Appendix D
DOE’s Response to the Committee’s Interim Report

In response to the committee’s interim report, the Department of Energy (DOE)-Carlsbad Field Office transmitted a summary of proposed resolutions or action items for the following draft of its characterization plan.

D.1 DOE’s Response

DOE’s response to the committee’s interim report consists of two following two elements: 1) a letter containing DOE’s proposed resolution and action items as a result of the committee’s findings and recommendations and 2) an attachment to the letter, named Attachment 1. The letter and its attachment are presented in Boxes D.1 and D.2, respectively.

BOX D.1 DOE’s Response to the Committee’s Interim Report

PROPOSED RESOLUTION/ACTION ITEMS

Concerning NAS Finding and recommendation #1: We have reevaluated the characterization information needs consistent with this recommendation. The process considered long-term repository performance information needs, safety and technical considerations, regulatory requirements, and legal requirements and led to the development of a discreet list of Characterization objectives. Attachment 1 is the result of this effort. Attachment 1 [see below] is being used to revise the Characterization Implementation Plan in the EPA submittal, as well as the WAP in the RCRA submittal. Attachment 1 also indicates whether or not we believe the characterization objectives require confirmation, and the methods we will propose in the submittal documents to obtain the characterization information.

Concerning NAS Finding and recommendation #2: The aforementioned Attachment 1 is the result of the reevaluation process we conducted as proposed by the NAS WIPP Panel.

Example 1: The list of prohibited items in the draft WAP (July 2001) will not be included as a specific list in the next draft WAP. With the exception of residual liquids, these “items” will be excluded from the list of prohibited items, but will continue to be dealt with by determining the hazardous waste numbers and prohibiting D001, D002, and D003. This effectively drives the decision from the container level to the stream level where hazardous waste code assignment decisions are typically made. The hazardous waste code(s) determination will be accomplished using AK. The 1% free liquid criteria was retained as a RCRA operational compliance consideration rather than for safety or performance reasons. The next draft WAP will be modified consistent with this change. See Attachment 1 for the rationale and justification for hazardous waste numbers and residual liquids.

Example 2: CBFO may, in the future, choose to remove the metals limits set in the CCA.



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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report Appendix D DOE’s Response to the Committee’s Interim Report In response to the committee’s interim report, the Department of Energy (DOE)-Carlsbad Field Office transmitted a summary of proposed resolutions or action items for the following draft of its characterization plan. D.1 DOE’s Response DOE’s response to the committee’s interim report consists of two following two elements: 1) a letter containing DOE’s proposed resolution and action items as a result of the committee’s findings and recommendations and 2) an attachment to the letter, named Attachment 1. The letter and its attachment are presented in Boxes D.1 and D.2, respectively. BOX D.1 DOE’s Response to the Committee’s Interim Report PROPOSED RESOLUTION/ACTION ITEMS Concerning NAS Finding and recommendation #1: We have reevaluated the characterization information needs consistent with this recommendation. The process considered long-term repository performance information needs, safety and technical considerations, regulatory requirements, and legal requirements and led to the development of a discreet list of Characterization objectives. Attachment 1 is the result of this effort. Attachment 1 [see below] is being used to revise the Characterization Implementation Plan in the EPA submittal, as well as the WAP in the RCRA submittal. Attachment 1 also indicates whether or not we believe the characterization objectives require confirmation, and the methods we will propose in the submittal documents to obtain the characterization information. Concerning NAS Finding and recommendation #2: The aforementioned Attachment 1 is the result of the reevaluation process we conducted as proposed by the NAS WIPP Panel. Example 1: The list of prohibited items in the draft WAP (July 2001) will not be included as a specific list in the next draft WAP. With the exception of residual liquids, these “items” will be excluded from the list of prohibited items, but will continue to be dealt with by determining the hazardous waste numbers and prohibiting D001, D002, and D003. This effectively drives the decision from the container level to the stream level where hazardous waste code assignment decisions are typically made. The hazardous waste code(s) determination will be accomplished using AK. The 1% free liquid criteria was retained as a RCRA operational compliance consideration rather than for safety or performance reasons. The next draft WAP will be modified consistent with this change. See Attachment 1 for the rationale and justification for hazardous waste numbers and residual liquids. Example 2: CBFO may, in the future, choose to remove the metals limits set in the CCA.

