This chapter describes the Department of Energy’s National Nuclear Security Administration’s (DOE-NNSA’s) conceptual plan to dilute and dispose of surplus plutonium material as transuranic (TRU) waste in the Waste Isolation Pilot Plant (WIPP). The plan is described by key locations throughout the DOE complex (Pantex, Los Alamos National Laboratory [LANL], Savannah River Site [SRS], and WIPP) and activities including transportation between the sites. Plans for scaling up operations and DOE-identified risks are presented. Analogous plans, developed by DOE’s Office of Environmental Management (DOE-EM), for downblending (i.e., diluting) and disposing of up to 6 MT of surplus non-pit plutonium in WIPP are also described.1
The committee received a set of documents and several briefings from DOE-NNSA that describe its plans to dilute and dispose of 34 metric tons (MT) of surplus plutonium material. The list of documents shown in Table 3-1 is part of a larger set of DOE-NNSA’s Life-Cycle Cost Estimate documents (SRNS, 2018a).2 Several documents in Table 3-1 were updated from those that the committee had available when it released its Interim Report, and other documents were new to the committee. For example, the system plan was updated; risk-based documents, the Risk and Opportunity Management Plan (ROMP; SRNS, 2018d) and the Risk and Opportunity Analysis Report (ROAR; SRNS, 2018e), were new to the committee as were analysis reports of criticality (Saylor and Scaglione, 2018) and initial performance assessment with the added diluted surplus plutonium transuranic (DSP-TRU) waste streams (Zeitler et al., 2018).
The scope and overview of DOE-NNSA’s dilute and dispose plan are described below. Any differences between this description of the dilute and dispose plan and the one provided in the Interim Report are noted.
DOE-NNSA began planning for the dilute and dispose process in 2016, following the completion of a DOE-led Red Team review of alternative options to the mixed oxide (MOX) plan (Mason, 2015; see Box 3-1). A high level schedule of DOE-NNSA’s dilute and dispose plan is shown in Figure 3-1.
1 As used by different offices within DOE, the terms “downblend” and “dilute” are synonymous and describe the process for mixing surplus plutonium with an adulterant to ensure that plutonium “is not recoverable without extensive reprocessing.” DOE notes in its Surplus Plutonium Disposition System Plan that “[t]he term dilution is the international nomenclature for using an adulterant to provide proliferation resistance and is in no way intended to avoid any applicable regulatory requirements” (SRNS, 2016, p. 8). The committee has chosen to use the terms “dilute” or “dilution” throughout this report, even when referring to DOE-EM plans and activities.
2 DOE-NNSA’s dilute and dispose documents that are not releasable to the public were not shared with the committee. For example, DOE-NNSA’s planning documents that contain proprietary or pre-decisional information could not be shared with the committee. Information and data gathered throughout a National Academies consensus study are made available to the public based on Federal Advisory Committee Act Section 15 requirements. For access to the publicly available documents used by the committee, contact the National Academies’ Public Access Records Office (PARO) at email@example.com.
TABLE 3-1 Set of DOE-NNSA Planning Documents for the Dilute and Dispose Program That Were Available to the Committee and Referenced Throughout This Chapter
|Authoring Organization||Report Title|
|U.S. Army Corps of Engineers||Independent Validation of GAO Compliance of Life-Cycle Cost Estimate (LCCE) for Surplus Plutonium Disposition (SPD) Program Dilute and Dispose Approach|
|National Nuclear Security Administration (DOE-NNSA) and Savannah River Nuclear Solutions (SRNS)||Surplus Plutonium Disposition Program Dilute and Dispose Approach Life Cycle Cost Estimate Summary Report [SRNS-RP-2018-00570, Revision 0]|
|DOE-NNSA, Material Management and Minimization (M3)||Material Management and Minimization - Surplus Plutonium Disposition Program Requirements Document for the Proposed Dilute and Dispose Approach [M3-SR-16-0009, Revision 1] (Cleansed)|
|DOE-NNSA and SRNS||Surplus Plutonium Disposition - Technical Baseline Description for the Proposed Dilute and Dispose Approach [SRNS-TR-2016-00285, Revision 1]|
|DOE-NNSA and SRNS||Surplus Plutonium Disposition - System Plan for the Proposed Dilute and Dispose Approach [SRNS-TR-2016-00136, Revision 1]|
|DOE-NNSA and SRNS||Surplus Plutonium Disposition Program Technology Readiness Assessment [SRNS-TR-2016-00295, Revision 1]|
|DOE-NNSA, M3||Surplus Pu Disposition Master Summary Schedule|
|DOE-NNSA and SRNS||Risk and Opportunity Management Plan for the National Nuclear Security Administration Surplus Plutonium Disposition Program Dilute and Dispose Approach [ROMP, Y-RMP-G-00023, Revision 1]|
|DOE-NNSA and SRNS||Surplus Plutonium Disposition Program Dilute and Dispose Approach Risk and Opportunity Analysis Report [ROAR, Y-RAR-G-00064, Revision 1]|
|DOE-NNSA, M3||NEPA Timeline / Summary (NAS milestones)|
|Zeitler, Todd R., et at; Sandia National Laboratories||Sandia National Laboratories Waste Isolation Pilot Plant: Summary Report for Surplus Plutonium Disposition Analysis Revision 1 [SAND2019-2307 O]|
|Saylor, E. M., and J. M. Scaglione||Nuclear Criticality Safety Assessment of Potential Plutonium Disposition at the Waste Isolation Pilot Plant [ORNL/TM-2017/751/R1]|
|Scaglione, J. M., and E. M. Saylor||Summary of US Surplus Weapons-Usable Plutonium WIPP Postclosure Criticality Analysis|
NOTES: All documents listed are available for public access. Savannah River Nuclear Solutions is a contractor that reports to DOE.
DOE-NNSA’s planning effort is being managed under DOE Order 413.3B, Program and Project Management for the Acquisition of Capital Assets, and has passed Critical Decision 0 (CD-0), Approve Mission Need; CD-1 in late 2019, which marked the completion of the project definition phase and the conceptual design (DOE, 2010, p. A-6, table 2.1); and CD-3A, in mid-February 2020 to allow for specific construction activities to begin (DOE, 2010).3 DOE-NNSA currently estimates that the effort to dilute and dispose of 34 MT of surplus plutonium will cost $18.2 billion (in then-year dollars) and take 31 years to complete, beginning with conceptual design in 2018 and ending with emplacement of all 34 MT of DSP-TRU waste in WIPP in 2049 (DOE, 2018b).4
The process outlined in the National Environmental Policy Act (NEPA) requires DOE-NNSA to obtain public comments and inputs on decisions and actions. The NEPA plans for dilute and dispose were presented in April 2019 to the committee (Richard, 2019). A notice of intent was expected to be issued in late 2019, but as of the writing of this report in early 2020, it had not yet been issued. A final environmental impact statement (EIS) was expected in mid-FY 2020, although this date appears unlikely (see Figure 3-1; an updated schedule was not available to the committee). The committee has not yet seen a detailed NEPA strategy for the conceptual plan or details on what constitutes a final EIS. Also shown in Figure 3-1 is the duration of the dilute and dispose process. The committee provides recommendations related to NEPA in Chapter 5.
The goal of DOE-NNSA’s dilute and dispose program is defined in the project’s System Plan: “to plan and execute the disposition of 34 MT of surplus weapons-usable plutonium consistent with United States (U.S.) nuclear nonproliferation policies in a cost-effective manner” (SRNS, 2018c, p. 8). DOE-NNSA’s Defense Nuclear Nonproliferation office is managing the dilute and dispose project and is focused on the disposition of 34 MT of surplus plutonium. However, the amount of diluted surplus plutonium material that is under consideration for dilution and disposal in WIPP is as large as 48.2 MT (see Figure 2-1). The 48.2 MT consists of up to 42.2 MT being managed by DOE-NNSA (34 + 7.1 + 1.1 MT) and 6 MT from DOE-EM for which there is a Record of Decision issued (DOE, 2016a; LANL, 2017).
