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4 Transuranic Waste Characterization Program
Pages 39-57

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From page 39...
... 4.1 Overview of the Current Waste Characterization Program The committee describes the CH-TRU waste characterization program as a suite of characterization activities that are performed at generator sites before shipping waste to WIPP (see Figure 4.~. These activities address requirements set forth by Congress (through the Land Withdrawal Act)
From page 40...
... Shipment , AK 1 RTR NDA 1 DAC/HSG 1 ; Gas Generation Testing L StatisticalCoring I , 1 | Analyses , Statistical VE | Do Ita l Management | Audit l ~ v Shipment - 1 , ~ , AK | Segregation/ | I Rework l ~3 NDA 1 | DAC;HSG l ~ , Gas Generation Testing Data Management Audit l __ Shipment FIGURE 4.1 Summary of typical characterization activities in the current contacthandled transuranic waste characterization program. Characterization activities may vary among generator sites.
From page 41...
... Headspace gas sampling and analysis is used to: identify and quantify volatile organic compounds (VOCs4) , confirm AK for hazardous waste identification, and identify and quantify flammable gases (hydrogen and methane)
From page 42...
... All waste is verified by ~ 00 percent headspace gas sampling, except homogeneous solids without VOC-related hazardous waste codes, or thermally treated wastes (see Section 4.2~. A small portion of the containers (approximately 1.8 percent)
From page 43...
... on all TRU waste characterization and certification activities. The quality assurance process that is now described in the HWFP requires, among other activities, the review, validation, and verification of all analytical data; reconciliation of analytical results with data quality objectives (DQOs)
From page 44...
... According to DOE, it takes about two months for a waste container to go through the entire data management process (Powell, 2003~.4 4.~10 Audits Audits are the operations conducted by DOE's auditing branch at generator sites to ensure that waste characterization sites conduct waste characterization activities in accordance with the HWFP Waste Analysis Plan, and that the information supplied by each site is managed properly. EPA, NMED, and the New Mexico Environmental Evaluation Group participate in these audits as observers and confirm that characterization requirements are addressed.
From page 45...
... For example, the characterization activities at the future Advanced Mixed Waste Treatment Facility in Idaho and at the Savannah River Site are somewhat different. The Advanced Mixed Waste Treatment Facility has the capability to "supercompact" waste for volume reduction and more efficient operations.5 Therefore, real-time radiography and/or visual examination are performed prior to compaction ancl/or final waste packaging.
From page 46...
... AK also includes information regarding the raw materials used in a process or operation, process description, products, and associated wastes. AK documentation includes the site history and mission, site-specific processes or operations, administrative building controls, and all previous and current activities that generate a specific waste (DOE-SAR, 2003~.6 According to the EPA's definition, AK may consist of a variety of information, such as the following (EPA, ~994~: detailed waste analyses at the time of generation, if performed in accordance with an acceptable quality assurance program; studies of the waste generating process—in addition to information about the process flowsheet and its goals, these may include data from the generator's process, or from similar generation processes undertaken elsewhere, and from experiments involving surrogate waste processes or products; waste characterization data obtained from facilities that send wastes off-site for treatment, storage, or disposal; 6EPA is currently in the final stages of a rulemaking to change 40 CFR 194.8 to streamle its certification process of confirmation at generator sites.
From page 47...
... As acknowledged in joint USNRC/EPA guidance, mixed wastes constitute one of those circumstances because of the potential for personnel exposure inherent in radioactive waste characterization (USNRC/EPA, 1997~. Although written for commercial mixed waste generators, the guidance states that it could apply to transuranic waste.
From page 48...
... 4.4.3 Accuracy of historical information A key question is how to verify the accuracy of historical information about waste. The accuracy of AK is, according to the Waste Acceptance Criteria, to be verified on a waste stream basis, although AK is also used to define waste streams.
From page 49...
... ~ shows characterization activities, the percentage of containers to undergo these activities, and average cost estimates per container in the current CH4°NMED observed that AK accuracy results are based primarily on waste from Rocky Flats Environmental Technology Site, part of which was sent to Idaho (NMED, 2003c)
From page 50...
... This estimate is based on an assessment at those generator sites that are currently characterizing and shipping waste to WIPP. There is uncertainty and a great variability in costs of characterization activities among sites depending on the nature of waste streams and the volume (DOE-CABE, 2003~.
From page 51...
... (U.S. Dears Non-Destructive Assay ~ 00 840 840 Headspace Gas Analysis ~ 00 620 620 Real-Time Radiography 32.8 730 240 Visual Examination/Retrievably Stored 1.2 22,500 270 -' .' Visual Examination/Newly Generated 67.2 540 360 Solids Coring and Sampling 0.5 24,000 120 Solids Analysis 0.5 63,000 310 Acceptable Knowledge 100 87 87 Drum Venting 1.8 120 2 Level I!
From page 52...
... . Analysis of the characterization data acquired to date along with continuing the characterization of increasingly diverse waste streams could identify new opportunities to use statistical sampling (rather than 100 percent of the waste stream)
From page 53...
... For example, DOE has obtained an exemption from headspace gas sampling and analysis for thermally treated wastes at the Rocky Flats Environmental Technology Site. To obtain regulatory relief from NMED, DOE provided a technically defensible case that showed how this particular waste stream could not contain any volatile organic compound.
From page 54...
... DOE adempled to demonstrate that non-destructive assay measurements coffected for safeguard reasons on a particular waste stream at the Rocky Flats Environmental Technology Site could be used as corroborating evidence or as a qualified quality assurance program in lieu of WIPP-certified nondestructive assay data. About 4,000 drums had already been measured individually with a nondestructive assay system, which collects information on plutonium, americium, and uranium-235 for safeguard purposes.
From page 55...
... Internal drivers for DOE's cleanup program may lead to a reduction in characterization activities necessary for protecting public and worker health in order to save money (Petrie, 2003~. Less stringent characterization activities could increase potential radiation doses received by the public (Reade, 2003~.
From page 56...
... Streamline TRU waste management by accepting demonstrated process knowledge for TRU waste characterization. Evaluate the concept of one or more locations to characterize TRU waste for WIPP disposal.
From page 57...
... A structured and quantitative analysis of the linkages between risks, benefits, and impacts of characterization activities along with analyses of past and future waste inventory characteristics is needed to arrive at a flexible waste characterization plan program that can take into account the variability of sites and waste streams, allowing for more efficient and effective waste characterization operations as well as communication among all parties (see Findings and Recommendations)


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