4.13 WASTE MANAGEMENT
4.13.1 Affected Environment
This section covers the ongoing waste management practices relating to generation, storage, treatment, and disposal of waste at Pantex Plant. It includes an overview of the regulatory framework and provides a summary of historic, current, and projected waste generation and waste management practices, including the quantities of wastes generated and managed under specified activities. Waste at Pantex Plant is primarily generated from ongoing assembly and dismantlement operations of nuclear weapons and high explosive(s) (high explosive(s) (HE)HE) production. Waste is also generated from support operations at Pantex Plant, such as medical services, vehicle maintenance activities, general office work, construction activities, environmental monitoring, laboratory activities, and environmental restoration (environmental restoration (ER)ER) activities.
4.13.1.1 Existing Waste Management Practices
Regulatory FrameworkThe Pantex Plant waste management program operates under a number of Federal and State regulations and permits obtained under these regulations that are primarily under the authority of the Environmental Protection Agency (EPA) and Texas Natural Resource Conservation Commission (TNRCC)TNRCC. Details on these laws and regulations are provided in chapter 6.0, Environmental Compliance Requirements for Implementing the Proposed Action and the Alternatives.
Regulatory agencies charged with enforcing regulations and statutes use the permit process as a primary tool. Table 4.13.1.11 lists Pantex Plant permits, the registration numbers, the issuing agency, the effective date, and the expiration date for each permit.
Pantex Plant is a large-quantity Resource Conservation and Recovery Act (RCRA) hazardous waste generator, an industrial solid waste generator, and a nonhazardous nonradioactive waste disposal facility. Pantex Plant operates under a RCRA Part B Permit as a hazardous waste treatment and storage facility (TNRCC 1996). Table 4.13.1.12 presents current waste management facilities.
The Federal Facility Compliance Act of 1992 (FFCA) includes provisions for mixed waste compliance with RCRA and required DOE to have approved, site-specific low-level mixed waste treatment plans in place by October 1995. A draft Proposed Site Treatment Plan was submitted to TNRCC in March 1995 for its approval. The Final Site Treatment PlanCompliance Plan was approved by TNRCC in September 1995 and an Agreed Order was issued October 2, 1995 (DOE 1995x).
The purposes of this Agreed Order and approved Site Treatment Plan-Compliance Plan include: fulfilling the requirements of FFCA; establishing regulatory milestones requiring DOE to develop treatment capacities and technologies and treat, ship to commercial treatment facilities, or otherwise meet RCRA land disposal restrictions (LDR) for all current inventory and projected inventories of all covered LDR mixed wastes; and allowing storage of current and projected LDR mixed wastes at Pantex Plant during the implementation and term of this Compliance Plan and Agreed Order (Pantex 1996f).
Table 4.13.1.1-1.--Permits Issued to Pantex Plant (.pdf)
Table 4.13.1.1-2.--Solid Waste Management Facilities, 1996 (.pdf)
In the March 1996 version of the Pantex Plant EIS, the proposed construction of the Hazardous Waste Treatment and Processing Facility (HWTPF) was considered necessary for enhanced efficiency and safety and meeting regulatory requirements established in the Agreed Order. With offsite disposal shipments of mixed waste in 1994 and two shipments in 1996, as noted in section 4.13.2.3, and changes contained in the August 1996 FFCA Compliance Plan Annual Update document, construction of the HWTPF is no longer considered a regulatory requirement. DOEs purpose and need for enhanced efficiency and safety of its current mixed waste, low-level radioactive waste and hazardous waste operations remain and are discussed in greater detail in appendix H. Without the HWTPF, waste treatment and processing capabilities are greatly reduced.
In terms of overall operational waste management, the RCRA Part B Permit is the most significant regulatory instrument. The State of Texas and EPA jointly issued Pantex Plant a Hazardous Waste Permit in April 1991 to address the processing and storage of hazardous waste. The permit was modified in January 1993 to allow treatment in tanks and containers in Building 119 and 1115A. In July 1994, the permit was modified to increase permitted storage capacity for hazardous waste in Buildings 119N, 117A, and 117B by 780,700 liters (206,260 gallons) (TNRCC 1995a:9; PC 1995).
Pantex Plant requested a Class 3 modification to the Hazardous Waste Permit issued in April 1991 by TNRCC and EPA. The initial request for modification, made in November 1991 and revised in October 1992, asked for the addition of 17 RCRA units at the Burning GroundBurning Ground, which were excluded from the April 1991 permit but continued to operate under RCRA Interim Status, and 10 additional storage units. On February 16, 1996, the Class 3 permit modification was approved by TNRCC. As a result, permitted storage increased (5 Conexes and 3 magazines), 5 Burning Ground units (3 flash pits, 2 cages) were closed, and 15 Burning Ground units received permit status (DOE 1994b:2-6, 2-7; TNRCC 1996).
Air emissions from the ongoing Burning Ground activities are subject to general air quality conditions established in the Hazardous Waste Permit. The permit states that this facility shall be operated in accordance with and subject to the applicable provisions of the Texas Solid Waste Disposal Act and the Texas Clean Air Act as amended, Chapter 382 of the Texas Health and Safety Code, and all applicable rules, regulations, and orders of the TNRCC. The resulting ash shall be managed so as to not cause or contribute to a condition of "air pollution" as defined in subchapter 382.003 of the Texas Health and Safety Code (TNRCC 1996:20-22).
