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OCR for page 7
Introduction
The U.S. Department of Energy (DOE) is responsible for the safe management
and disposal of transuranic (TRW) waste produced in defense-related activities and
stored at 27 DOE sites across the country.' Contact-handled transuranic (CH-TRU)
waste is currently being shipped from generator sites and characterization hubs to its
final disposal site, the Waste Isolation Pilot Plant (WIPP), in southeastern New Mexico.
To obtain authorization to ship TRU waste to WIPP, generator sites must first
characterize and certify their waste in compliance with characterization requirements set
forth by the U.S. Environmental Protection Agency (EPA) and the New Mexico
Environment Department (NMED). Adclitionally, shipping containers2 must be certified by
the U.S. Nuclear Regulatory Commission (USNRC), and shipments must comply with
U.S. Department of Transportation (DOT) requirements for hazardous waste. Figure 1.1
shows the location of the ten major TRU waste generator sites and transportation routes
to WIPP.
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FIGURE 1.1 Location of the ten major transuranic waste generation sites and primary
waste transportation routes to the Waste Isolation Pilot Plant. SOURCE: DOE.
Readers who are familiar with background information on transuranic waste and WIPP
can skip to Chapter 3.
21n this report, "shipping container" refers to a transportation package, typically a
TRUPACT-II, while "container" refers to a waste container, typically a 55-gallon drum.
7
OCR for page 8
8
Improving the Characterization Program for Contact-Handled Transuranic Waste
After four years of shipping and disposing TRU waste in WIPP, DOE has
identified waste characterization as one of the most costly and time-consuming parts of
the National TRU Waste Management Program.3 According to an assessment by DOE,
the cost of characterization and certification activities to prepare waste to be shipped to
WIPP (or elsewhere) is estimated to be $3.1 billion, or approximately 16 percent of the
$1 9 billion total life-cycle costs for the disposal of TRU waste (DOE-FSElS, ~ 997~.4
In light of this assessment, DOE asked the National Research Council for
scientific and technical advice on opportunities for improving the characterization
process and reducing the costs of the CH-TRU waste characterization program. A
committee of 12 experts was appointed by the National Research Council and assigned
the statement of task in Sidebar 1.~. The committee roster and biographical sketches
can be found in Appendix A.
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1.1 Boundaries of the Statement of Task and Strategy to Acictress lt
This report addresses the characterization program for CH-TRU waste; this is the
only type of waste currently allowed in WIPP. RH-TRU waste is not allowed for disposal
at WIPP because there is no characterization program approved by WIPP regulators for
this type of waste. Moreover, the proposed characterization plan for RH-TRU waste was
the object of a previous National Research Council report (NRC, 2002~. The present
report briefly addresses RH-TRU waste as a potential characterization challenge (see
Section 2.3.6~.
The committee discusses only those transportation requirements that have an
impact on characterization activities. It does not address other transportation issues,
such as shipment tracking, communication systems, emergency response plans, truck
inspections, transportation modes, and so forth.
The first objective of the statement of task is to review DOE's program for
transuranic waste characterization. Determining whether there are inefficiencies in the
characterization program and what improvements can be made is a complex task. To
perform it, a structured and quantitative analysis of characterization activities, coupled
with operational experience, can be used to identify which, if any, characterization
activities warrant changes. The committee proposes a structured and quantitative
analytical framework in Chapter 5 to support its main finding and recommendation
(Finding and Recommendation ~ ).
3The National TRU Waste Management Plan is a DOE system-wide approach to the
management and disposal of TRU waste stored and generated throughout the DOE weapons
complex (DOE-NTP, 2002~. DOE's Carlsbad Field Office manages this program. Information on
the program is available at: ~http://www.wipp.ws>.
4This estimate does not take into account discount rates.
OCR for page 9
Introduction
9
The second objective of the statement of task is addressed in Chapter 6. The
committee provides six recommendations that could increase the program's technical
soundness, efficiency, cost effectiveness, and safely to workers and the public. These
recommendations address the characterization program as whole, not specific
characterization activities.
