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4
Transuranic Waste Characterization Program
This chapter describes the current (2003) contact-handled transuranic (CH-TRU)
waste characterization program as approved by the New Mexico Environment
Department (NMED) and the U.S. Environmental Protection Agency (EPA), and
implemented at the five U.S. Department of Energy (DOE) waste generator sites
shipping waste to the Waste Isolation Pilot Plant (WIPP). Emphasis is given to the
concept of "Acceptable Knowledge" (AK), a central feature of the characterization
program. Lessons from experience and future opportunities to take advantage of, in the
context of waste characterization, are presented at the end of this chapter (Section 4.6~.
4.1 Overview of the Current Waste Characterization Program
The committee describes the CH-TRU waste characterization program as a suite
of characterization activities that are performed at generator sites before shipping waste
to WIPP (see Figure 4.~. These activities address requirements set forth by Congress
(through the Land Withdrawal Act), EPA, NMED, and the U.S. Nuclear Regulatory
Commission (USNRC). Regardless of the time of generation (i.e., existing or to-be-
generated), TRU waste is divided into three categories for characterization purposes:
homogeneous waste, debris waste, and debris waste that needs repackaging. All waste
being characterized is solid waste because liquids are prohibited in WIPP.
Homogeneous solids are solid residues such as inorganic sludge, salt wastes, or
pyrochemical salt wastes that are expected to contain TRU radionuclides, toxic metals,
and solvents. Homogeneous solids range from de-watered sludge with the consistency
of paste to solid cement.
Debris waste, as its name suggests, consists of heterogeneous solids. Debris
waste includes such items as protective clothing, gloves, rags, laboratory instruments,
and parts of equipment such as gloveboxes. Some debris waste inventory has to be
repackaged in a form suitable for shipment (see below). Characterization activities vary
depending on the category of solid waste. Wastes are characterized following the same
set of activities independent of their time of generation (i.e., existing waste and to-be-
generated waste are characterized in the same fashion if they belong to the same waste
category). According to DOE, there are approximately 750,000 drums of CH-TRU waste
remaining to be characterized (DOE-CABE, 2003~.
Waste characterization activities for CH-TRU waste, including recent changes,
are described in the following sections based on information provided by DOE (DOE-
CBFO, 2002), the Center for Acquisition and Business Excellence (DOE-CABE, 2003),
and the New Mexico Environmental Evaluation Group (EEG, 2003b). A detailed
description of the characterization activities is presented in the Waste Acceptance
Criteria (DOE-WAC, 2003) and in Attachment B of the HWFP (HWFP, 2003~.
4.~1 Acceptable Knowledge
AK is a term that encompasses historical process knowledge and information
from previous testing, sampling, and analyses of waste. DOE coined this term based on
-
~ ~ ,
. . . . · . . .. . . .
39
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40
i
Improving the Characterization Program for Contact-Handled Transuranic Waste
-
Debris
Waste
At=
Homogeneous
Waste
-
Debris Waste
(to be
Repackaged)
AK
1
| RTR l
| Segre ration/ |
L Rework
NDA
[: ~
| Gas Generation |
L Testing |
| Statistical VE |
,
Data
Management
Audit
1
-
......
Shipment
,
AK
1
RTR
NDA
1
DAC/HSG
1 ;
Gas Generation
Testing
L StatisticalCoring I
, 1
| Analyses
,
Statistical VE
| Do Ita l
Management
| Audit l
~ v
Shipment
- 1
, ~ ,
AK
| Segregation/ |
I Rework l
~3
NDA
1
| DAC;HSG l
~ ,
Gas Generation
Testing
Data
Management
Audit
l
__
Shipment
FIGURE 4.1 Summary of typical characterization activities in the current contact-
handled transuranic waste characterization program. Characterization activities may
vary among generator sites. NOTE: AK = Acceptable Knowledge; DAC = drum age
criterion; HSG = headspace gas sampling and analysis; NDA = Non-destructive assay;
RTR = real-time radiography; and VE = visual examination.
=
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Transuranic Waste Characterization Program
41
EPA's similar concept of process knowledge; EPA has recently adopted the term
"Acceptable Knowledge" when referring to WIPP processes to be consistent with DOE
terminology (see further discussion in Section 4.4~.
4.~2 Real-time racliography and visual examination
Real-time radiography is a non-destructive examination technique usually
involving X-ray imaging technology. Visual examination is an invasive process that
involves opening a TRU waste container to inspect its contents. Radiography, visual
examination, or a combination of both are used on every waste container to verify its
physical form, confirm the absence or presence of prohibited items, and evaluate the
masses of various fractions of materials important to the performance of WIPP, such as
ferrous metals, non-ferrous metals, cellulose, or plastics and rubber.
With recent changes to the HWFP, generator sites have the choice to
characterize to-be-generated waste with visual examination or radiography, the latter to
be verified through visual examination on a statistical fraction of containers as a quality
control check. Sites may elect to use visual examination before or radiography after
packaging, either separately or together, as long as 100 percent of the containers
undergo confirmation of AK.
The visual examination process can be performed in two ways: 1) two certified
operators perform the visual examination process; or 2) a certified operator examines a
videotape of the waste removal and sorting process. In addition, approximately 1.2
percent of the containers ultimately disposed of at WIPP (or approximately 9,000 drums)
must undergo a quality control check of radiography results by visual examination.
Containers found to have prohibited items are also visually examined and reworked (i.e.,
the container is opened in a gIovebox and prohibited items are removed, see below).
4.~.3 Non-clestructive assay
Non-destructive assay is a general term for a number of non-invasive techniques,
such as gamma spectroscopy and passive-active neutron measurement. These
techniques provide information about the radionuclide content of waste and whether
waste is TRU without destroying the waste or waste form.
4~.4 Drum age criterion and heacispace gas sampling and analysis
Both the NMED and the USNRC have requirements for headspace gas (HSG),
which is the gas clevelopecl in the void volume of waste containers (e.g., 55-gallon
drums). The NMED requirements are to support hazardous waste determination. The
USNRC requirements are to determine that only non-flammable gases are present. Both
requirements are satisfied by a single procedure, called headspace gas sampling and
analysis. Headspace gas sampling and analysis is used to:
identify and quantify volatile organic compounds (VOCs4),
confirm AK for hazardous waste identification, and
identify and quantify flammable gases (hydrogen and methane) for transportation
purposes.
