Below are the first 10 and last 10 pages of uncorrected machine-read text (when available) of this chapter, followed by the top 30 algorithmically extracted key phrases from the chapter as a whole.
Intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text on the opening pages of each chapter.
Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.
Do not use for reproduction, copying, pasting, or reading; exclusively for search engines.
OCR for page 1
Executive Summary
.
.
The U.S. Department of Energy (DOE) is responsible for the cleanup of defense-
related transuranic waste across its weapons complex. The designated disposal facility
for DOE's transuranic waste is the Waste Isolation Pilot Plant (WIPP), a geologic
repository near CarIsbad, New Mexico.4 Transuranic waste can be classified as contact-
handIed or remote-handIed based on the dose rate at the surface of containers (see
Sidebar 1.2~. This report addresses only the characterization of contact-handIed
transuranic waste.
Federal and New Mexico laws require that generator sites gather and confirm
existing information2 and, where necessary, acquire additional information on the
physical, chemical, and racliological properties of transuranic waste to ensure that the
waste contains only materials allowed to be shipped to and disposed of at WIPP. The
waste characterization program consists of all characterization activities that are
performed at generator sites to satisfy characterization requirements concerning
radiological and hazardous properties of the waste set forth by WIPP's regulatory
agencies: the U.S. Environmental Protection Agency (EPA), the New Mexico
Environment Department (NMED), and the U.S. Nuclear Regulatory Commission
(USN RC).
After four years of shipping and disposing transuranic waste in WIPP, DOE has
identified waste characterization as one of the most costly and time-consuming parts of
the National Transuranic Waste Management Program.3 According to assessments by
DOE, the cost of characterization and certification activities to prepare waste to be
shipped to WIPP is estimated to be $3.1 billion, or approximately 16 percent of the $19
billion total costs for the disposal of transuranic waste.4 A more recent DOE cost
estimate based on data from generator sites reported the average cost of characterizing
a 55-gallon drum of transuranic waste destined for WIPP to be $3,900 (see Chapter 4~.
In light of this assessment, DOE asked the National Research Council for advice
on the current waste characterization programs for transuranic waste and for
recommendations to increase the program's technical soundness, efficiency, cost
effectiveness, and safety to workers and the public (the complete task statement is in
Sidebar ~ . ~ ).
~Transuranic waste and WIPP are described in Chapter 1.
2Existing information about the waste becomes "acceptable" characterization information
through a qualification process described in 40 CFR 194.22(b). This qualified information is then
called "Acceptable Knowledge" (see Section 4.3 and Finding 4~.
3The program is a DOE system-wide approach to the management and disposal of
transuranic waste stored and generated throughout the DOE weapons complex. DOE-Carlsbad
Field Office manages this program. Information on the program is available on-line at:
.
4This estimate does not take into account discount rates.
5The committee also discusses characterization-related parts of the transportation
program.
1
OCR for page 2
2
Improving the Characterization Program for Contact-Handled Transuranic Waste
ES.1 Statement of the Problem
The contact-handIed transuranic waste characterization program is controversial.
DOE, as well as the New Mexico Environmental Evaluation Group and previous National
Research Council committees have suggested that some characterization activities may
be too extensive, costs too high, and some of the information gathered may not be used
to make any decision related to the protection of human health and safety or the
environment. Previous National Research Council committees' language is discussed in
Sections 1.2 and 5.9. On the other hand, stakeholders in New Mexico have argued that
all the current characterization activities are necessary to ensure an adequate level of
protection.
DOE has informed the committee of its intention to propose changes to the
characterization program to eliminate or modify activities that do not have an impact on
human health and safety or the environment. However, DOE did not provide the
committee with a formal analysis of the impacts of altering specific characterization
activities on costs and risks to the public, workers, or the environment.
