (including those containers with inadequate vents, no vent, or plugged vents) and meets at least one of the following criteria:
: 1. Obvious indications of pressurization.
: 2. Waste stream characteristics indicate a potential for generating concentrations of hydrogen or other flammable gas mixtures greater than or equal to the Lower Flammability Limit (LFL).
: 3. Waste stream data is either inadequate or unavailable to rule out the potential for generating concentrations of hydrogen or other flammable gas mixtures greater than or equal to the LFL.
A container deflagration involving material inside a SWB is not a credible physical threat to a worker because of the containment characteristics of the SWB. The four vents of the SWB are HEPA filtered, the lid is heavy and has a gasket seal held down by 42 bolts. The temperature of the SWB will be assessed. Monitoring the headgas space for flammable gases is being done with strict radiological controls in place for sampling of the very low potential for radiological releases.
There is no ignition source in the drums or the SWB.
6.2.3 Multiple Waste Container Deflagration (Event 7)
This event is due to waste container deflagration propagating horizontally or vertically to initiate additional container deflagrations. This event requires two suspect containers to be stacked, or of poor container integrity to be stored or staged immediately adjacent to each other.
6.2.4 Enclosure Deflagration (Event 8)
This event is due to hydrogen or other flammable/explosive gases inside an enclosure or within a container that has been placed inside and opened within an enclosure. Ignition sources include sparks, heat, etc. that can ignite gases as well as potential ignition sources in the waste, such as metal objects, pyrophoric material, and heat-generating chemical reactions.
6.3     Loss of Confinement/Containment 6.3.1 Vehicle/Equipment Impacts Waste/Waste Containers (Event 9)
This event is due to operation of vehicles or equipment within the facility. These vehicles and equipment may or may not be used in close proximity to the TRU waste. The impact type will vary based on the impact source and may involve, for example, container puncture by forklift tines, or result in a stacked drum array falling.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                         Draft Final 6.3.2 Drop/Impact/Spill Due to Improperly Handled Container, etc. (Event 10)
This event is due to mishandling of containers or to drops/impacts caused by equipment failure. If TRU waste containers may be dropped from elevated surfaces (e.g., SWB falling during removal from MCC).
6.3.3 Collapse of Stacked Containers (Event 11)
This event is a collapse of a stacked array of containers. The collapse may be a failure of the containers, pallets, or other stacking media due to corrosion, defective construction, damage, or improper stacking (e.g., exceeding limits, unstable array).
6.3.4 Waste Container Over-Pressurization (Event 12)
This event is due to a buildup of pressure inside of a container. The pressure buildup may be due to radiolysis of water or other hydrogenous material, thermal expansion of material/gases inside the container, or chemical reactions inside the container.
6.3.5 Direct Exposure to Radiation Events (Event 13)
This event is caused by ionizing radiation from the waste. The exposure may be due to normal operational conditions (e.g., handling, cleaning up a spill) or due to an accident that causes the loss of shielding inherent to the container/activity. If the facility processes both CH and RH TRU waste, separate events for these waste types must be included for complete hazard evaluation.
6.3.6 Criticality Events (Event 14)
Criticality events are considered beyond highly unlikely.
6.4    Externally Initiated Events 6.4.1 Aircraft Impact with Fire (Event 15)
This event occurs when a large commercial aircraft, small general aviation aircraft, or helicopter crashes into the facility and a fire ensues. Site over-flights and nearby airports are contributors to this event.
6.4.2    External Vehicle Accident (Event 16)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                         Draft Final This event is due to a vehicle, not associated with facility activities, impacting the facility/waste containers. Traffic on nearby roads contributes to this event.
6.4.3 External Vehicle Accident with Fire (Combustible or Pool) (Event 17)
This is a potential follow-on event for the external vehicle accident. After the vehicle accident, spilled combustible waste, and/or fuel from the vehicle ignite and burn.
6.4.4 External Explosion (Event 18)
This event is similar to the explosion due to mechanical failure with missiles occurring within the facility that was discussed earlier. The hazard is primarily from vehicles/roadways near the facility or storage location, or from nearby locations with large quantities of explosive gas (e.g., nearby gas pipeline, propane tanks, pressurized gas used for characterization or welding, etc.).
6.4.5 External Fire (Event 19)
This is a fire that begins outside of the facility and propagates to the facility. The external fire could be from wildland fires, other facilities, or another fire source. If TRU waste may be within and/or outside of a building, separate external fires must be addressed.
6.5    Natural Phenomenon Hazard (NPH) Initiated Events 6.5.1 Lightning (Event 20)
For facilities with electrical systems, a lightning strike may cause fires in the electrical system (e.g., ignition of wire insulation) that could ignite nearby material. Lightning strikes that cause fires outside of the facility are addressed as external fires. Additionally, lightning may strike a container or near stored/staged containers.
6.5.2 High Wind (Event 21)
This event is due to high winds causing impacts to both the facility and the containers via falling objects. The falling objects may be nearby trees, pole, cranes, or parts of the facility structure.
6.5.3 Tornado (Event 22)
This event is due to a direct effect of a tornado, falling objects, or tornado-produced missiles causing impacts to both the facility and the containers. Missiles may be produced from various Page 47

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                          Draft Final pieces of equipment or material (e.g., pallets). The falling objects may be nearby trees, poles, cranes, or parts of the facility structure.
6.5.4 Snow/Ice/Volcanic Ash Build-up (Event 23)
Accumulation of snow or ice may cause the roof of a facility or structure to collapse, or may cause nearby objects, such as trees, to fall and impact the waste containers. Volcanic ash is considered highly improbable.
6.5.5 Seismic Event (Impact Only) (Event 24)
The seismic event can cause failure of the facility structure (partial or catastrophic, depending on the facility construction), failure of equipment inside the facility, or other structure failure, which impacts the waste. Additionally, the event can cause containers to fall and spill their contents.
6.5.6 Seismic Event with Fire (Event 25)
The seismic event can cause failure of the facility, failure of equipment inside the facility, or failure of other structures, which impact the waste. Additionally, the event can cause containers to fall and spill their contents. The structural failure could involve damage to electrical systems that are not seismically qualified or involve other potential ignition sources (e.g., flammable materials or gas lines where present) that can ignite spilled combustible waste or other combustibles in the facility.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                       Draft Final 7    HAZARD ANALYSIS As described in Table 11, a total of 85 hazard events are available for unmitigated hazard evaluation from all the major types of accidents, NPH, and external events. Of these, 47 events were identified as having unmitigated Risk Class I or II to one or more of the receptors, requiring further mitigated hazard evaluation or accident analysis. The events carried forward indicate that the principal hazards during waste movement, handling, inspection, and temporary storage, involve fires or mechanical insults capable of breaching the primary packaging and providing the energy required to disperse the contents.
Other events/event types like direct exposure to radiation events, criticality events, tornado/high winds, aircraft impact, and chemical exposure did not carry forward into the DSA for control selection were screened out because they were:
* Risk Class III/IV
* Low consequence to all receptors
* Not plausible per DOE-STD-3009-2014 (not physically possible)
* External event frequency of occurrence less than 1E-6/yr Further evaluation and control selection is not required for hazard events that are screened out.
Their screening may be based on credited Initial Conditions (ICs), design specific assumptions, calculations, and/or physical characteristics of the WCS site. These events are detailed in Table 12.
Page 49

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                  Draft Final Table 12, Screened Out Events Event ID       Location           Event description         Justification for Not Screening Forward
* No fuel storage or flammable material areas in FWF or near pathway to BSA-1.
Fuel pool fire in the FWF, on
* Fuel leaks quickly disperse and isolated.
FWF to Event 1                    ramp out or during transit to
* No consequence to all receptors.
BSA-1 BSA-1.
* The MCC protects the TRU waste containers from any exposure to flames and explosion event.
* Reduces consequences to Low and Risk class III.
* Beyond Extremely unlikely (not physically possible)
* A fire originating outside the BSA-1 would not impact the TRU Event 1        BSA-1       Large fire outside BSA-1            material in the BSA-1.
* Minimal amount of flammable material on hand.
* Reduces consequences to Low and Risk class III.
* No explosive material storage areas in ECS or the BSA-1 (IC).
* No consequence to all receptors.
* The SWB protects the TRU waste from any exposure to flames Event 5     ECS, BSA-1     Ignition and explosion event.
* Explosions outside the BSA-1 would not impact waste.
* Reduces consequences to Low and Risk class III.
* Beyond Extremely unlikely (not physically possible).
* No hydrogen buildup along path, in the BSA-1 or storage FWF to and     Ignition of hydrogen or             location. SWBs are vented.
Event 8 in BSA-1      flammable gas
* Lack of evident ignition source for any flammable material.
* Storage areas in the open.
* Reduces consequences to Low and Risk class III.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                 Draft Final Event ID       Location           Event description       Justification for Not Screening Forward
* Beyond extremely unlikely based on historical activities.
* Thousands of MCCs handled this way without incident.
FWF to Event 9                    Vehicle impact into MCC
* No vehicle traffic allowed along the route.
BSA-1
* Waste inside MCC.
* Reduces consequences to Low and Risk class III.
ECS
* No vehicle traffic allowed in inspection area (IC).
Event 9      Inspection    Vehicle impact into waste
* Waste inside SWB.
area
* Reduces consequences to Low and Risk class III.
Drop /impact/spill due to
* Beyond extremely unlikely based on historical activities.
FWF to Event 10                    improperly handled waste
* Waste is in MCCs.
BSA-1 container
* Reduces consequences to Low and Risk class III.
* Beyond extremely unlikely based on historical activities (IC).
FWF to      Collapse of stacked Event 11
* Waste is in MCCs.
BSA-1       containers.
* Reduces consequences to Low and Risk class III External event that is less than 1E-6 per year based on the Aircraft impacting waste      methodology outlined in DOE-STD-3014-96, Accident Analysis for Event 15        BSA-1 containers in BSA-1.          Aircraft Crash into Hazardous Facilities. Frequency of occurrence less than 1E-6/yr.
External offsite vehicles     Not plausible due to the distance of public access roads from the Event 16 and   Controlled colliding with Waste          BSA-1 or FWF and the fenced WCS Property Protection Area.
17            area Containers within the BSA-1 Extremely unlikely with no release. Large distances separating the Gas pipeline explosion Event 18        Offsite                                   BSA-1 and FWF from the hazard. Frequency of occurrence less than impacting waste.
1E-6/yr.
Beyond extremely unlikely due to the potential initiators not having External fire, wildland fire, Event 19        Offsite                                   impact to loaded waste container. Large open graveled areas URENCO fire between initiating event and BSA-1 or FWF.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal              Draft Final Event ID      Location           Event description     Justification for Not Screening Forward Lightning striking waste or Highly unlikely during transfer from FWF to BSA-1 waste in MCC Event 20 BSA-1       building initiating fire or and administrative controls restrict work under lightning conditions.
NPH directly hitting waste      Waste containers are inside a building.
Tornado or high wind generated missiles impacting waste were Event 21 and                 High wind or tornado impact BSA-1                                   evaluated to be very low consequences which did not warrant further 22 NPH                    BSA-1 evaluation.
Event 23                   High snow load caused BSA- The roof loading design and construction of the BSA-1 is adequate BSA-1 NPH                     1 roof to collapse          to protect the TRU waste from damage.
Seismic events beyond very unlikely in the area. Waste remains in Event 24 and                 Seismic events, failure of BSA-1                                   SWB and sealed drums. Low consequence to any receptors.
25 NPH                    structure, potential fire Frequency of occurrence less than 1E-6/yr.
Berms around building and waste. Sitewide extensive water NPH         WCS         Flooding management practices.
* Low consequences to all receptors, Direct         BSA-1 and Direct radiation exposure
* Drums inside SWBs exposure to    Inspection radiation                    from waste in areas.
* The WCS Radiation Protection Program controls external and area internal exposures with administrative controls.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                       Draft Final 7.1   TRU Waste Handling Steps Events that were carried forward are associated with the sequence of events moving and handling the TRU waste. Activities performed will be covered by WCS applicable Health and Safety, Operations, Radiation Safety, Maintenance, Quality Assurance, Waste Acceptance or any other procedures deemed applicable. Procedure WI-OP-104.0, Retrieval and Preparation of LANL TRU Waste will apply.
A systematic approach to the removal of the cover material will begin.
: 1. The Operations Supervisor (OS) shall verify all required lift vehicles and equipment are properly inspected prior to initiating waste handling activities in accordance with MA1.1.1, Maintenance of Equipment, Mechanical, and Electrical Systems.
: 2. Activities in the FWF.
: 3. Starting from the north face of the array and working south the MCCs will be uncovered.
: 4. Heavy industrial equipment, such as a back-hoe and dump truck will be used to remove the bulk of the material. Manual means may also be required on the lid of the MCC.
: 5. As the MCCs are uncovered radiological surveys (RSs) of the exterior surfaces will continuously be performed. This will include surface exposure rates and contamination surveys.
: 6. The MCC lid will be removed and placed safely aside out of the immediate work area exposing the pea gravel void fill.
Note: If any water is visible above the pea gravel level inside the MCC, it will be collected in a tote and taken to the TSDF for sampling, treatment, and disposal as appropriate.
: 7. Radiological surveys and temperature readings will be performed of all the newly exposed surfaces.
: 8. The Competent Person shall visually examine the lifting and rigging equipment. If there is any question about the integrity of these items, the Operations Personnel shall notify the OS, and work shall stop until the OS or designee examines the equipment and approves their use. If lifting and rigging equipment is determined to be unacceptable for use, the FWF activities and conditions will be evaluated and a lift plan will be developed for lifting and securement of the affected MCCs on the Goldhoffer within the cell. The Goldhoffer Page 53

