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Introduction The U.S. Department of Energy (DOE) is responsible for the safe management and disposal of transuranic (TRW) waste produced in defense-related activities and stored at 27 DOE sites across the country.' Contact-handled transuranic (CH-TRU) waste is currently being shipped from generator sites and characterization hubs to its final disposal site, the Waste Isolation Pilot Plant (WIPP), in southeastern New Mexico. To obtain authorization to ship TRU waste to WIPP, generator sites must first characterize and certify their waste in compliance with characterization requirements set forth by the U.S. Environmental Protection Agency (EPA) and the New Mexico Environment Department (NMED). Adclitionally, shipping containers2 must be certified by the U.S. Nuclear Regulatory Commission (USNRC), and shipments must comply with U.S. Department of Transportation (DOT) requirements for hazardous waste. Figure 1.1 shows the location of the ten major TRU waste generator sites and transportation routes to WIPP. -A -A :~~.~ -~ ~ it. ^~ ~~ ~ ~~ ~~ ~~ :: :~ ~~ ~ ~~ ~~ ~ ~ ~ ~~ ~ ~~ : {~ ~ ~~ ~~ ~~ ~ ~ ~ ~~ ~~ ~ :: ~~ ~~ ~ it: ~~ :~: i: ~ ~ ~ ~~:~ I: ~~ ~ I: ~ ~~ in ~~ ~ `~ ~:~ ~~:~ i: ~~ ~~:~ ~~ ~~ ~~ ~ ~ ~ ~ ~ ~ ~~ ~ ~~ ~~ ~ ~ ~~ ~ ~~ ~ ~ ~~ ~~ : ~~:~:~::~ :~::~:~ ~:~:~ : ::: ::~: i:: i: ::~:::~: ::: ~ :::: :::: ~ ::~ ~ ~ ::::~: :~ ~~: ~ If: I: ~~:~ ~~ ~~:~ ~~:~ :: ~~:~:~ ~ ~ ~:~ ~~ :~ ~::::~:: i::::: ~~:~::~:~:~ If: ::::::: t::::::::::::::::::::::::::::::::::::::::::: :::::::::: :. (~ :: ::. : ~~ ~~.~:~$~:~:~: i~.~'~2~'~'~.~'~ ~~'~.~-~'~'~'~'~'~'''~.~''~'~'.'~'~'~''~'.'~''~,.~'~'~'~ i: ~~ ale: ~~ - ~~ .~- all: I- ~ ~ ~~ If- -I;: ~~ ~ ~ i:: ~ ~ 2'~ i:: ~:( :: ~~ ~ ::, ~ :,~: ~~ ~ i: ~ ail:: : ~~:~,~, ~: :: if: I: ~~ ~~:~:~ ~~= if: ~~ :::: ~~ ~~:~L'~::~ ~ ~~ ~~ ~~"~ ~ ~~ ,:~ - .~.~.~:~ ~ ~~ ~~ ~~: ail: ~ ~~:~ : {~ ~~ ~~:~ ~~ ~~ ~ ~ ~~ ~~ ~~,~ :5:~ ~~t - I,.. ~:.~ ~~ ~~.mmr<~om:.xw... :~mmm' ~,~,~ ~~.~d , i, ~~ I ~ ~~ = '$*mr:~.,x ~~ :. ~~ ' ~~ ~ ~~ ~ ~~ ~ ~~ ~~ ~ ~ ~~ ~~ ~~ ~~ ~ ~ ~~ ~~ ~ ~ ~ :~ I. - ~~,~,~,~ ~~ ~~ ~~ ~~ ~~-~-~,~-~,.~-~-~ ::m:4~: .. .~ ~~ :.~: ~: ~~ ~~ ~~`j4~_~::~ ~~ :~ ~~ ~ ~ ~~ :~ ~ ~~ ~~ ~~. ~~ .~ ~~ ~~:~ -a ~ ~ ~~ ~~ s ~ ~~ ~ ~~ ~~ ~ ~ ~ I'd W0. ~~ a- ~~ ~~ ~~ ~~ ~ 5 ~~ ~ ~~ ~~ {~ ~~ ~ ~ ~~ ~~ ~~ ~~ ~ , ~ ~ ~~ ~~ ~~ ~ ~ ~~ ~ ~ ~~ ~ ~~ ~~ a, ~ ~~ ~~ ~ ~~, ~ ~~ ~~ if, ~- -~ ~ ~ ~~ ~~ ~~ ~~ ~~ ~ ~~ ~ ~ ~~ ~~ ~~ ~ ~~ ~ ~ ~ ~~ ~ ~ ~~ ~ Art I. ~~ y$ ~~ ~~ ~ ~ if. ~~ -~ ~~ ~~ ~~ ~ ~ ~ ~~ ~ ~~ ~~- ~ ~ ~-~ I- ~ ~ ~~ ~ ~~ ~~ ~ .