The committee does not recommend changes to specific characterization
activities because of the policy nature of such a recommendation. Furthermore, to
recommend chances to specific activities would reouire a systematic and Quantitative
. . .. . ..
in, , , , ~
analysis of risks, costs, and impacts. Such an analysis is beyond the committee's scope
(see Finding 1~. Nevertheless, the committee provides illustrative applications (albeit
incomplete) of the proposed structured and quantitative analysis to three
characterization activities that were chosen on the basis of information provided by DOE
and findings from a previous National Research Council committee (see Section 5.9~.
The report also addresses programmatic, policy, and societal impacts of changes
to the characterization program as follows:
.
.
Programmatic impacts. Use of experience gained in the first four years of WIPP
operations to make programmatic improvements is discussed in Chapter 4. The
programmatic impact on risks and costs of changes to characterization activities
is discussed in Sections 5.3 and 5.4.
Policy impacts. It is important to recognize the distinction between regulatory
requirements (referred to as "characterization requirements") and the approach
to meet such requirements ("characterization activities"~. The committee does not
comment on regulatory requirements themselves because these are prerogatives
of DOE's and of the regulatory agencies.' Instead, the committee provides
scientific and technical advice on how to improve DOE's waste characterization
program within the current policy framework. The policy framework for TRU
waste characterization is described in Chapter 3 and Appendices C and D. The
committee addresses the policy impact of changes in the characterization
program in Section 5.5.
Societal impacts. Societal impacts of changes in the characterization program
are discussed in Section 5.6. Potential impacts of changes in the characterization
program on corridor states5 agreements with DOE are also discussed and these
societal impacts are the basis for Findings and Recommendations 5 and 6.
The assumption underlying this report is that WIPP must always be in
compliance with regulatory requirements. Any improvements to increase the program's
technical soundness, efficiency, cost effectiveness, and safely to workers and the public
must result in compliance with the regulations. Most changes require regulatory
approval. Therefore, the question is whether another characterization activity can meet a
given regulatory requirement in a more cost-effective way without reducing the level of
protection of human health and the environment. The answer to this question is provided
by the application of a structured, quantitative analysis of the value of the information
providecl by the characterization activity in question.
1.2 Origin of This Study
This study builds on two previous National Research Council reports on WIPP:
Improving Operations and Long-Term Safely of the Waste /so/afion Pilot Plant (NRC,
5Corridor states are those through which TRU waste is expected to be shipped, either to
interim DOE sites or to WIPP.
OCR for page 10
10
Improving the Characterization Program for Contact-Handled Transuranic Waste
2001), and 2) Characterization of Remote-Hanc//ec/ Transuranic Waste for the Waste
/so/ation Pilot P/anf (NRC, 2002~. The 2001 report provided a first assessment of
characterization activities for CH-TRU waste in the framework of a much broader task on
WIPP. The 2002 report addressed characterization activities for remote-handIed
transuranic (RH-TRU) waste.
Both committees discussed the history of some of the characterization activities
for contact-handIed transuranic (CH-TRU) waste appearing in the Hazardous Waste
Facility Permit (NRC, 2001, 2002, and references therein). Based on DOE analyses of
the records of the negotiation process with the State of New Mexico, it appeared that
DOE included certain waste characterization activities that went beyond what was
required to comply with the requirements in 40 CFR 264. For instance, DOE proposed to
NMED to conduct homogeneous waste and headspace gas sampling and analyses on
the totality of CH-TRU waste containers to confirm existing information about the waste.6
Furthermore, a provision for the confirmation of radiography results by visual
examination was also included in the 1995 permit application to NMED.
Therefore, the committee that authored the 2001 report recommended (NRC,
2001; page 66~:
DOE should eliminate self-imposed waste characterization requirements
that lack a legal or safely basis.~7~
Similarly, the committee that authored the 2002 report on the proposed characterization
program for RH-TRU waste recommended (NRC, 2002; page 49~:
DOE should propose only characterization activities that have a technical,
health and safely, or regulatory basis.
The present committee uses the characterization activities mentioned in the 2001 report
as examples of characterization activities to be re-evaluated using the analytical
framework described in Chapter 5 to determine their connection with the protection of
human heath and safely (see Section 5.9~.
1~3 Transuranic Waste Defined
Transuranic waste is radioactive waste containing radionuctides with atomic
numbers greater than that of uranium (Sidebar 1.2 provides information on the definition
and classifications of TRU waste). Transuranic waste is generated during the
manufacture and reprocessing of plutonium for production reactor fuel and irradiated
targets, as well as in various research programs. In recent years, TRU waste has also
been generated and collected for disposal through environmental remediation and
decontamination and decommissioning operations at DOE sites.
