Scott A. Anderson, Tim G. Hedahl
Kaiser-Hill Company

Gary L. Potter, Leslie T. Hatch
Savant Enterprises

The mission change at the Rocky Flats Environmental Technology Site from nuclear weapons production to closure and environmental cleanup has made formerly serviceable buildings and other structures surplus and no longer essential to the nation’s national security interests.

As a result, large quantities of contaminated and uncontaminated materials currently present at the site need to be brought under direct management control in terms of their final dispositioning. Such control can be accomplished by: (1) dispositioning the material as containerized or bulk wastes or (2) leaving the material in place based on a determination that it does not constitute an appreciable risk to the public and that disturbing and/or redistribution of the material poses a greater risk than leaving it alone.

It is recognized that contaminants in future waste generation are currently present at the site in equipment, building structures, surrounding soils, and other assets. Rocky Flats has developed a waste management strategy in which deliberate decisions are made as to the final disposition of the current waste inventory and wastes yet to be generated. This decision-making process, done in concert with stakeholders, establishes a mechanism for evaluating cleanup standards indexed to risk-based criteria to determine which materials can safely be left in place and which need to be removed and managed. For those materials brought under direct management control, the strategy details specific initiatives for waste generation, disposal, characterization, treatment and storage such that closure activities are accomplished pursuant to schedules specified in the Accelerated Closure Plan.

The Rocky Flats Environmental Technology Site (Rocky Flats or Site) has been forced to completely restructure its waste handling practices to meet the changing demands imposed by the new Site Cleanup Mission. As a result, the Site developed a Waste Management Strategy to effectively address the new challenges faced by a former nuclear weapons component manufacturing facility undergoing closure.

The primary objective of the Site’s Waste Management Strategy is to disposition wastes in a safe, compliant, and cost-effective manner. Unlike past strategies that focused primarily on storage, this new strategy eliminates waste inventories from active, labor-intensive management through a combination of actions including offsite disposal at federal and commercial repositories; treatment on site or at offsite waste destruction, immobilization, and/or recycle and reuse facilities; and onsite placement. Final dispositioning for some wastes cannot be accomplished immediately because approved repositories are not available, existing wastes are encumbered by incomplete characterization and/or do not conform to waste acceptance criteria of disposal sites. In addition, much of the waste has yet to be generated. As a result, the Site must develop and implement a Waste Management Strategy for interim waste management activities.

The central theme of the waste management strategy is to dispose of as much waste as possible in offsite facilities as expeditiously and economically advantageous as possible. This will be accomplished within the constraints of other site risk reduction activities and in accordance with sitewide funding priorities. Other waste handling activities will be done as appropriate to maintain safety and compliance requirements at minimal cost. The data used to develop the baseline strategy are shown in Table I below.

The Waste Management Strategy addresses all waste forms and functional elements. The waste forms include:

(1) Radiological Wastes

• Low-Level Waste (LLW)
• Low-Level Mixed Wastes (LLM)
• Transuranic Waste (TRU)
• Transuranic Mixed Waste (TRM)

(2) Hazardous (non-radioactive) Wastes

• Resource Conservation and Recovery Act Regulated
• Toxic Substances Control Act Regulated
• Medical

(3) Sanitary Wastes

(4) Uncontaminated Wastes

• Debris
• Trash

(5) Process Liquid Wastes

Waste management functional areas include characterization, treatment, storage, transport, and disposal. Hazardous wastes including non-radioactive wastes regulated by the Toxic Substances Control Act (TSCA) will continue to be shipped to offsite commercial treatment and recycle/reuse facilities. Solid sanitary wastes will be disposed in a combination of onsite and offsite commercial landfills and will ultimately be sent solely to an offsite commercial facility beginning in 1999. Liquid sanitary wastes will be treated in the Site’s sewage treatment plant. Uncontaminated debris will be sent offsite to commercial disposal sites or used onsite as clean fill material in support of environmental restoration activities. Process wastewater will continue to be treated in onsite existing facilities with significant effort devoted to the upgrade and/or replacement of aging system components.

The change in focus from weapons production (hence, waste storage) to accelerated site closure has forced major changes in the approaches used in managing wastes. These are summarized below:

Generation Strategy - The waste generation strategy emphasizes effective generation management and inventory management at the point of generation in order to eliminate downstream deficiencies, minimize rework, and facilitate disposal. The focus of the strategy is to minimize generation of all waste types and reduce the inventory of those wastes that are generated.

Disposal Strategy - The strategy is designed to maintain existing disposal avenues and to foster new growth in emerging disposal areas. It also maintains a shippable inventory in excess of shipping capacity by focusing on pre-certification activities. The overriding objective is to maximize offsite disposal.

Characterization Strategy - The characterization strategy provides for characterization of the waste in terms of its ultimate disposal destination. This eliminates redundancy and reduces costs, identifies characterization requirements and data quality objectives at the point of generation to minimize future downstream sampling and analysis demands.

