131 LA UR 03 5862 - National Nuclear Security Administration ...

Chemical WasteWaste projections for the ER Project by the SWEIS ROD are uncertain at best. These projections weredeveloped in the 1996–1997 time period. Estimates were based on the then current Installation Work Planmethodology. The ER Project office kept a continuously updated database of waste projections by waste typefor each PRS. Estimates were made for the amount of waste expected to be generated by that PRS for thelife of the ER Project. In 1996–1997, it was assumed that the life of the ER Project would be 10 years, butthe schedule now projects cleanup will extend to 2020. This demonstrates the legitimate uncertainty in wasteestimates and schedules developed for the ER Project caused by changing requirements and refined wastecalculations as additional data were gathered.One task of the ER Project is to characterize sites about which little is known and to make adjustments inwaste quantity estimates based on new information. In addition, even the most rigorous field investigationscannot truly determine waste quantities with a high degree of certainty until remediation has progressedconsiderably. Remediation can often create more or less waste, or waste that was not anticipated, based onfield sampling. Moreover, the administrative authority may not approve a no further action recommendationor may require additional sampling or an alternative corrective action than the one planned. All of thesefactors lead to waste projections that are highly uncertain.An example of the latter is MDA-P. The first closure plan for MDA-P was submitted to EPA, and laterNMED, in the early 1980s. This plan proposed closure in place, but was never approved. During the mid- tolate-1980s, all parties (LANL, DOE, EPA, and NMED) decided that clean-closure was a more appropriatestandard and the plan was rewritten to reflect risk-based clean-closure. All information in the closure plan,including waste estimates, was based on best available information (a combination of operating group recordsand data from field investigations). However, when remediation started, it quickly became apparent that earlyinformation was not reliable, and that there would be more waste generated than originally anticipated. TheER Project clean closure of MDA-P began on November 17, 1997, and Phase I (i.e., waste management,handling, and disposal) and Phase II (i.e., confirmatory sampling) activities completed by April 2002. A totalof 20,812 cubic yards of hazardous waste and 21,354 cubic yards of other waste were excavated and shippedto a disposal facility. A total of 6,600 cubic yards were shipped and used as clean fill at MDA-J.Chemical waste quantities are higher than projections for two reasons: ER Project cleanup activitiesduring 1999, 2000, and 2001 and the Legacy Materials Cleanup Project during 1998. The variability in ERProject waste projections is discussed above. The Legacy Materials Cleanup Project, completed in September1998, required facilities to locate and inventory all materials for which a use could no longer be identified.All such materials (more than 22,000 items) were characterized, collected, and managed. In 1999, the Non-Key Facilities also exceeded projections, and this was attributed to ER Project cleanups of PRSs within theNon-Key Facilities. When comparing the subtotal of Key and Non-Key Facilities, only the Legacy Programin 1998 pushes the quantities over SWEIS ROD projections. Regardless, these wastes (both ER and LegacyProgram) were and are shipped offsite, do not impact the local environs, and do not hasten the need to expandthe size of Area G. High amounts of chemical waste at Non-Key Facilities are mostly due to new constructionand some expanded operations.SWEIS Yearbook—2002 4-9