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report Until this change is made, the proposed RH-TRU characterization program must continue to require tracking of metals. Contrary to the NAS statement (“severe consequences”) the CBFO believes the “limits” do not impact the program, and the proposed characterization method of counting containers is simple to implement. For other reasons steel is the preferred material for waste containers, but the “limit” does not prohibit the use of other materials. The DOE anticipates that a minor amount of CH-TRU waste and no RH-TRU waste will be shipped in non-metal containers. We therefore do not view the consequences of the limitation as severe. Example 3: The NAS is correct in pointing out that Summary Category Groups (SCG) have no impact on long-term repository performance. SCG is in the current CH RCRA Permit in order to affect a decision on what kind of waste analysis is required by the Permit (S3000 and S4000 waste streams must be sampled and chemically analyzed). No sampling and analysis is proposed for RH-TRU waste, however the SCG requirement is retained in the program because it allows for an easy method of accounting for cellulosics, plastics, and rubber (CPR), which are related to repository performance. Since SCG determination is relatively easy and is part of the EPA program anyway, it will be included in the RCRA program as an activity complying with 40CFR264.13. Concerning NAS Finding and recommendation #3: The re-evaluation discussed for Finding #1 considered characterization objectives from a performance driven perspective as well as from regulatory and legal aspects. Nearly all resulting characterization objectives are unrelated to repository performance or to safety/technical considerations. New supporting documentation will clearly show the basis for each characterization objective. Concerning NAS Finding and recommendation #4: Consistent with this recommendation, DOE is preparing completed characterization documents for three major RH-TRU sites. These documents will be submitted directly to the EPA for its approval through the formal rulemaking process, and they will also be submitted to the NMED as examples along with a new draft request for RCRA Permit modification. Concerning NAS Finding and recommendation #5: Submittals to both the NMED (RCRA compliance) and the EPA (40CFR194 compliance) are being redrafted to balance flexibility with standardization as appropriate. The characterization documents discussed for Finding #4 will provide detailed inventory information which will assist in determining what aspects of the program can be standardized and how to allow for flexibility in site programs. Concerning NAS Finding and recommendation #6: This Finding and Recommendation is also fully addressed by the Resolution discussed for Finding #1. DOE agrees with the Panel that the former DQO associated with Total Activity is legally based and not technically based. As a result of the re-evaluation process described in the Resolution to Finding #1, it will be removed from the draft regulatory submittal documents. Concerning NAS Finding and recommendation #7: After re-evaluating the approach to RH-TRU waste characterization, as discussed in Finding #1, DOE continues to believe that nearly all required RH-TRU waste characterization can be accomplished using AK. Therefore worker exposure is no longer a significant issue related to RH-TRU waste, and eliminating most characterization physical activities has minimized program costs. Characterization activities may still be required on a very small percentage of the RH-TRU waste inventory, but these activities will always be conducted in such a way as to minimize worker exposure. Concerning NAS Finding and recommendation #8 As suggested by the Panel, DOE will complete the “systematic evaluation” recommended by Taggart to conclusively demonstrate that current RTR technology is adequate for RH-TRU waste characterization use; however, the revised characterization program no longer requires that

