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Executive Summary . . The U.S. Department of Energy (DOE) is responsible for the cleanup of defense- related transuranic waste across its weapons complex. The designated disposal facility for DOE's transuranic waste is the Waste Isolation Pilot Plant (WIPP), a geologic repository near CarIsbad, New Mexico.4 Transuranic waste can be classified as contact- handIed or remote-handIed based on the dose rate at the surface of containers (see Sidebar 1.2~. This report addresses only the characterization of contact-handIed transuranic waste. Federal and New Mexico laws require that generator sites gather and confirm existing information2 and, where necessary, acquire additional information on the physical, chemical, and racliological properties of transuranic waste to ensure that the waste contains only materials allowed to be shipped to and disposed of at WIPP. The waste characterization program consists of all characterization activities that are performed at generator sites to satisfy characterization requirements concerning radiological and hazardous properties of the waste set forth by WIPP's regulatory agencies: the U.S. Environmental Protection Agency (EPA), the New Mexico Environment Department (NMED), and the U.S. Nuclear Regulatory Commission (USN RC). After four years of shipping and disposing transuranic waste in WIPP, DOE has identified waste characterization as one of the most costly and time-consuming parts of the National Transuranic Waste Management Program.3 According to assessments by DOE, the cost of characterization and certification activities to prepare waste to be shipped to WIPP is estimated to be $3.1 billion, or approximately 16 percent of the $19 billion total costs for the disposal of transuranic waste.4 A more recent DOE cost estimate based on data from generator sites reported the average cost of characterizing a 55-gallon drum of transuranic waste destined for WIPP to be $3,900 (see Chapter 4~. In light of this assessment, DOE asked the National Research Council for advice on the current waste characterization programs for transuranic waste and for recommendations to increase the program's technical soundness, efficiency, cost effectiveness, and safety to workers and the public (the complete task statement is in Sidebar ~ . ~ ). ~Transuranic waste and WIPP are described in Chapter 1. 2Existing information about the waste becomes "acceptable" characterization information through a qualification process described in 40 CFR 194.22(b). This qualified information is then called "Acceptable Knowledge" (see Section 4.3 and Finding 4~. 3The program is a DOE system-wide approach to the management and disposal of transuranic waste stored and generated throughout the DOE weapons complex. DOE-Carlsbad Field Office manages this program. Information on the program is available on-line at: <http://www.wipp.ws>. 4This estimate does not take into account discount rates. 5The committee also discusses characterization-related parts of the transportation program. 1
2 Improving the Characterization Program for Contact-Handled Transuranic Waste ES.1 Statement of the Problem The contact-handIed transuranic waste characterization program is controversial. DOE, as well as the New Mexico Environmental Evaluation Group and previous National Research Council committees have suggested that some characterization activities may be too extensive, costs too high, and some of the information gathered may not be used to make any decision related to the protection of human health and safety or the environment. Previous National Research Council committees' language is discussed in Sections 1.2 and 5.9. On the other hand, stakeholders in New Mexico have argued that all the current characterization activities are necessary to ensure an adequate level of protection. DOE has informed the committee of its intention to propose changes to the characterization program to eliminate or modify activities that do not have an impact on human health and safety or the environment. However, DOE did not provide the committee with a formal analysis of the impacts of altering specific characterization activities on costs and risks to the public, workers, or the environment. The committee observes in Chapter 5 that a structured and quantitative analysis is necessary to determine whether a change to the characterization program is warranted and to justify proposed changes to the regulator~s), state and focal officials, and the general public. DOE is responsible for making the policy decision to seek regulatory approval for changes to a particular characterization activity. In Chapter 5, the committee provides the elements and illustrative applications (albeit incomplete) of a proposed structured and quantitative analytical framework that could be used to evaluate changes to specific characterization activities. ES.2 Finctings and Recommendations Several general observations underlie the committee's findings and recommendations. First, bringing WIPP to operational status is a significant achievement, given the technical and societal challenges of operating the first and only6 creep geologic repository for transuranic waste and the complex regulatory environment under which WIPP operates.7 During the development of the facility, WIPP has followed a regulatory path typical of many first-of-a-kind facilities with non-routine permits. In developing its transuranic waste characterization program, DOE proposed characterization activities to meet regulatory requirements.8 The regulatory agencies overseeing WIPP reviewed and approved the inclusion of these characterization activities in W! PP's proposed characterization program. The initial transuranic waste characterization program proposed by DOE to EPA and NMED was based on a conservative interpretation of regulatory requirements.9 6The Committee recognizes that WIPP is a unique facility for the deep geological disposal of transuranic waste and there are no plans for any other similar facilities in the United States. 7The committee identifies technical, societal, and regulatory challenges in Sections 1.5, 2.3, 2.4, and 3.4, respectively. The committee distinguishes between regulatory requirements (referred to as "characterization requirements") and the approach to meet such requirements ("characterization activities"~. The committee was not asked to comment on the regulatory requirements themselves or to provide other policy recommendations. 9That is, DOE introduced rigorous measures in its waste characterization program, including 100 percent sampling, redundant testing, and extensive confirmation of existing data for the purpose of compensating for the absence of experience in handling this aged waste. Such an approach is favored by regulators in general.
