Appendix C
Excerpt from the Committee’s Interim Report: Chapter 5

This appendix consists of an excerpt from the committee’s interim report (Box C1). This report focuses on the July 2001 draft of DOE’s proposed characterization plan (NRC, 2001 b).

BOX C1 Excerpt from the Committee’s Interim Report: Chapter 5

5

Committee’s Preliminary Findings and Recommendations

The following are the committee’s preliminary findings and recommendations concerning DOE’s proposed characterization plan for RH-TRU waste. The committee also provides observations and issues for further clarification to help DOE in future drafts of the plan’s supporting documents. As noted previously, findings and recommendations specific to Document 1 and Document 2 are based on the July 2001 draft.

Finding 1: With this new characterization plan for RH-TRU waste, DOE has an opportunity to introduce a truly performance-based characterization plan containing only requirements relevant to the long-term performance of WIPP and that have a safety, technical, or legal basis. Recommendation: DOE should not include in its characterization plan unnecessary requirements that do not affect the long-term performance of the repository and that do not have a safety, technical, or legal basis.

Rationale: The committee observes that characterization requirements for RH-TRU waste do not yet formally exist. Characterization requirements specific to RH-TRU waste will be finalized after DOE submits its characterization plan to EPA and NMED. The only legal requirements applying specifically to RH-TRU waste are those in the Land Withdrawal Act (see Chapter 3).

When DOE first applied for the certification of WIPP in 1996, it proposed a characterization plan for both CH- and RH-TRU waste. To facilitate the certification process, DOE imposed extra characterization requirements in the CH-TRU waste characterization plan, which was accepted by EPA and NMED (National Research Council, 2001, Appendix A1). DOE failed to realize that those characterization requirements would become a burden for the generator sites.1 Also, DOE did not foresee that characterization requirements for CH-TRU waste would become a standard against which to evaluate the RH-TRU characterization plan. In fact, according to the information gathered by the committee, EPA and NMED intend to compare RH-TRU waste characterization requirements to those in the CH-TRU waste characterization plan, as explained in Chapter 4.

The draft RH-TRU waste characterization plan may be following the same path as the CH-TRU waste characterization plan. That is, by wanting to facilitate the certification process for RH-TRU waste, DOE is failing to ask the most important question about the characterization of RH-TRU waste: what is the purpose of waste characterization for WIPP? The answer is the following: to evaluate the impact of waste components on the long-term performance of the repository. The



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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report Appendix C Excerpt from the Committee’s Interim Report: Chapter 5 This appendix consists of an excerpt from the committee’s interim report (Box C1). This report focuses on the July 2001 draft of DOE’s proposed characterization plan (NRC, 2001 b). BOX C1 Excerpt from the Committee’s Interim Report: Chapter 5 5 Committee’s Preliminary Findings and Recommendations The following are the committee’s preliminary findings and recommendations concerning DOE’s proposed characterization plan for RH-TRU waste. The committee also provides observations and issues for further clarification to help DOE in future drafts of the plan’s supporting documents. As noted previously, findings and recommendations specific to Document 1 and Document 2 are based on the July 2001 draft. Finding 1: With this new characterization plan for RH-TRU waste, DOE has an opportunity to introduce a truly performance-based characterization plan containing only requirements relevant to the long-term performance of WIPP and that have a safety, technical, or legal basis. Recommendation: DOE should not include in its characterization plan unnecessary requirements that do not affect the long-term performance of the repository and that do not have a safety, technical, or legal basis. Rationale: The committee observes that characterization requirements for RH-TRU waste do not yet formally exist. Characterization requirements specific to RH-TRU waste will be finalized after DOE submits its characterization plan to EPA and NMED. The only legal requirements applying specifically to RH-TRU waste are those in the Land Withdrawal Act (see Chapter 3). When DOE first applied for the certification of WIPP in 1996, it proposed a characterization plan for both CH- and RH-TRU waste. To facilitate the certification process, DOE imposed extra characterization requirements in the CH-TRU waste characterization plan, which was accepted by EPA and NMED (National Research Council, 2001, Appendix A1). DOE failed to realize that those characterization requirements would become a burden for the generator sites.1 Also, DOE did not foresee that characterization requirements for CH-TRU waste would become a standard against which to evaluate the RH-TRU characterization plan. In fact, according to the information gathered by the committee, EPA and NMED intend to compare RH-TRU waste characterization requirements to those in the CH-TRU waste characterization plan, as explained in Chapter 4. The draft RH-TRU waste characterization plan may be following the same path as the CH-TRU waste characterization plan. That is, by wanting to facilitate the certification process for RH-TRU waste, DOE is failing to ask the most important question about the characterization of RH-TRU waste: what is the purpose of waste characterization for WIPP? The answer is the following: to evaluate the impact of waste components on the long-term performance of the repository. The