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report confirmatory data be generated. For the minimal use of NDA and RTR that will still be required in the overall program, the standard technologies currently being employed in the CH-TRU waste program are more than adequate. The RH Team recommended program (see Attachment 1) calls for NDE to be used only to detect 1% residual liquid and only for a small percentage of the total RH-TRU waste inventory (most RH-TRU waste will be repackaged or newly generated). Resolution of current RTR systems, even in high radiation fields, is adequate for this determination. Concerning NAS Observation #1: Example 1: The next draft of the regulatory submittals will clearly reference the supporting analyses, and each characterization objective will have an explicit pointer to its basis. Example 2: The redrafted documents will be purged of imprecise language and important terms will be properly defined. Example 3: After the re-evaluation discussed in Finding #1, CPR will not be measured, it will be conservatively assigned a weight (based on the analyses referred to in Observation #1). However, in general, other techniques are to be employed only for the few (and usually small) waste streams for which there are insufficient AK. There is no direct link between surface dose rate and total curies that is used by the proposed program, however in some individual cases for some individual waste streams, if enough is known about the waste stream (AK), surface dose rate measurements can be used to adequately estimate the activity. The Defense Waste determination for RH-TRU waste will follow the acceptable precedent that has been established in the CH-TRU waste characterization program. The modified EPA submittal will provide detail concerning the TRU versus LLW determination. The ten radionuclides are not important to repository performance (See RH Impact Assessment included in the EPA submittal). This requirement will therefore not be included in the revised submittal document. Concerning NAS Observation #2: Example 1: The statement made in Document 1 (the EPA submittal) was made in the context of what is significant relative to 40CFR194 and also allows that the EPA has the final decision regarding significance. The statement made in Document 2 (the RCRA submittal) was made in the context of what is significant relative to 20.4.1.900 NMAC. In addition, the NMED has made it very clear that they consider this to be a Class 3 modification. Example 2: The modified Documents will no longer require estimates for CPR, metals, or VOCs. Some method of assurance that there is less than 1% residual liquids in a waste container is still required to address RCRA operational requirements, however no statement of allowable uncertainties is derived since there is no technical basis for an uncertainty statement. Example 3: The redrafted supporting documents will make it clear that the origin of the 1% liquid requirement is from transportation, has no bearing on repository performance, and is only indirectly related to RCRA regulatory requirements. Concerning NAS Observation #3: The NAS is correct in the observation that VE and RTR are inadequate techniques for distinguishing the list of prohibited items in the previous draft. RTR or VE are suitable techniques for detecting and distinguishing residual liquids, and the reevaluation requested in Finding #1 has determined that RTR or VE will only be used for that purpose. See also the Resolution to Finding #8. NOTE: This table has been edited for formatting purposes. The emphasis (italicized and underlined text) was added by DOE-Carlsbad Field Office. SOURCE: DOE (DOE-CBFO, 2002).

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report BOX D.2 Attachment 1 Accompanying DOE’s Letter to the Committee (see Box D.1) ATTACHMENT 1 RH-TRU WASTE CHARACTERIZATION PROGRAM Objectives, Characterization Methods, Implementation Standards RH-TRU Team Rationale and Justification Introduction The RH-TRU Team has reached consensus on what the basic elements of an RH-TRU waste characterization program should consist of (i.e., characterization objectives, characterization method, and implementation). This consensus was achieved by taking a “performance based approach” and examining from the “ground up” what the minimum characterization requirements should be to satisfy 40CFR194.24 (EPA) requirements and RCRA (NMED) requirements. Previous recommendations, findings, and observations from RSI and NAS/NRC reviews were heavily considered, and as the re-evaluation process progressed, each potential requirement was examined with respect to its basis; that is safety, repository performance, legal, or regulatory. Table 1 for EPA requirements and Table 2 for NMED requirements present the RH-TRU Team consensus recommendations of what basic characterization elements should be used to build an EPA and NMED compliant RH-TRU waste characterization program. This paper explains the RH-TRU Team rationale or justification for each entry in the attached Tables, [see Box D.1] Table Definitions (Columns) and Entry Justification/Rationale There is a separate Table for the EPA related RH-TRU waste characterization elements and the NMED related RH-TRU waste characterization elements, however the column definitions are identical for both. Characterization Objectives: This column lists the necessary overall program objective that must be accomplished by collecting waste characterization information. It is the basic question being asked and stems from safety, repository performance, regulatory, or legal considerations. EPA Characterization Objectives Account for ferrous and non-ferrous metals, is related to repository performance in that the CCA Appendix WCL requires a minimum of metals (20 million kilograms of ferrous metals and 2,000 kilograms of non-ferrous metals) be included in the final WIPP repository inventory. Thus it is necessary to account for disposed metals, by some means, in order to ensure that the specified minimums are emplaced. Once the minimum is achieved, no further accounting is necessary. Account for Cellulosics, Plastics, Rubber (CPR), is related to repository performance in that the CCA Appendix WCL limits total WIPP repository disposed inventory of CPR to a maximum of 20 million kilograms. Thus it is necessary to account for disposed CPR inventory, by some means, in order to ensure that the 20 million kilograms is not exceeded. Account for Free Water, is a regulatory expectation that the RH-TRU Team believes is prudent to meet even though no amount of free water in the RH-TRU waste will impact repository performance. Note that CCA Appendix WCL.5 states that, “Consequently, there is no need to monitor water in the waste for compliance with 40 CFR § 194.24(c).” The RH-TRU Team recommends that free water in RH-TRU waste be accounted for by some means.

