H.3 HAZARDOUS WASTE TREATMENT AND PROCESSING FACILITY
The Draft Reference Document for the HWTPF and the Conceptual Design Report for the HWTPF provide in-depth environmental information concerning the construction and operation of the HWTPF (Battelle 1995, DOE 1995). These documents have been extensively used in the following project description and are not cited repeatedly.
The normal operations at Pantex Plant generate low-level mixed waste (LLMW), low-level radioactive waste (LLW), hazardous waste (HW), and nonhazardous waste (NHW). These wastes need to be properly treated and/or disposed of to reduce their impact to human health and the environment. Excluding Burning Ground capabilities, only limited treatment and processing of wastes are currently performed at Pantex Plant. Additionally, these operations are conducted in facilities not originally designed for waste treatment and processing and are considered operationally limited (Battelle 1995:1; Pantex 1996:App C).
H.3.1 Purpose and Need for Action
The Department needs to enhance the efficiency and safety of its current waste operations. The Department proposes to meet its need by constructing the HWTPF. The proposed facility would consolidate current waste operations, provide a state-of-the-art facility to conduct hazardous operations, provide for the treatment and processing of stored wastes, improve waste minimization, and expand plant capabilities for waste treatment and processing to meet future demand goals (Battelle 1995:9). This centralized facility would concentrate like activities in one area, thus providing safer and more efficient working conditions (Battelle 1995:13). An alternative which assesses the facility design with largest potential for impact was used to bound the impacts discussed in volume I of the EIS. The proposed HWTPF is smaller in scope. Both are detailed below.
H.3.2 Bounding Alternative
The bounding HWTPF would, along with the Burning Ground, provide the necessary treatment capacity to meet future demands. The HWTPF would utilize a range of DOE developed treatment and processing technologies.
The HWTPF is presently under preliminary design at Pantex Plant. The purpose of the facility is to treat and process the numerous wastestreams onsite. These wastestreams would include LLMW, LLW, and HW. The HWTPF would enhance the waste sorting and repackaging, sampling, compacting, drum rinsing and crushing, wastewater solidification, and waste minimization capabilities at Pantex Plant. DOE developed technologies for treatment and processing of wastes would consist of basic technologies involving chemical stabilization and macroencapsulation. Wastes would be minimized or stabilized for offsite disposal with the maximum amount of materials undergoing recycling or reuse offsite. It is estimated that the construction of the 2,648-square meter (28,500-square foot) facility would take 24 months, involve approximately 129 workers, and encompass approximately 0.53 hectares (1.31 acres) of land disturbance (PC 1995:Table 1).
H.3.2.1 DOE Developed Technologies
DOE developed technologies may include chemical stabilization, macroencapsulation, waste management processes (e.g., compactor, solvent recovery), and offsite DOE and commercial treatment and processing technologies. Expanded discussions are available in the Draft Reference Document for the HWTPF and the FFCA Agreed Order and approved Plans.
Chemical Stabilization
The Agreed Order identifies stabilization as involving immobilization of the debris with reagents that reduce the leachability of the hazardous contaminants to levels deemed appropriate by Federal, State, and local regulations (DOE 1995e:35). To minimize the risk of contaminants leaching into the environment, wastes can be treated to limit the leachability of toxic heavy metal constituents, as well as to produce a hard, water resistant solid that can be deposited in a landfill. This process is called chemical stabilization. Waste generated at Pantex Plant could utilize this process. The process could be batched or continuous and would require a mixer, a waste feed system, and feeders for the reagents and water mixing (Battelle 1995:47-48).
Macroencapsulation
The FFCA Agreed Order identifies macroencapsulation as enclosing solid waste in an inert envelope to reduce exposure to potential leaching media in a landfill (DOE 1995e:37). This process is achieved by coating waste surfaces with materials (resins, plastics) that enclose it in a jacket of organic material. Jacketing of the entire waste container to seal wastes is also under consideration. This reduces the exposure of solid waste to elements that would cause the waste to leach into a landfill. This is the land disposal restriction treatment standard for debris and radioactive solids (Battelle 1995:49).
Other Waste Management Processes
Table H.3.2.1-1 lists additional waste management processes that are under consideration and could be used to treat and process waste generated at Pantex Plant. Treatment and disposal options include commercial facilities and facilities at other DOE sites in accordance with the FFCA Agreed Order and approved Plans.
