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Appendix J= Applicable or Relevant and ' ,•. ^• DOFJRLr2oo1-11 ,•- '<br />

Appropriate Requirements Rev. o l rnafi pA ^<br />

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Small quantities of waste may be generated from the placement of a barrier such as contaminated<br />

soils and cleanup debris generated during site preparation and construction. Wastes may also be<br />

generated during maintenance of the barrier. These wastes may or may not require treatment<br />

nrioria-^ to bz-disposaled at the ERDF. It is anticipated, however, that treatment to meet<br />

disoosal<br />

standards will be achievable.<br />

Wastes that will be left in place- unJer all comiinmcnt alternatices include residuals remaining in the<br />

61-cm (24-in.) concrete-encased tile sewer pipe drains located 13.7 m (45 ft) below grade.<br />

Limited characterization information (two "opportrmistic" samples of residual material on the skids<br />

of the robotic crawler, see Section 2.6) has shown that these residuals may contain quantities of<br />

transuranic (alpha-emitting transuranic isotopes with half-lives greater than 20 years)•<br />

radionuclides in concentrations greater than 100 nanocuries per gram of waste. Wastes<br />

exceeding these eoncentrations-.ea3led arc classified as TRU waste, and must be disposed to the<br />

Waste Isolation Pilot Plant deep geologic repository. However, under all of the disposal<br />

alternatives, the drain lines will be filled with grout to ensure that a preferential pathway for<br />

liquids is not left in place. The resulting solidified residuals would no longer meet the definition<br />

ofTRU waste and could be left in place. This assessment complies with various guidance' for<br />

concentration averaging of solidified waste matrices. Concentration averaging allows solidified<br />

waste to be based on the solidified nuclide activity divided by the volume or weight of the<br />

'For example, M.R.1Cnapp, U.S. Nuclear Regulatory Commission to Commission Licensees. "Issuance orFinat<br />

Branch Technical Position on Concentration Averaging and Eneapsulation, Revision in Part to Waste Ctassifcalion<br />

Technical Position," dated January 17,1995.<br />

Final FearibilirySrudyjor the Canyon Dispos!lion Initiative (221-U Faeiliry)<br />

fi,y4tttt"49(31SeptemtxrZLOl J-S 1<br />

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