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report Account for TRU Activity, is a regulatory expectation that the RH-TRU Team believes is prudent to meet even though, for RH-TRU waste, it is unrelated to repository performance. Note that CCA Appendix WCL.1 states that, “The total activity of the waste is not important for 40CFR194.24(c), because the containment requirements are normalized to the initial inventory.” The relationship of TRU activity to total activity is also explained in WCL.1, “The total activity of the waste at emplacement and during the entire 10,000-year performance period is dominated by the activities of four emplaced radionuclides: Am241, Pu238, Pu239, and Pu240.” The RH-TRU Team recommends that TRU activity in RH-TRU waste be accounted for by some means. Ensure waste is TRU (activity≥100 nCi/gm), is a legal requirement from the WIPP Land Withdrawal Act (LWA). The Team is in agreement that it is prudent to include it in the EPA Table, even though some members of the Team do not believe it to be of EPA regulatory concern. Account for Total Activity, is related to the LWA legal requirement that WIPP final RH-TRU waste inventory be limited to 5.1 million total curies. Thus it is necessary to account for disposed RH-TRU waste total activity, by some means. Limit canister activity to <23 curies per liter, is a LWA invoked legal requirement. This limit is specifically included in 40CFR194 as an EPA regulated Characterization Objective. Limit Surface Dose Rate of each container to <1000 rem/h, is a LWA invoked legal requirement. This limit is specifically included in 40CFR194 as an EPA regulated Characterization Objective. Limit WIPP inventory to <5% by volume for >100 rem/h on a canister basis, is a LWA invoked legal requirement. Thus canisters with surface dose rate exceeding 100 rem/h must be identified by some means. Ensure waste is RH (surface dose ≥200 mrem/h), is a de facto legal requirement of the LWA. The Team is in agreement that it is prudent to include it in the EPA Table, even though some members of the Team do not believe it to be of EPA regulatory concern. NMED Characterization Objectives Assign Hazardous Waste Numbers, is related to the regulatory requirement to comply with the terms and conditions of the WIPP Hazardous Waste Facility Permit (HWFP). The WIPP HWFP specifically prohibits hazardous wastes with the numbers D001, D002, and D003. Some other hazardous waste numbers have not been applied for and therefore are not allowed by the HWFP. Identify Physical Form, is a regulatory requirement that is indirectly related to 40CFR264.13. Limit residual liquids to <1% volume of RH canister (or drum for 160B), is related to a regulatory requirement to provide secondary containment at the WIPP for potential spills. An analysis justifying the 1% for CH-TRU waste at the WIPP is part of the HWFP record, however a similar analysis has not been done for RH-TRU waste. The RH-TRU Team believes it is prudent to include this limit as an RH-TRU waste requirement also. Note 1: The current HWFP for CH-TRU waste also includes residual liquid restrictions for internal containers (i.e., “Waste shall contain as little residual liquid as is reasonably achievable by pouring, pumping and/or aspirat-ing, and internal containers shall contain less than 1 inch or 2.5 centimeters of liquid in the

