                                                   DOCKET: EPA-HQ-OAR-2014-0609
                                       
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                       
                                       
                                       
                        TECHNICAL SUPPORT DOCUMENT FOR
                                       
                        SECTION 194.24:  REVIEW OF THE 
BASELINE INVENTORY USED IN THE COMPLIANCE RECERTIFICATION APPLICATION (CRA-2014) 
                                       
                                       
               Contract Number EP-D-10-042, Work Assignment 5-12
                                  Revision 0
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                     U.S. ENVIRONMENTAL PROTECTION AGENCY
                      Office of Radiation and Indoor Air
                  Center for Waste Management and Regulations
                             Washington, DC 20460
                                       
                                       
                                   July 2017
Table of Contents

Preface		iii
Acronyms	iv
1.0	Introduction	1
1.1	Inventory Terminology	3
1.2	Performance Assessment Inventory Requirements	3
2.0	Verification of the Inventory Assembly Process	5
2.1	Inventory Information Assembly and Review Process	5
2.1.1	The Comprehensive Inventory Database (CID)	5
2.1.2	Inventory Updating Procedure	6
2.2	Site Visits	7
2.3	Conclusion	13
3.0	Changes from the PABC-2009 Inventory to CRA-2014	14
3.1	Waste Volumes	14
3.1.1	Scaling Factors	14
3.1.2	CH TRU Waste Volumes	15
3.1.3	RH TRU Waste Volumes	15
3.2	Radionuclide Inventory	16
3.3	Non-Radioactive Waste Components	20
3.3.1	Materials Limits	20
3.3.2	Waste Material Parameters	20
3.3.3	Organic Ligands	21
3.3.4	Packaging Materials	22
3.3.5	Oxyanions in the Waste Inventory	22
3.3.6	Other Materials	22
3.3.7	Emplacement Materials	23
3.4	Verification of Parameters used in PA	24
3.5	Other Review Activities	24
4.0	Conclusions	25
5.0	References	26

List of Tables

Table 1-1.	Sources of Inventory Information for Certification/Recertifications	2
Table 2-1.       EPA Waste Characterization Inspections	7
Table 3-1.	WIPP Volume Scaling Factors	14
Table 3-2.	Unscaled CH TRU Waste Volumes for CRA-2014 based on ATWIR 2012 Inventories	15
Table 3-3.	Unscaled RH TRU Waste Volumes for CRA-2014 based on ATWIR 2012 Inventories	16
Table 3-4.       Total EPA Units used in Performance Assessments.	18
Table 3-5.	Scaled Radioactivity in the WIPP Repository	18
Table 3-6.       Comparing Activity (Ci) By Radionuclide Decayed to 2033	19
Table 3-7.       Comparing Total Activity (Ci) By Year.	20
Table 3-8.       Comparing Waste and Packaging Materials (kg)	21
Table 3-9.        Comparing Organic Ligands (kg)	22
Table 3-10.     Comparing Oxyanions (kg)	22
Table 3-11.     Cements (kg)	23
Table 3-12.     Cement Comparisons (kg)	23
Table 3-13.     Comparing Emplacement Materials (kg)	24

                                       
 Preface
The U.S. Department of Energy (the DOE) is required to submit a Compliance Recertification Application (CRA) to the U.S. Environmental Protection Agency (EPA) for the Waste Isolation Pilot Plant (WIPP) facility every five years including an updated assessment of future WIPP performance. During the EPA's review of the DOE's CRA-2014 performance assessment (PA), events associated with the February 2014 repository fire and radionuclide release have resulted in closed portions of the underground facility. This closure has created a situation where certain parts of the underground facility could not be accessed for ground control. Panel 9 may be abandoned along with plans to install panel closures in panels 3, 4, 5 and 6. 
Because the CRA performance assessments are predictions of post-closure repository performance and the EPA knows there will be modifications to the current repository design, modifying the CRA-2014 PA at this time to incorporate alternative parameter values would not add more reality to predictions of repository post-closure performance. Consequently, the EPA adopted the CRA-2014 PA as originally submitted by the DOE as the baseline, rather than have the DOE conduct a revised PA baseline calculation (PABC). In lieu of requesting a PABC-2014, the EPA requested that the DOE the DOE conduct a set of sensitivity studies to address some of the significant technical concerns arising from the EPA's CRA-2014 review. The inputs to these sensitivity studies broadly address many of the EPA's technical concerns that could potentially impact long-term repository performance. The Agency has reviewed the results of these studies and determined that there exists an adequate level of confidence -- that is, a reasonable expectation -- that the repository will continue to comply with EPA regulations. 

Additionally, the EPA recommends further work that can be conducted to evaluate many of the technical concerns identified in the EPA's review of the CRA-2014 PA, as well as incorporate future repository design changes. The EPA will work with the DOE to determine the best path forward for resolution of EPA's concerns, which could include additional data reviews, independent technical reviews, and possibly additional sensitivity analyses to reach a consensus for the next CRA. It is anticipated that the results of these efforts will be incorporated into the CRA-2019 PA or otherwise be made available during the EPA's review of the CRA-2019 PA.
Acronyms

ANL-E
Argonne National Laboratory  -  East
ANL-W
Argonne National Laboratory  -  West
ATWIR
Annual Transuranic Waste Inventory Report
BL
Babcock Wilcox
CARD
Compliance Application Review Document
CBFO
Carlsbad Field Office
CCA
Compliance Certification Application
CFR
Code of Federal Regulations
CH
Contact-Handled
Ci
Curie
CID
Comprehensive Inventory Database
CPR
Cellulose, Plastic, and Rubber
CRA
Compliance Recertification Application
DOE
U.S. Department of Energy
EDTA
Ethylenediaminetetraacetic Acid
EPA
U.S. Environmental Protection Agency
GE-VNC
General Electric  -  Vallecitos Nuclear Center
Hanford-RL
Hanford Richland Operations Office
INL
Idaho National Laboratory
KAPL-NFS
Knolls Atomic Power Laboratory  -  Nuclear Fuel Services
LANL
Los Alamos National Laboratory
LANL-CO
Los Alamos National Laboratory  -  Carlsbad Operations
LLNL
Lawrence Livermore National Laboratory
LWA
Land Withdrawal Act (PL 102-579)
MFC
Material Fuel Complex
MgO
Magnesium Oxide
MTHM
Metric Tons of Heavy Metal
MWd
Megawatt Days
NRD
Nuclear Radiation Development
NTS
Nevada Test Site
ORNL
Oak Ridge National Laboratory
PA
Performance Assessment
PABC
Performance Assessment Baseline Calculation
PAIR
Performance Assessment Inventory Report
PAVT
Performance Assessment Verification Test
QA
Quality Assurance
RFETS
Rocky Flats Environmental Technology Site
RH
Remote-Handled
RL
(Hanford) Richland
RP
(Hanford Office of) River Protection
SQS
Small Quantity Site
SRS
Savannah River Site
SWB
Standard Waste Box
TDOP
Ten-Drum Overpack
TRU
Transuranic [Waste]
TSD
Technical Support Document
TWBID
Transuranic Waste Baseline Inventory Database
TWBIR
Transuranic Waste Baseline Inventory Report
WIPP
Waste Isolation Pilot Plant
WMP
Waste Material Parameter
WSDT
Working Site Data Template
WTS
Washington TRU Solutions, LLC
WWIS
WIPP Waste Information System

Introduction

The U.S. Department of Energy (DOE) operates the Waste Isolation Pilot Plant (WIPP), located
in southeastern New Mexico, for the disposal of defense-related transuranic (TRU) waste. DOE
submitted the Compliance Certification Application (CCA) to the U.S. Environmental Protection
Agency (EPA or the Agency) in 1996. After extensive review of the CCA and supplemental
information provided by DOE, the Agency certified in 1998 that DOE met the relevant
regulatory requirements and WIPP began accepting waste in March 1999. DOE is required to
submit a Compliance Recertification Application (CRA) every 5 years after the date that waste was first accepted at WIPP; the first CRA was submitted in March 2004 (DOE 2004). 

In March 2009 DOE submitted the second Compliance Recertification Application, referred to here as CRA-2009. On May 21, 2009, EPA informed DOE that a revised performance assessment (PA) (referred to here as PABC-2009) would be required before the CRA-2009 could be judged to be complete (Cotsworth 2009a).