~ ~ ~~ ~ .~ ~~ ~. ~~ ~~ ~ ~ {~ ~~ ~ ~ ; ~~ :.*0cm~ .~m>,:.,..5...,~ i, ~ ~ ~ ~ ~~ ~~ .~ ,~,~ ~...:v ~~ ~ I've ~~ ~~ ~ ~~ ~ ~ ~ ~ ~,~ ~ ~~ ~~ ~~.~ ~~ ~. ~-~ ~~ ~~ ~ .$ ~~ .~ ~~; ~~ ~ ~ - .^m~ ... '~ ~-,6~. ~~,~ ~,~ ~ ~~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ I'll ~~_~ ~~:~.::~ - L_. ~ ~ ala. ~~ ~ ~~.~ ~~-~ )'~ :: +~ ~~,~\'~ /~:~ ~~-~'~ - ~,~:~ :: ~~ :- :: ~.~ :~:~ >0 -: :-: ~ ~~- : - 4~'~''~'~, '~_ Highway Legend ~ nt:eil$~e H'gP'ways _~. I S} HI~ ~ ,31 ~ H~ At_ ~ . ... . z . .. ::::::::::::::::::~::::: :::: ::: :~: : ~:~ ~:~ :~ ~ ~ ~ ~ ~:~ ~~: ~~:~ ~~ ~~ ~~ ~ ~~ :~ ~~:~ ~~ ~~ ~~ ~~:~ :: ::: ~~ i~ ~ ~ if: ~ ~~ ~~ Is. ~~ ~~ ::: A:: ~ :~ ~ ~~ ~~v i: ~~: ~~ ~~ ~~ ~ : ~ I~ ~~:: ~~ ~, ~~ :: ~ ~:~ : ~~-~ ~ ~ ~Nl~=l>~ ~ ~C~ ~ ~ ~ Am ~ ~~-.~.~- ~,4~ ~ :~:~.~. A: :: ~~:~:~:~'~ ~:~ ~~:,~ ~~ ~ ~:~ ~'~,~ ~~ ~~ '~ ~~'~,~:. ~~'~ ~~ ~~:::::::::::::::::::::: ::~: i: ~~,~ ~ .~ ~~.~ ~~'~'~: :~ :' ~ ~~ ': 'I'd ~'~ .' ~ - As-' '' -' '' ' ~,~ ~~-~.~_r ~ i. ~ ~ ~~ a, ~~ ~ ~~N ~ ~~-~-~-~-~ i ~ ~ FIGURE 1.1 Location of the ten major transuranic waste generation sites and primary waste transportation routes to the Waste Isolation Pilot Plant. SOURCE: DOE. Readers who are familiar with background information on transuranic waste and WIPP can skip to Chapter 3. 21n this report, "shipping container" refers to a transportation package, typically a TRUPACT-II, while "container" refers to a waste container, typically a 55-gallon drum. 7

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8 Improving the Characterization Program for Contact-Handled Transuranic Waste After four years of shipping and disposing TRU waste in WIPP, DOE has identified waste characterization as one of the most costly and time-consuming parts of the National TRU Waste Management Program.3 According to an assessment by DOE, the cost of characterization and certification activities to prepare waste to be shipped to WIPP (or elsewhere) is estimated to be $3.1 billion, or approximately 16 percent of the $1 9 billion total life-cycle costs for the disposal of TRU waste (DOE-FSElS, ~ 997~.4 In light of this assessment, DOE asked the National Research Council for scientific and technical advice on opportunities for improving the characterization process and reducing the costs of the CH-TRU waste characterization program. A committee of 12 experts was appointed by the National Research Council and assigned the statement of task in Sidebar 1.