Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report [illustrated] 0309084601, 9780309084604

Table of contents :
Executive Summary..............1
1 Introduction ..............8
2 RemoteHandled Transuranic Waste ..............15
3 Regulatory Context for the Disposal of RemoteHandled Transuranic Waste ..............27
4 Department of Energys Proposed Characterization Plan ..............34
5 Assessment of the Proposed Characterization Plan ..............47
References..............62
Appendix A Biographical Sketches of Committee Members ..............65

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CHARACTERIZATION OF REMOTE-HANDLED TRANSURANIC WASTE FOR THE WASTE ISOLATION PILOT PLANT INTERIM REPORT

Committee on the Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant Board on Radioactive Waste Management Division on Earth and Life Studies National Research Council

NATIONAL ACADEMY PRESS Washington, D.C.

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NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the committee responsible for the report were chosen for their special competence and with regard for appropriate balance. Support for this study was provided by the U.S. Department of Energy under cooperative agreement number DE-FC01-99EW59049. All opinions, findings, conclusions, and recommendations expressed herein are those of the authors and do not necessarily reflect the views of the Department of Energy. Additional copies of this report are available from: National Academy Press 2101 Constitution Avenue, N.W. Box 285 Washington, DC 20055 800–624–6242 202–334–3313 (in the Washington metropolitan area) http://www.nap.edu Copyright 2001 by the National Academy of Sciences. All rights reserved. Printed in the United States of America.

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THE NATIONAL ACADEMIES Advisers to the Nation on Science, Engineering, and Medicine National Academy of Sciences National Academy of Engineering Institute of Medicine National Research Council The National Academy of Sciences is a private, nonprofit, self-perpetuating society of distinguished scholars engaged in scientific and engineering research, dedicated to the furtherance of science and technology and to their use for the general welfare. Upon the authority of the charter granted to it by the Congress in 1863, the Academy has a mandate that requires it to advise the federal government on scientific and technical matters. Dr. Bruce Alberts is president of the National Academy of Sciences. The National Academy of Engineering was established in 1964, under the charter of the National Academy of Sciences, as a parallel organization of outstanding engineers. It is autonomous in its administration and in the selection of its members, sharing with the National Academy of Sciences the responsibility for advising the federal government. The National Academy of Engineering also sponsors engineering programs aimed at meeting national needs, encourages education and research, and recognizes the superior achievements of engineers. Dr. Wm.A.Wulf is president of the National Academy of Engineering. The Institute of Medicine was established in 1970 by the National Academy of Sciences to secure the services of eminent members of appropriate professions in the examination of policy matters pertaining to the health of the public. The Institute acts under the responsibility given to the National Academy of Sciences by its congressional charter to be an adviser to the federal government and, upon its own initiative, to identify issues of medical care, research, and education. Dr. Kenneth Shine is president of the Institute of Medicine. The National Research Council was organized by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy’s purposes of furthering knowledge and of advising the federal government. Functioning in accordance with general policies determined by the Academy, the Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering in providing services to the government, the public, and the scientific and engineering communities. The Council is administered jointly by both Academies and the Institute of Medicine. Dr. Bruce Alberts and Dr. Wm.A.Wulf are chairman and vice-chairman, respectively, of the National Research Council.

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COMMITTEE ON THE CHARACTERIZATION OF REMOTE-HANDLED TRANSURANIC WASTE FOR THE WASTE ISOLATION PILOT PLANT EULA BINGHAM, Chair, University of Cincinnati, Ohio SANFORD COHEN, SC&A, Inc., McLean, Virginia MILTON LEVENSON, Independent Consultant, Menlo Park, California KENNETH MOSSMAN, Arizona State University, Tempe ERNEST NIESCHMIDT, Idaho State University, Idaho Falls JOHN PLODINEC, Mississippi State University, Starkville ANNE E.SMITH, Charles River Associates, Washington, D.C. Consultant HEINO NITSCHE, University of California, Berkeley Liaison to the Board on Radioactive Waste Management ALEXANDER MACLACHLAN, E.I. du Pont de Nemours and Company (retired), Wilmington, Delaware Staff BARBARA PASTINA, Study Director ANGELA TAYLOR, Senior Project Assistant DARLA THOMPSON, Research Assistant

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BOARD ON RADIOACTIVE WASTE MANAGEMENT JOHN F.AHEARNE, Chair, Sigma Xi and Duke University, Research Triangle Park, North Carolina CHARLES MCCOMBIE, Vice Chair, Consultant, Gipf-Oberfrick, Switzerland ROBERT M.BERNERO, U.S. Nuclear Regulatory Commission (retired), Gaithersburg, Maryland ROBERT J.BUDNITZ, Future Resources Associates, Inc., Berkeley, California GREGORY R.CHOPPIN, Florida State University, Tallahassee RODNEY EWING, University of Michigan, Ann Arbor JAMES H.JOHNSON, JR., Howard University, Washington, D.C. ROGER E.KASPERSON, Stockholm Environment Institute, Sweden NIKOLAY LAVEROV, Russian Academy of Sciences, Moscow JANE C.S.LONG, Mackay School of Mines, University of Nevada, Reno ALEXANDER MACLACHLAN, E.I. du Pont de Nemours and Company (retired), Wilmington, Delaware WILLIAM A.MILLS, Oak Ridge Associated Universities (retired), Olney, Maryland MARTIN J.STEINDLER, Argonne National Laboratory (retired), Downers Grove, Illinois ATSUYUKI SUZUKI, University of Tokyo, Japan JOHN J.TAYLOR, Electric Power Research Institute (retired), Palo Alto, California VICTORIA J.TSCHINKEL, Landers and Parsons, Tallahassee, Florida Staff KEVIN D.CROWLEY, Director MICAH D.LOWENTHAL, Staff Officer BARBARA PASTINA, Staff Officer GREGORY H.SYMMES, Senior Staff Officer JOHN R.WILEY, Senior Staff Officer SUSAN B.MOCKLER, Research Associate TONI GREENLEAF, Administrative Associate DARLA J.THOMPSON, Senior Project Assistant/Research Assistant LATRICIA C.BAILEY, Senior Project Assistant LAURA D.LLANOS, Senior Project Assistant ANGELA R.TAYLOR, Senior Project Assistant JAMES YATES, JR., Office Assistant

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LIST OF REPORT REVIEWERS

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LIST OF REPORT REVIEWERS

This interim report has been reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise, in accordance with procedures approved by the National Research Council’s (NRC’s) Report Review Committee. The purpose of this independent review is to provide candid and critical comments that will assist the institution in making the published report as sound as possible and to ensure that the report meets institutional standards for objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. We wish to thank the following individuals for their participation in the review of this report: Robert Bernero, U.S. Nuclear Regulatory Commission, retired Gregory Choppin, Florida State University Gerhart Friedlander, Brookhaven National Laboratory, retired B.John Garrick, Garrick Consulting Kimberlee Kearfott, University of Michigan Werner Lutze, The Catholic University of America George P.Roberson, Lawrence Livermore National Laboratory Martin J.Steindler, Argonne National Laboratory, retired D.William Tedder, Georgia Institute of Technology Although the reviewers listed above have provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations, nor did they see the final draft of the report before its release. The review of this report was overseen by Harold Forsen, National Academy of Engineering, and Chris Whipple, Environ, Inc. Appointed by the National Research Council, they were responsible for making certain that an independent examination of this report was carried out in accordance with NRC procedures and that all review comments were carefully considered. Responsibility for the final content of this report rests entirely with the authoring committee and the NRC.

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LIST OF REPORT REVIEWERS viii

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CONTENTS ix

Contents

EXECUTIVE SUMMARY 1

1 INTRODUCTION AND TASK 5

2 REMOTE-HANDLED TRANSURANIC WASTE 9

3 REGULATORY CONTEXT FOR THE DISPOSAL OF RH-TRU WASTE 18

4 DESCRIPTION OF DOE’S CHARACTERIZATION PLAN FOR RH-TRU WASTE 22

5 COMMITTEE’S PRELIMINARY FINDINGS AND RECOMMENDATIONS 28

REFERENCES 37

APPENDIXES

A CH-TRU CHARACTERIZATION PLAN 39

B INFORMATION GATHERED TO DATE 41

C BIOGRAPHICAL SKETCHES OF COMMITTEE MEMBERS 42

D GLOSSARY 45

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CONTENTS x

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EXECUTIVE SUMMARY

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Executive Summary

About 3,600 m3 of defense-related remote-handled transuranic (RH-TRU)1 waste are currently stored across the United States Department of Energy’s (DOE’s) weapons complex. DOE is seeking authorization to dispose this waste at the Waste Isolation Pilot Plant (WIPP), in New Mexico, as part of the weapons complex cleanup effort. To this end, DOE will propose to WIPP’s regulatory agencies a plan for characterizing RH-TRU waste. DOE has asked the National Research Council to review the first draft of this plan and to provide recommendations to improve, if necessary, the plan’s technical soundness, compatibility with worker safety, and compliance with applicable regulatory requirements. Preliminary findings and recommendations are provided in this interim report. The two regulatory agencies for WIPP are the U.S. Environmental Protection Agency (EPA) and the New Mexico Environment Department (NMED). The WIPP is currently certified by EPA and permitted by NMED to dispose only of contact-handled transuranic (CH-TRU) waste. Approval of a characterization plan for RH-TRU waste is required to dispose of that waste in WIPP. The EPA and NMED will establish the final characterization requirements for RH-TRU waste on the basis of DOE’s proposed plan. The RH-TRU waste inventory is composed of retrievably stored waste and newly generated waste. Retrievably stored waste is waste produced prior to EPA and NMED approval of a characterization plan for RHTRU waste. Newly generated waste is waste that is produced after the approval of a characterization plan and meets the characterization requirements set forth by the regulatory agencies. Newly generated waste can be anticipated waste that has yet to be generated, or it can be existing waste that needs to be re-packaged in a suitable form for transportation and disposal. The data provided by DOE (Table 1 in Chapter 2) show that most of the retrievably stored RH-TRU waste is located at Oak Ridge National Laboratory (ORNL) and that most of the newly generated waste will be produced at the Hanford Site. The RH-TRU waste volume inventory comprises between 1 and 4 percent in volume of the total (CH-TRU plus RH-TRU) inventory for the WIPP facility. DOE calculated the total activity from the RH-TRU waste inventory (from retrievably stored waste and newly generated waste) to be approximately one million curies. Approximately 90 percent of the retrievably stored RH-TRU radioactivity is located at ORNL (Table 2, Chapter 2). Most of the radioactivity in RH-TRU waste is due to short-lived radionuclides, which will decay away in approximately 300 years. After this period, the radioactive content of RH-TRU waste would be approximately the same as that of CH-TRU waste. From the point of view of the long-term performance of WIPP (10,000 years is the regulatory compliance period), after approximately 300 years, RH-TRU waste will be virtually indistinguishable from CH-TRU waste. DOE’s stated objective is to propose a characterization plan for RH-TRU waste based on its impact on the performance of WIPP while protecting worker safety, reducing costs, eliminating unnecessary self-imposed requirements, and complying with

1Transuranic waste is radioactive waste containing alpha-emitting radionuclides of atomic number greater than 92, half-life greater than 20 years, and activity greater than 100 nanocuries per gram of waste. Transuranic waste is classified as remotehandled or contact-handled waste, according to the radiation dose rate at the surface of the package. A more detailed definition is given at the beginning of Chapter 2.

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EXECUTIVE SUMMARY

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regulatory requirements. The proposed characterization plan relies mainly on preexisting knowledge of the waste, also called acceptable knowledge2 (AK), and limited use of confirmatory measurements. This approach arises from DOE’s concern that higher surface dose rates associated with RH-TRU waste present potentially higher radiological risks to workers and higher associated costs compared to the approach for characterizing CHTRU waste. According to the information provided by DOE, about 80 percent of the RH-TRU waste inventory will meet the new characterization requirements set forth by the regulatory agencies, because it consists of future waste, waste that will be re-packaged, or waste that was characterized according to the approved CH-TRU characterization plan.3 For the remaining 20 percent of RH-TRU waste, DOE proposes to complement the existing AK, where necessary, with additional confirmatory activities. These activities are listed in 40 CFR 194.22(b) and are to be used individually or in combination to qualify AK: (1) peer review, (2) use of corroborative evidence, (3) confirmation by measurements, or (4) qualification of previous quality assurance programs (see Chapter 4). The preliminary findings and recommendations of this interim report, presented in Chapter 5, are the following: 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. 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. For example, according to the data provided by DOE on RH-TRU waste inventories (see Tables 1 and 2 in Chapter 2) and to the Sandia National Laboratory evaluation, the detection of prohibited items, the determination of metal content, and the attribution of waste summary category groups in the proposed RH-TRU waste characterization plan do not appear to affect the longterm performance of the repository. 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

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a definition of acceptable knowledge see the glossary (Appendix D) and Chapter 4. newly generated waste and re-packaged waste, the information constituting AK will be collected during generation or re-packaging of the waste according to the characterization requirements set forth by EPA and NMED. At Los Alamos National Laboratory, RH-TRU waste was characterized according to the approved CH-TRU waste characterization plan and will probably not need to be re-characterized. 3For

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EXECUTIVE SUMMARY

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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. 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. 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. Finding 5: There is substantial variability among RH-TRU waste generator sites with respect to waste volumes and activity contents, extent of AK available, and availability of characterization and repackaging facilities. 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. 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. 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. 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.