The committee observes in Chapter 5 that a structured and quantitative analysis
is necessary to determine whether a change to the characterization program is
warranted and to justify proposed changes to the regulator~s), state and focal officials,
and the general public. DOE is responsible for making the policy decision to seek
regulatory approval for changes to a particular characterization activity. In Chapter 5, the
committee provides the elements and illustrative applications (albeit incomplete) of a
proposed structured and quantitative analytical framework that could be used to evaluate
changes to specific characterization activities.
ES.2 Finctings and Recommendations
Several general observations underlie the committee's findings and
recommendations. First, bringing WIPP to operational status is a significant
achievement, given the technical and societal challenges of operating the first and only6
creep geologic repository for transuranic waste and the complex regulatory environment
under which WIPP operates.7
During the development of the facility, WIPP has followed a regulatory path
typical of many first-of-a-kind facilities with non-routine permits. In developing its
transuranic waste characterization program, DOE proposed characterization activities to
meet regulatory requirements.8 The regulatory agencies overseeing WIPP reviewed and
approved the inclusion of these characterization activities in W! PP's proposed
characterization program. The initial transuranic waste characterization program
proposed by DOE to EPA and NMED was based on a conservative interpretation of
regulatory requirements.9
6The Committee recognizes that WIPP is a unique facility for the deep geological
disposal of transuranic waste and there are no plans for any other similar facilities in the United
States.
7The committee identifies technical, societal, and regulatory challenges in Sections 1.5,
2.3, 2.4, and 3.4, respectively.
The committee distinguishes between regulatory requirements (referred to as
"characterization requirements") and the approach to meet such requirements ("characterization
activities"~. The committee was not asked to comment on the regulatory requirements themselves
or to provide other policy recommendations.
9That is, DOE introduced rigorous measures in its waste characterization program,
including 100 percent sampling, redundant testing, and extensive confirmation of existing data for
the purpose of compensating for the absence of experience in handling this aged waste. Such an
approach is favored by regulators in general.
OCR for page 3
Executive Summary
3
The initial application of conservative requirements is not uncommon for a first-
of-a-kincl regulated facility, in part because regulators and permittees have no direct
operational experience on which to base decisions (see Sidebar 3.2~. As operational
experience and analyses lead to better understanding, some characterization activities
could be modified, reduced, or eliminated and others added. Before such changes can
be made, the permittee must demonstrate to the regulator that the proposed changes
can provide the required level of safety and meet regulatory requirements. DOE is
following this approach for WIPP: requests to modify characterization activities have
been submitted to NMED, EPA, and USNRC, the majority of which have been approved
(see Section 3.3~.
As previously noted, a complete analysis of the benefits and costs of each waste
characterization activity is beyond the scope of this study and the commidee's capability.
In the first finding and recommendation, the committee recommends steps that DOE can
take to assess the value of characterization activities based on a structured and
quantitative analysis and given the experience gained from four years of operations. In
addition, the committee provides five other findings and recommendations that are
operational in nature, that do not address specific characterization activities, some of
which can be instituted without regulatory approval.
Finding 1: DOE has stated that some characterization activities are too expensive and
time consuming and can be modified without increasing risks while reducing
characterization time and costs. However, DOE has not presented a systematic analysis
to support this argument to the regulators or to the public. Although DOE has performed
analyses of many aspects of operations related to WIPP performance, including
transportation, the committee could find no studies that explicitly, systematically, and
quantitatively link its waste characterization program to risks to the public, workers, or
the environment.
Recommendation 1: DOE should use a systematic and quantitative approach to
determine the value of the information currently obtained by its waste characterization
activities and the impact of changes to them. This approach should also be used to
support permit modification requests and communicate with the public. The approach
should include analyses of the following types:
an assessment of the risks of transuranic waste handling, transportation, and
disposal activities, including the current characterization activities; and
an assessment of the impacts—risks, costs, and other impacts, including policy
and societal impacts of changes to the current waste characterization activities.
