The WPP Bulletin
United States
Environmental Protection
Agency
A Message From the Director
by Betsy Forinash
any of our readers may not be
aware, but EPA is in the midst
of a crucial period in our over-
sight of the WIPP's safety. The start of
the WIPP recertification period is still
over a year away, but it is actually the
current year that will set the foundation
for the work that we will do after DOE
submits its recertification application.
DOE has initiated a number of activities
that will require EPA's attention well be-
fore we begin the formal process of re-
certification. During the summer and fall
of 2002, we expect DOE to submit sev-
eral proposals to EPA for changes to
WIPP activities that are covered by our
recertification. While these changes
cover a variety of project areas, perhaps
the most important ones concern the
WIPP performance assessment, which is
the cornerstone of DOE's demonstration
of compliance with our public health
and environmental radiation protection
standards. We have been meeting often
with DOE representatives to discuss
their work in this area. EPA has advised
DOE to submit proposed changes in
2002 to allow sufficient time for review
in advance of recertification.
I would also like to highlight an action
that EPA has undertaken that is separate
from recertification. We have proposed
to change several provisions in our
WIPP Compliance Criteria (40 CFR Part
194) through a rulemaking. The pro-
posed changes are described in this Bul-
letin. We welcome your input through
written comments and public hearings,
which we will hold in New Mexico in
the fall.
This issue of the WIPP Bulletin intro-
duces yet another new feature, Ask
EPA, in which we respond to ques-
tions raised by stakeholders that are of
general interest. Please feel free to sub-
mit questions to our web page or toll-
free information line. We will respond
to requests for information, either indi-
vidually or also in the Bulletin.
Also, this issue's Technical Corner
addresses one of the most important
compliance topics during the initial
certification: DOE's analysis of the pos-
sible environmental releases of radioac-
tive materials due to human intrusion
into the WIPP (such as drilling for oil).
Our hope is that the Technical Cor-
ner will help to explain some of the
more complicated technical issues in a
straightforward, understandable way.
Finally, you should have received a
copy of our newest fact sheet on recer-
tification. This fact sheet explains
what's involved in recertification and
when the key steps will occur. If you
did not receive the fact sheet and
would like one, please contact us.
On behalf of all of us at EPA who work
on the WIPP, I want to thank you for
your continued interest in this impor-
tant project.
Inside this Issue
A Message From the Director 7
News Notes 2
WIPP Dockets Locations 2
Waste Shipments 3
Focus on: Making Experience Count 4
Ask EPA 5
Technical Corner 6
EPA's WIPP Activities 2002 7
Contacts and Online Resources 7
Printed on recycled paper
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WIPP News Notes
What's New on the
WIPP Website
We have redesigned our WIPP
website and added new user-
friendly features. Recent changes
include:
A separate side bar/menu for easier
site navigation
An improved link for WIPP-related
news as well as other recent devel-
opments within EPA's Radiation Pro-
tection Division (RPD)
A separate inspections page for up-
dated information on upcoming and
completed inspections
An updated Publications page with
our latest WIPP Bulletins and Fact
Sheets for 2002.
EPA's IMew Electronic
Docket (EDOCKET)
On June 1st, 2002, EPA unveiled a
new electronic docketing sys-
tem, EDOCKET, for use by the
Agency and the general public. This
new system supports the President's
new E- Government Strategy for
WIPP Dockets Locations
expanding electronic government to
make interactions easier.
What is a public docket?
A docket is a collection of documents
(letters, reports, reference materials,
etc.) that are used to support EPA's reg-
ulatory actions. EPA has three dockets
for the WIPP program:
A-92-56, which contains information
about the WIPP compliance criteria,
A-93-02, which contains information
considered in making the WIPP cer-
tification decision, and
A-98-49, which contains new infor-
mation that the EPA is reviewing to
determine whether the certification
should be modified, suspended, or
revoked.
Currently, all pertinent material is
submitted to the dockets in their
original, hard-copy form. This new
electronic system will eliminate the
use of cumbersome paper docu-
ments and allow greater participation
in Agency processes, including those
related to the WIPP.
Any interested parties may use EPA's
EDOCKET at http://www.epa.gov/rpas
EPA Docket Center (EPA/DC)
Air and Radiation Docket
EPA West, Mail Code 6102T
1200 Pennsylvania Ave., N.W.
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
(DocketA-93-02 only, EPA's
WIPP Certification Decision)
New Mexico State Library
1209 Camino Carlos Rey
Santa Fe, NM 87505
(505)476-9717
(Docket A-98-49 only,
EPA's WIPP Recertification
Decision)
to access the index of all available pub-
lic dockets and view current docu-
ments electronically. An advanced
search option is also available, which
will allow the user to search for a par-
ticular item by tide, release date, docu-
ment type, Federal Register citation,
program office, or other various identi-
fiers. The documents will be available
for viewing and can be downloaded in
.pdf (Adobe) format.