H.3.3 Facility Description
The bounding HWTPF would be a one-story building located north of the Steam Plant and west of South 13th Street. The facility would be designed for a life of not less than 25 years. The gross area of the facility is 2,650 square meters (28,500 square feet). The HWTPF would be divided into administrative and operations sections. These areas would be separated by a 3-hour fire wall on the exterior of the process areas, an access ramp, and a 1-hour fire wall on the administrative side of the ramp (Battelle 1995:16; DOE 1995:I.E 5).
The building design would be specific to facilitate decontamination and decommissioning. The walls and ceilings would be painted with a pinhole free epoxy paint, and cracks and joints would be sealed with a like material. The floors would be covered in a seamless material, and the walls would be designed for ease in dismantlement and packaging. All of the electrical devices in the operations area would be designed for a wet environment to facilitate washdown activities (Battelle 1995:29, 30). Prefabricated portable buildings for flammable liquid and hazardous liquid storage could be located in close proximity to the HWTPF. Approximately 24 to 30 55-gallon drums would be stored in each building (DOE 1995:I.E. 30-31).
H.3.3.1 Administration Section
This section would house offices, record storage, vestibule, locker rooms, a break room, a conference room, and a janitor's closet. This area would be accessible to handicapped individuals. The office area would house 12 employees, use modular furniture, and would comprise approximately 116 square meters (1,250 square feet). Record storage would be approximately 19 square meters (200 square feet) in area. The vestibule would be a 9-square meter (100-square foot) entryway that would provide the facility with a sheltered access. It would comply with handicap access requirements providing the appropriate door opening devices and access ramps.
Men's and women's locker rooms would occupy approximately 56 square meters (600 square feet) of space each, and would provide approximately 10 workers with a shower and locker area, and 8 workers with toilet facilities. The break room would be about 37 square meters (400 square feet) and would provide an eating area for an occupancy of 20 individuals. The conference room is a 42-square meter (450-square foot) open area that would provide a meeting and training space for up to 30 people. The janitor's closet would utilize approximately 9 square meters (100 square feet) of space for the storage of cleaning supplies (Battelle 1995:22-23).
H.3.3.2 Operations Section
The Operations Section would contain a shipping and receiving dock, a LLMW and LLW treatment and processing bay, two bays for treatment and processing operations, an HW treatment and processing bay, and a building services area (Battelle 1995:16). Because of the need for rapid evacuation, this building would not be designed to facilitate disabled persons (Battelle 1995:18).
Shipping and Receiving Area
This area would have three truck stalls for shipping, receiving, and crushed dumpster loading. The dock would handle staging of one truckload of material at a time, and the load could be staged for up to a week at the dock. Trucks ranging in size from tractor trailers to pickups would be accommodated. The area would have a forklift ramp for forklift access. The material would be weighed and certified prior to being loaded into the trucks. Other items for shipment might include bar-coded containers of newly generated waste materials. The containers would be coded for tracking and accountability, and the exterior would be checked for radioactive contamination (Battelle 1995:18).
Radioactive Waste Processing Bay
This area would treat and handle both LLW and LLMW, and may include variations of the following activities: LLW and LLMW sorting and repackaging, LLW and LLMW sampling, LLMW aerosol can puncturing, LLW and LLMW compacting, and low-level wastewater solidification (Battelle 1995:19). The area would have a high-efficiency particulate air (HEPA) filtered intake into the heating, ventilation, and air-conditioning (HVAC) system, as well as exhausts or hood vents to contain the contamination as necessary. Controls, such as cleaning the sorting and repackaging area between wastestreams, would be implemented, and the bay would contain monitors and alarms to alert personnel to the presence of airborne radioactive or chemical hazards (Battelle 1995:19).
Radioactive Waste Treatment Bays
Two bays would be designed to handle the treatment and processing of wastes. One of the bays would process Class 1 flammable liquids utilizing an open system while the other bay would process nonflammable wastes. The bays would contain individual airlocks with sloped accesses. The airlocks would contain a 4.5-metric ton (5-ton) overhead hoist, two overhead automatic doors (measuring, at a minimum, 4.3 meters [14 feet] in width by 4.3 meters [14 feet] in height), and would be HEPA filtered and have an interlocked alarm that would sound if more than one door was opened at a time (Battelle 1995:20-21).