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                     Draft Final transfer procedure will be modified for removal of the MCC from the FWF on the Goldhoffer.
Movement of the MCC from the FWF to BSA-1
: 9. The Kalmar will be used to remove the MCC from the storage location in the FWF and transport it to the top of the hill of the FWF to a flat surface.
: 10. The MCC will be loaded onto the Goldhoffer and restrained, RSs.
: 11. If the lifting points on the MCC are determined to be inadequate, a 120-ton crane will be used to load the MCC on the Goldhoffer and the Goldhoffer will be used to transfer the MCC to the BSA-1
: 12. The Goldhoffer with the MCC will be transported into the BSA-1 and into the ECS, RS performed.
Getting access to the SWB, moving the SWB from the MCC into the work area.
: 13. A vacuum system will be utilized for the removal of the pea gravel that covers the standard waste box (SWB).
: 14. Radiological surveys of all the newly exposed surfaces (including the pea gravel) will continue throughout the pea gravel extraction.
: 15. As each SWB is exposed they will be visually inspected for any damage or defects and temperature readings will be collected.
: 16. Once the pea gravel has been removed to the extent practicable around the top tier of SWBs the original rigging that was used to place the SWBs will be replaced with new rigging.
: 17. In the event that an undesirable situation is discovered during the inspection of the SWB or it is determined for any reason that the SWB cannot safely be withdrawn from the MCC, the lid may be placed back on the MCC until a path forward is determined. WCS in consultation with DOE shall evaluate options for removal and handling of the segregated MCC/SWBs.
: 18. Any damaged waste container shall immediately be brought to the attention of the radiation safety technician (RST), the radiation safety supervisor (RSS), the operations supervisor (OS) AND the operations manager (OM).
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                        Draft Final
: 19. A different lifting device may be used after approval of the Project Manager and QA.
: 20. The SWB will then be withdrawn from the MCC with the use of a hoist on the gantry lifting system and placed into a laydown area where it can be fully inspected and surveyed.
: 21. A temperature device will be used to test the temperature on the exterior of the SWB at multiple locations. A temperature between ambient air temperature and 100o F is considered stable (SRNL, 2018). Temperatures between 100o F and 135o F is considered average, and should be considered for additional monitoring. Above this temperature a more energetic reaction may be possible.
: 22. DOE may perform their inspection, headspace gas sampling, filter replacement, and bore-scope needed on the SWB at this time or the SWB may be staged in a roped off area for later work, RS.
: 23. Repeat the steps until all SWBs have been removed from their MCC.
: 24. Move the SWB to a staging area for potential shipment to WIPP.
: 25. Remove any remaining pea gravel from the MCC to the extent practical, RS.
: 26. Remove the empty, non-radiologically contaminated MCC from the ECS and BSA-1.
: 27. Place the SWB into a temperature-controlled storage area until approved by DOE for transport.
7.2    Hazard Description The hazard description continues by breaking all steps down into hypothetical problems with solutions and discussion. DSAs are not intended to analyze and provide controls for standard industrial hazards such as burns from hot surfaces, electrocution, and falling objects. These hazards are adequately analyzed and controlled in accordance with 10 C.F.R. Part 851, Worker Safety and Health Program, and are analyzed in a DSA only if they can be an accident initiator, a contributor to a significant uncontrolled release of radioactive or other hazardous material (for example, 120-volt wiring as initiator of a fire) or considered a unique worker hazard such as explosive energy.
Therefore, the WCS Safety Program will have significant input in those areas.
In addition, the WCS Environmental Safety, Health and Quality Assurance Program in coordination with the established Radiation Safety Program will be implemented in accordance Page 55

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                        Draft Final with the applicable regulations and Radioactive Materials Licenses. Engineering , safety and radiation safety controls procedures will be incorporated into the necessary plans, work instructions, quality requirements or guidance documents to provide the backbone of the fundamental safe work culture that WCS requires. In that capacity every worker has the right to stop work for what they perceive is an unsafe or off normal activity.
This document needs to provide a systematic evaluation of hazards and an appropriate set of controls commensurate with the results of the hazard evaluation. It has three elementshazard analysis, accident analysis, and hazard control selection, which are fundamental, because they determine the hazard controls needed to provide protection for workers, the public, and the environment.
Table 13 lists where the hazard is considered to occur. It is divided into the FWF and transportation to the BSA-1 and within the BSA-1. The likelihood of the event occurring will be considered as:
Anticipated (A),
Unlikely (U),
Extremely unlikely (EU) or Beyond extremely unlikely (BEU).
The consequences to the closest worker will be labeled high (H), moderate (M) or low (L).
A risk class (RC) will be assigned:
Risk Class:
I=      Combination of conclusions from risk analysis that identify situations of major concern II =    Combination of conclusions from risk analysis that identify situations of concern III = Combination of conclusions from risk analysis that identify situations of minor concern IV = Combination of conclusions from risk analysis that identify situations of minimal concern The type of control in the unmitigated analysis will be addressed as the initial condition credited (IC), preventative (P) and mitigation (M).
Page 56

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                 Draft Final Table 13, Hazard Evaluation Events Requiring Safety Controls Safety Significant Likelihood Structures, Systems and      Specific Administrative         Controls Number            Description         Consequences Components            (SAC) (type of control)
Risk Class (SSCs) (type of control)
Fire Events In FWF and movement up to top of ramp and into the BSA-1 Waste still in MCC throughout      Vehicle pre-op checklist (P)
U Vehicle fuel/hydraulic                     movement (IC)                      Other workers - spotter (P)
FWF 1                                       L leak with pool fire.                                                          Notify others (M)
III Fire extinguishers available (M)
Waste still in MCC throughout      Limit vehicle location and speeds (P)
EU Vehicle collision and                      movement (IC)                      Other workers - spotter (P)
FWF 2                                       L pool fire with Kalmar.                                                        Fire extinguishers available (M)
IV Notify others (M)
Waste still in MCC throughout      Limit vehicle location and speeds (P)
Vehicle collision and            EU movement (IC)                      Other workers - spotter (P)
FWF 3     pool fire with                    L Fire extinguishers available (M)
Goldhoffer.                      IV Notify others (M)
Waste still in MCC throughout      Limit combustibles in the area (P)
Ordinary combustible              U movement (IC)                      Other workers - spotter (P)
FWF 4     fire adjacent to MCC              L Fire extinguishers available (M) and/or vehicle.                  III Notify others (M)
Waste still in MCC throughout      Drivers in communication (P)
Vehicle collision                EU movement (IC)                      Other workers - spotter (P)
FWF 5     between Kalmar and                L Fire extinguisher available (M)
Goldhoffer pool fire.            III Notify others (M)
Kalmar drops MCC                           Waste still in MCC throughout      Drivers in communication (P) Workers EU onto Goldhoffer                            movement (IC)                      in communication (P)
FWF 6                                       L breaking fuel/hydraulic                                                       Fire extinguishers available (M)
III line with pool fire.                                                          Notify others (M)
Page 57

Documented Safety Analysis for WCS TRU Waste Handling and Disposal            Draft Final Safety Significant Likelihood Structures, Systems and       Specific Administrative         Controls Number            Description      Consequences Components            (SAC) (type of control)
Risk Class (SSCs) (type of control)
Waste still in MCC throughout      Drivers in communication with workers Goldhoffer breaks -         EU movement (IC)                      (P)
FWF 7     breaking fuel/hydraulic       L Fire extinguishers available (M) line with pool fire.         III Notify others (M)
In the BSA-1 Waste still in MCC (IC)            Vehicle pre-op checklist (P)
U Vehicle fuel/hydraulic                                                   Other workers - spotter (P)
BSA-1 1                                  L leak with pool fire.                                                     Notify others (M)
III Fire extinguishers available (M)
Waste inside the ECS. (IC)         Limit combustibles in the area (P)
Ordinary combustible         U Waste still in MCC (IC)            Other workers - spotter (P)
BSA-1 2    fire adjacent to MCC          L Fire extinguishers available (M) and/or vehicle.              III Notify others (M)
Waste inside the ECS. (IC)         Limit combustibles in the area (P)
U Ordinary combustible                  Waste inside SWB (IC)              Other workers - spotter (P)
BSA-1 3                                  L fire adjacent to SWB.                                                    Fire extinguishers available (M)
III Notify others (M)
Waste inside the ECS. (IC)         Limit combustibles in the area (P)
U Vehicle fuel/hydraulic                Waste inside SWB (IC)              Other workers - spotter (P)
BSA-1 4                                  L leak with pool fire.                                                     Fire extinguishers available (M)
III Notify others (M) 2 vehicles crash            U        Waste inside BSA-1 in SWB (IC)     Site Fire team responds (M)
BSA-1 5    outside, next to BSA-1        L                                          Fire extinguishers available (M) pool fire.                   III                                         Notify others (M)
Waste inside the ECS. (IC)         ECS ventilation system (M)
Non-compliant waste          A Waste inside SWB (IC)              Fire extinguishers available (M)
BSA-1 6    combustible fire in          M Temperature monitoring of SWBs (P)
TRU drum(s).                 III Notify others (M)
Page 58

Documented Safety Analysis for WCS TRU Waste Handling and Disposal               Draft Final Safety Significant Likelihood Structures, Systems and       Specific Administrative        Controls Number            Description        Consequences Components              (SAC) (type of control)
Risk Class (SSCs) (type of control)
Loss of Confinement Events In FWF and movement up to top of ramp and into the BSA-1 EU       Waste inside MCC (IC)                WCS proper handling and inspection MCC is dropped and FWF 8                                     L      SWB not breached (IC)                procedures (P) turns on its side.
III MCC is dropped and            EU       Waste inside MCC (IC)                WCS proper handling and inspection FWF 9     turns on its side. SWB          L      Drums intact. (IC)                   procedures (P) breached.                      III                                          Proper Radiological controls in place (P)
MCC is dropped and            EU       Waste inside MCC (IC)                WCS proper handling and inspection FWF 10     turns on its side. SWB         M                                            procedures (P) and drums breached.            II                                           Proper Radiological controls in place (P)
Tires on Kalmar or            EU       Waste in MCC (IC)                    WCS proper handling and inspection FWF 11     Goldhoffer go flat in           L                                           procedures (P) transit.                       III                                          Slow movement throughout (P)
In BSA-1 ECS ventilation system (P)           WCS proper handling and inspection When removing pea              U PPE being used (IC)                  procedures (P)
BSA-1 7    gravel, it is found to be       L HEPA system ECS ventilation          Proper Radiological controls in place (P) contaminated.                  II system (P)
Vacuum truck sealed and has a        WCS proper handling and inspection Contaminated pea U       HEPA filter                          procedures (P) gravel removed from BSA-1 8                                    L      PPE being used (IC)                  Proper Radiological controls in place (P)
ECS into BSA general II      Truck considered a radioactive area.
materials area (IC)
U       ECS ventilation system HEPA          WCS proper handling and inspection When SWB is exposed BSA-1 9                                    L      filtered (P)                         procedures (P) it is contaminated.
II      PPE being used (IC)                  Proper Radiological controls in place (P)
Page 59

Documented Safety Analysis for WCS TRU Waste Handling and Disposal              Draft Final Safety Significant Likelihood Structures, Systems and       Specific Administrative        Controls Number           Description       Consequences Components              (SAC) (type of control)
Risk Class (SSCs) (type of control)
U        ECS ventilation system HEPA          WCS proper handling and inspection When SWB is exposed BSA-1 10                                  L       filtered (P)                         procedures (P) it is damaged.
II       PPE being used (IC)                  Proper Radiological controls in place (P)
When lifting the SWB          U        ECS ventilation system HEPA          WCS proper handling and inspection BSA-1 11   it is dropped in the           L       filtered (P)                         procedures (P)
MCC.                          II       PPE being used (IC)                  Proper Radiological controls in place (P)
When lifting the SWB          U        ECS ventilation system HEPA          WCS proper handling and inspection BSA-1 12   it becomes wedged in           L       filtered (P)                         procedures (P) the MCC.                      II       PPE being used (IC)                  Proper Radiological controls in place (P)
Upon removal from the         U        ECS ventilation system HEPA          WCS proper handling and inspection BSA-1 13   MCC the SWB is                 L       filtered (P)                         procedures (P) dropped, no breach.           II       PPE being used (IC)                  Proper Radiological controls in place (P)
Upon removal from the         U        ECS ventilation system HEPA          WCS proper handling and inspection BSA-1 14   MCC the SWB is                 L       filtered (P)                         procedures (P) dropped and breached.         II       PPE being used (IC)                  Proper Radiological controls in place (P)
SWB is run into by a          U        ECS ventilation system HEPA          WCS proper handling and inspection BSA-1 15   fork-lift tine, drum           L       filtered (P)                         procedures (P) inside breached.              II       PPE being used (IC)                  Proper Radiological controls in place (P)
While awaiting                         Ground Fault Circuit Interrupters    WCS proper handling and inspection EU inspection an energized                (GFCI) are in place (P)              procedures (P)
BSA-1 16                                  L electrical line falls on                                                    Proper Radiological controls in place (P)
III the SWB.
Deflagration/Over-                     Waste inside SWB (IC)                Fire extinguishers available (M)
A pressurization                         ECS ventilation system HEPA          Proper Radiological controls in place (P)
BSA-1 17                                  L of noncompliant drum                   filtered (M)
III in SWB.
Page 60