There are 29 VOC species that are required to be characterized quantitatively in the
WIPP HWFP permit. The amounts of VOCs in the waste shipped to WIPP to date have been
small (about 5 ounces summed over the 40,000 drums emplaced in Panel 1~. The predominant
species found (more than 90 percent by mass) are acetone, 1,1,1-trichloroethane, toluene,
methylene chloride, and carbon tetrachloride.
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Improving the Characterization Program for Contact-Handled Transuranic Waste
Heacispace gas sampling and analysis uses gas chromatography/mass
spectrometry, flame-ionization gas chromatography, or Fourier-transformation infrared
spectroscopy to analyze headspace gases. This characterization activity also involves
aging the drum for a prescribed number of days (up to 242) to allow equilibration of
gases in the headspace prior to sampling and analysis. The required waiting time prior to
headspace gas sampling is referred to as the drum age criterion.
All waste is verified by ~ 00 percent headspace gas sampling, except
homogeneous solids without VOC-related hazardous waste codes, or thermally treated
wastes (see Section 4.2~. A small portion of the containers (approximately 1.8 percent)
requires new vents prior to shipping,2 and over two-thirds of the containers (68.7
percent) require documentation to show compliance with the drum age criterion.
4.~.5 Gas generation testing
Gas generation testing at elevated temperatures is performed for transportation
requirement purposes although it is not part of the WIPP Waste Acceptance Criteria or
the waste analysis plan in the Hazardous Waste Facility Permit (HWFP). This test is
used to measure gas generation rates for wastes whose historical information suggests
that flammable gases might exceed the limits for transportation.
In the test, waste drums suspected to contain higher-than-normal concentrations
of hydrogen-bearing or organic compounds are heated to an elevated temperature to
measure the amount of gas generated. This method accounts for both radiolytic
hydrogen or methane generation (the predominant source of flammable gases) and any
VOCs (if present) that might be driven out of the waste into the headspace gas by
elevated temperatures during shipping in the summer months. If the test shows that the
container would not generate enough flammable gas during shipping to produce an
explosive mixture in the transportation package, the container may be shipped.
Approximately 9 percent of the remaining legacy waste population of containers, i.e.,
41,000 drums (S,550 cubic meters), is expected to require elevated-temperature gas
generation testing (DOE-CABE, 2003~.
4~.6 Homogeneous waste coring and analysis
Homogeneous waste forms can be sampled in a way that is representative of the
bulk of the waste. These wastes undergo statistical coring and analysis, which determine
the chemical composition and concentrations of hazardous waste constituents and the
toxicity characteristics of waste in containers (see Section 4.2~. "Coring" is a process
wherein a container of solids is opened, and a hollow drill bit is used to obtain a core that
reaches from the top of the waste to a depth near the bottom of the container. The core
is taken from the bit and "sampled" by removing either one or three thin sections from
along its length. These sections become the sample.
For retrievably stored wastes, the HWFP states that homogeneous sampling and
analysis is used to determine the toxicity "characteristic" in the waste; that is, the
hazardous compounds that are considered toxic only if present above the threshold
concentrations listed in 40 CFR 261.24, or if the "listed" wastes under Subpart D of 40
CFR 261 are present. The HWFP requires analysis of homogeneous samples for total
2Most but not all retrievable stored drums have filter vents installed at the time of
generation. When a drum is exhumed or retrieved and does not have a vent, usually the site
safety procedures require immediate venting (installation of a filter). AISO, there are some waste
streams that have shown filter degradation over times, and those streams have a routine filter
replacement schedule. Finally, at certain sites, the headspace gas sample is collected through
the filter; in this case too, the filter must be replaced.
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Transuranic Waste Characterization Program
43
VOCs, semivolatile organic compounds (SVOCs), and analysis for metals. Tables in the
HWFP list over 30 chemicals for the VOC analysis, ~ ~ for the SVOC analysis, and 14
metals that are the primary targets, but other hazardous constituents may be added to
the list for a waste stream if they are found in more than 25 percent of the samples from
that waste stream (EEG, 2003b).
4.~.7 Segregation or rework
Segregation or rework are the activities required when a container is found to be
out of compliance with the Waste Acceptance Criteria (e.g., if real-time radiography or
visual examination finds a prohibited item in a container, that container is segregated
from the others, the prohibited item is removed, and the waste is repackaged).
4.~.8 Repackaging
Repackaging involves removing all contents from the original waste container,
sorting, size-reducing, compacting,3 and putting them into new containers. During
repackaging, waste that is not suitable for shipment and does not meet the hydrogen
generation limits for transportation is removed from the containers.
4.~.9 Data management
Data management includes the data-gathering operations and quality assurance
activities that the waste generator and the Department of Energy (DOE) perform to
assemble, record, and certify the information on each container and to assist in
managing each transportation payload container. DOE uses a quality assurance process
based on that used by nuclear power plants (NQA-~ ) on all TRU waste characterization
and certification activities. The quality assurance process that is now described in the
HWFP requires, among other activities, the review, validation, and verification of all
analytical data; reconciliation of analytical results with data quality objectives (DQOs);
satisfying data reporting requirements; and identification, documentation, and reporting
of all non-conformances.
Data review determines whether raw data have been collected properly and
ensures that raw data are properly "reduced" to an acceptable format. Data validation
confirms that the data reported satisfy the requirements of the waste analysis plan and
are accompanied by the approval of an authorizing official. Data verification
authenticates that data as presented represent the sampling and analysis activities as
performed and have been subjected to the appropriate levels of data review. Other
quality assurance activities, such as statistical calculations for random sampling,
confidence levels from analyses, evidence of independent technical review, supervisor
review, quality assurance review, chain-of-custody and sample preservation are also
described in Attachment B5 of the HWFP (HWFP, 2003~.