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EXECUTIVE SUMMARY

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To improve understanding, corroborate, and add credibility to the characterization plan, the committee also provides the following observations and issues for future consideration; details are given in Chapter 5: the information in the supporting documents for the RH-TRU waste characterization plan is sometimes convoluted, difficult to understand, difficult to find, and repetitious; there are also conflicting statements and discrepancies; 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. The committee’s recommendations are based strictly on scientific and technical considerations. Overall, 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 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.

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INTRODUCTION

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1 Introduction

The National Research Council, at the request of the U.S. Department of Energy-Carlsbad Field Office (DOE-CBFO), appointed a committee1 to provide an independent review of DOE’s proposed characterization plan for defense-related remote-handled (RH) transuranic (TRU) waste.2 The committee’s statement of task is reported in Sidebar 1. About 3,600 m3 of defense-related RH-TRU waste are currently stored across DOE’s weapons complex. DOE is seeking authorization to dispose of this waste at the Waste Isolation Pilot Plant (WIPP) in New Mexico as part of the effort to clean up its nuclear weapons complex. The WIPP, briefly described in Sidebar 2, currently holds a certification issued by the United States Environmental Protection Agency (EPA) and a Resource Conservation and Recovery Act (RCRA) Permit issued by the New Mexico Environment Department (NMED). The WIPP’s certification and the RCRA Permit allow the shipment and disposal of contact-handled (CH) TRU waste but exclude RH-TRU waste. When DOE first applied for certification of WIPP, it proposed a characterization plan for both RH-TRU and CH-TRU waste (DOE-CAO, 1996a). However, in their final decision, both EPA and NMED declared that DOE did not provide an adequate waste characterization method for RH-TRU waste and prohibited this waste from being shipped or emplaced in the repository. Both agencies also stated that DOE did not adequately describe its full RH-TRU waste inventory. However, both EPA and NMED acknowledged that DOE proposed an adequate characterization plan for CH-TRU waste. The main condition that must be met for the removal of the prohibition on emplacing RH-TRU waste in WIPP is for DOE to provide a characterization plan for RH-TRU waste that is approved by EPA and NMED. DOE is now proposing a characterization plan for RH-TRU waste that relies mainly on pre-existing knowledge of waste characteristics, called acceptable knowledge (AK),3 and reduces the use of confirmatory measurements. The characterization plan is described in more detail in Chapter 4. DOE is concerned with the potential exposure of workers to radiation during the characterization of RH-TRU waste and with the costs associated with handling and characterization activities.4 DOE is now preparing a new characterization plan for RH-TRU waste that is described in the following two documents to be submitted to EPA and NMED in the next few months: • Document 1: Notification of proposed change to the EPA Title 40 CFR Part 194 certification of the WIPP (DOE-CBFO, 2001a). • Document 2: Request for RCRA Class 3 permit modification to the NMED (DOE-CBFO, 2001b).

1The Committee on the Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant. Biographical sketches of committee members can be found in Appendix C. 2Transuranic waste is radioactive waste containing alpha-emitting radionuclides of atomic number greater than 92, half-life greater than 20 years, and activity greater than 100 nanocuries per gram of waste. Transuranic waste is classified as remotehandled or contact-handled waste according to the radiation dose rate at the surface of the package. A more detailed definition is given at the beginning of Chapter 2. 3For the definition of AK see the glossary (Appendix D) and Chapter 4. 4Remote-handled TRU waste requires the use of remote-handling tools and/or heavy shielding for the protection of workers.

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INTRODUCTION

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In this report, Documents 1 and 2 will often be referred to as the characterization plan’s “supporting documents.” EPA will review Document 1 to consider a change in the certification of WIPP, and NMED will review Document 2 to consider a modification in the RCRA Permit affecting mixed (see definition in Chapter 2) TRU waste. If EPA and NMED agree to modify certification and RCRA permit to allow RH-TRU waste in WIPP, final characterization requirements for RH-TRU waste will be established by these two regulatory agencies on the basis of DOE’s proposed plan.

SIDEBAR 1 STATEMENT OF TASK The objective of this study is to review and evaluate DOE’s plan to characterize remote-handled transuranic waste to be disposed of at WIPP. The committee will provide recommendations, as necessary, for improving the plan’s technical soundness, protection of worker safety, and compliance with applicable regulatory requirements. This study does not address transportation issues related to RH-TRU waste. Examples of criteria that could be used by the committee to review DOE’s characterization plan for RHTRU waste are the following: validity of assumptions used for the proposed plan; quality of information available on RH-TRU waste; uncertainties on process knowledge data and consequences if wrong; appropriateness and sensitivity of overall system safety to uncertainties in the waste specifications; limitations of the methodologies and procedures to characterize RH-TRU waste; and validity of DOE’s conclusions concerning its characterization plan.

COMMITTEE’S TASK This committee’s task is to provide recommendations to determine the RH-TRU characterization plan’s technical soundness, compatibility with worker safety, and compliance with applicable regulatory requirements. The committee reviewed only a draft version of Documents 1 and 2, dated July 2001. Findings and recommendations in this interim report apply only to this draft. DOE indicated that its characterization plan is evolving in response to discussions with the committee and to the recommendations by the Institute for Regulatory Sciences (RSI, 2001), which also reviewed Documents 1 and 2. DOE provided the committee with additional and updated information on its plan through briefings and correspondence exchanges. The committee did not verify data provided by DOE on RH-TRU waste inventories or cost estimates. Also, the committee also did not assess the validity of supplementary information supporting the characterization plan, such as the Sandia Inventory Impact Assessment Reports in Document 1 (Attachment B) and Document 2 (Appendix 1). The committee did, however, assess how DOE interpreted and used the results of these reports in supporting its characterization plan. The initial assumption for this study is that all the RH-TRU waste to be characterized is identified as defense-related and hence can be sent to WIPP, once a characterization plan is approved by EPA and NMED. The statement of task directs the committee to evaluate compliance of DOE’s characterization plan with regulatory requirements. These requirements are not yet

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INTRODUCTION

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specified for the characterization of RH-TRU waste. The characterization plan for RH-TRU waste, which will be the basis of characterization requirements, is currently being developed and is the object of this report. Therefore, the committee can only address compliance with the existing legal requirements, stated in the Land Withdrawal Act (Congress, 1992) and in Title 40 of the Code of Federal Regulations Part 194 (40 CFR 194). The committee offers in this interim report its initial findings and recommendations to draw DOE’s attention to issues that emerged during the initial phase of the study. In the final report, scheduled for release in the summer 2002, the committee will provide a final set of findings and recommendations to address fully its task statement reported in Sidebar 1. This interim report has been reviewed in accordance with the procedures of the National Research Council and reflects the consensus of the committee.

SIDEBAR 2 THE WASTE ISOLATION PILOT PLANT The WIPP, located near Carlsbad in southeastern New Mexico, is an underground facility mined within a 600-meter-thick salt bed lying 660 meters below the surface. The salt bed, called the Salado Formation, originated approximately 250 million years ago. Large salt beds such as this are found only in geologic regions that lack significant flows of groundwater. The WIPP is located in the Carlsbad area because this deep, relatively dry, underground environment greatly reduces the possibility of waste releases from the repository by natural processes. Moreover, waste containment relies on an important property of salt beds: salt tends to “heal” itself after being mined. Therefore, after several hundred years, the mined salt at WIPP will creep back around the waste and encapsulate it, thereby permanently locking it deep beneath the surface. The WIPP has been under study since the mid-1970s and under construction since January 1981. EPA certified WIPP for emplacement of CH-TRU waste in May 1998. In 1999, NMED granted to WIPP a permit (the RCRA Permit) to emplace mixed CH-TRU waste. The first CH-TRU waste shipment was received from the Los Alamos National Laboratory in March 1999. The first out-of-state shipment was received in June 1999, from the Rocky Flats Environmental Technology Site, and in September 2000 the first mixed CH-TRU waste shipment was received from the Idaho National Engineering and Environmental Laboratory. The WIPP and a performance assessment tool A performance assessment is a risk-based assessment of the safety performance of a nuclear waste facility. The purpose of the performance assessment for WIPP is to evaluate the ability of the repository to isolate radioactive waste from the accessible environment. The performance assessment organizes information relevant to long-term (i.e., over a 10,000-year period) repository behavior by assessing the probabilities and consequences of major scenarios by which radionuclides can be released into

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INTRODUCTION

the environment surrounding the WIPP site. Important scenarios include those due to human activities, whether deliberate or unintentional, that might occur near the WIPP site and potentially compromise the integrity of the repository. The performance assessment process consists of: 1. 2. 3. 4. 5.

compiling features, events, and processes that could affect the disposal system; classifying events and processes to enhance consistency and completeness; screening individual events and processes; combining events and processes into specific scenarios; and screening scenarios to identify and eliminate those that have little or no effect on the performance assessment.

The final analysis of WIPP’s certification of compliance consisted of a qualitative assessment of the quantitative results of the performance assessment (National Research Council, 2001, 1996). DOE identified ten radionuclides important to the long-term performance of WIPP: americium-241, curium-244, cesium-137, plutonium-238, plutonium-239, plutonium-240, plutonium-241, strontium-90, uranium-233, and uranium-234. Of these ten, strontium-90, uranium-233, and cesium-137 are important to RH- but not CHTRU waste streams. Containment requirements for these radionuclides and others are promulgated in Title 40 CFR 191, Appendix A. The performance assessment tool was peer reviewed and validated by EPA in its final decision to certify WIPP.

8

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2 Remote-Handled Transuranic Waste

Transuranic waste is radioactive waste containing alpha-emitting radionuclides of atomic number greater than 92, half-life greater than 20 years, and activity greater than 100 nanocuries per gram of waste. Transuranic waste is composed of materials such as clothing, tools, debris, other disposable items, as well as sludge. The waste was produced during the processing of nuclear materials for defense purposes and the cleanup of various nuclear weapon sites across the nation. Alpha radiation is the primary radiation-related health hazard associated with TRU waste. Alpha radiation cannot penetrate human skin but poses a potential health hazard if alphaemitting particles are inhaled or ingested in large enough quantities. The main alpha-emitting radionuclides in TRU waste are plutonium-238, plutonium-239, plutonium-240, and americium-241. In addition to alpha radiation, TRU waste also emits gamma radiation, which can penetrate the human skin and requires shielding during transport and handling. Gamma radiation is due mainly to fission and activation products, principally from the progenies of cesium-137 and strontium-90, and from cobalt-60. Transuranic waste is classified as contact-handled (CH) or remote-handled (RH), according to the dose rate at the package surface. According to the legal definition, “the term ‘contact-handled transuranic waste’ means transuranic waste with a surface dose rate not greater than 200 millirem per hour. The term ‘remote-handled transuranic waste’ means transuranic waste with a surface dose rate of 200 millirem per hour or greater”1 (Congress, 1992). Contact-handled TRU waste typically emits relatively little gamma radiation. Therefore, it can be handled directly by workers. Remote-handled TRU waste emits higher levels of gamma (penetrating) radiation. Therefore, gamma rays represent the main radiological health hazard for workers handling RH-TRU waste. Although alpha-radiation exposure has a greater health risk per unit energy deposited dose, the likelihood that workers will be exposed to alpha radiation is smaller compared to the likelihood for exposure to gamma radiation, because of the smaller penetration power for alpha radiation.2 Therefore, RH-TRU waste should not be handled directly by workers and requires heavy container shielding and/or remote-handling equipment. Transuranic waste is further classified as non-mixed or mixed. Mixed TRU waste contains both radioactive material regulated under the Atomic Energy Act and hazardous waste material regulated under RCRA. Examples of hazardous waste material are ignitable, corrosive, reactive, and toxic substances. DOE also makes a distinction between retrievably stored waste and newly generated waste, according to the waste generation period. Retrievably stored waste is

1The legal definition of CH-TRU and RH-TRU waste cited above is from the WIPP’s Land Withdrawal Act (Public Law 102–579). The 200 mrem per hour at the surface of a container has its basis in transportation requirements, and encompasses the assumption that a worker carrying packages with surface does rate of 200 mrem per hour for 30 minutes a day will not exceed the recommendation of 100 mrem per day of local exposure. The legal definition for a waste package emitting exactly 200 mrem per hour is ambiguous. Transuranic waste packages approaching the definitional limit (200 mrem/hour) are handled directly or remotely, depending on site-specific practices. 2This statement is not true if RH-TRU waste containers are breached and workers are directly exposed to alpha-emitting particles.

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waste produced after 19703 but prior to the implementation of an approved RH-TRU waste characterization plan. DOE is in the process of defining this waste characterization plan, through Documents 1 and 2, to obtain EPA’s and NMED’s approval. Newly generated waste is waste that is produced after the development, approval, and implementation of the waste characterization plan and meets the characterization requirements set forth by the regulatory agencies. Newly generated waste may be waste yet-to-be generated, such as waste at the Hanford Site (see below), or may be existing waste that needs to be re-packaged in a suitable form for transportation and disposal. For the newly generated waste total inventory (1,400 m3), the information constituting acceptable knowledge will be collected during the packaging or the re-packaging of the waste. According to DOE, AK for newly generated waste will meet the characterization requirements developed under the new RH-TRU waste characterization plan: “Waste that has to be repackaged or is being generated from a process line or decontamination/decommissioning can be generated in a way that supports disposal. Generating the data to support waste disposal to meet quality assurance requirements (i.e., two operators involved in data generation per process line; one to produce data and the other to validate) negates the need for nondestructive examination” (DOE-CBFO, 2000, section 2.3.1.6). RH-TRU WASTE INVENTORY Figure 1 shows the geographic location of the major RH-TRU waste generator sites in DOE’s nuclear weapons complex. These are the following: • • • •

Hanford Site, Washington, Idaho National Engineering and Environment Laboratory (INEEL), Los Alamos National Laboratory (LANL), New Mexico, and Oak Ridge National Laboratory (ORNL), Tennessee.

