Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant Interim Report (2001) / Chapter Skim
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5 Committee's Preliminary Findings and Recommendations
5 Committee's Preliminary Findings and Recommendations
Pages 28-36
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From page 28... ...
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 A]
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From page 29... ...
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 of such requirements were selfimposed and should be removed from the characterization plan of RH-TRU waste.
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From page 30... ...
A similar recommendation was made by the INS! 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 safely, reducing costs, eliminating unnecessary self-imposed requirements, and complying with regulatory requirements.
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From page 31... ...
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 of RH-TRU waste does not need confirmatory measurements because the information collected during repackaging or generation can meet characterization requirements.
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From page 32... ...
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 4According to the information provided by DOE, DOE is already amending its characterization plan to standardize as much as possible common elements across the complex.
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From page 33... ...
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.
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From page 34... ...
These analyses are presented in 7The authors of risk/cost analysis study in Document 2 recommend "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)
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From page 35... ...
The committee provides three examples of conflicts or discrepancies between Documents and Document 2. Example 7: Document ~ states that the differences between the RH- and CHTRU 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~.
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From page 36... ...
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.
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