Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant Final Report (2002) / Chapter Skim
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4 Department of Energy's Proposed Characterization Plan
4 Department of Energy's Proposed Characterization Plan
Pages 34-46
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From page 34... ...
Each site-specific RH-TRU waste characterization plan will undergo audits by DOE, EPA, and NMED before the beginning of shipments to WIPP. The new characterization requirements will be combined in a revised version of the waste acceptance criteria incorporating changes to allow RH-TRU waste in WIPP.
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Characterization Plan Given the above considerations, DOE's stated goal is to adopt a "performancebased" approach to characterize RH-TRU waste. Although Documents ~ and 2 do not provide a definition of a "performance-based characterization plan," the committee found the following definition in EPA's Compliance Application Review Document No.
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The committee interprets "performance-based characterization plan" as a plan requiring only that information needed to ensure repository integrity, protection of the environment, and health and safety of the public and workers while keeping in consideration tradeoffs between greater characterization accuracy and worker risks. While the characterization requirements to be addressed are the same, this proposed performance-based approach is quite different from the approach used for CHTRU waste characterization, as explained later in this chapter.
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DOE proposes not to confirm the newly generated information for 95 percent of the waste since this information will be collected under a certified quality assurance characterization program. The specific needs for waste analysis are described in DOE's proposed characterization plan as data quality objectives and quality assurance objectives.
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4.4 DOE's Proposed Characterization Plan to Address EPA Requirements The characterization requirements in the EPA Certification, addressing also the requirements in the Land Withdrawal Act, are described in Chapter 3. The data quality objectives, characterization, and implementation methods to address these requirements are provided in Document ~ and summarized in Table 4.~.
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4.5 DOE's Proposed Characterization Plan to Address NEED Requirements The characterization requirements in the current RCRA Permit are described in Chapter 3. The proposed data quality objectives and characterization methods to address these characterization requirements are presented in Document 2 and summarized in Table 4.2.
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40 in a)
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DOE's Proposed Characterization Plan 41 ~ U)
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DOE's Proposed Characterization Plan 43 _ .tn ' a.)
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The determination of the absence of all the prohibited items listed in the RCRA Permit was part of the requirements in the July 2001 draft of Document 2 (DOE-CBFO, 2001 b; Item 2; pages 2-27~. In the March 2002 draft, the only prohibited items explicitly listed as data quality objectives are residual liquids (if more than ~ percent by volume of waste)
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From page 45... ...
Concerning the WIPP's limit on volatile organic compound emissions, the characterization plan for CH-TRU waste requires tracking individual waste container headspace gas concentrations, which are determined by headspace gas sampling and analysis of CH-TRU waste containers. There is no characterization objective for a direct measurement of the headspace gases in the proposed RH-TRU waste characterization plan because canisters will be located in the walls of the disposal rooms behind shield plugs.
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46 Characterization of Remote-Handled TRU Waste for the WIPP that it is possible to account for volatile organic compounds emission rates from RH-TRU waste indirectly.4 This is accomplished by conservatively incorporating the maximum potential volatile organic compounds contribution from RH-TRU waste in the maximum allowable volatile organic compounds emission limits established by the RCRA Permit (Spangler et al., 2002~. 4To the best of committee's knowledge, experiments on volatile organic compound emissions from RH-TRU waste have not been conducted.
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