The figure also shows relative volumes of RH-TRU waste compared to CH-TRU waste for these sites. Tables 1 and 2 show RH-TRU waste inventories in terms of volume and radioactivity. These data show that there is substantial variability among generator sites concerning waste volumes and radioactivity contents. Table 1 shows the RH-TRU waste inventory of retrievably stored waste, newly generated waste, and planned volumes of waste to be shipped to WIPP. The inventory of retrievably stored RH-TRU waste at all DOE sites is 2,197 m3. A volume of about 1,400 m3 will be generated in the future, for a total of about 3,598 m3 of RHTRU waste. Further volume-reducing operations (see below) will decrease the waste volume to be emplaced in WIPP to 1,964 m3, as shown in the “Planned Volume” column of Table 1.

3In 1970, the Atomic Energy Commission (predecessor to DOE) first identified TRU waste as a separate category of radioactive waste. That same year, the Atomic Energy Commission determined that all TRU waste generated after 1970 must be segregated from low-level waste and placed in retrievable storage pending shipment to, and disposal in, an approved geologic repository. Transuranic waste produced in support of the nuclear weapons program from the 1940s through 1970 was disposed of by shallow land burial and other techniques at a number of sites owned and operated by the federal government. This type of waste is referred to as buried transuranic waste and most of this waste is considered irretrievable. The characterization plan reviewed by the committee does not address buried TRU waste.

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REMOTE-HANDLED TRANSURANIC WASTE

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The RH-TRU waste volume inventory comprises between 1 and 4 percent in volume of the total (CH-TRU plus RH-TRU) inventory for the WIPP facility (175,564 m3). The Land Withdrawal Act, governing emplacement of TRU waste at WIPP, limits RH-TRU waste volume to 7,080 m3. According to Table 1, the volume of RH-TRU waste planned to be emplaced in WIPP is well below the statutory limit. Tables 1 and 2 do not show the uncertainties in the inventories of RH-TRU waste at the different sites. These uncertainties arise from changes in the waste management or treatment plans. For example, DOE’s data for the Savannah River Site (SRS), in South Carolina, originally indicated a large RH-TRU waste inventory, reflecting disposal of materials stored in the separations canyons as TRU waste. However, SRS now plans to send this material to the high-level waste tanks, and process it with other high-level wastes, i.e., transform it into glass waste forms in the Defense Waste Processing Facility, for eventual disposition in a federal high-level waste repository. The uncertainties can also be significant for the sites that have yet to produce their RH-TRU waste, such as Hanford (see below).

FIGURE 1 Geographic location of the major RH-TRU waste sites and the WIPP. There are several other sites throughout the nation storing CH-TRU waste. SOURCE: DOE-CBFO, 2001c.

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TABLE 1 RH-TRU Waste Inventory of Retrievably Stored, Newly Generated, and Planned Volumes in m3 Sites

Retrievably stored waste

Newly Gen. Waste

Total Volume

Planned Volume

Hanford Site

207

938

1,145

1,048

INEEL

84

101

185

275

LANL

99

24

123

120

ORNL

1,306

288

1,594

453

Argonne National LaboratoryEast

2

8

10

10

Argonne National LaboratoryWest

1

5

6

6

Battelle Columbus Laboratories

0

20

20

20

Bettis Atomic Power Laboratory

3

0

3

3

Energy Technology Engineering Center

8

0

8

5

General Electric-Vallecitos Nuclear Center

11

0

11

11

Knolls Atomic Power Laboratory

3

6

10

10

Sandia National Laboratories

1

24

25

West Valley Demonstration Project

470

8

478

Total Waste

2,797

1,400

3,598

Major Sites

Small Quantity Sites

1,964

NOTE: Planned volume denotes the final packaged volume to be shipped to WIPP for disposal. The planned volume may be lower than the total volume because of the volume-reducing activities during the preparation of the waste for shipment (see text). The committee did not verify the information in this table. SOURCE: DOE-CBFO. 2001c.

Table 1 shows that most of the retrievably stored RH-TRU waste is located at ORNL (1,306 m3). This volume represents nearly 60 percent of the retrievably stored volume, and 36 percent of the total volume (3,598 m3) of RH-TRU waste. About two-thirds of the retrievably stored waste at ORNL is wet sludge and one-third is debris. The sludge will be dewatered, dried, and packaged for shipment in a special facility, currently under construction. Debris waste consists of hot cell4 and glovebox debris packaged in shielded containers. This waste will undergo volume-reduction operations during packaging. To meet the milestones set in the Federal Facility Compliance Act between DOE and the State of Tennessee, ORNL decided to move forward with the characterization facility to treat or re-package its RH-TRU waste and characterize it at the same time according to the same criteria set forth for CH-TRU waste characterization (EPA, 1992). Before treatment, homogeneous samples of wet sludge will be characterized by radiochemical assays performed in a laboratory on-site. Debris will be characterized by visual

4A hot cell is a large chamber for handling highly radioactive materials. It is usually equipped with thick shielding walls and viewing windows, remote-operated overhead cranes, closed-circuit televisions, and a variety of specialized tools and measuring devices.

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examination and non-destructive examination5 inside a hot cell during re-packaging. This treatment will reduce ORNL RH-TRU waste volume from 1,594 to 453 m3. Therefore, most of RH-TRU waste at ORNL is considered “newly generated waste” and will be characterized at the time of its generation. Table 1 also shows that most of the newly generated waste will be produced at the Hanford Site, where the RH-TRU waste inventory represents 37 percent of the newly generated volume of RH-TRU waste and 26 percent of the total volume. The RH-TRU waste at this site consists mostly of sludge on the bottom of the fuel pools, or equipment inside waste tanks, such as pumps, mixers, and pipelines, or RH-TRU waste buried in caissons and drums. At INEEL, the 185 m3 of retrievably stored RH-TRU waste is composed mostly of solids generated during the destructive examination of irradiated experimental fuel pins in a hot cell.6 Packaging of this waste will increase its total volume, as indicated in the table. The 99 m3 of retrievably stored RH-TRU waste at LANL was characterized and packaged between 1989 and 1994. LANL characterized this waste using the same characterization plan approved for CH-TRU waste, which consists of non-destructive assay methods, radiography, and radiochemical analyses. Characterization operations were performed in a hot cell, except for small quantities of waste analyzed for radiochemical composition in a laboratory. Therefore, RH-TRU waste at LANL will probably not need to be re-characterized because the methods used are in compliance with the already approved CH-TRU characterization plan. According to the information provided by DOE-CBFO, about 80 percent of the RH-TRU waste inventory (retrievably stored waste plus newly generated waste) will meet the characterization requirements in the new RHTRU waste characterization plan. In fact, this waste consists of yet-to-be-generated waste (as the waste at the Hanford Site), waste that will be re-packaged (as the sludge at ORNL), or waste that was characterized according to the approved CH-TRU characterization plan (as at LANL). For the remaining 20 percent of RH-TRU waste, DOE proposes to complement the existing AK, where necessary, with additional confirmatory activities (see Chapter 4). In the National Transuranic Waste Management Program DOE writes about retrievably stored waste: “Waste that has already been generated must undergo extensive characterization to meet the requirements of the WIPP Waste Analysis Plan to meet certification requirements for disposal (for instance, nondestructive examination, RCRA constituent sampling, analysis of homogeneous waste, and visual examination)” (DOECBFO, 2000). Table 2 shows that the retrievably stored RH-TRU waste activity is approximately 660,000 curies. The data show that 88.6 percent of this activity is in the retrievably stored RH-TRU waste at ORNL. Most of the radioactivity in RH-TRU waste is due to short-lived radionuclides such as cobalt-60 (half-life 5.26 years), plutonium-241 (14.4 years), strontium-90 (half-life 28 years), and cesium-137 (half-life 30 years). Therefore, in approximately 300 years, the radioactive content of RH-TRU waste due to gamma

5For

a definition of non-destructive examination, see the glossary (Appendix D). RH-TRU waste stored at INEEL was generated at Argonne National Laboratory East (ANL-E) mostly from defenserelated programs. The destructive examination and testing operations of spent fuel pins involved cutting, grinding, and polishing for subsequent examination. These operations generated a fine fuel particulate that adhered to the tools required for these operations, thus contaminating them with TRU elements. These tools (e.g., grinding and cutting wheels, glassware, light bulbs, rags) have been sent to INEEL. The fuel pin segments, integral fuel pins and the fuel dust are still stored at ANLE as high level waste or spent fuel for future disposition. A formal determination of the defense origin for RH-TRU waste stored at INEEL will be submitted for approval to DOE prior to disposal at WIPP (Bhatt, 2001). 6The

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REMOTE-HANDLED TRANSURANIC WASTE

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emitters will have decayed to approximately the same level as that of CH-TRU waste. After this period, RHTRU waste will be virtually indistinguishable from CH-TRU waste. In the Appendix BIR (Baseline Inventory Report) of the Compliance Certification Application (CCA), DOE calculated the total activity of the RH-TRU waste inventory (from retrievably stored waste and newly generated waste) to be approximately one million curies (DOE-CAO, 1996). Therefore, the estimated amount of RH-TRU curies to be emplaced in WIPP is considerably lower than the total amount of curies from RH-TRU waste allowed by the Land Withdrawal Act (5.1 million). The total activity to be emplaced in WIPP from CH-TRU waste is approximately 6.4 million curies. DOE calculated that the percentage of total activity from the RH-TRU waste inventory represents approximately 14 percent of the total activity expected in WIPP (from CH-TRU and RH-TRU waste). However, the percentage of activity due to long-lived TRU radionuclides in RH-TRU waste is only 0.5 percent of the total activity due to long-lived TRU radionuclides in both CH- and RH-TRU waste.7 Only long-lived TRU radionuclides are relevant to the long-term performance of the repository because the regulatory compliance period is 10,000 years and most of the radioactivity from fission products in RH-TRU waste will decay away in approximately 300 years. Therefore, RH-TRU waste represents a small fraction of the total TRU inventory in WIPP, both from the point of view of volume and TRU activity. TABLE 2 RH-TRU Waste Inventory Summary Activity Estimates in Curies Sites

Retrievably Stored Waste Activity (curies)

Major Sites Hanford Site

36,000

INEEL

6,360

LANL

10,700

ORNL

587,000

Small Quantity Sites Argonne National Laboratory-East

NR

Argonne National Laboratory-West

NR

Battelle Columbus Laboratories

5,800

Bettis Atomic Power Laboratory

16,300

Energy Technology Engineering Center

8

General Electric-Vallecitos Nuclear Center

NR

Knolls Atomic Power Laboratory

118

Sandia National Laboratories

NR

West Valley Demonstration Project

NR

Total Waste

662,286

NOTE: NR=Not Reported. NR typically denotes that the site did not report the information for a variety of reasons (e.g., the data are not readily available, the pedigree of the data may be questionable, recent characterization has not been performed, or the site did not respond). The committee did not verify the information in this table. SOURCE: DOE-CBFO, 2001c.

7Activities for RH- and CH-TRU waste were estimated in 1995, year of the inventory compilation. Activities decrease very rapidly for RH-TRU waste because of the short half-lives of its radionuclides. Activity ratios are also calculated in the CCA for the year 2033 (closure of the WIPP) and 2133 (end of the period of active institutional controls).

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ISSUES RELATED TO THE HANDLING OF RH-TRU WASTE Disposal of RH-TRU waste entails a number of activities at the generator sites and at WIPP, including the following: • • • • • • •

waste processing, waste characterization, packaging or re-packaging, local waste storage, loading of waste transportation casks, transportation from the generator sites to WIPP, and underground emplacement in WIPP.

The main issues concerning the handling of RH-TRU waste are potential radiation worker exposure and the associated costs (DOE-CBFO, 2001d). The predominant exposure pathways for workers from routine waste handling activities are direct exposure to external penetrating radiation or inhalation from surface contamination, and inhalation of airborne radioactive material generated during characterization and handling activities. Exposure pathways for workers under accident conditions include direct exposure to external penetrating radiation and inhalation of airborne particulates and gases due to accidents related to mechanical or thermal insults of waste containers (Restrepo and Millard, 2001). Because of the high surface dose rates, all of the handling operations involving RH-TRU waste are performed in hot cells, where available, and/or by remotehandling equipment. Therefore, the cost associated with the handling of RH-TRU waste is also an important issue. Waste processing activities consist of converting the waste to a form suitable for disposal in WIPP. For instance, wet sludge must be dried first because liquids are not allowed in WIPP (if more than one percent of waste volume). Waste characterization is necessary to receive permission to ship the waste to WIPP. DOE is proposing a characterization plan, described in Chapter 4, that relies mainly on information collected about the waste, called acceptable knowledge (AK), and reduces the use of confirmatory methods. According to DOE, this would reduce the potential for worker exposure from intrusive sampling and analysis activities as well as characterization costs (Document 2, Supplemental Information). Packaging or re-packaging will be carried out on waste that has not yet been generated (packaging) or on retrievably stored waste that has been packaged in the past but the container does not meet transportation requirements (re-packaging). Visual examination of solid waste during the re-packaging step is one of the most common characterization techniques performed in hot cells. As the waste is removed from the old container and sorted into new containers, a videocamera records on tape the items on the table while an operator describes them. This characterization method requires skilled operators to describe the waste, since it is done entirely by remote methods (see committee’s Observation 3 in Chapter 5). Volume-reducing operations, such as mechanical waste compacting, are also performed during the re-packaging process. Once the waste is packaged or repackaged, it must be stored on-site until it receives EPA’s and NMED’s (the latter only for mixed waste) approval for shipment. Finally, RH-TRU waste must be loaded onto transportation casks,8 transported to WIPP, and emplaced into horizontal boreholes in the walls of the disposal rooms.

