Wesley G. Estill and David L. Langley
Battelle Pantex

In March 1997, Pantex Plant shipped three drums of transuranic (TRU) waste, the only TRU waste in the state of Texas, to Los Alamos National Laboratory (LANL), at Los Alamos, New Mexico for interim storage. This shipment was part of a Department of Energy (DOE) initiative to consolidate waste from small quantity generator sites to the larger waste generator sites that are approved to ship to the Waste Isolation Pilot Plant.

The unprecedented movement of the containerized TRU waste to LANL was the result of a consolidated joint effort between DOE Albuquerque Operations Office, DOE Amarillo Area Office, LANL, the state of New Mexico's Governor's Office, Mason & Hanger Corporation Pantex Plant personnel, and the Battelle Pantex Radiation Safety and Waste Management Departments.

Because the TRU waste shipment was conducted across state lines, the semitruck and trailer used to haul the Nuclear Fuel Services Type B container, the Super Tiger, were subjected to federal interstate transportation regulations. To safeguard shipment accountability, the transportation contractor was required to have real-time location tracking equipment on board. The tracking system known as TRANSCOM is a unique satellite tracking system used to track TRU waste shipments throughout the United States.

The transfer of the TRU waste to the control of LANL resulted in a substantial savings in storage and surveillance costs to Pantex Plant located near Amarillo, TX.

The DOE Complex-Wide Integration Effort (CWIE) recommended consolidating transuranic (TRU) waste from small quantity sites to large quantity sites to reduce complex costs and risks. Due to this initiative and a desire to remove the TRU waste from the state of Texas, three drums of TRU waste were shipped from the Pantex Plant (Pantex) located near Amarillo, Texas, to Los Alamos National Laboratory (LANL), Los Alamos, New Mexico, on March 10, 1997.

Pantex does not generate TRU waste during routine operations. However, during the course of routine dismantlement operations in 1992, a sealed weapon component containing nuclear material cracked and released moderate quantities of plutonium, thereby leading to the generation of three drums of non-mixed TRU waste. The total volume of the waste was 0.624 cubic meters, and it was staged at Pantex pending approval to ship to a DOE-designated interim storage facility.

The waste was stored in 17C galvanized metal drums with lids fitted with filter vents. The drums were labeled according to United States Department of Transportation (DOT) regulation Title 49 Code of Federal Regulations (CFR) and labeled with bar codes as required by WIPP-DOE-069, "TRU Waste Acceptance Criteria for the Waste Isolation Pilot Plant."

The waste did not contain liquids nor any material that could contribute to corrosion. As a result of a controlled oxidation of the hydride, no pyrophoric concerns existed with the waste. The waste was primarily process waste, which consisted of contaminated personal protective equipment, plastic, paper tissues, cotton swabs, gloves, tape, cardboard, tools and clamps. The contents of each drum were enclosed in two internal 5-mil (or heavier) transparent plastic containment barriers or liners. The individual TRU waste packages within the two liners were triple-bagged for a total of five layers of containment.

Radiological characterization was based on analytical gamma spectroscopy, using the Canberra Waste Analysis System. The concentration of radionuclides in the drums was: 188.5, 202.8, and 2794.5 nCi/gm from isotopes Pu238, 239, 240 and Am241. (Note: Pu241 was included only in the calculations for shipping purposes but not considered in the TRU waste calculations because of a half life less than 20 years.) Therefore, the use of a Type B shipping container would be required by Title 49 CFR Part 173.435 since the TRU waste had activity above the listed A2 value in the table.

Pantex was tasked to find an interim storage site for the TRU waste, and Hanford was selected. Pantex personnel worked closely with Hanford personnel to contact all the appropriate people for this shipment. Pantex fulfilled the Hanford Waste Acceptance Criteria as required. Everyone was in agreement to ship the waste except the state of Washington. After further negotiations, it was determined Hanford could not accept the waste. This turn of events was only the first in a succession of roadblocks. Pantex did not stop the search, even though it was thwarted after eighteen months of preparation.

In 1994 Pantex began vigorously searching again for an interim storage facility. The Nevada Test Site (NTS) was at the top of the list for interim sites due to its past history of accepting TRU waste. Pantex contacted the DOE Nevada Operations Office in the summer of 1994 but encountered yet another roadblock. This time it was an agreement between the DOE and the State of Nevada. The agreement did not allow out of state shipments of TRU waste for interim storage into Nevada. After Pantex was informed of this decision, the search was directed to the other sites on the list.