On March 26, 2014, DOE submitted its 2014 Compliance Recertification Application (CRA-2014).  As part of the Agency's review, EPA submitted a series of letters to DOE requesting additional information. DOE provided supplemental information packages in response to EPA's requests.  EPA comments and DOE responses relevant to waste inventory are provided in Appendix B.

Confirming the validity of the waste inventory information for both emplaced inventory and estimated inventories of stored wastes at the generator sites is important to PA. For each of the CRAs, DOE updated the WIPP waste inventory, as required by 40 CFR 194.15. This Technical Support Document (TSD) describes the Agency's evaluation of DOE's inventory update process and documentation to ensure its adequacy for use in CRA-2014. The results of this review document the Agency's evaluation of DOE's compliance with the requirements of relevant portions of 40 CFR 194.24(a) and (b), and 194.15.

During its review of DOE's 2004 Compliance Recertification Application (subsequently referred to here as CRA-2004), EPA mandated that DOE conduct a revised PA designated the Performance Assessment Baseline Calculation (PABC-2004 or PABC04).  The PABC-2004 was a key element in EPA's 2006 determination that the Waste Isolation Pilot Plant (WIPP) continued to comply with the regulatory requirements of 40 CFR 194.34, "Results of Performance Assessments."  The CRA-2004 inventory was described in Chapter 4, Appendix TRU WASTE and Appendix DATA (Attachment F) of DOE 2004.  The cutoff date for that inventory was September 30, 2002.  A number of errors were uncovered during review of the CRA-2004 inventory, and these were corrected in the PABC-2004 inventory.  The waste inventory used to develop the radionuclide source term for the PABC-2004 was based on information contained in Leigh et al. 2005.  The PABC-2004 inventory was subsequently documented in greater detail in the Transuranic Waste Baseline Inventory Report  -  2004, referred to here as TWBIR 2004 (DOE 2006).  In addition, cellulosics, plastics, and rubber (CPR) used in emplacement materials were included in the inventory for the first time.  Details on the changes made to develop the PABC-2004 inventory from the CRA-2004 inventory are provided in Leigh et al. 2005. 
The CRA-2004 and the PABC-2004 inventories were thoroughly reviewed by EPA in support of its 2006 Recertification decision that the WIPP could continue to accept transuranic (TRU) waste for disposal.  EPA documented the results of its inventory review in the Compliance Application Review Document (CARD) for §194.24  -  Waste Characterization (EPA 2006a) and in the Inventory Technical Support Document (TSD) (EPA 2006b).  

Since the 2006 compliance decision, four additional inventory reports have been issued by DOE.  The TWBIR 2004 documents the PABC-2004 inventory from Leigh et al. (2005) in greater detail (DOE 2006).  The Annual Transuranic Waste Inventory Report  -  2007 (DOE/TRU-2008-3379, Rev.1), revised in mid-2008, presents the status of the inventory as of December 31, 2006, with corrections after-that-date.  The Annual Transuranic Waste Inventory Report  - 2008 (DOE/TRU-2008-3425, Rev. 0), published in October 2008, presents the status of the inventory as of December 31, 2007.  These documents will be referred to here as ATWIR 2007 and ATWIR 2008.  
The DOE 2009 Compliance Recertification Application (CRA-2009) used the PABC-2004 inventory to develop the inventory for the CRA-2009 PA.  Since this inventory was carefully reviewed and validated by EPA in its previous recertification decision, it was not reconsidered during the 2009 and 2014 CRA reviews, except for comparative purposes.  The conclusion from EPA 2006b (pg. 44) is restated for the record:

The inventory reported in the [2004] CRA, as amended by the [2004] PABC, adequately describes the chemical, radiological, and physical composition of the existing and to-be-generated waste as required by 40 CFR 194.24(a).  The descriptions provided in the inventory documents reviewed here include comprehensive lists of waste components and their approximate quantities in the waste also required by 40 CFR 194.24(a). 

Since EPA required a new PABC to support the 2009 Compliance Recertification Application, DOE proposed that the stand alone ATWIR 2008 inventory report be used for the PABC-2009, as outlined in the Executive Summary (pg. 5) of DOE/TRU-2008-3379, Revision 1.  The Performance Assessment Inventory Report (PAIR)  -  2008 (PAIR 2008) documents the scaling of the data in ATWIR 2008 and provides additional inventory information specific to PA that was not included in ATWIR 2008.  DOE adopted the same approach for the CRA-2014 and utilized the ATWIR 2012 inventory and 2012 PAIR reports. A summary of inventory reports and their utilization in various compliance certification/recertification activities is presented in Table 1-1.

Table 1.	Sources of Inventory Information for Certification/Recertifications  
                         Certification/Recertification
                             Inventory Report Used
CCA
TWBIR, Revisions 2 and 3
CRA-2004
CRA 2004, Appendix DATA, Attachment F
PABC-2004
Leigh et al. 2005
CRA-2009
Leigh et al. 2005/TWBIR 2004
PABC-2009 
ATWIR 2008/PAIR 2008
PABC-2014
ATWIR 2012/PAIR 2012
This technical support document discusses changes in the inventory since the PABC-2009, as documented in ATWIR 2012 and PAIR 2012.  As appropriate, comparisons are made to the PABC-2009 inventory relative to the CRA-2014. 

Inventory Terminology

To assist the reader in using this report, the following definitions may be useful.  An extensive glossary of inventory-related terms is included in Section 6 of ATWIR 2012.  

Final waste form  -  Final waste form is the expected physical form of the waste.  The use of the final waste form helps to group waste streams that are expected to have similar physical and chemical properties at the time of disposal.  Waste is assigned to 1 of 11 final waste forms, including solidified inorganics, salt, solidified organics, soils, uncategorized metals, lead/cadmium metal, inorganic non-metals, combustibles, graphite, heterogeneous, and filters. 

Waste  -  Defined term in 40 CFR 194.2.  Waste means the radioactive waste, radioactive material, and coincidental material subject to part 191 of this chapter.

Waste characteristic  -  Defined term in 40 CFR 194.2.  Waste characteristic means a property of the waste that has an impact on the containment of waste in the disposal system.  As noted in 40 CFR 194.24(b)(1), waste characteristics include, but are not limited to, solubility, formation of colloidal suspensions containing radionuclides, production of gas from the waste, shear strength, and compactibility.
 
Waste component  -  Defined term in 40 CFR 194.2.  Waste component means an ingredient of the total inventory of the waste that influences a waste characteristic.  Waste components to be analyzed per 40 CFR 194.24(b)(2) include, but are not limited to, metals, cellulosics, chelating agents, waste and other liquids, and activity in curies of each isotope of the radionuclides present.  
Waste material parameter (WMP)  -  Waste material parameters characterize quantities of certain components of the waste that are used in PA.  These parameters are usually expressed as material densities (kg/m[3]) and include the following categories:  Fe-based metals/alloys, Al-based metals/alloys, other metals/alloys, other inorganic materials, vitrified materials, cellulosic materials, rubber, plastics, solidified inorganic materials, cement (solidified), and soil. 
  
Performance Assessment Inventory Requirements

As described in Attachment 1 of PAIR 2012, the specific information needs for PA include the following:

 Waste stream volumes [in cubic meters (m[3])] and inventory of radionuclides on a waste stream basis for both CH and RH TRU waste, supplied in Curies and decayed to the year 2033, for the following radionuclides (scaled to a full repository):
      Am-241, Am-243, Cm-244, Cs-137, Np-237, Pu-238, Pu-239, Pu-240, Pu-241, Pu-242, Pu-244, Sr-90, Th-229, Th-230, Th-232, U-233, U-234, U-235, U-236, and U-238.
 Total CH and RH TRU inventories of all radionuclides (scaled to a full repository), supplied in Curies and decayed to the years; 2033, 2133, 2383, 3033, 7033, and 12033.
 Total inventory (scaled to a full repository) of all nonradiological waste material parameters reported in masses (kg) for the CH and RH TRU waste. Nonradiological waste material parameters include: cellulosic, plastic and rubber (CPR) materials; iron-based metal/alloys; aluminum-based metal/alloys; other metals; solidified inorganic materials; solidified organic materials; vitrified materials; cements; soils; and other inorganic materials. These components may affect actinide solubility or gas generation rates.
      Include only Portland cement (and concrete or other cements containing CaO or Ca(OH)2 in the inventory of cement. Specify whether the partial mass density of Cement is based on un-reacted (dry) cement, reacted (hydrated) cement, or a combination. Do not include Portland cement under other waste material parameters.
 Total inventory (scaled to a full repository) of steel, lead, CPR and any other materials used to facilitate packaging of waste in the WIPP, supplied in masses (kg) for both CHand RH TRU waste. These materials may contribute to gas generation.
 Total inventory (scaled to a full repository) of CPR materials and other biodegradable materials used to facilitate emplacement of waste and MgO in the WIPP, supplied in masses (kg) for both CH and RH TRU waste. Waste and MgO emplacement in the WIPP is facilitated by the use of plastic shrink-wrap, cardboard stabilizers, and other materials. Inventory estimates for these materials should be included. These materials may contribute to gas generation.
 Total inventory (scaled to a full repository) of organic ligands (acetic acid, sodium acetate, citric acid, sodium citrate, oxalic acid, sodium oxalate and sodium EDTA) and oxyanions (sulfates, nitrates and phosphates), supplied in masses (kg). These components may affect actinide solubility or gas generation rates.