~. The committee roster and biographical sketches can be found in Appendix A. , .. ~ ~ ~.~ ~ ~.~.~ ~ ~ ~~.~ ~.~ ~ I. ~ ~ :..: ~ :.~. :. :. .: :~: :. ~ .~. ~ :.: ~ ... ~~.~.~.~,~.~,,.~..,~.~.~.,~.~.~,~,~..,.,..~.~ . ~, .~ ~.~.~ ,~ ~:i. ...... = .~ ~ A.... ,.~ . . . . .. ........ ..~ ~ I I................ i. 4 :.:.: : ~..~. ... ~..~ .~ ~~ ._.. ::::::::::::::::::::::: 1.1 Boundaries of the Statement of Task and Strategy to Acictress lt This report addresses the characterization program for CH-TRU waste; this is the only type of waste currently allowed in WIPP. RH-TRU waste is not allowed for disposal at WIPP because there is no characterization program approved by WIPP regulators for this type of waste. Moreover, the proposed characterization plan for RH-TRU waste was the object of a previous National Research Council report (NRC, 2002~. The present report briefly addresses RH-TRU waste as a potential characterization challenge (see Section 2.3.6~. The committee discusses only those transportation requirements that have an impact on characterization activities. It does not address other transportation issues, such as shipment tracking, communication systems, emergency response plans, truck inspections, transportation modes, and so forth. The first objective of the statement of task is to review DOE's program for transuranic waste characterization. Determining whether there are inefficiencies in the characterization program and what improvements can be made is a complex task. To perform it, a structured and quantitative analysis of characterization activities, coupled with operational experience, can be used to identify which, if any, characterization activities warrant changes. The committee proposes a structured and quantitative analytical framework in Chapter 5 to support its main finding and recommendation (Finding and Recommendation ~ ). 3The National TRU Waste Management Plan is a DOE system-wide approach to the management and disposal of TRU waste stored and generated throughout the DOE weapons complex (DOE-NTP, 2002~. DOE's Carlsbad Field Office manages this program. Information on the program is available at: ~http://www.wipp.ws>. 4This estimate does not take into account discount rates.