Information gathered from the sites on the interim storage facility list led Pantex personnel to the list of DOE sites approved to ship TRU waste to the Waste Isolation Pilot Plant (WIPP) in Carlsbad, New Mexico. All listed sites were contacted. For various reasons, these sites would not agree to take the waste. The reasons varied and included "the state won't allow us" to, "the facility is shutting down, and we are searching for a site for our own TRU waste." The most common reason was "We are waiting for WIPP to open, and when that happens we can accept your TRU waste." DOE Rocky Flats personnel offered the most creative solution. They jokingly suggested to work out a trade, three of Rocky's pits for the three drums of Pantex TRU waste.

Pantex canvassed these sites quarterly for an update. The status was unchanged for approximately one year. Pantex personnel started networking with the National TRU Waste Steering Committee by attending its quarterly meetings. Finally, in December 1995, at the National TRU Waste Update meeting, there was a breakthrough. Representatives from LANL suggested Pantex ship its TRU waste to LANL. The prospect looked promising because Pantex and LANL were both under the same field office, the DOE Albuquerque Operation Office (AL). The position of the State of New Mexico on acceptance of out-of-state waste was uncertain even though there were no legal restrictions preventing waste from entering the state.

After several months of discussion, the principle parties came to an agreement. LANL was willing to take the Pantex TRU waste for interim storage, the DOE field office was supportive, and New Mexico did not pose any major roadblocks.

Now that the site was selected, Pantex, LANL, and DOE-AL were ready. The only remaining roadblock to prevent this shipment was finding a DOT, Nuclear Regulatory Commission (NRC)-approved shipping container.

Through networking with the TRU waste sites, Pantex determined to start with the experts, the DOE National TRU Program Office (NTPO) in Carlsbad, New Mexico. The DOE Carlsbad Area Office (CAO) suggested Pantex contact the WIPP transportation office, who suggested that Pantex use the Transuranic Package Transporter-II (TRUPACT II) shipping container. The only problem with this suggestion, was Pantex did not have the necessary TRUPACT II loading equipment or facility. Westinghouse, the WIPP Management and Operations contractor, had developed a mobile TRUPACT II loading trailer. Pantex would need to furnish an overhead crane and a limited amount of personnel. Westinghouse would provide the additional equipment and support to load the TRUPACT II. In October 1996, Pantex personnel observed a demonstration of the TRUPACT II Mobile Loading Unit (MLU) at the WIPP site. The equipment worked flawlessly. Pantex personnel were told one of the limitations to performing this operation outside was the wind velocity. The wind can be a major obstacle in the Texas Panhandle, where average daily wind speed is over 13 mph. Pantex personnel searched for a facility with an overhead crane large enough to accommodate the MLU and the truck carrying the TRUPACT II. The Pantex Vehicle Maintenance Facility (VMF) could house both trucks and had an overhead crane that met the necessary weight requirements. A ship date of November 15, 1996, had been set, everything was on schedule. With less than a week before the shipment, Pantex received a call from DOE-AL who informed us that DOE-CAO would not allow Pantex to use the TRUPACT-II shipping container. Due to the political climate in and around Santa Fe, the use of the TRUPACT II could potentially delay the opening of WIPP.

Next, Pantex issued a Request for Proposal and a Statement of Work for the shipping container. Nuclear Fuel Services Inc. in Erwin, Tennessee, proposed using their Model 6400 Super Tiger Protective Overpack (a Type B container) that could accommodate sixteen 55-gallon drums and a 200-gram fissile material limit, which was more than enough for the shipment. In February 1997, the NRC Certificate of Compliance for the Super Tiger was reviewed by DOE-AL, DOE-CAO, Nuclear Fuel Services, and Pantex representatives. After much discussion, it was agreed that the Super Tiger was acceptable and would be used for shipping the TRU waste to LANL.

In October 1996, the drums were isolated and opened at Pantex. A LANL waste management representative was present to participate in the waste certification process. Swipes were taken of the inner lid and outer surfaces of the outer plastic liner. No contamination was detected. The fifth or outer plastic liner was cut open to allow the drums to meet the hydrogen generation potential criteria established for the LANL waste (TRUCON code LA 116A) type shipping category lll.1A4 (from TRUPACT-II Content Codes, WIPP/DOE 89-004, Rev. 10, 12/96) that allows for a maximum of four plastic bags of containment.

All characterization, packaging, and labeling requirements from the TRU Waste Acceptance Criteria (WAC) for the WIPP and the LANL WAC were met. Waste Profile forms were completed and forwarded to LANL before the shipment. The TRUCON code that was agreed upon for the Pantex TRU waste was LA 116A (primarily combustible solids), an approved WIPP code to be used by LANL for future shipments to WIPP.

Since this shipment was not regulated by the Resource Conservation and Recovery Act, it was not necessary to notify the Texas Natural Resource Conservation Commission. In early March, 1997, however, DOE-AL notified the New Mexico Radioactive Waste Task Force (NMRWTF) Coordinator and the City Manager for the City of Santa Fe. The NMRWTF supplied a list of phone numbers for emergency notification in the event of an incident involving the shipment. NMRWTF also informed Pantex of an inspection by the New Mexico Department of Transportation (NMDT) that would take place at the New Mexico Port of Entry located at San Jon, New Mexico. NMDT informed Pantex that the inspection would be scrutinized against WIPP shipment requirements (that is, the Commercial Vehicle Safety Alliance Manual).