The WIPP waste inventory also includes large amounts of data not specifically required for PA, but which are used by DOE for other management purposes.

Verification of the Inventory Assembly Process

Inventory Information Assembly and Review Process

Prior to 2006, WIPP waste inventories were prepared at irregular intervals.  However, beginning in 2006, DOE started publishing waste inventories annually, and ATWIR 2007 (period ending December 31, 2006) was the first in the series of annual inventory reports.  Revising the inventory on an annual basis tends to reduce inventory errors.  Development of the annual TRU waste inventory is currently managed by Los Alamos National Laboratory  -  Carlsbad Operations (LANL-CO).  LANL-CO is responsible for data collection, data management, and quality assurance (QA).  The umbrella document for QA of the WIPP inventory is LCO-QPD-01 (LANL 2008a).

The Comprehensive Inventory Database (CID)

The Comprehensive Inventory Database (CID) is used to store and manage all WIPP inventory data.  The CID is managed by LANL-CO as a member of the WIPP team.  The CID for the 2014-CRA was created from the Transuranic Waste Baseline Inventory Database (TWBID), software version v.2.01 S.2.01, data version D.11.00 (LANL 2012a). The CID includes
estimates for TRU waste volumes, WMPs, PMs, complexing agents, oxyanions, and
radionuclides (decayed to common years 2012 and 2033 [WIPP proposed closure date]).

During preparation of the December 31, 2012, inventory report (ATWIR 2013), inventory data from CID, software version v.2.01 S.2.01, data version D.11.00 for each site were transferred to a Working Site Data Template (WSDT) that was sent to each waste generator site for updating.  The updated spreadsheets that were returned to LANL-CO from the waste generator sites form the basis of the WIPP Waste Information System (WWIS).  The updated spreadsheets that were returned to LANL-CO from the waste generator sites provided the input for the CID.  To ensure that the transfer of data from the TWBID to the WSDTs was complete and accurate and appropriate data transformations are correctly performed, LANL-CO developed the procedures described in INV-SAR-13 (Van Soest 2008).  

These procedures involved manually checking the data entries for nine waste streams to ensure that data information had been correctly transferred from TWBID to the WSDT for the respective waste stream.  In addition, three calculations documenting data manipulation were checked via spreadsheets.  These included Average Waste Parameter Density, Percent Containers Readily Shippable, and Projected Count for Current Form Container and Final Form Container.  The analyses demonstrated that the required data were completely and accurately transferred from TWBID to the WSDTs. 

Inventory information contained in the WWIS must be transferred to the CID to ensure that the CID inventory provides a complete picture of the disposal of all TRU wastes.  This report describes, in detail, that process and the database queries used to migrate the WWIS data into standardized CID Import Template files.    


The CID is qualified in accordance with the Los Alamos National Laboratory  -  Carlsbad
Operations (LANL-CO) Quality Assurance (QA) Program, which is in compliance with the
CBFO Quality Assurance Program Document (QAPD) (DOE 2010).

Inventory Updating Procedure 

To update the annual inventory, LANL-CO sends a WSDT from the prior inventory to each site for revision.  LANL-CO, sometimes accompanied by EPA, may visit the site to discuss the updating assumptions and process.  LANL-CO examines the WSDTs returned from the sites and conducts a variety of screening tests on the reported data.  Screening tests include comparison to regulatory and statutory requirements (e.g., is it commercial waste?).  Reported suites of radionuclides in secular equilibrium are questioned if some members of the suite are reported and others are not.  For example, if a site reported Pu-241 and Np-237 in a waste stream but not Am-241 (the daughter of Pu-241 formed by beta decay and the precursor to Np-237), then the site would be required to explain the reason that Am-241 was not reported. Checks are made to ensure that the contents of a waste container are consistent with the container volume.  If the data are found to be inaccurate or incomplete, the issue is discussed and resolved with the waste generator site, as described in LANL-CO procedure INV-SP-01 (McInroy 2007).  All correspondence is documented by e-mails, which are retained in the notebook records for each site.  When all issues have been resolved, the generator site signs off on the inventory, attesting to its completeness and accuracy.  The validated inventory data are then entered into the CID using procedures specified in INV-SP-02 (McInroy 2009).  

If subsequent changes to the CID information are required, a change form is implemented using procedures outlined in INV-SP-01 (McInroy 2007).  A signed change form and any supporting documentation are filed in the site-specific notebook.  The required revisions are then entered into the CID using procedures specified in INV-SP-02 (McInroy 2009).  

Minimum data maintained in the site-specific notebooks to ensure data traceability include the following:

 Inventory update request
 Original WSDT
 Analyses, when applicable
 Data Cover Sheet
 Updated WSDT and supporting documentation
 Signed documentation of TRU waste site validation
 Revisions were received after the CID upload that were corrected in the CID and documented on Form INV-SP-01-2 Inventory Data Form.

Other information may be included in the notebooks, such as notes on site visits and other correspondence not needed for data traceability.



Site Visits

The EPA is continually evaluating compliance with the requirements of Section 194.8 through QA and WC inspections, observations and technical reviews. Table 2-1 lists all EPA, Section 194.8(b) and Section 194.24 (i.e., continued compliance) inspections between October 2009 and November 2012. All of the EPA inspection reports are available in EPA's Air Docket and can be obtained using the Docket Nos. identified in the Table below. 

Table 2-1. EPA Waste Characterization Inspections 
                      January 2007 through December 2012
      
Site
Inspection/Tier 1 Evaluation
Date Performed
Date Approved
EPA Docket
AMWTP/BNFL





                    ANL/CCP
Unannounced Inspection
October 16, 2007

November 26, 2007

EPA Docket No. A-98-49; II-A4-94

Tier 1 addition of BN-510 waste stream
March 2, 2010
June 10, 2010
EPA Docket No. A-98-49; II-14-127

Continued Compliance Inspection
November 17-18, 2010
March 16, 2011
EPA Docket No. A-98-49; II-A4-143

Continued Compliance Inspection
October 30 to November 1, 2012
Not issued 
Not issued

Tier 1 RH Visual Examination (VE) newly packaged waste
May 28, 2008
July 10, 2008
EPA Docket No. A-98-49; II-A4-102

Tier 1 addition of 30 containers of K Wing RH waste to Argonne East Remote Handled Debris Mixed (AERHDM) waste 
May 20-21, 2010
September 13, 2010
EPA Docket No. A-98-49; II-A4-132

Tier 1 Addition of 100 Alpha Gamma Hot Cell Facility Debris containers to waste stream AEHRDM
July 2010
September 29, 2010
EPA Docket No. A-98-49; II-A4-136

Tier 1 Addition of 120 containers to AERHDM 
June 29, 2010
September 28, 2010
EPA Docket No. A-98-49; II-A4-134

Tier 1 Addition of 30-gallon RH containers of fuel examination waste (FEW) to AERHDM 
May 4 and 18, 2010
November 22, 2010
EPA Docket No. A-98-49; II-A4-140

Tier 1 to add eight 55-gallon K-Wing FEW RH containers to AERHDM
September 2011
February13, 2012
EPA Docket No. A-98-49; II-A4-158