In 1984, RCRA was amended by the Hazardous and Solid Waste Amendments, which imposed waste minimization requirements on hazardous waste generators and treatment, storage, and disposal facilities. To comply with the waste minimization requirements, Pantex Plant established a Pollution Prevention and Waste Minimization program. Volume II, appendix G, Pollution Prevention and Waste Minimization, provides detailed information regarding pollution prevention and waste minimization at Pantex Plant. This program has been distinguished with the White House Closing the Circle Award and the Vice Presidents Hammer Award in 1996 (MH 1996b).
Pantex Plant is also active in the Clean Texas 2000 pollution prevention program. The organizations involved in this program commit to reduce chemical releases and hazardous waste generation by 50 percent by the year 2000, using the 1987 Toxic Release Inventory Report as a baseline. Current and planned studies examining alternative treatment methods to open burning-open detonation of high explosives are discussed in volume II, appendix G.
Waste Management PracticesThe major categories of wastes generated at Pantex Plant are described below. The discussion covers waste characteristics, activities, locations, quantities, and general waste management practices. Activities at Pantex Plant generate wastes that are categorized as low-level radioactive waste (LLW), low-level mixed waste (LLMW), hazardous waste (HW), and nonhazardous nonradioactive waste (NHW). NHW has three categoriesClass 1, 2, and 3 (see Table 4.13.1.13). Other wastes include sanitary and industrial wastewater, stormwater, polychlorinated biphenyls (PCBs), asbestos, and medical wastes.
Table 4.13.1.1-3.--Nonhazardous(Nonradioactive) Waste Classification (.pdf)
Transuranic (TRU) and mixed TRU wastes are not normally generated, and no high-level radioactive wastes are currently generated at Pantex Plant. Three drums of TRU waste were generated in 1993 as a result of an incident during weapon dismantlement. The TRU waste is stored at Pantex Plant in an appropriately monitored facility awaiting approval of transfer to an offsite management facility (Pantex 1996:14.5). Pantex Plant uses trained personnel and approved program procedures to control waste from the point of generation through storage, treatment, and disposal (TNRCC 1996).
4.13.1.2 Waste Categories and Operations
Table 4.13.1.21 shows the annual waste generation from 1992 through 1995 for LLW, LLMW, HW, and NHW. Table 4.13.1.22 shows environmental restoration (ER)ER program projected annual waste generation from 1997 to 2000 for LLW, LLMW, HW, and NHW. Table 4.13.1.23 shows projected waste generation from 1997 to 2007. As of September 1995, waste in storage included 474 m3 (616 yd3) of LLW, 147 m3 (191 yd3) of LLMW, 153 m3 (199 yd3) of HW, and 311 m3 (404 yd3) of NHW. Each of these waste types is discussed below. Additionally, Chapter 14 of the Pantex Plant Environmental Information Document provides detailed waste stream and waste management facility information.
Low-Level Radioactive WasteLLW contains radioactivity not classified as high-level waste, TRU waste, spent nuclear fuel, or special by-product material as defined by DOE Order 5820.2A (DOE Order 5820.2A:Attachment 2, page 3). Pantex Plants LLW wastestreams include materials contaminated during weapons assembly, disassembly, maintenance, or quality assurance testing. Other wastestreams include protective clothing, filters, wipes, plastic, foam, rubber, desiccant, and debris (PC 1995f).
Table 4.13.1.2-1.--Industrial Operation-Related Waste Volumes, 1992 (.pdf)
Table 4.13.1.2-2.--Environmental Restoration Waste Projections, 1997 (.pdf)
LLW is stored onsite and shipped to the Nevada Test Site (Nevada Test Site (NTS)NTS) for disposition. Pantex Plant must accumulate and store LLW in a manner that does not create a nuisance or endanger the public health or environment. Pantex Plants LLW operating storage capacity is of at least 2,380 containers (Pantex 1996:14.8). To ensure that LLW does not pose a danger to the public or the environment, Pantex Plant manages LLW in accordance with the NTS Defense Waste Acceptance Criteria Certification and Transfer Requirement Program (NVO325). Under NVO325, Pantex Plant is required to characterize wastes using process knowledge or sampling and analysis based on NTS-established analysis requirements and standardized reporting. In addition, each shipment of waste must be certified. Certification is the process of determining, verifying, and attesting in writing to compliance with the Waste Acceptance Criteria. Pantex Plant ensures compliance by conducting internal quality assurance and quality control audits. Furthermore, NTS conducts an annual program review and approval inspection of the plants practices and quality controls (DOE 1992a:8, 17-20, 96-106).
Pantex Plant materials managed under NVO325 for shipment to NTS for disposal include: demilitarized and sanitized weapon debris, desiccant, support materials, and packaging materials. Radioactively contaminated classified weapon components that cannot be demilitarized and sanitized are sent to the NTS classified repository. Pantex Plant is presently approved to ship nine LLW streams to NTS for disposal. Five more wastestreams have been through the NTS review process and have approval pending, waiting for sampling and verification. Pantex Plant has also identified 14 other potential streams for inclusion at a later date, and more may be added later. These wastes are currently stored onsite (Pantex 1996:14.5).