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report bottom of the container.”). The RH-TRU Team did not retain these requirements for RH-TRU waste since their main purpose was related to eliminating the need to characterize liquids in internal containers (i.e., containers are RCRA “empty”). NMED Characterization Objective Number 1, Assign Hazardous Waste Numbers, requires the assignment of appropriate hazardous waste codes to containers, and the driver to further characterize liquids is eliminated. Note 2: In addition to liquids the September 2001 draft RH-TRU waste WAP included the following “prohibited items:” Pyrophoric materials Incompatible waste Explosives and compressed gases PCBs with concentrations greater-than-or-equal-to 50 ppm The RH-TRU Team concluded that it is unnecessary to specifically identify these “items” in the WAP or as specific Characterization Objectives. Pyrophoric materials, explosives and compressed gases fall under the RCRA definition of reactives (D003) and therefore are precluded by NMED Characterization Objective number 1, Assign Hazardous Waste Numbers. All wastes with HWFP acceptable Hazardous Waste Numbers have been demonstrated to be compatible, and therefore NMED Characterization Objective number 1, Assign Hazardous Waste Numbers, assures that there are no incompatible wastes. PCBs are subject to EPA regulation under TSCA and are regulated regardless of whether or not they are included in a RCRA permit as a prohibition. Therefore the RH-TRU Team has not included any of these “prohibited items” in the proposed RH-TRU waste characterization program as specific characterization objectives. Identify and Quantify VOCs, is related to health and safety considerations derived from other (than RCRA) EPA release and exposure limits imposed by the NMED. The existing VOC conditions in the HWFP (e.g. Room Based Limits for VOCs) are based on an extremely conservative analysis of bounding VOC releases. The RH-TRU Team recommends that a bounding analysis specific to the small volume of RH-TRU waste will obviate the need for generator/storage sites to characterize RH-TRU waste for VOCs. This RH-TRU Team recommended approach for VOCs is exactly that already proposed in the September 2001 draft Class 3 Request for RCRA Permit Modification for RH-TRU waste. Characterization Method: This column lists the general method to be used (as recommended by the RH-TRU Team) to accomplish the Characterization Objectives from the first column. EPA Characterization Methods Count containers emplaced in the WIPP, is a simple administrative accounting using the WIPP Waste Information System (WWIS) that meets the metals Characterization Objective. This method has already been approved by the EPA in the 40CFR191/194 “Final Rule” and is currently employed in the CH-TRU waste program. This is not a generator/storage site characterization requirement; it is a WIPP administrative requirement. Characterization method—Use AK to determine Summary Category Group (SCG) of each waste stream. WIPP admin requirement—Use WWIS to assign 620 kg/m3 up to container tare weight for debris waste. Relative to the CCA total inventory limit of 20 million kilograms of CPR, any practical contribution to the CPR inventory from RH-TRU waste is inconsequential. The RH-TRU Inventory Impact Assessment Report (Sandia, June 2001) used 620 kg/m3 of plastic for a bounding analysis that demonstrated

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report repository performance is not affected by RH-TRU waste CPR. Out of the three Summary Category Groups, (S3000—homogeneous solids, S4000—soils and gravel, S5000—debris) only S5000—debris contains significant quantities of CPR. Thus a very simple and conservative approach for meeting the CPR Characterization Objective is to use AK to identify S5000—debris waste streams, and use the WWIS to electronically calculate and assign a CPR weight value for every S5000—debris RH-TRU waste container that is emplaced in the repository. Because this assignment is based on a bounding analysis, and because there will always be enough AK to make the simple SCG designation, no confirmation of this designation is required. Use AK to assign either 0% or 1% by volume for each waste stream. The RH-TRU Inventory Impact Assessment Report (Sandia, June 2001) assumed that the final RH-TRU waste inventory in the WIPP was 50% by volume water. This bounding analysis demonstrated repository performance is not affected by any amount of water in RH-TRU waste. Thus a very simple and conservative approach for meeting this Characterization Objective is to use AK to either assign 0% volume of liquid to a specific RH-TRU waste stream or assign 1% volume. The RH-TRU Team chose 1% rather than 50% because transportation requirements will not allow more than 1% to be transported. Because the Sandia bounding analysis effectively demonstrates that selecting either 0% or 1% makes no difference in repository performance, and because AK will, in some cases, allow a definitive 0% decision to be made for a waste stream (e.g., thermally treated waste) or a default 1% will be assigned, no confirmation of this AK determination is required. Use AK to determine the relationship of TRU Activity to Total Activity for each waste stream, or establish a waste stream value by sampling and measurement, or measure the TRU Activity of each container. The RH-TRU Inventory Impact Assessment Report (Sandia, June 2001) assumed, for a bounding analysis, that the entire RH-TRU waste curie loading allowed by the LWA (5.1 million curies) was composed of Pu239 and showed that even this impossible condition would still comply with the 40CFR191 containment requirement. Thus any minimal AK information available with which to roughly estimate the ratio of TRU to Total Activity is sufficient to meet this Characterization Objective without the need for confirmation. If this minimal AK information is not available, measurements of Total Activity and TRU Activity should be obtained on a few randomly selected containers from the waste stream to establish a waste stream value. Alternatively a generator/storage site may choose to measure the TRU Activity of each container. Note that the method for meeting this Characterization Objective (EPA number 4) is closely tied to, and interrelated with, the following two methods for EPA Characterization Objectives numbers 5 and 6. The same Characterization Method used for TRU Activity (Characterization Method No. 4) is also used to make the TRU determination. Usually AK can be used to make a determination of TRU (versus LLW) for an entire waste stream if there is loading information (activity or mass) regarding Pu238 or Am241 and Pu239. Since this is a “legal” limit with no safety or repository performance implications, this AK determination need not be confirmed. If the TRU determination cannot be made using AK, a waste stream TRU determination may be made by measuring a few randomly selected containers. A TRU determination may also be made by measuring the value of TRU concentration for each container. Use AK to determine Total Activity of the waste stream, or establish a waste stream value by sampling and measurement, or measure the Total Activity of each container. Any minimal AK information available with which to roughly estimate the Total Activity is sufficient to meet this Characterization Objective without the need for confirmation. Characterization Parameters, Data Quality Objectives, and Methods (LANL, July 2001) pointed out that the expected (from the TWBIR) RH-TRU waste total activity inventory could be biased low by a factor of five before the LWA limit is challenged. If this minimal

