f/EPA      The
                                                            Bulletin
United States
Environmental Protection
Agency
                   A  Message  From  the  Director
                                   This bulletin is our first in nearly a
                                   year, and what a busy year it's been
                                   for EPA's WIPP program!  First, I
                              would like to introduce myself, Betsy
                              Forinash, as the new Director of the Cen-
                              ter for Federal Regulations, which is re-
                              sponsible for the EPA's oversight of WIPP.
                              Some of you may recognize my name
                              from when I worked on WIPP during the
                              development of EPA's Compliance Crite-
                              ria and the initial Certification Decision. I
                              am returning to work  on WIPP after
                              spending a few  years working on some
                              of EPA's other radioactive waste manage-
                              ment projects. I am excited to work on
                              such a  dynamic  and interesting  project
                              and I look forward to  keeping you in-
                              formed about the important issues of re-
                              certification and  continued compliance
                              with EPA's regulations.
                                 I'm pleased to report that last spring
                              we received a final report from Phoenix
                              Environmental and  Envirolssues, who
                              completed  an independent assessment
                              of our extensive outreach efforts  leading
                              up to the final WIPP Certification Deci-
                              sion. Their work was based in large part
                              on interviews with WIPP stakeholders. I
                              would like to thank those of you who
                              gave interviews  or otherwise  partici-
                              pated in this effort.  Your  contributions
                              are very much appreciated.
                                 We are looking closely at the report's
                              recommendations as we consider our fu-
                              ture outreach activities.  In fact, this Bul-
                              letin reflects feedback that we received
                              in the outreach evaluation. We learned
                              that the WIPP Bulletin is a well-regarded
                              source of information.  We have added
                              some new features  that we hope will
                              make the Bulletin even more informa-
                              tive:   News Notes,  which provides
                              short updates on EPA's and DOE's recent
                                                                        activities; and  a  Focus  On  section,
                                                                        which will explain a different technical
                                                                        aspect of the project in each issue. We
                                                                        welcome your  comments on the bul-
                                                                        letin; please send them to our Webmas-
                                                                        ter at webmaster.oria@epa.gov  or leave
                                                                        us a message on the information line at

                                                                        back.
                                                                           This issue's  Focus On  section ad-
                                                                        dresses EPA's actions to suspend waste
                                                                        shipments from the Idaho National En-
                                                                        gineering and  Environmental  Labora-
                                                                        tory (INEEL) in June 2001.   In this
                                                                        section you  will  find a summary of
                                                                        events  at INEEL and a description of
                                                                        EPA's actions.
                                                                           As  those  of you who  watch the
                                                                        WIPP project know, DOE has been ac-
                                                                        tively investigating changes to the WIPP
                                                                        program. EPA  is tracking these poten-
                                                                        tial changes and many other issues. In
                                                                        News Notes we  tell you about meet-
                                                                        ings, changes we have approved, and
                                                                        many other  items.   Our  Technical
                                                                        Corner series continues with more ex-
                                                                        planation of the purpose and design of
                                                                        the WIPP performance assessment.
                                                                          Inside this Issue
                                                                          A Message From the Director        1
                                                                          News Notes                    2
                                                                          Waste Shipments                3
                                                                          Regulatory Dockets Locations        3
                                                                          Introducing NSC's New Radiation
                                                                           Information Kit                 4
                                                                          Inspections at Idaho Site           5
                                                                          The Design of the WIPP Performance
                                                                           Assessment                  6
                                                                          Contacts and Online Resources       7
                                                                                Printed on recycled paper

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    WIPP News Notes
Stakeholder Meetings

  In February 2001, members of EPA's WIPP staff traveled to
  Albuquerque and Santa Fe to meet with representatives of
WIPP stakeholder organizations to share the preliminary
results of an independent evaluation of the WIPP Public
Outreach Program (see Message from the Director) and
to begin discussing plans regarding EPA's receitification deci-
sion for the WIPP. The recertification decision is expected to
be issued in 2004.
  EPA met with representatives from the Southwest  Re-
search and Information Center, the Environmental Evaluation
Group, Concerned Citizens for Nuclear Safety, Peace Action
New Mexico, Nuclear Watch of New Mexico,  and the New
Mexico Attorney General.
  In  addition to reviewing the public outreach program
evaluation, topics  of  interest to these  stakeholder groups
were  discussed including: making sure the public receives
balanced  information about technical  issues  before  EPA
reaches its recertification decision; meeting more often with
EPA staff during the recertification process; and the accept-
ability of certain program changes being considered by DOE.

