Donald E. Watkins
U.S. Department of Energy, Carlsbad Area Office
Carlsbad, NM

Michael S. Kearney
Roy F. Weston, Inc.
Carlsbad, NM

Sheila A. Lott
Advanced Sciences, Inc.
Carlsbad, NM

Thomas E. Bearden, P.E.
NFT, Inc.
Carlsbad, NM

The National Transuranic Program (NTP) is the Department of Energy's (DOE's) program for managing all transuranic (TRU) waste under DOE's purview. Much of this waste is eligible for disposal at the Waste Isolation Pilot Plant (WIPP); a portion is not. The NTP integrates TRU-waste system requirements so that all DOE TRU waste is effectively managed from generation to disposal, including characterization, treatment, and transportation. This paper addresses the major actions the NTP is taking to help ensure the timely delivery of waste to the WIPP as it approaches opening during the spring of 1998.

The DOE-owned TRU waste is currently stored at 10 major DOE sites and several small-quantity sites (SQSs); additional TRU waste will be generated during future operations and clean-up activities. Most of the waste is the result of nuclear weapons research, testing, and production, and is divided into two major categories: contact-handled (CH) and remote-handled (RH), depending on the external dose rate of the waste containers. TRU waste is also classified as being mixed or non-mixed. Mixed TRU waste contains hazardous materials regulated under the Resource Conservation and Recovery Act (RCRA). Examples of these hazardous materials are cleaning solvents and heavy metals. TRU waste that originated from defense sources and that meets the Waste Acceptance Criteria for the Waste Isolation Pilot Plan (WIPP-WAC) is eligible for disposal at the Waste Isolation Pilot Plant (WIPP), a deep geological repository located in southeastern New Mexico constructed specifically for the disposal of TRU waste.

The DOE Carlsbad Area Office (CAO) manages both the NTP and the WIPP. It is supported by three contractors: Westinghouse Waste Isolation Division, Sandia National Laboratories, and the CAO Technical Assistance Contractor (CTAC).

The DOE submitted the Compliance Certification Application (CCA) to the U.S. Environmental Protection Agency (EPA) on October 29, 1996. On October 23, 1997, the EPA announced that the CCA complies with applicable radioactive waste disposal regulations. The final EPA ruling on the CCA is expected in April or May 1998, and the WIPP may open 30 days later.

The CAO is actively certifying the three TRU-waste sites that will be the first to ship TRU waste to the WIPP. Los Alamos National Laboratory (LANL) received site certification in September 1997 for legacy debris TRU waste. Idaho National Engineering and Environmental Laboratory (INEEL) and the Rocky Flats Environmental Technology Site (RFETS) expect certification in early 1998. An aggressive audit schedule is being followed so that there will be time for these three sites to receive certification and transportation authority and have waste ready to ship to the WIPP by May 1998.

The National Transuranic Waste Management Plan (1) recommends a TRU waste management configuration that integrates site-specific waste management planning with the waste handling and disposal capabilities of WIPP. The plan provides an integrated TRU waste management system that complements and supports the Department of Energy-Environmental Management's (DOE-EM's) 10-year planning effort. The performance goals of the plan are to:

• Provide for TRU-waste site compliance with site-specific commitments, agreements, and orders
• Accelerate reduction of risk and mortgage by coordinating programs among sites
• Maximize disposal of TRU waste by the end of fiscal year (FY) 06
• Maximize the WIPP waste-handling and disposal efficiency

Disposal of CH-TRU waste will begin in FY98, when WIPP opens. Disposal of RH-TRU waste at WIPP will begin in FY03. Table I presents the estimated volumes of TRU waste by category at the major TRU-waste sites and small-quantity sites. Table II presents the current schedule for site certification and shipment of TRU waste. Table III presents a summary of planned waste disposal progress by FY06 and FY33.

Before a TRU-waste site begins shipping waste to WIPP, it receives waste certification authority and transportation authority from the CAO Manager after extensive reviews and audits verify that the site complies with all of WIPP's requirements. Each site is recertified annually.

TRU waste is certified by meeting the requirements of the WIPP-WAC (2) and its supporting documents, the Transuranic Waste Characterization Quality Assurance Program Plan (QAPP) (3) and the Transuranic Waste Characterization Sampling and Analysis Methods Manual (4). In order to ship TRU waste to the WIPP, sites also must meet the requirements of the TRUPACT-II Authorized Methods for Payload Control (TRAMPAC) (5), and site QA activities must conform to the CAO Quality Assurance Program Document (QAPD) (6). (The operative versions of some of these documents are available at the NTP Home Page at http://www.wipp.carlsbad.nm.us.)