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Introduction 9 The second objective of the statement of task is addressed in Chapter 6. The committee provides six recommendations that could increase the program's technical soundness, efficiency, cost effectiveness, and safely to workers and the public. These recommendations address the characterization program as whole, not specific characterization activities. The committee does not recommend changes to specific characterization activities because of the policy nature of such a recommendation. Furthermore, to recommend chances to specific activities would reouire a systematic and Quantitative . . .. . .. in, , , , ~ analysis of risks, costs, and impacts. Such an analysis is beyond the committee's scope (see Finding 1~. Nevertheless, the committee provides illustrative applications (albeit incomplete) of the proposed structured and quantitative analysis to three characterization activities that were chosen on the basis of information provided by DOE and findings from a previous National Research Council committee (see Section 5.9~. The report also addresses programmatic, policy, and societal impacts of changes to the characterization program as follows: . . Programmatic impacts. Use of experience gained in the first four years of WIPP operations to make programmatic improvements is discussed in Chapter 4. The programmatic impact on risks and costs of changes to characterization activities is discussed in Sections 5.3 and 5.4. Policy impacts. It is important to recognize the distinction between regulatory requirements (referred to as "characterization requirements") and the approach to meet such requirements ("characterization activities"~. The committee does not comment on regulatory requirements themselves because these are prerogatives of DOE's and of the regulatory agencies.' Instead, the committee provides scientific and technical advice on how to improve DOE's waste characterization program within the current policy framework. The policy framework for TRU waste characterization is described in Chapter 3 and Appendices C and D. The committee addresses the policy impact of changes in the characterization program in Section 5.5. Societal impacts. Societal impacts of changes in the characterization program are discussed in Section 5.6. Potential impacts of changes in the characterization program on corridor states5 agreements with DOE are also discussed and these societal impacts are the basis for Findings and Recommendations 5 and 6. The assumption underlying this report is that WIPP must always be in compliance with regulatory requirements. Any improvements to increase the program's technical soundness, efficiency, cost effectiveness, and safely to workers and the public must result in compliance with the regulations. Most changes require regulatory approval. Therefore, the question is whether another characterization activity can meet a given regulatory requirement in a more cost-effective way without reducing the level of protection of human health and the environment. The answer to this question is provided by the application of a structured, quantitative analysis of the value of the information providecl by the characterization activity in question. 1.2 Origin of This Study This study builds on two previous National Research Council reports on WIPP: Improving Operations and Long-Term Safely of the Waste /so/afion Pilot Plant (NRC, 5Corridor states are those through which TRU waste is expected to be shipped, either to interim DOE sites or to WIPP.

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10 Improving the Characterization Program for Contact-Handled Transuranic Waste 2001), and 2) Characterization of Remote-Hanc//ec/ Transuranic Waste for the Waste /so/ation Pilot P/anf (NRC, 2002~. The 2001 report provided a first assessment of characterization activities for CH-TRU waste in the framework of a much broader task on WIPP. The 2002 report addressed characterization activities for remote-handIed transuranic (RH-TRU) waste. Both committees discussed the history of some of the characterization activities for contact-handIed transuranic (CH-TRU) waste appearing in the Hazardous Waste Facility Permit (NRC, 2001, 2002, and references therein). Based on DOE analyses of the records of the negotiation process with the State of New Mexico, it appeared that DOE included certain waste characterization activities that went beyond what was required to comply with the requirements in 40 CFR 264. For instance, DOE proposed to NMED to conduct homogeneous waste and headspace gas sampling and analyses on the totality of CH-TRU waste containers to confirm existing information about the waste.6 Furthermore, a provision for the confirmation of radiography results by visual examination was also included in the 1995 permit application to NMED. Therefore, the committee that authored the 2001 report recommended (NRC, 2001; page 66~: DOE should eliminate self-imposed waste characterization requirements that lack a legal or safely basis.~7~ Similarly, the committee that authored the 2002 report on the proposed characterization program for RH-TRU waste recommended (NRC, 2002; page 49~: DOE should propose only characterization activities that have a technical, health and safely, or regulatory basis. The present committee uses the characterization activities mentioned in the 2001 report as examples of characterization activities to be re-evaluated using the analytical framework described in Chapter 5 to determine their connection with the protection of human heath and safely (see Section 5.9~. 1~3 Transuranic Waste Defined Transuranic waste is radioactive waste containing radionuctides with atomic numbers greater than that of uranium (Sidebar 1.2 provides information on the definition and classifications of TRU waste). Transuranic waste is generated during the manufacture and reprocessing of plutonium for production reactor fuel and irradiated targets, as well as in various research programs. In recent years, TRU waste has also been generated and collected for disposal through environmental remediation and decontamination and decommissioning operations at DOE sites. Transuranic waste consists of long-livecl alpha-emitting raclionuclicles, typically plutonium radioisotopes, contaminating items such as protective clothing and gloves, rags, laboratory instruments, gloveboxes, and equipment (see Sidebar 1.2~. Other TRU waste in semi-solid form consists primarily of sludge by-products from the chemical separation and recovery of plutonium and other transuranic isotopes. Some TRU waste 6For a description of these activities, see Chapter 4. 7The word "requirements" in the 2001 report corresponds to "activities" in this report. The term "legal basis" referred to the Land Withdrawal Act, the Resource Conservation and Recovery Act, Titles 40 CFR 191, 40 CFR 194, and 40 CFR 264.