There are several approaches to achieve this goal. One example is a structured
and quantitative analysis based on the value of characterization information collected. In
the context of this report, the value of characterization information is determined by how
much the information contributes to waste handling, transportation, or disposal
decisions. If the information is used to make decisions about waste handling,
transportation, or disposal, then it has an impact on the outcome of these decisions (for
instance, on reducing risks, uncertainties, costs, or delays), and thus it has value. On
the other hand if the characterization information is not used in current or future
ctecisions, then it has no impact, and therefore it has no value (see Chapter 5~.
DOE should use such an analytical approach to identify the connections between
waste characterization, risks, and costs, and to determine which activities impact these
connections. If weak connections are found, the same approach should be used to
OCR for page 4
i
4
Improving the Characterization Program for Contact-Handled Transuranic Waste
develop a rationale to request changes from the regulators. These analyses should be
published so that outside parties can evaluate the present characterization program and
the rationale for proposed changes to the program. Within its constraints of time and
information made available, the committee could only point out some of the risks to be
included in this risk analysis (see Section 5.3~; a complete risk assessment is a major
endeavor that the committee was not prepared to undertake.
Based on the information provided by DOE and findings by a previous National
Research Council committee, three characterization activities appear to be candidates
for the complete application of the analytical framework proposed by the committee:
1. heacispace gas sampling and analysis,
2.
3. visual examination to cont~rm radiography results.
homogeneous waste semolina and analysis' and
. ~ ,
. .. . ..
Finding 2: DOE now has four years of operational experience with the National
Transuranic Waste Management program that can be used to improve waste
characterization activities.
Recommendation 2: DOE should use its increasing experience base and advances in
technology to improve the current transuranic waste characterization program.
The following are examples of potential improvement opportunities together with
uses of information from an expanding operational experience base acquired thus far:
.
.
Experience can be used to estimate the extent to which each characterization
activity provides information that is: 1) essential to protect health and safety, 2)
redundant with other activities or with historical knowledge of the waste, and 3)
used to make decisions about waste handling, transportation, or disposal at
WIPP. This information is to be used in the structured and quantitative analysis of
the characterization program described in Chapter 5.
Analysis of the characterization data acquired to date along with continuing
characterization of increasingly diverse waste streams could identify new
opportunities to use statistical sampling (rather than 100 percent of the waste
stream) or different methods to confirm Acceptable Knowledge4° to provide
information that would be as protective of health and the environment as the
current measurements (see Sections 4.6.2 and 4.6.3~.
Experience provides a basis for 'know-how' transfer from one generator site to
others. The application and sharing of improvements in management methods
acquired at generator sites thus far can achieve cost, schedule, and worker dose
reduction across the DOE weapons complex (see Section 4.6.1 .1 ).
Experience allows a better understanding of costs and their variability across the
waste inventory and generator sites as well as a better understanding of the
relative value of different characterization methods providing similar information
(i.e., radiography versus visual examination). Understanding why
characterization costs differ significantly from waste stream to waste stream and
from site to site could also lead to better cost estimates for future waste streams
(see Chapter 5~. Changes to the characterization program that would improve the
characterization process, together with an expanding operational experience
unacceptable Knowledge is a term used by the EPA that encompasses historical process
knowledge and information from previous testing, sampling, and analyses of waste (see Sections
4.1, 4.3 and the Glossary).
OCR for page 5
Executive Summary
5
base, could help reduce both risks and costs. However, if new and more difficult
or complex waste types have to be dealt with in the future, or more stringent
cleanup standards are imposed by the regulators, then characterization costs
could increase (see Section 5.4~.
Fincting 3: Current characterization activities are applied generically to all waste types
and, with few exceptions, are not tailored to particular waste streams.
Recommendation 3: DOE should propose to its regulators a more flexible waste
characterization program that can take into account the properties of different waste
streams, allowing more efficient and effective waste characterization operations
.,
There are categories and subcategories of transuranic waste that may require
different methods of characterization depending on whether they are existing wastes,
wastes that pose special problems (see Sections 2.3 and 2.4), or to-be-generated
wastes. The rationale for this finding is twofold: ~ ~ some waste streams, by the nature of
their generation, their physical and chemical properties, and other special circumstances
can be shown not to require the entire suite of characterization activities that are
currently being carried out; and 2) current characterization methods or technologies are
unsuitable for certain waste streams.
