Review of the Department of Energy's Plans for Disposal of Surplus Plutonium in the Waste Isolation Pilot Plant (2020) / Chapter Skim
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5 System Vulnerabilities
5 System Vulnerabilities
Pages 81-105
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From page 81... ...
5.1 UNCLEAR FUTURE FOR THE PMDA AND ITS IMPACT ON THE DILUTE AND DISPOSE PLAN Several concerns regarding the Plutonium Management and Disposition Agreement (PMDA) between the Russian Federation and the United States, its uncertain future, and its relevance to the implementation and sustainability of the dilute and dispose plans for U.S.
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From page 82... ...
repository -- is not easily removed especially in the case of salt repositories such as the Waste Isolation Pilot Plant (WIPP) because salt creep is intended to entomb the waste within a few decades of emplacement and closure, adding to the difficulty of removal.
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From page 83... ...
2022 and for WIPP in FY 2023, yet DOE-NNSA may emplace DSP-TRU waste with or without IAEA inspection protocols in place. 5 Therefore, substantial uncertainty remains on the applicability and possible implementation of IAEA monitoring and verification protocols.
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From page 84... ...
8 A renegotiated PMDA could provide a strong assurance over decades that the dilute and dispose program would receive congressional support it needs to meet its non-proliferation objectives. However, recovery of emplaced diluted surplus plutonium by the United States and the lack of established IAEA monitoring and inspection protocols add challenges to the renegotiation.
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From page 85... ...
An approved approach for recovery by the United States of the emplaced diluted surplus plutonium waste form and lack of a clear plan for implementing IAEA inspections add further barriers to adherence of PMDA principles. CONCLUSION 5-1: Although not required for the Department of Energy's National Nuclear Security Administration's dilute and dispose program to move forward, a renegotiated Plutonium Management and Disposition Agreement (PMDA)
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From page 86... ...
approved in late 2018 a permit modification request by DOECBFO to alter the accounting and reporting of TRU waste volumes, as described in detail in Box 2-3. In summary, the change created two reporting volumes: a "Land Withdrawal Act TRU Waste Volume of Record" or LWA volume to refer to the volume as calculated using the gross internal volume of the disposal container for direct-loaded containers and the innermost disposal container for overpack containers and the "TRU Mixed Waste Volume," or TMW volume, to refer to the physical volume of all of the containers.
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From page 87... ...
These additional wastes put completion of the DSPTRU waste emplacement plans at risk. 5.2.2 WIPP Operational Availability Beyond sufficient waste volume capacity to fully support the dilute and dispose program objectives, another aspect of the WIPP availability issue concerns the mitigation of risks that threaten the ongoing and continuous availability of WIPP.
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From page 88... ...
5.3 CHANGING NATURE OF WIPP In the past, the TRU waste emplaced in WIPP has routinely been described as clothing, tools, rags, residues, debris, soil, and other items contaminated with small or moderate amounts of plutonium and other man-made radioactive elements, the unavoidable by-products of processes related to weapons production. 11 This notion extends to the original Compliance Certification Application where it is also noted that this type of waste is expected to be the largest category by volume: This notion that TRU waste comprises things modestly contaminated with plutonium (as opposed to 11 conditioned plutonium material)
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From page 89... ...
concluded that WIPP would reach current available physical capacity by 2026 and that at least two additional panels would be needed to accommodate future diluted surplus plutonium TRU waste. The existing panels in the WIPP underground are nearly full, and so new panels will have to be designed and mined to accommodate future wastes.
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From page 90... ...
TABLE 5-2 Increase in Total Radioactivity Reported by the Generator Sites for CH-TRU and RH-TRU Waste Between CRA-2014 and CRA-2109 NOTE: The majority of this increase (2.4 million Ci) is from SRS and is mainly due to the addition of the projected waste stream SR-KAC-PuOx representing the 6 MT DSP-TRU (accounted as ~4,200 m3 of TMW volume, and ~256 m3 of LWA Waste Container Volume)
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From page 91... ...
. 16 A full nuclear criticality assessment had not previously been performed for WIPP inventories because historically the TRU waste streams were characterized as having generally more dispersed fissile material and the mechanisms to concentrate the dispersed fissile material were considered absent (Rechard et al., 2000)
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From page 92... ...