3 Order 413.3B outlines an internal DOE process for reviewing and approving large acquisition programs through Critical Decision milestones. After reaching CD-0, DOE program managers may proceed with conceptual planning. See discussion in Chapter 2 and DOE (2010, p. A-5, table 2.0).
4 First emplacements of diluted non-pit plutonium and pit plutonium as DSP-TRU waste in WIPP are fiscal year (FY) 2023 and FY 2028, respectively (see Figure 3-1). Recall that the cost estimates were developed in FY 2017 dollars and converted to then-year dollars using escalation rates found in DOE (2018b).
As noted below, DOE-NNSA’s plans for dilution and disposal are based on DOE-EM’s current work on the 6 MT. In the committee’s analysis below, 48.2 MT will be used when considering the full impact of emplacing DSP-TRU waste in WIPP.
DOE-NNSA’s general plan and process steps are outlined in the System Plan (SRNS, 2018c) and are described below with the key process steps shown in a simplified process flow diagram in Figure 3-2. DOE-NNSA’s dilute and dispose plans make use of other existing plans and processes to reduce both costs and risk. For example, all of the transportation within the conceptual plan will make use of existing federal transportation programs: DOE’s Office of Secure Transportation (DOE-OST) and Carlsbad Field Office (DOE-CBFO) TRU Waste Transportation program. Similarly, the pit management, disassembly, and oxidation processes were originally developed for the MOX approach, and these steps have been reviewed for critical risks.
After the plutonium oxide material reaches SRS, it will follow a process path developed by DOE-EM to address the processing and disposing of up to 6 MT of surplus non-pit plutonium material, some of which is currently stored at SRS (DOE, 2016a). The committee was told that DOE-NNSA’s plans for dilution and disposal (process steps C through E in Figure 3-2) were identical to DOE-EM’s process steps for its 6 MT of material and that the two DOE offices will share resources and infrastructure.5 Once the DSP-TRU waste has been packaged, characterized, and determined to meet the WIPP waste acceptance criteria, it becomes approved for inclusion in payloads and awaits shipment to WIPP. For nuclear material control and accountability (MC&A) purposes, the diluted plutonium waste product is tracked as material until it is loaded into a TRUPACT-II for shipment to WIPP.6
5 Based on the documents received by the committee, there is not an integrated schedule that includes the downblending (dilution) and disposal of the 6 MT of surplus plutonium material being managed by DOE-EM. Also, DOE-EM’s work on downblending (dilution) and disposal does not fall under DOE Order 413.3B (as does DOE-NNSA’s plan) as it is an ongoing operation. Therefore, there are no critical decision milestones required to conduct the 6 MT program (see DOE-EM and DOE-NNSA responses to the committee’s questions, February 19, 2020, available by request through the National Academies’ Public Access Records Office at firstname.lastname@example.org).
All of the individual processes described above have been conducted and exercised by DOE (see Figure 4-1 for a schematic of the process steps and DOE programs from which they are modeled). However, the end-to-end process as described in the DOE-NNSA dilute and dispose plan has not been exercised. Additionally, some of the important process steps have not been demonstrated at levels or rates even remotely approaching the throughput proposed by the dilute and dispose plan. The committee reviews the processing steps below and highlights several risks from scaling up to meet the plan’s milestones.
3.2.1 Dilute and Dispose Scaling-Up Plans
As shown on Figure 3-2, there are four locations in which different activities and processes take place. Each of the high level processes and DOE-NNSA’s plans to scale up to meet the plan’s goals at each site are described. Additional details are available in the documents listed in Table 3-1.
18.104.22.168 Pantex Operations
DOE-NNSA’s dilute and dispose activities at Pantex are related to the 26.2 MT of surplus plutonium pits, which are currently stored there. Activities include retrieving, storing, and staging the pit containers; shipping the containers to LANL; and monitoring conditions for safety and accountability (see Figure 3-2, process steps A to B1). The pits will be shipped from the Pantex Plant to LANL via OST (see Section 3.3.2 for details on OST). These steps are similar to those designed for the MOX option. Staffing is expected to increase from a baseline of 18-22 persons to 30-42 persons during sustained operations for the dilute and dispose program. Efficiencies are expected to be gained through the use of new containers, which are under development and expected to be ready for the start of DOE-NNSA’s program.
22.214.171.124 ARIES at LANL
The LANL operations described in DOE-NNSA’s dilute and dispose plan consist of receiving pits from Pantex, storage and staging, size reduction to particles, thermal oxidation of particles, packaging, storage, staging, and shipping to SRS, with monitoring throughout (see Figure 3-2, process step B1). The size reduction and oxidation processes are conducted in the Advanced Recovery and Integration Extraction System (ARIES). ARIES was originally designed to demonstrate, at a pilot level, that pits could be safely and securely disassembled and oxidized in support of the MOX plan (Dillingham, 2012). ARIES is located in the Plutonium Facility at Technical Area 55, also referred to as “PF-4,” at LANL. Notably, this is the same facility in which DOE-NNSA has committed to increased pit production by 2030.
The non-pit oxide production step will process a total of 7.8 MT of surplus non-pit plutonium stored in different DOE sites (see Figure 3-2, process step B2). At this time, DOE-NNSA has not decided how much if any of the 7.8 MT of surplus non-pit plutonium material will be shipped to LANL or to SRS for oxidation (SRNS, 2018c, p. 21).
ARIES rates of disassembly and oxidation were obtained from the Office of Cost Estimating and Program Evaluation (DOE-CEPE) independent review of DOE-NNSA’s Life-Cycle Cost Estimate (LCCE) plan. The DOE-CEPE report shows a current rate of plutonium oxide production of 100 kilograms per year (kg/yr), ramping up to 1,117 kg/yr between FY 2022 and FY 2023 (DOE, 2018b, p. 5).7 Staffing increases from an 82-person baseline to 296 persons during maximum sustained operations (DOE, 2018b). DOE-NNSA’s ROAR identified equipment failures in the disassembly and oxidation steps as one of the highest risks for the dilute and dispose plan. To address these risks and to increase throughput, DOE-NNSA plans to purchase additional equipment to provide additional processing lines and to provide backup equipment in case of failure (SRNS, 2018e).
All shipments from Pantex to LANL and from LANL to SRS for the dilute and dispose plan are shipped via OST and are consistent with the transportation plans developed to ship the surplus plutonium material for the MOX plan (see Transportation Section 3.3.1).
126.96.36.199 Savannah River Site
When the plutonium oxide reaches SRS, it will follow a different processing path than that proposed for the MOX process. The process steps to be completed at SRS are receive and store plutonium oxide from LANL, dry blend with adulterant, perform non-destructive assay (NDA) and package, and stage and ship diluted plutonium (SRNS, 2018a). The processes described in DOE-NNSA’s plan are modeled after DOE-EM’s plans to dilute and dispose of 6 MT of surplus non-pit plutonium material (see Figure 3-3).
Dilution of the plutonium oxide is central to DOE-NNSA’s plans, and several details are important to other discussions within this report, and so some of the process steps are described in greater detail here. The process of dry blending the plutonium oxide with adulterant, shown in the green boxes of Figure 3-3, begins with the transfer of 3013 containers into a glovebox.8 Many of the operations within the glovebox are performed manually. The 3013 container is punctured to relieve any gas pressure that may have built up during storage and then is cut open to remove the plutonium oxide. A new twist-off container, SAVY, is proposed by DOE-NNSA’s plan to improve processing efficiency for this step (Cantey and Robertson, 2019, slide 8). The plutonium oxide is sieved and, if necessary, size reduced (i.e., using mortar and pestle). The plutonium oxide is then transferred in 170-gram allotments (or 150 fissile gram equivalent [FGE] plutonium-239) into blend cans prefilled with adulterant powder by an offsite supplier.9 Mixing the plutonium oxide with an adulterant to less than 10 weight percent produces a safeguards attractiveness level “D” material, which allows for the termination of certain nuclear MC&A requirements and also meets Plutonium Management and Disposition Agreement (PMDA) requirements (DOE, 2011; SRNS, 2018c; see Box 3-2).