Parties wishing to submit comments to
EPA will be able to do so electronically.
Once in the system, users will be able
to search for or key in the ID number
for the docket they wish to review.
After agreeing to a privacy and dis-
claimer notice, the user will then be al-
lowed to submit their comments (along
with any attachments) and enter their
name, group, or organization if they
wish to do so. The user will then re-
ceive a confirmation notice and their
comment will be published on the in-
ternet after review by the docket staff.
This allows the public to see their own
comments and also comment on an-
other user's comment(s). This process
is similar to a feedback forum.
Due to certain limitations and regula-
tions, certain types of information
(databases, copyrighted documents,
etc.) will not be placed in the elec-
tronic docket. For more information
on what is or is not accepted or any
other issue regarding EDOCKET,
please refer to the Federal Register for
May 31, 2002 (Vol. 67, No. 105; 38102-
38104), or contact Shivani Desai by
phone (202-566-1674) or e-mail
(desai.shivani@epa.gov). EPA's WIPP
dockets are not yet available on
EDOCKET.
Stakeholder Meetings
Several members of EPA's WIPP staff
met this spring with representatives
of the following WIPP stakeholder or-
The WIPP Bulletin July 2002
-------
ganizations in New Mexico: the Envi-
ronmental Evaluation Group, Nuclear
Watch of New Mexico, the Southwest
Research and Information Center, Sis-
ters of Loretto, Concerned Citizens for
Nuclear Safety, and the New Mexico
Attorney General. The meetings took
place in Albuquerque and Santa Fe in
March. In addition, we spoke sepa-
rately with representatives of Citizens
Against Radioactive Dumping by con-
ference call.
At the meetings, EPA responded to
questions on such topics as recertifica-
tion planning, DOE's research on ac-
tinide solubility, and recent peer
reviews conducted by DOE. EPA also
briefed participants about the pro-
posed changes to the WIPP Compli-
ance Criteria (see Focus on article).
A general topic that was discussed was
the need to make information pro-
duced by EPA and DOE easily accessi-
ble to the public. One avenue that EPA
is pursuing in this regard is an elec-
tronic docket that will make materials
available to anyone with access to the
Internet. Several stakeholders re-
quested that files posted electronically
be readily downloadable, and that re-
quests for comment be staggered to fa-
cilitate public review. We will take this
request into account when we post
documents online.
EPA Completes Review
of DOE's Annual WIPP
Change Report
EPA requires that DOE submit an an-
nual WIPP Change Report that doc-
uments any changes that were made to
the WIPP program during the previous
year. In September 1998 we provided
DOE with reporting guidance. We re-
view the changing information and de-
termine whether the initial certification
should be modified, suspended, or re-
voked. Sometimes DOE may want to
make changes to their activities to
make improvements or increase effi-
ciency. In most cases, these changes
are insignificant. If EPA thinks the
changes are significant, we may ask for
public comments to assist in our re-
view. Details of changes to the WIPP
that EPA has reviewed since 1998 may
be found in our recertification docket.
DOE submitted its fourth (FY 2001) an-
nual WIPP Change Report on Novem-
ber 13, 2001. EPA evaluated it along
with requested supplemental informa-
tion. On June 13, 2002, we determined
that the reported changes were not sig-
nificant and do not require a modifica-
tion, suspension, or revocation of our
Certification Decision of May 13, 1998.
We expect to receive the 2002 change
report in November.
Waste Characteriza-
tion Inspections
In December 2001 EPA inspected
the Hanford Site Plutonium Finish-
ing Plant to verify its continued com-
pliance with our regulations. During
this inspection we also examined the
use of new waste characterization
systems at the site. Based on our
inspection, we approved the site to
continue characterizing transuranic
waste using both the new methods
we inspected and previously ap-
proved systems.
In April, 2002, EPA inspected the
Idaho National Engineering and Envi-
ronmental Laboratory (INEEL) to ex-
amine new waste characterization
systems and a new waste stream (or-
ganic sludge). Based on our inspec-
tion, we determined the site was in
compliance with our regulations for
characterizing the waste streams and
equipment examined.
The reports for these inspections may
be found in our docket (A-98-49,
Items II-A4-20 and 21).