Panel  One Utilization

   EPA recently approved a change to DOE's plans for waste
   emplacement in Panel One. A "panel" is a section of the
WIPP that contains seven  disposal rooms. The design for the
WIPP calls for eight panels, of which only two have been ex-
cavated. DOE is quickly filling Panel One with waste; how-
ever, the rooms  of Panel  One  were mined out many years
  For More Information
  About the WIPP
  More information on EPA's continued activities concerning the
  WIPP can be obtained from  any of EPA's four public dockets
  (Washington DC, and Albuquerque, Carlsbad, and Santa Fe, New
  Mexico). The Docket number for EPA's post-certification activities
  at the WIPP is A-98-49. The pre-certification and certification de-
  cision Docket is A-93-02. For the latest information on EPA activ-
  ities regarding  the WIPP, please  call  EPA's recorded WIPP
  Information Line al             |
    You can also read all about EPA's WIPP Program on the Inter-
  net. EPA's WIPP homepage is an excellent source for current in-
  formation on EPA's WIPP activities. From the Homepage you can
  also download  EPA documents and docket information. EPA's
  WIPP Homepage address is: www.epa.gov/radiation/wipp/
                                                          ago and are already undergoing the natural processes that
                                                          will eventually close the rooms. Several of the rooms in Panel
                                                          One are experiencing significant lowering of the  roof and
                                                          raising of the floors due to salt creep. In an effort to reduce
                                                          the risk of injury to mine workers from a  roof collapsing,
                                                          DOE requested EPA's approval to bypass rooms 4, 5,  and 6
                                                          of Panel One and leave them permanently empty. DOE's re-
                                                          quest also means that no remote-handled TRU waste will be
                                                          placed in Panel One. In July 2001, EPA approved DOE's re-
                                                          quest on the basis that  it would have no significant  effect
                                                          on compliance with our regulations. A record of EPA's de-
                                                          cision  on the  issue can be found in EPA Docket A-98-49,
                                                          Item II-B3-19.

                                                          Experiments at WIPP

                                                            In August  2001, EPA approved the emplacement  of the
                                                            OMNISita astrophysics experiment in the WIPP facility for
                                                          the study of celestial bodies and matter. These astrophysics
                                                          experiments are not related to WIPP waste disposal activities.
                                                          An underground mine such as the WIPP is a good place for
                                                          this type of experiment because the shielding provided by
                                                          hundreds of feet of soil and rock helps prevent interference
                                                          of sensitive measurements by cosmic radiation.
                                                             EPA reviewed the technical information related to this ex-
                                                          periment and determined that, as long as the equipment is
                                                          removed after the experiment is completed,  there should be
                                                          no effect on the long-term containment performance of the
                                                          repository. For more information on this experiment check
                                                          the EPA Docket A-98-49, Item II-B3-20.

                                                          IMAS Report

                                                             The National Academy of Sciences (NAS) recently released
                                                             a report entitled,  "Improving Operations and Long-Term
                                                          Safety of the Waste Isolation Pilot Plant." This report identi-
                                                          fies research activities recommended by NAS to enhance the
                                                          understanding of the WIPP's long-term performance, as well
                                                          as changes to  waste management practices to promote effi-
                                                          ciency, cost- effectiveness, and worker and public safety. To
                                                          learn more about this report, see the National Academy Press
                                                          website at: www.nap.edu.

