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Presentation by Citizens for Alternatives to Radioactive Dumping (CARD)
Citizens for Alternatives to Radioactive Dumping (CARD)
presented its first witness DEBORAH READE. Ms. Reade has
spent 19 years studying various aspects of WIPP. She is the
author of the booklet "Everything You Always Wanted to Know
About WIPP" and several papers on WIPP waste and the DOE.
She specializes in translating technical information into
language that the general public can understand. Ms. Reade
began with CARD's opening statement.
The DOE is not ready to begin emplacing waste at the WIPP
site because there are still many critical unknowns in the
areas of waste characterization, site characterization, and
repository behavior. The possibility of karst at the WIPP
site has not been ruled out. [KARST is a geology defined by
underground channels which allows fluids to flow quickly
from one area to another carrying any contaminants with
them.] The behavior of the waste panel and shaft closures
and seals is known only theoretically CARD encourages the DOE to reach a better understanding
of their waste inventory. CARD encourages further waste
characterization as long as the DOE addresses the
characterization problems that have been raised during this
proceeding. Therefore, CARD proposes that the NMED permit the waste
characterization phase of the WIPP project but prohibit the
disposal phase at this time. The DOE should continue to
study the geology of the WIPP site. The DOE should use
Panel 1 as an experimental area to study closure and sealing
technologies. The DOE should design and test a
comprehensive waste characterization program to be approved
by the NMED. In the meantime, the DOE should characterize
and store the waste at the generator sites until such time
as the disposal phase might be permitted.
Y2K READINESS: The WIPP Project is highly computer-
dependent. Because of this, no waste should be shipped to
the facility until all internal systems have been assessed,
renovated, validated, and certified as fully operational.
All external systems and links between the internal and
external systems must be fully operational as well.
Computer chips may be date-dependent. The date-dependence
may exist even where more complex code is embedded in the
computer chips. Date-dependence can manifest even when the
operation of the actual system or subsystem uses no date
fields in everyday operations. WIPP is particularly computer-dependent in preparedness,
prevention, emergency response, and monitoring systems. The
Central Monitoring System (CMS) is a computerized system
that collects, records, and displays data for all critical
WIPP facility systems. These critical WIPP facility systems
include fire detection and alarm systems, heat, ventilation,
air conditioning, and electrical systems. There are
multiple internal/external communication systems. Some or
all of these communication systems could be wiped out by Y2K
problems. It is yet unknown whether external phone systems
will work at the beginning of the year 2000. The CMS components are powered from the central
Uninterruptible Power Supply which features automatic
switching. The system performs automatic checks of the
status of the WIPP site. Twenty-four (24) local processing
units monitor the status of the WIPP site. The fire
suppression-water pump is started automatically, and water
supplies are automatically switched from one source to
another. Automated systems and processing units are
potentially susceptible to Y2K problems. Before WIPP is allowed to receive waste, the NMED must
require the Permittees to prove that the following Y2K
preventive steps have been taken: 1. ASSESSMENT OF SYSTEMS: All networks, integrated
computer systems, sub-system components, and system software
should be assessed all the way down to the level of the
computer chips and individual lines of code. Each area of
the WIPP facility should identify its mission-critical
systems, emphasizing those systems whose degradation would
cause a loss of core capability. 2. RENOVATION: Identified problems should be solved
at the lowest level of physical or operational
existence. 3. VALIDATION: Systems should be certified as Y2K
compliant if they meet the requirements after they have been
comprehensively tested. 4. IMPLEMENTATION: Systems are certified as fully
operational in terms of independent performance and
interactions with systems of other departments or outside
services. The certification as fully operational (need
actual conditions) would occur sometime after January 2000
when there has been the opportunity to see what is working
and what might fail under actual Y2K conditions. OFF-SITE WASTE: The final Permit must require the
Permittees to apply for a Permit Modification for the waste
characterization procedures for each DOE generator/storage
site shipping waste to WIPP. The NMED should follow its
procedures to determine if each of the DOE's
generator/storage sites is able to properly characterize
waste. There are many indications in the Permit
Application, the draft Permit, and the DOE's written
Comments that each site has unique features and types of
waste. Further, the DOE generator/storage sites differ in
their abilities to characterize waste. Generator/storage
sites may even differ in the hazardous waste regulations
under which they must operate and characterize waste.