As part of data management activities, sites transmit required characterization,
certification, and shipping data to WIPP prior to shipping using the WIPP Waste
Information System. This system consists of an electronic database equipped with edit-
limit checks to ensure that the clata representing the waste payload containers comply
with the Waste Acceptance Criteria. Only DOE, EPA, NMED, the New Mexico
Environmental Evaluation Group, and corridor state authorities have access to
information in the database.
3Size reducing and compacting are performed only at certain sites, such as the future
Advanced Mixed Waste Treatment Facility at the Idaho National Engineering and Environmental
Laboratory.
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Improving the Characterization Program for Contact-Handled Transuranic Waste
The HWFP data management process is comprised of seven layers of review;
some of the reviews are performed at generator sites and some at the DOE-CarIsbad
Field Office. There are also quality assurance activities for transportation purposes, as
described in Appendix D. According to DOE, it takes about two months for a waste
container to go through the entire data management process (Powell, 2003~.4
4.~10 Audits
Audits are the operations conducted by DOE's auditing branch at generator sites
to ensure that waste characterization sites conduct waste characterization activities in
accordance with the HWFP Waste Analysis Plan, and that the information supplied by
each site is managed properly. EPA, NMED, and the New Mexico Environmental
Evaluation Group participate in these audits as observers and confirm that
characterization requirements are addressed. They may request corrective actions to a
site's characterization process if they believe it does not comply with the regulations.
4.2 Statistical Sampling or 100 Percent Confirmation?
, _
Some characterization activities are performed on all containers (e.g., non-
destructive assays, headspace gas analyses, development of AK, and data
management), whereas others apply to only a selected portion of the inventory (see
Table 4.1 in Section 4.6~. For example, homogeneous solids, soils, or grave! without
VOC-related hazardous waste codes, or thermally treated waste may qualify for reduced
headspace gas sampling. Debris waste does not undergo homogeneous sampling and
analysis, and only a statistical fraction of homogeneous solids, soils, or grave!
undergoes homogeneous sampling and analysis.
An example of statistical sampling is illustrated in the case of homogeneous
waste solids. In this case, there are hNo levels of statistical significance. The first is the
statistical significance of the samples collected from a container. The second is the
statistical significance of samples collected across a waste stream.
The first part of statistical significance refers to sampling a container in a
statistically representative way (more accurately called aliquoting); this can be done in
several ways. One of these ways is coring and aliquoting from different layers (at least
three are required in the HWFP). If the waste is in a cement matrix, coring involves
drilling into the solid waste to collect aliquots. If the waste form allows it, sample gridding
(i.e., pouring the powder into gricis and then randomly aliquoting from the celIs) can also
be used to minimize entrainment of particulates.
The second part of statistical significance refers to how accurately a subset of
samples from a waste stream represents the true mean of a parameter (e.g., the
average lead metal concentration). In this case, the population variance must be known
before deciding how many samples to collect. The greater the variance, the more
samples are needed to achieve a given accuracy (as specified in the HWFP). For
instance, the HWFP specifies how many waste containers from a determined waste
stream must be sampled. From the results of the analysis of this first set of containers,
the variance of the population is estimated, and a new calculation of the number of
samples from that waste stream is made to achieve the required confidence level on the
mean. If necessary, more containers are sampled until the required accuracy is
achieved. Of course, if the first subset sampling results in the required accuracy, there is
no need to continue sample collection. According to DOE-CABE, approximately 0.5
4DoE submitted a data management permit modification request to NMED on June 28,
2002 to implement automating data processes that would eliminate four of the seven levels of
review. NMED has not issued a decision to date.
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Transuranic Waste Characterization Program
45
percent of the remaining containers, or 375 drums, will undergo statistical coring and
analysis for hazardous constituents (see Table 4.1 in Section 4.6~.
4.3 Site-Specific Characterization Activities
Characterization activities may vary somewhat from one generator site to
another, depending on the type of waste to be characterized and on terms negotiated
between the state in which the waste is generated and DOE. For example, the
characterization activities at the future Advanced Mixed Waste Treatment Facility in
Idaho and at the Savannah River Site are somewhat different. The Advanced Mixed
Waste Treatment Facility has the capability to "supercompact" waste for volume
reduction and more efficient operations.5 Therefore, real-time radiography and/or visual
examination are performed prior to compaction ancl/or final waste packaging. This facility
also has the capability to size-reduce and repackage wastes from oversized waste
boxes. EPA and NMED must approve the suite of characterization activities at each site
before allowing waste to be shipped to WIPP. To date (December 2003), the Advanced
Mixed Waste Treatment facility has not been certified.
The Savannah River Site has adopted a "fast-scan" approach to real-time
racliography, which consists of performing a quick radiography scan of the waste
containers during the weekend to identify prohibited items. Containers with prohibited
items are set aside to be segregated or reworked at a later date, while those that do not
appear to contain prohibited items follow the "quality-assured" characterization activities
during the week. This approach is not part of the Waste Acceptance Criteria or the
HWFP and was introduced by DOE to increase the efficiency of characterization
activities (see also Section E.3~.
A further example of site-specific changes to the characterization program is the
headspace gas sampling and analysis process. At the Savannah River Site, the
container is placed into a sampling chamber after it has met the required drum age
criterion. A remotely controlled drill places a sampling port in the lid. First, a sample of
headspace gas is drawn into a flame ionization detector, which quickly provides
hydrogen and methane concentrations to determine if the headspace gas is below
flammability limits for transportation purposes. Then, a second sample is drawn and
injected into a gas chromatograph-mass spectrometer to analyze for 29 VOC species
specified in the HWFP.
During the 3100 Project at the Idaho National Engineering and Environmental
Laboratory, each container was sampled using a filter vent with a septum entry. A
needle was inserted into each drum (manually) and a headspace gas sample was drawn
into a canister to be combined with other canisters. These were shipped in drums (1 0 at
a time-one canister per drum) to an analytical laboratory at some distance from the drum
sampling area. First, ten aliquots (one from each canister) were taken. The aliquots were
combined and a sample was injected into a flame ionization detector for flammability
(hydrogen and methane). A second sample of the combined aliquots was injected into a
gas chromatograph-mass spectrometer for VOC analysis.