Low-Level Mixed WasteLLMW contains both radioactive and hazardous constituents as defined by the Atomic Energy Act (42 U.S.C. 2 )and RCRA (DOE Order 5820.2A:Attachment 2, page 3). Pantex Plants primary LLMW wastestreams are composed of debris from demilitarization and sanitization of weapons components contaminated during weapons assembly, disassembly, maintenance, and quality assurance testing. Other LLMW wastestreams include high explosive(s) (HE)HE-contaminated support material, organic liquids, aqueous liquids, organic solids, inorganic solids, lab packs, liquid mercury, batteries, and compressed gas (PC 1995f).
Pantex Plant stores all of its LLMW onsite. LLMW is managed in accordance with the Agreed Order and Site Treatment PlanCompliance Plan (Pantex 1996f), 30 TAC 335, the RCRA Part B Permit, and 40 CFR 260280. The Permits Waste Analysis Plan requires Pantex Plant to characterize wastes using process knowledge and test methods. The Waste Analysis Plan contains the methodologies and analyses used to properly characterize the LLMW (TNRCC 1996).
Pantex Plant treats LLMW and HW in three areas: the Burning Ground, Building 119, and Building 11-15A (Figure 4.13.1.21). The Burning GroundBurning Ground, an open air thermal treatment facility, operating under RCRA Permit Status, is located in the northern part of Pantex Plant. The Burning Ground is designed to handle waste HE and explosive-contaminated wastes from HE research and production activities. HE is treated in 15 thermal treatment units (nine trays, three pads, and three pans) (TNRCC 1996). Building 119, located in Zone 11, is permitted to allow treatment and processing of HW and LLMW in tanks and containers (TNRCC 1996).
While not part of the current operations, Pantex Plant plans to use the Hazardous Waste Treatment and Processing Facility (HWTPF) for LLMW, LLW, and HW treatment and processing. DOE is in the process of examining DOE developed technologies for enhancing HWTPF LLMW treatment and processing capabilities (Battelle 1995). Pantex Plant is also pursuing commercial LLMW treatment and disposal. A detailed discussion of the Hazardous Waste Treatment and Processing Facility (HWTPF)Hazardous Waste Treatment and Processing Facility (HWTPF)HWTPF can be found in appendix H. A detailed discussion of waste stream treatability groups can be found in the FFCA Agreed Order and the approved Site Treatment Plan-Compliance Plan.
Hazardous WasteUnder 40 CFR 261, HW is defined as a solid waste that meets any of these four conditions: is listed as a HW; exhibits a characteristic of a HW; is a mixture of a HW and a nonhazardous solid waste; or is derived from treatment, storage, or disposal of a HW. The term "solid" in this context does not specify physical form (i.e., HW may be solid, liquid, or gas) (40 CFR 261.3). The regulations exempt or exclude certain materials from its definition of hazardous wastes, and these exclusions and exemptions are not considered in this discussion. Pantex Plant generates HW during weapons assembly, disassembly, maintenance, and quality assurance testing; HE research and production; environmental restoration (ER)ER; and facility operations. Wastestreams include high explosive(s) (HE)HE, solvents, protective clothing, filters, wipes, oils, soils, paint waste, desiccant, tools, wastewater, and debris (PC 1995f).
Pantex Plant stores HW onsite and treats it onsite and offsite. HW is disposed of offsite. Pantex Plant uses commercial facilities for offsite treatment and disposal. HW is managed in compliance with RCRA regulations from the point of generation to storage and disposal (Pantex 1996:14.5).
Nonhazardous Nonradioactive WasteNHW is defined as a municipal solid waste or industrial solid waste that is not a listed or characteristic hazardous waste as defined in 40 CFR 261 and 30 TAC 335. Pantex Plant generates industrial solid NHW during weapons assembly, disassembly, maintenance, quality assurance testing; HE research and production; ER; and facility operations. Wastestreams include nonhazardous solvents, protective clothing, filters, wipes, nonhazardous oils, soils, nonhazardous paint waste, desiccant, tools, wastewater, and debris (PC 1995f).
Figure 4.13.1.2-1.--Waste Management Facility Location at Pantex Plant.
Pantex Plant accumulates and stores NHW onsite, and the treatment of NHW occurs both onsite and offsite. Onsite disposal of NHW includes construction debris in an onsite construction debris landfill. All other NHW wastestreams are disposed of offsite by commercial contractors. State regulation 30 TAC 335.4 allows Pantex Plant to accumulate and store NHW in any manner that does not create a nuisance or endanger public health or the environment. Texas Natural Resource Conservation Commission (TNRCC)TNRCC requires Pantex Plant to characterize NHW as a Class 1, Class 2, or Class 3 waste. Table 4.13.1.13 lists the regulations where the waste class is defined; the criteria defining each waste class; examples of each type of waste; and the storage, treatment, and disposal that is conducted on each class both onsite and offsite (Pantex 1996:14.5). Pantex Plant expects to generate approximately 522 metric tons (576 tons) per year of Class 2 waste (trash). The trash is disposed of through commercial vendors and the Amarillo Landfill (Pantex 1996:14.5). The Amarillo Landfill has more than 25 years of capacity (Pantex 1996:9.4, 14.5). Class 3 (construction debris) waste volumes are not reported (Pantex 1996:14.5).