Tier 1 Solidified Liquid Waste from K-Wing, Building 205
January 3, 2012
June 14, 2012
EPA Docket No. A-98-49; II-A4-162

Tier 1 2[nd] batch of RH FEW in 30-gallon containers
February  -  June, 2012
October 4, 2012
EPA Docket No. A-98-49; II-A4-140

Tier 1 of the Analytical Chemistry Lab (ACL)

July 31-August 1, 2012

September 4, 2012

EPA Docket No. A-98-49; II-A4-165


Tier 1 add two RH debris waste streams to AERHDM 
September 2012
October 4, 2012
EPA Docket No. A-98-49; II-A4-167

BAPL/CCP
Baseline Inspection 
August 30, 2010, September 23, 2010, December 8, 2010, and April 12-13, 2011
July 28, 2011
EPA Docket No. A-98-49; II-A4-151
GEVNC/CCP
RH Waste Baseline Inspection
December 2-4, 2008
August 26, 2009
EPA Docket No. A-98-49; II-A4-115
Hanford (RL)/CCP
CH Waste Baseline Inspection

Tier 1 K Basin CH waste 

                                2nd CH Waste Baseline Inspection

Tier 1 Super HENC

Hanford Tier 1 CH Solids (Limited) streams 
June 4-7 and 27, 2007

                               May 2009


April 27-29, 2010

                                  March 22-23, 2011

June-July, 2011

July 17, 2008
                               
                                N A                                              


December 21, 2010  

                            May 2, 2011

November 10, 2011        
EPA Docket No. A-98-49; II-A4-106

EPA Docket No. A-98-49; II-A4-116

EPA Docket No. A-98-49; II-A4-138
                                                                                                     
EPA Docket No. A-98-49; II-A4-146
                                                                                    EPA Docket No. A-98-49: II-A4-154

INL/CCP
Tier I CH Super HENC
                                    Tier 1 RH to add K-Cell waste
                                   Tier 1 Dose-To-Curie Probe Change

Tier 1 Waste Assay Gamma System density range extension
January 23-24, 2007
                                         
January 8-10, 2008

February-March, 2008                         


June 9, 2008

February 28, 2007_

January 24, 2008

April 11, 2008


October 7, 2008

EPA Docket No. A-98-49; II-A4-86
                                           EPA Docket No. A-98-49; II-A4-97
                                   EPA Docket No. A-98-49; II-A4-98
                                 
EPA Docket No. A-98-49; II-A4-107                            

Continued Compliance Inspection

Tier 1 addition of VE CH S5000 retrievably stored waste stream 
                                        Tier 1 RH VET
September 16-18, 2008 and December 2008
                         December 9-11, 2008

                              August 11, 2009
                                      
March 25, 2009

                         March 4, 2009

                       September 22, 2009

EPA Docket No. A-98-49; II-A4-112

EPA Docket No. A-98-49; II-A4-110

EPA Air Docket No. A-98-49; II-A4-118                                         


Tier 1 addition of ID-HFEF-S5400-RH Lot 1A and ID-ANLE-S5000 waste streams 
December 9-11, 2008
February 1, 2010
EPA Docket No. A-98-49; II-A4-122

Tier 1 addition of ID-MFC-S5400-RH waste stream
April-May 2010
June 11, 2010
EPA Docket No. A-98-49; II-A4-126

Tier 1 addition of ID-INTEC-RH waste stream
December 8-9, 2009, January 12-13, 2010, and February 17, 2010
August 17, 2010
EPA Docket No. A-98-49; II-A4-130

Tier 1 addition of Osprey and ID-HFEF-S5400-RH Lot 1B waste streams
July 13, 2009, to June 2010

August 23, 2010
EPA Docket No. A-98-49; II-A4-131

Tier 1 High Efficiency Neutron Counter (HENC) operating range extension
July 1, 2009 
September 22, 2010
EPA Docket No. A-98-49; II-A4-119

Tier 1 addition of ID-RTC-S3000 waste stream
September 22, 2009
November 1, 2010
EPA Docket No. A-98-49; II-A4-137

Tier 1 addition of IN-ID-NRF-153 waste stream
August 9-10, 2010
November 1, 2010
EPA Docket No. A-98-49; II-A4-135

Continued Compliance Inspection

Tier 1 RH HFEF Lot 4A
                                 Tier 1 WAGS Cd Filter
November 16-17, 2010

February-March 2011

May 2011
March 16, 2011

                          March 23, 2011

June 23, 2011
EPA Docket No. A-98-49; II-A4-142
   
EPA Docket No. A-98-49; II-A4-145   
                                                EPA Docket No. A-98-49; II-A4-150
                                      

Tier 1 RH waste stream IN-ID-NRF-SPC
                                 Tier 1 RH to add Lot 2 waste ID-ANLE-S5000

Unannounced Inspection -characterization of NRD Waste concurrently at CBFO and INL
October 4-5, 2011

                                    May 8-9, 2012

                          
September 19-20, 2011

March 12, 2012

                           July 25, 2012

                           
January 4, 2012
EPA Docket No. A-98-49; II-A4-159

EPA Docket No. A-98-49; II-A4-163
    
                            EPA Docket No. A-98-49; II-A4-157

LANL/CCP
CH Waste Baseline Inspection
                                Tier I CH HENC 2

Tier 1 CH HENC 1 Calibration Extension

RH Waste Baseline Inspection

Non-Conformance Report Evaluation                    
May 23-24, 2006 and August 22, 2006
                              September 2007
                                     
November, 2007

                               May 8-10, 2007                     

                                   July 29, 2008
June 21, 2007

October 22, 2007

December 7, 2007

                        February 19, 2008

                           August 21, 2008

EPA Docket No. A-98-49; II-A4-88
                               EPA Docket No. A-98-49; II-A4-91
                               EPA Docket No. A-98-49; II-A4-95                             

EPA Docket No. A-98-49; II-A4-96

EPA Docket No. A-98-49; II-A4-105

Tier 1 HENC2 Report 
(Non-Approval)
May 25-26, 2010
November 8, 2010
EPA Docket No. A-98-49; II-A4-139

Continued Compliance Inspection

Tier 1 CH Super HENC
May 25-26, 2010

                          August 16-17, 2011

February 9, 2011

                       October 28, 2011
EPA Docket No. A-98-49; II-A4-141

EPA Docket No. A-98-49: II-A4-153

Tier 1 CH HENC2 expansion of calibration range for lead-lined 55-gallon drums
April 28, 2010
April 30, 2012
EPA docket No. A-98-49; II-A4-139 

Tier 1 CH Super HENC1 extension of calibration range to assay lead-lined 55-gallon drums containing solidified materials
June 20-21, 2012
August 14, 2012
EPA Docket No. A-98-49; II-A4-164

Tier 1 approval to add Summary Category Group S4000
September  -  November, 2012
December 31, 2012
EPA Docket No. A-98-49; II-A4-168 
ORNL/CCP
CH Waste Baseline Inspection
November 2007
August 25, 2008
EPA Docket No. A-98-49; II-A4-103

Tier 1 CH Calibration Extension for segmented gamma scanner 
Unknown
October 8, 2008
EPA Docket No. A-98-49; II-A4-108

Tier 1 CH Calibration Extension for Drum Waste Assay System Imaging Passive Active Neutron 
November 17, 2008
January 8, 2009
EPA Docket No. A-98-49; II-A4-109

RH Waste Baseline Inspection
June 30-July 2, 2008
February 3, 2009
EPA Docket No. A-98-49; II-A4-111

Tier 1 to add Solvent Extraction Test Facility waste from November 1978-November 1991 to OR-REDC-RH-HET waste 
May 6, 2009
November 30, 2009
EPA Docket No. A-98-49; II-A4-120

Tier 1 addition of CH Summary Category Group S4000 waste
Unannounced Inspection
August 11-12, 2009

June 24-25, 2009
October 7, 2009

November 23, 2009
EPA Docket No. A-98-49; II-A4-117
                             EPA Docket No. A-98-49; II-A4-121

Tier 1 addition of CH VE and IQ3
February 23-24, 2010
March 30, 2010
EPA Docket No. A-98-49; II-A4-125

Tier 1 addition of RH Solvent Extraction Test Facility Pre-79 waste stream
February-March, 2010 
April 21, 2010
EPA Docket No. A-98-49; II-A4-124

