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5 A Framework for Evaluating Waste Characterization Activities
Pages 58-73

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From page 58...
... The purpose of the proposed analytical framework is to determine the value of the characterization information obtained through a given characterization activity. If the information is used to make decisions about waste handling, transportation, or disposal, then it has an impact on the outcome of these decisions (for instance, on reducing risks, uncertainties, costs, or delays)
From page 59...
... Similarly, this analysis can support proposed changes to the characterization program by showing that alternative characterization activities are more cost-effective than the current ones. The analytical framework proposed here denves from a decision-analysis For example, characterization information is used in preparation and archiving of a record of characterization activities and may have value in that context.
From page 60...
... ~: ~ Decision J L Improving the Characterization Program for Contact-Handled Transuranic Waste Current Characterization Activity/Program . Information Generated by - \ / Experience andAnalysis Characterization A ~ Based Learning Revised Characterization Activity/Program FIGURE 5.1 Features of the proposed analytical framework.
From page 61...
... Many of these studies are now being updated to reflect recent data and experiences and are periodically reevaluated. Although DOE has performed analyses of many aspects of operations related to WiPP performance, including transportation, the committee could find no studies that explicitly, systematically, and quantitatively link its waste characterization program to risks to the public, workers, or the environment (see Finding and Recommendation ~ )
From page 62...
... Hard costs are the costs associated with gathering characterization information. Table 4.1 shows that the most expensive characterization activities involve breaching waste containers and waste analyses.
From page 63...
... Scenarios in which characterization needs and costs may increase are the following: radiographic techniques and other special characterization techniques and technologies for large containers may have to be developed and may cost more than the observed costs to date; remote-handIed transuranic waste with dose rates greater than 1,000 rem per hour may be authorized in WIPP possibly requiring additional worker protection measures; previously buried TRU wastes may include more compromised containers requiring more elaborate handling procedures; future waste streams may require new or different characterization information; additional TRU waste not accounted for in current inventories may be approved for disposal in WIPP increasing total characterization, transportation, and disposal costs; or characterization requirements may be added or strengthened for public confidence purposes, in particular if an accident occurs.
From page 64...
... Regulatory compliance is grounded in risk considerations. Regulatory requirements are derived from assessments of the risks to the public, workers, or the environment and the need for records documenting waste characteristics, waste characterization activities, and oversight of related operations.
From page 65...
... 5.7 Cost-Effectiveness Analysis To determine whether a characterization activity has value, information on the risks, costs, and other impacts with and without the characterization activity is needed. For example, to determine the value of headspace gas sampling and analysis and how it reduces risks, data on the flammability and risks of worker exposure to high VOC concentrations if headspace gas sampling did not occur are necessary.
From page 66...
... be converted into a single number specifying equivalent cost or utility. Given its complexity, a complete analysis of the benefits and costs of each waste characterization activity is beyond the commidee's capability in this study.
From page 67...
... before shipment to WIPP to ensure that their concentration in WIPP waste disposal panels is within the limits allowed in the HWFP. The alternative characterization activity considered by the committee is room monitoring in WIPP for VOCs coupled with flammability tests at generator sites for compliance with transportation regulations.
From page 68...
... The objective of headspace gas sampling and analysis is to prevent shipment of flammable or explosive gases, exposure of WIPP workers to VOC concentrations above applicable limits, and VOCs release in the atmosphere. Room sampling would measure directly VOC concentrations in WIPP.8 Flammability limits could be tested at generator sites using alternative characterization methods to track hydrogen and methane (for example using gas chromatography with a flame ionization detector)
From page 69...
... NMED has provided comments to the committee on the DOE's analyses supporting the request for relief from this characterization activity. According to NMED, DOE did not go far enough in the analysis of the relationship between VOC data of waste emplaced thus far and those of future waste streams (NMED, 2003c; cover leHer)
From page 70...
... To decide whether a permit modification would improve the program a more complete analysis is needed in which the advantages of using the alternative characterization activity are considered along with the cost, time, and effort to prepare a permit modification request to NMED (and possibly a USNRC Certificate of Compliance modification) , as well as with the risks of decreasing the confidence of the public in New Mexico and that of corridor states in the safely of WIPP operations.
From page 71...
... . A societal impact of a change to this characterization activity has a potential to decrease of public confidence in DOE particularly if an accident occurs during handling, transportation, or disposal of uncharacterized homogeneous waste.
From page 72...
... Information is also needed on worker exposure during this activity to compare benefits and risks of performing this characterization activity. Details on the efforts and costs to perform statistical visual examination to confirm real-time radiography results for existing (or retrievably stored, in DOE's terminology)
From page 73...
... marginal benefits of checking relatively accurate radiography results on a small percentage of containers, it appears that visual examination to confirm radiography results on existing waste has tow value. Concerning this characterization activity, the New Mexico Environmental Evaluation Group writes (EEG, 2003b; page 59~: The [visual examination]


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