WIPP Recovery Plan Overview & Comments

WIPP RECOVERY PLAN
9-30-2014
Overview and Comments by Dean Wilkie

http://www.wipp.energy.gov/Special/WIPP%20Recovery%20Plan.pdf

The Recovery Plan which the DOE issued reportedly provides a safe and compliant approach to resuming operations at the Waste Isolation Pilot Plant (WIPP), the repository for disposal of the nation’s defense transuranic (TRU) waste. The U.S. Department of Energy (DOE) says that it is committed to resuming operations by the first quarter of calendar year 2016, and the Recovery Plan outlines the Department’s approach to meet that schedule while reportedly prioritizing safety, health, and environmental protection.

The Recovery Plan was issued before the investigations into the cause of the radiological release in the WIPP repository and other oversight actions were completed. Doe claims, in order to inform all stakeholders of the status of the Department’s current plans and the effects of the suspension of WIPP operations.”
I have the following observations concerning the plan which are of concern. First I will highlight some of the background information presented in the plan:

WIPP suspended operations on February 5, 2014, following a fire involving an underground vehicle. The fire:

  • Burned the engine compartment of the salt haul vehicle and consumed the front tires, which contributed significantly to the amount of smoke and soot in the area of the fire
    • Impinged on the mine walls and caused flaking of salt
    • The fire resulted in heavy smoke damage in the immediate area and the mechanical and electrical equipment and systems throughout the underground
    • Soot was deposited on the mine’s walls, shafts, and underground equipment, including the waste hoist tower which is used to transport TRU waste containers to the underground for disposal
    • Soot collected in the HEPA filtration system, resulting in necessary replacement of ventilation filters in June 2014

 

On February 14, 2014, a radiological event occurred underground:

  • Contaminating a portion of the mine primarily along the ventilation path from the location of the incident,
  • Released contamination into the environment
  • Bioassay tests showed that 22 workers received internal contamination as a result of the release
  • Portions of the WIPP underground and the existing surface mounted ventilation system are radiologically contaminated.
  • The exhaust drift and shaft, Panel 7, and the common drift area adjacent to Panels 1 through 8 are contaminated
    • This will require WIPP to operate with uncontaminated and contaminated sections of the underground, which is a key part of the recovery strategy.
      • “A key element of the strategy for recovery is not to decontaminate areas of WIPP where decontamination is technically challenging (such as the 2,100 foot vertical air exhaust shaft), or would be overly costly or delay the return to operationsThis will affect all aspects of WIPP operations, including policies, procedures, training, cost, and schedule, and will offer operational challenges to WIPP workers and management. Increased vigilance and attention to detail are required to ensure worker safety

 

The Department appointed two Accident Investigation Boards:

  • Investigation of the underground fire. The Accident Investigation Board published their report1 on March 13, 2014
  • A second Accident Investigation to determine the cause of the February 14 radiological release and to develop recommendations for corrective actions.
    • The second Accident Investigation Board used a two-phased approach
      • Phase 1 focused on the response to the radioactive material release, including related exposure to above ground workers and the response actions. The Phase 1 report2 was issued on April 24, 2014.
      • Phase 2 of the investigation is ongoing and focuses on the cause of the radiological release. The Board will provide its findings when the investigation is complete, currently expected by the end of calendar year 2014

 

DOE also established a Technical Assessment Team to perform a comprehensive, independent technical review of the mechanisms and chemical reactions that may have occurred and contributed to the release of radioactivity:

  • The investigations to date indicate that the February 14 radiological release originated from a TRU waste drum that did not meet the WIPP Waste Acceptance Criteria. The drum was processed at Los Alamos National Laboratory and is known to have nitrate salts, low pH, and organic material, which are likely to have been contributing factors to the release.

 

Nuclear Waste Partnership, has provided a detailed proposal for the expedited initial closure of Panel 6 and Panel 7, Room 7, so that a potential release from any nitrate-salt-bearing waste container does not pose a threat to human health and environment.