The difference between the Savannah River Site and the Idaho National
Engineering and Environmental Laboratory 3100 Project analytical methods is primarily
in the lower limit of detection. With the Idaho National Engineering and Environmental
Laboratory aliquots combined, the minimum detection limits are significantly increased.
5A recent report by DOE's Inspector General noted that there would be a 6 percent
volume reduction for the 65,000 cubic meters of TRU waste from Idaho instead of the 35 percent
initially estimated (DOE-IO, 2003~.
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Improving the Characterization Program for Contact-Handled Transuranic Waste
However, only one gas chromatograph-mass spectrometer analysis per batch is needed,
so some time is saved.
The Rocky Flats Environmental Technology Site obtained an exemption from the
NMED requirement to perform headspace gas sampling and analyses on thermally
treated waste (see also Sections 3.3.2.1 and E.4~. DOE also submitted a request for
HWFP modification to obtain an exemption from headspace gas sampling and analysis
for the seated sources stored at Los Alamos National Laboratory (see Section 2.3~.
NMED denied this permit modification request because DOE did not provide sufficient
evidence that sealed sources do not contain hazardous waste (NMED, 2003b). The use
of AK alone to determine the flammability of headspace gas is allowed by the USNRC,
but DOE elected to measure flammable gas concentrations in each container.
According to DOE, the quality assurance requirements for the headspace gas
analysis are more demanding than those for the flammability test for transportation
purposes. First, headspace gas sampling and analysis requirements in the HWFP are
linked with the SW-846 (EPA's Methods Manual), which introduces precision, accuracy,
representativeness, completeness, and comparability criteria. Second, all of the
headspace gas sampling and analysis requirements are subjected to scrutiny during the
audit process. Third, other quality protocols come into play such as: 1) calibration
standards at the ppm level, 2) instrument controls, and 3) follow-up analyses for
"Tentatively Identified Compounds" at concentrations above the "Program Required
Quantitation Level" for all 29 VOC species in the WIPP Part A Permit list. While the
actual analyses and setup for flammable gases and VOCs require similar technical
efforts and costs, meeting the HWFP requirements to determine the VOC concentrations
requires a greater data management effort because of the number of analyses,
associated calibrations, and quality assurance requirements (Nelson, 2003~.
~ , _ _ , _ _ ,
4.4 Acceptable Knowlec~ge
The first step in the characterization process is the compilation of all relevant
information available on the waste into an auditable record. This information is called
AK. The AK record must include information that describes the amount and how the
waste was generated and managed, as well as the physical, chemical, and radiological
properties.
AK also includes information regarding the raw materials used in a process or
operation, process description, products, and associated wastes. AK 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 (DOE-SAR, 2003~.6 According to the EPA's definition, AK may consist of
a variety of information, such as the following (EPA, ~994~:
detailed waste analyses at the time of generation, if performed in accordance
with an acceptable quality assurance program;
studies of the waste generating process—in addition to information about the
process flowsheet and its goals, these may include data from the generator's
process, or from similar generation processes undertaken elsewhere, and from
experiments involving surrogate waste processes or products;
waste characterization data obtained from facilities that send wastes off-site for
treatment, storage, or disposal;
6EPA is currently in the final stages of a rulemaking to change 40 CFR 194.8 to streamle
its certification process of confirmation at generator sites. EPA has indicated that it will provide a
more focused definition of AK in that rulemaking.
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Transuranic Waste Characterization Program
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47
the generator's records of analyses performed before the effective date of the
Resource Conservation and Recovery Act (RCRA) regulations; or
other historical data relevant to characterization of the waste (e.g., procurement
records).
Acceptable Knowledge is developed on a waste stream basis. Once a generator
site determines that a particular waste stream is suitable for disposal in WIPP, the
generator begins collecting all relevant information available (i.e., the AK) for the waste
stream. The collected AK is then reviewed and released by the generator site, following
the regulators' procedures. This preliminary AK report contains the generator's
assignment of a waste matrix code and a summary category group.7 The lager specifies
the physical form of the waste (homogeneous, soils or gravel, or debris) and hence the
sampling and characterization regimen for the waste streams. The generator then
submits to WIPP a Waste Stream Profile Form (brief summary of the AK report, with
citations) and the AK Summary Report, which is approved by WIPP prior to shipment of
any containers of waste from the waste stream in question.
The EPA recognized that under certain circumstances, the use of existing
knowledge of a waste stream might be preferable to performing a detailed
characterization. As acknowledged in joint USNRC/EPA guidance, mixed wastes
constitute one of those circumstances because of the potential for personnel exposure
inherent in radioactive waste characterization (USNRC/EPA, 1997~. Although written for
commercial mixed waste generators, the guidance states that it could apply to
transuranic waste. Therefore, this guidance may also be useful for federal facilities that
generate mixed waste, such as WIPP waste generator sites.
The concept and use of AK is central to the characterization program for TRU
waste because it determines the sampling and characterization regimen for the waste.
_ A e ~ ~ en ~ ·e
The AK process delineates the waste stream. If the required elements cannot be
documented in the AK summary, the waste must be treated as "newly generated waste,"
according to DOE's terminology. AK forms the basis against which the results of other
characterization methods are compared. This process is termed "confirmation of AK."
The characterization methods used to confirm AK include non-destructive assay,
headspace gas sampling and analysis, radiography and visual examination, and
homogeneous solids sampling and analysis (DOE-CABE, 2003~.
4.4.1 Uses of Acceptable Knowlec4e
The EPA allowed the use of AK to determine whether a waste stream was
"characteristically" hazardous, to comply with the RCRA requirement to analyze a
representative sample of the waste and determine its disposability. AK is used to
address several characterization requirements set forth by different regulatory agencies.
Uses of AK in the characterization program are the following:
determine that waste is defense-related and TRU;
assign waste to one of the ~ ~ waste matrix code groups (see Chapter 3~;
assess the presence of toxic material;
assess the presence of listed RCRA waste;
determine the absence of non-radionuclide pyrophoric materials;
determine the absence of liquids;
determine the absence of incompatible wastes;
7For a definition of waste matrix code and summary category group, see the Glossary.