The blend can is agitated using a Turbula blender (a 3-D mixer) to mix the dry powdered plutonium oxide with the dry powdered adulterant. The DOE-NNSA dilute and dispose planning documents consistently refer to this as a dry process (DOE-NNSA, 2018; SRNS, 2018a,b,c). The blend can is then “bagged out,” that is, encased in a plastic bag after removal from the glovebox. This bag is then inserted into an outer can (slip-lid can) which is also closed. See Figures 3-4 and 3-5.
The encased blend cans are subjected to NDA to confirm the intended composition of diluted surplus plutonium in the cans. These tests include measurements using a neutron multiplicity counter, a gamma isotopic system, and, for selected cans, a calorimeter (SRNS, 2018c). The current process uses 150 FGE operating limit per can to account for measurement uncertainty in waste assay. However, the drum limit is 380 FGE and is split between two cans of diluted material. After assurance of the proper amount of plutonium-239 in each blend can, two of the encased blend cans are inserted into a criticality control container (CCC) that is then sealed and inserted into a criticality control overpack (CCO) with the dimensions of a standard 55-gallon drum. NDA is important for two reasons: the data are used, first, to determine that the diluted surplus plutonium material meets the WIPP waste acceptance criteria (WAC), and second, for the tracking and accounting of the surplus plutonium material since the material is still under material safeguards.
8 As received from LANL at SRS, the 9975 (or 9977) shipping packages house 3013 containers with the plutonium oxide.
9 The adulterant powder is described as follows: “The adulterant is a combination of materials that are considered non-reactive, and the final waste form, including the adulterant, complies with WIPP waste acceptance criteria (WAC). . . . The dilute process blends a mixture of dry powders with plutonium oxide and packages this mixture in a configuration authorized for disposal at the WIPP geologic repository” (SRNS, 2018a, p. 18). The composition of the adulterant is not available to the public but information on the DSP-TRU waste form can be found in the Annual TRU Waste Inventory Report (ATWIR). For example, the 2016 ATWIR, the first to include the new SRS waste stream, SR-KAC-PuOx, for the 6 MT of diluted plutonium, has information on the waste stream’s material parameters and radionuclides (DOE-CBFO, 2016a, p. 314).
To date, no CCOs have been shipped to or emplaced in WIPP. However, DOE-EM has emplaced similar downblended/diluted material-associated debris from an earlier SRS campaign (emplaced in WIPP between August 2012 and September 2017): a total of 33.34 m3 (using the WIPP Land Withdrawal Act [LWA] inner container volume) waste was emplaced from waste stream SR-221H-PuOx, all in pipe overpack containers (POCs) with the exception of three standard waste boxes.10 Notably, POCs have been used for TRU wastes originating from not only SRS (i.e., a total of 27,025 POCs have been emplaced up to September 2019; see Table 5-4). To be emplaced in WIPP, the safeguards for this material required termination (see Box 3-2).
Up to seven CCOs containing DSP-TRU waste will be grouped together for transport (see Figure 3-6). Two groups of seven CCOs are placed on top of each other inside of a TRUPACT-II container (see Box 3-4, Box Figure 1). Thus, the DOE-NNSA and the DOE-EM dilute and dispose plans, which both anticipate a nominal fissile gram equivalent per CCO of 300 grams (with a 380-FGE limit), allow for 14 CCOs containing a nominal 4,200 (5,320 maximum) FGE of plutonium-239 to be placed into a single TRUPACT-II for shipment to WIPP. Up to three TRUPACT-IIs are loaded onto a trailer for a single shipment to WIPP.
The K-Area at SRS has the capacity to stage about 600 CCOs with options to expand as needed (SRNS, 2018c). The plans indicate that about 6,000 CCOs will be staged each year at maximum production, and interim safe storage space will be needed for 6,000 to 7,000 CCOs (about 1 year of production) to accommodate possible delays in shipments to WIPP (SRNS, 2018c).
10 Information collected during discussions in the open session of the committee’s April 2019 meeting. See video from the meeting available at https://vimeo.com/showcase/6028445/video/338026631 (accessed May 20, 2020). Also, data from the Performance Assessment Inventory Report or ATWIR (see Chapter 2) confirm that from 2012 to 2017, SRS shipped to and emplaced in WIPP at total of 666, 12-inch POCs stated to contain 61 kg of diluted surplus plutonium oxide.
If safeguards are terminated and the DSP-TRU is certified to meet the WIPP WAC, the packaged plutonium waste form will be organizationally transferred to DOE-CBFO, which will ship it to WIPP using TRU Waste Transport and emplace it in the repository as contact-handled transuranic11 (CH-TRU) waste (DOE, 2016a). See Transportation Section 3.3.
11 The term “transuranic waste” is defined in the Waste Isolation Pilot Plant Land Withdrawal Act (LWA) as “waste containing more than 100 nanocuries of alpha-emitting transuranic isotopes per gram of waste, with half-lives greater than 20 years, except for—(A) high-level radioactive waste; (B) waste that the Secretary has determined, with the concurrence of the Administrator, does not need the degree of isolation required by the disposal regulations; or (C) waste that the Nuclear Regulatory Commission has approved for disposal on a case-by-case basis in accordance with part 61 of title 10, Code of Federal Regulations.”
The dilution process at SRS is currently carried out at a small scale in order to process 6 MT of surplus non-pit plutonium for dilution and disposal (Maxted, 2019). As of the end of FY 2019, approximately 52 kg (or 0.052 MT) of surplus non-pit plutonium oxide had been diluted in the K-Area KIS glovebox following the process outlined in Figure 3-3. This diluted material was packaged in 250 CCOs and remains at SRS, awaiting the installation of characterization equipment in the K-Area expected to be operational by FY 2021.12 As noted earlier, a separate ~61 kg of surplus non-pit plutonium material was diluted, packaged in a total of 666 12-inch POCs, assessed, safeguards terminated, shipped, and emplaced at WIPP, but the processes were conducted in a different glovebox and were not identical to the plans proposed by DOE-NNSA in the dilute and dispose plan.
FINDING 3-1: The Department of Energy’s National Nuclear Security Administration’s (DOE-NNSA’s) dilute and dispose plan relies on dilution experience gained through DOE’s Office of Environmental Management (DOE-EM) efforts to dilute and dispose of 6 metric tons (MT) of surplus non-pit plutonium. However, so far, less than 1 percent (0.052 MT, as of the end of September 2019) has been processed following the steps proposed in DOE-NNSA’s plan and that material has not yet been emplaced in the Waste Isolation Pilot Plant. Furthermore, DOE-EM’s plans for diluting and disposing of up to 6 MT of non-pit plutonium indicate a completion date of 2046—meaning that the two dilute and dispose programs will concurrently operate and compete for resources for nearly the full duration of DOE-NNSA’s dilute and dispose program.
DOE-CEPE conducted a review of DOE-NNSA’s LCCE documentation in 2018. The DOE-CEPE report states that the DOE-NNSA dilute and dispose plans propose a 410-kg/yr dilution rate in FY 2026 at SRS, increasing to a sustained rate of 1,640 kg/yr by FY 2028 (DOE, 2018b). The current target dilution rate obtained by DOE-EM in the KIS glovebox is 25 kg/yr in FY 2019 (Nuclear Security & Deterrence Monitor, 2019). DOE-NNSA plans to achieve the sustained dilution rate through the purchase of additional gloveboxes and 24/7 glovebox operations (see Figure 3-7). Staffing projections show 15 personnel in 2018 rising to 241 for maximum steady-state operations through 2047 (DOE, 2018b). The sustained rate begins in FY 2028 and ends in FY 2047.
12 This implies that not all of the CCOs were filled to the current maximum of 300 FGEs of plutonium-239. See also “DOE-EM and NNSA responses to the committee’s questions,” February 2020. Available by request through the National Academies’ Public Access Records Office at email@example.com.