Wastes generated in the future (to-be-generated waste) may be better
characterized than existing waste, as a result of improvements in management methods,
processes, and record keeping. Therefore, some to-be-generated waste streams may
not require any, or as much, confirmation of the information collected at the time of
waste generation.
Recognizing the differences among waste streams and capitalizing on the
opportunities that the improved waste characterization information affords, DOE could
propose to its regulators reducing or eliminating some of the current characterization
activities for certain waste streams provided it supports its case with a systematic,
analytical, and quantitative approach (see Recommendation 1~. In addition, DOE should
begin detailed planning to address the technical challenges presented by certain waste
streams that DOE has not handled to date, as described in Sections 2.3 and 2.4.
Finding 4: DOE is currently using only one of the four methods approved by EPA in 40
CFR 194.22(b) to qualify information as Acceptable Knowledge, namely, confirmation by
measurement. Use of the other methods as appropriate could potentially reduce waste
handling and costs, increase the efficiency of characterization activities, and extend the
use of Acceptable Knowledge for waste generated in the future.
Recommendation 4: DOE should request authorization from its regulators to use all
four methods allowed by EPA for aualifvina waste information to be used as Acceotable
Knowlecige.
Continued reliance on the exclusive use of confirmatory testing, which
sometimes requires breaching waste containers, becomes an especially important issue
for some existing waste streams presenting characterization challenges (see Section
2.3~. Furthermore, the characterization of to-be-generated wastes is to be accomplished
in accordance with an NMED- and EPA-approved quality assurance program. Therefore,
, , _ .
44The four methods to qualify information to be used as Acceptable Knowledge are 1)
peer review, 2) use of corroborative evidence, 3) cone rmation by measurement, and 4)
qualification of a different quality assurance program.
OCR for page 6
6
Improving the Characterization Program for Contact-Handled Transuranic Waste
the information collected at the time of waste generation should not require confirmatory
measurements in order to be used as Acceptable Knowledge.
Finding 5: Transportation agreements for WIPP shipments have been fashioned over
many years of negotiation between DOE and the corridor states. Any changes in the
WIPP characterization program could be viewed as undermining these institutional
agreements.
Recommendation 5: In addition to working with its regulators, DOE should ensure that
corridor states are kept informed of negotiations for changes to the characterization
program. Specifically, DOE should communicate effectively with the Western Governors
Association, the Southern States Energy Board, and similar groups representing corridor
states. DOE should analyze, publish, and present to corridor states' representatives any
impact of proposed changes on transportation safety.
Fincling 6: StakehofJers have many concerns about WIPP program-related operations.
Although specific concerns may vary among people who live near generator sites (risks
to site workers, delay in removing waste from generator sites), along transportation
corridors (adequacy and reliability of characterization in the event of a transportation
accident), or near the WIPP facility (protection of public health over the long term), some
concerns are generally shared (the quality of DOE's requests for permit modifications;
risks to workers, the public, and the environment; and the adverse effects of external
performance pressures on the safety of the cleanup program). Many people who
provided comments to the committee expressed concern that any change in
characterization requirements or activities could result in decreased protection of worker
and public health and/or the environment.
Recommenctation 6: DOE should publish clearly written analyses of proposed changes
to the characterization program to document that these changes do not adversely affect
the protection of worker and public health and/or of the environment. DOE should also
provide public access to information about WIPP and its operations, including the WIPP
Waste Information System,42 and communicate interactively with state officials, tribes,
public interest groups, and scientific oversight organizations. In this context, the
proposed analytical framework could provide a technically defensible approach for
supporting changes to the characterization program.
42See the Glossary.
Representative terms from entire chapter:
characterization program
