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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- Vd3 sss-\ pus SSB|Q O^ sssjppy (f8099) A SSJBJS ------- |