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Appendix A2

DOE's Response to the Interim Report



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Page 109 Appendix A2 DOE's Response to the Interim Report

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Page 111 ~ enlarge ~ Department of Energy Carlsbad Field Office P.O. Box 3090 Carlsbad, New Mexico 88221 October 30, 2000 National Research Council Committee on the Waste Isolation Pilot Plant Board on Radioactive Waste Management C/O Kevin D. Crowley, Director 2101 Constitution Avenue, NW Washington, DC 20418 Dear Committee members: Thank you for your excellent work on the Waste Isolation Pilot Plant Interim Report. We have read your report with great interest and agree with its principles. I am attaching a response to each of the recommendations which you may wish to consider in developing your Final Report. To briefly summarize, our responses are as follows: Data on NORM is being collected and a database developed. We are actively pursuing reduction and elimination of self-imposed waste characterization requirements that lack a technical or safety basis. We are working closely with the Nuclear Regulatory Commission to minimize the impact of the 5% hydrogen limit, and to reduce or eliminate unnecessary repackaging of waste. TRANSCOM has been completely revised to include requested updates and to incorporate specific WIPP requirements. We are working with the states to identify and remedy gaps in emergency response coverage. In conclusion, your recommendations have been adopted as the cornerstone of our planning to bring WIPP to its full potential as the solution to managing our nation's TRU waste. Sincerely, ~ enlarge ~ Dr. Inés Triay, Manager Attachments Additional copies of Rail Study sent under separate cover cc: Lynne Wade, EM 23 Matthew Silva, EEG CBFO:OOM:IRT:KJB 00-0467 UFC #5480

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Page 112 Response to National Research Council Recommendations Committee on the Waste Isolation Pilot Plant – Interim Report I. NORM in the WIPP Vicinity Recommendation: “DOE should develop and implement a plan to sample oil-field brines, petroleum, and solids associated with current hydrocarbon production to assess the magnitude and variability of naturally occurring radioactive material (NORM) in the vicinity of the WIPP site.” Response: DOE agrees with this recommendation. The New Mexico State University Carlsbad Environmental Monitoring & Research Center (CEMRC) has undertaken a project to carry out the recommended assessment, as part of CEMRC's ongoing WIPP Environment Monitoring project. Although analyses of certain naturally occurring radioactive materials in hydrocarbon and scale matrices are somewhat standardized, the sensitivity of the standard methods will likely not be acceptable for at least a portion of the matrices targeted, resulting in the need for method enhancement research. In addition, no published methods are available for analyses of plutonium, americium and other TRU components of concern in hydrocarbons, so this analytical task will require extensive method development and validation prior to initiation of analyses of actual samples. NORM is an extremely sensitive topic in the oil and gas production industry in the region of the WIPP. As an example, one major exploration and production company that operates in Lea and Eddy counties recently submitted 48 pages of critique on draft Regulation Guidelines for the Management of NORM in the Oil and Gas Industry in New Mexico, which was issued by the New Mexico Environment Department in 1999. Initial contacts with those familiar with local and regional companies indicate that it is likely that many if not most operators will decline to cooperate. To create the maximum likelihood of obtaining cooperation, an option for anonymity will be offered to the operators, using a form of “double-blind” identification. This system would involve collection of samples by a commercial third-party service company that is acceptable to the operator, submittal of the samples to CEMRC without identification of the operator or well location (formation and production pool only), resulting in CEMRC reporting of results without specific operator or well identification. Path Forward: CEMRC received approval in August 2000, from DOE to proceed with the project without direct involvement of DOE in contacting affected production operators. A plan for a study entitled “Characterization of radioactive elements in oil and gas production in the vicinity of the WIPP” was developed by CEMRC. The initial phases of the study are in progress, including completion of a database of active wells and operators, development of sample collection and handling plans, and identification of commercial sample collection services currently operating in the area. Initial contacts with operators to solicit participation in the study will occur during November through February 2000. Contingent on cooperation of enough operators to create a representative sampling design, sample collection would be conducted during March through August 2001.