Waste Shipments
The number of shipments from
transuranic waste sites to the WIPP
as of June 30 is listed below. Each
shipment could contain as many as
42 drums of radioactive waste.
Savannah River
Rocky Flats
Los Alamos
Idaho
Hanford
12002 The WIPP Bulletin 3
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Focus On: Making Experience Count
Proposed Changes to EPA's Compliance Criteria for the Recertification
of the WIPP
It has been four years since we cer-
tified the WIPP as a disposal facil-
ity for defense transuranic (TRU)
wastes. In that period, we have con-
ducted dozens of regulatory inspec-
tions. Now we seek to apply that
experience to the WIPP Compliance
Criteria to keep them comprehensive
and appropriate, while also improving
process and resource efficiencies.
What are the
proposed changes?
Proposed revisions to the compliance
criteria include: (1) addition of a
process for making minor changes to
the provisions of the Compliance Cri-
teria; (2) changes to the approval
process for waste characterization pro-
grams at Department of Energy
transuranic waste sites; (3) changes to
allow for the submission of copies of
compliance applications and reference
materials in a non-paper format (e.g.,
compact disk); and (4) replacement of
the term "process knowledge" with
"acceptable knowledge." The second
item is the most significant change and
the focus of this article.
What is our Role?
On May 13, 1998, EPA announced its
final compliance certification deci-
sion. Since March 1999, the WIPP has
received hundreds of waste ship-
ments for disposal. EPA has regula-
tory authority over the WIPP for the
operational lifetime of the facility, ap-
proximately 35 years. As part of our
regulatory role at the WIPP, we re-
view, analyze, inspect, and approve
WIPP-related activities throughout the
DOE complex to ensure that DOE
operates the WIPP facility in compli-
ance with our regulations.
How are we making
our experience count?
One of the most critical aspects of our
ongoing regulatory oversight involves
the inspection of waste generator sites
that wish to send their waste to the
WIPP for disposal. WIPP certification
is based on specific assumptions
made about the composition of the
waste destined for disposal. It is cru-
cial that waste composition be mea-
sured and tracked, so that established
limits for waste components impor-
tant to the safe performance of the
WIPP facility are not exceeded. At the
time of the final certification, DOE
submitted a comprehensive waste
characterization plan for their facili-
ties, but was able to demonstrate their
waste characterization capability at
only one site for a single "waste
stream."
A "waste stream" is defined by DOE
as waste material generated from a
single process or activity that is simi-
lar in material, physical form, iso-
topic make-up, and hazardous
constituents. Given the limited
demonstration of DOE's waste char-
acterization capability, EPA issued a
condition in its final certification that
precludes DOE from shipping waste
to the WIPP until EPA has approved
the processes for characterizing
wastes destined for disposal.
Section 194.8(b) establishes the
process we use to approve waste
shipments from the waste generator
sites to the WIPP facility. Under the
section 194.8(b) approval process, we
must inspect and approve each DOE
TRU generator waste site that wishes
to ship waste, by conducting an in-
spection for each waste stream or
group of waste streams proposed for
disposal at WIPP. We also must pub-
lish a Federal Register notice to an-
nounce the inspection, open a 30-day
comment period, and solicit public
comment on relevant DOE docu-
ments. If a site receives our approval
to ship a single waste stream or group
of waste streams, that site may not
ship a different waste stream until we
perform an additional inspection
under section 194.8(b).
After four years of regulatory experi-
ence, we have determined that the
process used to approve waste ship-
ments to the WIPP may be improved.
To date, we have performed over 20
inspections under 194.8(b). Five major
DOE sites have been approved to ship
a variety of waste streams to the WIPP.
EPA inspectors have been able to
witness and verify DOE's ability to
characterize numerous waste streams.
Our experience in verifying DOE's
compliance shows that it is not always
ideal to have waste generator sites
demonstrate their characterization ca-
pabilities on individual waste streams.
The focus of our inspection program
will be on the overall waste character-
ization program at the site. For exam-
ple, we will evaluate how DOE staff
use their knowledge of waste charac-
terization processes and waste types
to select and use the right waste char-
acterization process for the particular
characteristics of the waste destined
for disposal.
We have also observed that the public
notice process in 194.8 has proven to
be confusing to the public, stakehold-
ers, and DOE. The proposed rule will
The WIPP Bulletin July 2002
-------
Ask EPA
What is EPA's process for
recertifying WIPP?