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48 Improving the Characterization Program for Contact-Handled Transuranic Waste
determine the absence of containerized gas or explosives;
determine the absence of reactive, corrosive, or ignitable waste characteristics;
track the presence of polychIorinated biphenyIs;8
determine the absence of sealed containers greater than 4 liters; and
· determine the fissile material content.
If the waste was generated after the implementation of RCRA (1 976), many of the above
physical and chemical characteristics of waste are gathered from the hazardous waste
codes assigned to the waste at the time of generation.
4~4.2 Qualification of Acceptable Knowledge
Based on EPA's requirements set forth in 40 CFR ~ 94.22(b), historical
information cofIected before an approved quality assurance program is in place must be
qualified before it is used as AK. Title 40 CFR 194.22(b) lists four methods that may be
used individually or in combination to qualify such data:
1. Peer review. In general, the use of peer review requires a structured and
documented review process.
2. Use of corroborating evidence. This may include other data generated prior to
approval of the quality assurance program or data on other waste streams that
should be able to represent the one being considered.
3. Confirmation by measurements. These confirmatory tests must be performed in
accordance with an approved quality-assurance program.
4. Qualification of quality assurance program. In practice, this means demonstrating
that the quality assurance program in effect when the AK was generated was
equivalent to a quality assurance program approved by WIPP.9
Currently, confirmation by measurements is the only method used to qualify
existing information, as negotiated between DOE and its regulators. All information
about existing waste collected before the establishment of a quality assurance program
must currently be confirmed by some type of measurement to become AK. The types
and frequency of confirmatory measurements vary depending on the particular waste
and the site. For example, for debris waste, information is confirmed by using either real-
time radiography or visual examination.
4.4.3 Accuracy of historical information
A key question is how to verify the accuracy of historical information about waste.
The accuracy of AK is, according to the Waste Acceptance Criteria, to be verified on a
waste stream basis, although AK is also used to define waste streams. How accuracy
should be determined is not specified in the Waste Acceptance Criteria. However, DOE
has established Data Quality Objectives for AK as required by the HWFP (2003;
Attachment Bat.
The following is an excerpt from the State of New Mexico HWFP (2003;
Attachment B3, Section B3-9~:
~Polychlorinated biphenyls are no longer listed in the HWFP as prohibited items;
however, DOE is required to track their presence according to EPA's authorization for WIPP
operation as a chemical waste landfill.
91n the case of newly generated wastes, it is likely that the generators' quality assurance
programs will be approved by WIPP prior to generation of the waste.
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Transuranic Waste Characterization Program
To ensure that the acceptable knowledge process is consistently applied,
the Permittees shall require sites to use the following definitions when
complying with the data quality requirements for acceptable knowledge
documentation:
Precision- Precision is the agreement among a set of replicate
measurements without assumption of the knowledge of a true value. [..]
· Accuracy Accuracy is the degree of agreement between an
observed sample result and the "true" value. The percentage of waste
containers, which require reassignment to a new waste matrix code,
and/or designation of different hazardous waste codes based on the
reevaluation of acceptable knowledge and sampling and analysis data will
be reported as a measure of acceptable knowledge accuracy. [..]
Completeness Completeness is an assessment of the number of
waste streams or number of samples collected to the number of samples
determined to be useab~e through the data validation process. t...]
· Comparability Data are considered comparable when one set of
data can be compared to another set of data. Comparability is ensured
through sites meeting the training requirements and complying with the
minimum standards outlined for procedures that are used to implement
the acceptable knowledge process. [...]
. Representativeness- Representativeness expresses the degree to
which sample data accurately and precisely represent characteristics of a
population.
49
There is great variability in AK accuracy (degree of agreement between observed
measurements and the "true" valuer among sites. AK accuracy is calculated by
comparing the EPA hazardous waste identification numbers (see the Glossary)
determined by confirmation activities to those predicted by historical information. A
recent DOE report documents AK accuracy results for waste from the Rocky Flats
Environmental Technology Site and Idaho Engineering and Environmental Laboratory.
This report shows high AK accuracy when compared to the data acquired through tests
with some slight differences among sites (Kehrman and Most, 2003~.~° According to
DOE, differences in AK accuracy are the outcome of the implementation of inadequate
procedures rather than erroneous historical information. Therefore, it is unclear how AK
accuracy varies among different waste streams and among different waste sites.
4~5 Characterization Costs
DOE provided the following characterization cost information at the committee's
request. According to a 2000 estimate in DOE's National TRU Waste Management Plan,
the total cost of waste management beginning in 2001 for the generator sites is $6.2
billion (DOE-NTP, 2000~. These estimates do not include costs for work done prior to
2001. The predicted cost from 2001 of characterization and certification of both CH-TRU
and remote-handled TRU waste is about $3.1 billion, or approximately 50 percent of the
total budget for all sites. Waste characterization at the current level represents 16
percent of the estimated total WIPP costs of $19 billion (DOE- FSElS, ~ 997~.
Table 4. ~ shows characterization activities, the percentage of containers to
undergo these activities, and average cost estimates per container in the current CH-
4°NMED observed that AK accuracy results are based primarily on waste from Rocky
Flats Environmental Technology Site, part of which was sent to Idaho (NMED, 2003c).
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Improving the Characterization Program for Contact-Handled Transuranic Waste
TRU waste characterization plan. The "life-cycle cost" of an activity is the product of the
"average unit cost," the total number of containers, and the fraction of containers that
require the activity. Most costs of characterization activities are self-explanatory and
refer to Figure 4.~. Waste certification costs include data management and audit
activities. Characterization support costs correspond to site activities related primarily to
container handling during characterization. The Savannah River Site was able to
account for this activity separately; other sites included container handling in the
characterization costs.
i
The table shows that, by far, the most costly procedures in the characterization
program are those that involve breaching or penetration of the container (e.g., solids
analysis, visual examination of reirievably stored waste, and homogeneous solids coring
and sampling). The cost of TRU waste characterization to date averages approximately
$3,900 per container. This estimate is based on an assessment at those generator sites
that are currently characterizing and shipping waste to WIPP.
