Improving Operations and Long-Term Safety of the Waste Isolation Pilot Plant: Final Report (2001)

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using these inputs together with their collective knowledge and experience. The report reflects a consensus of the committee and has been reviewed in accordance with NRC procedures.

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(NORM) in the vicinity of the WIPP site. Samples should be collected and analyzed for the radionuclides that will be present in transuranic waste emplaced at WIPP and the radionuclides common in NORM. These samples should be archived to permit subsequent analysis for constituents that may be of interest in the future. The committee recommends that a sampling plan be implemented prior to the closure of any underground rooms in WIPP that contain TRU waste.

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ing permits granted by external regulating authorities such as the Environmental Protection Agency and New Mexico Environment Department.

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fully reliable. Although efforts are being made by DOE to keep the system current, it has not kept pace with the rapid development of information technology. As a result, the TRANSCOM system is obsolete when compared to presently available communications systems.

Recommendations: DOE should consider cost-effective ways to improve the reliability and ease of use of the TRANSCOM system, either by improving or replacing it. If DOE decides to replace the current system, the committee strongly encourages the use or adaptation of existing commercial systems. In the near term, the DOE should develop an interim plan for maintaining an adequate communication and notification system until any such alternative system or TRANSCOM upgrade is ready for full-scale implementation. This plan should be driven by a comprehensive assessment of TRANSCOM component performance based on anticipated usage. In the long term, DOE should ensure that the system it employs is designed to meet the needs of WIPP shipment users and other major stakeholders in a timely and cost-effective fashion.

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As noted in the preface to this report, the first component of the statement of task is “to identify research activities that would enhance the assessment of long-term repository performance” (see Appendix A). The committee considers that data from radiological site characterization measurements would provide a necessary baseline to compare against future measurements, should the integrity of WIPP ever be challenged. This issue is explored in the next section.

The second component of the statement of task pertains to improvements of the DOE TRU waste management system. To address this issue, the committee sought to identify the technical, regulatory, legal, and/or safety bases of waste management activities that significantly impacted the overall system throughput, efficiency, cost, and safety. These issues are addressed in the last section of this report.

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FIGURE 1 Location of the Waste Isolation Pilot Plant. Inset shows the approximate location of the map area in New Mexico. SOURCE: NRC (1996, Figure 1.1.).

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sampling plan be implemented prior to the closure of any underground rooms in WIPP that contain TRU waste.

Rationale: Early studies discounted the potential for hydrocarbon production in the vicinity of WIPP, but over the past 20 years this way of thinking has changed dramatically. The site is now surrounded by wells (see Figure 2) for hydrocarbon production (Broadhead et al., 1995), and drilling activities continue. Furthermore, it is relatively common for brines associated with hydrocarbons to be radiogenic (Bloch and Key, 1981; Fisher, 1995). Oil-field brines in the Delaware Basin share this property (Fisher, 1995). The information available on oil-field brines and petroleum resources generally consists of gross radiation measurements (i.e., gross activity), rather than analytical data on the radionuclide constituents. Such analytical data on the radioactivity of oil-field brines and petroleum resources at the WIPP site have not been made available to the committee and may not exist.

If, during or after WIPP operations, increased radioactivity in the vicinity of WIPP is observed, is this the result of a failure of the WIPP to contain its waste, or is it due to NORM? This question cannot be answered easily unless the oil-field brines, petroleum, and solids associated with hydrocarbon production (e.g., suspended solids, precipitated scale, sludges, and formation fragments) are analyzed for their naturally occurring radiation. Analyses for radioactivity and radionuclides will be necessary if disputes arise about potential releases of radionuclides from the repository. An example of the need to obtain adequate NORM background data already has been observed with occurrences of natural surface contamination on the exterior of truck transportation packages while en route to WIPP during the first three months of operation.

“Human intrusion scenarios” involving hydrocarbon exploration and production are now considered processes through which radionuclides might be released from WIPP (Kirkes, 1998). If brines have a measurable NORM content, then human intrusion that results in brine flow through WIPP to the surface is a means by which radioactivity could be carried to the surface that is not due to the TRU waste emplaced in WIPP. If oil-field brine NORM is present, then it is conceivable that NORM releases would be greater than releases from the TRU waste contents of WIPP, even if drilling breaches the repository.

Transport and disposal of oil-field brines that have high NORM contents are also potential mechanisms for localized increases in radiation. Any such increases in radiation in the vicinity of WIPP cannot necessarily be attributed to WIPP operations or the failure of WIPP to contain its waste.

There are data suggesting that oil-field brines near WIPP might contain NORM. Otto (1989, reproduced in Fisher, 1995; see Figure 3)

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FIGURE 2 Petroleum wells in the vicinity of the WIPP site. See Figure 1 for an inset map showing the WIPP site's approximate location within New Mexico. SOURCE: Silva (1996, p. 24).

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FIGURE 3 Regions of high activity from NORM in the United States from (a) oil-producing facilities and (b) gas-producing facilities. Values are aggregated median differences over background. The legend shows various shadings corresponding to various ranges of dose rates measured in microrems per hour (µrem/h). These dose rates are radioactivity measurements of NORM deposits in piping and in fluids brought to the surface. These measurements describe the concentration of radioactive species, a characteristic of the NORM deposits at any locality that is not directly dependent on the local production rate (of hydrocarbons or brine) or on the amounts of fluid that were extracted to produce the deposits. SOURCE: Fisher (1995), after Otto (1989).

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shows the Delaware Basin of southeast New Mexico as a region of NORM activity in oil-and gas-producing facilities. Fisher states that “(1) not every major oil or gas field has associated high NORM levels, and (2) no major hydrocarbon-producing basin in Texas is exempt from high levels of radioactivity.” The major hydrocarbon-producing basins in Texas described by Fisher include the Delaware Basin, which contain producing formations near the WIPP site, and the adjacent Central Basin Platform (Hill, 1996, p. 26).

In response to committee requests for information, DOE has answered that no data have been collected on “naturally occurring radionuclides in the underground brines and hydrocarbons near WIPP by DOE. In addition, DOE is unaware of any related information collected by the oil and gas industry” (Mewhinney, 1998b).