DOE is required by law to submit documentation that the
WIPP remains in compliance with EPA's certification. DOE
must submit the first recertification application in March
2004, five years after the first receipt of waste at WIPP in
March 1999. As with the original WIPP application, EPA
will examine the information submitted by DOE to deter-
mine if it is complete. EPA may request additional infor-
mation from DOE. Once EPA has complete information,
EPA has six months to determine whether or not to recer-
tify WIPP. During these six months EPA will conduct a
thorough evaluation of the application, paying particular
attention to information or conditions that may have
changed since the original 1998 certification. EPA will also
request at least 30 days of public comment on DOE's re-
certification application to help form our decisions. Once
EPA's evaluation is complete, EPA will issue a determina-
tion on recertification in the Federal Register and will pro-
vide supporting documentation for our decision.
As the time for recertification approaches, we will provide
more updates and details on our activities and plans.
Focus on: Making Experience Count
(continued from page 4)
clarify this process. Only one approval per site will be issued
under 194.8. Under the new process, EPA will conduct in-
spections at each site and request public comment on EPA's
inspection report and proposed approval for a site. (Cur-
rently, we request comment on site waste characterization
plans that are made available to the public before inspec-
tion.) Reporting requirements will be assigned to each site
to address changes that may occur in the waste character-
ization program after site approval. Information received
through the reporting requirements will be used to deter-
mine when additional inspections are necessary. These in-
spections will be carried out to confirm continued
compliance and verify the adequacy of changes in the ap-
proved waste characterization programs.
We believe the proposed process will offer the same level of
oversight for waste characterization activities, make site ap-
provals more transparent, and increase EPA's control over re-
sources while maintaining confidence in DOE's compliance.
Ask EPA highlights questions
received from citizens on our WIPP
Information Line, our WIPP Web
Site, at our stakeholder meetings,
and from our newsletter readers.
What is RH Waste?
RH (remote-handled) waste is a type of radioactive waste
with a surface radiation dose rate of greater than 200 mrem
per hour. RH waste emits higher levels of penetrating gamma
radiation and, therefore, must be handled by remotely-oper-
ated machines. Like contact-handled transuranic waste (cur-
rently disposed of at the WIPP repository) RH waste may be
disposed of at the WIPP if the EPA approves such disposal.
Only a small portion of the volume of wastes potentially des-
tined for disposal at the WIPP is remote-handled waste. To
obtain an EPA approval, DOE sites generating or storing RH
waste (for example, Hanford and Oak Ridge) must show that
the radioactivity of RH waste that would be disposed of at the
WIPP facility will not exceed the limit imposed by law. EPA
is expecting a proposal from DOE for handling RH waste
during the summer.
What areas of expertise are repre-
sented on EPA's WIPP Team and
how can I contact them if I have
questions on EPA's WIPP Program?
EPA's WIPP Team consists of experts in the fields of chem-
istry, environmental science, geology, engineering, hydrol-
ogy and communications. The WIPP staff are located in
Washington, DC; and Dallas, Texas. Members of the team
conduct regular audits and inspections of WIPP-related ac-
tivities at the WIPP site and at other DOE facilities. If you
have questions about our WIPP regulatory program, you
can leave a message or question on our WIPP Information
(202) 564-9310. You may also contact us on the internet
through our webmaster at: webmaster.oria@epa.gov. A
member of the WIPP Team will respond to you directly
and promptly.
> 2002 The WIPP Bulletin 5
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WIPP Technical Comer
A Look at Human Intrusion into the WIPP
In our last Bulletin we discussed
the Features, Events and Processes
(FEPs) that were compiled and ex-
amined for evaluating the long-term
performance of the WIPP repository. In
that article, you may recall, we stated
that the human intrusion scenarios are
the most important to the containment
of waste. In this Technical Corner, we
will discuss the human intrusion sce-
narios specifically.
Analyses have shown that the only way
radioactive waste could be released
from the WIPP repository is if someone
intrudes into the repository or if intru-
sions elsewhere in the vicinity of WIPP
have impacts on the repository. DOE
has developed a list of ways that vari-
ous intrusions could impact the reposi-
tory. These are called human intrusion
scenarios. Most of the scenarios involve
Sample Drilling Scenario
Drilling Rig
Land Surface
Culebra
Waste Disposal RoomsI
-Borehole
Filled Shaft-
Key
Pressurized Brine
(Not to scale)
-
i
Possible pathways for radionuclide
releases resulting from human intrusion
some type of drilling or drilling prac-
tices.
The intrusion scenario that will have
the most impact on radioactive waste
releases is one that involves a borehole
that is drilled directly through a stack of
waste drums. This event is the most sig-
nificant because there are three ways
that radioactive waste could leave the
repository: cuttings, cavings and
spallings.