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                Draft Final Safety Significant Likelihood Structures, Systems and        Specific Administrative        Controls Number             Description      Consequences Components               (SAC) (type of control)
Risk Class (SSCs) (type of control)
While moving SWB to            A        SWB is a Type A container (IC)        Load carried low decreasing impact (P)
BSA-1 18    the staging area it is          L dropped.                       III While stacking 2 high          A        SWB is a Type A container (IC)        WCS proper handling and inspection BSA-1 19    the top SWB is                  L                                             procedures (P) dropped.                       III                                            Proper Radiological controls in place (P)
While inspecting the                    ECS ventilation system HEPA           WCS proper handling and inspection drums a drum leaks by          A        filtered (M)                          procedures (P)
BSA-1 20    over pressurizing and          M                                              Proper Radiological controls in place (P) blows out the SWB              II HEPA filter.
7.3  Security WCS will secure the waste once removed from the FWF as agreed to under the confidential security agreement between WCS and DOE.
Page 61

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                       Draft Final 8    ALTERNATE SCENARIO ANALYSIS Consideration should be given to the continuing passage of time for the TRU waste without a temperature runaway incident. Using the data from SRNL 2018 and SRNL 2020, which provided an independent assessment and develops technical information to build data and behavior models of the waste. The understanding of the kinetics, chemical reactivity, behavior of the SWBs in the MCCs at WCS, along with the models that were developed consistently support the probability of a rapid reaction being very low. A first order kinetic model with activation energies from simulant and drum testing led to recommendations which would facilitate safe shipment of the waste from WCS to a nearby DOE facility. Based on these conclusions the minimum recommendations are:
: 1. Ensure existing vents on the TRU drums are functional or replaced.
: 2. Ensure all four SWB vent plugs are removed, and new vents are installed.
: 3. Provide headspace gas data indicating a low probability of a runaway reaction.
: 4. Ensure precautions are utilized for the actual transit that would avoid complications including experiencing high daily temperatures, inclement weather and unusual traffic patterns.
: 5. Develop and implement a methodology for determining when and for how long a shipment can occur.
Continued collaboration with EM-LA, the technical review team and site contractors has initiated additional testing of a more representative oxidizer and absorbent material blend to confirm the safety of the affected waste matrix within the majority of the remaining 74 SWBs at WCS. As a result, WCS evaluated the following options for retrieval of the SWBs.
Option 1:
Removal of the waste from the FWF into BSA-1, retrieval of the SWBs from the MCC within BSA-1 and inside an ECS equipped with HEPA ventilation and temperature controls, and SWB staging within the temperature controlled ECS. Performance of this option employs the DSA engineered safety controls for container handling and does not require the removal of the RCRA codes and the safety and liability assurance from DOE. Note: Hazard events that require safety controls in the BSA-1 are detailed in Table 14 and Safety Significant Controls detailing the safety function, performance criteria and system evaluation for these are given for the BSA-1 in Table 15.
Option 1 employs the DSA ECS design feature which requires the structure to be the primary control measure and barrier in the event of an unlikely release of radioactive material and must be equipped with a HEPA ventilation system to maintain the structure at a negative pressure and must be temperature controlled during movement, inspection, and handling of the SWBs. WCS Page 62

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                          Draft Final performed a decision analysis to achieve the optimal technical approach, which factored in DSA requirements, worker safety of the collocated ongoing WCS operations, safe handling of the MCCs and SWBs, facility modifications, risks, costs and schedule to complete the modifications, permitting, licensing, and execution of the work. The decision analysis resulted in the selection of two structure types for Option 1 that will achieve all the requirements, the Stainless Steel Perma-Con or PVC Architectural Membrane Tent. Both the Perma-Con and the PVC Architectural Membrane Tent meet the DSA design feature requirements and are acceptable for use; however, in comparison, the Perma-Con, used for DOE TRU waste processing across the complex, is the safest due to the stainless-steel structure, especially considering a fire and/or deflagration accident scenario. The Perma-Con is also much easier to decontaminate in the case of a contamination event.
The Perma-Con would be the safest and the preferred design approach; however, WCS recognizes the fact that the SWB retrieval operation will be limited to handling closed waste containers, and considering all factors, including the reduced cost and schedule for procurement and installation, the PVC Architectural Membrane Tent within BSA-1 is the most practical design approach for the SWB retrieval.
Option 2:
Removal of the waste from the FWF to BSA-1, retrieval of the SWBs from the MCCs in the open air outside BSA-1, SWB staging within BSA-1 until DOE completes final testing, evaluations, and WIPP approval for shipment and disposal. Performance of this option requires the removal of the RCRA codes and further evaluation of the current analysis DOE is still performing and assurances from DOE that this demonstrates this waste will not react and is compliant for shipment and burial at WIPP, resulting in removal of the need for the DSA engineered safety controls for container handling at WCS.
To achieve either of these options in a safe manner the events and safety activities associated with the presented scenario can be used to developed safety characteristics for this scenario. The steps used in &sect;7.1 show the events used in the handling of the MCC during removal from the FWF and transfer into an ECS (Perma-Con or the PVC Architectural Membrane Tent structure) within BSA-1, accessing and removing the SWBs, inspection of the SWBs, staging and preparation of the SWBs for transport. Activities associated with moving the MCC from the FWF to BSA-1 are not part of this alternative scenario. Packaging and shipping the SWBs will only occur once the SWBs are approved for transport in compliance with the DOT regulations. These operations are covered with WCS existing procedures and the WCS Safety Program will control worker health and safety for industrial operations.
Page 63

Documented Safety Analysis for WCS TRU Waste Handling and Disposal               Draft Final Table 14, BSA-1 Hazard Evaluation Events Requiring Safety Controls Likelihood       Safety Significant Structures, Specific Administrative Controls Number           Description        Consequences        Systems and Components (SAC) (type of control)
Risk Class         (SSCs) (type of control)
Fire Events In the BSA-1 Waste still in MCC (IC)             Vehicle pre-op checklist (P)
Vehicle                        U Other workers - spotter (P)
BSA-1 1    fuel/hydraulic leak             L Notify others (M) with pool fire.                III Fire extinguishers available (M)
Waste inside the ECS. (IC)          Limit combustibles in the area (P)
Ordinary combustible           U Waste still in MCC (IC)             Other workers - spotter (P)
BSA-1 2    fire adjacent to MCC            L Fire extinguishers available (M) and/or vehicle.                III Notify others (M)
Waste inside the ECS. (IC)          Limit combustibles in the area (P)
U Ordinary combustible                    Waste inside SWB (IC)               Other workers - spotter (P)
BSA-1 3                                    L fire adjacent to SWB.                                                       Fire extinguishers available (M)
III Notify others (M)
Waste inside the ECS. (IC)          Limit combustibles in the area (P)
Vehicle                        U Waste inside SWB (IC)               Other workers - spotter (P)
BSA-1 4    fuel/hydraulic leak             L Fire extinguishers available (M) with pool fire.                III Notify others (M) 2 vehicles crash              U        Waste inside BSA-1 in SWB (IC)      Site Fire team responds (M)
BSA-1 5    outside, next to BSA-           L                                           Fire extinguishers available (M) 1 pool fire.                   III                                          Notify others (M)
Waste inside the ECS. (IC)          ECS ventilation system (M)
Non-compliant waste            A Waste inside SWB (IC)               Fire extinguishers available (M)
BSA-1 6    combustible fire in            M Temperature monitoring of SWBs (P)
TRU drum(s).                   III Notify others (M)
Loss of Confinement Events Page 64

Documented Safety Analysis for WCS TRU Waste Handling and Disposal            Draft Final Likelihood        Safety Significant Structures, Specific Administrative Controls Number          Description      Consequences         Systems and Components (SAC) (type of control)
Risk Class           (SSCs) (type of control)
In BSA-1 When removing pea           U         ECS ventilation system (P)          WCS proper handling and inspection BSA-1 7   gravel, it is found to      L        PPE being used (IC)                  procedures (P) be contaminated.            II       HEPA system on ECS (P)               Proper Radiological controls in place (P)
Vacuum truck sealed and has a        WCS proper handling and inspection Contaminated pea U        HEPA filter                          procedures (P) gravel removed from BSA-1 8                               L        PPE being used (IC)                  Proper Radiological controls in place (P)
ECS into BSA general II       Truck considered a radioactive area.
materials area (IC)
When SWB is                 U        ECS ventilation system HEPA          WCS proper handling and inspection BSA-1 9   exposed it is               L        filtered (P)                         procedures (P) contaminated.               II       PPE being used (IC)                  Proper Radiological controls in place (P)
When SWB is                 U        ECS ventilation system HEPA          WCS proper handling and inspection BSA-1 10  exposed it is               L        filtered (P)                         procedures (P) damaged.                    II       PPE being used (IC)                  Proper Radiological controls in place (P)
When lifting the            U        ECS ventilation system HEPA          WCS proper handling and inspection BSA-1 11  SWB it is dropped in        L        filtered (P)                         procedures (P) the MCC.                    II       PPE being used (IC)                  Proper Radiological controls in place (P)
When lifting the            U        ECS ventilation system HEPA          WCS proper handling and inspection BSA-1 12  SWB it becomes              L        filtered (P)                         procedures (P) wedged in the MCC.          II       PPE being used (IC)                  Proper Radiological controls in place (P)
Upon removal from           U        ECS ventilation system HEPA          WCS proper handling and inspection BSA-1 13  the MCC the SWB is          L        filtered (P)                         procedures (P) dropped, no breach.         II       PPE being used (IC)                  Proper Radiological controls in place (P)
Upon removal from                    ECS ventilation system HEPA          WCS proper handling and inspection U
the MCC the SWB is                   filtered (P)                         procedures (P)
BSA-1 14                              L dropped and                          PPE being used (IC)                  Proper Radiological controls in place (P)
II breached.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal            Draft Final Likelihood        Safety Significant Structures, Specific Administrative Controls Number          Description      Consequences         Systems and Components (SAC) (type of control)
Risk Class           (SSCs) (type of control)
SWB is run into by a        U        ECS ventilation system HEPA           WCS proper handling and inspection BSA-1 15   fork-lift tine, drum         L       filtered (P)                          procedures (P) inside breached.            II       PPE being used (IC)                   Proper Radiological controls in place (P)
While awaiting                       Ground Fault Circuit Interrupters     WCS proper handling and inspection EU inspection an                        (GFCI) are in place (P)               procedures (P)
BSA-1 16                                L energized electrical                                                       Proper Radiological controls in place (P)
III line falls on the SWB.
Deflagration/Over-                   Waste inside SWB (IC)                 Fire extinguishers available (M)
A pressurization                        ECS ventilation system HEPA          Proper Radiological controls in place (P)
BSA-1 17                                L of noncompliant drum                 filtered (M)
III in SWB.
While moving SWB            A        SWB is a Type A container (IC)        Load carried low decreasing impact (P)
BSA-1 18   to the staging area it       L is dropped.                 III While stacking 2 high       A        SWB is a Type A container (IC)        WCS proper handling and inspection BSA-1 19   the top SWB is               L                                             procedures (P) dropped.                    III                                            Proper Radiological controls in place (P)
While inspecting the                 ECS ventilation system HEPA           WCS proper handling and inspection drums a drum leaks          A        filtered (M)                          procedures (P)
BSA-1 20   by over pressurizing        M                                              Proper Radiological controls in place (P) and blows out the           II SWB HEPA filter.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                    Draft Final Table 15, Summary of Safety Significant Controls (SSCs)
SS SSC (Active/      Safety Functions           Performance Criteria            System Evaluation Passive)
To prevent radiological      Slopped walls, significant    The cell is designed and material releases due to     base mat construction,        constructed as an over FWF     seismic induced              separation of waste, non-     300-year stable (Passive)  collapse, high winds and     combustible construction      environment.
severe weather events of the cell.
To prevent radiological      Administrative restriction of The cell material is FWF     material release due to      combustible material within compacted red bed clay (Passive)  propagating externally       the cell.                     that is not combustible initiated fires in the cell.
To prevent radiological      Structural integrity of the   The MCC is designed for material release due to      concrete monolith, size       extended underground FWF seismic, NPH and fires.      shape and handling            placement to exceed 300 waste in limitations.                  years. Unencumbered MCC paths for movement and (Active) handling. Inspections of equipment used in the cell.
To prevent radiological Design feature. Constructed        Constructed of non-BSA-1,                                                               combustible material.
waste    material releases due to as Type II per the Standard handling. seismic induced              on Types of Building (Passive)  collapse, high winds and Construction. Concrete floor severe weather and NPH and curbs.
events of the building.
To prevent radiological Nine-inch curbs around             Unencumbered and BSA-1,    material releases due to facility.
waste                                                               controlled paths for loss of confinement from Waste in either MCC or            movement of material.
handling. vehicle/equipment impact. SWB.
(Passive)                                                            Administrative controls of vehicle activity.
To prevent radiological Noncombustible materials of Limited combustible material releases due to construction and waste            materials within the areas loss of confinement from containers.                       of operations.
BSA-1, fires.                       Container integrity.          Fire extinguishers waste Temperature monitoring of throughout.
handling.
SWB.                          Administrative controls.
(Active)
Procedures, spotters, active communications capability.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                Draft Final SS SSC (Active/       Safety Functions          Performance Criteria         System Evaluation Passive)
To prevent radiological HEPA filtration and negative  Administrative controls.
ECS and material releases to the   pressure in the structure.
waste                                                            Procedures, spotters, environment due to loss of handling area.                                                       active communications confinement from (Passive)                                                          capability.
vehicle/equipment impact.
To prevent radiological Noncombustible materials of   HVAC system to control material releases due to construction and waste       temperature.
loss of confinement from containers.                  Administrative Controls:
fires.                     Container integrity.       Radiological and ECS and                                 Temperature monitoring of  temperature monitoring, waste                                 SWB. Drums overpacked in   Procedures, handling area.                            SWB.                       communication devices, (Active)                                                          spotters, and controlled speeds minimize the potential for an event and reduce the impact of the potential event.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                      Draft Final 9    CONCLUSIONS This safety analysis documents the evaluation of the potential accident scenarios where the drum contents are available for release and dispersion and identified the Safety Significant Controls (SSCs), summarized inError! Reference source not found., to mitigate the hazards. The hazards are reasonable and considered to be manageable with the proper SSCs. Based on the hazards presented by the non-compliant drums within the majority of the SWBs, execution of this work requires a safe, controlled approach, including engineered controls as the first line of defense to ensure the safety of the collocated worker and environment. Performing the SWB retrieval within an ECS provides for a higher degree of radiation protection for the workers and environment. It minimizes the likelihood of a release, uncontrolled, or uncontained hazard from radioactive material to the worker and environment. The potential for a deflagration/over-pressurization within the non-compliant drums was evaluated, and if unmitigated, results in significant contamination event, driving the need for engineered contamination control equipment for TRU waste in addition to temperature controls and monitoring to maintain the SWBs at a safe, stable temperature below 100. The WCS technical approach includes the required DSA engineered and administrative controls to minimize the potential for a significant contamination event during SWB retrieval and storage.
Based on the current status of the non-compliant drums, this DSA establishes the set of safety controls, when taken into consideration with the existing WCS occupational safety, health, environmental and radiation safety programs, allows WCS to proceed immediately with Option 1 for the SWB retrieval rather than continuing to wait on additional analysis and evaluation for several more weeks which will never remove 100% of the risk associated with the non-compliant waste. WCS is immediately prepared to begin procurement and installation of the necessary radiological control equipment, procedure development, and training in preparation for the safe SWB retrieval. Upon readiness confirmation of the implemented ALARA and DSA controls, WCS will be prepared to proceed with unearthing MCCs and transfer to BSA-1, and within the DSA compliant ECS, designed to minimize the potential for a significant contamination event, WCS will be able to safely remove the remaining 74 SWBs from the MCCs and store them in a temperature-controlled area until DOE completes final testing, evaluations, and WIPP approval for shipment and disposal.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal Draft Final Page 70