TRU Wastes Compared to Wastes in Other 55-Gallon Drum Containers aTechnical Baseline Description, SRNS, 2018b. bNumber of waste streams derived from WDS/WWIS as of September 30, 2019, from https://wipp.energy.gov/WDSPA (accessed May 20, 2020)
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From page 93... ...
The addition of boron carbide readily removes the potential for criticality as seen in Figure 5-2. 17 The criticality safety assessment (evaluated over the 10,000-year compliance period)
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From page 94... ...
and further supplements: "The potential environmental impacts of TRU waste disposal at WIPP are evaluated in the Waste Isolation Pilot Plant Disposal Phase Final Supplemental Environmental Impact Statement (WIPP SEIS-II) (DOE/EIS-0026-S-2, September 1997)
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From page 95... ...
FINDING 5-2: The diluted surplus plutonium transuranic (DSP-TRU) waste streams appear to have little impact on the Waste Isolation Pilot Plant's (WIPP's)
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From page 96... ...
The initial criticality safety assessment, which has noted that abatement of criticality concerns may require boron carbide additives or load management, is in the context of the current room/panel design and evaluated for the 10,000-year regulatory compliance period. 20 Senator Udall helped establish the legal limits in the Waste Isolation Pilot Plant Land Withdrawal Act that resulted following a lawsuit that New Mexico won against DOE when he served as Attorney General for New Mexico.
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From page 97... ...
CONCLUSION 5-3: The possible accommodation of the dilute and dispose program inventory, representing a significant demonstrable change in the character of the Waste Isolation Pilot Plant repository and the social contract with the State of New Mexico, warrants a strategic approach to seeking its technical evaluation, regulatory review, safety analysis, and public engagement. An essential element to engender public trust and stakeholder acceptance is the use of independent oversight (versus regulatory)
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From page 98... ...
: The Department of Energy's National Nuclear Security Administration and Office of Environmental Management should engage New Mexico and South Carolina as well as their congressional delegations prior to the public engagement required by the National Environmental Policy Act process to assess prospects for successfully amending the existing legal agreements to allow for the dilution and packaging of up to 48.2 metric tons of surplus plutonium at the Savannah River Site and its disposal in the Waste Isolation Pilot Plant.
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From page 99... ...
Members of the public and the State of New Mexico should be afforded the opportunity to consider the significance of the dilute and dispose program in its entirety. As noted previously, a new DSP-TRU waste stream was recently identified, SR-KAC-PuOx-1, and associated with the 7.1 MT of surplus pit plutonium material (DOE-CBFO, 2019b)
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From page 100... ...
. Below, two federal actions and decisions relevant to the dilute and dispose programs are highlighted: • The final programmatic EIS, FPEIS-0229, evaluated strategies and locations for storing and dispositioning weapons-usable 21 fissile materials (DOE, 1996b)
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From page 101... ...
19588) ; and • Use the existing WIPP SEIS to maintain that the environmental impact of adding surplus plutonium at WIPP were evaluated: "The potential environmental impacts of TRU waste disposal at WIPP are evaluated in the Waste Isolation Pilot Plant Disposal Phase Final Supplemental Environmental Impact Statement (WIPP SEIS-II)
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From page 102... ...
RECOMMENDATION 5-5: The Department of Energy should implement a new comprehensive programmatic environmental impact statement (PEIS) to consider fully the environmental impacts of the total diluted surplus plutonium transuranic waste inventory (up to an additional 48.2 metric tons)
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From page 103... ...
. One could argue that the anticipated changes to the WIPP underground configuration, its lifetime extension (both of which are likely even without the DSP-TRU waste)
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From page 104... ...
FINDING 5-7: A segmented and incremental approach to revealing the full inventory under consideration for disposal as diluted surplus plutonium transuranic waste in the Waste Isolation Pilot Plant (WIPP) (initially 6 metric tons [MT]
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From page 105... ...
RECOMMENDATION 5-7: The Environmental Protection Agency, the Department of Energy, and the State of New Mexico should engage in developing a mutually agreed-upon strategy for vetting the effects of the dilute and dispose inventory, in its entirety (and as added to the rest of the projected and emplaced inventory) , on the Waste Isolation Pilot Plant.
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