The need for these data is clear—no effective monitoring of the WIPP area can be successful without understanding potential sources of radiation in the environment. Air, soils, sediments, ground and surface waters, biota, and people have been analyzed to provide a database (e.g., through CEMRC activities). NORM from local hydrocarbon operations must also be analyzed. The NORM data will

The committee recommends near-term action to collect and analyze these data based on an appropriate sampling plan. The plan must include frequency of sampling and analyses; radionuclides to be analyzed; collection of data to assess NORM radioactivity and to estimate its variability; sampling, analysis, and archiving protocols; and producing formations to be tested. These formations should include both past (if applicable) and present producing zones, new producing zones as they become exploited in the future, and formations from which brine is (or likely will be) extracted.

Samples could come from ongoing well-based operations that generate separator streams of oil, gas, and water. These separators and separator streams are owned by the operators of the leases. The drilling of new wells would be justified if data from separator streams prove to be inadequate.

The radionuclides of interest include both those that contribute to the site's NORM background radioactivity and those in the DOE TRU inventory destined for WIPP. The NORM activity may include contributions from potassium-40, isotopes of uranium and thorium, and daughter products such as isotopes of radium. Radionuclides in TRU waste include isotopes of uranium and TRU elements and, in remote-handled⁶ TRU

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waste, fission and activation products. Since some TRU inventory radionuclides are not commonly found in nature, sampling to determine whether such radionuclides are present in the environment may be a good way to distinguish radioactivity due to NORM from that due to TRU waste.

For the reasons given above, the committee supports the collection of NORM data on deep subsurface fluids, even though the isotopic signatures of NORM and TRU waste radioactivity are expected to differ and therefore to be readily distinguishable. In the committee's view, DOE would be better served to possess these NORM data prior to any reported discovery of significant radioactivity in the region; hence, in its recommendation the committee proposes that this survey to sample deep subsurface fluids be conducted in the near term. This survey need not continue once the measurement objectives, as proposed in this recommendation, have been met.

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erations and related worker safety issues at WIPP as posing no significant needs for waste characterization information, because no use of characterization data is made in any handling, shipping, or emplacement operations.

Recommendation : DOE should eliminate self-imposed waste characterization requirements that lack a legal or safety basis. One way to justify a reduction in waste characterization requirements is through implementation of joint U.S. Nuclear Regulatory Commission (USNRC)–U.S. Environmental Protection Agency (EPA) guidance (62 Federal Register 62079; see Appendix B), which appears to the committee to provide appropriate guidelines for implementation and integration of Resource Conservation and Recovery Act (RCRA) requirements for mixed TRU waste. Implementation of this regulatory guidance could significantly reduce the testing protocols and associated radiation exposure of personnel. Another way to justify a reduction is to identify the origins of all waste characterization requirements and to eliminate those requirements that lack a technical or safety basis. Such reductions may require modifications to existing permits granted by external regulating authorities such as the EPA and New Mexico Environment Department.

Rationale : The National TRU Program has developed waste restrictions, as described in the waste acceptance criteria (DOE, 1996a, 1999d), and requirements for waste generating sites presented in the quality assurance program plan (DOE, 1998b). These criteria and plans impose many required procedures on waste-generating sites. EPA and DOE Carlsbad Area Office audits are conducted to certify (i.e., approve for shipment) TRU waste streams. Additionally, each container of waste from a certified waste stream must be characterized, and shipping sites must prepare documentation on characterization data for each waste container. At the Los Alamos National Laboratory, the time to obtain all the requisite documentation and administrative approvals was greater than the time to process a drum of waste through the characterization and packaging protocols that had been developed. At all sites, the assembly, management, and storage of waste characterization information are resource-intensive activities, and drum handling is a major source of worker exposure. Of interest to the committee is the origin of these required procedures, because they increase the cost or risk or decrease the efficacy of operations.

The committee sought to identify the connection between the National TRU Program procedures and the various regulatory, legal, and technical requirements that the procedures should be devised to meet. The committee views these requirements in a hierarchy, at the top of which are legal and safety requirements, with regulatory specifications at the next tier, procedures proposed by DOE to meet regulatory requirements at the third tier, and the DOE protocols for these procedures at the fourth tier.

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The approach used by the committee was to focus on six primary National TRU Program procedures representative of high-level requirements that drive operational activities in waste characterization and repackaging (see Appendix A for an overview of these activities):⁹

These procedures are incorporated into the terms of the WIPP facility's RCRA “Part B” permit, which was issued in October 1999. The EPA guidelines that are specific to RCRA requirements are presented in Appendix B. However, the committee notes that the permit terms are subject to negotiation in a regulatory permitting process, based on the procedures proposed by DOE that became accepted as meeting regulatory requirements. A recent study (DOE, 1999c) has traced these and other TRU waste characterization requirements to their root origins in either (1) Carlsbad Area Office mandates, (2) regulatory certification and permit terms, (3) regulatory requirements or DOE orders, or (4) legal requirements.

A review of these six procedures revealed that one may be interpreted too strictly by DOE and three are without a technical or legal foundation:

Procedure 1: Determination that the TRU waste is of defense origin. WIPP is limited to defense-related waste as stipulated in the Land Withdrawal Act, with defense activities defined in the Nuclear Waste Policy Act of 1982. The committee notes that this definition includes the words “in whole or in part”, which can be interpreted to include mixtures of defense and nondefense waste, although DOE does not appear to take advantage of this (see DOE, 1997a; Nordhaus, 1996). That is, waste such as plutonium-238 (²³⁸Pu)-contaminated scrap from a facility used for both defense and nondefense missions at Los Alamos National Laboratory would appear to qualify as defense waste under the definition, without the need for waste segregation restrictions.

Procedure 2: Sampling and analysis of homogeneous waste. DOE has written, “There is no regulatory requirement to conduct homogeneous waste sampling and analysis, however, in an effort to meet the intent of 40 CFR 264.13, WIPP has imposed additional characterization requirements on the waste generators” (Nelson, 1999a, p. 2). No operational decisions are made based on these data; that is, the results of the sampling and analysis do not affect how waste is handled, so it is not clear what justifies the additional radiation exposure risk and cost of this procedure. In the committee's view, this sampling and analysis applied only to homogeneous waste is unnecessary: If acceptable knowledge documentation

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(see Appendix A) provides sufficient characterization information for heterogeneous waste, the committee can identify no technical reason why acceptable knowledge should not also be adequate for homogeneous waste.