                                                          Central Characterization  Program

                                                             The Central  Characterization  Program (CCP) is being de-
                                                             veloped by DOE to facilitate characterization of waste by
                                                          small quantity generator sites. DOE intends for the CCP to be
                                                          a  self- contained, transferable waste characterization pro-
                                                          gram that can be moved from site to site, thereby eliminating
2  The
               Bulletin

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the need to develop independent char-
acterization  programs at  small sites.
The  CCP is at an  early stage, and is
being tested at the  Savannah River Site
(SRS) in  South Carolina.  EPA per-
formed  an  inspection of the CCP's ef-
fectiveness  at SRS in October 15, 2001.
Subsequently, EPA  approved the CCP's
characterization  of debris  waste  for
shipment from SRS  to the WIPP for dis-
posal (A-98-49, Item II-A4-19).  EPA will
have to separately  approve the use of
the CCP for other waste streams and at
other DOE  sites.

Remote-Handled
Waste

   EPA observed a "surveillance" of the
   Battelle  Columbus Remote-Handled
Waste  Characterization Program  that
was  conducted by the DOE Carlsbad
Field  Office (CBFO) on August 27-29,
2001. The Battelle Columbus Laborato-
ries (BCL) have  generated  radioactive
waste from atomic energy research and
development activities since 1943. As
part  of  the decommissioning  of BCL,
DOE  is processing the  debris  waste
from the Hot Cell Laboratory in the JN-
1 Building and characterizing its radio-
logical contents. The waste from the
Hot Cell Laboratory belongs to the cat-
egory of TRU waste that poses radio-
logical hazards to workers and must be
handled in a  remote fashion. DOE's
August  surveillance focused on BCL's
ability to demonstrate compliance with
CBFO's  waste acceptance  criteria  and
quality assurance requirements for re-
mote-handled waste (RH-TRU). DOE is
using this type of  surveillance to  de-
velop a  RH-TRU waste characterization
proposal for EPA's review.
   Also, DOE recently submitted draft
plans for RH-TRU  waste characteriza-
tion to two separate peer review pan-
els: one sponsored  by the  National
Academy of Sciences and  one spon-
sored by the Regulatory Science Insti-
tute (RSI). In July and August 2001, EPA
staff presented to each panel on EPA
regulations  that  apply  to  RH-TRU
waste.  The  RSI  panel has issued its
report,  which may  be  obtained by
contacting  CBFO  at  1-800-336-WIPP.
The National Academy of Sciences is-
sued an interim report in December
2001. A final report is  expected in
Summer 2002.

Inspections at WIPP

  In June 2001, EPA performed  three
  inspections to verify that  DOE  is
continuing to operate the WIPP safely:
1) Subpart A inspection,  2)  disposal
system  monitoring  inspection,  and
3) emplacement inspection. The Sub-
part A inspection looks at DOE's ac-
tivities  to  monitor  any  radioactive
releases  during the time when waste
is being  stored. (Subpart A of 40 CFR
Part 191 governs radionuclide releases
to the  environment  as a result of
waste management and storage prior
to  disposal.) The  disposal  system
monitoring  inspection  looks at the
various  programs  DOE  has  estab-
  WIPP Dockets Locations
               Waste Shipments
              The number of shipments from
              transuranic waste sites to the WIPP
              as of mid-January is listed below.
              Each shipment could contain as many
              as 42 drums of radioactive waste.
              Savannah River
              Rocky Flats
              Los Alamos
              Idaho
              Hanford
             lished to monitor key conditions in
             and around the repository.  Finally,
             the emplacement inspection looks at
             the procedures and  methods used to
             place waste  containers in the under-
             ground repository.
               Through  these  inspections,  EPA
             has  determined  that the Subpart A,
             disposal  system monitoring,  and
             emplacement programs are function-
             ing  appropriately.   The reports for
             these and other  inspections may be
             found in our docket (Docket A-98-49,
             Item II-B3-18).
  US EPA Air Docket
  Waterside Mall Room
  M1500
  401 M St. SW
  Washington, DC 20460
  (202)260-7548
  (all dockets)

  Carlsbad Public Library
  101 S. Halagueno
  Carlsbad, NM 88220
  (505) 885-6776
  (all dockets)
Zimmerman Library
Government Publications
University of New Mexico
Albuquerque, NM 87131
(505) 277-5441
(all dockets)

Fogelson Library
College of Santa Fe
1600 St. Michaels Drive
Santa Fe, NM 87505
(505) 473-6576
(Docket A-93-02 only)
New Mexico State Library
1209 Camino Carlos Rey
Santa Fe, NM 87505
(505)476-9717
(Docket A-98-49 only)
                                                                                            The WIPP Bulletin 3