Hazardous Waste Operations Bay
This area would be used for the treatment and handling of HW, such as aerosol can puncturing, HW sorting/repackaging, HW sampling and compacting, HW drum rinsing, and HW solvent recovery. This bay would also have monitors and alarm systems to alert personnel to airborne contamination (Battelle 1995:20).
Building Support Services Area
This area includes the mechanical room, electrical room, storage rooms, personnel airlocks, forklift airlocks, and a supply corridor, with the mechanical and electrical rooms housing the majority of the facilities utility services. The storage rooms would store and stage inert materials, tools, supplies and would be monitored for chemical and radiation contamination. Personnel airlocks, with decontamination showers and eyewash stations and interlocked alarm systems, would be located in each operations bay. Interlocked forklift airlocks would allow forklift and saddletruck access to the bays. If necessary, decontamination of this equipment could be performed inside the airlocks. The supply corridor (ramp) would be the main path for materials handling and personnel access, and would also be the utility corridor for the majority of water, steam, electricity, and HVAC systems (Battelle 1995:21-22).
Flammable Liquid Storage Building
The Flammable Liquid Storage Building could be a 2.4-meter (8-foot) by 6.1-meter (20-foot), prefabricated, portable storage unit located about 24.4 meters (80 feet) southwest of the HWTPF. It would have a storage capacity of 24 55-gallon drums that would be separated by material storage. The stored materials may include polybutadiene, bitumen, polystyrene, epoxy and methylene di-isocyanate, and would be transported to the HWTPF by forklift or dolly. The building would contain an automatic, dry chemical fire suppression system, would be heated to a minimum temperature of 10 °C (50 °F), and would have a secondary containment unit that would drain into a sump. This would be a Factory Mutual approved, UL classified structure built to satisfy the following codes: Uniform Building Code, National Electric Code, National Fire Protection Association, Occupational Safety and Health Administration (OSHA), and the Environmental Protection Agency (Battelle 1995:24).
Hazardous Liquid Storage Building
The Hazardous Liquid Storage Building could be a 3.0-meter (10-foot) by 4.9-meter (16-foot) prefabricated building situated about 23 meters (75 feet) west of the HWTPF. Twenty 30-gallon containers, safety segregated by hazard, could be stored in this structure. The liquids stored would be used for the neutralization of certain wastestreams, including hydrochloric acid, sulfuric acid, phosphoric acid, glacial acid, and nitric acid. The structure would be heated to a minimum of 10 °C (50 °F), would have a secondary containment which would drain into a sump, and would utilize a mechanical ventilation system to ensure that hazardous fumes are not present (Battelle 1995:24-25).
H.3.3.3 Environmental Considerations
This facility would meet all present environmental codes and regulations, and its normal operation would not have cumulative or long-term adverse effects on the environment. Operation of this facility would be in compliance with Federal and State pollution control standards. Permitting requirements for the protection of the air, water, and environment would be readdressed prior to operation of this facility (DOE 1995:I.E 37-40).
The HWTPF conceptual design report for the bounding alternative has established the following schedule: air permit, 6 months; water permit, 6 months; and waste permit, 6 months. If the permits are handled as expected, the consolidated effort would occur within one year. If funding is delayed by one year, the permit modifications would likely begin a year or so later (DOE 1995:I.E 40).
The design of this facility includes an energy conservation analysis. A reduction goal of 10 percent in the average annual energy requirement per gross square foot has been established. Executive Orders 12003 and 12902 and the Pantex Fuel Policy will be followed. The design of the facility includes requirements of 10 CFR 435, Energy Conservation Voluntary Performance Standard for New Buildings; Mandatory for Federal Buildings, as amended. Appendix G, Pollution Prevention and Waste Minimization, presents an additional discussion of water and energy conservation (DOE 1995:I.E 35-36).
H.3.3.4 Health and Safety
This facility would operate under an approved Final Safety Analysis Report. The building would be protected by an automatic fire suppression system, alarms, emergency lighting, and fire extinguishers. The process areas would be kept under negative pressure and surfaces would be specially protected for minimizing releases. Airlocks, HEPA filters, emergency showers, eyewash stations, and requirements for personnel protective equipment would be utilized (DOE 1995:I.E 43-44).