Executive Summary 3 The initial application of conservative requirements is not uncommon for a first- of-a-kincl regulated facility, in part because regulators and permittees have no direct operational experience on which to base decisions (see Sidebar 3.2~. As operational experience and analyses lead to better understanding, some characterization activities could be modified, reduced, or eliminated and others added. Before such changes can be made, the permittee must demonstrate to the regulator that the proposed changes can provide the required level of safety and meet regulatory requirements. DOE is following this approach for WIPP: requests to modify characterization activities have been submitted to NMED, EPA, and USNRC, the majority of which have been approved (see Section 3.3~. As previously noted, a complete analysis of the benefits and costs of each waste characterization activity is beyond the scope of this study and the commidee's capability. In the first finding and recommendation, the committee recommends steps that DOE can take to assess the value of characterization activities based on a structured and quantitative analysis and given the experience gained from four years of operations. In addition, the committee provides five other findings and recommendations that are operational in nature, that do not address specific characterization activities, some of which can be instituted without regulatory approval. Finding 1: DOE has stated that some characterization activities are too expensive and time consuming and can be modified without increasing risks while reducing characterization time and costs. However, DOE has not presented a systematic analysis to support this argument to the regulators or to the public. Although DOE has performed analyses of many aspects of operations related to WIPP performance, including transportation, the committee could find no studies that explicitly, systematically, and quantitatively link its waste characterization program to risks to the public, workers, or the environment. Recommendation 1: DOE should use a systematic and quantitative approach to determine the value of the information currently obtained by its waste characterization activities and the impact of changes to them. This approach should also be used to support permit modification requests and communicate with the public. The approach should include analyses of the following types: an assessment of the risks of transuranic waste handling, transportation, and disposal activities, including the current characterization activities; and an assessment of the impactsrisks, costs, and other impacts, including policy and societal impacts of changes to the current waste characterization activities. There are several approaches to achieve this goal. One example is a structured and quantitative analysis based on the value of characterization information collected. In the context of this report, the value of characterization information is determined by how much the information contributes to waste handling, transportation, or disposal decisions. If the information is used to make decisions about waste handling, transportation, or disposal, then it has an impact on the outcome of these decisions (for instance, on reducing risks, uncertainties, costs, or delays), and thus it has value. On the other hand if the characterization information is not used in current or future ctecisions, then it has no impact, and therefore it has no value (see Chapter 5~. DOE should use such an analytical approach to identify the connections between waste characterization, risks, and costs, and to determine which activities impact these connections. If weak connections are found, the same approach should be used to
i 4 Improving the Characterization Program for Contact-Handled Transuranic Waste develop a rationale to request changes from the regulators. These analyses should be published so that outside parties can evaluate the present characterization program and the rationale for proposed changes to the program. Within its constraints of time and information made available, the committee could only point out some of the risks to be included in this risk analysis (see Section 5.3~; a complete risk assessment is a major endeavor that the committee was not prepared to undertake. Based on the information provided by DOE and findings by a previous National Research Council committee, three characterization activities appear to be candidates for the complete application of the analytical framework proposed by the committee: 1. heacispace gas sampling and analysis, 2. 3. visual examination to cont~rm radiography results. homogeneous waste semolina and analysis' and . ~ , . .. . .. Finding 2: DOE now has four years of operational experience with the National Transuranic Waste Management program that can be used to improve waste characterization activities. Recommendation 2: DOE should use its increasing experience base and advances in technology to improve the current transuranic waste characterization program. The following are examples of potential improvement opportunities together with uses of information from an expanding operational experience base acquired thus far: . . Experience can be used to estimate the extent to which each characterization activity provides information that is: 1) essential to protect health and safety, 2) redundant with other activities or with historical knowledge of the waste, and 3) used to make decisions about waste handling, transportation, or disposal at WIPP. This information is to be used in the structured and quantitative analysis of the characterization program described in Chapter 5. Analysis of the characterization data acquired to date along with continuing characterization of increasingly diverse waste streams could identify new opportunities to use statistical sampling (rather than 100 percent of the waste stream) or different methods to confirm Acceptable Knowledge4° to provide information that would be as protective of health and the environment as the current measurements (see Sections 4.6.2 and 4.6.3~. Experience provides a basis for 'know-how' transfer from one generator site to others. The application and sharing of improvements in management methods acquired at generator sites thus far can achieve cost, schedule, and worker dose reduction across the DOE weapons complex (see Section 4.6.1 .1 ). Experience allows a better understanding of costs and their variability across the waste inventory and generator sites as well as a better understanding of the relative value of different characterization methods providing similar information (i.e., radiography versus visual examination). Understanding why characterization costs differ significantly from waste stream to waste stream and from site to site could also lead to better cost estimates for future waste streams (see Chapter 5~. Changes to the characterization program that would improve the characterization process, together with an expanding operational experience unacceptable Knowledge is a term used by the EPA that encompasses historical process knowledge and information from previous testing, sampling, and analyses of waste (see Sections 4.1, 4.3 and the Glossary).
