Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant Final Report (2002) / Chapter Skim
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5 Assessment of the Proposed Characterization Plan
5 Assessment of the Proposed Characterization Plan
Pages 47-61
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. 5.1 Context of Remote-Handled Transuranic Waste Characterization Below are some general findings about the DOE's RH-TRU waste inventories.
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The committee recognizes that there may be uncertainties associated with the results of these impact analyses and that there may be scenarios that require a new set of performance assessment calculations.2 In response to the committee's question on uncertainties, Sandia National Laboratories reported that: "Uncertainties in Performance Assessment are dominated by those associated with geologic processes, chemical interactions of the waste, and possible human activities in the future. For example, the intrinsic permeability of the proximal host rock can vary over seven orders of magnitude; uncertainties with respect to microbial degradation of organic materials affect several key intermediate variables, such as long-term repository pressure and saturation; assumptions regarding human activities introduce the most notable impacts on repository performance.
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The committee interprets "performance-based characterization plan" as a plan ensuring repository integrity, protection of the environment, and health and safely of the public and workers while keeping in consideration tradeoffs between greater characterization accuracy and worker risks (see Chapter 4~. This section addresses the characterization activities that DOE proposes to implement the data quality objectives listed in Tables 4.1 and 4.2.
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In spite of these impact analyses, Documents ~ and 2 still propose characterization activities to determine the above parameters in RH-TRU waste. The committee provides below examples of characterization activities that do not appear to have a technical basis in the context of RH-TRU waste characterization.
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Given the results of the Sandia impact analyses, the committee questions the technical basis of this characterization activity. Example #2: One of the data quality objectives listed in Document ~ is the determination of TRU activity (expressed as plutonium-239 content)
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The results of the analysis could support and strengthen DOE's RH-TRU waste characterization activities with respect to prohibited items. DOE's proposed characterization plan was significantly modified between July 2001 and March 2002 concerning the determination of prohibited items in RH-TRU waste.
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Finding 2C: DOE's proposed characterization plan does not adequately address the issue of tolerable decision error rates associated with all characterization information. Recommendation: DOE's proposed characterization plan should address tolerable decision error rates associates!
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It is premature for DOE to develop quality assurance objectives until it has proposed tolerable decision error rates that limit risks related to the waste, and that recognize potential tradeoffs in costs and worker risks. Without setting tolerable decision error rates to create a bridge between the data quality objectives and the characterization methods, it will be impossible to determine whether the waste characterization plan requires too much or too little in terms of the quality of the data needed.
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Contact-handied TRU waste generators use radiography or visual examination, headspace gas sampling and analysis, and/or solids sampling and analysis to confirm AK information accuracy. Results showed a high accuracy of historical AK: above 95 percent for the determination of waste matrix codes at the major CH-TRU waste generator sites and above 93 percent for the determination of hazardous waste codes.
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. Under the committee's request for additional information, DOE provided a publication on X-ray radiography applied to RH-TRU waste characterization (Roney and White, 2001~.
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It follows that each site will produce a different implementation plan for waste characterization and worker radiation protection programs based on ALARA will also be different. However, a risk perspective of worker doses and costs could be illuminating in developing characterization requirements and in adding credibility to the plan.
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In Section 5.2, the committee also recommended that DOE's characterization plan should not set forth overly stringent tolerable decision error rates that could negatively impact the sites' ability to implement ALARA (see Finding 2C)
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Moreover, the only TRU waste characterization plan approved by EPA and NMED is that currently used for CH-TRU waste. With this characterization plan DOE proposes to meet EPA and NMED requirements following a different approach than that used for CH-TRU waste.
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Rather, the characterization program should ensure repository integrity, protection of the environment and of the health and safely of the public and workers, while keeping in consideration tradeoffs between greater characterization accuracy and worker risks. Finding 4B: The submittal documents include, as basis for characterization objectives, waste acceptance criteria and other requirements than those applicable to the EPA Certification and RCRA Permit.
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Also, DOE's proposed characterization plan does not adequately address the issue of tolerable decision error rates associated with all characterization information. In some instances, the plan lacks specificity because most of the operational details are site-specific and were not available at the time of writing.
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