 

MAJOR CONCERNS:

  • WIPP plans to forgo extensive de-contamination and will operate with uncontaminated and contaminated sections of the underground which will place a confusing protocal on ensure workers are not exposed to changing contamination environments which require differing levels of Personal Protection Equipment (PPE) such as respirators and anti-contamination clothing. DOE claims this is a key part of the recovery strategy.Comment: WIPP DOE and the contractor at the site are introducing numerous risks by allowing work to proceed with the presence of differing levels of contamination. The probability of a worker receiving an uptake of contamination will be significantly increased due to the complexities of procedural compliance while working in these mixed environments.

 

  • Increasing ventilation capacity is a principal requirement for safe underground operations. Since the radiological event, it is necessary to operate the existing underground ventilation system in filtration mode, which is inadequate to support operations in both the “clean” and contaminated underground areas.
  • The ventilation levels must be increased to support the recovery of WIPP and resume waste emplacement and, eventually, full disposal operations and concurrent mining operations.
  • The recovery strategy calls for ventilation to be increased in phases.
    • The  first phase is the installation of two skid-mounted fans on the associated HEPA filter units, which will increase the ventilation flow from 60,000 cfm to 114,000 cfm and allow redundancy for fan maintenance.
    • The second phase is the supplemental ventilation system, which will reconfigure the underground with bulkheads, ventilation regulators in the bulkheads, and supplemental fans “without much expense”
    • The third phase, consists of a new permanent ventilation system and the construction of a supporting shaft and two drifts. This last phase will restore WIPP to its pre-incident airflow capacity for simultaneous mining and waste emplacement operations.Comment:  Phased installation of the ventilation system is going to place the facility at a higher risk due to the lack of redundancy, quality level installation and introduction of temporary modifications which will be hard to track to the final installation of the permanent systems as well as adding confusion to the procedures for operation of the system. The phase 1 and 2 installations will not be to the seismic standards which are required at a non-reactor nuclear facility.  Again, DOE-WIPP is short cutting the schedule by not waiting for final ventilation design, procurement and installation prior to performing any waste handling.
  • Rather than hire new workers trained to work in radiologically contaminated environments the current workforce is being trained to perform work in uncontaminated and contaminated environments to minimize skills mix imbalances.
            • Maintaining the ability of workers to perform recovery functions, in addition to their normal WIPP duties is a DOE priority. For example, waste handlers and miners will be performing recovery scope, including soot cleaning and decontamination until waste emplacement and mining resume.Comment: DOE is mandating the elimination of hiring the properly trained and “experienced” personnel to perform delicate cleanup, decontamination activities in order to save money and bypass the time needed in the schedule to hire certified people. In addition, they are placing their workforce in an increased risk to being over worked while trying to shuffle between new assignments while at the same time shifting to perform their current job duties.This decision could easily be the beginning of another investigation board report..”rather than hiring new specially trained workers, DOE-WIPP placed an excessive and unrealistic burden on it’s existing work force”.   “The Department will continue to look for opportunities to execute work in parallel and reduce the schedule.” DOE is making the mistake of saying they will take what ever steps are necessary to ensure safety but at the same time they are making these statements which shows an urgency to get the waste shipment storage process back in operation and as such are putting “schedule” over “safety”. There should be no urgency in this recovery process!

    Additionally, to restore WIPP to full operations, two capital asset project line items are required:

          • A new permanent ventilation system, with an estimated cost range of $65 million–$261 million, and
          • A supporting exhaust shaft, with an estimated cost range of $12 million–$48 million. These line item cost estimates are preliminary and will be refined as detailed planning is developed and as uncertainties are reduced.

     

    Comment:  DOE should be required to obtain a guarantee funding commitment from Congress for these two items prior to the end of this fiscal year and prior to the first quarter in next fiscal year. The funding should be given immediately to accelerate the installation of these two items prior to any waste emplacement operations.