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Introducing a NewRadiation Resource Kit for Teachers
 H
           ow big a risk does radiation pose to our fami-
           lies, our environment and to future  genera-
           tions?  What should individuals and society do
   to ensure  that the  benefits of radiation are  not out-
   weighed by the risks? These questions and others are
   answered  in a new "Understanding  Radiation: A Re-
   source  Kit for Teachers" that is  now available free to
   high school teachers to help educate students about ra-
   diation and risk.
  Ordering Information:

  To order your free Understanding Radiation Kit mail or fax
  the following information:  Name, School, Address, Phone,
  Email and Grade taught to:

  Understanding Radiation Kit
  National Safety Council/Environmental Health Center
  1025 Connecticut Avenue, NW #1200
  Washington, DC 20036

  Fax:(202)293-0032

  You may also e-mail your request to: cohend@nsc.org.
The Understanding Radiation Resource Kit contains:

  Two 10-minute videos:
   > "A Look at Radiation"- an overview of radiation as part of our
   everyday lives and
   >~ "Managing Radiation" - a look at  how federal, state, and
   local agencies manage radiation

  Guidebook, "Understanding Radiation in our World"- a 60-plus
   page book with in-depth discussion of radiation related issues.

  A Companion Guide for high school science teachers with sug-
   gested classroom activities and a lesson plan on radiation re-
   lated  risk (aligned with learning goals  in national science
   education standards).

  Overheads and Handouts - a set of overheads (16) and hand-
   outs (14) for use in conjunction with the risk analysis lesson
   plan.

  Poster, "Nuclear Science Wall Chart" - a poster (11" x 14") -
   summarizing nuclear science issues (produced by the Contem-
   porary Physics Education Project and the Lawrence  Berkeley
   National Laboratory)

This kit was developed through a cooperative agreement between
the National Safety Council's Environmental Health Center and the
U.S. Environmental Protection Agency.
                                  For Further Information on EPA's WIPP Activities
                                      Please Call the WIPP Information Line
                              a
                                             or visit our website at:
                           http://www.epa.gov/radiation/WIPP
4  The
             Bulletin

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Focus  on:  Inspections  at Idaho  Site

      This  summer EPA  suspended  shipments  to the  WIPP  from  DOE's  Idaho  National  Engineering
      and Environmental Laboratory (INEEL) in response to a failure by DOE to comply with the waste char-
      acterization requirements of EPA's WIPP Certification Decision. This article answers some basic questions
about the suspension. EPA's written actions on this issue can be found  in Docket A-98-49, Item II-A4-17.
Why did  EPA suspend
shipments from  IIMEEL?

  We learned in late June 2001  that
DOE had shipped and emplaced waste
in the WIPP from INEEL that had been
characterized using radioassay equip-
ment that EPA had not previously ap-
proved. It  was necessary to suspend
shipments temporarily to prevent addi-
tional noncompliant waste  from being
disposed of in the WIPP while we in-
vestigated the situation.
  Under Condition 3 of our WIPP Cer-
tification  Decision,  processes   and
equipment used for waste characteriza-
tion must be inspected and approved
by EPA before transuranic  waste may
be shipped from a DOE site. INEEL was
using radioassay equipment called the
Waste Assay  Gamma  Spectrometer
(WAGS) to provide information about
(characterize) the radioactive isotopes
in the waste  containers. As of June
2001, EPA had not evaluated the WAGS
radioassay equipment for effectiveness.
  During the first six months of 2001,
INEEL shipped  850   unauthorized
drums characterized using this radioas-
say  equipment. Of these,  725 drums
were actually placed in the WIPP, while
the  rest were stored  above-ground
awaiting disposal.

What actions did EPA
take?