Procedure 3: Headspace gas sampling and analysis. DOE informed the committee that “there is no regulatory requirement to conduct headspace gas sampling and analysis, however, in an effort to meet the intent of 40 CFR 264.13, WIPP has imposed additional characterization requirements on the waste generators” (Nelson, 1999a, p. 3). The headspace gas sampling and analysis was developed as a means of checking on conformance with USNRC and the U.S. Department of Transportation (DOT) requirements (see Appendix A for relevant sections of these regulations); however, these requirements can be met by other means (see the recommendations that follow on the issue of gas generation).

Procedure 6: Visual examination. Visual examination is done on a fraction of the waste containers to confirm the real-time radiography and acceptable knowledge waste characterization information (Nelson, 1999a, p. 5). However, there is no requirement for verification of real-time radiography results. An alternative way to confirm these results without operator exposure would be to use standardized test drums. The visual examination confirmation is a self-imposed procedure that yields no benefit but results in increased risk of exposure and cost.

A DOE study (1999c) also confirms that procedures 2, 3, and 6 identified above are based on terms negotiated in a permit and not on a required regulation or legal mandate. The committee sees no utility in the information that these procedures provide. Any speculative benefits of acquiring this information must be weighed against the risks and costs. The committee's judgment is that the collection of these data from superfluous procedures increases, rather than decreases, the risk and safety of the overall TRU waste operations.

These superfluous characterization and intrusive procedures also represent a conflict with the ALARA principle. The issue of how to handle conflict between regulatory requirements for waste characterization information and ALARA is beyond the scope of the committee's statement of task. At issue, however, is whether the present TRU waste management program results in significantly more worker radiation exposure than is justified to satisfy safety and nonnegotiable regulatory requirements.

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Recommendations:

The goal of these recommendations is to expedite the transport of TRU waste to WIPP by increasing the amount of waste that can be carried safely in each truckload or trainload, without compromising the level of safety and containment that is provided by the shipping container. These recommended options would reduce the number of truckloads required to transport the waste to WIPP and the associated transportation risks.

Rationale : The amount of TRU waste in each waste drum and truck shipment is limited because of the potential for radiolytic generation of hydrogen gas (H₂). Within TRU waste, radiolytic hydrogen gas generation is due primarily to the co-disposal of alpha emitters with organic materials. The DOE has developed a radiolysis model to calculate hydrogen generation rates and the hydrogen concentration in each headspace¹¹ inside a waste container. Limiting any H₂ concentration to 5 percent leads to a restriction, expressed as maximum allowable wattage, on alpha activity (i.e., the amount of alpha-emitting radionuclides) within each waste container (e.g., a 55-gallon drum). The value of 5 percent H₂ (as a mole

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fraction) in air as a “flammability limit” can be used in any USNRC license application on a transportation package without the need for further safety analysis because of its conservatism. This allowable wattage is a function of the G value¹² of the solid matrix of the waste materials adjacent to each alpha emitter and the total resistance to the flow of hydrogen gas that the waste and packaging contents provide, due primarily to the layers of plastic bags in the waste.

Wattage limits based on this model determine whether or not a waste container may be transported to WIPP without repackaging. The gas generation model, and the wattage limits derived from it, specify the terms of operation that are contained in the DOE safety analysis report for the TRUPACT-II transportation package. These terms of operation are also specified in DOE's application to the USNRC for regulatory approval of the TRUPACT-II transportation package. The certificate of compliance for TRUPACT-II issued by the USNRC is subject to modifications (and in fact has been amended several times since the original certificate was issued in the late 1980s), provided that DOE can offer sufficient adequate safety assurances and comply with applicable regulations, principally the USNRC's 10 CFR 70-71 and DOT's 49 CFR 171-173.

The current model is based on worst-case scenario of H₂ generation and wattage limits. Because of this worst-case approach and the extreme assumptions used in the model, the calculations often exceed experimental observations by orders of magnitude. The explanations for these large discrepancies are only beginning to be studied (see Idaho Engineering and Environmental Laboratory, 1998; Mewhinney, 1998a). Specific examples follow.

The results of these gas generation model assumptions have severe consequences.¹³ Repackaging is carried out to redistribute waste in containers (e.g., 55-gallon drums) in order to meet the wattage limits derived from the gas generation model for each container. This repackaging of waste exposes workers to radiation and increases the number of containers, thereby diluting the waste into a greater volume.

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Transportation-related risks (and costs) are also incurred in repackaging, because the extra containers require additional shipping loads with many additional truck trips. DOE estimates reveal that this repackaging of ²³⁸Pu contact-handled TRU waste may increase the number of ²³⁸Pu shipments by more than a factor of ten, to as many as 150,000 extra drums (Lechel and Leigh, 1998).¹⁴ Another consequence of such volume expansions that should be considered is the impact on WIPP's volume limit.¹⁵ Therefore, the maximum allowable wattage imposed by the gas generation model is a major technical restriction of the National TRU Program.

Recent information (DOE, 1999b; Gregory, 1999) suggests that significant progress is being made toward developing technical information to support planned future applications to the USNRC to amend the terms of the TRUPACT-II safety analysis report and certificate of compliance. Research continues to investigate the use of hydrogen getters¹⁶ (Mroz et al., 1997, 1999), methods for puncturing bags, use of vented bags (Gregory, 1999), and relief from the restrictive G values (Idaho Engineering and Environmental Laboratory, 1998).

To provide containment of its radioactive contents, the TRUPACT-II shipping container uses outer O-rings that generate a vacuum seal. In this package design, internally generated gas, such as H₂, builds up to pressurize the internal gas volume. Other transportation package designs are possible that are less sensitive than the TRUPACT-II to the potential for H₂ gas generation. One such system for transport of TRU wastes was the ATMX railcar system, which DOE used for hundreds of shipments over several decades to safely transport TRU waste from the Mound Laboratory in Ohio and from the Rocky Flats Environmental Technology Site in Colorado to the Idaho National Engineering and Environmental Laboratory. Based on the integrity provided by the railcar, this system was exempted (DOT exemption number DOT-E 5948) from the double-containment and vacuum seal requirements for packages used to transport plutonium (classified as “Type B” fissile packages). As a result, this system did not suffer limitations of the kind that are imposed on the TRUPACT-II due to radiolytic gas generated and trapped within the shipping container.