1) Cuttings are the actual waste cut
out by the action of the drill bit.
2) Cavings are the waste that is re-
moved or washed from the sides of
the borehole by the action of drilling
fluid flowing in the borehole.
3) Spallings are the waste that can be
forced into the borehole of the sur-
rounding waste room by the action
of pressurized gas in the waste
room.
These mechanisms combine to pro-
duce the greatest releases when
modeling the WIPP.
A great deal of work has been done to
attempt to understand cuttings, cav-
ings, and in particular, spallings.
Spallings is driven by gas pressure.
therefore a clear understanding of the
mechanisms that create gas in the
waste rooms is very important. Gas
pressure in the waste rooms is created
by the degradation of materials in the
waste. For example, if there is suffi-
cient water in the repository, the steel
55 gallon drums used to transport
waste to WIPP and other metals will
rust and produce gas. If the pressure
generated in a waste room is high
enough when a drilling intrusion hap-
pens, a spallings release could occur.
(continued on page 7)
The WIPP Bulletin July 2002
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Technical Corner
EPA and DOE also considered the im-
pact of mining for natural resource,
such as potash mining, near WIPP.
This human intrusion scenario may
not directly impact the waste rooms,
but it may affect the transport of
waste from WIPP. For example,
potash mining hundreds of feet above
the WIPP may indirectly change the
characteristics of shallower rock for-
mations, such as the Culebra, and
may cause brine to flow more readily
through those formations.
EPA's analyses of the human intru-
sion scenarios showed that even
with human intrusion into the WIPP
repository, EPA's containment re-
quirements will be met and the site
will remain safe.
The human intrusion scenarios can be
very complex. They cover many im-
portant topics that integrate all that we
currently know about the WIPP site. In
our next issue of the WIPP Bulletin,
we will consider one of the human in-
trusion scenarios that was important
during EPA's Certification Decision:
Fluid Injection.
EPA's WIPP Activities
2OO2
Summer
Proposed Technical Meet-
ing with DOE (Location: TBD)
DOE's Proposal for Remote
Handled Waste (RH) at WIPP
Proposal on Revisions to EPA's
Compliance Criteria for the WIPP
Fall
Proposed Technical Meeting with DOE
(Location: TBD)
Public Hearings in New Mexico on EPA's
Proposed Revisions to WIPP Compliance
Criteria
Meetings with Stakeholder Groups in
New Mexico
Performance Assessment Related
Proposal from DOE
Publish Final Decision on
Revisions to EPA's Compliance
Criteria for the WIPP
Dates for EPA's WIPP Activities
are based on projected time-
frames for receiving infor-
mation from DOE
For A/lore Information
About the WIPP
More information on EPA's continued
activities concerning the WIPP can be
obtained from any of EPA's five public
dockets (Washington DC, and Albu-
querque, Carlsbad, and Santa Fe, New
Mexico). The Docket number for EPA's
recertification activities at the WIPP is
A-98-49. The pre-certification and certi-
fication decision Docket is A-93-02. For
the latest information on EPA activities
regarding the WIPP, please call EPA's
recorded WIPP Information Line at
ad all about EPA's WIPP
Program on the Internet. EPA's WIPP
Homepage is an excellent source for
current information on EPA's WIPP activ-
ities. From the Homepage you can also
download EPA documents and docket
information. EPA's WIPP Homepage ad-
dress is:
www.epa.gov/radiation/wipp/
Contacts and On-Line Resources
WIPP Transportation Information*
WIPP Facility Dennis Hurtt
TRU Waste U.S. Department of Energy
Transportation Office of Public Affairs
National Transportation Program
Transportation Anne Clarke
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) 476-3224
(303) 969-6744, ext. 0363
(303) 623-9378
(202) 293-2270, ext. 478
www.wipp.carlsbad.nm.us
www.ntp.doe.gov
www.emnrd.state.nm.us/wipp
www.fhwa.dot.gov/omc/omchome.html
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.
July 2002 The WIPP Bulletin 7
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SEPA
United States Environmental
Protection Agency (6608J)
Washington, DC 20460
First Class Mail
Postage and Fees Paid
EPA
G-35
Official Business
Penalty for Private Use $300
Forwarding Service Requested
For Further Information on EPA's WIPP Activities
Pleasp Hall thp WIPP Information Line
or visit our website at:
http://www.epa.gov/radiation/wipp
Office of Radiation and Indoor Air (6608J) EPA 402-N-02-002 www.epa.gov/radiation July 2002
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