Tier 1 addition of CH Burial Trench Soil Waste
February-March 2011
March 23, 2011
EPA Docket No. A-98-49; II-A4-144
SNL/CCP
RH Waste (SNL-HCF-S5400-RH) Baseline Inspection

Tier 1 to include RH containers generated from waste groups PKE00027/54 and PKE00047 in existing waste stream SNL-HCF-S5400-RH
March 8, May 10 and June 7-8, 2011

                         December 2011 to January 2012
November 23, 2011


March 28, 2012
EPA Docket No. A-98-49; II-A4-155

                            EPA Docket No. A-98-49; II-A4-160
SRS/CCP
Tier 1 SGS

Tier 1 addition of SRS Battelle Columbus Laboratory waste stream SR-RL-BCLDP.001
August 7-8, 2007

July 17-19, 2007, July 31-August 2, 2007, and December 4-5, 2007       
August 30, 2007

August 25, 2008
EPA Docket No. A-98-49; II-A4-90
                              EPA Docket No. A-98-49; II-A4-104

Tier 1 addition of Nondestructive Assay Box Counter (NABC)
March 24-26, 2009
August 4, 2009
EPA Docket No. A-98-49; II-A4-114

Tier 1 addition of CH S3000 waste
September 30, 2010
March 23, 2010
EPA Docket No. A-98-49; II-A4-123

Tier 1 addition of SR-BCLDP.001.001, SR-BCLDP.001.002, SR-BCLDP.002, SR-BCLDP.003, SR-BCLDP.004.002, SR-BCLDP.004.003 waste streams
November 2009  -  March 2010
September 13, 2010
EPA Docket No. A-98-49; II-A4-129

Tier 1 extension of calibration to the NABC
March 24-26, 2009
September 14, 2010
EPA Docket No. A-98-49; II-A4-133

Tier 1 allowing use of American Society for Testing and Materials standard efficiency calibration method for NABC
                                Tier 1 RH Sabotage Drum
May 12, 2011 timeframe


                             April - May 2011
May 31, 2011



June 8, 2011

EPA Docket No. A-98-49; II-A4-148


                            EPA Docket No. A-98-49; II-A4-149

RH Baseline Inspection 
July 26, 2011
April 18, 2012
EPA Docket No. A-98-49; II-A4-161 

Tier 1 request for using 5-foot setback configuration for the NABC
August 14-15, 2012
September 11, 2012
EPA Docket No. A-98-49; II-A4-166

In addition to the baseline and Tier 1 inspections, the EPA performs continued compliance (announced) and unannounced inspections to verify that the approved sites continue to implement EPA-approved systems of controls when characterizing waste for WIPP disposal. During the reporting period for 2014 CRA, the EPA conducted eight continued compliance and unannounced inspections that are listed in the above table in italic. These are conducted in accordance with §194.24 requirements that are discussed in CARD 24 available in FDMS Docket ID No. EPA-HQ-OAR-2014-0609, Air Docket A-98-49 accompanying EPA's 2014 Recertification Decision.

Conclusion

LANL-CO has a comprehensive array of QA procedures in place to ensure the accuracy of the data published in the annual inventory reports.  The procedures cover not only systematic, documented revision of the WSDTs, but also data entry procedures to the CID from the WSDTs and the WWIS.  Independent reality checks on submitted data are also conducted.  During EPA site visits a number of records were reviewed and were found to be consistent with the relevant QA procedures.  Based on the formal inventory updating process, inventory reporting is being conducted in a manner that should reduce database errors.   

A detailed review of the functionality of the various codes used to process inventory information is included in CARD 23, which addresses models and computer codes (DOCKET No. EPA-HQ-OAR-2014-0609).  

Changes from the PABC-2009 Inventory to CRA-2014

      
The waste information used in the CRA-2014 PA is updated from that used in the CRA-2009 PABC calculations.  The Performance Assessment Inventory Report (PAIR)  -  2012 (Van Soest 2012) was released on November 29, 2012.  The PAIR  -  2012 contains updated estimates to the radionuclide content and waste material parameters, scaled to a full repository, based on inventory information collected through December 31, 2011.  The WIPP PA inventory parameters are updated in the CRA-2014 PA to account for this new information.  Waste information in the CRA-2014 PA is discussed further in Kicker and Zeitler (Kicker and Zeitler 2013).
Scaled inventory volumes were not reported in ATWIR 2012, nor were quantities of complexing agents, oxyanions, solidified cements, and emplacement materials (ATWIR 2013).  These types of information are needed for PA, and the data needs were filled by compilations included in PAIR 2012.

The following sections provide detailed comparisons of waste volumes, waste material parameters, contained radioactivity, complexing materials, etc., based on ATWIR 2008/PAIR 2008 ATWIR 2012/PAIR 2012 inventories. 

Waste Volumes

Scaling Factors

Since the volumes of stored, projected, and emplaced waste destined for the WIPP are less than the authorized volumes of 168,485 m[3] for CH TRU waste and 7,079 m[3] for RH TRU waste, it is necessary to scale waste volumes to the repository regulatory limits for PA calculations.  In developing the scaling factors, only projected waste volumes are adjusted.  The scaling factor for CH TRU waste, SFCH, is calculated as follows: 

      SFCH = (168,485 - (Vs + Ve)) Vp,

where Vs is the volume of stored waste, Ve is the volume of emplaced waste, and Vp is the volume of projected waste.  The scaling factor for RH TRU waste is similarly calculated using the appropriate RH volumes and the volume limit of 7,079 m[3].  These same scaling factors are then also used to scale the projected portion of radionuclide activity and non-radiological material mass estimates used in PA. Scaling factors based on the three most recent recertifications are presented in Table 3-1. 
 
Table 3.	WIPP Volume Scaling Factors
                                     Waste
                                      CCA
                              PABC-2004/ CRA-2009
                                   PABC-2009
                                   CRA-2014
                                    CH TRU
                                     2.05
                                     1.48
                                     5.72
                                     2.66
                                    RH TRU
                                      1.0
                                     0.861
                                     4.87
                                     3.67
      Sources:  ATWIR 2007, Table 2-1; PAIR 2008, Table 5-1; PAIR 2012 p. 10

CH TRU Waste Volumes

Table 3-2 compares the stored, projected, and anticipated waste volumes by waste generator site for CH TRU, based on the ATWIR 2012 inventory.  The reported values are for unscaled volumes.  

Table 4.	 Unscaled CH TRU Waste Volumes for CRA-2014 based on ATWIR 2012 Inventories
                                     Site
Stored CH TRU (m[3])
Projected CH TRU (m[3])
Anticipated Volumes (m[3])
                                       
                                   CRA-2014
Argonne National Laboratory
4.10E+01
1.28E+02
1.69E+02
Hanford (Richland) Site
1.60E+04
3.92E+03
2.00E+04
Idaho National Laboratory
2.56E+04
9.63E+01
2.57E+04
Knolls Atomic Power Laboratory - Nuclear Fuel Services
7.80E+01
4.53E+02
5.31E+02
Lawrence Berkeley National Laboratory
4.16E-01
4.16E-01
8.32E-01
Lawrence Livermore National Laboratory
2.27E+02
7.64E+02
9.92E+02
Los Alamos National Laboratory
5.78E+03
2.97E+03
8.74E+03
Material and Fuels Complex
2.70E+00
3.06E+01
3.33E+01
Nevada National Security Site
4.70E+01
4.54E+01
9.23E+01
Nuclear Radiation Development Site
1.87E+00
8.32E-01
2.70E+00
Oak Ridge National Laboratory
8.31E+02
1.05E+02
9.36E+02
Sandia National Laboratories
5.44E+00
4.73E+01
5.27E+01
Savannah River Site
1.62E+03
3.88E+03
5.50E+03
Grand Total
5.02E+04
1.24E+04
6.27E+04
Sources:  ATWIR 2012, Table 3-1


RH TRU Waste Volumes

Table 3-3 compares the stored, projected, and anticipated waste volumes by waste generator site for RH TRU, based on the ATWIR 2012 inventory.  The reported values are for unscaled volumes. 