        • DOE sites that generate waste for disposal at WIPP will continue characterization and certification activities to meet regulatory milestones. WIPP is reexamining its processes to ensure that all sites have rigorous characterization, treatment, and packaging processes and procedures in place to ensure compliance with WIPP Waste Acceptance Criteria.

     

    Comment: This activity and responsibility is too complex for DOE-WIPP to regulate, monitor, assess, audit and control.  DOE WIPP field office manager currently has the responsibility for and approves the WIPP TRU WASTE ACCEPTANCE CRITERIA.

    http://www.lm.doe.gov/land/sites/co/rocky_flats/closure/references/147-WIPP-CH-WAC.pdf

     

    For Example:

    The CBFO (Carlsbad Field Office) is responsible for the day-to-day management and direction of strategic planning and related activities associated with the characterization, certification, transportation, and disposal of defense TRU waste. The CBFO holds the applicable permits, certifications, and records of decision necessary for the operation and closure of the WIPP facility.

    The CBFO assists the sites in resolving issues about the management of TRU waste as requested. The CBFO provides policy and oversight direction for TRU waste program activities related to site certification of waste for disposal at WIPP. The CBFO is also responsible for the following:

  • Ensuring that the sites prepare implementation documentation and programs to meet the requirements and criteria in the CH-WAC
  • Overseeing activities associated with the characterization and certification of CH-TRU waste proper use of approved transportation packaging, receipt, management, and disposal of CH-TRU waste in WIPP
  • Providing a fleet of NRC-approved Type B transportation packagings for shipment of CH-TRU waste from the sites to WIPP
  • Ensuring that CH-TRU waste accepted for management and disposal at WIPP complies with the WIPP Hazardous Waste Facility Permit, applicable laws, and regulations as described in this CH-WAC
  • Reviewing and approving proposed revisions to the CH-WAC to ensure that environmental impacts associated with any revision are bounded by existing WIPP National Environmental Policy Act documentation

 

The fact that Los Alamos National Laboratory failed to follow procedures while packaging their waste is a prime example of how WIPP failed to ensure they sent safe waste. Los Alamos’s failures ultimately lead to the breached container. The DOE site contractors are each separate entities who are all competing for similar work and each of which is trying to cut cost, scope and schedule to profit from their respective DOE contracts. DOE Headquarters needs to transfer this function within their headquarters organization and incorporate the use of external independent regulators or states where the sites are to regulate and enforce through control of performance bonuses.

DOE WIPP READINESS ASSESSMENT:

http://www.wipp.energy.gov/Special/WIPP%20Recovery%20Plan.pdf

Operational Readiness Reviews:

      • Activities associated with performance of the contractor and DOE reviews for initial emplacement and operation of the permanent ventilation system. These reviews will be executed after completion of required operational (processes, procedures, and personnel qualifications) and facility (equipment and control systems) improvements and contractor-led assessments.

 

Comment:  These activities do not detail how extensive the readiness review is nor does it detail the environmental issues and certification process to establish emplacement of waste storage nor does it detail or delineate those items mentioned on the Defense Nuclear Safety Review Boards recommendations which DOE-WIPP agreed to comply with.

 

ASSUMPTIONS AND RISKS:

      • Waste emplacement can begin under a permit modification, administrative order, or Resource Conservation and Recovery Act contingency plan without meeting the annual air flow requirements currently in the waste permit. Repository monitoring requirements are being evaluated to determine permit impacts associated with reduced ventilation (less than 260,000 standard cfm running annual average ventilation exhaust rate in accordance with the Permit).

 

Comment:  This item is worded in such a manner that would allow DOE-EM to issue an administrative order which would bypass the planned activites to ensure that resumption of WIPP operations will be conducted according to the plan that was issued.

 

      • The accident investigation is not complete; however, there is no indication at this time that retrieval of waste from Panel 7, Room 7 will be necessary.

 

Comment:  There can be no fully understood root cause if the waste container is not removed from the panel 7 room 7 area. The lack of information needed by removal of the waste/other items will negate any lessons learned or waste specific restrictions to prevent further incidents in the future.

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