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Improving the Characterization Program for Contact-Handled Transuranic Waste ....~.;~.. S: :~ it. has beta, gamma, or X-ray emissions associated with the TRU radionuctides or with other contaminants of the waste. WIPP can only accept defense-related TRU waste, which is waste produced through activities associated with the U.S. defense nuclear weapons program. Because of its radiological hazard and the tong half-lives of some of its radionuclides, long-term geologic isolation must be provided for TRU waste. In ~ 992, the U.S. Congress designated the WIPP, a facility near CarIsbad, New Mexico, as the nation's geologic disposal facility for clefense-relatecl transuranic waste (U.S. Congress, 1992~. The WIPP facility is described in Section 1.4. The EPA, NMED, and USNRC are the threes agencies that regulate WIPP and its related activities. The implementation of regulatory requirements, including those on characterization, is described in permits9 granted by the regulators: the EPA Certificate of Compliance for WIPP with 40 CFR 194; the NMED Hazardous Waste Facility Permit (HWFP); and the USNRC Certificates of Compliance for containers used to ship TRU DOE is also a self-regulator for WIPP through internal orders and guidance manuals, as explained in Chapter 3. 91n this report, the word "permit" is used in the general sense, addressing both the licensing of radioactive material, transportation containers, or the permitting of hazardous waste facilities.

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Introduction 13 waste to WIPP (see Chapter 3 and the GIossary). WIPP has to maintain compliance with the EPA, NMED, and USNRC permits at all times to continue operations. Waste characterization activities are designed to meet requirements in these permits. 1.4 The Waste Isolation Pilot Plant The Waste Isolation Pilot Plant, located near CarIsbad, New Mexico, is the nation's defense-related transuranic waste repository, as designated by Congress in the Land Withdrawal Act of 1992 (U.S. Congress, 1992~. Legal criteria for WIPP related to TRU waste disposal are discussed in Chapter 3 and Appendix C. The WIPP Land Withdrawal Act transferred control of the WIPP federal land from the Department of the Interior to the Department of Energy. This Act allows the disposal of 175,564 cubic meters of transuranic waste in WIPP, of which 7,080 cubic meters can be RH-TRU waste. The amount of radioactivity in RH-TRU waste is limited to 5. ~ million curies. The WIPP has been under study since the mid-1970s and under construction since January 1981. The facility received the first CH-TRU waste shipment in March ~ 999 and the first mixed CH-TRU waste shipment in September 2000 To date (December 2003), more than 46,000 drum-equivalents40 of waste have been emplaced underground and over 2,000 shipments of CH-TRU waste have been sent to WIPP. The five sites that are currently shipping waste to WIPP are the following: Rocky Fiats Environmental Technology Site, Idaho National Engineering and Environmental Laboratory, Los Alamos National Laboratory, Savannah River Site, and Hanford Site. Throughout the country there are approximately 27 TRU waste generator sites; most of them are considered "smalI-quantity" waste generator sites (see Section 2.2 for a complete inventory). The WIPP disposal area is located about 660 meters below ground in a salt bed, called the Salado Formation (see Figure 1.2~. Bedded salt formations have many attributes that make them suitable hosts for a geologic repository. First, large salt formations are found mainly in stable geologic areas with little seismic activity. Second, large salt beds such as the Salado Formation are found only in regions that do not have significant groundwater movement. This deep, relatively dry, underground environment reduces the possibility of waste releases from the repository by natural processes. Third, under the lithostatic pressure at the repository depth, the salt slowly "creeps" to fill voids, thereby encapsulating and immobilizing the waste deep beneath the surface. Analyses indicate that that the mined salt will flow and encapsulate the waste approximately 200 years after closure of the WIPP facility (Knowles and Economy, 2000~. A further advantage of salt formations is that they are easily mined without the use of explosives. The underground waste disposal area in WIPP will consist of eight "panels," each containing seven rooms. After four years of operation, the first pane! has been filled with CH-TRU waste and close. Emplacement of CH-TRU waste in the second pane! began in December 2002. Mining of the third pane! began in May 2003. Contact-handIed transuranic waste drums and boxes are being stacked in three layers in each room (Figure 1.3~. Magnesium oxide is emplaced on top of the waste containers as backfill and to produce an above-neutral pH environment, thereby reducing the solubility of the actinides. In 2001, DOE requested permission from EPA to discontinue the use of small bags of magnesium oxide ("mini-sacks") to reduce workers exposure to waste. Large 4The term "drum-equivalent" refers to any waste container, such as standard waste boxes or 1 O-drum overpacks, whose volume is normalized to 55-gallon drums (7.5 cubic feet), the most common waste container. Three of the rooms in Panel 1 were left vacant because of roof instability.