H.3.3.5 Safeguards and Security
No special requirements are needed since the facility would not handle classified material or documents (DOE 1995:I.E 46).
H.3.4 Relationship to Other Projects
The bounding HWTPF would be constructed with a common dock area with the RCRA Hazardous Waste Staging Facility (currently under construction). The HWTPF would not be dependent upon the adjacent facility. Coordination of fire protection and other utilities and services would be accomplished (DOE 1995:I.C 1).
The High Pressure Fire Protection Water Supply System expansion project would coordinate with the HWTPF project (DOE 1995:I.C 1).
H.3.5 Environmental Impacts
H.3.5.1 Infrastructure
Electrical usage would increase from 411 to 598 megawatthours per year. No natural gas would be used at the facility. Steam usage would increase from 3.4 million kilograms per year (7.4 million pounds per year) to 4.5 million kilograms per year (9.9 million pounds per year). The steam generation would increase the use of water from 451,000 liters per year (119,000 gallons per year) to 564,000 liters per year (149,000 gallons per year). It would also increase the use of natural gas from 0.2 million cubic meters per year (7.1 million cubic feet per year) to 0.3 million cubic meters per year (9.5 million cubic feet per year) (PC 1995:Table 3).
H.3.5.2 Land Resources
The proposed building site is located between Zones 11 and 12 North adjacent to the recently constructed Hazardous Waste Staging Facility, which is surrounded by a buffer zone. The facility is designed to be 2,648 square meters (28,500 square feet). The facility would consolidate and improve operations and increase the safety to the worker, the public and the environment. No environmental impacts are expected from the proposed construction on the surrounding land resources (PC 1995:Table 1; DOE 1993:11).
H.3.5.3 Geology and Soils
There could be very minor impacts to the soils due to erosion during construction. The area of temporarily disturbed soil would be 5,295 square meters (57,000 square feet) (PC 1995:Table 1). Mitigation measures such as sediment traps, diversion of surface water runoff from the construction area, dikes, silt fences, and covering the disturbed area with rip rap would be used to minimize soil erosion.
H.3.5.4 Water Resources
Water use is expected to increase from 685,000 liters per year (181,000 gallons per year) to 4,312,000 liters per year (1,141,000 gallons per year). The generation of wastewater is expected to increase from 685,000 liters per year (181,000 gallons per year) to 3,802,000 liters per year (1,006,000 gallons per year). The proposed facility construction site is not located within a known, playa-associated 100-year floodplain (PC 1995:Table 3; Battelle 1995:16, 88).
H.3.5.5 Air Quality
Airborne particulate matter (i.e., dirt and equipment emissions) levels would be elevated during the construction period. During operation, the facility design would minimize the possibility of any unplanned or nonsudden release of HW or HW constituents to the air (40 CFR 264.31). The RCRA facility design requirements include emission standards for process vents, equipment leaks, and containers (40 CFR 264 Subparts AA, BB, and CC). The design criteria include HEPA filters in the radioactive and hazardous waste processing areas ventilation systems, use of negative pressure, interlocked/alarmed air locks, radioactive and hazardous constituents ventilation system monitoring with alarms, and HEPA filter efficiency monitoring and testing (Battelle 1995:57-58). Additionally, the fume level within the building would be limited by the Hazardous Waste Permit (HW-50284). The permit would stipulate the number of waste containers that can be opened at any one time (DOE 1993:11).
Air emissions from current waste management activities are addressed in section 4.7, Air Quality. Waste management air emissions result from drum handling and processing, bulk transport, and fugitive emissions. Hazardous air pollutants include chlorinated solvents like trichloroethane, aromatic solvents like toluene, xylene, ketones, alcohols, ethers, and other organic solvents. Impacts of these activities and air pollutants were modeled and the results were presented in section 4.7.2.1 of volume I, Impacts of Continued Operations. The HWTPF through consolidation and use of state-of-the-art emission control equipment would impact the environment to a lesser degree.
H.3.5.6 Acoustics
Noise levels would temporarily increase during construction from operation of heavy construction equipment such as graders, cement mixers, and construction vehicle traffic. During waste handling operations, noise would be emanating from forklift operations and loading dock operations. Local worker and transportation traffic would contribute to the ambient noise in the area. The majority of the noise sources are expected during the operation of the HVAC system and other processing equipment which includes a waste compactor, a drum crusher, and an aerosol can puncturing station (Battelle 1995:75-76). The operational areas design will include noise controls pursuant to OSHA standards (29 CFR 1910.95).