Similar to the ROAR’s assessment of LANL operations, the dilution and NDA operations that take place at SRS are assigned a high program execution risk due to potential equipment failures, which are proposed to be addressed by multiple parallel dilution gloveboxes and efficiencies in waste characterization. One example of such an opportunity is to recognize the low variability of the DSP-TRU waste stream by streamlining the waste characterization process.
188.8.131.52 Receive and Unload at WIPP
According to DOE-NNSA, the DSP-TRU waste “meets all the criteria of transuranic (TRU) waste and the WIPP WAC. The DSP-TRU waste stream is handled the same as other TRU waste when containers are received at WIPP. The normal processing times for receipt and unloading of TRU wastes at WIPP are within 8 to 12 hours of receipt” (DOE-NNSA, 2019, p. 2).
Historically, once TRU waste shipments arrive from DOE generator sites at WIPP, they are cleared by WIPP site security, and then undergo a radiological survey and a shipping documentation review. The loaded trailer is moved next to the Waste Handling Building. The TRUPACT-IIs are inspected and surveyed to ensure that they are not damaged or radiologically contaminated. Any significant problems or discrepancies are addressed before a TRUPACT-II is returned to service. A schedule is maintained for routine maintenance and evaluation of the casks. The TRUPACT-II is then brought into the Waste Handling Building for unloading (DOE-CBFO, 2016b, pp. 48-49).
The TRUPACT-IIs containing DSP-TRU waste assessed at Attractiveness Level D would include electronic tamper indicators and may be staged for several days in secured waste handling areas.13 Processing steps for the TRUPACT-IIs once inside the Waste Handling Building and through emplacement of the CCOs in the underground can be found in the System Plan (SRNS, 2018c, p. 28).
Finally, as reported by DOE-NNSA,
The priority and exact sequence of emplacement underground is determined by multiple operational factors including container configuration, radiation protection (worker dose) controls, and volatile organic compounds, for example. The receipt and disposal prioritization/flow for downblended/diluted plutonium TRU waste would also take into account security and roll-up considerations for the waste staging area. Once designated for the emplacement queue, waste is disposed underground typically the same day that the shipping container is unsealed. If WIPP emplacement operations are significantly delayed, then shipment of the surplus plutonium TRU waste will be paused at the Savannah River Site. The standard WIPP procedure for TRU waste emplacement may be adjusted to support future verification activities, if required. (DOE-NNSA, 2019, p. 2)
Transportation is an important component of the dilute and dispose plans. The safe and uneventful transportation of all nuclear materials and defense-generated nuclear wastes is important to a varied and diverse audience which includes the general public, the host state of the repository, communities and states within the transportation corridor that could be impacted, as well as businesses, industry, and a variety of levels of government.
As shown in Figure 3-2, OST will be responsible for shipping undiluted plutonium material from Pantex to LANL and from LANL to SRS. The packaged DSP-TRU waste will be shipped from SRS to the WIPP site utilizing the DOE-CBFO TRU waste shipment programs to WIPP (TRU waste transportation within the United States is managed by DOE-CBFO). From start to end, the estimated length of a single shipment from Pantex to its final destination at WIPP is more than 3,300 miles via
interstate truck transport.14 Details of the transport of the surplus plutonium pits, oxide, and DSP-TRU waste are not well detailed in DOE-NNSA’s plans to dilute and dispose of surplus plutonium. We present below background information about OST and TRU waste transport as well as information pertaining to DOE-NNSA’s dilute and dispose plans.
3.3.1 DOE Office of Secure Transportation
As part of its mission to maintain national security and public safety, OST is responsible for the protection and transportation of special nuclear materials within the United States.15 As shown in Figure 3-2, OST is responsible for shipping undiluted plutonium materials from the Pantex Plant to LANL and oxidized plutonium material from LANL to SRS, utilizing safety, security, and safeguarding protocols that have been in use for more than 70 years without an accident causing either a fatality or release of radioactive material.16 Enhanced government-owned security resources such as packaging, technologically advanced self-protecting transportation assets, federal agents serving as escorts (who will deny unauthorized access), nonpublic continuous shipment monitoring, and confidential routing and timing for classified shipments are used by OST.
While OST is responsible for obtaining appropriate federal and state permits for its conveyances, such as hazardous materials, nuclear materials, and oversize overweight permits, it applies for annual rather than single trip permits so as to not predetermine potential routes. As an additional security measure, advance notifications of potential shipments, timing, or routes are not made outside of the DOE organization. OST convoys are continuously monitored en route by the OST Transportation and Emergency Control Center located in Albuquerque, New Mexico. Any off-normal situations are resolved internally and are not reported publicly.
Additional security measures are required for OST conveyances due to the attractiveness of its cargo to adversaries (i.e., special nuclear material). OST security and safety risk assessments are not shared publicly, and the committee did not review OST documents related directly to the dilute and dispose program.
3.3.2 Transuranic Waste Transportation in the United States
DOE-NNSA’s dilute and dispose plans rely on the existing TRU waste transportation infrastructure to ship the packaged DSP-TRU waste from SRS to WIPP (see Figure 3-2). DOE-CBFO is responsible for the transportation of TRU waste to WIPP from DOE sites.17
The WIPP TRU waste transportation system has always utilized contract commercial motor carriers whose sole responsibility is to transport TRU waste within a DOE site, between DOE sites, and from one DOE site to the WIPP facility. States are active partners in safe highway transportation because they enforce federal and state laws regarding commercial motor vehicle compliance. They also enforce state statutes, rules, and laws (see Appendix D). Box 3-3 describes the collaborative role played by the states in establishing early coordination on TRU waste transportation. Appendix E provides further background on the states’ active partnership in maintaining transportation safety.
15 As set forth in DOE Order 460.1D, the Atomic Energy Act of 1954 broadly regulates how DOE will conduct its packaging and transportation activities. Because of the nature of certain types of shipments, DOE-NNSA must achieve a level of safety equivalent to that required by the Department of Transportation (DOT) and the U.S. Nuclear Regulatory Commission (U.S. NRC) for comparable commercial shipments. Thus, DOE-NNSA self-certifies transportation packages as meeting the Type B requirements set forth by the U.S. NRC. The U.S. NRC does not recertify DOE-NNSA packages (https://www.energy.gov/nnsa/office-secure-transportation, accessed May 20, 2020).
16 See https://www.energy.gov/nnsa/office-secure-transportation (accessed February 19, 2020).
17 The waste destined for WIPP may contain hazardous material in addition to transuranic contamination and materials; currently all waste that is emplaced in WIPP is considered mixed (hazardous and TRU) waste. Therefore, all TRU waste shipments are subject to transport regulations related to both hazardous and radiological materials.
Since the 1990s, the DOE Secretary of Energy has promulgated formal memoranda of agreement addressing a meaningful interactive relationship among DOE, states, and tribes on such matters as the safe and uneventful transportation of radioactive materials/waste and nuclear waste across the United States. Reinforcing the essential principles of communication, collaboration, consultation, and cooperation, the memoranda of agreement continue to serve as foundational documents for the TRU waste transportation program.
OST has taken a more focused approach to engagement. OST has an ongoing liaison program whose focus is to build relationships with state and local law enforcement authorities along possible routes. These relationships are encouraged in the DOE Directives Program or DOE-NNSA equivalencies.18 This effort is key to cooperative and collaborative emergency response with state and local emergency response officials.
The TRU waste transportation corridor identified in the dilute and dispose plans involves the following states: Alabama, Georgia, Louisiana, Mississippi, New Mexico (the WIPP host state),
18 OST provides information about its program to state and local law enforcement in three ways:
- one of the OST liaisons will conduct an in-person community-level presentation where the liaison describes the program, shows a comprehensive video, then holds a question and answer period;
- OST has a computer-based training program; and
- an OST module with video (https://www.youtube.com/watch?v=OasNhj1i2ic&t=6s, accessed March 31, 2020) is taught as part of the DOE Modular Emergency Response Radiological Transportation Training course for emergency response personnel.
The OST in-person presentation and training focuses on tactics in the event of an accident or incident involving an OST convoy, how to approach and interact with the Convoy Commander, and how OST participates in the incident command system.