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report committee recommends that existing requirements for CH-TRU waste, when applied to the characterization of RH-TRU waste, should be evaluated on the basis of their impact on the performance of the repository. The existence of regulatory requirements in the CH-TRU waste characterization plan does not imply that the same requirements should be included in the characterization plan for RH-TRU waste. Finding 2: The committee questions the relevance of some of the requirements in the RH-TRU waste characterization plan to DOE’s stated objective. According to the performance-based evaluation of RH-TRU waste by Sandia National Laboratories, presented in the characterization plan, none of the RH-TRU waste components have an effect on the long-term performance of the repository. Recommendation: DOE should evaluate characterization requirements in the proposed plan against safety, their impact on the performance of the repository, and regulatory compliance. Rationale: The committee questions the relevance of some of the requirements proposed in the characterization of RH-TRU waste. For example, the detection of prohibited items, the determination of metal content, and the attribution of waste summary category groups do not seem to be characterization requirements based on the long-term performance of the repository (see examples below). According to the performance-based evaluation of RH-TRU waste by Sandia National Laboratories (Appendix 1 of Document 1 and Attachment B of Document 2), none of the RH-TRU waste components have an effect on the long-term performance of the repository. Many of the requirements in the proposed characterization plan of RH-TRU waste derive from the CH-TRU waste characterization plan described in WIPP’s RCRA permit and EPA’s certification. Concerning the CH-TRU characterization plan, the 1998 Committee found that “many requirements and specifications concerning waste characterization and packaging lacked a safety or legal basis”2 (National Research Council, 2001, page 4). The present committee also recognizes that many such requirements were self-imposed and should be removed from the characterization plan of RH-TRU waste. The committee acknowledges that DOE’s approach to use mostly AK without requiring 100 percent confirmatory activities is a positive step in this direction. However, the characterization plan’s supporting documents should provide an analysis of the legal and safety requirements proposed for RH-TRU waste on the basis of their impact on the performance of the repository. Of course, legal requirements, like those in the Land Withdrawal Act, cannot be changed or removed, but these legal requirements are few and not excessively restrictive. The committee provides the following examples to support this finding and recommendation: Example 1: The list of prohibited items contained in the RCRA permit for CH-TRU waste may not be appropriate for RH-TRU waste when the risks associated with hazardous chemical waste are balanced against radiological risks and costs. In Documents 1 and 2, there is no analysis of the safety implications of the prohibited items in WIPP. It is important to analyze the yet-undefined safety implications of these prohibited items and balance these implications against potential radiological risks to workers and associated costs of identifying prohibited items in RH-TRU waste. Such an analysis would be helpful to DOE in comparing the risks workers are exposed to and the associated costs of characterizing RH-TRU waste for prohibited items. The results of the analysis will support and strengthen DOE’s RH-TRU waste characterization plan or point out deficiencies in it. Example 2: In the CCA, DOE wrote: “Ferrous and ferrous-alloy metals (and their corroded products) provide the reactants that reduce radionuclides to lower and less-soluble oxidation states. As discussed in Appendix WCA [Waste Characterization Analysis], the anticipated quantity of these metals to be emplaced in WIPP is two to three orders of magnitude in excess of the quantity required to assure reducing conditions. The waste containers supply more than enough iron to provide adequate reductant. Therefore, no upper or lower limit need be established for the quantity of ferrous and ferrous-alloy metals that may be emplaced, beyond the present projection of containers” (DOE, 1996a, Appendix WCL.2). Nonetheless, in the CCA, DOE imposed a lower limit for ferrous material in the repository at 2×107 kg. Nowhere else in the CCA is this limit discussed or justified. This self-imposed limit has somewhat severe consequences because it requires DOE to use steel containers throughout the disposal phase. This example of