H.3.5.7 Biotic Resources
Flora and fauna that currently use the facility construction site would be permanently removed or displaced by construction. The general site area has been disturbed by construction of the existing roads utilities and plant activities including the RCRA Hazardous Waste Staging Facility Treatment (Battelle 1995:73). The building site does not contain any unique, unusual, or critical habitats for known threatened or endangered species, nor does it adversely restrict known or established migratory corridors used by wildlife (DOE 1993:10; Battelle 1995:73).
H.3.5.8 Cultural Resources
No archaeological sites or historical resources have been identified in or near the proposed construction site (Battelle 1995:80, 81).
No decisions have been made regarding use of existing facilities that may qualify as a historic resources. The decision to reuse, modify, or demolish will be addressed in future NEPA documentation.
H.3.5.9 Socioeconomic Resources
The construction cost of this facility would be approximately $13.5 million. Construction of the facility is expected to employ 129 short-term employees and would probably result in a small temporary increase in local employment (Battelle 1995:85; PC 1995:Table 1). A substantial portion of the material costs would enter the wholesale and retail trade sector of the regional economy. Approximately 25 to 30 percent of this cost would be labor in all aspects of the construction process. This facility is designed for 20 employees. Five of the employees are considered new employees and would represent 0.16 percent of 3,800 employees currently working at Pantex Plant (Battelle 1995:85-86).
H.3.5.10 Transportation
The construction of this facility would result in a temporary increase in onsite and area traffic during a 12- to 18-month period. Normal day shift work hours, Monday through Friday, are expected. Since construction of the facility is in a Limited-Access Area, plant security personnel would accompany construction workers to and from the construction site. Wastes would be transported from several storage and accumulation areas in Zones 4, 11, and 12 and back to storage after treatment. Material supplies would be transported through Building 16-15 Central Shipping and Receiving. During operation, five new employees would travel to the plant from the local area. Impact analysis of onsite waste transportation is addressed in section 4.12 of volume I.
H.3.5.11 Waste Management
This facility is designed to handle approximately 500-700 cubic meters (650-910 cubic yards) of waste per year. The total volume handled annually is not expected to vary; however, the volume of each type (i.e., low-level mixed, low-level, and hazardous) of waste handled is expected to vary (PC 1996).
Annually, the amount of low-level mixed waste generated at the 2,000 weapons activity level (presented in table 4.13.1.2-3 from section 4.13, Waste Management, in volume I) is 183.2 cubic meters (239.6 cubic yards). A majority of these wastes could be expected to undergo some form of processing or treatment in the HWTPF before disposal as described in section H.3.2.1. The LLMW could undergo sorting and repackaging, waste sampling and certification, marking and labeling to meet Department of Transportation (DOT) requirements, waste compacting, etc. In addition, some waste streams may be solidified. Detailed descriptions of waste volumes by treatability groups and potential DOE treatment technologies, including offsite options, are presented, in whole or in part, in the following documents: 1996 Pantex Plant Environmental Information Document, Pantex Plant's Agreed Order Site Treatment Plan-Compliance Plan, and the April 1995 Draft Reference Document for the Hazardous Waste Treatment and Processing Facility (Pantex 1996a, DOE 1995e, Battelle 1995).
Annually, the amount of low-level waste and hazardous waste generated at the 2,000 weapons level (presented in table 4.13.1.2-3 from section 4.13, Waste Management, in volume I) is 249 cubic meters (326 cubic yards) and 191.6 cubic meters (250.5 cubic yards), respectively. A majority of these wastes could be expected to undergo some form of processing or treatment in the HWTPF before disposal as described in section H.3.2.1. The LLW and HW could undergo sorting and repackaging, waste sampling and certification, marking and labeling to meet DOT requirements, waste compacting, etc. In addition, some waste streams may be solidified (Battelle 1995:41, 42).