Other Waste TypesSanitary and industrial wastewater is discharged into the Wastewater Treatment Facility. Stormwater drains to the playas onsite. Treated effluent from the Wastewater Treatment Facility is discharged into Playa 1.
The State of Texas defines medical waste as solid waste generated during the diagnosis, treatment, or immunization of human beings or animals during research, biological production, or biological testing. The Pantex Plant Medical Department generates medical waste during diagnosis, treatment, and immunization of plant personnel, and includes urine cups, medical gloves, cotton balls, blood samples, sharps containers, contaminated sharps, bandage material contaminated with body fluids, and scintillation vials with urine samples. The Pantex Plant Medical Department follows internal procedures for waste collection and management. Medical waste is disposed of offsite by a commercial contractor (Pantex 1996:14.5).
As of December 31, 1993, all PCB-contaminated parts and equipment used at Pantex Plant contained concentrations of less than 50 parts per million and are managed in accordance with the Toxic Substances Control Act (15 U.S.C. 2601) regulations (Pantex 1996:14.5). These PCB and asbestos wastes are transported to offsite permitted facilities for treatment and disposal (DOE 1995b:2-10). Transuranic wastes are not normally generated. No high-level radioactive wastes are currently generated at Pantex Plant.
Environmental Restoration WasteEPA placed Pantex Plant on the National Priorities List as a Superfund cleanup site, effective June 30, 1994 (59 FR 27989). Superfund cleanup sites are regulated under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) (42 U.S.C. 9601), as amended by the Superfund Amendments and Reauthorization Act (42 U.S.C. 9608). Superfund sites are prioritized for cleanup of hazardous substance releases that pose threats to human health or the environment.
The environmental restoration (ER)ER program at Pantex Plant is now regulated both by the State of Texas and EPA under both the RCRA and CERCLA requirements. A tri-party Federal Facility Agreement (FFA)Federal Facility Agreement is currently being negotiated to outline the reporting requirements, schedules, and funding. It is unknown at this time what impact any additional conditions and requirements specified in the Federal Facility Agreement will have on the Pantex Plant ER program (Pantex 1996:15.0).
Since CERCLA requirements are being negotiated, Pantex Plant is following the RCRA Part B Permit, which requires Pantex Plant to investigate and manage its 144 identified solid waste management unit (SWMU)solid waste management units (SWMUs) as described in section 4.5, Geology and Soils. The permit also includes extensive investigation requirements and management criteria for SWMUs (TNRCC 1996:Attachments EG).
While 144 SWMUs were identified as sites of potential concern and the early waste calculations were very high, subsequent investigations have determined that many of the sites are less contaminated and have smaller cleanup volumes (DOE 1995e:4-28). Table 4.13.1.22 provides the best available information on waste projections from ER activities. The ER program generates waste through investigation and remediation activities. Pantex Plant ER wastes are expected to include LLW, HW and NHW. The ER wastestreams include contaminated soils, high explosive(s) (HE)HE-contaminated materials, protective clothing, wipes, tools, wastewater, and debris (PC 1995f). Starting in 1999, the ER wastes are expected to be primarily liquid wastes resulting from monitoring systems and restoration management of contaminated water from the perched aquifer (Pantex 1996:14.5, 15.5).
4.13.1.3 Solid Waste Management Facilities
Table 4.13.1.12 identifies the facilities where waste management activities are currently carried out. Wastes are collected from various generator sites in Zone 12 South at Pantex Plant and staged at Building 1242 for sorting and segregating before they are transferred to various waste management facilities. Other generator sites throughout Pantex Plant move waste directly to the 117N storage pad or Building 119N (Pantex 1996:14.6, 14.7). Given below is a brief summary of the current and proposed management facilities for Pantex Plant waste. See Figure 4.13.1.21 for the location of these facilities.
Four facilities (117N Pad, 117A, 117B, and 119N) are used for storing waste in Zone 11. The 117N Pad is an above-grade permitted storage pad with two sheds. This facility is used to store LLMW, HW, LLW, and other wastes and materials. Units 117A and B are permitted storage pads adjacent to the 117N Pad and are used for storage of wastes on a single, above-grade concrete pad. Building 119 is used for the storage of HW, LLMW, LLW, and other wastes and materials. The north portion of this building is also used to repackage and stage waste for shipment (Pantex 1996:14.8).
In Zone 4, four HW magazines, one LLW magazine, thirteen HW Conex boxes, and 20 LLW Conex boxes are available for storage of wastes. The four HW magazines are used for storage of liquid and solid LLMW and HW. Containers of LLW are periodically moved from storage areas and transported to Nevada Test Site (NTS)NTS for disposal. The Conex boxes are large steel containers with a capacity of about 72 cubic meters (94 cubic yards). The 13 HW Conex boxes have a permitted storage capacity of 4,467 drums and a total operating capacity of 946 containers. Twenty Conex boxes are used for storage of LLW until it is shipped offsite (Pantex 1996:14.8).