Table 5.	 Unscaled RH TRU Waste Volumes for CRA-2014 based on ATWIR 2012 Inventories
                                     Site
Stored CH TRU (m[3])
Projected CH TRU (m[3])
Anticipated Volumes (m[3])
                                       
                                   CRA-2014
Argonne National Laboratory
2.38E+01
5.64E+01
8.02E+01
Hanford (Richland) Site
- - 
4.99E+00
4.99E+00
Idaho National Laboratory
1.54E+03
9.22E+02
2.47E+03
Knolls Atomic Power Laboratory - Nuclear Fuel Services
2.16E+02
- - 
2.16E+02
Lawrence Berkeley National Laboratory
- - 
1.31E+01
1.31E+01
Lawrence Livermore National Laboratory
7.92E+01
- - 
7.92E+01
Los Alamos National Laboratory
1.13E+01
8.30E+01
9.43E+01
Material and Fuels Complex
3.67E+02
1.47E+02
5.14E+02
Nevada National Security Site
2.38E+01
5.64E+01
8.02E+01
Nuclear Radiation Development Site
- - 
4.99E+00
4.99E+00
Oak Ridge National Laboratory
1.54E+03
9.22E+02
2.47E+03
Sandia National Laboratories
- - 
- - 
- - 
Savannah River Site
4.62E+01
1.12E+01
5.74E+01
Grand Total
2.29E+03
1.24E+03
3.53E+03
Sources:  ATWIR 2012, Table 3-2


Radionuclide Inventory
      
The containment requirements for the WIPP disposal system are defined in 40 CFR 191.13, "Containment Requirements," which states in part that:

         (a) Disposal systems for spent nuclear fuel or high-level or transuranic radioactive wastes shall be designed to provide a reasonable expectation, based upon PAs, that the cumulative releases of radionuclides to the accessible environment for 10,000 years after disposal from all significant processes and events that may affect the disposal system shall:
         
             Have a likelihood of less than one chance in 10 of exceeding the quantities calculated according to Table 1 (appendix A); and
            
             Have a likelihood of less than one chance in 1,000 of exceeding ten times the quantities calculated according to Table 1 (appendix A).

Table 1 of 40 CFR Part 191 Appendix A (reproduced here) specifies the release limits for specific radionuclides.  
Table 1 of Appendix A.  Release Limits for the Containment Requirements
(U.S. Environmental Protection Agency 1985, Appendix A, Table 1)
Radionuclide
Release Limit Li per 1000 MTHM[a] or Other Unit of Waste[b]
Americium-241 or -243
100
Carbon-14
100
Cesium-135 or -137
1,000
Iodine-129
100
Neptunium-237
100
Pu-238, -239, -240, or -242
100
Radium-226
100
Strontium-90
1,000
Technetium-99
10,000
Thorium (Th) -230 or -232
10
Tin-126
1,000
Uranium (U) -233, -234, -235, -236, or -238
100
Any other alpha-emitting radionuclide with a half-life greater than 20 years
100
Any other radionuclide with a half-life greater than 20 years that does not emit alpha particles
1,000
a  Metric tons of heavy metal (MTHM) exposed to a burnup between 25,000 megawatt-days (MWd) per metric ton of heavy metal (MWd/MTHM) and 40,000 MWd/MTHM.
b  An amount of TRU wastes containing one million Ci of alpha-emitting TRU radionuclides with half-lives greater than 20 years.

As described in footnote b of Table 1 the release limits are per "an amount of TRU waste containing one million Ci of alpha-emitting radionuclides with half-lives greater than 20 years."  The normalized release R used in PA is defined as:

	R= ∑(Qi/Li)(1 x 10[6] Ci/C) ,

where Qi is cumulative release of the ith radionuclide to the accessible environment over 10,000 years, Li is the release limit for the ith radionuclide from Table 1 of Appendix A, and C is the total quantity of radioactivity in alpha-emitting transuranic radionuclides with half-lives greater than 20 years.  Thus for PA, it is necessary to quantify all of the radionuclides covered in Table 1 of Appendix A, and also to quantify TRU radionuclides with half-lives greater than 20 years.  For the PABC-2004/CRA 2009 PAs, C was 2.32 x 10[6] Ci resulting in a Waste Unit Factor (WUF) of 2.32 (DOE 2009, Appendix PA, Section PA-2.2.1).  This is based on the WIPP-scale inventory decayed to 2033, the assumed closure date for the repository. Table B-2 of Fox, Clayton and Kirchner 2009 identifies these nuclides and determines that they contribute 2.60 x 10[6] Ci at closure or resulting in a WUF of 2.60.  In the 2009 CRA PABC. In the CRA-2014 PA, C = 2.06 x 10[6] Ci (Kicker and Zeitler 2013, Section 2). The total number of EPA units in the scaled inventory decayed to 2033 is obtained by the following equation:
		Ews = ΣEi = Σwi/(WUF x Li)
where Ei is the number of EPA units of the ith radionuclide in a waste stream wi is the quantity of radioactivity in the ith waste stream (Ci), WUF is the waste unit factor, Li is the release limit for the ith radionuclide and Ews is the total EPA units for the waste stream.  Summing Ews for all waste streams results in the total EPA units, ET.  ET is directly proportional to the sum of all radionuclides in all the waste streams and inversely proportional to the sum of all TRU radionuclides in all the waste streams.  As shown in Table 3-4, the total EPA units have remained very consistent in PA.
Table 6. Total EPA Units used in Performance Assessments.
                              PABC-2004/ CRA-2009
                                   PABC-2009
                                   CRA-2014
                                   EPA Units
                                   Reference
                                   EPA Units
                                   Reference
                                   EPA Units
                                   Reference
                                    10,170
                             Fox and Clayton, 2010
                                    10,100
                   Fox, Clayton and Kirchner 2009, Table A-1
                                    10,222
                       Kicker and Zeitler 2013, Table 3

Radioactive inventories for 2012, scaled to the full repository volume and decayed to 2033, are included in Table 3-5, based on PAIR 2012.  These values are obtained by determining the activity density (Ci/m[3]), based on the individual waste stream volume and activity content of each radionuclide, and scaling these values to the full repository volumes for RH TRU and CH TRU.  The scaled activity densities are multiplied by the CH TRU repository limit of 168,485 m[3] and the RH TRU limit of 7,079 m[3], as appropriate to the waste stream categorization, to obtain the scaled quantities of radioactivity.  For comparison, the PABC-2004/CRA-2009, PABC-2009 and CRA-2014 are shown in Table 3-5.  No significant changes in the quantity of radioactivity in the scaled inventory have occurred since between the PABC-2004.

Table 7.	Scaled Radioactivity in the WIPP Repository
                                  aWaste Type
                              PABC-2004/CRA-2009
                                   PABC-2009
                                   CRA-2014
                                       
                              Radioactivity (Ci)
                                   Reference
                              Radioactivity (Ci)
                                   Reference
                              Radioactivity (Ci)
                                   Reference
                                    CH TRU
                                      --
                                      --
                                   3.10E+06
                             PAIR 2008, Table A.1
                                   2.70E+06
                             PAIR 2012, Table 5-3
                                    RH TRU
                                      --
                                      --
                                   3.50E+05
                             PAIR 2008, Table A.1
                                   9.36E+05
                             PAIR 2012, Table 5-4
                                     Total
                                   3.53E+06
                          Leigh et al. 2005, Table 2
                                   3.45E+06
                                      --
                                   3.63E+06
                                      --
a  -  decayed to 2033
Tables 3-6 and 3-7 present the change between values presented in the PAIR 2012 for CRA-2014 and their counterparts from the PABC-2009 (PAIR-2008; LANL 2009). These changes are provided simply to demonstrate the differences between the two PAs. It should be noted that although the same scaling methodology applied for PAIR-2012 was also used for the PAIR-2008, the reported values are based on different underlying inventories (12/31/2007 for PAIR-2008, and 12/31/2011 for PAIR-2012), and thus use distinct scaling factors in order to scale to a full repository.