Inventories of both radionuclides and hazardous materials as
well as the physical form of wastes are different at
different sites. Each generator/storage site must be
approved as a separate entity by the NMED before it is
allowed to ship waste to WIPP. In the final Permit,
pursuant to the Quality Assurance (QA) regulations, the NMED
must be required, not just allowed, to oversee all
generator/storage site audits. WASTE HANDLING BUILDING SECONDARY CONTAINMENT: The
Permittees should be prohibited from using the floor coating
in the Waste Handling Building (WHB) as a secondary
containment system. The floor coating has the potential to
crack or to be scraped off under normal working conditions.
The floor coating may also become cracked or separated from
the surface of permanently attached structures that are
repeatedly subjected to the movement of heavy loads. INSPECTION OF 55-GALLON DRUM SEVEN-PACKS: The final
Permit must require that both the center drum of a 55-gallon
seven-pack assembly and the drums on pallets in the WHB be
inspected. No exemptions should be allowed. It is
unacceptable to neglect the inspections of some drums just
because the inspection is difficult. Drum assemblies and
storage configurations should be changed to allow visual
access. It is not scientifically credible to assume that
the center drum in a 7-pack is less likely to have problems
than the outer drums. If the center drum cannot be
inspected, an empty spacer drum should be required
instead. The problems associated with the inability to inspect
some of the drums are intensified by the lack of real-time
continuous air monitors (CAMs) in the WHB. CAMs should be
placed throughout the WHB so that local releases can be
detected as they occur. Under the current system in the
WHB, the only detection devices are at the exit doors. If a
release happens, workers will not know about it until
exiting the building. With a CAM system in place, workers
will be notified immediately and will be able to contain the
release according to standard procedures. Under the current
system, if a release happens, workers can track released
materials throughout the WHB before detection. CHEMICAL INCOMPATIBILITY OF WASTE AND PACKAGING
MATERIALS: Much of the waste is packed in plastic bags made
of polyethylene or polyvinyl chloride (PVC). Many
containers are lined with a polyethylene coating. These
plastics are capable of discharging enough static
electricity to ignite any flammable gases within a drum, as
for example hydrogen or benzene gas. [According to the 1996
North American Emergency Response Guidebook, an IGNITABLE
SOURCE includes "heat, sparks, flames, static electricity
and friction.] Most hydrogen gas within the waste drums will be vented,
but methane could still be a problem. In addition, filters
could be blocked or corroded, allowing gases to build up in
a drum. Many of the VOCs are flammable, and the presence of
some non-flammable VOCs, like trichloroethylene, lower the
flammability limits for both hydrogen and methane.
[According to the 1996 North American Emergency Response
Guidebook, a FLAMMABLE LIQUID "has a flash point of 60.5šC
(141šF) or lower.] In stored drums, larger quantities of
hydrogen are being generated than were expected, and this
could be true for other flammable gases as well. There are other possible sources for drum fires in the
waste inventory. There are no provisions for dealing with
burning containers that arrive at WIPP in a TRUPACT-II. A
lack of underground CAMs makes it impossible to detect any
burning or smoldering waste drums. A lack of aisle space
makes it difficult or impossible to safely put out waste
drum fires underground. RELEASES TO THE ATMOSPHERE: The Permit Application and
the draft Permit describe the non-VOC component of the
hazardous waste as being present in large pieces rather than
in particulate form. In fact, the DOE plans to ship large
quantities of respirable unsolidified process plutonium
residues from the Rocky Flats Environmental Technology Site
(RFETS). There are about 117 tons of plutonium-bearing
residues at Rocky Flats. Most of these residues will only
be repackaged, not solidified. Metals in these waste
streams will exist as respirable particles. Descriptions detailing the specific quantities and
chemical make-ups of these hazardous wastes may not exist in
available Acceptable Knowledge (AK) documentation. This
information will have to be discovered through sampling and
analysis procedures. Because these wastes will have been
repackaged, they will be recharacterized as newly generated
waste. Newly generated waste will be sampled and analyzed
only once a year after an initial ten-sample set is taken.