During 1996, three burn pits and two burn cages under went RCRA closure (TNRCC 1996). Closure plans for all RCRA permitted facilities are part of the existing permit; however, approved work plans are not in place. The plant has successfully completed several other RCRA closures and partial closures in recent years (TNRCC 1995a).
For wastewater treatment capabilities, also see sections 4.3, Plant Facilities and Infrastructure, and 4.6, Water Resources. Pantex Plant thermally treats HE and HE-contaminated wastes. Buildings 119 & 1115A provide onsite LLMW treatment capabilities. Additionally, Pantex Plant is capable of treating and processing (such as compaction and repackaging) hazardous waste, including LLMW in tanks and containers.
4.13.2 Impacts of Proposed Action
This section discusses impacts of the Proposed Action on the regulatory status and waste management operations at Pantex Plant for an approximately 10-year period. This includes impacts on Pantex Plant's permit status, required RCRA closures, treatment methods, storage limits, disposal capacities, and the volume of waste transported offsite. Impacts are evaluated for continued operations, pit storage, environmental restoration (ER)ER, and new facility construction and upgrades. These activities would generate LLW, LLMW, HW, NHW, and other wastes. Since waste management impacts are dependent on total waste volume and waste category, impacts concentrate on LLW, LLMW, HW, and NHW (Class 1). Medical, PCB, and asbestos wastestreams are small at Pantex Plant and are not discussed further. Impacts from NHW (Class 2 and 3) are discussed to a lesser degree due to reduced risk to human health and the environment.
4.13.2.1 Impacts of Continued Operations
Weapons-Related ActivitiesUnder the Proposed Action, three levels of operations on 2,000, 1,000, and 500 weapons per year are evaluated. Table 4.13.1.23 provides annual waste generation projections by waste type and activity level for the 10-year period for all site activities except ER.
If operations on 2,000 weapons are performed annually, approximately 249 cubic meters (326 cubic yards) of LLW would be generated per year. The volume of LLMW generated per year is expected to be 183.2 cubic meters (239.6 cubic yards), while the volume of HW and NHW (Class 1) generated per year would be 191.6 cubic meters (250.5 cubic yards) and 741.6 cubic meters (970 cubic yards), respectively.
If operations on 1,000 weapons are performed annually, annual LLW generation would decrease by approximately 47 percent compared to operations on 2,000 weapons; annual LLMW generation would decrease by approximately 35 percent. The volume of HW and NHW (Class 1) generated per year would decrease by approximately 44 and 29 percent, respectively.
If operations on 500 weapons are performed, annual generation of LLW would decrease by approximately 71 percent compared to operations on 2,000 weapons; annual LLMW generation would also decrease by 56 percent. The volume of HW and NHW (Class 1) generated per year would decrease by approximately 67 and 48 percent, respectively.
Pit Storage ActivitiesPit storage activities generate LLW, LLMW, HW, and NHW. The amount of waste generated (less than 1 cubic meter [1.3 cubic yards] per year) for each waste category is small compared to the volume of waste routinely handled at the plant, and would not affect waste management activities (PC 1995j). The activities generating waste include Radiation Safety operations, (e.g., labels, security seals, and personnel protective equipment) and minor maintenance.
Pit Repackaging OperationsThe repackaging of pits from AL-R8 containers into AT-400A containers is expected to begin in late 1996 or early 1997. At this point, empty AL-R8 containers resulting from the AT-400A repackaging effort will either be reused for other purposes at Pantex Plant or be turned over to the DOEs normal excess materials disposition program. Other wastes that would be generated would be routine and also well within the total waste generation described for the Proposed Action. The pit repackaging operations would result in additional worker radiological exposures. These impacts are discussed in section 4.14.
Environmental Restoration(ER) Activities
ER activities are expected to generate LLW, HW, and NHW, but the volume of waste generated from these activities would be independent of the number of weapon operations. When the majority of the remediation is completed, expected by the year 2000, a small amount of waste would continue to be generated (e.g., from monitoring and treatment). Table 4.13.1.22 provides estimates of waste generation from ER. Current waste volume projections are considered small when compared to pre-1994 conservative estimates.
Comparing ER waste projections in Table 4.13.1.22 and plant industrial waste projections from operations on 2,000 weapons per year shown in Table 4.13.1.23 shows that ER wastes would represent less than 3.8 percent of the industrial waste after 1999. In 1997 and 1998, the total volumes of ER projected waste and the projected wastes volumes for the 2,000 weapons level are 2,356 cubic meters (2,781 cubic yards) and 2,946 cubic meters (3,548 cubic yards), respectively. These volumes are below the historic high level managed in 1993. ER projected wastes are not considered to pose a major impact to waste management operations at Pantex Plant. Furthermore, no additional waste management facilities or modifications of existing waste management facilities are planned to support ER wastes. Current waste management facilities are planned to be used to support the ER activities. Current waste management facilities are expected to handle the projections in 4.13.1.22.
