PERFORMANCE ASSESSMENT

2009 EPA WIPP RECERTIFICATION FACT SHEET

PERFORMANCE ASSESSMENT

What is Performance Assessment?

Performance Assessment (PA) is an analysis that uses a series
of models and computer calculations to estimate cumulative
releases of radionuclides from the Waste Isolation Pilot Plant
(WIPP) to the accessible environment over a 10,000-year
period. The WIPP PA assesses whether WIPP will meet the
radionuclide release limits specified by 40 CFR § 191.13 for
10,000 years after repository closure. The release limits are
based on the amount of radionuclides the U.S. Environmental
Protection Agency (EPA) has determined can be released from
the repositojy without being detrimental to human health or
the environment. EPA compares the results from PA with the
release limits as part of the basis for its WIPP recertification
decision.

What are the major steps in performing a PA?

PA is designed to answer three primary questions about the
WIPP site:

1)	What features, events and processes (FEPs) could be
important for repository performance over the next
10,000 years?

2)	How likely are these FEPs?

3)	What are the consequences of these FEPs?

To answer these questions, PA

1)	Identifies FEPs that might affect the disposal system

2)	Examines the effects of these FEPs on the
performance of the disposal system

3)	Estimates the cumulative releases of radionuclides to
the accessible environment, including the
uncertainties associated with all significant processes
and events

Analysis of FEPs

A systematic approach is used to identify, compile, and screen
a comprehensive list of FEPs that may be relevant to disposal
system performance. The FEPs include both natural and man-
made processes and events. FEPs that are not significant for
disposal system performance are excluded from the PA based

on low consequence, low probability, or regulatory
specifications (i.e, if they exclude a process or event). FEPs
that cannot be excluded are retained and used in the PA. In
some cases, a FEP that is beneficial to repository performance
(i.e., impedes radionuclide release) has been excluded from
PA if its implementation would introduce an unnecessary level
of complexity.

Consequences of undisturbed and disturbed
performance

The FEPs retained in the PA provide the basis for the models
and computer codes that predict long-term performance of an
undisturbed or disturbed repository. Undisturbed performance
includes the predicted behavior of the disposal system,
assuming it is not disrapted by human intrusion or the
occurrence of unlikely natural events. Disturbed performance
includes the predicted behavior of the disposal system in
response to human intrusion or other disruptive actions,
including drilling, fluid injection, secondary oil recovery
methods (water flooding), disposal of natural brines,
excavation mining, solution mining and future development of
leases.

PA calculates the consequences for undisturbed and disturbed
performance by modeling the physical attributes of the
repository, including site geology, site hydrology, the waste
form, and its engineered features, in a manner that captures the
long-term behavior of the disposal system.

How has PA changed since the initial compliance
decision, the 2004 recertification decision and now?

The PA used in the initial compliance certification decision
incorporated all the information available at that time. For the
2004 recertification decision, the models and parameters were
updated to include the most current information. More
information has become available since the 2004
recertification decision; hence, there are some changes in the
PA for the CRA-2009. These changes include improvements
to parameters and computer codes, as well as corrections to
parameters and input files. However, the results of the PA
show essentially no change in compliance, with projected

United States Environmental Protection Agency | Office of Air and Radiation (6608J) | June 2009
http://www.epa.gov/radiation/wipp/index.html


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PERFORMANCE ASSESSMENT

releases less than one tenth of the EPA limits. The same
calculation methodologies and conceptual models used in the
2004 recertification decision are used for the CRA-2009 PA.

PA results for CRA-2009

The results of the PA predict the amount and likelihood of
cumulative releases of radionuclides to the accessible
enviromnent over a 10,000-year period. The accessible
enviromnent includes the ground surface, atmosphere, surface
water and the subsurface boundary defined by all points lying
directly below the boundary of the WIPP controlled area. The
results of the WIPP PA are expressed as complementary
cumulative distribution functions (CCDFs) that define the
probability that the releases from the repository will exceed a
given level. A CCDF is required by EPA's regulations and
provides a convenient comparison of the PA results with the
regulatory release limits from 40 CFR 191.13(a).

2009 EPA WIPP RECERTIFICATION FACT SHEET

Figure 1 shows that the total release calculated for the
disturbed repository for CRA-2009 lies to the left of the
release limits (i.e., comparing the solid blue curve to the
dashed black lines). This demonstrates that the predicted
performance of the repository is almost a factor of 10 below
the regulatory limits for cumulative radionuclide release.
Figure 1 also shows the contributions to total normalized
release from the four major release pathways: cuttings and
cavings, direct brine release, spallings and through the Culebra
aquifer. These four pathways can only occur for disturbed
performance, with a drilling intrusion into the repository.
Cuttings and cavings and direct brine release are the dominant
pathways causing total release, as can be seen in Figure 1. For
the undisturbed repository (not shown in Figure 1), there is
zero cumulative release of radionuclides to the accessible
enviromnent over 10,000 years.

Figure 1. Mean complementary cumulative distribution functions offour disturbed pathways and of total releases in Replicate 2
of the PAfor CRA-2009.

0.001

0 0001

0.0001

0.01	0.1

R = Release (EPA Units)

—	—Cuttings and Cavings

-	- - Direct Brine

Spallings

For Further Information

Sections 194.23, Models and Computer Codes, 194.25, Future States Assumptions, 194.31, Application of Release Limits, 194.32,
Scope of Performance Assessments, 194.33 Consideration of Drilling Events in Performance Assessments, and 194.34, Results of
Performance Assessments, provide additional information on PA for CRA-2009. Appendices MASS, PA, and SCR provide
detailed descriptions of the modeling assumptions, computational methods, and FEP screening justifications for the CRA-2009
PA.

United States Enviromnental Protection Agency | Office of Air and Radiation (6608J) | June 2009
http://www.epa.gov/radiation/wipp/index.html


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