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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report
regulatory requirements into one document to guide generator sites in the development of their characterization programs.
5.5Overall Assessment of DOE’s Characterization Plan
The committee observed a net improvement between the July 2001 and March 2002 drafts of the characterization plan. Concerning the plan’s technical soundness, DOE itself recognized that this plan is not completely performance based and that several other considerations played a role in the development of this plan. The committee identified some characterization activities lacking technical bases in the context of RH-TRU waste and a potential technical problem with radiographic examination of waste. Also, DOE’s proposed characterization plan does not adequately address the issue of tolerable decision error rates associated with all characterization information.
In some instances, the plan lacks specificity because most of the operational details are site-specific and were not available at the time of writing. The site-specific accompanying documents should provide useful clarifications. In the context of RH-TRU waste characterization and from a performance point of view, the committee found that the general approach DOE is proposing is technically sound. However, Documents 1 and 2 do not present a performance-based plan as effectively as they could.
Concerning the plan’s protection of worker health and safety, the committee recommends that the approved characterization plan not include overly stringent tolerable decision error rates that could negatively impact the sites’ ability to manage worker risks. It is important to recognize that the allowable uncertainties in the final characterization plan approved by EPA and NMED may have an impact on generator sites’ radiation protection programs.
Concerning compliance with regulatory requirements in the EPA Certification and RCRA Permit, the committee did not observe any requirement that was not addressed in DOE’s characterization plan. In fact, the proposed characterization plan for RH-TRU waste addresses some requirements that are not under the relevant agency’s purview. Moreover, the characterization plan for RH-TRU waste deliberately tracks as close as possible that for CH-TRU waste. The committee recommends evaluating whether existing characterization practices for CH-TRU waste, when applied to the characterization of RH-TRU waste, have an impact on the protection of the environment, health and safety of public and workers, and cost-effectiveness of the characterization program.