H.3.5.12 Human Health Risks
There would be no radiation risks during construction, since construction activities would not involve the use of any radioactive materials or waste. Chemical human health risks during construction would be mitigated through compliance with OSHA Chapter 1926 regulations and an approved project-specific health and safety plan. The Contractor Safety and Health Program requires a written plan for approval by the Fire, Waste Management, Industrial Hygiene, and Safety Departments. The plan establishes permits for safety, excavation, fire department, radiation work, confined space entry and hot work (e.g. welding) as necessary (Pantex 1992).
Potential sources of radiological exposures during operation would be limited to alpha-, beta-, and gamma-emitting materials like depleted uranium, thorium, and tritium. External and internal occupational exposure to radiation would be limited to the standards promulgated in DOE Order 5480.11. Through the use of engineering controls and administrative controls, personnel exposure would be as low as reasonably achievable (ALARA). Potential sources of chemical exposures during operations would be from HW, HW constituents, and chemicals and materials used in treating the waste. Personal protective clothing and equipment would be used to mitigate the potential health risks in compliance with 40 CFR 264 Subparts A, C, and D (Battelle 1995:94-96).
Section 4.14 of volume I bounds human health risks for the entire plant, including waste management operations. A detailed description of the human health risks of waste treatment-related activities is contained in the June 1995 Environmental Assessment for the Operation of the Glass Melter Thermal Unit at the U.S. Department of Energy's Mound Plant (DOE 1995d).
H.3.6 No Action Alternative
In the Draft Pantex Plant EIS, the proposed construction of the HWTPF was considered necessary for enhancing waste operational 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 volume I, section 4.13.2.3, and changes contained in the August 1996 Federal Facility Compliance Act (FFCA) Compliance Plan Annual Update document (DOE 1995e), construction of the HWTPF is no longer considered a regulatory requirement.
However, without the HWTPF, waste treatment and processing capabilities remain greatly limited and do not meet the Department's purpose and need. As a result, Pantex Plant would continue to conduct limited treatment and processing of wastes onsite at Building 11-9 and 11-7 Pad. Pantex Plant would continue to rely on offsite contractors and facilities to treat and process waste for offsite disposal. The current waste management practices would continue as would the currently identified problems. Section 4.13 of volume I contains detailed descriptions of the current waste management practices and associated impacts.
H.3.7 Proposed Action-A Scaled Down Version of the Hazardous Waste Treatment and Processing Facility Alternative
The Proposed Action is the construction of a scaled down HWTPF. The proposed HWPTF would conduct the same treatment and processing of waste as the bounding alternative. The construction period would be expected to last 12 months. At an estimated cost of $5 million, the scaled down HWTPF would operate mainly the macroencapsulation and stabilization technologies, as well as the following waste management operations: LLW and LLMW sorting/repackaging, LLW and LLMW sampling, LLMW drum crusher, LLMW aerosol can-puncturing station, LLW and LLMW compactor, LLW wastewater solidification, HW sorting/repackaging/sampling, HW aerosol can puncturing station, HW compactor, HW drum rinsing system, and HW solvent recovery. The lifecycle is assumed to be 10-15 years less than the bounding alternative facility (PC 1996). Section 4.13 of volume I contains detailed descriptions of the current waste management practices and associated impacts.
This facility would utilize design features and administrative controls to protect employees and the environment and would meet all present environmental codes and regulations, as well as pollution control standards. Its normal operation would not have cumulative adverse effects on the environment. However, modifications to air, water, and waste permits are expected. Air and water permits are usually reviewed and approved within 6 months. Since this would involve new treatment processes being implemented and current processes occurring in a new facility, the site's Hazardous Waste Permit would have to be modified. Under the current permit, these types of changes are categorized as major changes to the permit. Review and approval of waste permits can last more than two years for major changes. Additionally, preparation of the permit modification requires several months. Detailed design reports and facility plans are required and public meetings would be held to address concerns and justify the adequacy of the permit modification.
H.3.8 Alternatives Eliminated from Detailed Study
Three alternatives were eliminated from detailed study. The use of temporary facilities to conduct waste treatment was not considered practical since RCRA requires extensive design features including secondary containment, emission controls, safety requirements, and fire protection. The modification of the existing treatment facility, Building 11-9, was not analyzed extensively since impacts are considered equal to or greater than moving to a newer facility. Additionally, Building 11-9, a wood structure, was built in 1944 and would require historical preservation coordination. The third alternative requires total offsite management of the waste. However, offsite treatment capacities are subject to change.
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