Improving the Characterization Program for Contact-Handled Transuranic Waste Bound for the Waste Isolation Pilot Plant (2004) / Chapter Skim
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3 Regulatory and Policy Framework for Waste Characterization
3 Regulatory and Policy Framework for Waste Characterization
Pages 27-38
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From page 27... ...
These cooperative agreements mandate regular meetings in which radiological health, emergency management, and transportation officials receive information on TRU waste program activities and discuss planning and implementation concerns with DOE representatives. Although it is not a regulator, the New Mexico Environmental Evaluation Group has had an oversight role since 1978 to help ensure the protection of public health and safely and the environment.
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From page 28... ...
, 40 CFR 191, 40 CFR 194, and 40 CFR 264.3 The CH-TRU waste characterization program consists of characterization activities to address requirements in the above laws and regulations. The characterization activities appear in the following WIPP authorization basis documents: t EPA Certificate of Compliance for WIPP, NMED Hazardous Waste Facility Permit (HWFP)
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3.2.5 Waste Acceptance Criteria The Waste Acceptance Criteria is a document written by DOE to consolidate all of the existing acceptance criteria and ensure uniformity in TRU waste documentation, transportation, handling, and disposal activities at WIPP. The Waste Acceptance Criteria set limits and criteria on the physical aspects, racliological aspects, quantity, and chemical composition of TRU waste.
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30 Improving the Characterization Program for Contact-Handled Transuranic Waste have been revised several times since 1980 to reflect programmatic changes approved by NMED, EPA, and USNRC. All revisions to the Waste Acceptance Criteria require review of possible environmental impacts.
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. According to DOE, these regulatory changes have been beneficial to the National TRU Waste Management Program (Kehrman, 2002~.
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and beginning of operation (1999) , EPA has gathered extensive experience implementing the requirements and has conducted many independent technical reviews and inspections of WIPP and DOE's TRU waste facilities around the United States to verify compliance with WIPP disposal regulations.
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3.3.2 Programmatic changes relevant to NMED The New Mexico Hazardous Waste Act authorizes the N M ED to establ ish procedures to modify a permit. EPA has identified three classes of permit modifications of hazardous waste (RCRA)
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From page 34... ...
; allow statistical headspace gas sampling and analysis for thermally treated waste (Rocky Flats Environmental Technology Site reports saving more than $30 million in headspace gas characterization cost for 17,300 drums of residues in pipe overpacks) ; determine the mix-certification rate by performing visual examination as a quality control check on radiography on a summary category group rather than individual waste streams (Rocky Flats Environmental Technology Site reports saving more than $19 million by not having to determine and implement a mix-certification rate for every waste stream)
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From page 35... ...
Waste is categorized into waste streams based on how it is produced, its waste categories, and waste matrix cocles, depending on the agencies. In the EPA Certificate of Compliance certification application, DOE identified 569 waste streams based on historical knowledge, while EPA sorted WIPP waste inventor by volume in 10 waste categones, and NMED identified ~ ~ Waste Matrix Code Groups (see definition of waste stream in the GIossary)
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From page 36... ...
DOE must meet sites' cleanup milestones set forth by DOE's compliance agreements with EPA and generator states' regulators, such as Federal Facility Compliance Agreements and Tri-Party Agreements. For instance, DOE has made a commitment to the State of Colorado to close the Rocky Flats Environmental Technology Site by December
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37 15, 2006. The Idaho Settlement Agreement with DOE stipulated that the Idaho National Engineering and Environmental Laboratory must ship at least 3,100 cubic meters of TRU waste out of the State of Idaho by December 31, 2002 (this was called the "31 00 Projects.
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From page 38... ...
This has been the case with NMED's Hazardous Waste Facility Permit and with the EPA and USNRC Certificates of Compliance. 3.5 Discussion: Experience with the Permit Moctification Process DOE has successfully submitted modification requests for its HWFP, EPA, and USNRC permits to streamline characterization activities and make the process more cost- and time-effective.
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