Transuranic waste consists of long-livecl alpha-emitting raclionuclicles, typically
plutonium radioisotopes, contaminating items such as protective clothing and gloves,
rags, laboratory instruments, gloveboxes, and equipment (see Sidebar 1.2~. Other TRU
waste in semi-solid form consists primarily of sludge by-products from the chemical
separation and recovery of plutonium and other transuranic isotopes. Some TRU waste
6For a description of these activities, see Chapter 4.
7The word "requirements" in the 2001 report corresponds to "activities" in this report. The
term "legal basis" referred to the Land Withdrawal Act, the Resource Conservation and Recovery
Act, Titles 40 CFR 191, 40 CFR 194, and 40 CFR 264.
OCR for page 11
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OCR for page 12
Improving the Characterization Program for Contact-Handled Transuranic Waste
....~.;~..
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has beta, gamma, or X-ray emissions associated with the TRU radionuctides or with
other contaminants of the waste. WIPP can only accept defense-related TRU waste,
which is waste produced through activities associated with the U.S. defense nuclear
weapons program.
Because of its radiological hazard and the tong half-lives of some of its
radionuclides, long-term geologic isolation must be provided for TRU waste. In ~ 992, the
U.S. Congress designated the WIPP, a facility near CarIsbad, New Mexico, as the
nation's geologic disposal facility for clefense-relatecl transuranic waste (U.S. Congress,
1992~. The WIPP facility is described in Section 1.4.
The EPA, NMED, and USNRC are the threes agencies that regulate WIPP and
its related activities. The implementation of regulatory requirements, including those on
characterization, is described in permits9 granted by the regulators: the EPA Certificate
of Compliance for WIPP with 40 CFR 194; the NMED Hazardous Waste Facility Permit
(HWFP); and the USNRC Certificates of Compliance for containers used to ship TRU
DOE is also a self-regulator for WIPP through internal orders and guidance manuals, as
explained in Chapter 3.
91n this report, the word "permit" is used in the general sense, addressing both the
licensing of radioactive material, transportation containers, or the permitting of hazardous waste
facilities.
OCR for page 13
Introduction
13
waste to WIPP (see Chapter 3 and the GIossary). WIPP has to maintain compliance with
the EPA, NMED, and USNRC permits at all times to continue operations. Waste
characterization activities are designed to meet requirements in these permits.
1.4 The Waste Isolation Pilot Plant
The Waste Isolation Pilot Plant, located near CarIsbad, New Mexico, is the
nation's defense-related transuranic waste repository, as designated by Congress in the
Land Withdrawal Act of 1992 (U.S. Congress, 1992~. Legal criteria for WIPP related to
TRU waste disposal are discussed in Chapter 3 and Appendix C. The WIPP Land
Withdrawal Act transferred control of the WIPP federal land from the Department of the
Interior to the Department of Energy. This Act allows the disposal of 175,564 cubic
meters of transuranic waste in WIPP, of which 7,080 cubic meters can be RH-TRU
waste. The amount of radioactivity in RH-TRU waste is limited to 5. ~ million curies.
The WIPP has been under study since the mid-1970s and under construction
since January 1981. The facility received the first CH-TRU waste shipment in March
~ 999 and the first mixed CH-TRU waste shipment in September 2000 To date
(December 2003), more than 46,000 drum-equivalents40 of waste have been emplaced
underground and over 2,000 shipments of CH-TRU waste have been sent to WIPP. The
five sites that are currently shipping waste to WIPP are the following: Rocky Fiats
Environmental Technology Site, Idaho National Engineering and Environmental
Laboratory, Los Alamos National Laboratory, Savannah River Site, and Hanford Site.
Throughout the country there are approximately 27 TRU waste generator sites; most of
them are considered "smalI-quantity" waste generator sites (see Section 2.2 for a
complete inventory).
