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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