              Table 8.   Comparing Activity (Ci) By Radionuclide Decayed to 2033
                                       
                                 Radionuclide
                                   PABC-2009
                                   CRA-2014
                                  Net change

CH
RH
CH
RH
CH
RH
Am-241
4.68E+05
4.48E+03
6.97E+05
8.06E+03
2.29E+05
3.59E+03
Am-243
7.17E+01
7.80E+00
2.18E+01
2.95E+01
-5.00E+01
2.17E+01
Cm-244
2.61E+03
4.36E+02
5.24E+03
4.73E+03
2.63E+03
4.29E+03
Cs-137
5.48E+02
8.89E+04
2.31E+03
2.33E+05
1.77E+03
1.44E+05
Np-237
3.65E+01
2.49E+00
2.04E+01
2.84E+00
-1.61E+01
3.52E-01
Pu-238
1.47E+06
5.11E+03
5.95E+05
5.80E+03
-8.73E+05
6.91E+02
Pu-239
5.10E+05
2.92E+03
5.67E+05
7.27E+03
5.73E+04
4.35E+03
Pu-240
1.44E+05
9.89E+02
1.67E+05
7.94E+03
2.35E+04
6.95E+03
Pu-241
5.06E+05
3.94E+03
6.48E+05
1.49E+04
1.43E+05
1.10E+04
Pu-242
7.46E+01
1.25E+00
1.66E+03
6.44E+03
1.58E+03
6.44E+03
Pu-244
3.48E-04
2.34E-06
1.01E-02
7.38E-06
9.79E-03
5.05E-06
Sr-90
5.03E+02
7.99E+04
2.31E+03
2.07E+05
1.81E+03
1.27E+05
Th-229
8.81E+00
4.19E+00
4.19E-01
9.81E-01
-8.39E+00
-3.21E+00
Th-230
5.87E-01
9.20E-03
4.13E+00
1.02E-02
3.54E+00
9.62E-04
Th-232
2.75E-01
6.86E-02
1.48E+00
1.46E-02
1.21E+00
-5.40E-02
U-233
1.56E+02
5.09E+01
9.82E+01
4.04E+01
-5.78E+01
-1.05E+01
U-234
3.04E+02
5.18E+00
2.10E+02
3.23E+01
-9.43E+01
2.72E+01
U-235
4.42E+00
7.04E-02
8.66E+00
6.77E+01
4.24E+00
6.76E+01
U-236
1.35E+00
2.48E-01
5.08E+00
3.65E-01
3.73E+00
1.17E-01
U-238
2.71E+01
2.96E-01
3.51E+01
2.97E+01
8.05E+00
2.94E+01



                        Table 9. Comparing Total Activity (Ci) By Year.

                                       
                                     Year
                                   PABC-2009
                                   CRA-2014
                                  Net Change

                                      CH
                                      RH
                                      CH
                                      RH
                                      CH
                                      RH
                                                                           2033
3.10E+06
3.50E+05
2.70E+06
9.36E+05
-4.06E+05
5.85E+05
                                                                           2133
1.74E+06
4.24E+04
1.62E+06
1.16E+05
-1.14E+05
7.37E+04
                                                                           2383
1.01E+06
7.19E+03
1.17E+06
3.00E+04
1.59E+05
2.28E+04
                                                                           3033
7.25E+05
4.93E+03
8.49E+05
2.53E+04
1.25E+05
2.04E+04
                                                                           7033
5.28E+05
3.40E+03
5.93E+05
2.02E+04
6.47E+04
1.68E+04
                                                                          12033
4.35E+05
2.88E+03
4.87E+05
1.73E+04
5.22E+04
1.44E+04




Non-Radioactive Waste Components

Materials Limits

According to 40 CFR 194.24(c): 

      For each waste component identified and assessed pursuant to paragraph (b) of this section, the Department shall specify the limiting value (expressed as an upper or lower limit of mass, volume, curies, concentration, etc.), and the associated uncertainty (i.e., margin of error) for each limiting value, of the total inventory of such waste proposed for disposal in the disposal system.

In accordance with this requirement, the DOE specified the following limiting values for waste material components:  ferrous metals  -  minimum 2 x 10[7] kg; CPR maximum  -  2 x 10[7] kg; free water emplaced with the waste  -  maximum 1,684 m[3]; and nonferrous metals (metals not containing iron)  -  minimum 2 x 10[3] kg.  These limits on waste material components have remained unchanged since the CCA was published (DOE 2014, 24.3.5).  

Waste Material Parameters

The WIPP waste inventory maintains the densities of the components comprising each waste stream and types of packaging materials used to emplace the waste streams.  Table 3-8 compares the average densities for waste materials and packaging materials in CH and RH TRU waste from the PABC-2009 and CRA-2014 inventories.  As described below, these complex-wide waste material densities are obtained by rolling up the waste material densities and waste stream volumes for each waste stream, based on data calls to the sites.  

Table 10. Comparing Waste and Packaging Materials (kg)

Waste Materials
                                       
                                 PABC-2009*[a]
                                  CRA-2014[b]
                                  Net Change

                                      CH
                                      RH
                                      CH
                                      RH
                                      CH
                                      RH
﻿Iron-based Metal/Alloys 
                                                                       1.37E+07
                                                                       1.21E+06
                                                                       1.09E+07
                                                                       1.35E+06
                                                                      -2.82E+06
                                                                       1.40E+05
Aluminum-based Metal/Alloys 
                                                                       2.55E+05
                                                                       7.30E+04
                                                                       4.37E+05
                                                                       2.01E+04
                                                                       1.82E+05
                                                                      -5.29E+04
Other Metal/Alloys 
                                                                       8.60E+05
                                                                       2.00E+05
                                                                       7.62E+05
                                                                       4.71E+05
                                                                      -9.81E+04
                                                                       2.72E+05
Other Inorganic Materials 
                                                                       6.07E+06
                                                                       2.80E+05
                                                                       6.34E+06
                                                                       1.03E+06
                                                                       2.63E+05
                                                                       7.48E+05
Cellulosics 
                                                                       6.67E+06
                                                                       1.54E+05
                                                                       3.55E+06
                                                                       1.18E+05
                                                                      -3.12E+06
                                                                      -3.63E+04
Rubber 
                                                                       9.45E+05
                                                                       4.65E+04
                                                                       1.09E+06
                                                                       8.80E+04
                                                                       1.44E+05
                                                                       4.15E+04
Plastics 
                                                                       6.43E+06
                                                                       1.97E+05
                                                                       5.20E+06
                                                                       2.93E+05
                                                                      -1.23E+06
                                                                       9.52E+04
Cement** 
                                                                       2.94E+06
                                                                       2.87E+04
                                                                       2.71E+06
                                                                       1.32E+06
                                                                      -2.30E+05
                                                                       1.29E+06
Solidified Inorganic Material 
                                                                       1.81E+07
                                                                       7.62E+05
                                                                       1.11E+07
                                                                       2.08E+04
                                                                      -6.95E+06
                                                                      -7.41E+05
Solidified Organic Material 
                                                                       6.33E+06
                                                                       2.38E+04
                                                                       4.01E+06
                                                                       2.69E+03
                                                                      -2.32E+06
                                                                      -2.11E+04
Soils 
                                                                       1.78E+06
                                                                       1.77E+05
                                                                       5.80E+06
                                                                       1.39E+05
                                                                       4.01E+06
                                                                      -3.73E+04
Vitrified 
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
Packing Materials 
 Cellulosics  
 8.67E+05  
 0.00E+00  
 7.23E+05  
 0.00E+00  
 -1.45E+05  
 0.00E+00  
 Plastics  
 2.63E+06  
 1.00E+05  
 2.47E+06  
 3.01E+05  
 -1.61E+05  
 2.01E+05  
 Rubber***  
 NA  
 NA  
 6.91E+04  
 4.18E+03  
 NA  
 NA  
 Steel  
 3.14E+07  
 4.46E+06  
 3.00E+07  
 6.86E+06  
 -1.36E+06  
 2.41E+06  
 Lead  
 0.00E+00  
 2.51E+04  
 0.00E+00  
 8.28E+03  
 0.00E+00  
 -1.68E+04  
 Grand Total  
 9.89E+07  
 7.73E+06  
 8.52E+07  
 1.20E+07  
 -1.38E+07  
 4.30E+06  
* For comparison purposes, the PAIR-2008 values were converted from average density (kg/m3) to mass (kg) by
multiplying each density by the respective legislated WIPP volume capacity (CH - 168,485 m3, RH - 7,079 m3).
** The Cement totals here reflect only those reported by the TRU waste sites. The emplaced portion is accounted for in
the Solidified Inorganic Material, Solidified Organic Material, and Other Inorganic Materials categories.
*** Rubber packaging material was not estimated in the PAIR-2008
Sources: a  -  PAIR 2008, Table 4-2
               b  -  PAIR 2012, Table 6-3


 
Organic Ligands

Organic ligands can form dissolved complexes with actinide elements in the waste, resulting in increased actinide solubilities.  Consequently, ligands are tracked in the WIPP waste inventory.  Quantities of organic ligands (complexing agents) for the three most recent inventories are presented in Table 3-9.  