8The

design of these casks must be certified by the U.S. Nuclear Regulatory Commission.

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DOE is concerned about the potential exposure of workers to radiation during the characterization and handling of RH-TRU waste (DOE-CBFO, 2001d). As supplemental information for Document 2, DOE presented a report evaluating risk/cost-impacts associated with RH-TRU waste characterization options compared with characterization of CH-TRU waste. Options included full characterization, as done for CH-TRU waste, AK, and visual and/or radiographic examination. Characterization activities associated with CH-TRU waste include non-destructive assay, headspace gas sampling, visual examination/radiography, solid coring and sampling, container venting, and gas-generation testing (Appendix A). The analysis addresses risk based on the dose to workers associated with routine characterization activities and risk from accidents (Restrepo and Millard, 2001). According to this analysis, worker doses do not increase substantially with increase in characterization of RH-TRU waste, assuming that adequate facilities and equipment will be used for characterization. However, the risk to workers from postulated accidents involving RH-TRU waste increase by factors of 2 for AK, 4 for visual examination/radiography, and 10 for full RH-TRU characterization compared to a normalized CH-TRU risk of 1.0. Using AK to characterize RH-TRU waste would minimize worker doses and risks (Restrepo and Millard, 2001, page ii). The findings of the risk/cost analysis report are consistent with the committee’s observation that, because most operations involving the characterization of RH-TRU waste are performed remotely, workers may receive comparable radiation doses characterizing RH-TRU waste to those received in the characterization of CH-TRU waste performed outside a hot cell. Moreover, it is not clear whether workers will be exposed to radiation specifically during the characterization step, given that there are other potentially more hazardous steps involved in the complete handling of RH-TRU waste at the generators’ sites, such as packaging, handling, and transporting the waste. While data on worker exposure during characterization of CH-TRU waste is available, data on worker exposure during the characterization of RH-TRU waste are scarse. As mentioned previously, the RH-TRU waste inventory at LANL has already been characterized and it is now stored on-site waiting for permission to be shipped to WIPP. Dose data pertaining to the characterization step per se have not been collected because of the negligible doses involved in the operations in the hot cell or on small samples in the laboratory. Staff from LANL estimated that the risk of radiation exposure is negligible during the characterization of waste, rather it is from the handling of containers outside the hot cell.9 The Battelle Columbus Laboratories (BCL) in Ohio is the only site currently characterizing RH-TRU waste. BCL developed its own RH-TRU waste characterization plan, which involves visual examination of the waste during re-packaging. The re-packaging step, which occurs in a hot cell, is necessary because the current RHTRU waste containers do not meet transportation requirements. The estimated collective dose to workers handling RH-TRU waste, as determined by BCL health physics staff, is 100 person-mrem (1 person-millisievert) per container.10 This is a cumulative dose, which includes waste characterization, as well as the handling of the containers for onsite storage. Several workers are involved in the manipulation and transfer of each container. BCL also monitored for radiation exposure to individual workers during container handling and manipulation; for instance, the lid and seals of waste containers

9Personal

communication with Dr. Larry Field, staff of the Los Alamos National Laboratory, October 17, 2001. dose corresponds to an average of 5 workers handling the containers. Battelle Columbus Laboratory memorandum from D.Ridgley dated 12April, 2000. 10This

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must be attached manually outside of the hot cell. A typical dose to a worker is 10–20 mrem (0.1–0.2 millisievert) per container. According to the “Supplemental Information” attachment of Document 2, the estimate for worker dose resulting from the characterization of CH-TRU waste is approximately 15–20 mrem per container (Restrepo and Millard, 2001). This is based on DOE and generator data estimates of 15–30 contacts and handling per container, 5–10 mrem per hour contact dose rate, and assuming a reduction factor of 5 for workers conducting routine operations at some distance from the waste containers. These data show that exposure at BCL (10–20 mrem per container) is comparable to the exposure for the characterization of CH-TRU waste. It is unclear how the exposure incurred during the characterization phase compares to that incurred in other handling operations. It is also unclear how representative BCL worker exposure data are for other RH-TRU waste generators. For instance, container handling methods and procedures (the key determinant of worker dose) may be different at other generator sites. However, data from BCL are informative because this is the only site currently characterizing RH-TRU waste. DOE is also concerned about the costs associated with the characterization of RH-TRU waste if performed following the same characterization plan approved for CH-TRU waste. This plan is summarized in Appendix A. Briefly, the CH-TRU characterization plan requires sampling and analysis to confirm AK and the application of some characterization techniques on every container. According to DOE and the generator sites, the characterization of a RH-TRU waste container under the CH-TRU waste characterization requirements is estimated to cost in the range of $20,000 to $300,000 per container (Restrepo and Millard, 2001). In contrast, the cost for characterizing a CH-TRU waste is about $3,800 per container11 (DOE-EM, 2001). The large range in characterization cost estimates is due to the variability in the waste content and the characterization processes among the sites. In addition, these cost estimates are not site-specific and take into account only a few characterization scenarios. According to the risk/cost impact analysis in Document 2, “costs incurred for full characterization of RH-TRU waste relative to CH-TRU costs increase by about an order of magnitude for full characterization to $300,000 per container. Infrastructure costs increase from $10,000 for CH-TRU to $100,000 per container for full characterization of RH-TRU waste…increased costs are due to additional storage, retrieval, handling, and characterization times necessary to compensate for increased radiation exposure conditions” (Restrepo and Millard, 2001, page ii and 19).12

11The most representative characterization cost data refer to the characterization of CH-TRU waste at the Rocky Flats Test Site. The cost of $3,800 per container includes retrieval from storage, radiography, non-destructive assays, headspace gas analyses, visual examination, gas generation testing, data validation, data package preparation, container certification, and WIPP data verification. Data do not include costs for treatment, storage, or loading transuranic waste in transportation casks. 12The committee has not validated these cost estimates.

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3 Regulatory Context for the Disposal of RH-TRU Waste

The U.S. Congress, through the Land Withdrawal Act (Public Law 102–579), designated the WIPP to be the nation’s repository for defense-related TRU waste (Congress, 1992). Congress also established the controlling legal criteria for WIPP in the Land Withdrawal Act. This Act stipulates that EPA must establish the disposal regulations for TRU waste at WIPP. EPA promulgated radiation safety standards in 40 CFR Part 191 and Part 194, the latter specifically for WIPP. EPA authorized NMED to regulate radioactive mixed wastes in New Mexico in accordance with EPA’s regulations. This state regulatory authority extends only to TRU mixed wastes destined for WIPP (EPA, 1990). Therefore, NMED regulates the management, storage, and disposal of TRU mixed waste at WIPP, and establishes the general and specific standards for these activities. The main regulatory documents for TRU mixed waste are the New Mexico Hazardous Waste Act as codified in Part 20 of the New Mexico Administrative Code (NMAC). DOE’s new characterization plan for RH-TRU waste must be in compliance with the above regulatory documents. At the time of the certification of WIPP, DOE interpreted and translated EPA’s and NMED’s regulatory documents into characterization requirements for TRU waste. These requirements were accepted by EPA and NMED and appear now in EPA’s certification and in the RCRA Permit for WIPP. These requirements are described in the following paragraphs. LAND WITHDRAWAL ACT REQUIREMENTS FOR TRANSURANIC WASTE IN WIPP The Land Withdrawal Act is the only guiding legislation for WIPP. As defined in the Land Withdrawal Act: • The term “WIPP” means the Waste Isolation Pilot Plant project authorized to demonstrate the safe disposal of radioactive waste materials generated by atomic energy defense activities. • The term “disposal” means permanent isolation of transuranic waste from the accessible environment with no intent of recovery, whether or not such isolation permits the recovery of such waste. • The term “transuranic waste” means waste containing more than 100 nanocuries of alpha-emitting transuranic isotopes per gram of waste, with half-lives greater than 20 years, except for: (A) high-level radioactive waste, (B) waste that the Secretary of Energy has determined, with the concurrence of the EPA Administrator, does not need the degree of isolation required by the disposal regulations, or (C) waste that the Nuclear Regulatory Commission has approved for disposal on a case-by-case basis in accordance with Part 61 of Title 10, Code of Federal Regulations (Congress, 1992).

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The Land Withdrawal Act establishes the five main legal requirements for TRU waste in WIPP, some of which apply specifically to RH-TRU waste. These requirements are the following: • Nature of waste to be disposed in WIPP: the WIPP can only receive transuranic waste (defined above) generated by atomic energy defense activities. • Total volume of transuranic waste: the WIPP is allowed to contain up to 175,564 m3 of transuranic waste at WIPP. • Volume of RH-TRU waste: the WIPP is allowed to contain up to 7,080 m3 of RH-TRU waste, which represents about 4 percent of the total volume of TRU waste allowed in WIPP. • Total activity of RH-TRU waste: RH-TRU waste received at WIPP shall not exceed 23 curies per liter maximum activity level (averaged over the volume of the container). The total curies of the RH-TRU waste received at WIPP shall not exceed 5.1 million curies.1 WIPP’S CERTIFICATION REQUIREMENTS FOR THE CHARACTERIZATION OF TRANSURANIC WASTE • In 1998, EPA certified that WIPP is in compliance with the radioactive waste disposal regulations set forth in 40 CFR 191 and 40 CFR 194 and in compliance with EPA standards set forth by the Land Withdrawal Act of 1992. A characterization program to meet these requirements was developed for TRU waste and is now applied to CH-TRU waste. In EPA’s view, “DOE has established a precedent with CH waste program” (Monroe, 2001). The CH-TRU waste characterization program is therefore perceived as the standard against which the RH-TRU waste characterization application will be evaluated. The characterization requirements, listed in the CH-TRU waste characterization plan, were based on the conclusions drawn from the performance assessment of the repository. DOE presented its performance assessment for WIPP in the CCA submitted to EPA to obtain certification (see Sidebar 2). The characterization objectives for CH-TRU waste are based on waste parameters identified as important to the performance of the repository (Helton et al., 1998). These parameters are the following: • Amount of free water: In the CCA, DOE stated that the total amount of water or brine present is important because water is the only means to release radionuclides in the environment and because it controls several other factors, such as corrosion and gas generation.2 The total limit in the RH-TRU waste inventory of free water must be less than 71 m3. In the CCA, DOE agreed to meet this requirement by demonstrating that a • Surface dose rate: no TRU waste received at WIPP may have a surface dose rate exceeding 1,000 rems per hour. No more than 5 percent of 7,080 m3 (354 m3) is allowed to have surface dose rates exceeding 100 rems per hour.

1Note that the total activity limits for RH-TRU waste do not distinguish between the activity due to the TRU nuclides and that due to the gamma emitters. 2The main gases potentially generated in the WIPP in presence of brine are carbon dioxide, methane, and hydrogen. These gases are generated by microbial waste degradation inside the WIPP. In addition, hydrogen can also be produced by radiolysis or by corrosion of metal containers. An increase in gas pressure inside the repository must be avoided since it may affect room closure rates, fracture development, brine inflow, and the possibility of waste entrainment in gas during a drilling event (called spalling).

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RH-TRU waste stream or an individual container contains less than 1 percent by volume of residual liquids.3 • Amount of corrodible metals: The CCA includes requirements for a minimum amount of corrodible metals in WIPP. The minimum amount of corrodible metals has been set to ensure a reducing environment inside the repository. A reducing environment maintains radionuclides in a low oxidation state, which usually corresponds to a minimum solubility. Therefore, waste characterization must ensure that the amount of corrodible metals in the waste is above the minimum amount allowed. • Amount of biodegradable cellulosics, plastic, and rubber (CPR): DOE must account for the volume of CPR because of the potential gas generation from the decomposition of these organic materials. RCRA PERMIT REQUIREMENTS FOR THE CHARACTERIZATION OF TRANSURANIC WASTE In 1999, NMED granted a RCRA Permit to WIPP to manage and dispose of mixed CH-TRU waste only. This permit currently contains requirements for the characterization of mixed CH-TRU waste. DOE is now proposing a change to the RCRA Permit to allow disposal of mixed RH-TRU waste. NMED recommended that DOE build its proposed RH-TRU waste characterization plan based upon the requirements in the existing permit and to provide justification for any difference between the RH-TRU and the existing CH-TRU characterization plan (Zappe, 2001). Currently, the RCRA Permit requires that the characterization of mixed TRU waste be based on the knowledge of the physical form of waste (homogeneous solids, soil or gravel, debris) and the exclusion of prohibited items, listed as follows: • • • • •

Liquid waste, Non-radionuclide pyrophorics (addressed by the hazardous waste numbers4), Hazardous wastes that do not contain TRU waste, Incompatible chemicals (addressed by the hazardous waste numbers), Polychlorinated biphenyls greater than or equal to a concentration of 50 ppm (addressed by the hazardous waste numbers), • Explosives (addressed by the hazardous waste numbers) and compressed gases, and • Ignitable, corrosive, and reactive wastes (addressed by the hazardous waste numbers).