South Carolina, Tennessee, and Texas19 (see Figure 3-8). Two cognizant state regional organizations, the Southern States Energy Board (SSEB, 2018) and WGA (2019), have memoranda of agreement with DOE to enhance safety, security, and communication.20 There are no tribes along the transportation route from SRS to WIPP.
The TRU waste transportation program is documented in the TRU Transportation Plan, DOE-CBFO-38-3103 (DOE-CBFO, 2016b), excerpts of which were used to provide significant details to this section of the report. The DOE TRU Waste Transportation Plan was developed by incorporating the guiding principles of the state regional planning guides. Over 32 years, a robust transportation system for TRU waste has been designed, implemented, maintained, and updated. As evidence of the success of this approach, the Blue Ribbon Commission on America’s Nuclear Future cited the TRU waste transportation model as a proven transportation system and recommended that DOE utilize it as a prototype for other nuclear materials and waste transportation campaigns including spent nuclear fuel and high level waste (BRC, 2012, p. 85).
19 Under the DOE TRU Transportation Plan, the Supplemental Stipulated Agreement with New Mexico is “an agreement resolving certain New Mexico State off-site concerns (dated December 27, 1982)” (DOE-CBFO, 2016b, p. 113). It includes funding to the state for transportation activities related to accident prevention, emergency management, public information, and information sharing and development within New Mexico, the western states, and across the nation.
20 There are two other regional organizations who are engaged in the transportation of TRU waste along other transportation corridors to WIPP: the Council of State Governments East and Midwest. They are the Council of State Governments East and Midwest (https://www.csg.org, accessed May 23, 2020).
DOE-CBFO provides advance notice to state gubernatorial designees of TRU waste shipments bound for WIPP so those officials can accomplish a variety of activities. These advanced notices include semiannual notifications of planned shipments, an 8-week rolling schedule containing more detailed information about the shipments, an 8-week rolling schedule summary that is suitable for distribution to emergency response personnel, and a 2-hour notification made by the driver of the shipment to the WIPP Central Monitoring Room (who calls the state 24-hour point-of-contact) before that shipment is expected to cross state lines. States depend on these notifications to monitor TRANSCOM (see Box Figure 2 in Box 3-4 below); to schedule inspections; to coordinate if or how they will provide escorts for WIPP shipments off-route or through their jurisdictions; and to maintain awareness and vigilance in order to provide emergency and other assistance. Because of the classified nature of special nuclear materials and as noted previously, OST does not make advance notifications along its intended route.
184.108.40.206 Legal and Regulatory Requirements
DOE’s special nuclear materials transportation (i.e., OST) and its TRU waste transportation programs operate under guidance established in law, regulation, statute, rule, and internal DOE orders including development of DOE-NNSA equivalency orders. These documents define safety and security requirements for transportation (see Appendix D).
For highway shipments of TRU waste to WIPP, DOE-CBFO uses preferred routes under DOT regulations specified in 49 CFR Part 397 (Transportation of Hazardous Materials). Subpart D establishes requirements for routing shipments of Highway Route Controlled Quantities (HRCQ) of radioactive materials. Route deviations are coordinated with states on a case-by-case basis (DOE-CBFO, 2016b).
DOE-CBFO has selected a route for transporting TRU waste from SRS to WIPP (see Figure 3-8). The route utilizes U.S. Interstate Highway I-20 from South Carolina to west Texas and then either U.S. or state highways from there to WIPP. I-20 passes through several large cities including Atlanta (Georgia), Birmingham (Alabama), Jackson (Mississippi), Shreveport (Louisiana), and Dallas (Texas).
Packages21 used to transport TRU waste to WIPP must meet U.S. NRC requirements in 10 CFR Part 71 (Packaging and Transportation of Radioactive Material) for “Type B” packages.22 The package design must be certified by the U.S. NRC, and the design, fabrication, assembly, testing, maintenance, repair, modification, and use of the package must be carried out under a U.S. NRC-approved quality assurance program (see Box 3-4).
220.127.116.11 Accident/Incident History
The National TRU Program (NTP) and TRU Waste Transportation Program report that there have been 20 incident/accidents involving empty and loaded TRU transporters, none of which resulted in the release of radioactive or hazardous material since shipments to WIPP began in 1999. Of the 20 incidents/accidents, 6 occurred along the route from SRS to WIPP between 2005 and 2013.
The most severe accident in the history of the TRU waste program occurred in Idaho on December 27, 2005. The accident highlights the type of safety risks present during transport—which in this case were not related to radiological releases (DOE-CBFO, 2005). While hauling three empty TRUPACT-IIs, which were secured to the trailer, the WIPP driver lost control of the vehicle, causing first the tractor then the trailer to roll over onto their side. All three TRUPACT-II containers became detached from the trailer; one rolled across two lanes of traffic, through the highway median, across two oncoming lanes of traffic, and came to rest against a right-of-way fence (Idaho State Police, 2006). The other two landed on the edge of the highway on the same side as the WIPP tractor and trailer. All three TRUPACT-II casks sustained surface damage but maintained their integrity according to field testing. The WIPP drivers sustained minor injuries. After it was determined that the cause of the accident was that the driver lost consciousness, the driver was charged with inattentive driving and was released by the carrier.
DOE-CBFO has developed detailed procedures to respond to such an accident (DOE-CBFO, 2017b),23 reaffirming the DOT regulations (49 CFR §§ 177.843, 177.854, 107.117, and 107.105), which provide required instructions for actions after an incident or accident. The “Recovery Guide” also provides other comprehensive procedures and functional processes (DOE-CBFO, 2017b).24
21 According to the U.S. NRC website, “Package means the packaging together with its radioactive contents as presented for transport.” See https://www.nrc.gov/reading-rm/doc-collections/cfr/part071/part071-0004.html (accessed May 20, 2020).
22 Type B packages are designed to maintain containment effectiveness during normal transport conditions and withstand severe accidents without containment losses or increases in external radiation levels that would endanger emergency responders or the public.
23 These detailed procedures are also in the tractor cab for use by the drivers and emergency response personnel. DOE is immediately available to provide technical assistance over the telephone, utilizing these procedures, and will deploy assets from across the nation to respond in the shortest time possible, including
- The team that will be deployed after an incident, which is called the CBFO Incident/Accident Response Team (IART). The IART serves as a technical advisor in a unified command system to ensure appropriate package recovery and movement.
- The regional Radiological Assistance Program Teams, which are available and, if called upon, will be deployed to verify containment of contents of the packaging.
- Additional regional and national DOE resources will be made available.
24 The Recovery Guide is also a unique resource on where to obtain a 50-ton crane, how to weld lugs onto packages, and appropriate load securement for final movement of the recovered package when released from the scene.
18.104.22.168 Shipment Projections
DOE has a long history of shipping TRU waste from SRS to WIPP. Since 2001, DOE has made 1,623 shipments of CH-TRU waste from SRS to WIPP, involving 17,674 m3 total transuranic mixed waste (TMW) volume and 10,844 m3 total LWA volume, as of late October 2019.25 The commercial motor vehicles that transported this waste traveled almost 2.5 million loaded miles. This equates to about 1,500 loaded miles per trip. Since 1999, the entire TRU Waste Transportation Program has made more than 12,000 shipments of TRU waste to WIPP, representing almost 15 million miles of transport (DOE-EM, 2017).
The TRU Waste Transportation Program is operationally mature: the highway route for transporting TRU waste from SRS to WIPP has been established; emergency response personnel along the route have been and continued to be trained; and TRU waste shipments have been made along the route since 2001 (except for a 3-year pause in shipments when operations at WIPP were temporarily halted). DOE has demonstrated that it is able to ship TRU waste from SRS to WIPP on a routine basis.
For shipments from SRS to WIPP, prior to the temporary closure of WIPP in 2014, DOE-CBFO was making, on average, about 120 shipments per year, or a little over 2 shipments per week (SRS, 2018). In the future, DOE-CBFO plans to make about four shipments of diluted surplus plutonium per week to WIPP through 2049 with no more than two in transit at a time (SRNS, 2018b).