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nology companies and various institutions involved in emergency response monitoring in Colorado, Illinois, Pennsylvania, Idaho, Wyoming, Oregon, Arizona, North Carolina, and Utah) to a committee survey are shown below. On a scale of 1 to 5, with 1 = inadequate, 2 = poor, 3 = average, 4 = good, and 5 = excellent, the average scores for TRANSCOM system on five issues were as follows:

Most survey responders also wrote either explicitly or by using examples that the system was (1) unreliable (citing frequent downtime, connection or access problems, or other hardware or software problems), (2) not user friendly (citing features such as slow data rates, the time required to download information, and “old technology”), and (3) not economical because of the high costs for modem connections. Of those survey responders who had experience with at least one other transportation tracking system, each provided written comments attesting to the “unreliable” and/or “not user-friendly” features of TRANSCOM.

The committee concludes from this survey and from other materials received (e.g., presentations at committee meetings in October 1998, May 1999, and July 1999) that the TRANSCOM system has failed to give its users confidence in its reliability, ease of use, and the timeliness with which accurate information can be accessed. The committee regards these features as important for engendering public confidence and trust in WIPP's transportation program, especially for incidents in which some sort of emergency response is required.

The committee considers that given the potential interest in and visibility of WIPP shipments, the tracking system should provide reliable, real-time, and user-friendly access to information for the state users and other interested parties. In principle, this could be accomplished through upgrades to the current TRANSCOM system. However, rather than maintaining and upgrading a technically obsolete system, the committee believes that it would be more prudent for DOE to implement a less expensive, higher-quality system using a currently available commercial communications product (for a summary of transportation communication initiatives using information technology, see Allen [1998]). Careful screening of vendors is necessary to ensure that the desired system can perform to specification and be delivered on schedule and within budget.

Recent DOE efforts (Nelson, 1999b) are aimed at developing upgraded information technology capabilities (“TRANSCOM 2000”) for the TRANSCOM system. Specifically, modem connections to access data of interest (e.g., the commercial bill of lading for a shipment) are to be replaced in the near future by internet postings. These plans for improved user interface and data distribution capabilities do not address other parts of the system, such as the speed with which data are acquired and proc-

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essed prior to posting. These data acquisition and processing activities appear to introduce time delays that limit system performance; for example, position updates showing the locations of trucks along routes are delayed by several (up to seven) minutes (Nelson, 1999b). An as-yet-unspecified element of these planned upgrades is the extent to which future stakeholder participation will be solicited and used to provide sufficient feedback to ensure that the product ultimately developed addresses user concerns. Moreover, the timetable for off-the-shelf availability of TRANSCOM 2000 appears to the committee to be several years in the future, a problematic scenario for a WIPP shipping activity that is already underway.

One issue relevant to these planned information disclosures in TRANSCOM 2000 is the extent to which such information is needed or useful, by which parties, and to what ends. For example, the terrorist hazard and/or the potential for deliberate sabotage would presumably increase as this information is disseminated more broadly. If restricted access to certain information were important, security firewalls could be used to prevent internet information from being accessed outside of the TRANSCOM user community.

At present, the National TRU Program is one of many DOE users of the TRANSCOM system that is managed by another DOE program unit, the DOE transportation center in Albuquerque, New Mexico; other DOE transportation users include shippers of low-level waste and spent nuclear fuel. If the DOE transportation program that maintains TRANSCOM cannot provide sufficient improvements to fully implement the above recommendations, another approach would be for the National TRU Program to adapt a commercially available tracking system for use on WIPP shipments only. If the tracking system need only meet WIPP shipment requirements, the system specifications would likely be simpler, with a correspondingly greater likelihood that a commercially available product could be adapted for use. For example, WIPP shipments involve unclassified material, which may allow relief from the full suite of TRANSCOM system requirements that have been developed for all of DOE shipping needs.

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covery 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.

Rationale: To respond appropriately to any accident or other incident associated with a WIPP shipment, an emergency response system has been developed involving the DOE and state and local governments. Four levels of emergency response teams have been established. The first responders, typically the local police or local fire department, are to alert others. Their “911” call routes the incident to the attention of the second responders, the state emergency management agency, which then involves the state police and any state hazardous material (HAZMAT) or radiological response teams. The third responders are DOE Radiological Assistance Program teams that would be sent from major DOE sites (e.g., Idaho Engineering and Environmental Laboratory or the DOE Carlsbad Area Office) to conduct radiological emergency (medical) response. The fourth level of response is DOE remediation teams who perform measures such as righting a truck and any necessary site cleanup and restoration activities (DOE, 1998a).

Because of the required integrity of the TRUPACT-II shipping container, which is tested and certified to conform to the USNRC's 10 CFR 71 regulatory requirements, the containment offered by this container normally cannot be breached in an accident scenario. Therefore, emergency response procedures in these four levels of response normally would preclude any consideration of releases of materials from the TRUPACT-II. Under normal conditions, the emergency response procedures would still be needed for traffic management and other necessary operations in accident-related situations.

DOE's emergency response program relies heavily on WIPP corridor states to conduct emergency responder training and develop response plans in the event of a transportation incident. DOE also maintains its own specialized response capabilities that can be deployed on an as-needed basis. Although this approach offers certain advantages in terms of state and local involvement, system-level integration is a significant concern.

Maintaining an effective emergency response program necessitates that, if an incident should occur anywhere along a WIPP route, qualified responders can reach the scene in a timely fashion. Emergency preparedness is a formidable challenge given the thousands of miles of highway that comprise WIPP routes.

While WIPP corridor states are coordinating with DOE to ensure the safe transport of WIPP shipments¹⁸ (DOE, 1995, 1999b; Klaus, 1999; Ross, 1999; Wentz, 1999), the public may view this responsibility as ulti-

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mately resting with DOE as the system manager. The public might well expect qualified emergency response coverage along the entire length of each WIPP route, and in the committee's view, DOE could be heavily criticized if an event occurs that demonstrates weaknesses in the emergency response program, regardless of whether serious consequences are involved. Hence, although the recommendations in this section are not legal requirements, these assessments of the emergency response capabilities are, in the committee's view, important for providing a well-orchestrated transportation system.