[The DOE is required to take ten samples from each waste
stream to verify its AK characterization.] The processing
of these wastes was done long ago and will not be reviewed
weekly for process changes as is required for newer wastes.
It is unlikely that these older drums will be tested under
the more frequent process-batch procedure. The process-
batch procedure is used for newly generated wastes whose
process changes. The DOE also wants to eliminate the
initial ten-sample requirement. This characterization
procedure is inadequate to understand these wastes. Respirable and unsolidified hazardous particulates are
not addressed in the Application or draft Permit as WIPP
waste. [Respirable and unsolidified plutonium contaminated
residues contain an unknown quantity of hazardous
particulates.] The DOE did not list these hazardous
particulates in its Application documents. Therefore,
potential releases of these hazardous particulates to the
atmosphere were not considered. This resulted in a void of
information concerning the health effects of such releases
to the workers and the general public. If a large quantity
of this waste were released from containers during a roof-
fall event or methane gas explosion, harmful consequences to
human health and the environment might occur. The DOE's analyses of roof-falls concluded that a roof-
fall in an active room is "beyond extremely unlikely." The
DOE's determination does not apply to Panel 1. The DOE also
claims that no drums would be breached during a roof fall.
However, the drums used in the test that led to this
conclusion were stronger than the drums used for the WIPP
waste. The possibility of numerous roof bolts falling from
the ceiling and puncturing the drums has been ignored.
[Falling roof bolts can generate sparks if they hit metal
drums, possibly igniting flammable gases.] VISUAL EXAMINATION MISCERTIFICATION RATE: [The
miscertification rate is the error rate between the results
of the radiography of a waste drum and the results of the
visual examination of the same drum.] The draft Permit
allows generator sites that do not have historical
miscertification rates for radiography to begin verifying
that radiography by visually examining (VE) only 2% of the
radiographed containers. However, each generator site is
unique in their ability to characterize waste. LANL's
historical rate is 11%. The Rocky Flats' rate is somewhat
more than 2%. Only the rate for INEEL remains at 2%. The
burden is on the DOE to show that the sites can characterize
the waste. One hundred percent (100%) of the containers
should be visually examined for the first year. The
miscertification rate for the waste drums destined for the
bin scale tests was 58%. This high rate of miscertification
was discovered when all of the bin scale test drums were
opened and visually examined in the early 1990's.
At the last WIPP Quarterly Meeting (a technical exchange
and update where the DOE officials, EEG, NMED, and other
state officials, as well as the public were present) even
high-level DOE people seemed uninformed about WIPP's Y2K
compliance status. Ms. Reade did not know if the DOE has
produced any documentation of Y2K compliance at WIPP. Such
documentation has not been produced at this hearing.