The WIPP disposal area is located about 660 meters below ground in a salt bed,
called the Salado Formation (see Figure 1.2~. Bedded salt formations have many
attributes that make them suitable hosts for a geologic repository. First, large salt
formations are found mainly in stable geologic areas with little seismic activity. Second,
large salt beds such as the Salado Formation are found only in regions that do not have
significant groundwater movement. This deep, relatively dry, underground environment
reduces the possibility of waste releases from the repository by natural processes. Third,
under the lithostatic pressure at the repository depth, the salt slowly "creeps" to fill voids,
thereby encapsulating and immobilizing the waste deep beneath the surface. Analyses
indicate that that the mined salt will flow and encapsulate the waste approximately 200
years after closure of the WIPP facility (Knowles and Economy, 2000~. A further
advantage of salt formations is that they are easily mined without the use of explosives.
The underground waste disposal area in WIPP will consist of eight "panels," each
containing seven rooms. After four years of operation, the first pane! has been filled with
CH-TRU waste and close. Emplacement of CH-TRU waste in the second pane!
began in December 2002. Mining of the third pane! began in May 2003. Contact-handIed
transuranic waste drums and boxes are being stacked in three layers in each room
(Figure 1.3~. Magnesium oxide is emplaced on top of the waste containers as backfill
and to produce an above-neutral pH environment, thereby reducing the solubility of the
actinides. In 2001, DOE requested permission from EPA to discontinue the use of small
bags of magnesium oxide ("mini-sacks") to reduce workers exposure to waste. Large
4°The term "drum-equivalent" refers to any waste container, such as standard waste
boxes or 1 O-drum overpacks, whose volume is normalized to 55-gallon drums (7.5 cubic feet), the
most common waste container.
Three of the rooms in Panel 1 were left vacant because of roof instability.
OCR for page 14
14 Improving the Characterization Program for Contact-Handled Transuranic Waste
FIGURE 1.2 Schematic representation of the completed Waste Isolation Pilot Plant
Facility. The facility will have eight disposal panels, each divided into seven rooms. Only
two and part of a third pane! have been mined to date (2003~. SOURCE: DOE.
bags of magnesium oxide ("super-sacks") continue to be emplaced on top of waste
stacks. Figure 1.3 shows both mini-sacks and super-sacks.
1.5 Life Cycle of Transuranic Waste
The life cycle of TRU waste, from its generation to its designated final disposal at
WIPP, generally42 consists of the following:
waste generation or recovery from its current storage location;
.
processing and packaging, if necessary;
characterization and certification;
loading into shipping containers;
road transportation to WIPP;
· receipt, unloading, handling, surface interim storage; and
underground emplacement at WIPP.
The following is a brief description of these steps. As previously mentioned,
transuranic waste is already in storage at generator sites or wit! be generated during
ongoing operations or during deactivation and decommissioning activities at DOE sites.
TRU waste is currently being storecl in metal drums, concrete moclules, and metal and
wooden boxes. Safe recovery of stored waste can be complex and difficult if containers
are difficult to access, if their integrity has been compromised, or if storage records are
not available or are deficient.
42The life cycle of TRU waste may vary slightly from site to site, depending on the types
of waste streams and agreements between DOE and generator sites.
OCR for page 15
Introduction
15
FIGURE 1.3 Contact-handIed transuranic waste emplaced in Pane! 1. Two types of
waste containers are visible: standard waste boxes and 55-gallon drums. Magnesium
oxide was placed on top of the waste in large cylindrical containers and on the sides in
"mini-sacks" as backfill to ensure an above-neutral pH of the environment and thus
reduce the Volubility of actinides. Mini-sacks of magnesium oxide are no longer used in
the Waste Isolation Pilot Plant. SOURCE: DOE.
Waste processing activities may consist of chemical processing or consolidation
of wastes (by compaction or by conversion to a form suitable for disposal at WIPP). For
instance, wet sludge must be dried because liquids are prohibited (if more than ~
percent of free liquid by waste volume) in WIPP. In any event, if the waste is not
containerized, it must be packaged in accordance with the USNRC Certificate of
Compliance as described in the TRUPACT-~! Authorized Methods for Payload Control
(see Appenclix D).