The system-level integration necessary to ensure adequate emergency response would have to manage the jurisdictional boundaries between the various responsible government agencies. For example, under the federal Occupational Safety and Health Act (specifically, 29 CFR 1910.120), an employer is responsible for providing training; consequently, the state has the responsibility to determine the extent and adequacy of training (i.e., who is trained and in what capabilities) for first- and second-level responders. States have, to date, offered free WIPP-related training opportunities. No “quality assurance” program yet exists to evaluate periodically and systematically the extent of training and response capabilities within states. Moreover, the database lists trained personnel by state only, rather than by local region (e.g., county). As required by the Land Withdrawal Act, DOE provides the states with WIPP-specific hazard information, but DOE does not furnish protective, detection, monitoring, or communication equipment to states.

These and other demarcations of responsibilities should be managed to ensure that prompt and effective response capability for any transportation incident exists anywhere along a WIPP route. Although the training and response time associated with the first and second responders are not under DOE's direct control, a system to assess the extent and adequacy of this response coverage would be useful for DOE to properly prepare for and manage WIPP transportation incidents.

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As experience is gained in the WIPP shipping program, empirical data could be gathered to improve upon the initial estimates of risk and cost that are associated with each operation. The effort to reduce risks and costs necessarily would include some consideration of uncertainty, the procedures needed to adequately bound this uncertainty, and an assessment of which TRU waste program elements are the most important to control.

For example, the current National TRU Program has many procedures to control certain program elements. Over time, the most effective of such controls could be identified and retained. The reduction of risks and costs is possible in a management approach that takes into consideration public preferences for certain restrictions and implements procedures to minimize relevant uncertainties. As empirical data and experience are gathered, estimates of risks and costs of various components of the TRU waste operations can be refined. Such risk and cost estimates are useful to probe the elements of the waste management system that need to be controlled most restrictively, whether to meet legal or technical safety restrictions or to address public preferences for how radioactive waste is to be managed and transported.

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Gregory, P. 1999. Gas generation model for TRUPACT-II. Presentation to the Committee on the Waste Isolation Pilot Plant. Albuquerque, N. Mex. July 26.

Herczeg, A. L., H. J. Simpson, R. F. Anderson, R. M. Trier, G. G. Mathieu, and B. L. Deck. 1988. Uranium and radium mobility in groundwaters and brines within the Delaware Basin, southeastern New Mexico, U.S.A. Chemical Geology. Vol.72: 181-196.

Hill, C. A. 1996. Geology of the Delaware Basin, Guadalupe, Apache, and Glass Mountains, New Mexico and West Texas: Permian Basin Section. Midland, Tx. Society for Sedimentary Geology Publication No. 96-39, 480 pp

Idaho National Engineering and Environmental Laboratory (INEEL). 1998. TRUPACT-II Matrix Depletion Program Final Report. INEEL/EXT-98-00987. Rev. 0. September.

Kenney, J., J. Rodgers, J. Chapman, and K. Shenk. 1990. Preoperational Radiation Surveillance of the WIPP Project by EEG, 1985-1988 (EEG-43). Albuquerque, N. Mex.: Environmental Evaluation Group.

Kenney, J. W. 1991. Preoperational Radiation Surveillance of the WIPP Project by EEG During 1990 (EEG-49). Albuquerque, N. Mex.: Environmental Evaluation Group.

Kenney, J. W. 1992. Preoperational Radiation Surveillance of the WIPP Project by EEG During 1991 (EEG-51). Albuquerque, N. Mex.: Environmental Evaluation Group.

Kenney, J. W. 1994. Preoperational Radiation Surveillance of the WIPP Project by EEG During 1992 (EEG-54). N. Mex.: Environmental Evaluation Group.

Kenney, J. W., and S. C. Ballard. 1990. Preoperational Radiation Surveillance of the WIPP Project by EEG During 1989 (EEG-47). Albuquerque, N. Mex.: Environmental Evaluation Group.

Kenney, J. W., P. S. Downes, D. H. Gray, and S. C. Ballard. 1995. Radionuclide Baseline in Soil Near Project Gnome and the Waste Isolation Pilot Plant (EEG-58). Albuquerque, N. Mex.: Environmental Evaluation Group.

Kenney, J. W., D. H. Gray, and S. C. Ballard. 1998. Preoperational Radiation Surveillance of the WIPP Project by EEG During 1993 Through 1995 (EEG-67). Albuquerque, N. Mex.: Environmental Evaluation Group.

Kenney, J. W., D. H. Gray, S. C. Ballard, and L. Chaturvedi. 1999. Preoperational Radiation Surveillance of the WIPP Project by EEG from 1996-1998 (EEG-73). Albuquerque, N. Mex.: Environmental Evaluation Group.

Kirkes, R. 1998. Resource extraction near WIPP—A status of current industry practice. Westinghouse Electric Company report to the Committee on the Waste Isolation Pilot Plant. Albuquerque, N. Mex. August 18.

Klaus, J. 1999. Presentation to the Committee on the Waste Isolation Pilot Plant. Albuquerque, N. Mex. July 26.

Lechel, D. J., and C. D. Leigh. 1998. Plutonium-238 Transuranic Waste Decision Analysis. SAND98-2629. Albuquerque, N. Mex.: Sandia National Laboratories.

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Mewhinney, J. A. 1998a. Letter to Thomas Kiess. October 7, and enclosures.

Mewhinney, J. A. 1998b. Letter to Thomas Kiess. December 15, and enclosures.

Mroz, E., S. Kosiewicz, D. Finnegan, C. Leibman, S. Djordjevic, C. Loehr, and J. Weinrach. 1997. Increasing TRUPACT-II wattage limits: Two technical approaches. Technology: Journal of the Franklin Institute. Vol. 334A: 357-363.

Mroz, E., D. Finnegan, P. Noll, S. Djordjevic, C. Loehr, C. Banjac, J. Weinrach, J. Kinker, and M. Connolly. 1999. Increasing TRUPACT-II wattage limits: Hydrogen G-Values and getters. Presentation at Waste Management '99. Tucson, Ariz. March.

