The  WPP Bulletin
United States
Environmental Protection
                    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

    WIPP News Notes
What's  New on the
WIPP Website

     We have redesigned our  WIPP
     website and added new user-
friendly  features.  Recent  changes
•  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

             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
  EPA Docket Center (EPA/DC)
  Air and Radiation Docket
  EPA West, Mail Code 6102T
  1200 Pennsylvania Ave., N.W.
  Washington, DC 20460
  (all dockets)

  Carlsbad Public Library
  101 S. Halagueno
  Carlsbad, NM 88220
  (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
(Docket A-98-49 only,
EPA's WIPP Recertification
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
dockets  are   not yet  available  on

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
                                                                                     12002 The WIPP Bulletin 3

 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
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:  A
member of the WIPP Team will respond to you directly
and promptly.
                                                                                   > 2002 The WIPP Bulletin 5

    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
    Waste Disposal Rooms—I
                                                  Filled Shaft-
                                     Pressurized Brine
                                             (Not to scale)
Possible pathways for radionuclide
releases resulting from human intrusion
some type of drilling or drilling prac-
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
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

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

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
             • 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

• Proposed Technical Meeting with DOE
(Location: TBD)
• Public Hearings in New Mexico on EPA's
Proposed Revisions to WIPP Compliance
 • 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:
   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
   *EPA does not regulate waste transportation to WIPP, however, we receive many requests for this information.
                                                                                          July 2002 The WIPP Bulletin 7

United States Environmental
Protection Agency (6608J)
Washington, DC 20460
First Class Mail
Postage and Fees Paid
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:
      Office of Radiation and Indoor Air (6608J) • EPA 402-N-02-002 • • July 2002