Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant Final Report (2002) / Chapter Skim
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Executive Summary
Executive Summary
Pages 1-7
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' waste and to provide recommendations, as necessary, for improving the plan's technical soundness, protection of worker safely and health, and compliance with regulatory requirements. There are approximately 3,800 cubic meters of defense-related RH-TRU waste to be removed from DOE's weapons complex.
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A DOE review of the CH-TRU waste characterization procedures revealed that DOE developed self-imposed waste restrictions in the waste acceptance criteria and in the implementation documents used by generator sites to characterize CH-TRU waste. A previous National Research Council committee found that these self-imposed procedures lack technical, safety, or legal basis (see Sidebar 3.
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This is due to the characteristics of DOE's RH-TRU waste inventories in terms of volume and radiological composition. To address the EPA and NMED regulatory requirements, DOE proposes to use the following characterization methods: dose-to-curie conversion, visual examination, radiography, direct assay, counting containers, AK, and characterization at the time of packaging.
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The committee acknowledges that nontechnical considerations may be important for maintaining effective working relationships among DOE, EPA, and NMED; however, DOE should propose only characterization activities that have a technical, health and safety, or regulatory basis. The committee provides the following examples of activities lacking a technical basis in the context of RH-TRU waste characterization: determination of radiological activity, free water/liquid, ferrous metal, cellutosics, plastic, rubber, and polychIorinated biphenyIs
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DOE's proposed characterization plan should address tolerable decision error rates associated with characterization information. These errors should not be overly stringent so as to negatively impact the sites' ability to implement ALARA.5 For the 5 percent of the RH-TRU waste inventory that does not require packaging or repackaging, it is not clear how visual examination and radiography can confirm AK information for prohibited items (Finding 2D)
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While the regulatory requirements for CH- and RH-TRU waste characterization are the same, the approach to address these requirements can be different. The committee evaluated, from a technical point of view, the approach DOE is proposing to characterize RH-TRU waste and how it addresses regulatory requirements.
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However, Documents and 2 do not present a performance-based plan as effectively as they could. Concerning the plan's protection of worker health and safety, the committee recommends that the approved characterization plan not include overly stringent tolerable decision error rates that could negatively impact the sites' ability to manage worker risks.
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