The total number of shipments that will be required for DSP-TRU waste can be estimated using the current assumed amount of plutonium-239 per CCO (i.e., 300 FGE). For the 34 MT, approximately 2,700 shipments will be made between 2024 and 2049, assuming 4.2 kg plutonium per TRUPACT-II and three TRUPACT-IIs per shipment. For the 6 MT, there are expected to be approximately 475 shipments; and for the 8.2 MT, if this material is determined to be diluted and disposed, there would be an additional 650 shipments. In total and for DSP-TRU waste only, there would be approximately 3,825 shipments of DSP-TRU waste from SRS to WIPP—more than twice the number of shipments from SRS to WIPP between 2001 and the end of October 2019.
22.214.171.124 Transportation Security
DOE-CBFO is required to have a transportation security plan that is based on a layered approach (or a graded resource) and details the responsibility for engagement at the local, state, regional, and national government levels with full integration of DOE and other federal agency personnel and resources. According to the TRU Waste Transportation Plan (DOE-CBFO, 2016b), the nonpublic TRU Waste Transportation Security Plan (DOE/WIPP-03-03233) was written to meet the DOT requirements in 49 CFR Part 172, Subpart I, Safety and Security Plans.26
DOE-NNSA’s dilute and dispose plan states that once the diluted plutonium material has been packaged, characterized, and shown to meet the WIPP WAC, it will be shipped using the same process and equipment as other TRU waste shipments (SRNS, 2018b, p. 19). However, in response to committee questions, DOE-NNSA noted that the following additional security measures will be put in place:
As shipments of the dilute and dispose TRU waste are initiated, NNSA will deploy an electronic tamper indicating seal to demonstrate continuity of knowledge for U.S. surplus plutonium disposition. Implementation of this electronic seal on TRUPACT-IIs used for transportation of the dilute and dispose TRU waste will enable NNSA to independently verify receipt of surplus plutonium materials at WIPP, if required. (DOE-NNSA, 2019, p. 2)
The committee was told of a Campaign Plan that was under development for the dilute and dispose program and will require eventual approval by the DOE Deputy Secretary. The Campaign Plan was being
25 See https://www.wipp.energy.gov/general/GenerateWippStatusReport.pdf (accessed November 19, 2019).
26 The plan is nonpublic and was not made available to the committee.
developed to assess security requirements for the transportation and emplacement of the diluted surplus plutonium TRU waste. The Campaign Plan will document security strategies for protection of material, facilities involved, transportation, and equivalencies that may be required throughout the duration of the combined DOE-EM and DOE-NNSA 40-MT (6 MT plus 34 MT) surplus plutonium disposition campaign and includes the follow information:
- Describes each facility and the security strategies in place today;
- Identifies roles and responsibilities;
- Aligns and adjusts with installation of new capabilities and increased production;
- Security continues throughout program, including at WIPP, consistent with operations today;
- Evaluates threats periodically throughout the program; and
- Identifies processes for contingency planning—incorporates risk mitigation strategies (McAlhany et al., 2018, slide 14).
126.96.36.199.1 Materials Risk Review Committee
The process for review of the Campaign Plan and eventual approval by the DOE Deputy Secretary has been handled by the Materials Risk Review Committee (MRRC). The MRRC was established by DOE Order in 2016 to adjudicate technical risk analyses of special nuclear material (SNM) holdings, security postures implemented to safeguard those materials, and material holding/storage configurations across the DOE complex. The Office of Defense Programs (NA-10), the Office of Defense Nuclear Security, and the Office of Counterterrorism and Counterproliferation (NA-80) are all represented on the MRRC, and the reviews are coordinated by the Director of the Office of Security (AU-50). Key components of these reviews are technical assessments performed by teams within NA-80 and NA-10. NA-80 conducts material risk assessments for the MRRC to help understand sensitivities or potential risks associated with various nuclear material operations, leveraging experts in materials science, physics, actinide chemistry, and nuclear engineering from across the DOE complex to assist with these reviews. The committee understands that NA-80 was intimately involved in reviewing the dilute and dispose approach and flowsheet, including informing and assessing potential risks of the proposed material dilution and packaging approaches to prepare excess plutonium materials for disposition. The NA-80 technical review also involved consideration of safeguards termination and extensive reviews of the long-term Campaign Plan, which outlines the technical requirements and planned operations for disposition of the surplus plutonium over a multidecade period. The committee further understands that any potential security risks identified by the MRRC process will be forwarded to the DOE Deputy Secretary together with mitigation strategies that seek to provide equivalencies to risk acceptance consistent with relevant procedures and policies for SNM.
188.8.131.52 Review of Plans for Funding Transportation
DOE-NNSA’s dilute and dispose plan utilizes many existing DOE facilities, processes, and systems. In support of that effort, several intra-DOE partner programs have, according to the LCCE, agreed to support DOE-NNSA’s Dispose and Dilute Mission Need through utilization of current transportation and repository emplacement systems already in use. DOE-NNSA’s partner programs have accepted and will incorporate base operations costs and capacities of dilute and dispose into their ongoing program missions (SRNS, 2018a). For example, the DOE-CBFO and the OST programs have agreed to accept these costs. Transportation and emplacement at WIPP were not included in the LCCE (SRNS, 2018a, pp. 6, 9, 22) because these activities are determined to be within base operating costs of existing DOE programs (DOE, 2018b, p. 6).
The U.S. Army Corps of Engineers conducted an independent assessment of the cost estimation used in the LCCE for the dilute and dispose program. They noted that DOE-NNSA’s approach of not including transportation costs may have been:
appropriate for estimation of “program” related lifecycle costs since the program has assumed that all non-NNSA funded support of facilities and personnel will continue to be funded by their existing partner programs. However, this assumption appears to be inconsistent with expectations of GAO guidance that LCCEs capture all relevant life cycle costs, without regard to funding source. Further, the absence of these costs may result in inappropriate conclusions if the estimate is used to compare the LCCE for the Dilute and Dispose approach and the LCCE resulting from continuation of the MOX approach for disposition of surplus plutonium. This is because the values of these cost elements will not necessarily be the same for the MOX approach. (USACE, 2018, p. 29)
A key aspect of the PMDA (see Chapter 2) is to render the surplus plutonium into “forms unusable for nuclear weapons” (DOS, 2000, p. 1), thus making it “practicably irrecoverable” by International Atomic Energy Agency (IAEA) definitions (IAEA, 1972, p. 4). The agreed-upon method for disposition by both the United States and the Russian Federation in the PMDA is irradiated MOX fuel. The spent fuel standard has been used as a recoverability metric to compare various plutonium disposition options and is defined by DOE as follows: “The surplus weapons usable plutonium should be made as inaccessible and unattractive for weapons use as the much larger and growing quantity of plutonium that exists in spent nuclear fuel from commercial power reactors” (DOE, 1997, footnote 5). While the PMDA does not use this term, irradiated MOX fuel meets the spent fuel standard.
The current PMDA-approved method of disposition is the MOX fuel option that includes irradiation in a reactor and would provide the following barriers for reuse in weapons (NRC, 1994):
- Chemical: Oxidation of the plutonium metal, and dilution of the oxidized plutonium with uranium oxide (UO2) to form MOX fuel.
- Isotopic: The plutonium-239 isotopic composition is shifted during irradiation by the fission of plutonium-239 and -241 and by the transmutation of plutonium-239 to -240, plutonium-240 to -241, and plutonium-241 to -242. The ratio of plutonium-240/plutonium-239 would be increased to at least 0.1, making the plutonium much more difficult to use for production of normal weapons.
- Radiation: Irradiation in a reactor creates a radiation barrier sufficient to be self-protecting for decades.
- Physical: The weight and size of a nuclear fuel assembly is sufficient to require special-handling equipment for processing.27
- Chemical: Oxidation of the plutonium metal and dilution of the plutonium-239 with a classified dry-blended adulterant, and
- Physical: Packaging of the diluted plutonium within a stainless steel pipe (the CCC) within a 55-gallon drum and emplaced in the underground at WIPP.