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report AK information is not available, measurements of Total Activity should be obtained on a few randomly selected containers from the waste stream to establish a waste stream value. Alternatively a generator/storage site may choose to measure the Total Activity of each container. The same Characterization Method used for Total Activity (Characterization Method No. 6) may also be used to meet Characterization Objective number 7. Characterization Parameters, Data Quality Objectives, and Methods (LANL, July 2001) showed that for the vast majority of RH-TRU waste streams AK will demonstrate that it is not feasible to load a canister (or any container) to 23 curies per liter. For the rare exception where AK indicates 23 curies per liter is hypothetically feasible, measurements of Total Activity should be obtained on a few randomly selected containers from the waste stream to establish a waste stream value. Alternatively a generator/storage site may choose to measure the Total Activity of each container. Use standard industry survey methods to measure and report Surface Dose Rate. This is a standard practice measurement using standard equipment. Any container that has a measured Surface Dose Rate of 1000 rem/h or greater cannot be shipped to the WIPP. This measurement also is used for achieving Characterization Objectives 9 and 10. Use standard industry survey methods to measure and report Surface Dose Rate. This is a standard practice measurement using standard equipment. The Surface Dose Rate measured value of each container that is shipped to the WIPP must be reported in the WWIS. The WIPP will use WWIS data to load manage and assure no more than 5% of the containers of RH-TRU waste emplaced in the repository exceed a Surface Dose Rate of 100 rem/h. Use standard industry survey methods to measure and report Surface Dose Rate. This is a standard practice measurement using standard equipment. If the Surface Dose Rate measured value of a container is less than 200 mrem/h then that container should be managed as Contact Handled TRU (CH-TRU) waste. NMED Characterization Methods Use AK to delineate waste streams, assign Hazardous Waste Numbers and Summary Category Group (SCG) to waste streams, and assign individual containers to waste streams. Hazardous Waste Numbers and SCG are assigned on a waste stream basis; therefore the population of containers constituting a specific waste stream must be identified. AK must be used for the majority of this information. There are no other reasonable means (i.e., measurement) or confirmation techniques. For example, F codes depend on the generation process and therefore can only be identified by knowledge of the process used (part of AK). Because all allowable hazardous wastes (identified by Hazardous Waste Numbers) are managed identically at the WIPP, Hazardous Waste Numbers, or lack thereof, are not used for any operational management decisions. Confirmation of Hazardous Waste Number assignment is therefore not required. The Characterization Method for establishing SCG is the same as described in the preceding NMED Characterization Method number 1. Use AK to demonstrate that the waste stream does not contain residual liquid, or that individual containers in a waste stream contain <1% residual liquid, or sample and NDEA/VE to determine the waste stream does not contain residual liquid, or NDEA/VE each container in a waste stream. AK may provide definitive information (e.g., all liquids are eliminated by thermal process) to show that the waste stream contains no residual liquids. If so, no confirmation is required. Or AK may provide a record for each container