4.13.2.2 Impacts of New Facility Construction and Upgrades
Six new facilities would be constructed under the Proposed Action. Debris generated by construction or modification of the new facilities would be disposed of in the onsite landfill; trash would be disposed of in the Amarillo landfill. Generation of this waste would not affect Pantex Plant's waste management activities.
The Pit Reuse FacilityPit Reuse Facility is expected to generate 1.5 cubic meters (1.9 cubic yards) of LLW, 0.5 cubic meter (0.6 cubic yard) of LLMW, 0.6 cubic meter (0.8 cubic yard) of HW, and 6.0 cubic meters (7.8 cubic yards) of NHW (Class 1) annually. This relatively small increase in waste generated would not increase the impacts resulting from current waste management practices (PC 1995g:Table 3).
The Gas Analysis Laboratory (GAL)Gas Analysis Laboratory, Materials Compatibility Assurance Facility (MCAF)Material Compatibility Facility, Nondestructive Evaluation FacilityNondestructive Evaluation Facility, and the Metrology and Health Physics Calibration and Acceptance FacilityMetrology and Health Physics Calibration and Acceptance Facility are expected to generate the same types and quantities of waste as the existing facilities they would replace, and thus their operational impacts would not change from current waste management practices (PC 1995g:Table 3).
HWTPF is being designed to treat and process LLMW, LLW, and HW. Pantex Plant would need up to two years to obtain new permits or modify existing permits (Battelle 1995). DOE developed technologies are being considered for treatment of LLMW to meet RCRA land disposal restrictions in compliance with the FFCA Agreed Order and approved site treatment plan and waste acceptance criteria for potential disposal sites. The large volume treatment process (e.g., Macroencapsulation) may increase the volume of waste by a factor of 1.45, depending upon the process used. This increased waste volume is taken into account when determining the overall impacts on waste management operations (see section 4.13.2.3) (PC 1995g:Table 4). An expanded discussion regarding the HWTPF is presented in volume II, appendix H.
A discussion of energy conservation design criteria is provided in volume II, appendixes G and H for the new facilities and upgrades.
4.13.2.3 Summary of Impacts
As shown in Table 4.13.1.23, the volume of all waste types generated at Pantex Plant excluding ER wastes would decrease with the decrease in operations on weapons levels.
If the site continues to ship HW offsite on a monthly basis, no additional storage capacity would be required. Annual HW projections in Table 4.13.1.23 are equal to or below HW generated annually in 19921995 (DOE 1996f:18). The number of HW shipments is expected to be at or below historic levels. If HW is treated at the HWTPF, the number of shipments would begin to increase in the year 2002 because treatment is expected to increase waste volume.
The Pantex Plant permitted operating storage capacity is 7,044 containers of LLMW (TNRCC 1996). In July 1996, 482 containers of LLMW were stored (PC 1996f). If no offsite disposal is provided, for annual operations on 2,000 weapons, 879 containers containing 183.2 cubic meters (239.6 cubic yards) of LLMW would be placed into storage starting in 1997. As a result, additional waste storage capacity would be required in 2004, regardless of whether the waste is treated or not. Similarly, for annual operations on 1,000 and 500 weapons, 568 and 389 containers containing 118.3 cubic meters (154.7 cubic yards) and 81 cubic meters (105.9 cubic yards) of LLMW, respectively, would be placed in storage starting in 1997. As a result, additional waste storage capacity would not be needed for the 1,000 weapons level and the 500 weapons level. For operations on 2,000, 1,000, and 500 weapons, Pantex Plant would be annually required to provide storage for 1,275, 824, and 564 containers, respectively, for the treatment of LLMW. For operations on 2,000 and 1,000 weapons, Pantex Plant would need to provide additional waste storage for 6,405 and 1,895 containers, respectively, by 2007. For operations on 500 weapons, no additional waste storage facilities would be required by 2007.
In 1994, a shipment of LLMW totalling 33 cubic meters (43 cubic yards) was disposed at a commercial facility in Utah. A second shipment in June 1996 totalled 70 cubic meters (91 cubic yards) of LLMW. The June 1996 shipment reduced the LLMW inventory by 31.6 percent. A third shipment in September 1996 further reduced LLMW inventories by a total of 50 percent. Additional future offsite disposal would further reduce waste operation impacts including waste inventories (PC 1996e, PC 1995n).
To obtain additional storage for LLMW, Pantex Plant has two options. The first is to convert or expand an existing building. The second is to build a new facility. Both require permit changes, but the first option is more desirable. The first option was previously completed at Pantex Plant in July 1994 when Buildings 119N, 117A, and 117B were added. If additional storage is not approved, shutdown is possible with impacts to all Pantex Plant operations and employees.
If the site continues to ship LLW routinely throughout the year, no additional storage capacity would be required. From 19921994, the plant shipped 990.9 cubic meters (1,296.1 cubic yards) of LLW in 4,760 drums (PC 1995n). The plant has a storage capacity of at least 2,380 containers (495.82 cubic meters [648.53 cubic yards]). For operations on 2,000, 1,000, and 500 weapons, 1,195, 631, and 343 drums, respectively, would be generated annually. With an average of 1,587 drums shipped annually, the shipment capacity exceeds the generation projections for all weapons levels. If the shipments cease and the estimated storage capacity of 2,380 containers is exceeded, storage facilities would be added, as appropriate, to avoid impacting Pantex Plant principal operations.