Documented Safety Analysis for WCS TRU Waste Handling and Disposal                  Draft Final 10 REFERENCES Department of Energy (DOE) Environmental Health (EH) 1988, Internal Dose Conversion Factors for Calculation of Dose to the Public, DOE/EH0071, DE88 014297, July 1988.
DOE-1994, DOE Limited Standard, Hazard Baseline Documentation, DOE-EM-STD-5502-94, August 1994.
DOE-2006, Accident Analysis for Aircraft Crash into Hazardous Facilities DOE-2006, Accident Analysis for Aircraft Crash into Hazardous Facilities. DOE-STD-3014-2006, May 2006.
DOE 2007, Preparation of Safety Basis Documents for Transuranic (TRU Waste Facilities. DOE-STD-5506-2007, April 2007.
DOE 2008a, Integration of Safety into the Design Process, DOE-STD-1189-2008, March 2008.
DOE 2008b, Site-Wide Environmental Impact Statement for Continued Operation of Los Alamos National Laboratory, Los Alamos, New Mexico. DOE/EIS-0380, May 2008.
DOE 2013, Airborne Release Fractions/Rates and Respirable Fractions for Nonreactor Nuclear Facilities, Volume 1 - Analysis of Experimental Data. DOE-HDBK-3010-94, Reaffirmed 2013.
DOE 2014a, Preparation Guide for U.S. Department of Energy Non-Reactor Nuclear Facility Documented Safety Analyses Standard, DOE-STD-3009-2014, November 2014.
DOE 2014b, Review and Approval of Nuclear Facility Safety Basis and Safety Design Basis Documents, DOE-STD-1104-2014, December 2014.
DOE 2015. Accident Investigation Report Phase 2, Radiological Release Event at the Waste Isolation Pilot Plant, February 14, 2014. Office of Environmental Management, April 2015.
DOE 2016a. Safety Evaluation Report, SER-AREA G-ESS-14-002, Rev 5. October 2016.
DOE 2016b, Supplemental Analysis for Treatment, Repackaging and Storage of Nitrate Salt Waste Drums at Los Alamos National Laboratory, DOE/EIS-380-SA-04, December 2016.
DOE 2016c, Preparation of Documented Safety Analysis for Interim Operations at DOE Nuclear Facilities, DOE-STD-3011-2016.
DOE 2018, Hazard Categorization of DOE Nuclear Facilities, DOS-STD-1017-2018, November 2018.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal               Draft Final DOE/WIPP 2003, Safety Evaluation Report of the WIPP Preliminary Safety Analysis Report, DOE/WIPP-03-3174, Appendix B, January 2003.
EPA-1999, Cancer Risk Coefficients for Environmental Exposure to Radionuclides, Federal Report No. 13, EPA 402-R-99-001, September 1999.
HotSpot-2020, HotSpot Version 3.1.2, National Atmospheric Release Advisory Center, Lawrence Livermore National Lab. February 11, 2020.
Los Alamos National Lab (LANL 2016), Evaluation of the likelihood for Thermal Runaway for Nitrate Salt Containers in Storage at Los Alamos National Laboratory, LA-UR-16-22002, March 25, 2016.
NCRP-129, Recommended Screening Limits for Contaminated Surface Soil and Review Of Factors Relevant To Site-Specific Studies, National Council On Radiation Protection And Measurements, Report Number 129, 1999.
NUREG-1140, A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees, August 1991.
Savannah River National Laboratory (SRNL) 2018 Stability Study of LANL RNS Waste at Waste Control Specialists, SRNL-RP-2018-00644, Rev. 0, June 2018.
SRNL-2020, Waste Control Specialists Technical Review Team Report, SRNL-RP-2020-00146, July 2020.
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal     Draft Final Appendix 1, GENERAL RESUSPENSION General Resuspension Minimum PE-Ci Activity HotSpot Version 3.1.2 General Resuspension Oct 29, 2020 1:27:37 PM (Resuspension Factor : NCRP Report No. 129)
Source Material        : Pu-239 F 24065y Source Term           : 7.44E+01 uCi/m2 Resuspension Factor        : 1.0E-06 1/m Effective Release Radius : 1.00E+00 m Effective Source Term       : 9.6E-12 Ci/s Contamination Age          : 1.00E+00 day Wind Speed (h=10 m)           : 1.00 m/s Surface Wind Speed (h=2 m) : 0.41 m/s Stability Class      :F Respirable Dep. Vel.      : 1.00 cm/s Receptor Height         : 1.5 m Inversion Layer Height : None Sample Time            : 10.000 min Breathing Rate        : 4.17E-04 m3/sec Distance Coordinates       : All distances are on the Plume Centerline Maximum Dose Distance            : 0.038 km MAXIMUM TED                     : 9.67E-05 rem Inner Contour Dose        : 0.050 rem Middle Contour Dose          : 0.010 rem Outer Contour Dose         : 1.00E-03 rem Exceeds Inner Dose Out To : Not Exceeded Exceeds Middle Dose Out To : Not Exceeded Exceeds Outer Dose Out To : Not Exceeded FGR-13 Dose Conversion Data - Total Effective Dose (TED)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal Draft Final DISTANCE           TED               AVERAGE PER 1-HR EXPOSURE TIME       AIR CONCENTRATION km         (rem)          (Ci/m3) 0.010        2.1E-06          3.2E-15 0.020        4.3E-05          6.4E-14 0.040        9.6E-05          1.5E-13 0.100        2.5E-05          3.8E-14 0.500        2.6E-07          3.9E-16 1.000        2.9E-08          4.4E-17 2.000        2.6E-09          3.9E-18 6.000        3.5E-11          5.3E-20 8.000        1.1E-11          1.7E-20 32.000         9.4E-17          1.4E-25 51.000         0.0E+00          0.0E+00 100.000          0.0E+00          0.0E+00 Page 74

Documented Safety Analysis for WCS TRU Waste Handling and Disposal     Draft Final General Resuspension Average PE-Ci Activity HotSpot Version 3.1.2 General Resuspension Oct 29, 2020 1:37:37 PM (Resuspension Factor : NCRP Report No. 129)
Source Material        : Pu-239 F 24065y Source Term           : 9.21E+01 uCi/m2 Resuspension Factor        : 1.0E-06 1/m Effective Release Radius : 1.00E+00 m Effective Source Term       : 1.2E-11 Ci/s Contamination Age          : 1.00E+00 day Wind Speed (h=10 m)           : 1.00 m/s Surface Wind Speed (h=2 m) : 0.41 m/s Stability Class      :F Respirable Dep. Vel.      : 1.00 cm/s Receptor Height         : 1.5 m Inversion Layer Height : None Sample Time            : 10.000 min Breathing Rate        : 4.17E-04 m3/sec Distance Coordinates       : All distances are on the Plume Centerline Maximum Dose Distance            : 0.038 km MAXIMUM TED                     : 1.20E-04 rem Inner Contour Dose        : 0.050 rem Middle Contour Dose          : 0.010 rem Outer Contour Dose         : 1.00E-03 rem Exceeds Inner Dose Out To : Not Exceeded Exceeds Middle Dose Out To : Not Exceeded Exceeds Outer Dose Out To : Not Exceeded FGR-13 Dose Conversion Data - Total Effective Dose (TED)
Page 75

Documented Safety Analysis for WCS TRU Waste Handling and Disposal Draft Final DISTANCE           TED               AVERAGE PER 1-HR EXPOSURE TIME       AIR CONCENTRATION km         (rem)          (Ci/m3) 0.010        2.7E-06          4.0E-15 0.020        5.3E-05          8.0E-14 0.040        1.2E-04          1.8E-13 0.100        3.1E-05          4.8E-14 0.500        3.2E-07          4.8E-16 1.000        3.6E-08          5.4E-17 2.000        3.2E-09          4.8E-18 6.000        4.4E-11          6.6E-20 8.000        1.4E-11          2.1E-20 32.000         1.2E-16          1.8E-25 51.000         0.0E+00          0.0E+00 100.000          0.0E+00          0.0E+00 Page 76

Documented Safety Analysis for WCS TRU Waste Handling and Disposal     Draft Final General Resuspension Median PE-Ci Activity HotSpot Version 3.1.2 General Resuspension Oct 29, 2020 1:38:44 PM (Resuspension Factor : NCRP Report No. 129)
Source Material        : Pu-239 F 24065y Source Term           : 7.20E+01 uCi/m2 Resuspension Factor        : 1.0E-06 1/m Effective Release Radius : 1.00E+00 m Effective Source Term       : 9.3E-12 Ci/s Contamination Age          : 1.00E+00 day Wind Speed (h=10 m)           : 1.00 m/s Surface Wind Speed (h=2 m) : 0.41 m/s Stability Class      :F Respirable Dep. Vel.      : 1.00 cm/s Receptor Height         : 1.5 m Inversion Layer Height : None Sample Time            : 10.000 min Breathing Rate        : 4.17E-04 m3/sec Distance Coordinates       : All distances are on the Plume Centerline Maximum Dose Distance            : 0.038 km MAXIMUM TED                     : 9.36E-05 rem Inner Contour Dose        : 0.050 rem Middle Contour Dose          : 0.010 rem Outer Contour Dose         : 1.00E-03 rem Exceeds Inner Dose Out To : Not Exceeded Exceeds Middle Dose Out To : Not Exceeded Exceeds Outer Dose Out To : Not Exceeded FGR-13 Dose Conversion Data - Total Effective Dose (TED)
Page 77