 Table 11.	Comparing Organic Ligands (kg)
                                   Compound
                                 PABC-2009[a]
                                  CRA-2014[b]
                                  Net Change
Acetate 
                                   9.70E+03 
                                   9.96E+03 
                                                                      2.56E+02 
Acetic Acid 
                                   1.32E+04 
                                   1.41E+04 
                                                                      9.60E+02 
Citrate 
                                   2.55E+03 
                                   2.55E+03 
                                                                      6.11E+00 
Citric Acid 
                                   5.68E+03 
                                   5.23E+03 
                                                                     -4.54E+02 
EDTA 
                                   3.54E+02 
                                   3.76E+02 
                                                                      2.18E+01 
Oxalate 
                                   6.46E+02 
                                   6.50E+02 
                                                                      4.02E+00 
Oxalic Acid 
                                   2.66E+04 
                                   1.78E+04 
                                                                     -8.74E+03 
Sources: a  -  PAIR 2008, Table 4-7
               b  -  PAIR 2012, Table 6-6

Packaging Materials

Packing material is defined as the materials used to construct the containers that hold TRU waste. The packing material masses for the WIPP-approved payload containers are fixed values in the CID. The site contacts report the expected final form container type, and the CID generates the PM masses using consistent values associated with the container type. An analysis was performed (French 2009) to calculate the PM masses to be assigned to the various WIPP-approved container types in the CID. The purpose of that analysis was to document the calculations that provide the packing material masses for steel, plastic, cellulose, lead, and rubber used in the containers for packaging CH and RH TRU waste for shipment to WIPP. 
Quantities of packaging materials were presented previously in Table 3-8.  


Oxyanions in the Waste Inventory

The WIPP inventory also tracks certain oxyanions, including SO4[-2], PO4[-3], and NO3[-1].  These species play differing roles in microbial degradation of CPR materials in the repository and, consequently, knowledge of their relative availability contributes to understanding which microbial reactions occur and how much gas is generated.  Oxyanion masses are summarized in Table 3-10.


                             Table 12. Comparing Oxyanions (kg) 
Oxyanion
                                 PABC-2009[a]
                                  CRA-2014[b]
                                  Net Change 
Nitrate 
                                   1.73E+06 
                                   1.70E+06 
                                  -2.65E+04 
Phosphate 
                                   1.99E+05 
                                   2.07E+05 
                                   7.56E+03 
Sulfate 
                                   5.91E+05 
                                   4.72E+05 
                                  -1.18E+05 
Sources: a  -  PAIR 2008, Table 4-9
               b  -  PAIR 2012, Table 6-5

Other Materials

Two additional analyses were performed in the 2012 PAIR to supplement the inventory information that the CID could not readily provide. They are: Estimation of Cellulose, Plastic, and Rubber Emplacement Materials in the Waste Isolation Pilot Plant (WIPP) (LANL 2012c) and Chemical and Cement Components 2011 Inventory Estimates (LANL 2012b).

The Chemical and Cement Components 2011 Inventory Estimates (LANL 2012b) analysis was performed in order to determine the total amount of oxyanions, complexing agents (a.k.a. organic ligands), and cement that would be present in a full WIPP repository. These inventory estimates are only available for that data collected from the TRU waste sites. They are not available from the WDS, which would represent the already-emplaced portion. Therefore, DOE concluded that an analysis was warranted in order to account for those constituents that have already been emplaced at the WIPP. 

Cement could be a source of mineral-fragment-type colloids and also affect the pH of repository brines.  Appendix SCR (DOE, 2014) provides additional discussion pertaining to the role of cement on radionuclide transport (Section 6.1.4.2.4).  The cement types and masses used in PABC-2009 and CRA-2014 are summarized in Tables 3-11 and 3-12, respectively. 

                             Table 13. Cements (kg) 
Type
                               CH Mass (kg) [a]
                               RH Mass (kg) [a]
Reacted Only 
                                   2.90E+06 
                                   1.32E+06 
Combination Reacted / Unreacted 
                                   6.55E+06 
                                      --
Grand Total 
                                   9.45E+06 
                                   1.32E+06 
Source:    a  -  PAIR 2012, Table 5-6



Table 14. Cement Comparisons (kg) 
Type
                                 PABC-2009[a]
                                  CRA-2014[b]
                                  Net Change 
Cement
                                   1.23 E+07
                                   1.07 E+07
                                   1.3 E+06
Sources: a  -  PAIR 2008, Table 4-11
               b  -  PAIR 2012, Table 5-6

 
Emplacement Materials

The Estimation of Cellulose, Plastic, and Rubber Emplacement Materials in the WIPP (LANL 2012c) analysis was performed in the 2012 PAIR in order to estimate the amount of emplacement materials (not associated with container packages themselves) in a full WIPP repository. Since the CID only compiles the materials data related to the waste and the packaging
containers, this supplemental analysis was warranted. 

Materials used to assist in the emplacement of waste in the WIPP repository include cardboard and plastic slip sheets between stacked drums, plastic wrapping of 7-drum packs, and plastic sacks used to contain MgO.  No emplacement materials are used for RH TRU waste. These materials add to the mass of CPR materials and increase the potential for gas generation within the repository if they are microbially degraded.  

Quantities of CPR in emplacement materials are summarized in Table 3-13.  No rubber has been identified in emplacement materials.


Table 15. Comparing Emplacement Materials (kg) 
Material 
                                  PAIR-2008 
                                  PAIR-2012 
                                  Net Change 
Cellulose 
                                   2.26E+05 
                                   2.60E+05 
                                   3.41E+04 
Plastic 
                                   1.11E+06 
                                   1.25E+06 
                                   1.34E+05 
Grand Total 
                                   1.34E+06 
                                   1.51E+06 
                                   1.68E+05 
Sources: a  -  PAIR 2008, Table 4-4
               b  -  PAIR 2012, Table 5-7


Verification of Parameters used in PA
 
The use of all inventory-related parameters in the PA for CRA-2014 was reviewed as discussed in Appendix B of SC&A 2017.  The review included confirmation that the new parameters related to emplacement materials had been included (see Section 3.3.7).  All inventory-related parameters were correctly implemented in the CRA-2014 PA.

Other Review Activities


During the course of its review of the CRA-2014, EPA raised completeness issues in several letters to DOE and DOE provided responses in a companion series of letters.  The full text of these completeness questions, DOE responses, and EPA evaluation of DOE's responses are included in Appendix A of SC&A 2017.  EPA is satisfied that DOE has adequately responded to the inventory-related completeness comments and there are no unresolved questions. 


Conclusions


The methodology for calculating the waste unit factor and release limits in the 2009 PABC is unchanged from that used in the CCA, the 2004 CRA and is appropriate and acceptable
for PA.

The waste inventory used in the CRA-2014 PA was very similar to that used in the PABC-2009.  The PABC-2009 inventory was thoroughly reviewed by EPA as part of the 2009 recertification decision, and findings were documented in the 194.24 CARD and in the Inventory Technical Support Document, which can be found in Docket EPA-HQ-OAR-2009-0330 on regulations.gov.  

In 2006, DOE switched from an approach where inventories were developed on an ad hoc basis to one where the inventories were developed annually.  The adaptation of the annual approach reduces sources of error in the inventory.  The waste inventory used in CRA-2014 was based on the ATWIR 2012/PAIR 2012 inventory.  This was the sixth annual inventory.  During the course of EPA recertification reviews, the Agency has examined the QA procedures used to populate the CID from the database, used to update the CID annually, and used to transfer data from the WWIS to the CID.  In addition, procedures used to verify chemical components in the waste and estimate the quantities in the waste were reviewed.  Spot checks have been made of various calculated values in the inventory documentation and the checked values were determined to be correct. EPA also determined that DOE had adequately responded to CRA-2014 completeness comments related to inventory.  On the basis of its review, EPA concluded that DOE has appropriate QA procedures in place to accurately document the WIPP waste inventory on an annual basis.  EPA further concluded that the ATWIR 2012/PAIR 2012 inventory is appropriate for use in PA calculations.     


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