Systems could begin to be affected by Y2K-like problems even
before January 1, 2000. Even systems that have been "fixed"
might have bugs that will not show up until after that date
when systems are actually operating. Acceptable Knowledge
(AK) may be computerized. The DOE could lose track of data
on waste characterization or on the waste drums arriving at
WIPP. The WIPP Waste Inventory System (WWIS) might be Y2K
vulnerable since it is a computer data system. During the bin-scale tests the DOE wanted to study the
interaction of the waste with brine and salt. The DOE
opened all of the drums to determine the identity of the
wastes with which they would be experimenting. Even though
all of the waste was certified to the Waste Acceptance
Criteria (WAC) existing at the time, 58% of the drums were
found on visual examination NOT to meet the WAC or shipping
criteria. The WAC violations discovered during the bin-
scale test would still be violations under the current WAC
(no free liquids, etc.). Eventually the DOE decided not to
conduct the bin-scale tests at WIPP. The experiments were
done in a laboratory. Some of the Rocky Flats residues must be further
processed before shipment to WIPP to make them less
concentrated and in order to meet Safeguard Termination
Limits. The DOE has given itself a variance on some of
these limits and now allows up to a 10% concentration of
plutonium in the residues. There is at least 2,600 kg
[approximately 5,720 pounds] of plutonium in the Rocky Flats
residues. The public should be involved in the process of
certifying each generator site as capable of characterizing
and shipping waste to WIPP. The NMED should participate in
the initial site audits and all site audits thereafter. It
is appropriate for the DOE to pay NMED's costs to
participate in the site audits. This process is in effect
in other states, like California. If the 7-pack center drums (or other drums that are
stacked or otherwise inaccessible for inspection) are not
inspected, those waste drums could corrode or breach and no
one would know. Without CAMs throughout the WIPP site, a
release could go undetected. Workers should not be
unnecessarily exposed to radiation or hazardous materials
while inspecting these drums. In order to protect workers,
an empty spacer drum should replace the center waste drum.
One of the main documents the DOE used in their analyses
of roof fall events was "Analysis of Roof Falls and Methane
Gas Explosions in Closed Rooms and Panels," PLG-1167. This
document contains many unjustified assumptions. At one
point in the document, an analysis was not done because it
was too complicated to do easily. Instead of completing the
analysis, the DOE made an "argument" to support the
document's conclusion. Ms. Reade stated that she could just
as well make a good "argument" to the contrary. Some health studies have been done at the DOE sites. Ms.
Reade is most familiar with some health studies done at LANL
where thyroid cancer rates were shown to be four times the
state average. Female LANL workers also had elevated
ovarian and other cancer rates which the researcher said
were not attributable to radiation since the subjects'
exposures were so low. This leaves open the possibility
that the causal factor was a RCRA-regulated material used at
LANL. Most of the waste destined for WIPP at LANL is stored in
fabric domes, although some of the waste is covered with
dirt or retrievably buried. The waste in the domes is
monitored. The LANL dome waste is in danger from fire and
other natural disasters. However, the DOE is concentrating
on preparing to ship this waste to WIPP instead of building
safer "bunker" type retrievable storage facilities. The DOE
does not have the resources or personnel to do both. Safe
and secure storage of TRU waste at LANL should be done
first. Legacy waste is buried throughout the DOE complex.
[LEGACY WASTE is waste that was generated in the past and
has been dumped or buried on-site at the DOE facilities.]
The legacy waste is not intended for disposal at WIPP. The
legacy waste is contaminating the groundwater, soil and air
at DOE facilities throughout the country. If there is a methane gas explosion at the WIPP site, in
theory the panel closures will hold. However, this theory
has never been tested. When the DOE is risking the lives of
workers in an underground mine, the DOE should be 100% sure
that the panel closures will hold in case of a methane gas
explosion. Panel closures are not seals. Some gases will
escape from these panel closures during WIPP's operational
phase. The DOE does not always follow-up its computer modeling
with actual physical tests. In fact, sometimes the physical
results are different from the theoretical ones. In such
cases, the DOE will continue to use the theoretical
parameters anyway, for example, the DOE's solubility
modeling for the WIPP site. CARD supports the characterization of the waste, but not
disposal as a means to gain an understanding of the waste.
Existing characterization is not adequate and requires
regulatory guidance from the NMED. Similarly, the DOE does
not understand the geology of the WIPP site. As time
passes, our understanding of the WIPP site improves. Site
characterization and waste characterization could proceed
simultaneously. Informed decisions could then be made
whether WIPP is the appropriate disposal site for our
nation's transuranic defense waste. The DOE has stated that
the WIPP waste could stay at the generator sites safely for
decades. The DOE's track record is questionable. There have been
many problems with the DOE's past operations of its
facilities. The myriad of problems and lack of solutions
give pause about the DOE's ability to operate WIPP
safely.
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