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Page 113 -2- Response to National Research Council Recommendations Committee on the Waste Isolation Pilot Plant – Interim Report II. Waste Characterization Recommendation: “DOE should eliminate self-imposed waste characterization requirements that lack a legal or safety basis.” Response: DOE agrees with this recommendation. DOE has developed and begun the implementation of a strategy to systematically improve the Waste Analysis Plan by reducing the frequency of waste characterization and implementing methods that make characterization simpler, less expensive and, above all, safer. On August 8, 2000, the New Mexico Environment Department approved two packages of Class 2 modifications to the WIPP's Hazardous Waste Facility Permit. These two packages include three requests submitted on April 5, 2000 and three submitted April 20, 2000. Approval of these modifications results in significant cost savings associated with waste characterization and will reduce radiation exposures to workers. A summary of the approved modifications follows: The “miscertification rate” of TRU waste was revised to apply to the waste summary category group instead of each waste stream. This results in a ten-fold reduction in number of drums that must be opened for visual examination (VE). The solids sampling requirements for analysis of VOCs have been revised to allow use of one subsample instead of three subsamples. This will avoid a cost of approximately ten million dollars that INEEL would have had to spend in re-analyzing the samples. The number of headspace gas samples required has been reduced for two types of waste streams to a statistically selected number of drums, instead of 100% sampling. The two types of waste streams now eligible for statistical headspace gas sampling are wastes that have been thermally processed and homogeneous wastes with “acceptable knowledge” that demonstrates no volatile organic compounds have been present in the waste. Several modifications have been prepared and submitted that specifically address safety issues associated with TRU waste handling and disposal. One such modification, submitted in October 2000, will allow generators to remove from consideration for VE any containers that pose a safety concern. For example, if a generator determines that opening a container with a high fissile gram content is a safety hazard, that container can be ruled ineligible for VE and another container selected.

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Page 114 -3- Path Forward: The next modification request, which will be submitted in November 2000, will provide alternatives to VE as a quality control check on radiography. Should the modification be granted, DOE intends to implement this change across the complex. The Permit modification requesting authorization for remote handled waste disposal at WIPP (to be submitted in December 2000) presents a performance based waste analysis plan that emphasizes the use of nonintrusive characterization techniques and eliminates the need for headspace gas sampling and analysis, solids sampling and analysis, VE, and other confirmatory measurements. The DOE also plans to collect data from waste characterization activities that will allow the systematic reduction or elimination of headspace gas sampling, solids sampling, VE, and radiography. These changes will be promptly implemented as suitable supporting data are identified.

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Page 115 -4- Response to National Research Council Recommendations Committee on the Waste Isolation Pilot Plant – Interim Report III. A Derive A More Realistic Gas Generation Model Recommendation: “DOE should derive a more realistic radiolytic gas generation model, validate it through confirmatory testing, use the results to recalculate gas generation limits, and seek regulatory approval to implement these limits.” Response: DOE agrees with this recommendation. An application for Revision 19 of the TRUPACT-II Safety Analysis Report was submitted to the Nuclear Regulatory Commission in April 2000. Among other things, the application includes the following: Matrix Depletion – The g-values of organic materials decline as a function of absorbed radiation dose. Testing performed at Los Alamos National Laboratory demonstrated that the g-value of polyethylene declines from an initial g-value of 3.4 to 1.1. The application requests the use of the lower g-value. When approved this new g-value will increase the allowable wattage up to a factor of 3 (depending on the packaging configuration). Option for the mixing of shipping categories that will allow the sites to ship payloads with different waste forms and to take credit for the use of dunnage containers (additional void volume and reduced gas concentrations). Use of more realistic g-values to take credit for non-gas generating materials present in the waste, based on percentages of moisture or organic material present. The previous model assumed a worst-case, 100% moisture/organic material scenario. (This change has been approved by the Nuclear Regulatory Commission.) Use of a new shipping category notation that accurately reflects the packaging configuration of the waste. The previous notation grouped all sites under selected worst-case packaging configurations. (This change has been approved by the Nuclear Regulatory Commission.) Path Forward: The application for Revision 19 was submitted to the Nuclear Regulatory Commission in April 2000 and is scheduled for approval in January 2001. We believe this to be a very responsive review cycle. Taken as a whole, Revisions 17, 18, and 19 provide an increase of up to 100 times the wattage that was allowed under Revision 16.