Items such as polychlorinated biphenyls, compressed gas, and other types of hazardous waste were probably not accounted for in the AK accumulated for retrievably stored RH-TRU waste. For this type of waste, AK must be complemented by other methods, as those listed in Chapter 4 from 40 CFR 194.22(b). The current RCRA Permit also excludes RH-TRU waste, any waste container that does not have volatile organic compound concentrations reported for the headspace, any waste container that has not undergone radiographic or visual

3The limitation of free liquid to 1 percent of the waste volume is primarily a transportation requirement. DOE used this requirement as one of the initial assumptions in the analysis of the repository performance presented in the CCA. Therefore, the repository is certified on the basis of the presence of 1 percent or less of free liquid in the waste. This requirement is now integrated as part of EPA’s requirements to ensure the performance of the repository as predicted in the CCA. 4See the glossary (Appendix D).

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examination, and any waste container that has not been preceded by a certified Waste Stream Profile Form.5 FINDINGS OF THE PREVIOUS NATIONAL RESEARCH COUNCIL’S COMMITTEE6 ON WIPP The 1998 Committee on WIPP found “inadequate legal or safety bases for some of the National TRU Program requirements and specifications. That is, some waste characterization specifications have no basis in law, the safe conduct of operations to emplace waste in WIPP, or long-term performance requirements” (National Research Council, 2001, page 77). The 1998 Committee recommended that DOE “eliminate selfimposed waste characterization requirements that lack a legal or safety basis” (National Research Council, 2001, page 78). The 1998 Committee understood that those requirements that have no legal or safety bases are also not important to the long-term performance of the repository. A recent study by DOE showed that some waste characterization procedures are indeed not prescribed by safety or legal requirements (DOE-CAO, 1999a). This review of the CH-TRU waste characterization procedures by DOE-CBFO revealed that “there is no regulatory requirement to conduct homogeneous waste sampling and analysis, however, in an effort to meet the intent of 40 CFR 264.13, WIPP has imposed additional characterization requirements on the waste generators.” DOE also informed the 1998 Committee that “there is no regulatory requirement to conduct headspace gas sampling and analysis, however, in an effort to meet the intent of 40 CFR 264.13, WIPP has imposed additional characterization requirements on the waste generators.” Finally, the 1998 Committee found that there is no legal requirement for the verification of radiography results by visual examination.7 According to the study by DOE-CBFO and according to the 1998 Committee, DOE developed self-imposed waste restrictions in the waste acceptance criteria (DOE-CAO, 1996b, 1999b) and in the requirements for waste generating sites presented in the quality assurance program plan8 (DOE, 1998b). Therefore, sampling and analysis of homogeneous waste, headspace gas sampling and analysis, and visual examination procedures to characterize CH-TRU waste are based on terms negotiated in the RCRA Permit rather than driven by performance-based characterization requirements (National Research Council, 2001, Appendix A1).

5See

the glossary (Appendix D). National Research Council Committee on the Waste Isolation Pilot Plant (1998–2001). The committee is referred to as “the 1998 Committee.” 7Visual examination is the process of physically examining TRU waste by removing it from the container it was originally packaged in. The justification for visual examination in the RCRA Permit and in EPA’s certification is to verify acceptable knowledge and radiography information. 8The quality assurance program plan describes the overall plans and activities to meet the project’s quality assurance goals. These consist of the planned and systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satisfactorily in service. 6The

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DESCRIPTION OF DOE’S CHARACTERIZATION PLAN FOR RH-TRU WASTE

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4 Description of DOE’s Characterization Plan for RH-TRU Waste According to the information gathered during committee meetings, DOE’s stated objective is to propose a characterization plan for RH-TRU waste based on the determination of only those waste characteristics that have an impact on the long-term performance of WIPP.1 The intention is to reduce potential worker exposure to radiation, in compliance with the ALARA (as low as is reasonably achievable) principle, reduce costs, and eliminate self-imposed requirements for waste characterization (DOE-CBFO, 2001d). This plan is different from the existing EPA and NMED-approved characterization plan for CH-TRU waste. DOE acknowledged that the “contact-handled TRU waste characterization program is inefficient and costly. [The] RH-TRU waste characterization program should be performance-driven” (DOE-CBFO, 2001d). According to the information provided in Documents 1 and 2, the justification for a characterization plan different from that for CH-TRU waste relies on the small inventory of RH-TRU waste compared to that of CHTRU waste and on the small impact of RH-TRU waste components on the repository performance. The rationale for this new plan is given in two Sandia National Laboratories RH-TRU waste impact analyses, presented in Attachment B of Document 1 and in Appendix 1 of Document 2. The committee received updated information from DOE-CBFO on the RH-TRU waste inventory during its two information-gathering meetings. These data are reported in Tables 1 and 2 in Chapter 2. The plan proposed by DOE for RH-TRU waste characterization relies primarily on AK to provide adequate characterization information. AK refers to knowledge of waste characteristics derived from information on materials or processes used to generate the waste. This information may include administrative, procurement, and quality control documentation associated with the generating process, or past sampling and analytic data. The major elements of process knowledge usually include information about the process used to generate the waste, material inputs to the process, and the time period during which the waste was generated.2 Additional AK is created when old wastes are sampled, treated, or repackaged. Acceptable knowledge is applied on a waste stream basis3 and may be supplemented with sampling and measurement programs or container-by-container measurements. Based upon EPA’s requirements set forth in 40 CFR 194.22(b), existing process information collected before an approved quality assurance program is in place must be qualified for use as AK. Presumably, this would apply to AK data for any retrievably stored RH-TRU waste. 40 CFR 194.22(b) lists four methods that may be used individually or in combination to qualify such data: (1) peer review, (2) use of corroborative evidence, (3) confirmation by measurements, or (4) qualification of previous quality assurance programs. DOE proposes to use the first three of these options “frequently” to qualify “old” AK data (data collected prior to the approved quality

1DOE

refers to this concept as “performance-based” or “performance-driven characterization plan.” definition of AK is derived from EPA’s definition of “process knowledge,” which is similar to the definition DOE uses for AK (40 CFR 194). EPA describes “process knowledge” as a subset of AK. 3A waste stream is defined as waste material generated from a single process or activity or as multiple containers with similar physical, chemical, or radiological characteristics. 2This

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assurance program plan) for RH-TRU waste characterization whenever a site deems that a 100 percent inspection required for CH-TRU waste characterization to be either too costly or too risky for a particular RHTRU waste stream (see Document 1, page 5). Confirmatory activities may be performed on sub-populations samples from the waste stream every time AK meets the characterization requirements and is elected to be the sole method used to characterize a waste stream. These activities will be performed on statistical samples if AK on a waste stream is found to be inconclusive, incomplete, or does not have sufficient information necessary to meet the characterization requirements. If confirmation by representative sampling and measurement is the approach selected, measurements will be performed using standard non-destructive examination techniques, standard radioassay techniques, and standard radiological survey techniques as appropriate for the characterization requirement. The RH-TRU characterization plan provides some flexibility to the sites for meeting the characterization requirements. The plan allows the sites to manage the waste characterization risk to workers by establishing subpopulations of waste streams that can be characterized using radiography or visual examination to complement AK based on operational considerations (e.g., facility radiation limits). The methodologies for representative selection of containers and of waste stream sub-populations, as well as the frequency for these confirmatory measurements are not specified in the proposed RH-TRU characterization plan. Instead, the plan provides the flexibility to determine how to meet the established characterization requirements using the allowable confirmatory methods described above. No details are provided for how DOE will ensure that sites have appropriately applied the allowable methods. However, the methodology for establishing the representative selection of containers and waste stream sub-populations must be documented and approved by DOE in each site’s quality assurance program plan. In addition, the documents/records associated with the representative container and sub-population selection must be maintained in the site project records and are subject to DOECBFO audit. DOE’S PLAN TO ADDRESS EPA’S CERTIFICATION REQUIREMENTS FOR RH-TRU WASTE DOE’s proposed method to meet EPA’s certification requirements, addressing also the requirements in the Land Withdrawal Act, is to use AK to meet all or part of the characterization requirements of the approved quality assurance program plan. Where AK is deemed to be the sole source of characterization information, it will be subject to verification and validation using the requirements set forth in 40 CFR 194.22(b). To meet the requirements of 40 CFR 194.22(b), which provide for added assurance that the AK information is adequate, AK characterization results will be qualified, confirmed, or verified using any one or a combination of the four allowed methods from 40 CFR 194.22(b) mentioned above. DOE is planning to meet the data quality objectives4 for RH-TRU waste using the following methods: • Measure surface dose rate of RH-TRU waste containers to exclude those with surface dose rates exceeding 1,000 rems per hour.

4Data quality objectives are qualitative and quantitative statements that clarify program technical and quality objectives, define appropriate types of data, and specify tolerable levels of potential decision errors that will be used as the basis for establishing the quality and quantity of data needed to support decisions.

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• Track the RH-TRU waste total activity inventory by the quantification of total activity for a unit (waste stream or individual container) within a factor of five of the true value with a confidence level of 95 percent. • Account for metals by counting containers as they are emplaced in the WIPP repository.5 • Account for CPR by automatically assigning a value of 50 percent of CPR in the net weight of an emplaced RH-TRU debris container. • Constrain the total inventory of free water by limiting individual units or containers of RH-TRU waste to less than one percent by volume of residual liquid. The total inventory of free water is tracked using AK, visual examination during repackaging, or radiography to verify that the water content is less than one percent by volume. Document 1 provides examples of what DOE would consider “adequate AK” in the determination of EPA’s required parameters. For instance, if process knowledge shows that a waste stream is composed exclusively of pyrochemical salts, this precludes any significant residual liquids and assures that there is less than one percent by volume of residual liquids (Document 1, Attachment A, page 13). DOE’S PLAN TO ADDRESS THE RCRA PERMIT REQUIREMENTS FOR RH-TRU WASTE The characterization objectives to comply with the RCRA Permit requirements reflect the waste parameters (described in Chapter 3) that must be known to store or dispose of the waste at the WIPP facility. In Appendix A of Document 2, DOE includes an analysis by Sandia National Laboratories that estimates the inventory impact assessment for the WIPP’s RCRA Permit. A 300-year model of the WIPP facility was used to demonstrate that the air pathway is the only viable pathway for hazardous constituent release even under bounding conditions on the contents of RH-TRU mixed waste. The simulation results show that there is no migration of contaminated brine across the land withdrawal boundary. According to DOE, an insignificant amount of contaminated brine leaves the waste area and no contaminated gas migrates beyond the immediate boundaries of the repository. Thus, the calculation results show that in the 300-year period, there is insufficient brine to saturate the waste and form a mobile leachate. Without a mobile leachate, RCRA-regulated metals, or other soluble RCRA-regulated substances cannot be transported to the accessible environment in the long term. A volatile organic compound emissions model was used to demonstrate that the generation of volatile organic compounds from RH-TRU waste could be calculated without requiring headspace gas sampling and analysis. Moreover, according to DOE’s analysis, cellulosics, plastic, rubber, ferrous metal, and free liquid in RH-TRU waste will not have a significant impact on repository performance, even at quantities much greater than expected. Therefore, DOE does not deem it necessary to determine, to a high degree of certainty, the presence and quantity of the above waste components. On the basis of this analysis, DOE proposes that waste characterization information needed for the safe management of RH-TRU waste may be obtained primarily by using AK and be complemented by radiography or visual examination. Under the proposed approach, AK

5Metals only have a minimum limit in the CCA. According to DOE, waste containers supply more than enough iron to provide adequate reducing conditions. Hence, metals inside waste containers do not need to be quantified.

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DESCRIPTION OF DOE’S CHARACTERIZATION PLAN FOR RH-TRU WASTE

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would also be used to determine the physical form of the waste and the absence of prohibited items. DOE states that the “AK characterization method proposed for RH-TRU waste complies with 40 CFR Parts 260 through 264 requirements, is consistent with formally issued joint NRC [Nuclear Regulatory Commission]/EPA guidance, and reduces worker exposure to radioactivity in compliance with 10 CFR Part 835” (Document 2, Item 2, page 2– 12). The proposed RH-TRU waste characterization plan to achieve NMED requirements is as follows: • Determine the physical form of the waste at the Summary Category Group level. • Determine the absence of the following prohibited items: 1. 2. 3. 4. 5.

Liquids; Pyrophoric materials; Incompatible waste; Explosives and compressed gases; and Polychlorinated biphenyls with concentrations greater-than-or-equal-to 50 ppm.

• Determine the listed and characteristic hazardous constituents in the waste. • Determine if a waste is listed as specified in 20.4.1.200 NMAC (incorporating 40 CFR 261.31 and 33); assign the appropriate EPA hazardous waste number(s); and list EPA’s hazardous waste number(s). • Determine if a waste exhibits the toxicity characteristic as specified in 20.4.1.200 NMAC (incorporating 40 CFR 261.24); assign the appropriate EPA hazardous waste number(s); and list EPA’s hazardous waste number(s). In Document 2, DOE writes: “prohibited items that are not addressed by the hazardous waste number determination are determined through the use of AK, radiography and/or visual examination […]. If sufficient information to determine the absence of prohibited items is not available through the use of one or more of these three waste characterization techniques, the waste is not acceptable for disposal at the WIPP facility. The remaining prohibited items in the RCRA Permit overlap with the prohibited items for transporting the waste in one of the RH-TRU waste shipping casks approved by the U.S. Nuclear Regulatory Commission […]. Therefore, the combination of information available from the proposed characterization techniques and the information used to ensure legal waste transportation to WIPP ensures that the absence of prohibited items is known to a sufficient degree of confidence” (Document 2, Item 2, page 2–7). On the basis of the analysis presented in Appendix A of Document 2, DOE determined that the proposed RH-TRU characterization plan does not require the determination of material parameter category weights, toxicity characteristic codes, and headspace gas analysis. The determination of these three parameters is required in the CH-TRU waste characterization plan. In summary, DOE proposes to use AK as much as possible to accumulate the information on RH-TRU waste required by NMED and EPA and to perform only the confirmatory measurements required to complete AK. Details on these confirmatory measurement requirements are not specified in Documents 1 and 2. This plan is quite different from the CH-TRU waste characterization plan currently in use, as explained below.