There is uncertainty and a great variability in costs of characterization activities
among sites depending on the nature of waste streams and the volume (DOE-CABE,
2003~. Characterization of the waste that has been shipped to WIPP has cost $160
million so far. If the cost of characterization remains the same, then characterization of
all of the remaining CH-TRU waste destined for WIPP (approximately 750,000 drums)
may cost up to $3 billion.
According to the cost analysis provided by DOE (DOE-CABE, 2003; page 23),
tarn area where costs could greatly be reduced pertains to the number of
times a drum is actually moved prior to shipment to WIPP. [..] It is
estimated that as the characterization program matures at each site and
the number of waste streams approved for disposal increases, the
number of drum movements could be reduced by up to 50°/O.
The committee discusses below the CH-TRU characterization program and
proposes some opportunities for improving its effectiveness. This discussion is reflected
in the findings and recommendations in Chapter 6.
4.6 Discussion: Lessons from Experience and Future Opportunities
Shipment to and emplacement of more than 40,000 drums of TRU waste in
WIPP after four years of operations is evidence of the acceptability to the regulators of
the waste characterization program thus far. The opening and operation of the WIPP
facility would not have been possible if DOE had not provided its regulators with
sufficient information of acceptable quality, including waste characterization information.
However, after four years of operations, there are lessons to be learned and, with the
experience base steadily increasing as WIPP operations continue, opportunities for
identifying characterization activities that are not necessary to protect human health and
safety and the environment.
Determining whether there are inefficiencies in the characterization program and
what improvements can be made is a complex task. To perform this task, a structured
and quantitative analysis of characterization activities, coupled with operational
experience, can be used to identify which, if any, characterization activity produces
information that is not used in decisions concerning waste handling, transportation, or
disposal and if alternatives that are more cost-effective and result in the same, or
greater, level of protection of human health and the environment exist.
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51
Table 4.1 Characterization Activities, Percentage of Containers Ultimately Emplaced in
the Waste Isolation Pilot Plant Requiring Such Activity, and Average Cost Estimates
Characterization Activity
Percentage
of Average Unita Average Cost
Containers Cost (U.S. Containera
Activity Dollars) (U.S. Dears
Non-Destructive Assay ~ 00 840 840
Headspace Gas Analysis ~ 00 620 620
Real-Time Radiography 32.8 730 240
Visual Examination/Retrievably Stored 1.2 22,500 270
-' .' Visual Examination/Newly Generated 67.2 540 360
Solids Coring and Sampling 0.5 24,000 120
Solids Analysis 0.5 63,000 310
Acceptable Knowledge 100 87 87
Drum Venting 1.8 120 2
Level I! Data Management ~ 00 ~ 60 ~ 60
- i i- Gas Generation Testing for Transportation 9 670 60
Drum Age Criterion 68.7 46 32
Segregation or Rework 30 1,400 420
Waste Certification ~ 00 330 330
Characterization Support Activities ~ 648 52
Average Cost of Characterization per Container
aThe average unit cost is the cost to characterize a single container. The average cost per
container is the unit cost averaged on the number of containers undergoing a particular
characterization activity.
SOURCE: DOE-CABE, 2003.
3,900
This structured and quantitative analysis is the subject of Chapter 5 and leads to
the committee's main recommendation (Recommendation 1~. In addition to supporting
the proposed analytical framework, operational experience can be used to identify
opportunities to improve the characterization program that are operational in nature,
some of which can be instituted without regulatory approval, as discussed below.
4.6.1 Uses of operational experience
While characterization information gathered to date at four sites cannot be
directly extrapolated to other sites and to waste yet to be characterized, the operational
experience accumulated during these first four years of WIPP activities provides a basis
on which to evaluate whether improvements in efficiency and costs can be realized while
continuing to protect human health and safety and the environment (see Finding and
Recommendation 2~. Examples of uses of operational experience to evaluate and
improve the effectiveness of the characterization program are the following:
Experience can be used to estimate the value and extent to which each
characterization activity provides information that is: ~ ~ essential to protect health
and safety, 2) reclundant 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 would be of use in the structured and
quantitative analysis of the characterization program described in Chapter 5.
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Improving the Characterization Program for Contact-Handled Transuranic Waste
.
.
Analysis of the characterization data acquired to date along with continuing the
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 AK 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. ~ . ~ ).
Experience allows a better understanding of cost 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~.
Only the second of these four examples potentially leads to changes requiring regulatory
approval.
4. 6. 1. ~ Operational experience has a/ready produced improvements in waste handling
The first four years of operational experience have already benefited waste
handling operations. Characterization activities involve significant handling and
intermediate storage (staging) of waste containers. Each container is subjected to
multiple analyses, most of which can be the basis for rejecting a container which then
has to be set aside waiting to be reworked. Some analyses require temperature control
and aging of waste, and most require special equipment with limited throughput, such as
headspace gas sampling and analysis. These activities require moving waste containers
from one characterization operation to another or the staging of waste containers in the
proximity of characterization areas. DOE refers to this handling of containers during
characterization as the "dance of the drums" (DOE-CABE, 2003; page 23~:
Drums are moved multiple times for characterization for many reasons
(e.g., when the drum needs to be separated from the batch because
something is amiss with the data package, when a cirum fails a
certification test, or when the assay is problematic). The drum then needs
to be set aside until the issue is resolved, or the drum is reworked. Costs
at [the Idaho Engineering and Environmental Laboratory] are $~.33 per
movement. Costs at [the Savannah River Site] are $21.60 per movement.
Both [sites; have independently estimated that drums were moved
approximately thirty (30) times in the characterization process.
At some sites, limited storage capacity and storage times (under current limitations of
the generator sites' permits) result in further waste handling to and from storage areas
between characterization operations.
The Rocky Flats Environmental Technology Site has demonstrated that the
system for handling containers throughout the characterization process can be
streamlined as workers and management gained experience. Improvements in
operations developed at this site have led to improvements in cost, schedule, and
worker protection (Spears, 2003~. Such an improvement process might be applied
advantageously at the other generator sites.
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53
4.6.2 Different approaches for different waste streams
Transuranic wastes are generated at different times, in different ways, and have
different properties and compositions. The quality of information available on each waste
stream is particularly important because this information becomes part of AK and
determines the extent of characterization activities necessary to confirm this knowledge.