National Research Council. 1996. The Waste Isolation Pilot Plant: A Potential Solution for the Disposal of Transuranic Waste. Washington, D.C.: National Academy Press.

Neill, R. H., L. Chaturvedi, D. F. Rucker, M. K. Silva, B. A. Walker, J. K. Channell, and T. M. Clemo. 1998. Evaluation of the WIPP Project's Compliance with the EPA Radiaton Protection Standards for the Disposal of Transuranic Waste (EEG-68). Albuquerque, N. Mex.: Environmental Evaluation Group, 291 pp. , plus appendixes.

Nelson, R. 1999a. E-mail correspondence to committee containing attachment of summaries of regulatory drivers for certain characterization activities. Carlsbad, N. Mex.: Department of Energy. May 11.

Nelson, R. 1999b. E-mail correspondence to committee containing attachment of TRANSCOM and TRANSCOM 2000 Report. Carlsbad, N. Mex.: Department of Energy. October 21.

Nordhaus, R. 1996. Department of Energy memorandum. Interpretation of the term “Atomic Energy Defense Activities” as used in the Waste Isolation Pilot Plant Land Withdrawal Act. September 9.

Olson, W. C. 1999. Letter to Thomas Kiess on New Mexico NORMS regulations. May 19, with attachment.

Otto, G. H. 1989. A national survey on naturally occurring radioactive materials (NORM) in petroleum producing and gas processing facilities. Report to the American Petroleum Institute, 265 pp

Ramey, D. S. 1985. Chemistry of Rustler Fluids (EEG-31). Environmental Evaluation Group. Albuquerque, N. Mex.: Environmental Improvement Division Health and Environment Department State of New Mexico.

Ross, R. 1999. Presentation to the Committee on the Waste Isolation Pilot Plant. Albuquerque, N. Mex. July 26.

Silva, M. K. 1996. Fluid injection for salt water disposal and enhanced oil recovery as a potential problem for the WIPP. Proceedings of a June 1995 Workshop and Analysis (EEG-62). Albuquerque, N. Mex.: Environmental Evaluation Group, 177 pp

U.S. Department of Energy. 1995. Emergency Planning, Response, and Recovery: Roles and Responsibilities for TRU Waste Transportation Incidents. DOE./CAO-94-1039. Carlsbad, N. Mex.

U.S. Department of Energy. 1996a. Waste Acceptance Criteria for the Waste Isolation Pilot Plant. DOE/WIPP-069. Rev. 5. Carlsbad, N. Mex.

U.S. Department of Energy. 1996b. TRUPACT-II Content Codes (TRUCON). DOE/WIPP 89-004. Rev. 10. December.

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U. S. Department of Energy. 1997a. Carlsbad Area Office Interim Guidance on Ensuring that Waste Qualifies for Disposal at the Waste Isolation Pilot Plant. February 13.

U.S. Department of Energy. 1997b. Safety Analysis Report for the TRUPACT-II Shipping Package. Rev. 16. February.

U.S. Department of Energy. 1997c. Waste Isolation Pilot Plant Annual Site Environmental Report Calendar Year 1996: Waste Isolation Division. Westinghouse Electric Corp. Report. DOE/WIPP 97-2225, 9 chapters.

U.S. Department of Energy. 1998a. Waste Isolation Pilot Plant Transportation Plan. DOE/CAO 98-3103. Rev. 0 November 10.

U.S. Department of Energy. 1998b. Transuranic Waste Characterization Quality Assurance Program Plan. CAO-94-1010. Rev. 1.0 December 18.

U.S. Department of Energy. 1999a. DOE Order 435.1. http://www.explorer.doe.gov:1776/htmls/reqs/doe/newserieslist.html. Washington, D.C.

U.S. Department of Energy. 1999b. DOE Responses to Requests for Information from the National Academies Committee on the Waste Isolation Pilot Plant. July 22.

U.S. Department of Energy. 1999c. Findings and Recommendations of the Transuranic Waste Characterization Task Force. Final Report. August 9.

U.S. Department of Energy. 1999d. Waste Acceptance Criteria for the Waste Isolation Pilot Plant. Revision 7. DOE/WIPP-069.

Wentz, C. 1999. Presentation to the Committee on the Waste Isolation Pilot Plant. Albuquerque, N. Mex. July 26.

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recertifications. Changing some of the repository features (e.g., the design of the engineered seals to close underground rooms once they are filled with waste or the design of the seals to close the vertical shafts to the surface) would require regulatory approval because of their importance to the model of long-term performance.

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characterization information on the waste constituents. The DOE Carlsbad Area Office and EPA use the acceptable knowledge documentation to certify each “waste stream” (i.e., waste-generating process), and TRU waste sent to WIPP must come from a certified waste stream.

Sampling and Analysis of Homogeneous Waste for RCRA Constituents. Most of the TRU waste is heterogeneous in nature and requires no further characterization beyond acceptable knowledge to satisfy the regulatory requirements of RCRA. For homogeneous waste, a fraction of the waste containers (e.g., 55-gallon drums or standard waste boxes) are cored to extract representative samples that are analyzed for constituents (e.g., volatile and semi-volatile organic compounds, toxic metals, and other hazardous chemicals) regulated by RCRA. Both the acceptable knowledge procedure (for heterogeneous waste) and the sampling and analysis procedure (for homogeneous waste) were proposed by DOE for the terms of operation that would be specified in its RCRA Part B permit. These terms have been accepted by New Mexico, which has authority delegated by the EPA to regulate RCRA materials and mixed waste and which issued the RCRA Part B permit in October 1999.

Real-Time Radiography. A real-time radiography procedure using x-rays is performed on all waste containers to look for items such as pressurized cans or free-standing liquids that are prohibited from being transported under DOT regulations. If any of these items are present in a waste container, its contents are repackaged, at which time the prohibited materials are removed. Another purpose of the radiography examination is to confirm the acceptable knowledge characterization information.