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report a self-imposed requirement is acknowledged by DOE-CBFO itself. In fact, DOE informed the committee of its intention to request the elimination of this limit during the re-certification process (DOE-CBFO, 2001f). Example 3: Waste summary category groups indicate the final form of the waste as it is emplaced in WIPP. These groups are: homogeneous waste, soils and gravel, and debris waste. The CH-TRU waste requirements for NMED direct DOE to attribute a summary category group to each waste container. However, this information does not have any impact on the long-term performance of the repository. According to the information gathered thus far, this information is not used by NMED in any type of decision-making process concerning RH-TRU waste in the repository. Therefore, the committee questions why this requirement is being included in the RH-TRU waste characterization plan. A similar recommendation was made by the Institute for Regulatory Sciences peer review on DOE’s characterization plan.3 Finding 3: The RH-TRU waste draft characterization plan reviewed by the committee does not clearly present DOE’s stated objective of characterizing waste based on its impact on performance of WIPP, while protecting worker safety, reducing costs, eliminating unnecessary self-imposed requirements, and complying with regulatory requirements. In the committee’s opinion, the documents reviewed do not put forward a performance-based characterization plan. Recommendation: In the supporting documents, DOE should clarify the objectives of the characterization plan and how to achieve them. Rationale: DOE presented the objectives of its characterization plan for RH-TRU waste during the two information-gathering meetings with the committee. The committee expected these objectives to be clearly presented and pursued in Documents 1 and 2, but this was not the case. Document 2 mentions that DOE’s characterization plan adopts a “Performance-Based Measurement System” but the committee struggled to find a clear explanation of this concept and its implementation in the supporting documents. The committee found a clear explanation of a “performance-based characterization plan” in EPA’s Compliance Application Review Document No. 24, concerning waste characterization. This document reads: “DOE must provide waste inventory information for use in the performance assessment, including the radionuclide content of waste and the physical and chemical components that may affect disposal system performance” (EPA, 1998, page 21–1). EPA also defines a “waste characteristic” as “a property of the waste that has an impact on the containment of waste in the disposal system” (40 CFR 194.2). DOE’s stated objective is in agreement with EPA’s statements concerning waste characterization. However, the supporting documents do not explicitly outline the state objectives and the way DOE intends to implement its “performance-based characterization plan.” The committee acknowledges that, in Attachment B of Document 1 and in Appendix 1 of Document 2, DOE provides two performance assessment analyses of RH-TRU waste in WIPP. However, these analyses and the performance assessment tool are not fully used to support a performance-based characterization plan. The performance assessment tool played a central role in WIPP’s certification process. If the characterization plan were properly built upon performance assessment results, it would be easier for EPA and NMED to assess the plan and it could add credibility to the proposed characterization approach. Finding 4: From the information gathered during the two committee meetings, it appears that most of the RH-TRU waste to be disposed of at WIPP will be newly generated waste, repackaged waste, or waste that has already been characterized following the CH-TRU waste characterization plan. Therefore, most RH-TRU waste does not need confirmatory measurements because the information collected during repackaging or generation can meet characterization requirements. Recommendation: In the documents supporting its characterization plan, DOE should discuss the relative volumes of retrievably stored waste and newly generated waste in the context of the different qualities of AK. DOE should also consider the impact of these volumes and AK differences on the characterization plan. Rationale: According to DOE, about 80 percent of the RH-TRU waste inventory will be waste to be generated in the future or existing waste that must be repackaged (see Chapter 2). For this

