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WIPP Regulatory Compliance November 5, 2008

WIPP Regulatory Compliance November 5, 2008. Ross Kirkes Sandia National Laboratories John Hart and Associates, P.A. Carlsbad, New Mexico SAND 2008-6920P.

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WIPP Regulatory Compliance November 5, 2008

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  1. WIPP Regulatory ComplianceNovember 5, 2008 Ross Kirkes Sandia National Laboratories John Hart and Associates, P.A. Carlsbad, New Mexico SAND 2008-6920P Sandia is a multiprogram laboratory operated by Sandia Corporation, a Lockheed Martin Company, for the United States Department of Energy under contract DE-AC04-94AL85000.

  2. Key Legislative and Regulatory Actions

  3. WIPP Land Withdrawal Act - 1992 • LWA withdrew WIPP site (16 square miles) from public domain • Established EPA as the regulatory authority for WIPP; i.e., EPA identified as WIPP’s “certifier” • Directed EPA to issue final disposal regulations - 40 CFR 191 was held in remand due to First Circuit court decision • Directed EPA to issue certification criteria • Directed EPA to recertify WIPP’s compliance every 5 years 2

  4. 40 CFR Part 191 “Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes” • Has 3 primary components • Subpart A: Applies to doses to man during operations • Subpart B: Establishes 1) long-term containment requirements; 2) assurance requirements; and 3) individual protection requirements due to disposal • Subpart C: Protection of sources of groundwater from contamination • WIPP Compliance Applications address only Subparts B and C 3

  5. 40 CFR Part 191, Subpart B • Subpart B has 3 primary components: • Containment Requirements • Must consider human intrusion (disturbed performance) • 10,000 year performance period • Must demonstrate a “reasonable expectation” of compliance • Assurance Requirements • Used to reduce uncertainties associated with long-term disposal systems • Individual Protection • Limits radiation doses to the public • Applies to undisturbed performance only 4

  6. 40 CFR Part 191, Subpart C • Subpart C, “Groundwater Protection” • Must demonstrate that the disposal system will not cause concentrations of radionuclides in groundwater to exceed levels specified in the Safe Drinking Water Act (40 CFR 141) during the 10,000-year performance period • Applies to undisturbed performance only 5

  7. Subpart B Containment: Release Limits For Undisturbed and Disturbed Performance Subpart B Individual Protection Dose Limits For Undisturbed Performance Subpart A Management and Storage Environmental Dose Limits During Operational Period 1998-2033 (anticipated) Subpart B Assurance: Monitoring, Institutional Controls, Multiple Barriers,Natural Resources, Retrievability Subpart C Ground-Water Protection: Concentration Limits For Undisturbed Performance Key Elements of 40 CFR 191

  8. 40 CFR Part 194 “Criteria for the Certification and Recertification of the Waste Isolation Pilot Plant’s Compliance with the 40 CFR 191 Disposal Regulations” • Establishes Certification Criteria for WIPP • Specifies HOW the WIPP shall demonstrate compliance with 40 CFR 191 • Specifies WHAT must be in a compliance application • Specifies how CHANGES to the approved compliance baseline will be addressed 7

  9. History of WIPP’s Compliance Documentation • WIPP began proactively developing compliance documents in anticipation of forthcoming EPA regulations • Compliance Status Report (1994) • First attempt at a documenting compliance in a regulatory format; intended to demonstrate the project’s maturity of both scientific and regulatory programs • Draft Compliance Certification Application (1995) • Second attempt; based on EPA’s draft Certification Criteria • Compliance Certification Application (1996) • DOE’s first Formal Compliance Application prepared to EPA’s final Certification Criteria

  10. Regulatory Cycle • DOE Submitted the Compliance Certification Application in October 1996 • - EPA Issued WIPP’s Certification in May 1998 • - Waste disposal began March 26, 1999 • DOE Submitted the Compliance Recertification Application March 26, 2004 • - EPA Recertified WIPP March 29, 2006 • Currently completing the 2009 Compliance Recertification Application planned for March 2009 9 For internal use only. Do not cite or distribute.

  11. Recertification Application Content • Recertification applications must provide updated information that is relevant to compliance • - Monitoring data • - New analyses and results • - Experimental work and results • - New or different inventory estimates • “…any activities or assumptions that deviate from the most recent compliance application” (40 CFR 194.15(6))

  12. Recertification Application Content • New performance assessments have been required for CRA-2004 and CRA-2009 • - Performance assessments for recertification roll-up any changes to the baseline since the most recent recertification application • Changes in the amount of the chemical engineered barrier • Changes in the mine geometry • Changes in models • Changes in engineered systems • Model grid changes • New or different model parameters • Inventory updates • Hydrologic flow field updates (t-fields) • EPA wants to see if there are any unexpected consequences from the sum of these changes, which are usually granted in piecemeal fashion

  13. Recertification Application Format • Compliance Certification Application (1996) and the Compliance Recertification Application (2004) told a story • - Geology prior to disruption to construct facility • - Facility design • - Waste expected in facility • - Conceptual models that describe what will happen in the facility over time (scenarios) • - Same basic chapter and appendix format • Nine main chapters • Approximately 15 appendices • CRA-2004 used blue italics to identify changed text in the original CCA.

  14. Recertification Application Format • CRA-2009 format has been changed to resemble the EPA’s Compliance Application Review Documents (CARDs) • - Presents the specific regulatory criterion followed by DOE’s demonstration of compliance with that section e.g., 194.42 Monitoring; 194.43 Passive Institutional Controls; 194.44 Engineered Barriers… • Heavily references the CCA and CRA-2004 • Will provide EPA with electronic versions that use hyper-links to previous applications and references

  15. Compliance Recertification Application 2009 Schedule • Began drafting sections of CRA in Sept-07 • Computer models ran Dec-07 thru Feb-08 • Performance Assessment documentation developed Oct-07 thru Jul-08 • Phased reviews in Apr-08, Jul-08, Aug-08, & Sept-08 • Final internal review in Nov-08 • Provide to DOE HQ in December for signature by Secretary of Energy • Transmit to EPA in March 2009

  16. QUESTIONS?

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