Executive Summary 5 base, could help reduce both risks and costs. However, if new and more difficult or complex waste types have to be dealt with in the future, or more stringent cleanup standards are imposed by the regulators, then characterization costs could increase (see Section 5.4~. Fincting 3: Current characterization activities are applied generically to all waste types and, with few exceptions, are not tailored to particular waste streams. Recommendation 3: DOE should propose to its regulators a more flexible waste characterization program that can take into account the properties of different waste streams, allowing more efficient and effective waste characterization operations ., There are categories and subcategories of transuranic waste that may require different methods of characterization depending on whether they are existing wastes, wastes that pose special problems (see Sections 2.3 and 2.4), or to-be-generated wastes. The rationale for this finding is twofold: ~ ~ some waste streams, by the nature of their generation, their physical and chemical properties, and other special circumstances can be shown not to require the entire suite of characterization activities that are currently being carried out; and 2) current characterization methods or technologies are unsuitable for certain waste streams. Wastes generated in the future (to-be-generated waste) may be better characterized than existing waste, as a result of improvements in management methods, processes, and record keeping. Therefore, some to-be-generated waste streams may not require any, or as much, confirmation of the information collected at the time of waste generation. Recognizing the differences among waste streams and capitalizing on the opportunities that the improved waste characterization information affords, DOE could propose to its regulators reducing or eliminating some of the current characterization activities for certain waste streams provided it supports its case with a systematic, analytical, and quantitative approach (see Recommendation 1~. In addition, DOE should begin detailed planning to address the technical challenges presented by certain waste streams that DOE has not handled to date, as described in Sections 2.3 and 2.4. Finding 4: DOE is currently using only one of the four methods approved by EPA in 40 CFR 194.22(b) to qualify information as Acceptable Knowledge, namely, confirmation by measurement. Use of the other methods as appropriate could potentially reduce waste handling and costs, increase the efficiency of characterization activities, and extend the use of Acceptable Knowledge for waste generated in the future. Recommendation 4: DOE should request authorization from its regulators to use all four methods allowed by EPA for aualifvina waste information to be used as Acceotable Knowlecige. Continued reliance on the exclusive use of confirmatory testing, which sometimes requires breaching waste containers, becomes an especially important issue for some existing waste streams presenting characterization challenges (see Section 2.3~. Furthermore, the characterization of to-be-generated wastes is to be accomplished in accordance with an NMED- and EPA-approved quality assurance program. Therefore, , , _ . 44The four methods to qualify information to be used as Acceptable Knowledge are 1) peer review, 2) use of corroborative evidence, 3) cone rmation by measurement, and 4) qualification of a different quality assurance program.
6 Improving the Characterization Program for Contact-Handled Transuranic Waste the information collected at the time of waste generation should not require confirmatory measurements in order to be used as Acceptable Knowledge. Finding 5: Transportation agreements for WIPP shipments have been fashioned over many years of negotiation between DOE and the corridor states. Any changes in the WIPP characterization program could be viewed as undermining these institutional agreements. Recommendation 5: In addition to working with its regulators, DOE should ensure that corridor states are kept informed of negotiations for changes to the characterization program. Specifically, DOE should communicate effectively with the Western Governors Association, the Southern States Energy Board, and similar groups representing corridor states. DOE should analyze, publish, and present to corridor states' representatives any impact of proposed changes on transportation safety. Fincling 6: StakehofJers have many concerns about WIPP program-related operations. Although specific concerns may vary among people who live near generator sites (risks to site workers, delay in removing waste from generator sites), along transportation corridors (adequacy and reliability of characterization in the event of a transportation accident), or near the WIPP facility (protection of public health over the long term), some concerns are generally shared (the quality of DOE's requests for permit modifications; risks to workers, the public, and the environment; and the adverse effects of external performance pressures on the safety of the cleanup program). Many people who provided comments to the committee expressed concern that any change in characterization requirements or activities could result in decreased protection of worker and public health and/or the environment. Recommenctation 6: DOE should publish clearly written analyses of proposed changes to the characterization program to document that these changes do not adversely affect the protection of worker and public health and/or of the environment. DOE should also provide public access to information about WIPP and its operations, including the WIPP Waste Information System,42 and communicate interactively with state officials, tribes, public interest groups, and scientific oversight organizations. In this context, the proposed analytical framework could provide a technically defensible approach for supporting changes to the characterization program. 42See the Glossary.