Treatment and processing of LLMW, LLW and HW at the Hazardous Waste Treatment and Processing Facility (HWTPF)HWTPF is scheduled to begin in the year 2001. Depending on the treatment and processing techniques, the volume of waste could either increase or decrease, which would affect the number of offsite shipments. However, minimal impacts are expected since historical capacities are greater than the expected generation rates.
Minimal impacts to NHW management are expected. The amount of NHW projected would be below historic numbers generated during 19921995 (DOE 1996f:18). The Amarillo landfill has more than 25 years of capacity (Pantex 1996:9.4, 14.5). Onsite disposal of NHW Class 2 and NHW Class 3 wastes is currently allowed. Minimal impacts from environmental restoration (ER)ER wastes are expected as they represent less than 3.8 percent of waste generated from industrial operations after 1999.
Any additional storage, treatment, and disposal facilities required beyond existing and currently planned activities will be covered in future NEPA documentation.
4.13.3 Impacts of No Action Alternative
Under the No Action Alternative, the operations on 2,000, 1,000, and 500 weapons per year are the same as those evaluated under the Proposed Action except that disassembly of weapons would cease once pit storage reached the authorized level of 12,000.
Under the three levels of activity, LLMW, LLW, HW, and NHW operations would continue as described in the Proposed Action with minimal impacts. However, without the Hazardous Waste Treatment and Processing Facility (HWTPF)HWTPF, waste treatment and processing capabilities are greatly reduced. If Building 119, 117 Pad, or offsite capacities do not compensate for the lack of a HWTPF, the plant would pursue possible options to avoid adverse regulatory and operational impacts. One option is to expand Building 119 or 117 Pad, and a second is to continue to reduce waste generation through reduced workloads or a combination of the options. Additional information regarding the HWTPF is available in volume II, appendix H.
4.13.4 Impact of Pit Storage Relocation Alternative
This section discusses the impacts of the Pit Relocation Alternative on waste management operations and regulatory status at Pantex Plant that would result during the 10-year period. The operations at Pantex Plant would be the same as those discussed under the Proposed Action, section 4.13.2.1.
4.13.4.1 Impacts of Relocating 20,000 Pits
Pit storage activities generate minimal waste (less than 1 cubic meter [1.3 cubic yards] per year of LLW, LLMW, HW, and NHW); therefore, relocation of pit storage to another site would not affect waste management at Pantex Plant. Impacts to the relocation alternative sites are addressed in chapter 5.
4.13.4.2 Impacts of Relocating 8,000 Pits
Pit storage activities generate minimal waste (less than 1 cubic meter [1.3 cubic yards] per year of LLW, LLMW, HW, and NHW); therefore, relocation of pit storage to another site would not affect waste management at Pantex Plant. Impacts to the relocation alternative sites are addressed in chapter 5.
4.13.5 Cumulative Impacts
The cumulative impacts presented here include impacts of the continued operations at Pantex Plant combined with impacts associated with activities described in the WM PEIS, SSM PEIS, and S&D PEIS. Since the Pantex Plant EIS Proposed Action and the SSM PEIS No Action Alternative represent a continuum of operations, the impacts associated with any new mission or facility that could be implemented at Pantex Plant are discussed in the context of that continuum. The impacts from the WM PEIS program are combined with those of the Pantex Plant EIS Proposed Action. The impacts from the S&D PEIS are combined with those of the SSM PEIS No Action Alternative. A detailed discussion of this methodology is presented in section 4.2.
The final S&D PEIS will include an alternative that is a refinement of these storage alternatives. As discussed in sections 1.4 and 1.7.3 of this volume, the final S&D PEIS will include an alternative under which pits from Rocky Flats Environmental Technology Site (RFETS) could be transferred to Pantex Plant for storage in Zone 4 as early as 1997. The impacts of this alternative are fully accounted for in this EIS because the pits from RFETS could not cause the total number of pits stored in Zone 4 to exceed the storage limit of 20,000 pits analyzed under the Proposed Action. Furthermore, RFETS pits that could come to Pantex Plant would have the same characteristics, as analyzed in the S&D PEIS, as pits currently or previously stored at Pantex Plant.
4.13.5.1 Impacts of Alternatives in the Waste Management Programmatic Environmental Impact Statement
The WM PEIS examines the environmental impacts of alternative configurations for the management of radioactive and hazardous wastes at DOE sites throughout the U.S. Pantex Plant routinely manages three of the five waste types (LLMW, LLW, and HW) addressed in the WM PEIS. For the purpose of analyses, the WM PEIS considered a baseline inventory and a projected inventory after 20 years. Pantex LLMW represented only 0.3 percent of the entire DOE complex projected LLMW. Similarly, the analyses considered Pantex Plant LLW and HW projected waste inventory at 0.2 percent and 14 percent of the DOE Complex, respectively.
In most alternatives, LLMW and LLW wastes would be shipped offsite for treatment and disposal. Under all alternatives, HW would be shipped offsite for treatment and disposal.