Documented Safety Analysis for WCS TRU Waste Handling and Disposal Draft Final DISTANCE          TED                AVERAGE PER 1-HR EXPOSURE TIME       AIR CONCENTRATION km         (rem)          (Ci/m3) 0.010        2.1E-06          3.1E-15 0.020        4.1E-05          6.2E-14 0.040        9.3E-05          1.4E-13 0.100        2.5E-05          3.7E-14 0.500        2.5E-07          3.8E-16 1.000        2.8E-08          4.2E-17 2.000        2.5E-09          3.8E-18 6.000        3.4E-11          5.2E-20 8.000        1.1E-11          1.6E-20 32.000         9.1E-17          1.4E-25 51.000         0.0E+00          0.0E+00 100.000          0.0E+00          0.0E+00 Page 78

Documented Safety Analysis for WCS TRU Waste Handling and Disposal     Draft Final General Resuspension Maximum PE-Ci Activity HotSpot Version 3.1.2 General Resuspension Oct 29, 2020 1:39:31 PM (Resuspension Factor : NCRP Report No. 129)
Source Material        : Pu-239 F 24065y Source Term           : 3.52E+03 uCi/m2 Resuspension Factor        : 1.0E-06 1/m Effective Release Radius : 1.00E+00 m Effective Source Term       : 4.5E-10 Ci/s Contamination Age          : 1.00E+00 day Wind Speed (h=10 m)           : 1.00 m/s Surface Wind Speed (h=2 m) : 0.41 m/s Stability Class      :F Respirable Dep. Vel.      : 1.00 cm/s Receptor Height         : 1.5 m Inversion Layer Height : None Sample Time            : 10.000 min Breathing Rate        : 4.17E-04 m3/sec Distance Coordinates       : All distances are on the Plume Centerline Maximum Dose Distance            : 0.038 km MAXIMUM TED                     : 4.58E-03 rem Inner Contour Dose        : 0.050 rem Middle Contour Dose          : 0.010 rem Outer Contour Dose         : 1.00E-03 rem Exceeds Inner Dose Out To : Not Exceeded Exceeds Middle Dose Out To : Not Exceeded Exceeds Outer Dose Out To : 0.11 km FGR-13 Dose Conversion Data - Total Effective Dose (TED)
Page 79

Documented Safety Analysis for WCS TRU Waste Handling and Disposal Draft Final DISTANCE           TED               AVERAGE PER 1-HR EXPOSURE TIME       AIR CONCENTRATION km         (rem)          (Ci/m3) 0.010        1.0E-04          1.5E-13 0.020        2.0E-03          3.0E-12 0.040        4.5E-03          6.9E-12 0.100        1.2E-03          1.8E-12 0.500        1.2E-05          1.8E-14 1.000        1.4E-06          2.1E-15 2.000        1.2E-07          1.8E-16 6.000        1.7E-09          2.5E-18 8.000        5.2E-10          7.8E-19 32.000         4.4E-15          6.7E-24 51.000         0.0E+00          2.6E-28 100.000         0.0E+00          0.0E+00 Page 80

Documented Safety Analysis for WCS TRU Waste Handling and Disposal     Draft Final Appendix 2, PLUTONIUM RESUSPENSION Plutonium Resuspension Minimum Activity HotSpot Version 3.1.2 Plutonium Resuspension Nov 1, 2020 9:24:25 AM (Resuspension Factor : NCRP Report No. 129)
Source Material        : Weapons Grade Pu Source Term           : 7.44E+01 uCi/m2 Resuspension Factor        : 1.0E-06 1/m Effective Release Radius : 1.00E+00 m Effective Source Term       : 9.6E-12 Ci/s Contamination Age          : 1.00E+00 day Wind Speed (h=10 m)           : 1.00 m/s Wind Direction         : 180.0 degrees Wind from the South Surface Wind Speed (h=2 m) : 0.41 m/s Stability Class      :F Surface Roughness Length : 3.0 cm Respirable Dep. Vel.      : 1.00 cm/s Receptor Height         : 1.5 m Inversion Layer Height : None Sample Time            : 10.000 min Breathing Rate        : 4.17E-04 m3/sec Distance Coordinates       : All distances are on the Plume Centerline Maximum Dose Distance            : 0.038 km MAXIMUM TED                     : 1.30E-05 rem Inner Contour Dose        : 0.500 rem Middle Contour Dose          : 0.100 rem Outer Contour Dose         : 1.00E-03 rem Exceeds Inner Dose Out To : Not Exceeded Exceeds Middle Dose Out To : Not Exceeded Exceeds Outer Dose Out To : Not Exceeded FGR-13 Dose Conversion Data - Total Effective Dose (TED)
Page 81

Documented Safety Analysis for WCS TRU Waste Handling and Disposal Draft Final DISTANCE           TED              AVERAGE PER 1-HR EXPOSURE TIME      AIR CONCENTRATION km         (rem)         (Ci/m3) 0.010        2.9E-07         3.2E-15 0.020        5.7E-06         6.4E-14 0.040        1.3E-05         1.5E-13 0.080        5.5E-06         6.2E-14 0.100        3.4E-06         3.8E-14 0.500        3.4E-08         3.9E-16 1.000        3.9E-09         4.4E-17 2.000        3.5E-10         3.9E-18 4.000        2.6E-11         2.9E-19 6.000        4.7E-12         5.3E-20 8.000        1.5E-12         1.7E-20 10.000         6.1E-13         6.8E-21 32.000         1.3E-17         1.4E-25 100.000          0.0E+00         0.0E+00 Page 82

Documented Safety Analysis for WCS TRU Waste Handling and Disposal     Draft Final Plutonium Resuspension Average Activity HotSpot Version 3.1.2 Plutonium Resuspension Oct 31, 2020 10:37:45 AM (Resuspension Factor : NCRP Report No. 129)
Source Material        : Weapons Grade Pu Source Term           : 9.21E+02 uCi/m2 Resuspension Factor        : 1.0E-06 1/m Effective Release Radius : 1.00E+00 m Effective Source Term       : 1.2E-10 Ci/s Contamination Age          : 1.00E+00 day Wind Speed (h=10 m)           : 1.00 m/s Wind Direction         : 180.0 degrees Wind from the South Surface Wind Speed (h=2 m) : 0.41 m/s Stability Class      :F Respirable Dep. Vel.      : 1.00 cm/s Receptor Height         : 1.5 m Inversion Layer Height : None Sample Time            : 10.000 min Breathing Rate        : 3.30E-04 m3/sec Distance Coordinates       : All distances are on the Plume Centerline Maximum Dose Distance            : 0.038 km MAXIMUM TED                     : 1.27E-04 rem Inner Contour Dose        : 1.00E-05 rem Middle Contour Dose          : 5.00E-06 rem Outer Contour Dose         : 1.00E-06 rem Exceeds Inner Dose Out To : 0.16 km Exceeds Middle Dose Out To : 0.21 km Exceeds Outer Dose Out To : 0.35 km FGR-13 Dose Conversion Data - Total Effective Dose (TED)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal Draft Final DISTANCE          TED               AVERAGE PER 1-HR EXPOSURE TIME       AIR CONCENTRATION km         (rem)          (Ci/m3) 0.010        2.8E-06          4.0E-14 0.200        5.5E-06          7.8E-14 0.040        1.3E-04          1.8E-12 0.100        3.3E-05          4.8E-13 0.500        3.4E-07          4.8E-15 1.000        3.8E-08          5.4E-16 2.000        3.4E-09          4.8E-17 6.000        4.6E-11          6.6E-19 8.000        1.4E-11          2.1E-19 32.000         1.2E-16          1.8E-24 51.000         0.0E+00          0.0E+00 100.000          0.0E+00          0.0E+00 Page 84

Documented Safety Analysis for WCS TRU Waste Handling and Disposal     Draft Final Plutonium Resuspension Median Activity HotSpot Version 3.1.2 Plutonium Resuspension Oct 31, 2020 10:35:10 AM (Resuspension Factor : NCRP Report No. 129)
Source Material        : Weapons Grade Pu Source Term           : 7.20E+02 uCi/m2 Resuspension Factor        : 1.0E-06 1/m Effective Release Radius : 1.00E+00 m Effective Source Term       : 9.3E-11 Ci/s Contamination Age          : 1.00E+00 day Wind Speed (h=10 m)           : 1.00 m/s Wind Direction         : 180.0 degrees Wind from the South Surface Wind Speed (h=2 m) : 0.41 m/s Stability Class      :F Respirable Dep. Vel.      : 1.00 cm/s Receptor Height         : 1.5 m Inversion Layer Height : None Sample Time            : 10.000 min Breathing Rate        : 3.30E-04 m3/sec Distance Coordinates       : All distances are on the Plume Centerline Maximum Dose Distance            : 0.038 km MAXIMUM TED                     : 9.96E-05 rem Inner Contour Dose        : 1.00E-05 rem Middle Contour Dose          : 5.00E-06 rem Outer Contour Dose         : 1.00E-06 rem Exceeds Inner Dose Out To : 0.15 km Exceeds Middle Dose Out To : 0.19 km Exceeds Outer Dose Out To : 0.33 km FGR-13 Dose Conversion Data - Total Effective Dose (TED)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal Draft Final DISTANCE          TED               AVERAGE PER 1-HR EXPOSURE TIME       AIR CONCENTRATION km          (rem)          (Ci/m3) 0.010       2.2E-06           3.1E-14 0.200       4.3E-06           6.1E-14 0.040       9.9E-05           1.4E-12 0.100       2.6E-05           3.7E-13 0.500       2.6E-07           3.8E-15 1.000       3.0E-08           4.2E-16 2.000       2.6E-09           3.8E-17 6.000       3.6E-11           5.2E-19 8.000       1.1E-11           1.6E-19 32.000        9.6E-17           1.4E-24 51.000        0.0E+00           0.0E+00 100.000         0.0E+00           0.0E+00 Page 86

Documented Safety Analysis for WCS TRU Waste Handling and Disposal     Draft Final Plutonium Resuspension Maximum Activity HotSpot Version 3.1.2 Plutonium Resuspension Oct 31, 2020 10:32:54 AM (Resuspension Factor : NCRP Report No. 129)
Source Material        : Weapons Grade Pu Source Term           : 3.52E+03 uCi/m2 Resuspension Factor        : 1.0E-06 1/m Effective Release Radius : 1.00E+00 m Effective Source Term       : 4.5E-10 Ci/s Contamination Age          : 1.00E+00 day Wind Speed (h=10 m)           : 1.00 m/s Wind Direction         : 180.0 degrees Wind from the South Surface Wind Speed (h=2 m) : 0.41 m/s Stability Class      :F Respirable Dep. Vel.      : 1.00 cm/s Receptor Height         : 1.5 m Inversion Layer Height : None Sample Time            : 10.000 min Breathing Rate        : 3.30E-04 m3/sec Distance Coordinates       : All distances are on the Plume Centerline Maximum Dose Distance            : 0.038 km MAXIMUM TED                     : 4.87E-04 rem Inner Contour Dose        : 1.00E-05 rem Middle Contour Dose          : 5.00E-06 rem Outer Contour Dose         : 1.00E-06 rem Exceeds Inner Dose Out To : 0.26 km Exceeds Middle Dose Out To : 0.33 km Exceeds Outer Dose Out To : 0.54 km FGR-13 Dose Conversion Data - Total Effective Dose (TED)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal Draft Final DISTANCE         TED                    AVERAGE PER 1-HR EXPOSURE TIME         AIR CONCENTRATION km       (rem)              (Ci/m3) 0.010      1.1E-05            1.5E-13 0.200      2.1E-05            3.0E-13 0.040      4.8E-04            6.9E-12 0.100      1.3E-04            1.8E-12 0.500      1.3E-06            1.8E-14 1.000      1.5E-07            2.1E-15 2.000      1.3E-08            1.8E-16 6.000      1.8E-10            2.5E-18 8.000      5.5E-11            7.8E-19 32.000       4.7E-16            6.7E-24 51.000       0.0E+00            2.6E-28 100.000        0.0E+00            0.0E+00 Page 88

Documented Safety Analysis for WCS TRU Waste Handling and Disposal      Draft Final Appendix 3, GENERAL FIRE General Fire Minimum Activity HotSpot Version 3.1.2 General Fire Nov 25, 2020 2:36:43 PM Source Material         : Pu-239 F 24065y Material-at-Risk (MAR) : 2.3400E+00 Ci Damage Ratio       (DR) : 0.10 Airborne Fraction (ARF) : 1.00E-02 Respirable Fraction (RF) : 5.00E-02 Leakpath Factor (LPF) : 0.500 Respirable Source Term : 5.85E-05 Ci Non-respirable Source Term : 1.11E-03 Ci Release Radius          :1m Cloud Top             : 0.00 m Physical Height of Fire : 0 m Effective Release Height : 0.00 m Wind Speed (h=10 m)           : 1.00 m/s Wind Direction           : 180.0 degrees Wind from the South Avg Wind Speed (h=H-eff) : 0.41 m/s Stability Class       :F Surface Roughness Length : 3.0 cm Respirable Dep. Vel.       : 1.00 cm/s Non-respirable Dep. Vel. : 1.00 cm/s Receptor Height          : 1.5 m Inversion Layer Height : None Sample Time             : 10.000 min Breathing Rate          : 3.30E-04 m3/sec Distance Coordinates        : All distances are on the Plume Centerline Maximum Dose Distance            : 0.010 km MAXIMUM TED                     : 0.756 rem Inner Contour Dose         : 0.500 rem Middle Contour Dose          : 0.100 rem Outer Contour Dose          : 1.00E-03 rem Exceeds Inner Dose Out To : 0.018 km Exceeds Middle Dose Out To : 0.059 km Exceeds Outer Dose Out To : 0.35 km Page 89