DOE-NNSA asserts that the end state (after both dilution and emplacement in a repository) of the dilute and dispose process would introduce sufficient chemical and physical barriers to practical recovery of the material to meet non-proliferation objectives (i.e., deterring future recovery by the United States or by others).
27 A fuel assembly consisting of ~200 rods and 12 feet long is more than 2 MT (see, e.g., https://www.nrc.gov/materials/fuel-cycle-fac/fuel-fab.html (accessed May 20, 2020) for light-water reactor fuel assemblies).
The committee was asked to review additional waste streams and to assess DSP-TRU waste’s potential impact on them as well as the impact on LWA capacity limits. In updating the volume information reported in the Interim Report with the new volume of record (VoR) calculation (see Box 2-2), the committee updated the volumes of specific waste streams noted in its Interim Report and used DOE-reported volumes for emplaced and future TRU wastes (DOE-CBFO, 2018a, 2019a).
3.5.1 Estimates of Volumes of Other Potential TRU Wastes
A summary of the volume estimates for specific wastes updated from the Interim Report are below. The committee makes the assumption that, for future waste estimates, the three TRU wastes streams listed below will be placed into direct-loaded 55-gallon drums and will therefore have equivalent LWA and Resource Conservation and Recovery Act TMW volumes (see Box 2-2). Also, estimated future volumes are based on currently available information. Future volume estimates have uncertainties and can vary from one estimate to the next. The numbers presented below are used to illustrate the issue of the possible over-subscription of the LWA limits at WIPP, and hence the issue of competition for limited remaining space:
Further notes, references, and assumptions about these waste volumes are highlighted below:
- DOE has not made a decision to dispose of tank waste in WIPP but the volumes have been included in future estimates of WIPP waste. Disposal of some TRU waste stored in tanks at Idaho and Hanford would require 3,187 m3 based on recent estimates.28 However, the tank waste estimates vary by year. For example, earlier estimates of tank wastes from Hanford indicate up to 8,400 m3 of disposal space, not including the volume of tank waste solidifier (DOE-CBFO, 2014, section 184.108.40.206).
- Disposal in WIPP of GTCC and GTCC-like waste was identified as one of several preferred alternatives in the final EIS for GTCC and GTCC-like waste. The volume of DOE-owned and generated GTCC-like waste is 2,900 m3 (DOE, 2016b, table S-1, GTCC-like totals for Groups 1 and 2). The total volume of both GTCC and GTCC-like waste would require about 12,000 m3 of disposal space.
- Estimated volumes for TRU waste generated from future pit production are provided in the Final EIS (DOE, 2019).29 For the most likely scenario, 30 pits per year at LANL and 50 pits per year at SRS, DOE estimated that over 50 years of the program, 57,550 m3 of TRU waste would be generated. Of note was the ability of DOE to prioritize TRU waste streams for emplacement in WIPP (DOE, 2019, p. 65): “In addition, use of WIPP capacity for national security missions such as pit production would be given priority in the allocation process.”
- Estimates of projected TRU waste generated from pit production activities at LANL have been separately reported. For example, a recent draft supplemental analysis of the Site-wide EIS for Continued Operations of LANL reported TRU waste generation estimates for pit production to
29 At the time of the Interim Report’s release, estimated volumes of TRU waste generated by pit production activities were not available. All volumes noted here are assuming the TMW (outermost container) volume. The LWA volume may be less because some waste may be overpacked.
- be 5,350 m3 (DOE, 2020, table 4-5). In another, waste stream LA-MHD01.001 was identified in the 2019 Annual TRU Waste Inventory Report (ATWIR) as TRU waste generated by LANL’s pit production activities (“Mixed heterogeneous debris waste generated in TA‐55”) with an estimated total volume of 4,756 m3 (DOE-CBFO, 2019b, p. 147). This latter volume is subtracted from the 57,550 m3 total from the pit production EIS in Table 3-2.
- Another recent decision by DOE could affect the shipping capacity needed for dilute and dispose plans. DOE, the U.S. Navy, and Idaho agreed that DOE-CBFO would prioritize TRU waste shipments from Idaho National Laboratory (INL) until nearly all of the TRU waste has been removed from INL. DOE-CBFO has agreed to allocate at least 55 percent of WIPP shipments to INL.30
TABLE 3-2 Volumes of Emplaced and Future TRU Wastes for WIPP
|Before VoR (m3)||After VoR (m3)||Reference|
|DSP-TRU (48.2 MT)||33,740||2,056||Committee calculation (based on 300 FGE per container)|
|Emplaced TRU waste in WIPP through end of 2018a||94,936||67,175||WDS/WWIS datasets, October 2018 and April 2019|
|Projected TRU waste thru 2033 and beyond||80,080d||63,011e||(DGE-CBFO, 2018a, tables 3-3 and 4-4: DOE-CBFO, 2019a, tables 3-3 and 4-4)|
|GTCC-likeb||2,900||2,900||(DOE, 2016b, table S-1, CH + RH values from Groups 1 and 2)|
|Pit production TRU wasteb,c||52,794||52,794||DOE, 2019; DOE-CBFO, 2019b|
|% LWA capacity limit||152||109||Maximum: 175,564 m3|
NOTES: References for the table values are included. ATWIR = Annual TRU Waste Inventory Report; DSP-TRU = diluted surplus plutonium transuranic; EIS = environmental impact statement; GTCC = Greater Than Class C; LWA = Land Withdrawal Act; VoR = volume of record; WDS/WWIS = Waste Data System/WIPP Waste Information System.
a The values are interpolated from data reported on October 13, 2018, and April 3, 2019, in the WDS/WWIS as an estimate for the emplaced volume on December 31, 2018.
b Assumed to be direct loaded so volumes are not affected by VoR calculation.
c In the 2019 ATWIR, waste stream LA-MHD01.001 (TRU waste generated by LANL’s pit production activities) estimated total volume is listed as 4,756 m3 (DOE-CBFO, 2019b, p. 147). This total is subtracted from the 57,550 m3 total from the pit production EIS.
e DSP-TRU waste volumes associated with waste streams SR-KAC-PuOx (6 MT of surplus plutonium) and SR-KAC-PuOX-1 (7.1 MT of surplus plutonium) has been subtracted from the total (589 m3, after VoR, see DOE-CBFO, 2019a) noting that a portion of the 7.1 MT volume is not included in the projected totals.
30 See the Idaho/DOE/Navy Supplement Agreement Concerning Conditional Waiver of Sections D.2.e and K.1 and the 1995 Settlement Agreement (see p. 5): https://gov.idaho.gov/wp-content/uploads/sites/74/2019/11/doe-inl2019-supplemental-agreement-signed.pdf (accessed May 20, 2020).
3.5.2 Emplaced and Future TRU Wastes Volumes
The committee used several sources from DOE-CBFO to assess the impact of DSP-TRU on future waste streams in addition to those listed above (because the waste streams discussed above are mostly not included in current DOE-CBFO estimates of future TRU wastes). The sources are emplacement volumes in WIPP reported by WDS,31 to determine a value for emplaced wastes; and the two most recent ATWIRs, to estimate future waste volumes. The 2018 ATWIR (DOE-CBFO, 2018a), which provided estimates of future TRU waste volumes as of December 31, 2017, is the last inventory released by DOE-CBFO before the VoR changes took effect. The 2019 ATWIR (DOE-CBFO, 2019b) was released in December 2019, with estimates of TRU as of December 31, 2018, and is the first to report LWA and TMV volumes separately. The 2019 ATWIR includes adjusted volumes from the 2018 ATWIR—which are recalculated according to the VoR instructions. The committee chose to use the 2018 estimated and adjusted volumes to illustrate the impact of the VoR on emplaced and future TRU wastes.
The relevant tables from the two reports (DOE-CBFO, 2018a, 2019a) are
- Table 3-3. CH/RH [Contact Handled/Remote Handled] Waste Volume Changes—which lists the grand total volume for the current and previous year estimated through 2033 (in the 2019 ATWIR, this includes the column Adjusted ATWIR-2018 Totals); and
- Table 4-4. Projected WIPP CH/RH-TRU Volume Beyond 2033—which provides estimated projected volumes in addition to the values listed in Table 3-3.