Some CH-TRU 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.
Experience has shown that, in some cases, it is possible to tailor the
characterization program to specific waste streams thereby adjusting the extent of
confirmation activities to the quality and type of the information available (see Finding
and Recommendation 3~. For example, DOE has obtained an exemption from
headspace gas sampling and analysis for thermally treated wastes at the Rocky Flats
Environmental Technology Site. To obtain regulatory relief from NMED, DOE provided a
technically defensible case that showed how this particular waste stream could not
contain any volatile organic compound.
Opportunities for tailoring waste characterization to waste streams may be
greater with to-be-generated waste. To-be-generated waste may be better characterized
than existing waste because the characterization information can be collected at the time
of waste generation under an approved quality assurance program. Future
improvements in management methods, processes, and record keeping will also lead to
better characterization information. Therefore, some to-be-generated waste may not
require any, or as much, confirmation of the information collected about the waste.
On the other hand, existing waste streams may have less detailed information
available and require extensive characterization. As more waste is characterized, it may
be found that current characterization methods or technologies may be unsuitable for
certain waste streams. For instance, some existing wastes may pose characterization
challenges and may need a stream-specific characterization process (see for instance
Sections 2.3 and 2.4~.
Special characterization techniques may be needed for non-destructive
examination and assay to measure gas concentrations in the storage container, to
handle large pieces of equipment (e.g., gIoveboxes with unique designs), or to address
problems not yet encountered. Specialized operator training, new or improved
equipment and facilities, special material handling and record keeping, and additional
funding requirements are potential challenges that may have to be addressed. Changes
to tailor the characterization program to different waste streams require regulatory
approval.
,
4.6.3 Different qualification methods for different waste information
The confirmation-by-measurement method is applied systematically by DOE to
qualify information to be used as AK, regardless of the extent of the information available
or the origin of the waste. As experience continues to be gained, there may be future
opportunities to take advantage of: 1) a statistical sampling program rather than 100
percent confirmation activities, or 2) the three other methods allowed to qualify AK (i.e.,
peer review, corroborative evidence, and qualification of another quality assurance
program; see Section 4.4.2~.
Applying statistical sampling rather than 100 percent confirmation to certain
waste streams has already led to increases in program efficiencies. For example, as
noted in Section 3.3.2, DOE has already successfully obtained a change to the HWFP
that reduced the number of waste containers to undergo visual examination as a quality
control check on radiography results, thereby saving more than $19 million.
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Improving the Characterization Program for Contact-Handled Transuranic Waste
The larger the number of containers included in a particular waste population to
be sampled, the greater the potential increase in the program efficiency. As noted in
Section 3.4, in the Certificate of Compliance application for WIPP, DOE identified 569
waste streams, while EPA sorted WIPP waste inventory by volume into 10 classes. In
the HWFP. NMED identified ~ ~ Eves of waste streams decendina on the main matrix
,, ~ _
e ~ ~ ~ ~ . · ~ ~ I d · d · d ~ I do- d
component. It too many streams are defined, the opportunities to use and benet~t from a
statistical approach are diminished because the population to be sampled within each
stream is smaller. At the limit, if each container is its own waste class, no statistical
method for that class can be used.
However, defining the population loosely to be all-inclusive could also be
misleading. For instance, if a population to be sampled is defined to include both to-be-
generated and existing waste (assuming the lager has poor historical information
available), then statistical sampling methods would hardly represent the population. To
ensure representativeness, the statistical sampling approach could apply to increasingly
inclusive waste populations possibly followed by either decreasing sampling rates as
experience is gained (and appropriate performance is documented) or increasing
sampling rates if information is found to be inaccurate.
Future experience with to-be-generated waste may show that it is possible to use
AK for selected wastes without the need for confirmation. This can be done by managing
and recording what is put into the containers in compliance with the approved CH-TRU
waste characterization plan and by following an approved quality assurance program
(see Findings and Recommendations 3 and 4~. Similarly, for existing waste that needs to
be repackaged, if the appropriate characterization activities are performed during
packaging under a regulator-approved program, they shouIcl provide AK-qualifiecl
information without the need to open containers for visual examination or headspace gas
measurement.
Previous attempts by DOE to use qualification methods other than confirmatory
measurements were not successful. DOE adempled to demonstrate that non-destructive
assay measurements coffected for safeguard reasons on a particular waste stream at
the Rocky Flats Environmental Technology Site could be used as corroborating
evidence or as a qualified quality assurance program in lieu of WIPP-certified non-
destructive assay data.
About 4,000 drums had already been measured individually with a non-
destructive assay system, which collects information on plutonium, americium, and
uranium-235 for safeguard purposes. The Rocky Flats Environmental Technology Site
measured the same population with a WIPP-certified system and made a statistical
argument (based on the first 1,000 drums) that the total plutonium in the waste stream
as predicted from the safeguards non-destructive assay was within ~ percent of that
predicted by the WIPP-certified system.
EPA dicl not accept safeguard data as a qualifying method because the data did
not provide information on all 10 radionuclides listed in the Compliance Certification
Application (see Appendix C). EPA also rejected this qualifying method for containers
with less than 0.5 grams of plutonium, the lower detection limit for safeguard data. Also,
the New Mexico Environmental Evaluation Group notes that several measurements
accepted by the DOE's internal safeguards program were found to be significantly in
error when containers were re-measured using WIPP-certified instruments (EEG,
2003b).
DOE is currently evaluating opportunities for using peer review as a qualification
method for existing information. For example, DOE has proposed to EPA that staff of the
Los Alamos National Laboratory conduct a peer review on the seated sources stored at
this site, for which, according to DOE, extensive documentation is available. These
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55
sources also need to be repackaged before shipment; therefore, the information
collectecl during repackaging, along with peer review of historical knowledge, may not
need any confirmation by measurement. Changes to confirmation activities require
regulatory approval.
4.6.4 Importance of effective communication
Experience shows that stakeholders,44 not only in New Mexico, but also in states
generating waste and in corridor states, have concerns about WIPP-related operations.