Documented Safety Analysis for WCS TRU Waste Handling and Disposal            Draft Final FGR-13 Dose Conversion Data - Total Effective Dose (TED)
RESPIRABLE DISTANCE     TED    TIME-INTEGRATED GROUND SURFACE            GROUND SHINE ARRIVAL AIR CONCENTRATION DEPOSITION               DOSE RATE   TIME km    (rem)          (Ci-sec)/m3        (uCi/m2)
(rem/hr) (hour:min) 0.010   7.6E-01      5.2E-06       1.4E+01        5.8E-08    <00:01 0.020   4.6E-01      3.1E-06       3.5E+00        1.4E-08    <00:01 0.040   2.0E-01      1.4E-06       6.8E-01       2.8E-09     00:01 0.080   5.4E-02      3.7E-07       1.1E-01       4.4E-10     00:03 0.100   3.2E-02      2.2E-07       5.8E-02       2.4E-10     00:04 0.500   3.3E-04      2.3E-09       4.7E-04       1.9E-12     00:20 1.000   3.8E-05      2.6E-10       5.3E-05       2.2E-13     00:40 2.000   3.4E-06      2.3E-11       4.7E-06       1.9E-14     01:20 4.000   2.6E-07      1.8E-12       3.5E-07       1.4E-15     02:41 6.000   4.7E-08      3.2E-13       6.5E-08       2.6E-16     04:02 8.000   1.5E-08      1.0E-13       2.0E-08       8.2E-17     05:23 10.000    6.0E-09      4.2E-14       8.3E-09       3.4E-17     06:43 32.000    1.3E-13      8.6E-19       1.7E-13       0.0E+00     21:32 100.000     0.0E+00      0.0E+00        0.0E+00       0.0E+00     >24:00 Page 90

Documented Safety Analysis for WCS TRU Waste Handling and Disposal      Draft Final General Fire Average Activity HotSpot Version 3.1.2 General Fire Nov 25, 2020 1:19:50 PM Source Material         : Pu-239 F 24065y Material-at-Risk (MAR) : 2.8950E+01 Ci Damage Ratio       (DR) : 0.10 Airborne Fraction (ARF) : 1.00E-02 Respirable Fraction (RF) : 5.00E-02 Leakpath Factor (LPF) : 0.500 Respirable Source Term : 7.24E-04 Ci Non-respirable Source Term : 1.38E-02 Ci Release Radius          :1m Cloud Top             : 0.00 m Physical Height of Fire : 0 m Effective Release Height : 0.00 m Wind Speed (h=10 m)           : 1.00 m/s Wind Direction           : 180.0 degrees Wind from the South Avg Wind Speed (h=H-eff) : 0.41 m/s Stability Class       :F Surface Roughness Length : 3.0 cm Respirable Dep. Vel.       : 1.00 cm/s Non-respirable Dep. Vel. : 1.00 cm/s Receptor Height          : 1.5 m Inversion Layer Height : None Sample Time             : 10.000 min Breathing Rate          : 3.30E-04 m3/sec Distance Coordinates        : All distances are on the Plume Centerline Maximum Dose Distance            : 0.010 km MAXIMUM TED                     : 9.4 rem Inner Contour Dose         : 0.500 rem Middle Contour Dose          : 0.100 rem Outer Contour Dose          : 1.00E-03 rem Exceeds Inner Dose Out To : 0.090 km Exceeds Middle Dose Out To : 0.17 km Exceeds Outer Dose Out To : 0.78 km FGR-13 Dose Conversion Data - Total Effective Dose (TED)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal             Draft Final RESPIRABLE DISTANCE     TED    TIME-INTEGRATED GROUND SURFACE         GROUND SHINE    ARRIVAL AIR CONCENTRATION DEPOSITION              DOSE RATE     TIME km      (rem)      (Ci-sec)/m3        (uCi/m2)           (rem/hr)     (hour:min) 0.010   9.4E+00       6.4E-05     1.8E+02        7.1E-07     <00:01 0.020   5.6E+00       3.9E-05     4.3E+01        1.7E-07     <00:01 0.040   2.5E+00       1.7E-05     8.4E+00        3.4E-08      00:01 0.080   6.7E-01      4.6E-06      1.3E+00       5.5E-09      00:03 0.100   4.0E-01      2.7E-06      7.2E-01       2.9E-09      00:04 0.500   4.1E-03      2.8E-08      5.8E-03       2.4E-11      00:20 1.000   4.7E-04      3.2E-09      6.5E-04       2.7E-12      00:40 2.000   4.2E-05      2.9E-10      5.8E-05       2.4E-13      01:20 4.000   3.2E-06      2.2E-11      4.4E-06       1.8E-14      02:41 6.000   5.8E-07      4.0E-12      8.0E-07       3.3E-15      04:02 8.000   1.8E-07      1.2E-12      2.5E-07       1.0E-15      05:23 10.000    7.5E-08      5.1E-13      1.0E-07       4.2E-16      06:43 32.000    1.5E-12      1.1E-17      2.1E-12       0.0E+00      21:32 100.000     0.0E+00      0.0E+00       0.0E+00       0.0E+00      >24:00 Page 92

Documented Safety Analysis for WCS TRU Waste Handling and Disposal      Draft Final General Fire Median Activity HotSpot Version 3.1.2 General Fire Nov 25, 2020 1:39:40 PM Source Material         : Pu-239 F 24065y Material-at-Risk (MAR) : 2.2630E+01 Ci Damage Ratio       (DR) : 0.10 Airborne Fraction (ARF) : 1.00E-02 Respirable Fraction (RF) : 5.00E-02 Leakpath Factor (LPF) : 0.500 Respirable Source Term : 5.66E-04 Ci Non-respirable Source Term : 1.07E-02 Ci Release Radius          :1m Cloud Top             : 0.00 m Physical Height of Fire : 0 m Effective Release Height : 0.00 m Wind Speed (h=10 m)           : 1.00 m/s Wind Direction           : 180.0 degrees Wind from the South Avg Wind Speed (h=H-eff) : 0.41 m/s Stability Class       :F Surface Roughness Length : 3.0 cm Respirable Dep. Vel.       : 1.00 cm/s Non-respirable Dep. Vel. : 1.00 cm/s Receptor Height          : 1.5 m Inversion Layer Height : None Sample Time             : 10.000 min Breathing Rate          : 3.30E-04 m3/sec Distance Coordinates        : All distances are on the Plume Centerline Maximum Dose Distance            : 0.010 km MAXIMUM TED                     : 7.3 rem Inner Contour Dose         : 0.500 rem Middle Contour Dose          : 0.100 rem Outer Contour Dose          : 1.00E-03 rem Exceeds Inner Dose Out To : 0.081 km Exceeds Middle Dose Out To : 0.16 km Exceeds Outer Dose Out To : 0.72 km FGR-13 Dose Conversion Data - Total Effective Dose (TED)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal         Draft Final RESPIRABLE DISTANCE     TED    TIME-INTEGRATED GROUND SURFACE        GROUND SHINE ARRIVAL AIR CONCENTRATION DEPOSITION           DOSE RATE   TIME km    (rem)      (Ci-sec)/m3            (uCi/m2)         (rem/hr)   (hour:min) 0.010   7.3E+00       5.0E-05     1.4E+02       5.6E-07   <00:01 0.020   4.4E+00       3.0E-05     3.3E+01       1.4E-07   <00:01 0.040   1.9E+00       1.3E-05     6.5E+00       2.7E-08    00:01 0.080   5.2E-01       3.6E-06     1.0E+00      4.3E-09    00:03 0.100   3.1E-01       2.1E-06     5.6E-01      2.3E-09    00:04 0.500   3.2E-03       2.2E-08     4.5E-03      1.8E-11    00:20 1.000   3.7E-04       2.5E-09     5.1E-04      2.1E-12    00:40 2.000   3.3E-05       2.3E-10     4.6E-05      1.9E-13    01:20 4.000   2.5E-06       1.7E-11     3.4E-06      1.4E-14    02:41 6.000   4.6E-07       3.1E-12     6.3E-07      2.6E-15    04:02 8.000   1.4E-07       9.8E-13     2.0E-07      8.0E-16    05:23 10.000    5.8E-08       4.0E-13     8.0E-08      3.3E-16    06:43 32.000    1.2E-12       8.3E-18     1.7E-12      0.0E+00    21:32 100.000     0.0E+00       0.0E+00      0.0E+00      0.0E+00    >24:00 Page 94

Documented Safety Analysis for WCS TRU Waste Handling and Disposal      Draft Final General Fire Maximum Activity HotSpot Version 3.1.2 General Fire Nov 25, 2020 2:45:03 PM Source Material         : Pu-239 F 24065y Material-at-Risk (MAR) : 1.1070E+02 Ci Damage Ratio       (DR) : 0.10 Airborne Fraction (ARF) : 1.00E-02 Respirable Fraction (RF) : 5.00E-02 Leakpath Factor (LPF) : 0.500 Respirable Source Term : 2.77E-03 Ci Non-respirable Source Term : 5.26E-02 Ci Release Radius          :1m Cloud Top             : 0.00 m Physical Height of Fire : 0 m Effective Release Height : 0.00 m Wind Speed (h=10 m)           : 1.00 m/s Wind Direction           : 180.0 degrees Wind from the South Avg Wind Speed (h=H-eff) : 0.41 m/s Stability Class       :F Surface Roughness Length : 3.0 cm Respirable Dep. Vel.       : 1.00 cm/s Non-respirable Dep. Vel. : 1.00 cm/s Receptor Height          : 1.5 m Inversion Layer Height : None Sample Time             : 10.000 min Breathing Rate          : 3.30E-04 m3/sec Distance Coordinates        : All distances are on the Plume Centerline Maximum Dose Distance            : 0.010 km MAXIMUM TED                     : 36 rem Inner Contour Dose         : 0.500 rem Middle Contour Dose          : 0.100 rem Outer Contour Dose          : 1.00E-03 rem Exceeds Inner Dose Out To : 0.15 km Exceeds Middle Dose Out To : 0.27 km Exceeds Outer Dose Out To : 1.2 km FGR-13 Dose Conversion Data - Total Effective Dose (TED)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal            Draft Final RESPIRABLE DISTANCE    TED    TIME-INTEGRATED GROUND SURFACE          GROUND SHINE ARRIVAL AIR CONCENTRATION DEPOSITION            DOSE RATE     TIME km    (rem)            (Ci-sec)/m3     (uCi/m2)         (rem/hr)    (hour:min) 0.010   3.6E+01      2.5E-04        6.7E+02      2.7E-06    <00:01 0.020   2.2E+01      1.5E-04        1.6E+02      6.7E-07    <00:01 0.040   9.5E+00      6.5E-05        3.2E+01      1.3E-07     00:01 0.080   2.6E+00      1.8E-05        5.1E+00      2.1E-08     00:03 0.100   1.5E+00      1.0E-05        2.8E+00      1.1E-08     00:04 0.500   1.6E-02      1.1E-07       2.2E-02      9.0E-11     00:20 1.000   1.8E-03      1.2E-08       2.5E-03      1.0E-11     00:40 2.000   1.6E-04      1.1E-09       2.2E-04      9.1E-13     01:20 4.000   1.2E-05      8.3E-11       1.7E-05      6.8E-14     02:41 6.000   2.2E-06      1.5E-11       3.1E-06      1.3E-14     04:02 8.000   6.9E-07      4.8E-12       9.6E-07      3.9E-15     05:23 10.000    2.9E-07      2.0E-12       3.9E-07      1.6E-15     06:43 32.000    5.9E-12      4.1E-17       8.1E-12      0.0E+00     21:32 100.00    0.0E+00      0.0E+00        0.0E+00       0.0E+00     >24:00 Page 96