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14 Improving the Characterization Program for Contact-Handled Transuranic Waste FIGURE 1.2 Schematic representation of the completed Waste Isolation Pilot Plant Facility. The facility will have eight disposal panels, each divided into seven rooms. Only two and part of a third pane! have been mined to date (2003~. SOURCE: DOE. bags of magnesium oxide ("super-sacks") continue to be emplaced on top of waste stacks. Figure 1.3 shows both mini-sacks and super-sacks. 1.5 Life Cycle of Transuranic Waste The life cycle of TRU waste, from its generation to its designated final disposal at WIPP, generally42 consists of the following: waste generation or recovery from its current storage location; . processing and packaging, if necessary; characterization and certification; loading into shipping containers; road transportation to WIPP; receipt, unloading, handling, surface interim storage; and underground emplacement at WIPP. The following is a brief description of these steps. As previously mentioned, transuranic waste is already in storage at generator sites or wit! be generated during ongoing operations or during deactivation and decommissioning activities at DOE sites. TRU waste is currently being storecl in metal drums, concrete moclules, and metal and wooden boxes. Safe recovery of stored waste can be complex and difficult if containers are difficult to access, if their integrity has been compromised, or if storage records are not available or are deficient. 42The life cycle of TRU waste may vary slightly from site to site, depending on the types of waste streams and agreements between DOE and generator sites.

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Introduction 15 FIGURE 1.3 Contact-handIed transuranic waste emplaced in Pane! 1. Two types of waste containers are visible: standard waste boxes and 55-gallon drums. Magnesium oxide was placed on top of the waste in large cylindrical containers and on the sides in "mini-sacks" as backfill to ensure an above-neutral pH of the environment and thus reduce the Volubility of actinides. Mini-sacks of magnesium oxide are no longer used in the Waste Isolation Pilot Plant. SOURCE: DOE. Waste processing activities may consist of chemical processing or consolidation of wastes (by compaction or by conversion to a form suitable for disposal at WIPP). For instance, wet sludge must be dried because liquids are prohibited (if more than ~ percent of free liquid by waste volume) in WIPP. In any event, if the waste is not containerized, it must be packaged in accordance with the USNRC Certificate of Compliance as described in the TRUPACT-~! Authorized Methods for Payload Control (see Appenclix D). To obtain authorization to ship TRU waste to WIPP, generator sites must first characterize and certify their waste streams43 that is, identify them as TRU, determine their physical forms, quantify their chemical constituents, ensure the absence of prohibited items, and provide a certification record. Waste characterization is used to ensure the safe transportation of waste from generator sites to WIPP, to ensure its safe clisposal, and to provide a certified record of clisposal activities. From a regulatory perspective, all waste sent to WIPP must comply with the WIPP Waste Acceptance Criteria, HWFP, and transportation requirements (see Chapter 3~. The waste characterization program for CH-TRU waste is describecl in Chapter 4. Repackaging of waste may be required in the following instances: 1) the original waste container does not meet transportation requirements, or 2) the waste needs processing to remove prohibited material (see Appendix C). Waste from small-quantity generator sites can be characterized at other sites having more complete and acceptable characterization capabilities. This is the case, for example, of TRU waste from the Mound Laboratory in Ohio, which is being sent to the Savannah River Site in South Carolina for characterization and certification prior to 43A waste stream is defined as waste material generated from a single process or activity or as waste in containers having similar physical, chemical, or radiological characteristics (see the Glossary).

