Hanford Site Hazardous waste determination report for transuranic debris waste streams NPFPDL2A

This hazardous waste determination report (Report) describes the process and information used on the Hanford Site to determine that waste stream number NPFPDLZA, consisting of 30 containers of contact-handled transuranic debris waste, is not hazardous waste regulated by the Resource Conservation and Recovery Act (RCRA) or the New Mexico Hazardous Waste Act. For a waste to be hazardous under these statutes, the waste either must be specifically listed as a hazardous waste, or exhibit one or more of the characteristics of a hazardous waste, Le., ignitability, corrosivity, reactivity, or toxicity. Waste stream NPFPDLZA was generated, packaged, and placed into storage between 1993 and 1997. Extensive knowledge of the waste generating process, facility operational history, and administrative controls and operating procedures in effect at the time of generation, supported the initial nonhazardous waste determination. Because of the extent and reliability of information pertaining to this waste type, and the total volume of waste in the debris matrix parameter category, the Hanford Site is focusing initial efforts on this and similar waste streams for the first shipment to the Waste Isolation Pilot Plant (WIPP). RCRA regulations authorize hazardous waste determinations to be made either by using approved sampling and analysis methods or by applying knowledge of the waste in light of the materials or the process(es) used. This latter approach typically is referred to as process knowledge. The Transuranic Waste Characterization Quality Assurance Program Plan (CAO-94-1010) for WIPP refers to acceptable knowledge in essentially the same terms; acceptable knowledge as used throughout this Report is synonymous with the term process knowledge. The 30 containers addressed in this Report were characterized by the following methods: Acceptable knowledge; Nondestructive examination using real-time radiography; Visual examination; and Headspace gas sampling and analysis. The initial nonhazardous waste determination was based solely on acceptable knowledge. Relevant administrative documents and operating methods in effect at the time of waste generation were reviewed, generator waste profiles and certifications were examined, and personnel interviews were conducted. The acceptable knowledge information and supporting data were further evaluated based on the results of nondestructive examination, visual examination, and container headspace gas analysis. In all cases, the physical examination processes supported the initial nonhazardous waste determination, and in effect served to validate and finalize that determination. Sections 2.0 through 5.0 of this Report describe in more detail the actions taken and conclusions reached with respect to this nonhazardous waste determination, The hazardous waste determination process described in this Report fully satisfies the requirements of 40 CFR 261, and the Memorandum of Agreement (MOA-June 16, 1999) signed by the U.S. Department of Energy (DOE) and the New Mexico Environment Department pertaining to the exchange of waste stream information