To obtain authorization to ship TRU waste to WIPP, generator sites must first
characterize and certify their waste streams43 that is, identify them as TRU, determine
their physical forms, quantify their chemical constituents, ensure the absence of
prohibited items, and provide a certification record. Waste characterization is used to
ensure the safe transportation of waste from generator sites to WIPP, to ensure its safe
clisposal, and to provide a certified record of clisposal activities. From a regulatory
perspective, all waste sent to WIPP must comply with the WIPP Waste Acceptance
Criteria, HWFP, and transportation requirements (see Chapter 3~. The waste
characterization program for CH-TRU waste is describecl in Chapter 4. Repackaging of
waste may be required in the following instances: 1) the original waste container does
not meet transportation requirements, or 2) the waste needs processing to remove
prohibited material (see Appendix C).
Waste from small-quantity generator sites can be characterized at other sites
having more complete and acceptable characterization capabilities. This is the case, for
example, of TRU waste from the Mound Laboratory in Ohio, which is being sent to the
Savannah River Site in South Carolina for characterization and certification prior to
43A waste stream is defined as waste material generated from a single process or activity
or as waste in containers having similar physical, chemical, or radiological characteristics (see the Glossary).
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,
Improving the Characterization Program for Contact-Handled Transuranic Waste
shipment to WIPP (see Appendix E). Waste shipped to other DOE sites for interim
storage and characterization need not undergo the characterization for disposal required
for waste that is shipped directly to WIPP (see Table D.~. Intersite shipments made
prior to shipment to WIPP must, however, comply with transportation requirements and
with the receiving site's waste acceptance criteria. These interim characterization sites
must ensure proper characterization and certification of all waste shipped to WIPP from
their site, including that received from other sites.
Once certified by EPA and NMED, packaged TRU waste is loaded onto USNRC-
approved transportation packages, the most common being the TRUPACT-~l, and
transported to WIPP by road following routes established in accordance with corridor
states. The final steps when waste arrives at WIPP consist of checking the shipment for
contamination, and if none is found, unloading the waste, storing it temporarily at the
surface, and finally emplacing it underground for permanent disposal.44
, - - - ~
1.6 Challenges of Transuranic Waste Characterization
Transuranic waste characterization presents several challenges for DOE's
National TRU Waste Management Program, such as the following:
· High characterization costs arid variabi/itv in estimates.
, On average,
characterizing TRU waste to date costs $3,900 per drum (see Section 4.5~.
There is great variability in cost estimates from site to site due to differences in
waste type and volume, different characterization procedures and different
methods of reporting costs. Because of such variability, analyzing and comparing
characterization costs are complex tasks.
Mu/tip/e generator sites. There are 27 TRU waste generator sites across the
country. Waste characterization procedures vary (although only slightly) from site
to site even though they all comply with the same WIPP Waste Acceptance
Criteria and requirements in the WIPP HWFP.
Wide variety of waste streams. DOE identified 569 transuranic waste streams in
the Baseline Inventory Report. These vary from heterogeneous debris from
deactivation and decommissioning to homogeneous sludges from waste
processing. These definitions are, of course, somewhat arbitrary, and the number
of waste streams may vary according to the definitions employed.
Wide variation in knowledge of waste nature. Waste streams have been
produced at different times, at different sites, and using clifferent processes;
furthermore, new streams will be generated in the future. There is a wide range
of knowledge concerning the nature of the waste to be characterized. Procedures
in place at the site where waste was generated also determine the extent of
waste knowledge: records of waste generated in a production facility where
operating procedures are codified are generally more detailed than those of
waste generated in a research facility. This difference in knowledge of the nature
of the waste (also callecl "Acceptable Knowledge,"45 see Chapter 4) has an
impact on the extent of characterization activities before waste is shipped to
WIPP.
44A detailed description of the waste disposal process can be found on DOE's WIPP
Internet site: .
45Acceptable Knowledge is a term used by EPA that encompasses historical process
knowledge and information from previous testing, sampling, and analyses of waste. See Section
4.4 and the Glossary.
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Introduction
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Programmatic uncertainties. The amount and characteristics of future waste
streams may be considerably different from current estimates depending on
changes in ongoing programs and in cleanup strategy within DOE. Technological
advances will create opportunities to improve waste characterization but their
time and impact on the program are difficult to assess.
There are also characterization challenges associated with specific TRU waste streams,
as discussed in Section 2.3, as well as regulatory challenges, discussed in Section 3.4.
,
,, .
Representative terms from entire chapter:
characterization activities