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DESCRIPTION OF DOE’S CHARACTERIZATION PLAN FOR RH-TRU WASTE

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COMPARISON OF THE RH-TRU AND CH-TRU CHARACTERIZATION PLANS The CH-TRU waste characterization plan approved by EPA and NMED is described in Appendix A. Briefly, it consists of a 100 percent of confirmatory activities on CH-TRU waste containers by AK, radioassay, headspace gas sampling, radiography, or visual examination. Both EPA and NMED must grant approval of each generator site’s waste characterization process and approval for each waste stream. For homogeneous wastes,6 this includes taking core samples of a fraction of waste containers prior to their shipment to WIPP. For debris wastes, a 100 percent confirmation program (with headspace gas and radiography determinations for RCRA compliance, and NDA and radiography determinations for EPA’s compliance) was imposed. The most significant difference between the CH- and the RH-TRU waste characterization plans is that the latter does not require confirmatory testing, sampling, or analysis on 100 percent of containers and allows for representative selection of containers for radiography and visual examination. According to DOE, and as noted previously, the quality assurance provisions of 40 CFR 194.22(b) allow DOE to qualify AK by (1) peer review, (2) corroboration with new data, (3) confirmation by measurements, or (4) qualification of previous quality assurance programs. Currently, only confirmatory measurements are being considered and their frequency of use is not specified. Like the current CH-TRU program, each specific TRU waste generator site will develop a sitespecific RH-TRU waste characterization plan that will undergo audit by DOE and inspection by EPA and NMED before shipment of RH-TRU waste from that site. EFFECTIVENESS OF AK From the operational experience acquired with CH-TRU waste, it is possible to obtain some indication of the effectiveness of the AK method as a characterization method. The WIPP permit requires generator sites to prepare an AK Information Accuracy Report. Two measures are specified: 1) Percentage of waste containers that require reassignment to a new Waste Matrix Code.7 2) Percentage of waste containers that require designation of different hazardous waste numbers. AK information accuracy is determined as the result of AK Information Confirmation. Generators are to use radiography or visual examination, headspace gas sampling and analysis, and/or solids sampling and analysis to confirm AK information accuracy. Effectiveness of the CH-TRU acceptable knowledge process is demonstrated by the AK Information Accuracy Reports from the various generator or storage sites (DOE-CBFO, 2001e). During the second information-gathering meeting, DOE showed results of the effectiveness of AK for CH-TRU characterization. Results showed a high accuracy in AK information: above 95 percent for the determination of waste matrix codes at the major CH-TRU waste generator sites and above 93 percent for the determination of hazardous waste numbers, with one exception. At INEEL, an accuracy

6Homogeneous waste is one of the “Summary Category Groups” that indicate the final form of the waste. Homogeneous waste is waste consisting of one main constituent (for instance, sludge) as opposed to the other two category groups: soils and gravel, and debris waste. 7See the glossary (Appendix D).

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DESCRIPTION OF DOE’S CHARACTERIZATION PLAN FOR RH-TRU WASTE 27

of 80 percent was achieved in the hazardous waste numbers determination because this site did not assign new codes on a container basis.

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COMMITTEE’S PRELIMINARY FINDINGS AND RECOMMENDATIONS

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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 CHTRU 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 committee recommends that existing requirements for CHTRU 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.

1DOE, during the second committee meeting declared that the “contact-handled TRU waste characterization program is inefficient and costly” (DOE-CBFO, 2001d).

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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 performancebased 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 of 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

2According 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).

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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 2×107kg. 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 a self-imposed requirement is acknowledged by DOECBFO 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 RHTRU waste characterization plan. A similar recommendation was made by the RSI 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

3The 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).

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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 of 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 re-packaged (see Chapter 2). For this large amount of waste, the information constituting AK will be collected during the generation or the re-packaging 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 re-packaged 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

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• 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 site5 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. 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

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

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an example of a missing or 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 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

be provided to go to other characterization methods if AK is found to be insufficient” (RSI, 2001, page 77).

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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 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 informationgathering 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, 2001e). 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, CPRs, and hazardous material) will have a minimal impact on the repository performance. These analyses are presented in

7 The 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). 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).

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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 Documents 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 RHTRU wastes, are indeed substantial and therefore meet the criteria and intent of a Class 3 modification” (Document 2, NMED1_FrontMatter, page 5). 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.

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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.

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References

40 CFR 191. EPA (U.S. Environmental Protection Agency). Environmental Radiation Protection Standards for the Management and Disposal of Spent Nuclear Fuel, High-level and Transuranic Radioactive Wastes. Final Rule. December 20, 1993. Federal Register 58(242):66398–66416. 40 CFR Part 194. EPA. Criteria for the Certification and Recertification of the Waste Isolation Pilot Plant’s compliance with the 40 CFR Part 191 Disposal Regulations, Final Rule. May 18, 1998. Federal Register 63(95):27353–2740. Bhatt, R.N. 2001. Explanation on the origin of RH-TRU waste at INEEL. Personal communication. Congress (U.S. Congress). 1992. The Waste Isolation Pilot Plant Land Withdrawal Act, as amended. Public Law 102–579. Available at: . DOE (U.S. Department of Energy). 2001. Summary Data on the Radioactive Waste, Spent Nuclear Fuel, and Contaminated Media Managed by the U.S. Department of Energy. April. 2001. Available at: . DOE-CAO (U.S. Department of Energy-Carlsbad Area Office). 1996a. Compliance Certification Application, DOE/CAO-1996–2184. Carlsbad, New Mexico. DOE-CAO. 1996b. Waste Acceptance Criteria for the Waste Isolation Pilot Plant, DOE/WIPP-069, Revision 5. Carlsbad, New Mexico. DOE-CAO. 1999a. Findings and Recommendations of the Transuranic Waste Characterization Task Force. Final Report. August 9. Carlsbad, New Mexico. DOE-CAO. 1999b. Waste Acceptance Criteria for the Waste Isolation Pilot Plant, Revision 7. DOE/WIPP-069. Carlsbad, New Mexico. DOE-CBFO (U.S. Department of Energy-Carlsbad Field Office). 2000. National TRU Waste Management Plan. DOE/NTP-96–1204. Revision 2. December 2000. Albuquerque, New Mexico. DOE-CBFO. 2001a. Draft Class 3 Permit Modification Request for RH-TRU Mixed Waste, Revision 1. July 17, 2001. Carlsbad, New Mexico. DOE-CBFO. 2001b. Notification of Proposed Change to the EPA’s Waste Isolation Pilot Plant 40 CFR Part 194 Certification. July 16, 2001. Draft. Revision 1. Carlsbad, New Mexico. DOE-CBFO. 2001c. RH-TRU waste inventories. Presentation before the committee during the second information-gathering meeting. October 2, 2001. Albuquerque, New Mexico. DOE-CBFO. 2001d. Inés Triay’s presentation before the committee during the first information-gathering meeting. August 3, 2001. Columbus, Ohio. DOE-CBFO. 2001e. Robert Kehrman, DOE-CBFO presentation before the committee during the second information-gathering meeting. October 2, 2001. Albuquerque, New Mexico. DOE-CBFO. 2001f. Roger A.Nelson, DOE-CBFO. Personal communication. DOE-EM (U.S. Department of Energy-Office of Environmental Management). 2001. Transuranic Waste Characterization Cost Analysis. Memorandum from L.Wade, Director of the Waste Isolation Pilot Plant Office. February 23, 2001. Washington, District of Columbia. EPA (U.S. Environmental Protection Agency). 1990. New Mexico: Final Authorization of State Hazardous Waste Management Program. Revision. July 11, 1990. Federal Register 55(133):28397.

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EPA. 1992. Oak Ridge Federal Facility Compliance Agreement for Mixed Waste Subject to Land Disposal Restrictions (LDR). June 12, 1992. DOCKET NO. 92–02 FFR. Available at: . EPA. 1998. CARD (Compliance Application Review Document) No. 24 Waste Characterization. Available at: . EEG (Environmental Evaluation Group). 2001. Some Issues Identified by EEG regarding the Characterization of RH TRU Waste. Statement of Dr. Matthew Silva before the committee on October 4, 2001. Albuquerque, New Mexico. Helton, J.C., J.E.Bean, J.W.Berglund, F.J.Davis, K.Economy, J.W.Garner, J.D. Johnson, R.J.MacKinnon, J.Miller, D.G.O’Brien, J.L.Ramsey, J.D.Schreiber, A.Shinta, L.N.Smith, D.M.Stoelzel, C.Stockman, and P.Vaughn. 1998. Uncertainty and Sensitivity Analysis Results Obtained in the 1996 Performance Assessment of the Waste Isolation Pilot Plant. SAND98–0365. Sandia National Laboratories. Albuquerque, New Mexico. Monroe, S.D. 2001. EPA Requirements for Remote-Handled Transuranic Waste. Presentation before the committee during the first information-gathering meeting. August 3, 2001. Columbus, Ohio. National Research Council. 1996. The Waste Isolation Pilot Plant. A Potential Solution for the Disposal of Transuranic Waste. National Academy Press. Washington, District of Columbia. National Research Council. 2001. Improving Operations and Long-Term Safety of the Waste Isolation Pilot Plant. National Academy Press: Washington, District of Columbia. Nelson, R.A. 2001. DOE-CBFO explanation of data quality objective for total activity of RH-TRU waste. Provided during the second committee meeting. Albuquerque, New Mexico. Restrepo, L.F. and J.B.Millard. 2001. A Risk/Cost Impact Analysis of Various Options for Characterizing Department of Energy Generated Remote-Handled Transuranic Waste. June 30, 2001. Omicron-01–012. Albuquerque, New Mexico. In Notification of Proposed Change to the EPA’s Waste Isolation Pilot Plant 40 CFR Part 194 Certification. July 16, 2001. Draft. Revision 1. Carlsbad, New Mexico. RSI (Institute for Regulatory Science). 2001. Requirements for Disposal of Remote-Handled Transuranic Wastes at the Waste Isolation Pilot Plant. Technical Peer Review Report. ASME International. ASME/CRTD-RP-01–84. July 30-August 3, 2001. Carlsbad, New Mexico. Taggart, D. 2001. Private communication with Dr. D.Taggart, DOE-CBFO. November 14, 2001. TWBIR (Transuranic Waste Baseline Inventory Report). 1996. U.S. Department of Energy, Carlsbad Area Office. DOE/CAO-95–1121, Revision 3, June 1996. Carlsbad, New Mexico. Zappe, S. 2001. NMED’s Prohibition of Remote-Handled TRU Waste at WIPP. Presentation before the committee during the second information-gathering meeting. October 2, 2001. Albuquerque, New Mexico.

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APPENDIX A

39

Appendix A CH-TRU Waste Characterization Plan

The characterization program described here has been developed for contacthandled transuranic (TRU) waste and applied to date to TRU mixed waste. The methods, equipment, procedures, determination of uncertainty, and other protocols used at DOE sites to perform these characterizations have been approved by the Department of Energy (DOE) Carlsbad Field Office, New Mexico Environment Department (NMED) and EPA. The major procedures are described in the following sections: Determination of the Origin and Composition of the Waste by Acceptable Knowledge. Acceptable knowledge of the origin and composition of the waste must be documented to provide evidence that the waste has a defense origin (by the terms of the Land Withdrawal Act, only defense-related TRU waste may legally be sent to the Waste Isolation Pilot Plant (WIPP) and to provide characterization information on the waste constituents. DOE Carlsbad Area Office and EPA use the acceptable knowledge documentation to certify each “waste stream” (i.e., waste-generating process), and TRU waste sent to WIPP must come from a certified waste stream. Sampling and Analysis of Homogeneous Waste for Resource Conservation Recovery Act (RCRA) Constituents. Most of the TRU waste is heterogeneous in nature and requires no further characterization beyond acceptable knowledge to satisfy the regulatory requirements of RCRA. For homogeneous waste, a fraction of the waste containers (e.g., 55-gallon drums or standard waste boxes) are cored to extract representative samples that are analyzed for constituents (e.g., volatile and semi-volatile organic compounds, toxic metals, and other hazardous chemicals) regulated by RCRA. Both the acceptable knowledge procedure (for heterogeneous waste) and the sampling and analysis procedure (for homogeneous waste) were proposed by DOE for the terms of operation that would be specified in its RCRA Permit. These terms have been accepted by New Mexico, which was delegated authority by EPA to regulate RCRA materials and mixed waste and to issue the RCRA Part B permit in October 1999. Radiography. A radiography procedure using X rays, also called real-time radiography, is performed on all waste containers to look for items such as pressurized cans or free-standing liquids that are prohibited from being transported under DOT regulations. If any of these items are present in a waste container, the prohibited materials are removed and the contents repackaged. This radiographic examination is also used to confirm the acceptable knowledge characterization information. Visual Examination. A visual examination is performed on a fraction of the waste containers by placing the waste contents into a glovebox to verify the acceptable knowledge and real-time radiography information. DOE proposed that two percent of the initial population of containers of each waste stream be visually examined, and if these evaluations resulted in few miscertifications, then the percentage of subsequent waste containers to undergo visual examination would be reduced. In October 1999, New Mexico in its RCRA Permit stipulated the initial fraction of containers to undergo visual examination to be 11 percent. Radioassay and Determination of Fissile Isotope Content. The number of curies of each transuranic isotope is determined by radioassay (e.g., gamma scans) to a specified precision and accuracy. The fissile isotope content is assessed using non-destructive assay methods, such as passive-active neutron systems. This information is

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APPENDIX A

40

used to meet the Nuclear Regulatory Commission requirement restricting the amount (several hundred grams) per container of each fissile species to ensure criticality safety. Headspace Gas Sampling. Headspace gas sampling is carried out on all waste containers for flammable gases (specifically, volatile organic compounds, hydrogen, and methane). This procedure has been proposed as a means of checking on conformity with the U.S. Department of Transportation regulations (e.g., 40 CFR 173 and 40 CFR 177) and U.S. Nuclear Regulatory Commission regulations (e.g., 10 CFR 71) that address the transport of flammable and/or gas-generating substances with radioactive materials. DOE has proposed the headspace gas sampling procedure in its application to the U.S. Nuclear Regulatory Commission for a licensing certificate on the transportation package (named the TRansUranic PACkage Transporter, or TRUPACT-II) that is loaded with waste containers for transport by truck to WIPP.