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report showing that there is <1% liquid. If so, no confirmation is required. If AK is not definitive, NDE or VE of a few representative containers may show that the waste stream does not contain residual liquids. If AK or sampling indicates that there may be some containers with >1% residual liquid, then NDE or VE of each container should be done. Use bounding analysis for RH contribution to reduce current HWFP Room Limits. This is not a Characterization Method. This analysis has already been completed and can be found in Appendix 2 of the September 2001 draft Request for Class 3 Permit Modification (RH-TRU). This analysis bounded the possible contribution of VOCs from RH-TRU waste, and correspondingly lowered the Room Based Headspace VOC Limits set in the current HWFP. Reducing the Room Based VOC concentration limits eliminates the need to characterize RH-TRU waste for VOC concentrations. Implementation: This column sets the standard of adequacy, sufficiency, or acceptability for the Characterization Methods selected in the adjacent column. EPA Implementation WWIS electronically counts. As pointed out in the corresponding Characteriza-tion Method column, this is a WIPP administrative action, not a characterization activity and therefore no adequacy standard is set. Use generator/storage site SCG designation from site documents. If a site has previously determined a waste stream(s) to be one of three SCGs (S3000– homogeneous solids, S4000—soils and gravel, S5000—debris), then that determination is acceptable for program use. If the site has not determined the SCG and AK shows the process that generated the waste produces a uniform and homogeneous product, then designate the waste stream as S3000 or S4000 as appropriate, otherwise designate the waste stream as S5000. Current RH-TRU waste inventory information indicates that every retrievable RH-TRU waste stream that is a candidate for WIPP disposal already has a SCG designation. The associated WIPP administrative action is described in the Characterization Method. AK documents use of liquid management procedures, or a process that precludes liquids; otherwise assign 1%. To assign 0%, AK is sufficient if it is documented that the waste stream generation procedures included liquid management procedures (e.g., procedures required the removal of liquids or the absorption of liquids), or it is documented that the waste stream generation process precludes liquids (e.g., material balance input records, thermal treatment, etc.). If this AK information is negative or unavailable, a default assignment of 1% is made. AK must include TRU information (sufficient to demonstrate waste stream concentration exceeds 100 nCi per gram), or the waste stream value must be established by sampling and measurement, or the TRU Activity must be measured for each container. Because the same AK information is used for both the TRU Activity Characterization Objective and the TRU versus LLW determination, the more stringent TRU/LLW Characterization Objective sets the AK adequacy standard. Generally, AK is sufficient if the predominant TRU isotopes are identified (usually Pu238 or Pu239 and Am241), and there is waste stream activity information regarding those isotopes. If sufficient AK information is not available, TRU Activity for the waste stream can be established by measuring TRU Activity of representative containers. As with AK, only the predominant TRU isotope (usually Pu238 or Pu239 and Am241) need be measured. A sufficient number of containers shall make up the sample size in order to establish that the waste stream value exceeds 100 nCi per gram with 67% certainty.

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report If a site elects to measure the TRU Activity of each container, measurement of the predominant TRU isotope is sufficient. If activity of the predominant isotope is marginally below 100 nCi per gram, a site may choose to include additional TRU isotopes in the measurement. See Implementation item number 4 above. AK must include sufficient information with which to make an estimate of Total Activity for the waste stream, or the waste stream value must be established by sampling and measurement, or the Total Activity must be measured for each container. AK is sufficient if the predominant high activity isotopes (e.g., Cs137) have been identified for the waste stream and there is a record of a few activity determinations for those isotopes. If sufficient AK information is not available, Total Activity for the waste stream can be established by measuring Total Activity of representative containers. A sample size of two to ten containers, depending on waste stream size, and measurement of only the predominant high activity isotopes, is sufficient to establish a Total Activity value for the waste stream. If a site elects to measure the Total Activity of each container, measurements of the predominant high activity isotopes are sufficient. The analysis from Characterization Method eliminates any need for Implementation. Industry standard survey instruments. This is a straightforward, common practice application of standard industry techniques to measure surface dose rate and requires no further explanation. Industry standard survey instruments. This is a straightforward, common practice application of standard industry techniques to measure surface dose rate and requires no further explanation. Industry standard survey instruments. This is a straightforward, common practice application of standard industry techniques to measure surface dose rate and requires no further explanation. NMED Implementation Use generator/storage site waste stream designation, records of container assignments, Hazardous Waste Numbers if mixed waste, and SCG assignment Every RH-TRU site planning to ship RH-TRU waste to the WIPP is currently operating under an EPA authorized State RCRA program. Waste streams have previously been designated under these programs, hazardous waste numbers have been assigned when appropriate, and the SCG for each waste stream has been determined. Implementation for Physical Form is included in the above Implementation number 1. AK must document the use of liquid management procedures, or a process that precludes liquids, or there must be a record for each container indicating <1% residual liquid, or NDE/VE of a few representative containers from the waste stream can show the absence of residual liquids, or every container must undergo NDE/VE. Liquid management procedures are standard operating procedures used in the waste generation process that eliminate or mitigate the presence of free liquids (e.g., removal or absorption). Examples of processes that preclude liquids are material input records that show no liquids were introduced to the process or a thermal treatment process that removes liquids. If sufficient AK information is not available, the absence of residual liquids in any