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report large amount of waste, the information constituting AK will be collected during the generation or the repackaging of the waste. The committee agrees with DOE that AK for newly generated waste can meet the data quality objectives developed under the new RH-TRU waste characterization plan. Therefore, for about 80 percent of RH-TRU waste, confirmatory measurements may not be necessary as long as this waste is generated or repackaged using the approved quality assurance program plan. Documents 1 and 2 do not mention that over 80 percent of the RH-TRU waste inventory will be newly generated or newly packaged waste. The committee recognizes that DOE made the distinction between the two qualities of AK (Attachment A, Document 1) for newly generated waste and retrievably stored waste. However, the committee suggests that the waste characterization plan distinguish not only AK qualities but also the relative volumes of newly generated waste and retrievably stored waste. This information may help DOE, the regulatory agencies, and the public to frame the context of the characterization plan for RH-TRU waste. If the volume of RH-TRU waste represents between 1 and 4 percent of the volume of TRU waste, and 80 percent of RH-TRU waste will meet AK, then only between 0.2 and 0.8 percent of the waste will need confirmatory activities for AK. This is an important observation, and it could have a substantial impact on characterization requirements proposed for RH-TRU waste. Finding 5: There is substantial variability among RH-TRU waste generator sites, including: variability in the composition of the waste streams, variability in the extent of AK available, variability in the characterization and repackaging facilities available, and variability and uncertainties in the current and projected inventories of RH-TRU waste. DOE’s current characterization plan allows some flexibility to the sites, but it does not account explicitly for the above variability. Recommendation: The RH-TRU waste characterization plan should recognize the large variabilities from site to site and should ensure sufficient flexibility to accommodate them. However, characterization activities that share common elements across sites should be standardized.4 Rationale: The committee received the information about the RH-TRU waste inventories during its two information-gathering meetings. These data are reported in Tables 1 and 2 in Chapter 2. This information is barely present, as supplemental information, in Document 2. in the supporting documents, the committee expected a discussion about RH-TRU waste inventories at the different generator sites, their characterization plans, and capabilities. Including this discussion in Documents 1 and 2 could help DOE to recognize both the large variances from site to site and common elements across sites. Flexibility is important to adapt each characterization requirement to the site’s RH-TRU waste inventory and characterization facilities. A rigid, overly prescriptive characterization plan may lead to unnecessary radiation exposures to workers and characterization costs. For example, small sites that do not have adequate characterization facilities may find themselves in a difficult situation if the characterization plan mandates specific confirmatory activities, even in the presence of adequate AK. If the site must perform confirmatory measurements or visual examination in a hot cell it would have to ship its waste to a different site equipped with a hot cell or use a mobile hot cell. Therefore, the added costs of such confirmatory measurements could be significant. The committee also recommends that common elements among the sites be standardized to facilitate characterization compliance verifications and, possibly, reduce characterization costs. Finding 6: The requirements to qualify information collected on each waste stream, whether by AK or by any other method described in 40 CFR 194.22(b), have not been established with any specificity in the supporting documents. Recommendation: DOE should revise the supporting documents by adding clear and technically defensible data qualification requirements for its RH-TRU waste characterization plan. Additionally, each data quality objective should have a safety, technical, or legal basis.

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report Rationale: To optimize waste characterization activities, it is important to define how generator sites will use AK, radiography, or visual examination to characterize their RH-TRU waste streams, the data qualification requirements, and the procedures to meet those requirements. This recommendation is also consistent with the recommendation of a second peer review on DOE’s characterization plan.6 The committee provides below an example of a missing or an unclear technical basis for one of the data quality objectives in Document 1. Example: In Document 1, DOE does not provide a technical basis for the requirement that the quantification of the total activity “must be within a factor of 5 of the true value, with a confidence value of 95 percent.” DOE provided an explanation during an information-gathering meeting: “The need to accumulate information regarding the total activity of RH-TRU waste is driven by limits set forth in the Land Withdrawal Act. The Land Withdrawal Act limits are derived from original DOE estimates about the RH-TRU inventory. The Transuranic Waste Baseline Inventory Report indicates that the total RH-TRU inventory to be disposed of at WIPP corresponds to a total activity of approximately one million curies (TWBIR, 1996). This corresponds to approximately one-fifth of the Land Withdrawal Act limit (5.1 million curies), hence the factor of five. Allowing an uncertainty of a factor of five (with a confidence level of 95 percent or greater) ensures that, even if the cumulative measurement of the estimated one million curies of RH-TRU waste activity were offset by a factor of five and biased low, the Land Withdrawal Act limit would not be violated (Nelson, 2001). The committee observes that, just because DOE expects to emplace one-fifth of the curies specified in the Land Withdrawal Act, this does not justify a requirement that the measured activity for a unit be within a factor of five of the “true value.” Finding 7: Available estimates of worker exposure and characterization costs for RH-TRU waste are scarce and may not be representative of all RH-TRU waste generator sites. Recommendation: To better develop and support its characterization plan, DOE should provide more detailed and site-specific estimates of worker exposure and characterization costs for RH-TRU waste. The characterization plan should clearly demonstrate how it minimizes radiation exposure to workers and associated costs. Rationale: Since the characterization plan for RH-TRU waste is not yet finalized, information on worker exposure and characterization costs for RH-TRU waste is scarce. The only data available are from BCL and LANL, and they may not be representative for all RH-TRU waste generator sites (see Chapter 2). However, exposure and cost estimates can be calculated quite well, particularly if the uncertainties become a part of the results. The committee found the risk/cost impact study in Document 2 (Supplemental Information) to be very informative. However, this study only considered three characterization scenarios to estimate exposure risks and costs: the full characterization used for CH-TRU waste (see Appendix A), AK only, and visual or radiographic examination. A detailed risk perspective of worker exposure and costs could be very illuminating in developing characterization requirements and in adding credibility to the plan. The approach to estimate exposures would be to structure different scenarios, rank the scenarios on the basis of the supporting evidence, and calculate the exposures and doses. This type of dose and exposure information would add much to the discussion of the differences between CH-and RH-TRU waste characterization plans. An equivalent approach could be adopted to better estimate characterization costs. A similar recommendation was also provided by Restrepo and Millard.7 Finding 8: DOE’s characterization plan calls for application of specific technologies, such as X-ray radiography, to provide confirmatory data. The committee could not determine the effectiveness of these technologies in characterizing the high-dose-rate fraction of RH-TRU waste containers. Recommendation: DOE should provide complete and defensible justification for the technologies proposed for obtaining confirmatory data and provide evidence of their effectiveness. Rationale: DOE specifically mentions “X-ray scanning of waste containers to identify and verify waste contents” (Document 1, Attachment A, page 15). Given the importance placed on radiography to determine the presence of prohibited items, the characterization plan should clarify