Visual Examination. A visual examination is performed on a fraction of the waste containers, by spilling the waste contents into a glovebox, to verify the acceptable knowledge and real-time radiography information. The value of this fraction was proposed by DOE to be two percent of the initial population of containers of each waste stream, and if these evaluations resulted in few miscertifications, then the percentage of subsequent waste containers to undergo visual examination would be reduced. In October 1999, New Mexico in its RCRA Part B permit stipulated the initial fraction of containers to undergo visual examination to be 11 percent.

Radioassay and Determination of Fissile Isotope Content. The number of curies of each transuranic isotope is determined by radioassay (e.g., gamma scans) to a specified precision and accuracy. The fissile isotope content is assessed using methods such as passive-active neutron systems. This information is used to ensure criticality safety, a USNRC requirement, which imposes a restriction on the amount (several hundred grams) of each fissile species per container. This restriction is less stringent than the amount derived from the gas generation model, discussed below.

Headspace Gas Sampling. Headspace gas sampling is carried out on all waste containers for flammable gases (specifically, volatile organic compounds, hydrogen, and methane). This procedure has been proposed

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as a means of checking on conformity with the DOT regulations (e.g., 40 CFR 173 and 40 CFR 177) and USNRC regulations (e.g., 10 CFR 71) that address the transport of flammable and/or gas-generating substances with radioactive materials (Mewhinney, 1998b). These regulations include the following statements:

DOE has proposed the headspace gas sampling procedure in its application to the USNRC for a licensing certificate on the transportation package (named the TRansUranic PACkage Transporter, or TRUPACT-II) that is loaded with waste containers for transport by truck to WIPP.

Repackaging of Waste to Meet Wattage Limits Imposed by a Radiolytic Gas Generation Model. Gas generation can occur during the transport of a waste container to WIPP. The radiolytic generation of hydrogen gas in TRU waste comes from the co-disposal of organic materials (containing hydrogen) with alpha-emitting radionuclides, which irradiate the organic matter to produce H⁺ ions that combine to form H₂ molecules. The current gas generation model is based on assumptions about the configuration of organic materials and radionuclides. It relates the concentration of hydrogen gas in any headspace to the alpha activity (i.e., activity from alpha-emitting radionuclides) within each waste container. More than one gaseous headspace can exist in a waste container, palmarily because TRU waste, when generated and disposed in DOE facilities, was contained within layers of confinement provided by plastic bags that may still be intact and thereby inhibit the flow of hydrogen.

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By placing a 5 percent (mole fraction) limit on the maximum H₂ concentration within any headspace, this gas generation model calculates an upper limit, commonly expressed as a maximum thermal wattage, on the alpha activity allowed for the entire waste container. These wattage limits are a function of the waste materials and the number of layers of confinement provided by plastic bags. Because of its conservatism, the value of 5 percent H₂ (as a mole fraction) in air as a “flammability limit” can be used in any USNRC license application for a transportation package without the need for further safety analysis.

For example, for a 55-gallon drum containing a plastic liner and heterogeneous debris with plutonium inside three layers of sealed plastic bags, the wattage limit is approximately 0.028 W (DOE, 1996b, p. 5-6e), which corresponds to a limit of 14 g (0.89 Ci) of plutonium-239 or 0.049 g (0.84 Ci) of plutonium-238. Waste containers containing more wattage than the maximum value allowed by the model have their waste contents repackaged to distribute the TRU waste into configurations that will meet these wattage limits. This is accomplished by spilling these contents into shielded gloveboxes and dividing the waste into several new containers, each filled with a fraction of the contents of the original waste container. At Los Alamos National Laboratory in 1998-1999, gas generation restrictions resulted in the repackaging of 36 drums of plutonium-238 waste from the waste stream “TA-55-43” into approximately 120 drums that were placed inside standard waste boxes.⁴

The output of the characterization program is a set of characterization data for each waste container. If the characterization information is within acceptable limits as determined by the waste acceptance criteria and quality assurance program plan (or waste analysis plan) specifications, the waste container is certified and approved for shipment to WIPP.

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The trucks travel to WIPP on approved highway routes during approved times and maintain communication with a DOE control center. In addition to a cellular telephone and a citizens band radio, each truck contains a satellite transponder that enables it to be tracked en route using DOE's satellite-based telecommunications system, the TRANSportation Tracking and COMmunication (TRANSCOM) System. The TRUPACT-IIs are inspected at the WIPP site and their contents (waste-filled drums or boxes) are unloaded and delivered to an underground elevator for emplacement into rooms excavated in the subsurface salt bed.

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and quality assurance program plan documents and in the RCRA Part B permit for the testing of mixed waste seem at odds with the ALARA (as low as reasonably achievable) principle.

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ice and eminent achievement in the field of radioactive waste management.

Michael Hardy, president of Agapito Associates, Inc., has experience in numerical modeling and field experimentation in practical, engineeringoriented studies to gather characterization data and to evaluate the merits of design features of proposed high-level waste repositories. Dr. Hardy is a member of the Society of Mining, Metallurgical and Exploration Engineers, Inc., and the American Society of Civil Engineers (ASCE). He is Chairman of the Underground Technical Research Council, a joint ASCE/American Institute of Mining, Metallurgical, and Petroleum Engineers Committee.

Stanley Kaplan, principal of Kaplan & Associates, Inc., is one of the early practitioners of the discipline now known as Quantitative Risk Assessment and a major contributor to its theory, language, philosophy and methodology. Dr. Kaplan is a Fellow of the Society for Risk Analysis and the author of a number of the seminal papers in this field. He is one of the first contributors to the Russian science TRIZ, the Theory of the Solution of Inventive Problems, and currently consults and teaches in this area. He is a founder and board chairman of Bayesian Systems, Inc., a Washington-based company developing diagnostic, decision, simulation, and business management software. Dr. Kaplan is the recipient of several awards and honors, including the Society for Risk Analysis Distinguished Achievement Award in 1996. Dr. Kaplan was elected to the National Academy of Engineering in 1999.