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APPENDIX B

41

Appendix B Information Gathered to Date

In addition to the committee’s expertise in relevant technical disciplines and knowledge of the Department of Energy (DOE) problems, several other sources of information were used to develop this interim report. The committee reviewed Documents 1 and 2, and considered relevant regulatory documents, such as 40 CFR 191, 40 CFR 194, in particular subpart 24 referring to waste characterization, the Land Withdrawal Act, RCRA (Resource Conservation and Recovery Act) Permit, and the joint Nuclear Regulatory Commission/EPA guidance. The committee held two information-gathering meetings so that members could familiarize themselves with the problems at four Remote-Handled Transuranic (RH-TRU waste) waste generator sites and hear from the stakeholders. During the first meeting, which was held on August 1–3, 2001 in Columbus, Ohio, DOE gave the committee an overview of its draft RH-TRU characterization plan. The committee received briefings on the following sites: • • • • • •

Argonne National Laboratory, Illinois Battelle Columbus Laboratories, Ohio, Hanford Site, Washington, Idaho National Engineering and Environment Laboratory, Los Alamos National Laboratory, and Oak Ridge National Laboratory.

The committee heard about current characterization methods for RH-TRU waste and their limits and possibilities. The briefings were followed by a tour of the Battelle Columbus Laboratories site. Thus far, the committee has received complete cooperation from DOE and has not been constrained in its information gathering efforts. During the second meeting, held on October 3–5, 2001, in Albuquerque, New Mexico, the committee was briefed by New Mexico Environment Department, the Environmental Evaluation Group, and by local interested members of the public.

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APPENDIX C

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Appendix C Biographical Sketches of Committee Members

Eula Bingham, Chair, is a professor of environmental health at the University of Cincinnati. Dr. Bingham’s interests include risk assessment, regulatory toxicology, environmental carcinogenesis, and occupational health surveillance. She was a volunteer investigator at the National Institute of Environmental Health Sciences and the assistant secretary of labor (Occupational Safety and Health Administration). She was the first recipient of the William Lloyd Award for occupational safety. Throughout her career, Dr. Bingham has served on numerous national and international advisory groups, including advisory committees of the National Research Council, Food and Drug Administration, Department of Labor, National Institute for Occupational Safety and Health, National Institutes of Health, Natural Resources Defense Council, and the International Agency for Research on Cancer. These committees addressed research needs in health risk assessment and the potential health effects of environmental exposure to chemicals. In 1989, Dr. Bingham was elected to the Institute of Medicine. She earned her M.S. in physiology and her Ph.D. in zoology from the University of Cincinnati. Sanford Cohen is the founder and president of SC&A, Inc., an energy and environmental consulting firm providing expertise in radiation sciences, management, health and safety analyses, communications services, and information management. He has managed several contracts for agencies of the U.S. government, including the Environmental Protection Agency, the Centers for Disease Control, the Council on Environmental Quality, the Congressional Office of Technology Assessment, the Department of Energy, and the Nuclear Regulatory Commission. Dr. Cohen is involved in regulatory guidance pertaining to environmental management (including RCRA/CERCLA requirements), remediation of contaminated sites, safe disposal of hazardous wastes, site characterization in support of decontamination and decommissioning projects, recycling of scrap metal from nuclear facilities, electric and magnetic fields effects, and indoor air quality. Prior to founding SC&A in 1981, Dr. Cohen was the vice president and manager of Teknekron, Inc., Washington Operations, and president of Teknekron Research, Inc., a consulting group working with the above government agencies. Dr. Cohen earned his B.S. in science engineering at Northwestern University and his Ph.D. in nuclear engineering at the University of Michigan. Milton Levenson is an independent consultant. Mr. Levenson is a chemical engineer with more than 50 years of experience in nuclear energy and related fields. His technical experience includes work in technologies related to nuclear safety, fuel cycle, water reactors, advanced reactors, and remote control. His professional experience includes research and operations positions at the Oak Ridge National Laboratory, the Argonne National Laboratory, the Electric Power Research Institute, and Bechtel. Mr. Levenson is a fellow and past president of the American Nuclear Society; a fellow of the American Institute of Chemical Engineers; and recipient of the American Institute of Chemical Engineers’ Robert E.Wilson Award. He is the author of more than 150 publications and presentations and holds three U.S. patents. Mr. Levenson served as chairman or committee member in several National Research Council studies, including the most

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APPENDIX C

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recent study on WIPP. He was elected to the National Academy of Engineering in 1976. He received his B.Ch.E. from the University of Minnesota. Kenneth Mossman is professor of health physics and director of the Office of Radiation Safety at Arizona State University (ASU) in Tempe, where he has also served as assistant vice president for research. Prior to his arrival at ASU, Dr. Mossman was a faculty member of the medical school and dental school at Georgetown University in Washington, D.C., and was professor and founding chairman of the Department of Radiation Science in Georgetown’s Graduate School. His research interests include the biological effects of low-level radiation, radiation exposure in pregnancy, health effects of environmental radon, radiation protection, and public policy. Dr. Mossman has over 110 publications, including six books and proceedings related to radiation health issues. He has presented testimony before the U.S. House of Representatives and the U.S. Senate. In 1984, Dr. Mossman was awarded the prestigious Elda Anderson Award from the Health Physics Society (HPS), in 1995 he received the HPS Marie Curie Gold Medal; and from 1996 to 1998 he served as a Sigma Xi distinguished lecturer. Dr. Mossman was elected a fellow of the HPS in 1994 in recognition of outstanding contributions to the field of health physics; he also served as president of HPS. Dr. Mossman earned a B.S. in biology from Wayne State University, M.S. and Ph.D. degrees from the University of Tennessee in radiation biology, and M.Ed, degree in higher education administration from the University of Maryland. Ernest Nieschmidt is the director of the Laser Laboratory and adjunct associate professor of physics at Idaho State University, College of Engineering. His research interests span the development of a neutron activation analysis facility, sonoluminescence, and the destruction of hazardous organic components of mixed waste by free-radical chemistry. He is also involved in the development of the Laser Isotope Separation Laboratory to pursue research in separation of isotopes using selective excited states induced by laser. For most of his career, Mr. Nieschmidt worked for different contractors at the Idaho National Engineering and Environmental Laboratory on techniques to assay radioactive and transuranic waste material. These included passive and active neutron interrogation, analysis of active gamma rays and gamma rays produced by neutron inelastic scattering, neutron capture, chronoimaging, time correlations, and the application of position-sensitive detectors. He authored 106 publications related to topics in physical sciences. Mr. Nieschmidt earned his M.S. in physics at the San Diego State College. John Plodinec is director of the Diagnostic Instrumentation and Analysis Laboratory at Mississippi State University. His laboratory specializes in developing instrumentation for unusual environments and in characterizing processes and technologies under real-world conditions. Dr. Plodinec is an internationally recognized expert in waste management and glass science. He has made important contributions in several areas of radioactive waste management, ranging from waste characterization to glass durability modeling. Prior to joining the Mississippi State University, he worked for 22 years at DOE’s Savannah River Site, where he collaborated in building and operating the first remote in-cell melter and served as primary technical lead for the product qualification program. In this capacity, he oversaw the remote-handled transuranic waste streams produced by the Savannah River Site. He has authored over 90 publications, primarily on waste vitrification and thermodynamics of waste management. He holds a patent on a device to sample high-level waste and on a slurryfeeding device for glass

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APPENDIX C

44

melters. Dr. Plodinec earned his Ph.D. in physical chemistry from the University of Florida. Anne E.Smith is a vice president of Charles River Associates (CRA), an economics consulting firm. Dr. Smith is an expert in risk management, cost-benefit analysis, economic modeling, and integrated assessment of complex environmental and energy issues. Issues that she has analyzed include contaminated sites, global climate change, air quality, and emissions trading. Dr. Smith has developed and reviewed decision support tools for risk-based ranking of contaminated sites and for making risk trade-offs in selecting remediation alternatives. She has submitted formal comments on the development of EPA Hazard Ranking System for identifying Superfund sites, has served on committees of the National Research Council on assessing contaminated site risk management activities, was a project leader in a review for the U.S. Congress of Superfund and RCRA concerns within the U.S. nuclear weapons facilities, and her testimony has been sought by committees of the U.S. Senate on air quality issues. Dr. Smith has a Ph.D. in economics from Stanford University, with a Ph.D. minor in engineering-economic systems. Prior to joining CRA, Dr. Smith was a vice president of Decision Focus Inc. She has also served as an economist in the Office of Policy Planning and Evaluation of the U.S. Environmental Protection Agency.

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APPENDIX D

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Appendix D Glossary

20.4.1:

20.4.1.200: 20.4.1.500:

20.4.1.900:

10 CFR 20: 10 CFR 835:

40 CFR 191:

(the New Mexico Administrative Code (NMAC) chapter 20, section 4, part 1). New Mexico Environment Department. Establishes the regulations for the management of hazardous waste consistent with the New Mexico Hazardous Waste Act and Federal RCRA regulations, 40 CFR Parts 260 through 270. New Mexico Environment Department. This regulation (incorporating 40 CFR Parts 261.24, 261.31 and 361.33) requires DOE to identify and list hazardous wastes. New Mexico Environment Department. This regulation (incorporating 40 CFR 264) requires DOE to conduct a detailed analysis of the hazardous waste components of transuranic mixed waste to obtain all the information on how to treat, store or dispose of the waste. DOE must demonstrate that the design and operation of the facility will minimize the possibility of the release of TRU mixed waste, a fire, or an explosion. NMED prohibits the following at WIPP: • liquid waste, • pyrophoric materials, • non-mixed hazardous wastes, • chemically incompatible wastes, • explosives and compressed gases, • polychlorinated biphenyl concentrations, and • ignitable, corrosive, and reactive waste. New Mexico Environment Department. This document contains the hazardous waste permit program requirements issued by the NMED (incorporating 40 CFR 270). These requirements must be met by the DOE to receive NMED approval of the waste analysis plan submitted as Part B of the permit application (see Hazardous Waste Permit) for mixed transuranic waste. (Title 10 Code of Federal Regulations Part 20): United States Nuclear Regulatory Commission. Standards for Protection Against Radiation. U.S. Department of Energy. Occupation Radiation Protection. Establishes the standards, limits, and program requirements for protecting individuals from ionizing radiation resulting from DOE activities. U.S. Environmental Protection Agency. Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes, Final Rule. This regulation prescribes EPA environmental radiation protection standards that will apply to all sites (except Yucca Mountain) for the deep geologic disposal of highly radioactive waste. Congress required EPA to evaluate whether the WIPP complies with subparts B and C of the disposal regulations set forth in this document for the management and disposal of transuranic radioactive wastes.