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Page 116 -5- Response to National Research Council Recommendations Committee on the Waste Isolation Pilot Plant – Interim Report III.B Safety Analysis to Determine the Damaging Concentration of Hydrogen Recommendation: “DOE should perform a safety analysis to determine the concentration and quantity of hydrogen that, upon ignition, could damage the seals of the TRUPACT-II shipping container. The goal of the safety analysis would be to demonstrate whether such an event could occur inside a waste package, and whether the energy associated with such an event could result in the rupture of containment provided by the TRUPACT-II. This analysis could provide the rationale to obtain relief from the 5 percent hydrogen flammability limit and should form the basis for a future modification to the present TRUPACT-II license.” Response: DOE agrees with the recommendation. Performing the safety analysis, which may include testing, would be the first step toward an application. Preliminary review of the recommendation has raised an issue of handling drums at the WIPP that could have a potentially flammable gas mixture. The safety analysis should be extended to waste handling operations at WIPP. If the safety analysis indicates that there is not a safety concern, then an application would be submitted to the Nuclear Regulatory Commission for their review and approval. One proposed solution is to encapsulate the waste in a manner that would contain any detonation that might occur. It is noted that there is no precedence for Nuclear Regulatory Commission approval of shipment of a flammable gas and radioactive material in the same package. Also, the U.S. Department of Transportation (DOT) prohibition against shipping containers of flammable gas and radioactive material on the same vehicle if they could co-mingle would have to be addressed. Path Forward: The following steps will be pursued to respond to this recommendation: Perform a safety analysis to determine whether WIPP could unload drums of waste that contained flammable gas. Assess ArrowPAKtm suitability for macro-encapsulation to contain potential deflagration events. Determine the incremental quantity of waste that could benefit from implementation of this recommendation (assuming the current application for Revision 19 to the TRUPACT-II Safety Analysis Report is approved). Perform the recommended analysis and/or testing. Prepare an application and submit to the Nuclear Regulatory Commission for review. Seek DOT concurrence.

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Page 117 -6- Response to National Research Council Recommendations Committee on the Waste Isolation Pilot Plant – Interim Report III.C Technical Approaches to Reduce Hazards Such As Inert Gas Recommendation: “DOE should consider technical approaches for reducing hazards from hydrogen generation, such as filling the headspace of the waste containers or the shipping containers with an inert gas to displace air and thereby reduce the flammability hazard.” Response: DOE agrees with this recommendation and is actively pursuing several alternative technologies such as hydrogen “getters.” There are several technical issues associated with this recommendation that would have to be investigated: Would a drum containing multiple layers of confinement around the TRU waste benefit from the proposed technology; e.g., inert gas in the drum headspace? Does the proposed technology require opening individual payload containers or does it apply to the TRUPACT-II; i.e. inert the TRUPACT-II ICV headspace? Does the proposed technology prevent or mitigate detonation/deflagration inside multiple layers of confinement or inside the TRUPACT-II? (See recommendation III.B above.) A method of measuring the flammable gas concentration in the headspace of a 55-gallon drum has been included in the application for Revision 19 of the TRUPACT-II Safety Analysis Report. This only requires a single measurement that can be made in real-time instead of a lengthy gas generation rate test that requires measuring the rate of change of hydrogen gas over several hours or days. Path Forward: The following steps will be pursued to respond to this recommendation: Alternative technical recommendations such as inert gas or hydrogen getters will be considered and a report prepared. Perform analysis and/or testing of those alternative, technologies that look promising. Submit an application to the NRC for any technologies that can be supported by analysis or test results.

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Page 118 -7- Response to National Research Council Recommendations Committee on the Waste Isolation Pilot Plant – Interim Report III.D Reevaluate the Feasibility of Rail Recommendation : “DOE should reevaluate the technical and regulatory feasibility of shipping high-wattage TRU waste using ATMX railcar shipping system.” Response: DOE agrees with the recommendation to reconsider the use of rail. DOE is currently reviewing a recently commissioned rail study report (included as an attachment). The report concluded that shipment of TRUPACT-II by rail is not cost effective unless significantly reduced rail rates are available. The report also recommended investigation of a new shipping package (TRUPACT-III) for shipping high wattage waste and oversize boxes by rail or truck. DOE has not made a decision regarding the use of ATMX railcar for shipments to WIPP. Using ATMX would require one of the following to occur: 1. Approval by the NRC – this would require exemption(s) from several of the requirements in 10 CFR 71. Or, 2. Revision of the Consultation and Cooperation Agreement between the State of New Mexico and DOE, plus revision to the WIPP Land Withdrawal Act. Path Forward : The following steps will be pursued to respond to this recommendation: Determine the incremental inventory of TRU waste that could benefit from rail shipment (assuming the current application for Revision 19 to the TRUPACT-II Safety Analysis Report is approved). Evaluate and compare the benefits and regulatory difficulty of two options – TRUPACT-III vs. ATMX. Make a decision based on information obtained. Proceed with the chosen option.