The committee’s assessment is summarized in Table 3-2. At the beginning of the committee deliberations, under the outer container volume accounting, it was evident that the total surplus plutonium inventory would exceed the WIPP capacity, as was noted in the DOE-NNSA Surplus Plutonium Disposition Performance Assessment Inventory Report—2017: “The volume of anticipated (stored plus projected) and emplaced TRU waste reported by the DOE TRU waste sites … including the SPD proposal, exceeds the legislated volume capacity for WIPP by approximately 17,700 m3” (LANL, 2017, p. 10).
Additionally, there is inordinate pressure on WIPP to accommodate all federal needs for disposal of defense TRU wastes for decades to come, and reliable access to its capacity, both physical and statutory, is an essential and critical requirement for the success of DOE-NNSA’s conceptual plans. The DSP-TRU waste streams, both DOE-NNSA’s and DOE-EM’s, can be well estimated decades in advance.32 Previously, the committee was told that there were no mechanisms for prioritizing disposal space years in advance or reserving space in WIPP for high-priority waste streams.33
However, the data in Table 3-2 and Figure 3-9 make clear that LWA statutory capacity remains an issue, primarily due to pit production TRU waste. In fact, the impact of the DSP-TRU waste on other wastes is miniscule—which represents ~1 percent of the LWA capacity (or 2,057 m3)—but the impact of other wastes on DSP-TRU is large. The committee’s recommendation to prioritize DSP-TRU waste and to reserve space in WIPP remains valid—especially since DOE has made similar agreements for pit production TRU waste and guaranteed shipment rates from Idaho.
31 TMW and LWA totals as reported by WDS/WWIS Repository volumes dates October 13, 2018, and April 3, 2019; two reports that were downloaded by the committee.
32 The character and form of the DSP-TRU waste is deliberately produced (not a waste derived from other processes) and the volume of the containers is standardized, allowing high-resolution projections to be made, unlike much of the TRU waste that is generated through routine operations across the DOE complex. The physical volume of DSP-TRU waste generated from 48.2 MT would fill approximately two of WIPP’s existing panels.
RECOMMENDATION 3-1 (modified from Interim Report RECOMMENDATION 1): Capacity at the Waste Isolation Pilot Plant (WIPP) should be treated as a valuable and limited resource by the Department of Energy (DOE). DOE is able to prioritize national security mission waste streams for WIPP (i.e., pit production transuranic [TRU] waste). Because emplacement in WIPP is critical to both DOE’s Office of Environmental Management’s (DOE-EM’s) and DOE’s National Nuclear Security Administration’s (DOE-NNSA’s) dilute and dispose plans, the DOE-NNSA Administrator, in consultation with the DOE-EM Assistant Secretary, should prioritize and reserve Land Withdrawal Act capacity in WIPP for the full amount of diluted surplus plutonium TRU waste (2,057 cubic meters). Otherwise, the DOE-NNSA and the DOE-EM programs are at risk of not being able to disposition the full amount of 48.2 metric tons of surplus plutonium via dilute and dispose.
DOE-NNSA has promulgated two documents to address risk management and analysis for the dilute and dispose program. The first of these documents, the Risks and Opportunities Management Plan (SRNS, 2018d, table 3), formalizes DOE’s risk management plan consistent with Government Accountability Office (GAO) criteria for cost estimating and assessments. The U.S. Army Corps of Engineers has independently reviewed the ROMP and found that the overall plan meets GAO criteria, but noted some deficiencies. The committee has not undertaken a separate analysis of the ROMP given that DOE has already adopted this risk management approach and because it has been evaluated formally.
The second document, the Risk and Opportunity Analysis Report (SRNS, 2018e, table ES.3), contains the DOE-NNSA risk team’s assessments of program and execution risks for the dilute and dispose approach. The dilute and dispose ROAR seeks to identify, quantify, and evaluate economic consequences of the dilute and dispose program. This application is similar to most economic risk and opportunity approaches with some interesting differences because it is a government-funded project and a large investment with numerous options. Several key points are that 28 experts were involved as primary contributors and many more contributed from the following sites:
The research team followed a typical process, including
- Reading documents,
- Identifying assumptions,
- Sorting out many options to find those with the highest level of risk and opportunity, and
- Narrowing the list and evaluating options.
The ROAR indicates that 124 actions/events were identified. Of these, 76 were excluded according to the authors as duplicative and too improbable. The authors of the ROAR acknowledge that three risk sources were excluded from consideration, including revision of the baseline requirements for the project; changes in funding from the initial authorization; and events out of control of the responsible organizations. The ROAR summarizes key conclusions and summarizes 48 risks and opportunities. Most summaries are 1 to 1.5 pages and include background, event, and impact of the event on cost should it occur, as well as brief notes on the likelihood of the event.
This committee focused on the 10 boxes in the “high” category for “program” and “execution” risks. Given the materials provided, the committee has no basis to question the classification of high versus moderate versus low risks and benefits. However, three issues are of concern, listed in order of importance below.
The first is that the ROAR risk analysis is focused on cost, not on human or ecological health. For example, an anomalous event at WIPP causing delays in shipments from SRS (Event ID 2716, SRNS, 2018e) is rated a “moderate” risk. The report notes that such an event occurred in 2014 leading to the well-known 3-year shutdown of WIPP. At the time of the event, there was an expectation that the event might cost $2 billion to remediate. However, some venting to the surface did occur as a result, and although it was minimal, this fact is not noted in the risk analysis. It could be argued that this is not a “moderate” risk when human or ecological health are accounted for.
The second of these issues is the lack of data and technical justification for the findings. For example, the ROAR identifies a program risk, anomalous events occur at SRS causing delays in shipments to WIPP (ID 2635), as a schedule risk with a reported frequency of occurrence of once every 10 years, or at least three times over the program life. The committee has no data to independently substantiate the estimated frequency of unplanned events in the proposed program and there is concern over the fidelity of these data used in the ROAR based on the early phases of both the DOE-EM and the DOE-NNSA programs.
The third issue is the brevity of the descriptions and the collapsing of several events into another. The committee was unable to satisfy itself that all risks are sufficiently captured and reviewed—especially in terms of health and safety. Examples include certain potential exposure events, such as an incident in which K-Area infrastructure fails or a site safety incident occurs (Infrastructure Failure of Less Than 6 Months May Cause Delays [K-Area, SRS], Event ID 2603), which addressed health and safety a bit more explicitly than others. In the ROAR, that event was then rolled into K-Area Infrastructure Failures Causing Disruption in Operations May Cause Delays and Impact Production (Event ID 2608)—which was closed. Event ID 2608 made no mention of the exposure or health and safety concerns, and so Event ID 2603 was seemingly lost rather than included. In another example, Blend Can Non-Destructive Assay (NDA) Equipment Calibration Failure Causes Rework and Additional Operator Exposure (Event ID 2606) includes exposure risks in its title and statement of event, but the description focuses on the operational element in the rest of the summary.
These types of events are clearly presented in the detailed event sheets in the appendixes, but they are buried in the main body of the ROAR. The descriptions of the risks and mitigations could be made explicit about all the types of risks addressed and properly represented in summary.
RECOMMENDATION 3-2: The focus of the Risk and Opportunity Analysis Report (ROAR) is on cost and schedule. This approach is different from a standard risk assessment and performance assessment and the Department of Energy’s National Nuclear Security Administration (DOE-NNSA) should clearly communicate what types of risks it addresses in the ROAR and what types it does not. It is not clear how human and ecological health (and other risks) within the dilute and dispose program are identified and managed in addition to the numerous DOE nuclear safety and security orders to which all programs must comply. Therefore, DOE-NNSA should clearly state how the risks to human health and safety are addressed in its plans. One option is to add a category to the ROAR events to indicate plausible risks and consequences of exposing workers and especially the public.