Treatment Strategy - The treatment strategy utilizes offsite and temporary/mobile onsite treatment to ensure wastes are acceptable for disposal. This is accomplished by expanding the use of treatment capacities within the Department of Energy (DOE) complex and through use of treatment technologies developed in the commercial sector.

Storage Strategy - The strategy is designed to store waste only to the extent necessary due to treatment/disposal constraints or to accumulate sufficient quantities to facilitate cost-effective treatment/disposal. However, excess storage capacity will still be maintained to accommodate perturbations in availability of offsite disposal capacity as well as to provide contingent storage to ensure Site closure activities can proceed uninterrupted.

The Waste Management Strategy is designed to effectively and economically disposition wastes associated with Site cleanup. It offers a safe, compliant, least-cost solution to waste handling. A number of issues potentially affect the successful implementation of the strategy. To address the issues facing the Site, the Waste Management Program is working to develop and implement contingencies and innovations to ensure that wastes are properly managed and that Site cleanup progresses on schedule.

In general, impact management decisions are based on a hierarchy of Site priorities:

• Risk Reduction
• Mortgage Reduction
• Sustainability
• Remediation and Contamination Control
• Compliance Enhancement
• Performance Improvement
• Overhead Control

In an ideal world, it would be possible to attack each item in order of importance, eliminate it as a priority item, and move to the next in line. However, practical limitations require an integrated approach to resolution of these priorities. That is, trade-offs are continually made to apply the proper resources to the most pressing needs, taking into account funding allocations, physical limitations, stakeholder concerns, and other factors that can influence the prioritization system.

Waste management decisions are similarly based on a hierarchy of priorities consistent with the Site priorities including:

• Maximize Waste Disposal (risk and mortgage reduction)
• Maximize Offsite Waste Treatment for Disposal (risk and mortgage reduction), and
• Minimize Long-Term Waste Storage (mortgage reduction)
• Optimize Resource Requirements, i.e., operate at lowest cost while maintaining core competencies essential to effectively performing waste handling functions (sustainability)

As with Site priorities, the actual implementation of the prioritization system involves consideration of certain aspects of all priority items with regard to particular constraints such as funding, physical limitations, resource availability, uncertainties, etc.

The term "impact management" as used for strategic purposes, addresses programmatic risk and not health risk. From a strategic point of view, impact management is undertaken to identify possible risk areas, evaluate the cause and effect of these areas, identify the impacts of the cause/effect relationship, and implement contingencies to minimize the probability of occurrence and consequence. Within the Waste Management program, there are six areas that have the potential to affect the overall success of the strategy. These include:

• Programmatic Risk
• Generation Risk
• Characterization Risk
• Disposal Risk
• Treatment Risk
• Storage Risk

Figure 1 provides a graphic depiction of the relationships between these areas.

In general, waste management priorities are indexed to health and compliance liability risks for the specific waste forms. For example, should funding shortfalls affect radioactive waste disposal, preference would be given to shipping TRU/TRM first, followed by LLM, then by LLW. Non-radioactive wastes are disposed of during the year of generation because it is cost effective to do so within the funding constraints of the annual budgeting process. Similarly, radioactive liquid wastes would be given preference over solids to minimize health risks, spill potential, and compliance liabilities.

In addition to health and compliance liabilities, waste management priorities are also indexed to short term and long term (i.e., life-cycle) impacts. In order to effectively implement the Waste Management Strategy, decision making must take into account these differences. For example, a relatively small decrease in funding in a single year (e.g., 10%) may result in a significant increase in life-cycle cost. Thus, while the immediate reduction may drive the strategy in the short term, it does not necessarily result in the best overall implementation of an integrated Waste Management Strategy in the long term. Decisions to modify specific attributes of the strategy are performed based on previous year accomplishments and as annual funding allocations are authorized.

For each risk category below, a list of strategic options is presented in order of importance and impact. The list of options should be viewed as a "menu" in which items can be fully or partially implemented, singly or in combination, as resources, Site priorities, and other factors dictate. Each of the risk categories is addressed individually below. A generalized decision flowchart for determining possible outcomes following evaluation of each of the risk areas is given in Figure 2.

This category is designed to capture the overarching issues with the potential to impact the other five functional categories. The most significant contributor to programmatic risk is funding. In addition to the direct impacts of funding on the overall strategy, there are concurrent cost implications associated with each of the elements below. For each element that results in an increase in the length of time for closure, the cost of closure increases. As the cost of closure increases, the potential for budget allocations to cover the increased costs typically decreases, further lengthening the schedule required for closure.

Strategic Options:

(1) Revenue generation/cost reduction - implement actions that minimize capital investment and streamlines or improves efficiency of existing operations such that the functions can be performed at less cost. This deals primarily with administrative and procedural actions associated with waste characterization, packaging, load preparation, training, and quality control aspects of Waste Management. However, dramatic changes in operating approaches related to disposal, treatment and storage are also appropriate.

(2) Establish "unit cost" basis for all Waste Management elements to allow for effective options analysis and decision making.