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report container in a waste stream can be demonstrated with a statistical degree of certainty by NDE/VE of representative containers. A sufficient number of containers shall make up the sample size in order to establish that less than 10% of the containers in a waste stream contain more than 1% by volume residual liquids (with 67% certainty). A site may elect to NDE/VE every container in order to demonstrate that every container has less than 1% by volume residual liquid. No Implementation is required for VOCs. DQO: The RH-TRU Team applied the DQO process to each element of the proposed RH-TRU waste characterization program in order to ascertain whether formal DQOs need be developed. The DQO process was designed by the EPA primarily as a decision making tool applied to sampling and analysis studies for contaminated site remediation; however the process remains useful in the RH-TRU waste characterization program as a screening tool to determine if DQOs should apply. The seven-step DQO process is described in “Guidance for the Data Quality Objectives Process, EPA QA/G-4.” Essentially DQOs establish what information is needed, and what level of quality the data should have associated with it, in order for a meaningful, risk based or consequence based decision to be made. “Data quality objectives (DQOs) for the data collection activity describe the overall level of uncertainty that a decision-maker is willing to accept in results derived from environmental data” (EPA SW-846). Using this process, the RH-TRU Team determined that there are no DQOs needed for the Characterization Objectives established for the RH-TRU waste characterization program. EPA and NMED DQOs Step 1 of the DQO process is to “State the Problem.” The problem statements for each element of the proposed RH-TRU waste characterization program are the Characterization Objectives listed in the first column of the attached Tables. Step 2 of the DQO process is to “Identify the Decision.” There are no decisions to be made as a result of characterization activities for Table 1 EPA elements 1, 2, 3, 4, 6, and 9. These are all data collection activities to provide information for management, administrative, or load management decisions that may be needed in the future. Thus there are no DQOs for these elements. There are no decisions to be made as a result of characterization activities for Table 2 NMED elements 1, 2 and 4. Elements 1 and 2 are both administrative labeling activities done for the purpose of regulatory compliance that have no safety, repository performance, or technical consequences. NMED element 4 is potentially a data collection activity to enable future load management decisions regarding RCRA Permit Room Based VOC Limits. However the approach (Characterization Method from the Tables) taken for RH-TRU waste VOCs has eliminated this element as a RCRA characterization objective. Thus there are no DQOs for NMED elements 1, 2, and 4. Step 6 of the DQO process is to “Specify Tolerable Limits on Decision Errors.” The decision(s) to be made for EPA elements 5, 7, and 8 are receive-not-receive at the WIPP, and for EPA element 10 the decision is receive as RH-TRU waste or CH-TRU waste. Legal and regulatory limits and/or definitions drive decisions for each of these four elements, and there are no technical, safety, or repository performance consequences. Therefore “Tolerable Limits on Decision Errors” cannot be established for these four elements, and thus there are no DQOs for these elements. The decision to be made for NMED element 3 is receive-not-receive at the WIPP. Regulatory operational compliance drives this decision, and since there are no technical, safety, or repository performance consequences, no “Tolerable Limits on Decision Errors” can be established. Thus there is not a DQO for

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Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant: Final Report NMED element 3. QAO: The WIPP project has historically listed “accuracy,” “precision,” “representative-ness,” “comparability,” and “completeness” as the elements of QAOs. These are the same elements used in the EPA SW-846 (2.1) definition of DQOs. From an EPA perspective, QAOs are synonymous with DQOs, and thus the RH-Team established no QAOs for either EPA or NMED Characterization Objectives for the same reasons DQOs were not applicable. NOTE: This copy has been edited for formatting purposes. The emphasis (italicized text) was added by DOE-Carlsbad Field Office. This table is part of the document DOE’s Proposed Resolution and Action Items in Response to the Committee’s Interim Report. SOURCE: DOE (DOE-CBFO, 2002). REFERENCE DOE-CBFO. 2002. This material was submitted to the committee on January 18, 2002. This record is publicly available.