  Our first action was to suspend all
TRU waste shipments to the WIPP from
INEEL until we could determine exactly
what led to the shipment of unautho-
rized  drums.  We instructed DOE's
Carlsbad Field Office  (CBFO) to sus-
pend shipments on June 27.
   Next, we sent an inspection team to
INEEL  on  July 2-3 to  investigate the
causes  of  the noncompliance and to
verify which waste containers were af-
fected.  At this inspection, we also con-
firmed  that DOE had  complied with
our suspension  of shipments. At the
conclusion  of the inspection, we al-
lowed  INEEL to resume shipment of
waste  characterized   by   approved
processes and equipment (drums not
characterized using the WAGs system).
   Last, we held a second inspection at
INEEL on July 25-26 specifically to eval-
uate the WAGS radioassay equipment.
As a result of this inspection, we found
the WAGS equipment to be effective
and authorized DOE to resume ship-
ping and disposing of TRU waste char-
acterized  by  the WAGS  radioassay
equipment. We issued this approval on
August 15. With this approval, EPA also
determined that waste containers al-
ready placed by DOE in the disposal
system may remain there  and waste
containers  held on the surface may be
placed  in the disposal system.

How did shipping  of
unauthorized drums
occur?

   During our first inspection in early
July, we reviewed DOE's  analysis of
the causes of the noncompliance. Ac-
cording to  this analysis, INEEL  inter-
nally approved the WAGS radioassay
equipment for WIPP use but failed to
request CBFO's and EPA's approval of
key procedural changes to the equip-
ment prior to actually shipping waste
that  had been  analyzed  using  the
WAGS equipment. (Under current reg-
ulations, INEEL may use any available
system to characterize  waste without
prior approval, but may not ship it to
WIPP until EPA approval is given.)
  Such a request would have initiated
independent  reviews by both  CBFO
and EPA. The error appeared to  be the
result of a breakdown mainly  in the
area of document control, as  well as an
incorrect assumption by INEEL person-
nel  that the  similarity  of the  WAGS
radioassay equipment to previously-ap-
proved equipment meant that indepen-
dent review by CBFO and EPA was not
necessary.

What actions are
being taken to prevent
recurrence?

  DOE is taking steps to analyze fully
the  causes of the noncompliance and
prevent recurrence. INEEL is making
improvements to  document  control
procedures to minimize confusion over
approved processes  and equipment,
among other actions. Also, CBFO has
already inspected  document  control
procedures at other  approved  waste
sites (such as Rocky Flats) to  verify that
similar  problems  have not  occurred.
EPA will review  the status of CBFO's
and INEEL's responses at future inspec-
tions. The WIPP  is a  complex project,
and it is important to  understand com-
pliance failures such as the recent one
at INEEL to prevent them from recur-
ring. Inspections are a powerful tool for
EPA to verify the compliance of DOE's
WIPP activities.
                                                                                       The WIPP Bulletin 5

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    WIPP Technical Comer
The  Design  of  the WIPP
Performance  Assessment
     The disposal regulations at 40 CFR
     Part 191 include  requirements
     for  containment  of  radionu-
clides. The containment requirements
specify that releases of radionuclides
to the accessible environment must be
unlikely to exceed specific  limits for
10,000  years after disposal. At the
WIPP, the specific release  limits are
based on the amount of waste in the
repository at the time of disposal. As-
sessment of the likelihood that the
WIPP will meet these release limits is
conducted  through  the use  of  a
process  known as performance  as-
sessment (PA).
  In past issues of the WIPP Bulletin,
we have provided information on the
development of the performance as-
sessment. In this issue we examine the
                                  features, events and processes (FEPs)
                                  that are the foundation of the PA.
                                    The WIPP PA process culminates in
                                  a series of computer simulations that
                                  attempts to describe the physical at-
                                  tributes of the disposal system (site
                                  characteristics, waste forms and quan-
                                  tities, engineered features) in a man-
                                  ner that captures the behaviors and
                                  interactions among its various compo-
                                  nents.  The computer  simulations re-
                                  quire the  use of conceptual models
                                  that represent the physical attributes
                                  of the repository that  include the re-
                                  sults of a screening process applied to
                                  the FEPs. The conceptual models are
                                  then expressed as mathematical rela-
                                  tionships, which are solved with itera-
                                  tive numerical models, which are then
                                  translated into computer code. The re-
     Types of Features, Events, and
   Processes  (FEPs)
   Natural:  site stratigraphy, Castile brine reservoirs, salt deformation,
   formation of fractures, volcanic activity, groundwater chemistry, and
   sea level changes
   Waste- and repository-induced: disposal system geometry, waste
   characteristics and inventory, seal design and characteristics, backfill
   characteristics, and radioactive characteristics of waste
   Human-initiated: oil, gas, water resource, and  potash activities; land
   use, farming, and urbanization
suits of the simulations are intended to
show the potential releases of radioac-
tive materials from the disposal system
to the accessible environment over the
10,000-year regulatory time frame.
  In preparing the certification appli-
cation for EPA, DOE compiled a list of
1,200 features,  events or processes
from various  international  surveys.
DOE then conducted an initial screen-
ing process  that eliminated FEPs that
could not happen because of WIPP's
location  (for example, tidal waves).
After this initial  screening  process,
there were 236 FEPs  left for more de-
tailed consideration.  These final FEPs
were grouped into three major cate-
gories: natural, waste- and repository-
induced, and human-initiated.
  DOE further refined the list of FEPs
using an  elimination process. There
were three criteria to eliminate FEPs:

1) Regulatory -  Some FEPs can be
   omitted based on specific regula-
   tory requirements.  For example,
   drilling activities that occur outside
   the Delaware Basin do not have to
   be considered  in  the performance
   assessment,  according  to EPA's
   compliance criteria.
2) Probability -  Some FEPs can be
   omitted because of the low proba-
   bility that the FEP will occur.  For
   example, DOE determined that the
   probability of a meteorite landing
   in the vicinity of the WIPP is so
6  The
             Bulletin

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   Contacts  and  On-Line  Resources
   1AIIPP Transportation  Information*
  WIPP Facility  Dennis Hurt!
  TRU Waste    U.S. Department of Energy
  Transportation Office of Public Affairs
              National Transportation Program
  Transportation William B. (Bill) Mackie
  Issues       Coordinator of New Mexico's Radioactive
              Waste Task Force, State of New Mexico
              Richard Swedberg
              Health Physicist
              U.S. Department of Transportation
              Ron Ross
              Program Manager
              Western Governors' Association
              Debbie Cohen
              National Safety Council
            (505) 234-7327
            (505) 476-3248
www.wipp.carlsbad .nm .us

www.ntp.doe.gov
www.emnrd.state.nm.us/wipp
            (303) 969-6744, ext. 0363        www.fhwa.dot.gov/omc/omchome.html
            (303) 623-9378
            (202) 293-2270, ext. 478
www.westgov.org/wipp
www.nsc.org/ehc/wipp.htm
   *EPA does not regulate waste transportation to WIPP, however, we receive many requests for this information.

Technical Corner
   low that  it does  not need  to  be
   considered in the  PA.
3) Consequences - Some FEPs can be
   omitted because the consequences
   resulting  from the FEP, even if it
   does occur, are so  small. For ex-
   ample, there would be no conse-
   quences to the repository or the
   containment of waste if an archeo-
   logical excavation took  place  on
   the  surface in the vicinity of the
   WIPP.
   Upon completion  of this process,
DOE selected 83 FEPs to be included
in the final  performance  assessment
process. These FEPs  were then used
to develop scenarios  and models.
   The DOE  had to  justify the omis-
sion  of any  features, events and
processes that could occur but are not
included in the final PA calculations.
The omission of some  FEPs was one
of the topics  on which EPA received
the most public comment during the
certification process. Some people dis-
agreed with  DOE and  EPA's elimina-
tion of certain FEPs. Examples of FEPs
that commenters  said should be  in-
cluded in the performance assessment
are:  karst topography, fluid injection
and air drilling.
   Of all the FEPs that are considered
for the PA calculations, the human-in-
trusion  scenarios related to  drilling
have been  shown to have  the  most
significant impact on the disposal sys-
tem and its ability to contain waste. In
the next issue of the WIPP Bulletin,
we will discuss some of the human-in-
trusion scenarios  in  more detail and
describe  how we considered public
comment on these scenarios.
                                        Office of Radiation and Indoor Air
                                        (6608J)
                                        EPA 402-N-02-001
                                        www.epa.gov/radiation
                                        March 2002
                                                                                               The WIPP Bulletin 7

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