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report and support the information on the method’s effectiveness in high radiation fields expected for RH-TRU waste. In general, DOE should provide complete and defensible justification for the technologies proposed for obtaining confirmatory data and provide evidence of their effectiveness. This issue was also raised by NMED during the committee’s information-gathering meeting (Zappe, 2001). This recommendation is also consistent with a recommendation by the RSI peer review on DOE’s characterization plan.8 DOE also concurs on this matter by stating: “Though DOE collected some data and analysis indicating that there are no fundamental obstacles to radiographing RH-TRU wastes, there has not been a systematic demonstration of that capability. As a consequence, there is lingering doubt regarding its feasibility in general. The simplest means to put these doubts to rest is to design and perform a systematic evaluation” (Taggart, 2001 e). The committee supports this suggestion. Observations and Issues for Further Clarification To improve understanding, corroborate, and add credibility to its characterization plan, DOE should clarify the following points in its supporting documents: Observation 1: The committee observes that the information in the supporting documents for the RH-TRU waste characterization plan is sometimes convoluted, difficult to understand, difficult to find, and repetitious. Examples are provided below. Example 1: DOE presents an analysis that shows that the gamma-emitting radionuclides in RH-TRU waste will have a minimal impact on the long-term performance of the repository. DOE also presents an analysis that shows that RH-TRU waste components (metals, free liquids, cellulosics, plastic, rubber, and hazardous material) will have a minimal impact on the repository performance. These analyses are presented in Attachment B of Document 1 and in Appendix A of Document 2, respectively. The body of the text supporting the characterization plan barely refers to these two key analyses. DOE should give these analyses a more prominent role in Documents 1 and 2 and explicitly refer to these analyses to support its characterization plan. Example 2: Some aspects of the characterization plan are difficult to evaluate because terms such as “representative selections” and “appropriate samples” are not properly defined. Example 3: The plan, as described in Documents 1 and 2, lacks specificity. For example, for the CPR and free water, when is AK and when is radiography employed? Are surveys conducted by the same mechanisms for lower and higher surface dose rates? What is the link between the surface dose rates and the total curies by waste stream? How is a waste stream determined to be suitable for disposal at WIPP (i.e., transuranic waste of defense origin)? How are the ten radionuclides important to the long-term performance of WIPP (see Sidebar 2) identified and quantified? Observation 2: There are conflicting statements and discrepancies between Document 1 and Document 2. The committee acknowledges that the two documents address different agencies and requirements. However, to improve the understanding and add credibility to its characterization plan, the documents could be made consistent with each other and conflicts and discrepancies resolved whenever possible. The committee provides three examples of conflicts or discrepancies between Document 1 and Document 2. Example 1: Document 1 states that the differences between the RH- and CH-TRU characterization plans are not significant: “Because the RH-TRU waste characterization program does not represent a significant change to the existing certification, the 40 CFR 194 process will be the compliance mechanism for obtaining EPA’s approval of each individual TRU waste site for disposal of its RH-TRU waste at WIPP” (Document 1, EPA01 Notice, page 6). However, Document 2 finds the differences significant: “The proposed modification is classified as a Class 3 permit modification per 20.4.1.900 NMAC…As indicated above, the additional provisions being requested in this permit modification, deemed necessary to provide for management, storage, and disposal of RH-TRU wastes, are indeed substantial and therefore meet the criteria and intent of a Class 3 modification” (DOE, 2001b).