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16 , Improving the Characterization Program for Contact-Handled Transuranic Waste shipment to WIPP (see Appendix E). Waste shipped to other DOE sites for interim storage and characterization need not undergo the characterization for disposal required for waste that is shipped directly to WIPP (see Table D.~. Intersite shipments made prior to shipment to WIPP must, however, comply with transportation requirements and with the receiving site's waste acceptance criteria. These interim characterization sites must ensure proper characterization and certification of all waste shipped to WIPP from their site, including that received from other sites. Once certified by EPA and NMED, packaged TRU waste is loaded onto USNRC- approved transportation packages, the most common being the TRUPACT-~l, and transported to WIPP by road following routes established in accordance with corridor states. The final steps when waste arrives at WIPP consist of checking the shipment for contamination, and if none is found, unloading the waste, storing it temporarily at the surface, and finally emplacing it underground for permanent disposal.44 , - - - ~ 1.6 Challenges of Transuranic Waste Characterization Transuranic waste characterization presents several challenges for DOE's National TRU Waste Management Program, such as the following: High characterization costs arid variabi/itv in estimates. , On average, characterizing TRU waste to date costs $3,900 per drum (see Section 4.5~. There is great variability in cost estimates from site to site due to differences in waste type and volume, different characterization procedures and different methods of reporting costs. Because of such variability, analyzing and comparing characterization costs are complex tasks. Mu/tip/e generator sites. There are 27 TRU waste generator sites across the country. Waste characterization procedures vary (although only slightly) from site to site even though they all comply with the same WIPP Waste Acceptance Criteria and requirements in the WIPP HWFP. Wide variety of waste streams. DOE identified 569 transuranic waste streams in the Baseline Inventory Report. These vary from heterogeneous debris from deactivation and decommissioning to homogeneous sludges from waste processing. These definitions are, of course, somewhat arbitrary, and the number of waste streams may vary according to the definitions employed. Wide variation in knowledge of waste nature. Waste streams have been produced at different times, at different sites, and using clifferent processes; furthermore, new streams will be generated in the future. There is a wide range of knowledge concerning the nature of the waste to be characterized. Procedures in place at the site where waste was generated also determine the extent of waste knowledge: records of waste generated in a production facility where operating procedures are codified are generally more detailed than those of waste generated in a research facility. This difference in knowledge of the nature of the waste (also callecl "Acceptable Knowledge,"45 see Chapter 4) has an impact on the extent of characterization activities before waste is shipped to WIPP. 44A detailed description of the waste disposal process can be found on DOE's WIPP Internet site: . 45Acceptable Knowledge is a term used by EPA that encompasses historical process knowledge and information from previous testing, sampling, and analyses of waste. See Section 4.4 and the Glossary.

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Introduction 17 Programmatic uncertainties. The amount and characteristics of future waste streams may be considerably different from current estimates depending on changes in ongoing programs and in cleanup strategy within DOE. Technological advances will create opportunities to improve waste characterization but their time and impact on the program are difficult to assess. There are also characterization challenges associated with specific TRU waste streams, as discussed in Section 2.3, as well as regulatory challenges, discussed in Section 3.4. , ,, .