Since 1971, when focal officials in CarIsbad began advocating the development of the
nation's first underground waste disposal facility in their area, local and state officials,
citizens, and organizations have been involved in policy making about the WIPP site
(Fleck, 2002~. As plans for a repository acivancecl, interest in WIPP expandecl to include
officials and citizens along potential waste transportation routes in other regions of New
Mexico, in states where DOE production facilities are located, and along transportation
corridors.
Although there has been broader public acceptance of the WIPP facility over
time,42 there continue to be concerns about characterization-related activities and
transportation (SRIC, 2001a; UNM, 2001; Daniels, 2003~. Members of the public are
concerned about DOE's reliability in adequately protecting human health and safely,
particularly in the event of an accident. Concerns about transportation include the use of
uncertified characterization procedures; the safely of shipping containers; and the safely
of transportation routes. A transportation protocol agreement has been signed between
DOE and some of the corridor states reflecting the desire to ensure safe and uneventful
shipments of waste to WIPP (see Sidebar 3. ~ ).
During open meetings in CarIsbad and Santa Fe, the committee heard concerns
about waste characterization from members of stakeholders organizations43 including
the following:44
Rationale for proposed permit modifications is lacking (Nuclear Watch of New
Mexico, 2003~.
DOE permit modification requests are frequent and of poor quality (SRIC, 2002;
Petrie, 2003~.
There is a lack of transparency in the clecision-making process (SRIC, 2001b;
Arends, 2003; Hancock, 2003; Peirie, 2003; Reade, 2003~.
Internal drivers for DOE's cleanup program may lead to a reduction in
characterization activities necessary for protecting public and worker health in
order to save money (Petrie, 2003~.
Less stringent characterization activities could increase potential radiation doses
received by the public (Reade, 2003~.
44The term "stakeholders" indicates local officials and interested and affected members of
the public in New Mexico, waste generator states, and corridor states.
42The University of New Mexico has been tracking public opinion since 1990 (UNM,
2001 ).
43As others have noted, most people who comment publicly about WIPP in New Mexico
are members of existing stakeholder groups (Phoenix Environmental and Envirolssues, 2001;
Drew et al., 2003~.
44The committee's understanding of the concerns of citizens and officials about
characterization activities is based on presentations to the committee and on published
documents (e.g., public comments on HWFP modification requests), not on an independent study
conducted by the committee.
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56 Improving the Characterization Program for Contact-Handled Transuranic Waste
Changes to the waste characterization program may result in a decrease of
regulatory authority by EPA and NMED (Peirie, 2003~.
Communities near generator sites are concerned about risks to site workers;
risks of storing waste at the sites; costs; and delays in moving waste out of their sites.
Representatives of Citizen Advisory Boards from nine DOE sites prepared the following
recommendations for DOE during a recent conference on TRU wastes (CAB, 2003~:
~ .
.
Characterize TRU waste as required to reduce risk and minimize transportation
and handling of the waste, while making the process cost-effective.
Streamline TRU waste management by accepting demonstrated process
knowledge for TRU waste characterization.
Evaluate the concept of one or more locations to characterize TRU waste for
WIPP disposal.
Finish the analyses and make a decision with adequate public involvement
regarding where to characterize TRU waste for disposal.
Several law suits against DOE involving generator or corridor states on matters
related to WIPP were filed in 2003, reflecting focal group's concerns with the shipment
and storage of out-of-state wastes to their site (Ashton, 2003; Mulick and Stang, 2003~.
For example, in Washington State, there was concern about the Hanford Site receiving
TRU wastes from the Badelle Columbus Laboratories site in Ohio for characterization
before being shipped to WIPP (Mulick and Stang, 2003; Stang, 2003~. The state filed a
lawsuit against DOE to reach an agreement on an accelerated shipping schedule for
Hanford waste to WIPP, in exchange for storing and characterizing waste from other
sites.
Experience has shown that effective, transparent communication and the use of
the established regulatory processes to make changes to the characterization program
can help build cooperation and confidence among all parties (see Finding and
Recommendation 5 and 6~. The lack of public accessibility to characterization records
and the WIPP Waste Information System database is a frequently-expressed concern
among stakehofJers. WIPP stakeholders have also publicly commented on the lack of
information on proposed changes to the characterization program. Records of changes
to the WIPP program show that regulators granted modifications to the authorization
documents only after extensive communications and data exchanges with DOE staff,
and after DOE provided a defensible technical analyses to show that proposed changes
do not weaken protection of the human health and safety and the environment (see
Section 3.3~.
The New Mexico Environmental Evaluation Group's independent evaluations
have contributed in building effective communication and transparency. This group
provides technical input and oversight to DOE about WIPP issues, including
transportation, and helps in conveying technical information to stakeholders and the
general public. The quarterly meetings between DOE, NMED, the New Mexico
Environmental Evaluation Group, the New Mexico Office of the Attorney General, and
interested members of the public are an example of DOE's efforts to maintain
communications and address concerns. Changes in the communication and outreach
efforts of the program do not require regulatory approval. Experience in other waste
45An agreement was reached in October 2003 by establishing a legally binding schedule
for the removal of TRU waste from the Hanford Site in exchange for accepting TRU waste
shipments from Ohio.
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Transuranic Waste Characterization Program
57
disposal programs has shown that effective communication with stakeholders and
regulators as well as transparency can help to reduce or mitigate the lack of trust, avoid
charges of secrecy, and possibly lead to greater tolerance of changes, where warranted
(NRC, 2003 and references therein).
Using operational experience is only one of the keys to improving the program.
The uniqueness of certain sites or waste streams does not always allow taking
acivantage of past experience. Moreover, changes to the characterization program may
have policy or societal impacts that need to be considered prior to submitting a permit
modification request. A structured and quantitative analysis of the linkages between
risks, benefits, and impacts of characterization activities along with analyses of past and
future waste inventory characteristics is needed to arrive at a flexible waste
characterization plan program that can take into account the variability of sites and
waste streams, allowing for more efficient and effective waste characterization
operations as well as communication among all parties (see Findings and
Recommendations).
Representative terms from entire chapter:
waste characterization