Documented Safety Analysis for WCS TRU Waste Handling and Disposal     Draft Final Appendix 4, GENERAL PLUME General Plume Minimum Activity HotSpot Version 3.1.2 General Plume Nov 25, 2020 2:30:37 PM Source Material        : Pu-239 F 24065y Material-at-Risk (MAR) : 2.3400E+00 Ci Damage Ratio       (DR) : 0.10 Airborne Fraction (ARF) : 1.00E-02 Respirable Fraction (RF) : 5.00E-02 Leakpath Factor (LPF) : 0.500 Respirable Source Term : 5.85E-05 Ci Non-respirable Source Term : 1.11E-03 Ci Effective Release Height : 0.00 m Wind Speed (h=10 m)          : 0.41 m/s Wind Direction          : 180.0 degrees Wind from the South Wind Speed (h=H-eff)         : 0.17 m/s Stability Class       :F Respirable Dep. Vel.      : 1.00 cm/s Non-respirable Dep. Vel. : 1.00 cm/s Receptor Height         : 1.5 m Inversion Layer Height : None Sample Time            : 10.000 min Breathing Rate         : 3.30E-04 m3/sec Distance Coordinates       : All distances are on the Plume Centerline Maximum Dose Distance           : 0.043 km MAXIMUM TED                    : 0.014 rem Inner Contour Dose        : 1.00E-05 rem Middle Contour Dose         : 5.00E-06 rem Outer Contour Dose         : 1.00E-06 rem Exceeds Inner Dose Out To : 0.31 km Exceeds Middle Dose Out To : 0.35 km Exceeds Outer Dose Out To : 0.47 km FGR-13 Dose Conversion Data - Total Effective Dose (TED)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal             Draft Final DISTANCE     TED    TIME-INTEGRATED     GROUND SURFACE      GROUND SHINE ARRIVAL AIR      CONCENTRATION         DEPOSITION         DOSE RATE     TIME km    (rem)        (Ci-sec)/m3         (uCi/m2)           (rem/hr)    (hour:min) 0.010   1.3E-17       9.0E-23     2.9E+02        1.2E-06     <00:01 0.200   7.7E-05       5.3E-10     1.2E-04       4.9E-13      00:19 0.040   1.4E-02       9.4E-08     3.1E-01       1.3E-09      00:03 0.100   1.6E-03       1.1E-08     3.5E-03       1.4E-11      00:09 0.500   7.8E-07       5.4E-12     1.1E-06       4.5E-15      00:49 1.000   2.1E-08       1.4E-13     2.9E-08       1.2E-16      01:38 2.000   2.8E-10       1.9E-15     3.9E-10       1.6E-18      03:17 6.000   6.8E-14       4.7E-19     9.4E-14       0.0E+00      09:51 8.000   6.3E-15       4.3E-20     8.6E-15       0.0E+00      13:08 32.000    0.0E+00       0.0E+00      0.0E+00        0.0E+00     >24:00 51.000    0.0E+00       0.0E+00      0.0E+00        0.0E+00     >24:00 100.000     0.0E+00       0.0E+00      0.0E+00        0.0E+00     >24:00 Page 98

Documented Safety Analysis for WCS TRU Waste Handling and Disposal     Draft Final General Plume Average Activity HotSpot Version 3.1.2 General Plume Nov 25, 2020 2:18:05 PM Source Material        : Pu-239 F 24065y Material-at-Risk (MAR) : 2.8950E+01 Ci Damage Ratio       (DR) : 0.10 Airborne Fraction (ARF) : 1.00E-02 Respirable Fraction (RF) : 5.00E-02 Leakpath Factor (LPF) : 0.500 Respirable Source Term : 7.24E-04 Ci Non-respirable Source Term : 1.38E-02 Ci Effective Release Height : 0.00 m Wind Speed (h=10 m)          : 0.41 m/s Wind Direction          : 180.0 degrees Wind from the South Wind Speed (h=H-eff)         : 0.17 m/s Stability Class       :F Respirable Dep. Vel.      : 1.00 cm/s Non-respirable Dep. Vel. : 1.00 cm/s Receptor Height         : 1.5 m Inversion Layer Height : None Sample Time            : 10.000 min Breathing Rate         : 3.30E-04 m3/sec Distance Coordinates       : All distances are on the Plume Centerline Maximum Dose Distance           : 0.043 km MAXIMUM TED                    : 0.172 rem Inner Contour Dose        : 1.00E-05 rem Middle Contour Dose         : 5.00E-06 rem Outer Contour Dose         : 1.00E-06 rem Exceeds Inner Dose Out To : 0.49 km Exceeds Middle Dose Out To : 0.56 km Exceeds Outer Dose Out To : 0.77 km FGR-13 Dose Conversion Data - Total Effective Dose (TED)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal             Draft Final DISTANCE     TED    TIME-INTEGRATED GROUND SURFACE          GROUND SHINE    ARRIVAL AIR CONCENTRATION DEPOSITION            DOSE RATE      TIME km    (rem)           (Ci-sec)/m3        (uCi/m2)         (rem/hr)    (hour:min) 0.010   1.6E-16      1.1E-21       3.5E+03      1.4E-05      <00:01 0.200   9.5E-04      6.5E-09       1.5E-03      6.0E-12      00:19 0.040   1.7E-01      1.2E-06       3.9E+00      1.6E-08       00:03 0.100   2.0E-02      1.4E-07       4.3E-02      1.8E-10      00:09 0.500   9.6E-06      6.6E-11       1.4E-05      5.5E-14      00:49 1.000   2.6E-07      1.8E-12       3.6E-07      1.5E-15      01:38 2.000   3.5E-09      2.4E-14       4.8E-09      2.0E-17      03:17 6.000   8.4E-13      5.8E-18       1.2E-12      0.0E+00       09:51 8.000   7.7E-14      5.3E-19       1.1E-13      0.0E+00       13:08 32.000    0.0E+00       0.0E+00       0.0E+00       0.0E+00     >24:00 51.000    0.0E+00       0.0E+00       0.0E+00       0.0E+00     >24:00 100.000     0.0E+00       0.0E+00       0.0E+00       0.0E+00     >24:00 Page 100

Documented Safety Analysis for WCS TRU Waste Handling and Disposal     Draft Final General Plume Median Activity HotSpot Version 3.1.2 General Plume Nov 25, 2020 2:20:59 PM Source Material        : Pu-239 F 24065y Material-at-Risk (MAR) : 2.2630E+01 Ci Damage Ratio       (DR) : 0.10 Airborne Fraction (ARF) : 1.00E-02 Respirable Fraction (RF) : 5.00E-02 Leakpath Factor (LPF) : 0.500 Respirable Source Term : 5.66E-04 Ci Non-respirable Source Term : 1.07E-02 Ci Effective Release Height : 0.00 m Wind Speed (h=10 m)          : 0.41 m/s Wind Direction          : 180.0 degrees Wind from the South Wind Speed (h=H-eff)         : 0.17 m/s Stability Class       :F Respirable Dep. Vel.      : 1.00 cm/s Non-respirable Dep. Vel. : 1.00 cm/s Receptor Height         : 1.5 m Inversion Layer Height : None Sample Time            : 10.000 min Breathing Rate         : 3.30E-04 m3/sec Distance Coordinates       : All distances are on the Plume Centerline Maximum Dose Distance           : 0.043 km MAXIMUM TED                    : 0.135 rem Inner Contour Dose        : 1.00E-05 rem Middle Contour Dose         : 5.00E-06 rem Outer Contour Dose         : 1.00E-06 rem Exceeds Inner Dose Out To : 0.47 km Exceeds Middle Dose Out To : 0.54 km Exceeds Outer Dose Out To : 0.73 km FGR-13 Dose Conversion Data - Total Effective Dose (TED)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal                Draft Final RESPIRABLE DISTANCE      TED    TIME-INTEGRATED GROUND SURFACE           GROUND SHINE     ARRIVAL AIR CONCENTRATION DEPOSITION             DOSE RATE       TIME km    (rem)              (Ci-sec)/m3      (uCi/m2)          (rem/hr)    (hour:min) 0.010   1.3E-16      8.7E-22        2.8E+03      1.1E-05       <00:01 0.200   7.4E-04      5.1E-09        1.2E-03      4.7E-12       00:19 0.040   1.3E-01      9.1E-07        3.0E+00      1.2E-08       00:03 0.100   1.5E-02      1.1E-07        3.4E-02      1.4E-10       00:09 0.500   7.5E-06      5.2E-11        1.1E-05      4.3E-14       00:49 1.000   2.0E-07      1.4E-12        2.8E-07      1.1E-15       01:38 2.000   2.7E-09      1.9E-14        3.8E-09      1.5E-17       03:17 6.000   6.6E-13      4.5E-18        9.1E-13      0.0E+00       09:51 8.000   6.1E-14      4.2E-19        8.3E-14      0.0E+00       13:08 32.000    0.0E+00      0.0E+00         0.0E+00       0.0E+00      >24:00 51.000    0.0E+00      0.0E+00         0.0E+00       0.0E+00      >24:00 100.000     0.0E+00      0.0E+00         0.0E+00       0.0E+00      >24:00 Page 102

Documented Safety Analysis for WCS TRU Waste Handling and Disposal     Draft Final General Plume Maximum Activity HotSpot Version 3.1.2 General Plume Nov 25, 2020 2:26:03 PM Source Material        : Pu-239 F 24065y Material-at-Risk (MAR) : 1.1070E+02 Ci Damage Ratio       (DR) : 0.10 Airborne Fraction (ARF) : 1.00E-02 Respirable Fraction (RF) : 5.00E-02 Leakpath Factor (LPF) : 0.500 Respirable Source Term : 2.77E-03 Ci Non-respirable Source Term : 5.26E-02 Ci Effective Release Height : 0.00 m Wind Speed (h=10 m)          : 0.41 m/s Wind Direction          : 180.0 degrees Wind from the South Wind Speed (h=H-eff)         : 0.17 m/s Stability Class       :F Respirable Dep. Vel.      : 1.00 cm/s Non-respirable Dep. Vel. : 1.00 cm/s Receptor Height         : 1.5 m Inversion Layer Height : None Sample Time            : 10.000 min Breathing Rate         : 3.30E-04 m3/sec Distance Coordinates       : All distances are on the Plume Centerline Maximum Dose Distance           : 0.043 km MAXIMUM TED                    : 0.659 rem Inner Contour Dose        : 1.00E-05 rem Middle Contour Dose         : 5.00E-06 rem Outer Contour Dose         : 1.00E-06 rem Exceeds Inner Dose Out To : 0.64 km Exceeds Middle Dose Out To : 0.73 km Exceeds Outer Dose Out To : 0.99 km FGR-13 Dose Conversion Data - Total Effective Dose (TED)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal              Draft Final DISTANCE     TED    TIME-INTEGRATED GROUND SURFACE         GROUND SHINE ARRIVAL AIR CONCENTRATION DEPOSITION           DOSE RATE       TIME km    (rem)             (Ci-sec)/m3     (uCi/m2)         (rem/hr)     (hour:min) 0.010   6.2E-16      4.3E-21       1.4E+04       5.5E-05     <00:01 0.200   3.6E-03      2.5E-08       5.6E-03      2.3E-11      00:19 0.040   6.5E-01      4.4E-06       1.5E+01       6.0E-08      00:03 0.100   7.6E-02      5.2E-07       1.7E-01      6.8E-10      00:09 0.500   3.7E-05      2.5E-10       5.2E-05      2.1E-13      00:49 1.000   9.9E-07      6.8E-12       1.4E-06      5.6E-15      01:38 2.000   1.3E-08      9.2E-14       1.8E-08      7.5E-17      03:17 6.000   3.2E-12      2.2E-17       4.4E-12      0.0E+00       09:51 8.000   3.0E-13      2.0E-18       4.1E-13      0.0E+00       13:08 32.000    0.0E+00       0.0E+00       0.0E+00       0.0E+00     >24:00 51.000    0.0E+00       0.0E+00       0.0E+00       0.0E+00     >24:00 100.000     0.0E+00       0.0E+00       0.0E+00       0.0E+00     >24:00 Page 104

Documented Safety Analysis for WCS TRU Waste Handling and Disposal      Draft Final Appendix 5, PLUTONIUM FIRE Plutonium Fire Minimum Activity HotSpot Version 3.1.2 Plutonium Fire Nov 1, 2020 8:42:48 AM Source Material         : Weapons Grade Pu Material-at-Risk (MAR) : 0.029 kg Damage Ratio       (DR) : 1.00 Airborne Fraction (ARF) : 1.00E-02 Respirable Fraction (RF) : 5.00E-02 Leakpath Factor (LPF) : 0.500 Respirable Source Term : 5.87E-04 Ci Non-respirable Source Term : 1.12E-02 Ci Specific Activity       : Ci/g Release Radius          :1m Cloud Top             : 0.00 m Physical Height of Fire : 0 m Effective Release Height : 0.00 m Wind Speed (h=10 m)           : 1.00 m/s Wind Direction           : 180.0 degrees Wind from the South Avg Wind Speed (h=H-eff) : 0.41 m/s Stability Class       :F Surface Roughness Length : 3.0 cm Respirable Dep. Vel.       : 1.00 cm/s Non-respirable Dep. Vel. : 1.00 cm/s Receptor Height          : 1.5 m Inversion Layer Height : None Sample Time             : 10.000 min Breathing Rate          : 3.33E-04 m3/sec Distance Coordinates        : All distances are on the Plume Centerline Maximum Dose Distance            : 0.010 km MAXIMUM TEDE                     : 5.4 rem Inner Contour Dose         : 0.500 rem Middle Contour Dose          : 0.100 rem Outer Contour Dose          : 1.00E-03 rem Exceeds Inner Dose Out To : 0.070 km Exceeds Middle Dose Out To : 0.14 km Page 105

Documented Safety Analysis for WCS TRU Waste Handling and Disposal   Draft Final Exceeds Outer Dose Out To : 0.65 km FGR-11 Dose Conversion Data - Total Effective Dose Equivalent (TEDE)
RESPIRABLE DISTANCE     TEDE     TIME-INTEGRATED GROUND SURFACE        ARRIVAL AIR CONCENTRATION DEPOSITION           TIME km     (rem)      (Ci-sec)/m3             (uCi/m2) (hour:min) 0.010    5.4E+00       5.2E-05     1.4E+02      <00:01 0.200    3.7E-02      3.6E-07      7.9E-02      00:08 0.040    1.4E+00       1.4E-05     6.8E+00       00:01 0.100    2.3E-01      2.2E-06      5.9E-01      00:04 0.500    2.4E-03      2.3E-08      4.7E-03      00:20 1.000    2.7E-04      2.6E-09      5.3E-04      00:40 2.000    2.4E-05      2.4E-10      4.7E-05      01:20 6.000    3.3E-07      3.3E-12      6.5E-07      04:02 8.000    1.0E-07      1.0E-12      2.0E-07      05:23 32.000     8.9E-13      8.6E-18      1.7E-12      21:32 51.000    3.5E-17       3.4E-22      6.8E-17     >24:00 100.000      0.0E+00      0.0E+00       0.0E+00     >24:00 Page 106