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APPENDIX D

40 CFR 194:

46

U.S. Environmental Protection Agency. Criteria for the Certification and Recertification of the Waste Isolation Pilot Plant’s compliance with the 40 CFR Part 191 Disposal Regulations, Final Rule. This regulation stipulates that DOE must provide a list to the EPA that identifies and describes waste characteristics that can impact the WIPP’s performance. This list may be derived from methods that include process knowledge and non-destructive assay/examination. On May 18, 1998, the EPA issued a final rule certifying that the WIPP was compliant with applicable EPA TRU waste disposal regulations set forth in 40 CFR 191 and the compliance criteria of 40 CFR 194 (63 FR 27354). 40 CFR 194.22(b): U.S. Environmental Protection Agency. This section includes the quality assurance requirements for waste characterization activities and assumptions. The quality assurance provisions allow the characterization of waste by 1) peer review; 2) corroboration with new data, 3) confirmation by measurement, or 4) qualification of previous QA programs. 40 CFR 261: U.S. Environmental Protection Agency. Identification and Listing of Hazardous Waste. This part identifies those solid wastes that are subject to regulation as hazardous wastes under Parts 262– 265, 268, 270, 271, and 124 of Title 40 of the Code of Federal Regulations. Codified in New Mexico as 20 NMAC 4.1, Subpart II. 40 CFR 264: U.S. Environmental Protection Agency. Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities. This subpart establishes minimum national standards, that define the acceptable management of hazardous waste. Codified in New Mexico as 20 NMAC 4.1, Subpart V. 40 CFR 270: U.S. Environmental Protection Agency. This regulation establishes provisions for the Hazardous Waste Permitting Program under Subtitle C of the Resource Conservation and Recovery Act. This regulation and the associated State of New Mexico regulations require the permitting of the WIPP as a hazardous waste management unit. Codified in New Mexico as 20 NMAC 4.1, Subpart IX. Acceptable Knowledge: a term used by the EPA that encompasses process knowledge and results from previous testing, sampling, and analysis of waste. Acceptable knowledge includes information regarding the raw materials used in a process or operation, process description, products, and associated wastes. Acceptable knowledge documentation includes the site history and mission, site-specific processes or operations administrative building controls, and all previous and current activities that generate a specific waste. ALARA: As low as is reasonably achievable. Radiation protection program for minimizing personnel exposure to radiation. Audit: a planned and documented investigative evaluation of an item or process to determine the adequacy and effectiveness as well as compliance with established procedures, instructions, drawings, and other applicable documents. Buried Transuranic radioactive waste meeting the current definition of TRU waste, which was disposed of by shallow Waste: land burial and other techniques at a

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APPENDIX D

47

number of sites owned and operated by the federal government in support of the nuclear weapons program from the 1940s through 1970. In 1970 the Atomic Energy Commission first identified TRU waste as a separated category of radioactive waste, and all TRU waste generated after 1970 has been segregated from low-level waste and placed in retrievable storage pending shipment to and disposal in an approved geologic repository. Most of this buried waste is considered irretrievable. Compliance Certifica- DOE submits this application (titled 40 CFR Part 191, Compliance Certification Application for tion Application (CCA): the Waste Isolation Pilot) to the EPA in order to request certification from the EPA for the WIPP facility. Certified Waste: containers of waste that meet the WIPP waste acceptance criteria. Code of Federal Regula- 1) a codification of the general and permanent rules published in the Federal Register by the tions (CFR): department and agencies of the federal government. The CFR is divided into 50 titles that represent broad areas subject to federal regulation. It is issued quarterly and revised annually. 2) All federal regulations in force are published annually in codified form in the CFR. Contact-handled (CH) Transuranic waste that has a measured radiation dose rate at the container surface of 200 millirem waste: per hour or less and can be safely handled without special equipment when in closed containers. [LWA] Cellulosics, Plastic, the characterization objectives for RH-TRU waste set forth by the EPA in 40 CFR 191 and 40 CFR Rubber (CPR): 194 require that DOE account for the volume of CPR because of the potential gas generation from the decomposition of these organic materials. Data Quality Objectives qualitative and quantitative statements that clarify program technical and quality objectives, define (DQO): the appropriate type of data, and specify tolerable levels of potential decision errors that will be used as the basis for establishing the quality and quantity of data needed to support decisions. Defense Waste: 1) radioactive waste from any activity performed in whole or in part in support of DOE atomic energy defense activities; excludes waste under purview of the Nuclear Regulatory Commission or generated by the commercial nuclear power industry. 2) Nuclear waste derived mostly from the manufacturing of nuclear weapons, weapons-related research programs, the operation of naval reactors, and the decontamination of weapons production facilities. Gray (Gy): the standard unit of absorbed ionizing-radiation dose. Hazardous Constituent: those chemicals identified in Appendix VIII of 20 NMAC 4.1 Subpart II (40 CFR Part 261). Hazardous Waste. As defined in 40 CFR 261.3, waste that because of its quantity, concentration, or physical, chemical or infectious characteristics, may cause or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible illness, or pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed. Hazardous wastes are

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APPENDIX D

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listed in 20 NMAC 4.1 Subpart II (40CFR Part 261) and/or exhibit one of the four characteristics— ignitability, corrosivity, reactivity, and toxicity in 20 NMAC 4.1 Subpart II (40 CFR Part 261). Hazardous Waste Num- numbers assigned to identify the EPA category of hazardous waste. Hazardous waste numbers’ bers: assignment for RH TRU waste ensures that only those wastes that are permitted at the WIPP are disposed of and to ensure waste compatibility during the operational phase at the WIPP. Headspace Gas: the gas within the free volume at the top of a closed container (between the container lid and the waste inside the container) or containment, such as a drum or bin, containing TRU mixed or simulated waste. The gas may be generated from biological, chemical, or radiolytic processes; this includes contributions from volatile organic compounds (VOC) present in the waste. Headspace Gas Analysis:headspace gas is sampled using a gas-tight syringe to draw a gas sample from beneath the drum or box lid. The sample is analyzed by gas chromatography and/or mass spectrometry for hydrogen, methane, and volatile organic compounds. Land Withdrawal Act Public law 102–579 withdraws the land at the WIPP site from “entry, appropriation, and disposal.” (LWA): It transfers jurisdiction of the land from the secretary of the interior to the secretary of energy and reserves the land for activities associated with the development and operation of the WIPP. It requires DOE to comply with the EPA’s radioactive waste standards and final disposal regulations and to conduct studies to analyze the impact of RH-TRU wastes on repository performance. It includes many other requirements and provisions pertaining to the protection of public health and the environment. The LWA was signed into law on October 30, 1992. Non-destructive Exami- NDE is a general term for a number of standard techniques that include radiography and digital nation (NDE): radiography computed tomography (DR/CT). Radiography is a non-destructive qualitative and semi-quantitative technique that involves X-ray scanning of waste containers to identify and verify waste container contents. Because of the shielding associated with RH TRU waste, DR/CT may be required rather than the more commonly used radiography. New Mexico Hazardous the New Mexico legislation that establishes the state hazardous waste management program. Waste Act (HWA): Newly Generated TRU waste generated after the development, approval, and implementation of the TRU waste Waste: characterization program that meets the requirements outlined in the TRU waste characterization quality assurance program plan. Part of the inventory might not have been generated yet but is estimated to be generated at some time in the future by the TRU waste generator/storage sites. Packaging: the assembly of components necessary to ensure compliance with packaging requirements, it may consist of one or more receptacles, absorbent material, spacing structures, thermal insulation, radiation shielding, and devices for cooling or absorbing mechanical shocks.

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APPENDIX D

Performance Assessment:

49

risk-based assessment of the safety performance of a nuclear waste facility. The purpose of the performance assessment for WIPP is to evaluate the ability of the repository to isolate radioactive waste from the accessible environment. The performance assessment organizes information relevant to long-term (i.e., over a 10,000-year period) repository behavior by assessing the probabilities and consequences of major scenarios by which radionuclides can be released to the environment surrounding the WIPP site. Important scenarios include those due to human activities, whether deliberate or unintentional, that might occur near the WIPP site and potentially compromise the integrity of the repository. The performance assessment process consists of: 1. compiling features, events, and processes that could affect the disposal system; 2. classifying events and processes to enhance consistency and completeness; 3. screening individual events and processes; 4. combining events and processes into specific scenarios; and 5. screening scenarios to identify and eliminate those that have little or no effect on the performance assessment. The final analysis of WIPP’s certification of compliance consisted of a qualitative assessment of the quantitative results of the performance assessment. Pyrophoric: spontaneously ignitable materials. Process Knowledge: the determination of waste container contents through the study of existing records on the production history of the waste. Quality Assurance: the planned and systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satisfactorily in service. Quality Assurance Pro- documents that describe the overall program plans and activities to meet the project’s quality gram Plans (QAPP): assurance goals. Radioassay: a term used to define measurement methods for determining the radionuclide content of waste and includes both non-destructive assay (NDA) and destructive assay (e.g. radiochemistry). Radiological Survey: Measurements of radioactive contamination levels or dose rates associated with a site together with the appropriate documentation and data evaluation. When AK indicates that some containers may approach 1000 rem/h or that some containers exceed 100 rem/h then radiological surveys of each container may be required. Industry standard survey instruments can be used in this process and are required to discriminate at 100 rem/h and 1000 rem/h. Radiography: a non-destructive, non-intrusive radiographic examination technique that enables a qualitative (and in some cases quantitative) evaluation of the contents of a waste container. Radiography utilizes X rays to inspect the contents of the waste container in real time. It is used to examine and verify the physical form of the waste for certain waste forms, identify individual waste components, and verify the absence of certain non-compliant items.

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APPENDIX D

RCRA Part B Permit:

50

issued for the WIPP on October 27, 1999 by the NMED. This permit (incorporating 20.4.1.500 and 20.4.1.900) determines that DOE’s disposal plan for mixed TRU waste is acceptable. Also called the Hazardous Waste Facility Permit. Rem (Roentgen Equiva- unit of radiation dose used to derive a quantity called equivalent dose. This relates the absorbed lent Man): dose in human tissue to the effective biological damage of the radiation. Not all radiation has the same biological effect, even for the same amount of absorbed dose. Equivalent dose is often expressed in terms of thousandths of a rem, or mrem. The equivalent dose (rem) is determined by multiplying the absorbed dose (rad) by a quality factor (Q) that is unique to the type of incident radiation. Remote-handled (RH) transuranic wastes that have a measured radiation dose rate at the container survey of 200 millirem Waste: per hour or greater but not more than 1,000 rem per hour. This waste must be handled remotely (i.e., with machinery designed to shield the handler from radiation). Resource Conservation established a system for tracking and regulating hazardous wastes from the time of their generation and Recovery Act through disposal. The law requires safe and secure procedures to be used by hazardous waste (RCRA): generators in treating, handling, transporting, storing, and disposing of hazardous substances. RCRA is designed to prevent new uncontrolled hazardous waste sites. The law also regulates the disposal of solid waste that may not be considered hazardous. Note: 20 NMAC 4.1 and 40 CFR Parts 260–281 are the regulations for complying with RCRA with respect to hazardous waste and hazardous waste treatment, storage, and disposal facilities in New Mexico. Retrievably Stored TRU waste generated after 1970. In 1970 the Atomic Energy Commission (predecessor to the DOE) Waste: first identified TRU waste as a separate category of radioactive waste. The same year, the Atomic Energy Commission determined that all TRU waste generated after 1970 must be segregated from low-level waste and placed in retrievable storage pending shipment to and disposal in an approved geologic repository. Federal facilities in Washington, Idaho, California, Colorado, New Mexico, Nevada, South Carolina, Ohio, Tennessee, and Illinois are currently storing TRU waste. See also Buried Transuranic Waste. Roentgen: unit used to measure a quantity called exposure. This can only be used to describe an amount of gamma and Xrays, and only in air. One roentgen is equal to depositing in dry air enough energy to cause 2.58×10` 4 coulombs per kg. It is a measure of the ionizations of the molecules in a mass of air. The main advantage of this unit is that it is easy to measure directly, but it is limited because it is only for deposition in air, and only for gamma and x rays. Sievert: unit of measurement of radiation dose equivalent. One sievert is equal to the actual dose, in grays, multiplied by a quality factor that is larger for more dangerous forms of radiation. Summary Category categories for each waste stream to facilitate RCRA waste characterization that reflect the final Group: waste forms acceptable for WIPP disposal. The waste summary categories are identified by the generators and are the following:

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APPENDIX D

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S3000: Homogeneous solids S4000: Soils/gravel S5000: Debris waste radioactive waste consisting of radionuclides with atomic numbers greater than 92 in excess of agreed limits. A more precise definition, in DOE Order 5820.2A, EPA regulation 40 CFR 191, and the Land Withdrawal Act, is waste that is not high-level waste “contaminated with alpha-emitting radionuclides of atomic number greater than 92 and half-lives greater than 20 years in concentrations greater than 100 nanocuries per gram.” The regulatory definition excludes actinide elements with atomic numbers between 90 and 92 (most significantly, Th and U isotopes), in agreement with the literal meaning of “transuranic.” However, common usage of “transuranic waste” is often understood to include all actinides. Transuranic mixed TRU waste that is co-contaminated with hazardous constituents as identified in 20 NMAC 4.1 waste: Subpart II (40 CFR 261), subparts C and D. Visual Examination the process of physically examining TRU waste by removing it from the container it was originally (VE): packaged in. Volatile Organic Com- RCRA regulated organic compounds that readily pass into the vapor state and are present in pounds (VOC): transuranic mixed waste. Waste Acceptance Cri- a set of conditions established for permitting transuranic wastes to be packaged, shipped, managed, teria (WAC): and disposed of at the WIPP. Waste Analysis Plan document describing the procedures that will be carried out at a facility to obtain chemical and (WAP): physical analysis of each waste managed so that all information will be known to treat, store or dispose of the waste in accordance with 40 CFR 264.13. Waste Characterization: sampling, monitoring, and analysis activities to determine the nature of the waste. Waste Matrix Code: code assigned by the TRU waste generator/storage sites to categorize mixed and some non-mixed waste streams in the DOE system into a series of five-digit alphanumeric codes (e.g., S5400; Heterogeneous Debris) that represent different physical/chemical matrices. These codes were developed by DOE in response to the Federal Facility Compliance Act of 1992. Waste Profile Form: form that waste generator must complete to properly identify and document the characterization of any solid, liquid, hazardous, radioactive, or mixed waste. The Waste Profile Form must provide a complete and concise description of the waste, including the details of the generating process. The Waste Profile Form process provides generators with guidance to help make the determination of the waste’s physical, chemical, and radiological characteristics with sufficient accuracy to permit proper segregation, treatment, and disposal according to the final treatment/disposal facility’s waste acceptance criteria.

Transuranic Waste:

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APPENDIX D

Waste Stream:

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waste material generated from a single process or activity or as multiple containers with similar physical, chemical, or radiological characteristics.