Little or no cumulative waste management operational impacts from WM PEIS alternatives are expected. Current Pantex Plant waste management operational impacts are bounded by the Pantex Plant EIS. Additional and bounding impacts from HW operations are presented in the WM PEIS. Impacts of alternatives, including those noted above, are covered in the WM PEIS.
The WM PEIS provides environmental information to be used in deciding where to locate waste management activities on a national basis. Subsequent site- or project-level NEPA review would be conducted prior to implementing these decisions.
4.13.5.2 Impacts of Alternatives in the Stockpile Stewardship and Management Programmatic Environmental Impact Statement
The SSM PEIS includes three alternatives that apply to Pantex Plant: No Action, Downsize Existing Capability, and Relocate Capability. Under the No Action Alternative, no downsizing or modification of facilities would occur. Due to the reduced workload expected in the future, waste management impacts from operations are expected to be less than current impacts. Generated wastes would be adequately managed with existing waste management facilities. Under the downsizing alternative, Pantex Plant has adequate waste management facilities to treat, store, and dispose of its wastesalthough waste treatment, storage, and disposal alternatives are contingent upon programmatic decisions of the WM PEIS. Under the relocation alternative, the amount of decontamination and decommissioning activities and wastes would eventually increase.
4.13.5.3 Impacts of Alternatives in the Storage and Disposition of Weapons-Usable Fissile Materials Programmatic Environmental Impact Statement
The S&D PEIS is considering Pantex Plant for long-term storage of inventories of nonsurplus weapons-usable plutonium and highly enriched uranium (HEU), storage of inventories of surplus weapons-usable plutonium and HEU pending disposition, and disposition of surplus weapons-usable plutonium. For storage, the strategy for long-term storage of weapons-usable plutonium and HEU, as well as the storage site(s), would be decided. The storage alternatives include upgrading the existing plutonium storage facilities, consolidation of plutonium from other sites, and collocation of plutonium and HEU storage. The collocation alternative is used for analysis purposes in this EIS as the bounding storage alternative.
Under the S&D PEIS Collocation Alternative, construction of new storage facilities would be required in order to store plutonium and HEU at Pantex Plant. Construction and operation would have an impact on existing Pantex Plant waste management activities by increasing the generation of TRU, LLW, LLMW, HW, and NHW. Not including the Proposed Action or the Waste Management program, approximately 10 cubic meters (13 cubic yards) of TRU waste and 4 cubic meters (5 cubic yards) of mixed TRU waste would be processed and packaged to meet the offsite waste acceptance criteria. Approximately 1,300 cubic meters (1,700 cubic yards) of LLW contaminated with plutonium and uranium would require disposal. The 0.2 cubic meters (55 gallons) of liquid LLMW and 66 cubic meters (86 cubic yards) of solid LLMW would be treated and disposed of through the use of existing and planned facilities according to the Pantex Site Treatment Plan (Pantex 1996f). The 2 cubic meters (528 gallons) of liquid and 2 cubic meters (3 cubic yards) of solid HW would have a negligible impact on waste management activities at Pantex Plant. The 129,500 cubic meters (34,200,000 gallons) of liquid NHW may require construction of sanitary, utility, and process wastewater treatment systems. The 1,840 cubic meters (3,400 cubic yards) of solid NHW would require disposal at the offsite landfill.
For the disposition alternatives in the S&D PEIS, the emphasis at this stage in the NEPA decision process is on the strategy and technology mix rather than the actual site. The evolutionary Light Water Reactor is used for analysis purposes in this EIS as the bounding disposition alternative. Implementation of this disposition alternative would require the construction and operation of a pit disassembly and conversion facility, plutonium conversion facility, mixed oxide fuel fabrication facility, and one or more light water reactors. The bounding alternative also assumes that all of the facilities previously mentioned would be collocated at the same site (potentially Pantex Plant).
For disposition (not including the Proposed Action or the Waste Management program), approximately 52 metric tons (57 short tons) of spent fuel, 4 cubic meters (1,056 gallons) of liquid, and 651 cubic meters (846 cubic yards) of solid TRU, and approximately 204 cubic meters (265 cubic yards) of solid mixed TRU would be generated. Approximately 18,964 cubic meters (5.017 million gallons) of liquid and 2,498 cubic meters (3,247 cubic yards) of solid bk1low-level waste (LLW)LLW and 1.24 cubic meters (177 gallons) of liquid and 235 cubic meters (308 cubic yards) of solid bk0low-level mixed waste (LLMW)LLMW would also be generated. Liquid and solid HW generation would be 8 cubic meters (1,112 gallons) and 192 cubic meters (250 cubic yards), respectively. Liquid and solid bk2nonhazardous waste (NHW)NHW generation would be 485,300 cubic meters (128 million gallons) and 7,516 cubic meters (9,771 cubic yards), respectively (DOE 1996a:Summary).
Waste treatment, storage, and disposal alternatives are contingent upon programmatic decisions resulting from the WM PEIS.
4.13.6 Potential Mitigation Measures
Pantex Plant has an active waste minimization and pollution prevention awareness program. This program is an organized, comprehensive, continuing effort to prevent pollution and reduce waste generation at the plant. It includes specific waste reduction goals for major categories of waste. Program details are provided in volume II, appendix G.
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