Howard M. ‘Skip' Kingston is professor of chemistry in the Department of Chemistry and Biochemistry and in the Center for Environmental Research and Education. Also at Duquesne University, he is director of the Center for Microwave and Analytical Chemistry. His research interests include the development, automation, and standard encapsulation and transfer of analytical analysis methods. For the past several years, he has been actively involved in advancing the area of microwave sample preparation through basic research and the development of procedures that have been adopted by the EPA as standard methods. From 1976 to 1991 he was a supervisory research chemist in the Inorganic Analytical Research Division of the National Institute of Standards and Technology (NIST), where he conceived and managed the Consortium on Automated Analytical Laboratory Systems dedicated to developing automated analytical capability for industry. He has received numerous awards for his pioneering work in several areas, including R&D 100 Awards in 1996 and 1998, the IR 100 Award in 1987, the 1988 “Pioneer in Laboratory Robotics” award, the 1990 NIST Applied Research Award, the Department of Commerce Bronze Medal in 1990, the Award of Merit from the Federal Laboratory Consortium in 1991, and the EPA RCRA Service to Others Award in 1998. He has co-edited and co-authored the American Chemical Society professional reference texts Introduction to Microwave Sample Preparation: Theory and Practice (1988) and Microwave Enhanced Chemistry: Fundamentals, Sample Preparation, and Applications (1997).

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He holds multiple patents in the field of speciation, microwave chemistry, and chelation chromatography.

W. John Lee, Peterson Chair and professor of petroleum engineering at Texas A&M University and formerly executive vice-president of technology at S. A. Holditch & Associates, Inc., has expertise in petroleum reservoir imaging, flow tests in low-permeability formations, and enhanced recovery practices. Professor Lee was elected to the National Academy of Engineering in 1993.

Milton Levenson, independent consultant, is a chemical engineer with over 50 years of experience in nuclear energy and related fields. His technical experience includes work in nuclear safety, fuel cycle, water reactor technology, advanced reactor technology, remote control technology, and sodium reactor technology. His professional experience includes research and operations positions at Oak Ridge National Laboratory, Argonne National Laboratory, the Electric Power Research Institute, and Bechtel. Mr. Levenson is the past president of the American Nuclear Society; a fellow of the American Nuclear Society and the American Institute of Chemical Engineers; and the recipient of the American Institute of Chemical Engineers' Robert E. Wilson Award. He is the author of over 150 publications and presentations and holds three U.S. patents. He received his B.Ch.E. from the University of Minnesota. He was elected to the National Academy of Engineering in 1976.

Werner F. Lutze, professor of chemical and nuclear engineering at the University of New Mexico and director of the UNM Center for Radioactive Waste Management (CeRaM), has over 25 years of research experience in materials science and geochemical issues relevant to the management of radioactive wastes, including selective mineral ion-exchange processes, repository near-field chemistry, waste form development, and trace analyses. He has published widely on weapons plutonium immobilization, waste disposal, and the chemistry of nuclear materials. Professor Lutze is a member of several professional organizations, including the Materials Research Society, the German Nuclear Society, and Sigma Xi.

Kimberly Ogden, associate professor of chemical and environmental engineering at the University of Arizona, has conducted research with Los Alamos National Laboratory collaborators to design treatment methods for remediating hazardous waste sites containing both toxic metals and organics, including plutonium-cellulose mixtures. She is also engaged in collaborations with ECO Compliance Inc. in preparing proposals and reports for the remediation of hazardous waste sites. Professor Ogden has authored or co-authored several book chapters, papers, and presentations in environmental science and technology. She is a member of the American Institute of Chemical Engineers, the American Association for the Advancement of Science, and the American Chemical Society.

Martha Scott, associate professor of oceanography at Texas A&M University, is a researcher in marine radiochemistry and geochemistry. Her

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present research involves radionuclide distribution in the Russian Arctic. Her work has dealt with the interaction between oceans and rivers, transport of materials in the marine environment, and chemistry of manganese nodules. The behavior of plutonium isotopes in rivers, estuaries, and marine sediments has been one of her longstanding research interests. She served for two years as an associate program director for chemical oceanography at the National Science Foundation (1992-1993). She received the Ph.D. degree from Rice University and was a National Science Foundation post doctoral fellow at Yale University.

John M. Sharp, Chevron Centennial Professor of Geology at The University of Texas at Austin, leads an active research program in hydrology. Professor Sharp has authored and co-authored over 200 journal articles, books, reports, and presentations. He is a fellow of the Geological Society of America and recipient of its O.E. Meinzer award (1979) and the American Institute of Hydrology's C.V. Theis Award (1996). Dr. Sharp is the current editor of Environmental and Engineering Geoscience. He received his B. Geological E. with Distinction from the University of Minnesota and his M.S. and Ph.D. degrees in Geology from the University of Illinois.

Paul G. Shewmon, emeritus professor of materials science and engineering at the Ohio State University, received a B.S. degree in metallurgical engineering from the University of Illinois and M.S. and Ph.D. degrees, also in metallurgical engineering, from the Carnegie Institute of Technology. He recently retired as Humbolt Senior Scientist at the Max Planck Institute Metallforschung in Stuttgart. He has received the ASM deMille Campbell Lecture and Award and the TMS Institute of Metals Lecture & Mehl Medal. He was elected to the National Academy of Engineering in 1979.

James Watson, Jr., professor of environmental sciences and engineering and the Director of the Air, Radiation, and Industrial Hygiene Program at the University of North Carolina at Chapel Hill, holds an M.S. degree in physics from North Carolina State University and a Ph.D in environmental sciences and engineering from the University of North Carolina at Chapel Hill. Professor Watson is accomplished in the fields of environmental radioactivity and radioactive waste management. He has received the Underwood and McGavran Awards for excellence in teaching and the Greenberg Alumni Endowment Award for excellence in teaching, research, and service. He is a past president of the Health Physics Society and a past chairman of the Radiological Health Section of the American Public Health Association. He has served on the Environmental Protection Agency's Radiation Advisory Committee and the executive committee of the agency's Science Advisory Board. He is a past chairman of the North Carolina Radiation Protection Commission and currently chairs the commission's Committee on Low-Level Radioactive Waste Management.

Ching H. Yew, an independent consultant and emeritus professor from The University of Texas at Austin, has specialized in the study of hydraulic fracturing and borehole stability. Dr. Yew is a fellow of the America Society of Mechanical Engineers and a member of the Society of Petroleum

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Engineers. Dr. Yew has authored a text and published several articles concerning hydraulic fracturing and borehole stability. The computer code developed by him has been adopted for field use by many oil and gas industries.

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