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report Example 2: In Document 2, DOE allows for estimates of CPR, metals, and volatile organic compounds in the characterization of these waste constituents. Yet, DOE requires measurements without any specification of allowable uncertainties of the quantities of free water. This appears to be in conflict with the analysis in Document 1, Appendix A, which concludes that the performance of the repository is insensitive to the water content of the waste. Example 3: Some of the statements made in Document 2 appear to contradict the approach to waste characterization discussed in Document 1. For example, on page 2–5 of ITEM 2, Document 2, DOE states: “This demonstrates that the waste material parameter weights and amount of free liquid for RH-TRU waste are not needed to ensure the integrity of the repository; therefore, waste characterization activities to identify these parameters are not necessary.” Yet in Document 1, DOE lays out a program to measure the amount of free liquid in each waste container. The supporting documents should clearly specify that free liquid limits are necessary to meet transportation requirements and are not directly relevant to repository performance. Observation 3: It is not clear how visual examination and radiography can differentiate all prohibited from non-prohibited items. For example, visual examination and radiography cannot distinguish between corrosive and non-corrosive liquids, whereas AK may provide records of the existence of such liquids in the waste. Therefore, AK may be a better indicator of some of the currently prohibited items than visual examination and radiography. Closing Remarks The statement of task directs the committee to provide recommendations based on scientific and technical considerations. The committee recognizes that some of its recommendations may not be implemented because of regulatory or policy decisions, which may not be based on scientific or safety considerations. These decisions ultimately belong to the regulatory agencies. The committee acknowledges and supports DOE’s endeavors to improve worker safety, reduce costs, and eliminate unnecessary self-imposed requirements. However, the documents prepared for EPA and NMED to present the characterization plan for RH-TRU waste do not address these goals as effectively as they could. The committee acknowledges that DOE has been extremely responsive in revising the characterization plan on the basis of discussions during the information-gathering meetings. Also, staff of DOE-CBFO efficiently provided additional information whenever requested. The committee looks forward to future drafts of the characterization plan for RH-TRU waste. The committee will hold two more meetings to discuss the next draft of the characterization plan (if available), further address issues identified in this interim report, and develop its final report, which will be issued in the summer 2002. 1   DOE, during the second committee meeting, declared that the “contact-handled TRU waste characterization program is inefficient and costly” (DOE-CBFO, 2001d). 2   According to the 1998 Committee, the requirements that do not have a technical basis are: sampling and analysis of homogeneous waste, headspace gas sampling and analysis, and visual examination procedures to characterize CH-TRU waste (see Chapter 4). 3   The RSI peer review recommended: “DOE should evaluate the necessity of identifying waste streams by EPA’s Hazardous Waste Numbers or Characteristics. If there is no impact on WIPP performance and integrity, the DOE should work with the regulatory agencies to remove this requirement” (RSI, 2001, page 77). 4   According to the information provided by DOE, DOE is already amending its characterization plan to standardize as much as possible common elements across the complex. 5   Shipments from site to site are allowed before the waste characterization plan is approved because DOE’s waste characterization plan applies only to waste shipped to WIPP. 6   The RSI recommended the following: “A detailed procedure for determining whether there is sufficient AK available on a waste should be developed as part of the permit application. This procedure should be consistent across all waste generating sites…[A] detailed procedure should be provided to go to other characterization methods if AK is found to be insufficient” (RSI, 2001, page 77).

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report 7   The authors of the risk/cost analysis study in Document 2 recommend that “a detailed risk/cost impact analysis should be performed for individual site generators to quantify waste characterization option costs, potential worker dose rates, worker risks, and overall impact. This would facilitate a more rigorous evaluation of risks and costs for characterization options” (Restrepo and Millard, 2001, page iii). 8   In its peer review, the RSI recommended: “More detail and specificity on WAC [waste acceptance criteria] using AK, VE [visual examination], and radiography (including types of instrumentation to be used) should be provided in the permit application” (RSI, 2001, page 77). NOTE: References in this appendix apply to the committee’s interim report (NRC, 2001b).