Notification to the NM State Police Patrol was not required because the shipment was not a highway route controlled shipment per DOT or a classified shipment per DOE. DOE-AL also notified DOE-CAO and DOE-HQ about the shipment and the date. DOE-AL and DOE-CAO discussed the consolidation effort with the Western Governors Association. DOE-AL orally notified the NM Environmental Division of the intent to consolidate the three drums at LANL.

The transporter of the shipment, A.J. Mettler Hauling and Rigging, Inc., used the Transportation Tracking and Communications (TRANSCOM) system to track the shipment while in route. It consists of satellite communications and navigation systems and a computer database network. The TRANSCOM system contained information such as found on the Bill of Lading. The NM Department of Public Safety accessed the information during the shipment.

On the morning of March 10, 1997, a pre-job briefing was held with personnel from DOE-AAO, Pantex, and Nuclear Fuel Services. This briefing was held to familiarize Pantex personnel with the specifics for loading the SuperTiger. Upon conclusion of the briefing, the Super Tiger was backed into a standard type loading dock for loading. After loading and securing the Nuclear Fuel Services Super Tiger container, the truck was inspected at Pantex's VMF. Minor welding was required on the trailer, which pushed the departure time to 2000 hours on the evening of March 10, 1997. Both Pantex and NFS representatives accompanied the shipment to Los Alamos. At the New Mexico Port of Entry, the trailer was inspected by NMDT officials. The shipment was back on the road after the inspection. The convoy stayed on Interstate 40 until reaching Clines Corners, New Mexico, then routed north through Santa Fe to LANL, arriving without incident in the early morning hours of March 11, 1997. After a short meeting with representatives from DOE Los Alamos Area Office, LANL, Pantex, and NFS to discuss the unloading procedure, the Super Tiger was unloaded at TA-54, Area G without incident. The three drums were placed in a large TRU waste storage facility.

A post shipment meeting was conducted with the NMRWTF Coordinator on March 12, 1997, in Santa Fe. He was provided details of the safe and successful shipment. He expressed his appreciation for a job well done.

Based on the information from the DOE-AL Memorandum entitled "Intersite Transuranic Waste Shipment Notification" sent to EM-30 on February 20, 1997, the following mortgage and risk reduction options were considered at Pantex:

Option #1: Continue to store and manage the TRU waste at Pantex with the intent of shipping directly from Pantex to WIPP (assuming Pantex could ship to WIPP in the November FY00 time frame). The estimated total cost for this option was $1,081,300, which would include costs associated with Pantex becoming WIPP certified.

Option #2: Continue to store and manage TRU waste at Pantex with the intent of consolidating Pantex waste at LANL using the TRUPACT-II to transport the waste. The estimated total cost for this option was $150,000 based on Pantex estimated waste management costs of $40,000 per year projected through November FY00.

Option #3: Consolidate the Pantex TRU waste at LANL for interim storage using a commercial vendor for shipment on March 10, 1997. The estimated cost was approximately $16, 800.

Based on the DOE cost savings resulting in immediate mortgage and risk reduction at Pantex, the DOE-AL recommendation was to pursue Option #3 utilizing the most cost effective commercial vendor.

Therefore, it is estimated that approximately $133,200 was saved by performing Option #3 and consolidating the Pantex TRU waste at LANL for interim storage using a commercial carrier for the shipment. This number is based on the proposed costs that would have been incurred if option #2 had been adopted. Over one million dollars was saved relative to the adoption of Option #1.

The Pantex Plant complied with the CWIE recommendation to consolidate TRU waste from a small quantity site to a large quantity site in order to reduce costs and risks. After repeated attempts to locate and acquire approval from an interim storage site, Pantex was allowed to ship its 3 drums of TRU waste to LANL. After repeated attempts to find a transporter with a Type B container, NFS was contracted to ship the TRU waste on March 10, 1997. A savings of approximately $133,200 was realized by shipping the TRU waste in March of 1997 by commercial carrier, NFS, Inc.

1. Title 49 CFR Parts 172-173, Transportation, current revision.
2. WIPP-DOE-069, "Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant," Current revision.
3. WIPP/DOE 89-004, Rev. 10, 12/96, TRUPACT-II Content Codes.
4. Commercial Vehicle Safety Alliance Manual, May 1, 1996, Department of Energy, Agreement No. DE-FC01-94 RW00295.
5. DOE-AL Memorandum, 2-20-97, "Intersite Transuranic Waste Shipment Notification."

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