To assist the TRU-waste sites with their site certification programs, the CAO developed the Generator Site Certification Guide (7). This guide describes the actions to be taken by the CAO and the TRU-waste sites to ensure that all NTP requirements are met before TRU waste is shipped to the WIPP. The guide contains references to those requirements documents that the TRU-waste sites must meet and against which they will be audited in order for the CAO to grant authority to certify and transport waste to the WIPP. The following documents prepared by the TRU-waste sites are required for site certification:

The TRU Waste Certification Plan, which documents how the site complies with each requirement of the WIPP WAC

The Certification Quality Assurance Plan, which documents how compliance with each quality requirement in the WIPP WAC is assessed by the site; this plan may be separate or included in the site's Certification Plan

The Waste Characterization Quality Assurance Project Plan (QAPjP), which explains in detail the procedures and methods that the site intends to use for waste characterization

The Site-Specific TRAMPAC, which describes in detail how the site complies with Appendix 1.3.7 of the TRUPACT-II Safety Analysis Report for Packaging (SARP) as reflected in the WIPP WAC

The Packaging Quality Assurance Plan, which describes the site's QA program for TRU waste packaging

The Sampling Plan, required by the QAPP, which supports the site's QAPjP and defines how waste containers are chosen for sampling on a waste stream basis.

A series of certification audits have been performed at TRU-waste sites (LANL, INEEL, and RFETS). Lessons learned so far include:

Early and regular contact between CAO and the sites is essential; much site effort can be wasted if it is not closely aligned with CAO direction.

Sites should consider submitting their certification documents to CAO early in their development for informal review. This will facilitate the formal review.

During pre-audit activities, CAO will review site procedures to determine if all CAO requirements have been addressed. This is called an "adequacy review" or "flow-down analysis" and is very labor intensive. It is during this phase that "disconnects" between the site TRU program and the affected site operations groups are found. Sites (especially the larger ones) should expect and plan for extensive internal coordination among affected groups.

Audits are delayed if, in CAO's judgment, the site is not ready and functioning. CAO requires a minimum of 30 days operational experience using revised procedures prior to conducting the audit.

The CAO and DOE Headquarters co-chair the TRU Waste Steering Committee, which is made up of representatives from all the major TRU-waste sites. The committee provides leadership, vision, and support in developing a strong, systematic approach to managing the NTP and integrates each site program into one national program. It identifies issues, shares lessons learned, and presents the status of activities at each site. The committee meets three times a year and has monthly conference calls.

The CAO Assistant Manager for National TRU Waste Operations is a member of the EM Waste Management Steering Committee. The Waste Management Steering Committee is used to set and refine policy, processes, and guidance to help ensure an integrated management program for all DOE waste. The committee acts as the interface between waste management and other EM organizations and is the senior coordinating and communication group for DOE waste management policy.

As the scheduled opening date for WIPP draws near (spring 1998), it has become evident that the WIPP RCRA Part B Permit (8) will not be approved by the State of New Mexico before WIPP opens. Consequently, NTP has shifted its emphasis toward the early certification of non-mixed TRU waste at the three lead sites. If a significant amount of non-mixed waste is certified and ready for disposal now, it can be shipped immediately upon WIPP's opening. Final certification and disposal of mixed TRU waste will be deferred until the WIPP RCRA Part B Permit is approved.

Interim guidance has been developed and distributed to assist the TRU-waste sites in establishing and demonstrating through "acceptable knowledge" (AK) documentation that only TRU waste generated by atomic energy defense activities is certified for disposal at the WIPP (9). It contains specific guidance on documenting the sources of waste streams to ensure that they were generated by defense activities and to ensure that they meet the definition of transuranic waste and are not high-level waste or spent nuclear fuel. The bases for this guidance include legislative requirements and the U.S. DOE General Counsel's interpretation of defense waste as it applies to the WIPP. The NTP also has the responsibility for federal non-defense TRU waste. Its final disposition will be addressed in the Comprehensive Disposal Recommendation.

The laws that apply to WIPP require that the waste disposed there be TRU waste that was generated by defense activities. There are, however, TRU wastes that were generated under commercial or civilian programs and non-defense programs or that don't meet the technical definition of TRU waste; they are not currently eligible for disposal at WIPP. Many of these wastes exist at TRU-waste sites and their volumes and characteristics are collected in response to the TRU waste data calls. No disposal system has yet been planned for such wastes; however, NTP continues to keep track of these wastes and will recommend strategies for their management and disposal.

The Transuranic Waste Baseline Inventory Report (10) summarizes the DOE TRU waste inventory, projections, and characteristics. The report provided the data used in the performance assessment calculations that support the CCA. It includes the total DOE TRU waste inventory including non-defense, commercial, polychlorinated biphenyl contaminated, "unknowns," and buried TRU waste. The latest revision was issued in June 1996.

The NTP investigated current mobile technologies that can be used to characterize and certify TRU waste. Mobile systems which can be quickly set up at TRU-waste sites are seen as necessary to meet sites' characterization and handling requirements for small-quantity sites without facilities and for larger sites while permanent facilities are being constructed or augmented. The NTP published its findings in the Mobile Systems Capabilities Plan (MSCP) (11). The CAO is proceeding to approve two vendor teams that were selected to participate under a cooperative agreement.