Generation risk is affected by two primary items: (1) projected volumes may not reflect actual volumes at the time of generation (impacts treatment, storage, and disposal), and (2) modifications to the cleanup standards established for soil cleanup could significantly alter the volumes of remediation waste actually generated.

Strategic Options:

Characterization risk is affected by five items: (1) representative sampling of heterogeneous waste matrices; (2) reliability of process knowledge data; (3) analytical capability and capacity; (4) capacity to perform non-destructive characterization (including real-time radiography and non-destructive assay); and (5) ability to recharacterize existing legacy inventory.

Strategic Options:

(1) Enhance onsite capability for non-destructive assay and characterization.

(2) Solicit commercial/mobile capability.

(3) Characterize and pre-certify sufficient standing inventory (i.e., in excess of current shipping capacity) such that waste disposal can continue uninterrupted and at cost-effective rates.

Disposal risk is affected by five primary items: (1) availability of offsite commercial/DOE capacity for LLW/LLM; (2) capability of commercial facilities to accept waste containing radioactivity concentrations up to 100 nCi/g; (3) commencement of operations at the Waste Isolation Pilot Plant (WIPP) for TRU/TRM disposal; (4) availability of vehicles for transportation to the WIPP; and (5) physical ability to stage, load, and ship all waste types from Rocky Flats.

Strategic Options:

(1) Encourage development of new commercial disposal capabilities for LLW/LLM.

(2) Develop alternate transportation systems primarily focused on rail shipment of LLW/LLM.

(3) Seek temporary offsite storage.

(4) Prolong interim onsite storage.

Treatment risk is affected by three primary items: (1) availability of offsite commercial/DOE treatment capacity for LLM; (2) availability of offsite capacity for TRU/TRM; and (3) availability of transport system(s) for shipment of TRU/TRM offsite for treatment.

Strategic Options:

(1) Complete new construction for aging systems, e.g., Waste Water and Sludge Treatment system.

(2) Obtain contractual and/or other cooperative arrangements with offsite commercial/DOE treatment facilities for treatment of LLM.

(3) Expand use of existing onsite small scale treatment units.

(4) Obtain contractual commitments from commercial firms for onsite use of temporary, transportable treatment units.

(5) Develop alternate transport systems for shipment of TRU/TRM offsite for treatment.

(6) Seek exemptions where warranted in accordance with risk-based criteria.

Storage risk is affected by three items: (1) ability to construct and operate new, low-cost facilities for interim storage, (2) offsite shipping/disposal capacity, and (3) waste generation rates.

Strategic Options:

(1) Consolidate wastes in single purpose waste management facilities located outside the Protected Area.

(2) Re-evaluate the safety analyses associated with "gram loading" for radionuclides in waste storage facilities.

(3) Construction of new interim storage facilities for contingency.

(4) Retrofit of existing facilities.

The Waste Management Strategy is designed to meet the expectations of the Department of Energy, regulatory agencies, and other stakeholders by managing wastes in a safe, compliant, and cost-effective manner. Specifically, it is designed to effectively and economically manage the disposal, treatment, and storage of all wastes associated with Site cleanup. This will be accomplished by controlling generation of difficult to manage waste forms; maximizing offsite disposal through accelerated shipping and through improved characterization and treatment; and by maintaining sufficient onsite storage capability to effectively manage on-hand waste inventories until disposal avenues become available and sufficient quantities are ready for cost-effective transport. The effective execution of the Waste Management Strategy will enable Rocky Flats to successfully accomplish the objectives of the Site Closure Plan.

Significant progress has been made in the implementation of the new Waste Management Strategy, and progress will continue throughout completion of the Site closure process. The progress, including the change in focus from past to present/future is highlighted in Table II. Historically, storage was the accepted practice due to budget determinations being made on an annual basis. Storage was the most economical alternative in light of the expectation of a continuing production mission. With emphasis now on site closure and the life-cycle cost approach to budgeting and cost analysis, expedited disposal is now the desired approach. This transition is further described in Figure 3.

This transition to a disposal strategy has been slow to implement because of: (1) limited number of offsite disposal options, (2) stored legacy waste does not conform to available disposal site acceptance criteria, (3) offsite disposal activities are still vulnerable to unanticipated budget reductions, and (4) the need for cultural changes.

This is just one example of how contract reform, hence strategy realignment, has resulted in incentive to perform closure related work elements rather than incentivizing asset preservation and longevity at Rocky Flats.

This strategic approach may be applicable to other sites, especially those undergoing or scheduled to undergo full closure because it clarifies the relationships and degree of stakeholder interaction in the areas of regulatory negotiation, clean up standards, economic redevelopment and asset reutilization. Such clarification improves the decision making construct relative to categorizing wastes and developing the means for its final dispositioning.

The disposal strategy has gained significant support based on the successes of the past year. The new Waste Management Strategy with its emphasis on reducing onsite inventories will ultimately enable successful accelerated site closure at the least possible cost.

BACK