Documented Safety Analysis for WCS TRU Waste Handling and Disposal      Draft Final Plutonium Fire Average Activity HotSpot Version 3.1.2 Plutonium Fire Oct 31, 2020 10:46:19 AM Source Material         : Weapons Grade Pu Material-at-Risk (MAR) : .357 kg Damage Ratio       (DR) : 1.00 Airborne Fraction (ARF) : 1.00E-02 Respirable Fraction (RF) : 5.00E-02 Leakpath Factor (LPF) : 0.500 Respirable Source Term : 7.23E-03 Ci Non-respirable Source Term : 1.37E-01 Ci Specific Activity       : 8.10E-02 Ci/g Release Radius          :1m Cloud Top             : 0.00 m Physical Height of Fire : 0 m Effective Release Height : 0.00 m Wind Speed (h=10 m)           : 1.00 m/s Wind Direction           : 180.0 degrees Wind from the South Avg Wind Speed (h=H-eff) : 0.41 m/s Stability Class       :F Respirable Dep. Vel.       : 1.00 cm/s Non-respirable Dep. Vel. : 1.00 cm/s Receptor Height          : 1.5 m Inversion Layer Height : None Sample Time             : 10.000 min Breathing Rate          : 3.30E-04 m3/sec Distance Coordinates        : All distances are on the Plume Centerline Maximum Dose Distance            : 0.010 km MAXIMUM TED                     : 13 rem Inner Contour Dose         : 1.00E-05 rem Middle Contour Dose          : 5.00E-06 rem Outer Contour Dose          : 1.00E-06 rem Exceeds Inner Dose Out To : 3.3 km Exceeds Middle Dose Out To : 3.8 km Exceeds Outer Dose Out To : 5.6 km FGR-13 Dose Conversion Data - Total Effective Dose (TED)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal   Draft Final RESPIRABLE DISTANCE    TED    TIME-INTEGRATED GROUND SURFACE        ARRIVAL AIR CONCENTRATION DEPOSITION          TIME km    (rem)      (Ci-sec)/m3           (uCi/m2) (hour:min) 0.010   1.3E+01       6.4E-04     1.7E+03     <00:01 0.200   8.7E-02      4.4E-06      9.8E-01     00:08 0.040   3.3E+00       1.7E-04     8.3E+01      00:01 0.100   5.3E-01      2.7E-05      7.2E+00     00:04 0.500   5.5E-03      2.8E-07      5.8E-02     00:20 1.000   6.3E-04      3.2E-08      6.5E-03     00:40 2.000   5.7E-05      2.9E-09      5.8E-04     01:20 6.000   7.8E-07      4.0E-11      8.0E-06     04:02 8.000   2.4E-07      1.2E-11      2.5E-06     05:23 32.000    2.1E-12      1.1E-16      2.1E-11     21:32 51.000    8.2E-17      4.2E-21      8.4E-16    >24:00 100.000     0.0E+00      1.9E-27      0.0E+00     >24:00 Page 108

Documented Safety Analysis for WCS TRU Waste Handling and Disposal      Draft Final Plutonium Fire Median Activity HotSpot Version 3.1.2 Plutonium Fire Oct 31, 2020 10:55:53 AM Source Material         : Weapons Grade Pu Material-at-Risk (MAR) : 0.279 kg Damage Ratio       (DR) : 1.00 Airborne Fraction (ARF) : 1.00E-02 Respirable Fraction (RF) : 5.00E-02 Leakpath Factor (LPF) : 0.500 Respirable Source Term : 5.65E-03 Ci Non-respirable Source Term : 1.07E-01 Ci Specific Activity       : 8.10E-02 Ci/g Release Radius          :1m Cloud Top             : 0.00 m Physical Height of Fire : 0 m Effective Release Height : 0.00 m Wind Speed (h=10 m)           : 1.00 m/s Wind Direction           : 180.0 degrees Wind from the South Avg Wind Speed (h=H-eff) : 0.41 m/s Stability Class       :F Respirable Dep. Vel.       : 1.00 cm/s Non-respirable Dep. Vel. : 1.00 cm/s Receptor Height          : 1.5 m Inversion Layer Height : None Sample Time             : 10.000 min Breathing Rate          : 3.30E-04 m3/sec Distance Coordinates        : All distances are on the Plume Centerline Maximum Dose Distance            : 0.010 km MAXIMUM TED                     : 9.8 rem Inner Contour Dose         : 1.00E-05 rem Middle Contour Dose          : 5.00E-06 rem Outer Contour Dose          : 1.00E-06 rem Exceeds Inner Dose Out To : 3.1 km Exceeds Middle Dose Out To : 3.6 km Exceeds Outer Dose Out To : 5.3 km FGR-13 Dose Conversion Data - Total Effective Dose (TED)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal   Draft Final RESPIRABLE DISTANCE      TED    TIME-INTEGRATED GROUND SURFACE       ARRIVAL AIR CONCENTRATION DEPOSITION          TIME km    (rem)      (Ci-sec)/m3            (uCi/m2) (hour:min) 0.010   9.8E+00       5.0E-04    1.4E+03      <00:01 0.200   6.8E-02      3.5E-06     7.6E-01      00:08 0.040   2.6E+00       1.3E-04    6.5E+01       00:01 0.100   4.2E-01      2.1E-05     5.6E+00      00:04 0.500   4.3E-03      2.2E-07     4.5E-02      00:20 1.000   4.9E-04      2.5E-08     5.1E-03      00:40 2.000   4.4E-05      2.3E-09     4.5E-04      01:20 6.000   6.1E-07      3.1E-11     6.3E-06      04:02 8.000   1.9E-07      9.7E-12     1.9E-06      05:23 32.000    1.6E-12      8.3E-17     1.7E-11      21:32 51.000    6.4E-17      3.3E-21     6.5E-16     >24:00 100.000     0.0E+00      1.5E-27     0.0E+00      >24:00 Page 110

Documented Safety Analysis for WCS TRU Waste Handling and Disposal      Draft Final Plutonium Fire Maximum Activity HotSpot Version 3.1.2 Plutonium Fire Oct 31, 2020 10:51:28 AM Source Material         : Weapons Grade Pu Material-at-Risk (MAR) : 1.367 kg Damage Ratio       (DR) : 1.00 Airborne Fraction (ARF) : 1.00E-02 Respirable Fraction (RF) : 5.00E-02 Leakpath Factor (LPF) : 0.500 Respirable Source Term : 2.77E-02 Ci Non-respirable Source Term : 5.26E-01 Ci Specific Activity       : 8.10E-02 Ci/g Release Radius          :1m Cloud Top             : 0.00 m Physical Height of Fire : 0 m Effective Release Height : 0.00 m Wind Speed (h=10 m)           : 1.00 m/s Wind Direction           : 180.0 degrees Wind from the South Avg Wind Speed (h=H-eff) : 0.41 m/s Stability Class       :F Respirable Dep. Vel.       : 1.00 cm/s Non-respirable Dep. Vel. : 1.00 cm/s Receptor Height          : 1.5 m Inversion Layer Height : None Sample Time             : 10.000 min Breathing Rate          : 3.30E-04 m3/sec Distance Coordinates        : All distances are on the Plume Centerline Maximum Dose Distance            : 0.010 km MAXIMUM TED                     : 48 rem Inner Contour Dose         : 1.00E-05 rem Middle Contour Dose          : 5.00E-06 rem Outer Contour Dose          : 1.00E-06 rem Exceeds Inner Dose Out To : 4.5 km Exceeds Middle Dose Out To : 5.3 km Exceeds Outer Dose Out To : 7.9 km FGR-13 Dose Conversion Data - Total Effective Dose (TED)
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Documented Safety Analysis for WCS TRU Waste Handling and Disposal   Draft Final RESPIRABLE DISTANCE      TED    TIME-INTEGRATED GROUND SURFACE      ARRIVAL AIR CONCENTRATION DEPOSITION        TIME km    (rem)      (Ci-sec)/m3          (uCi/m2) (hour:min) 0.010   4.8E+01       2.5E-03    6.7E+03     <00:01 0.200   3.3E-01      1.7E-05     3.7E+00     00:08 0.040   1.3E+01       6.5E-04    3.2E+02      00:01 0.100   2.0E+00       1.0E-04    2.8E+01      00:04 0.500   2.1E-02      1.1E-06     2.2E-01     00:20 1.000   2.4E-03      1.2E-07     2.5E-02     00:40 2.000   2.2E-04      1.1E-08     2.2E-03     01:20 6.000   3.0E-06      1.5E-10     3.1E-05     04:02 8.000   9.3E-07      4.8E-11     9.6E-06     05:23 32.000    8.0E-12      4.1E-16     8.2E-11     21:32 51.000    3.1E-16      1.6E-20     3.2E-15    >24:00 100.000     0.0E+00      7.2E-27     0.0E+00     >24:00 Page 112

WASTE CONTROL SPECIALISTS LLC Agreed Order 2015-0514-RAW-E Docket No. 070-7005 June 30, 2022 APPENDIX 4 Project Plan Sensitive/Confidential Information Subject to Withholding from Public Disclosure Pursuant to 10 CFR 2.390 CONFIDENTIAL - excepted from public disclosure pursuant to Texas Government Code Section 552.110 (a)-(c)

WASTE CONTROL SPECIALISTS LLC Agreed Order 2015-0514-RAW-E Docket No. 070-7005 June 30, 2022 This portion of the application/request/amendment contains Sensitive/Confidential Information Subject to Withholding from Public Disclosure Pursuant to 10 CFR 2.390 and Texas Government Code Section 552.110 (a)-(c)

WASTE CONTROL SPECIALISTS LLC Agreed Order 2015-0514-RAW-E Docket No. 070-7005 June 30, 2022 APPENDIX 4.A Project Schedule Sensitive/Confidential Information Subject to Withholding from Public Disclosure Pursuant to 10 CFR 2.390 CONFIDENTIAL - excepted from public disclosure pursuant to Texas Government Code Section 552.110 (a)-(c)

WASTE CONTROL SPECIALISTS LLC Agreed Order 2015-0514-RAW-E Docket No. 070-7005 June 30, 2022 This portion of the application/request/amendment contains Sensitive/Confidential Information Subject to Withholding from Public Disclosure Pursuant to 10 CFR 2.390 and Texas Government Code Section 552.110 (a)-(c)

WASTE CONTROL SPECIALISTS LLC Agreed Order 2015-0514-RAW-E Docket No. 070-7005 June 30, 2022 APPENDIX 5 Design of Radiological Containment Enclosure Sensitive/Confidential Information Subject to Withholding from Public Disclosure Pursuant to 10 CFR 2.390 CONFIDENTIAL - excepted from public disclosure pursuant to Texas Government Code Section 552.110 (a)-(c)

WASTE CONTROL SPECIALISTS LLC Agreed Order 2015-0514-RAW-E Docket No. 070-7005 June 30, 2022 This portion of the application/request/amendment contains Sensitive/Confidential Information Subject to Withholding from Public Disclosure Pursuant to 10 CFR 2.390 and Texas Government Code Section 552.110 (a)-(c)

WASTE CONTROL SPECIALISTS LLC Agreed Order 2015-0514-RAW-E Docket No. 070-7005 June 30, 2022 APPENDIX 6 Work Instruction Sensitive/Confidential Information Subject to Withholding from Public Disclosure Pursuant to 10 CFR 2.390 CONFIDENTIAL - excepted from public disclosure pursuant to Texas Government Code Section 552.110 (a)-(c)

WASTE CONTROL SPECIALISTS LLC Agreed Order 2015-0514-RAW-E Docket No. 070-7005 June 30, 2022 This portion of the application/request/amendment contains Sensitive/Confidential Information Subject to Withholding from Public Disclosure Pursuant to 10 CFR 2.390 and Texas Government Code Section 552.110 (a)-(c)

WASTE CONTROL SPECIALISTS LLC Agreed Order 2015-0514-RAW-E Docket No. 070-7005 June 30, 2022 APPENDIX 6.A Referenced Procedures Sensitive/Confidential Information Subject to Withholding from Public Disclosure Pursuant to 10 CFR 2.390 CONFIDENTIAL - excepted from public disclosure pursuant to Texas Government Code Section 552.110 (a)-(c)

WASTE CONTROL SPECIALISTS LLC Agreed Order 2015-0514-RAW-E Docket No. 070-7005 June 30, 2022 This portion of the application/request/amendment contains Sensitive/Confidential Information Subject to Withholding from Public Disclosure Pursuant to 10 CFR 2.390 and Texas Government Code Section 552.110 (a)-(c)}}