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Page 119 -8- Response to National Research Council Recommendations Committee on the Waste Isolation Pilot Plant – Interim Report IV. DOE's Communication and Notification Program Recommendation: DOE should consider cost-effective ways to improve the reliability and ease of use of the TRANSCOM system, either by improving or replacing it utilizing current technologies, and ensure the future system meets the WIPP and other stakeholders needs. Response: DOE agrees with the recommendations and, in fact, has been working toward this effort since mid-1998. On September 12, 2000 in Albuquerque NM, the DOE National Transportation Program-Albuquerque (NTPA) presented a response to the Interim Report recommendations. Committee members represented were Dr. Mark Abkowitz and Mr. Al Gruella. The presentation included improvements to the present TRANSCOM system and a demonstration of the new web-based TRANSCOM2000 system. NTPA has identified the problems and has provided resolution that has increased reliability and stability of the present client server Windows-based system for over 7 months. These problems included difficulty in logging in, extended download times, loss of positional data, and date and time anomalies. Feedback from system users indicates that the system provides, consistently reliable and accurate information, is more user friendly, and is meeting the needs of our customers. Customer complaints related to using the client-server version have been reduced to a very rare occurrence. In May 1999, NTPA hosted a TRANSCOM user application design session to team with DOE, State and Tribal TRANSCOM users, to develop system requirements for a new Internet-based communications and tracking system. In August 2000, the new application was beta-tested and discrepancies were identified and addressed. TRANSCOM2000 uses various commercial state-of-the-art Internet compatible software elements. These include: Object F/X GIS mapping software and engine, QTRACS satellite positional and two-way communications software, Oracle Relational DBMS 8I, Oracle Report and Oracle Forms 6I. The TRANSCOM Communications Center will have up-to-the-minute satellite weather service available. Security elements on the new application include native Oracle encryption, operation on the Secure Socket Layer (SSL), and multiple layers of application access security down to the database level. A firewall will also reside between the public and the application server.

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Page 120 -9- Positional update information will be received via frame-relay between the satellite service provider and the TRANSCOM2000 database. These positional updates will be requested every 2 minutes and should be available to the users on average of 2-5 minute intervals. Path Forward : The estimated schedule for implementation of the TRANSCOM2000 is mentioned below. Firewall configuration and connectivity to the WIPP has been established. The WIPP Central Monitoring Room operators will be trained during the initial implementation process. The Major Application Security and Test Plans are under development. These plans must be approved prior to implementation per DOE Order. Completion date: November 2000. DOE/AL Operations configuration: in process. Weather and Qtracs servers being installed, firewall server built and awaiting software installation, Operations Center fully staffed. Completion Date: November/December 2000. Demonstration of operational readiness: December 2000.

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Page 121 -10- Response to National Research Council Recommendations Committee on the Waste Isolation Pilot Plant – Interim Report V. DOE's Emergency Response Program Recommendation: The committee recommends that DOE explore with states and other interested parties how to develop processes and tools for maintaining up-to-date spatial information on the location, capabilities, and contact information of responders, medical facilities, recovery equipment, regional response teams, and other resources that might be needed to respond to a WIPP transportation incident. This assessment should explore which organization(s) should develop and maintain the capability to generate and maintain such information. DOE should also determine where emergency response capability is currently lacking, identify organization(s) responsible for addressing these deficiencies, and take action to address them. Response: The information that needs to be gathered and analyzed must come from the state, tribal, and local governments. According to preliminary telephone calls to the Western Governors' Association and the Federal Emergency Management Agency, there is not a national or state system that currently tracks the information that the Committee recommends the DOE collect and analyze. DOE must determine what level of participation the state, tribal and local governments are willing to have in the collection of this information and the maintaining of a database or reports. Logistically, the DOE will be trying to collect information from 30 states and 12 tribal governments which translates to data on over 100,000 emergency responders, and thousands of fire and police departments, ambulance services, and hospitals. Path Forward: DOE will send letters to the regional, state, and Indian Tribal governments with whom it has cooperative agreements, asking them to communicate the recommendation of the Committee to all of its affected members. They will be asked to analyze their current data collections systems, and to define their willingness to participate in a regular assessment as recommended by the Committee. They will further be asked to define their funding and manpower requirements, to submit the required data, and make counter recommendations that may fulfill the intent of the recommendation. This would include their recommendations on where the information is to be maintained and who will have the responsibility to analyze and make recommendations for improvement based on that data.

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