More than 120 metric tons of plutonium residues have been identified as potential TRU waste to be disposed of at WIPP. Residues are plutonium-bearing solids with plutonium concentrations below 50 weight percent. Ninety-five percent of these residues are stored at Hanford, LANL, RFETS, and Savannah River Site (SRS). In 1992, the CAO began working with RFETS on the Residues Efficiencies Working Group to evaluate options for safe, cost-effective disposal of residues at the WIPP if they are declared waste. The group developed the pipe overpack container concept, which has been tested and approved for use in the TRUPACT-II by the U. S. Nuclear Regulatory Commission (NRC). The leak-tight pipe container and impact limiter is placed inside of the TRUPACT-II containment vessel, providing criticality safety, shielding, and immobilization of high-activity residues in the pipe.

The NTP continues to determine the best possible routes to transport waste to the WIPP. A recent modification to the routing scheme reduced any potential exposure risk to approximately four million people. This modification removed about 1,400 road miles and will save the DOE about $54 million over the life of the WIPP. The DOE continues to optimize the transportation corridors: the results are an important feature of the NTWMP.

A new shipping container, the HALFPACK, is being developed specifically for shipping heavier-than-average drums of CH-TRU waste. This new container is a shorter and lighter version of the TRUPACT-II container. It can carry seven 55-gallon drums (vs. 14 55-gallon drums in TRUPACT-IIs), one standard waste box (SWB) (vs. two SWBs in TRUPACT-IIs), or four 85-gallon drums, which are sometimes used to overpack 55-gallon drums of questionable integrity. Because of its lighter weight, the HALFPACK is more efficient for the transport of heavy drums; its use will reduce the total number of shipments of CH-TRU waste to the WIPP over its lifetime by approximately 2,000, resulting in a savings of more than $20 million. Three HALFPACKs are able to transport 21 heavy drums in one truck shipment, whereas the heavier TRUPACT-II allows transport of only 14 heavy drums.

Two prototypes of the HALFPACK have been fabricated and one was tested to gather engineering information which will be used in the final design. Following this testing, certification test units will be fabricated and tested in accordance with the NRC's requirements for certifying Type B shipping containers. A SARP, required for certification, will be prepared and submitted to the NRC for approval.

As WIPP prepares to open in 1998, the NTP is poised to begin shipping TRU waste immediately from the three major TRU waste sites: INEEL, LANL, and RFETS. Initially, non-mixed TRU waste will be accepted until WIPP's RCRA permit is issued, allowing mixed waste to be accepted. The NTP is ensuring that additional sites are slated for full certification in FY98-02, followed by RH-TRU waste certification and, in time, a Comprehensive Disposal Recommendation for all TRU waste in the federal inventory.

1. U. S. DEPARTMENT OF ENERGY, "The National Transuranic Waste Management Plan," DOE/NTP-96-1204, Revision 1, Carlsbad Area Office (December 1997).
2. U. S. DEPARTMENT OF ENERGY, "Waste Acceptance Criteria for the Waste Isolation Pilot Plant (WAC)," DOE/WIPP-069, Waste Isolation Pilot Plant (December 1996).
3. U. S. DEPARTMENT OF ENERGY, "Transuranic (TRU) Waste Characterization Quality Assurance Program Plan (QAPP)," CAO-94-1010, Revision 1, Carlsbad Area Office (in press).
4. U. S. DEPARTMENT OF ENERGY, "Transuranic Waste Characterization Sampling and Analysis Methods Manual," DOE/WIPP-91-043, Revision 2, Carlsbad Area Office (November 1997).
5. U. S. NUCLEAR REGULATORY COMMISSION, "TRUPACT-II Safety Analysis Report for Packaging (SARP)," Appendix 1.3.7 TRUPACT-II Authorized Methods For Payload Control (TRAMPAC), Revision 16. NRC Docket No. 71-9218, Office of Regulatory Procedures (February 1997).
6. U. S. DEPARTMENT OF ENERGY, "Quality Assurance Program Document (QAPD)," CAO-94-1012, Revision 1, Carlsbad Area Office (April 1996).
7. U. S. DEPARTMENT OF ENERGY, "Generator Site Certification Guide," DOE/CAO-95-2119, Revision 1, Carlsbad Area Office (August 1997).
8. U. S. DEPARTMENT OF ENERGY, "Resource Conservation and Recovery Act Part B Permit Application," DOE/WIPP-91-005, Revision 6.3, Carlsbad Area Office (August 1997).
9. U. S. DEPARTMENT OF ENERGY, "Carlsbad Area Office Interim Guidance on Ensuring that Waste Qualifies for Disposal at the Waste Isolation Pilot Plant," CAO:NTP:MRB 97-0238 UFC 5822, Carlsbad Area Office (February 1997).
10. U. S. DEPARTMENT OF ENERGY, "Transuranic Waste Baseline Inventory Report," DOE/CAO-95-1121, Revision 3, Carlsbad Area Office (June 1996).
11. U. S. DEPARTMENT OF ENERGY, "Mobile Systems Capabilities Plan," DOE/NTP-96-1202, Revision 0, Carlsbad Area Office (September 1996).

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