The Presentation by the
New Mexico Environmental Evaluation Group
"The purpose of the New Mexico Environmental Evaluation
Group (EEG) is to conduct an independent technical
evaluation of the Waste Isolation Pilot Plant (WIPP) Project
to ensure the protection of the public health and safety and
the environment. The WIPP Project, located in southeastern
New Mexico, is being constructed as a repository for the
disposal of transuranic (TRU) radioactive wastes generated
by the national defense programs. The EEG was established
in 1978 with funds provided by the U.S. Department of Energy
(DOE) to the State of New Mexico. Public Law 100-456, the
National Defense Authorization Act, Fiscal Year 1989,
Section 1433, assigned EEG to the New Mexico Institute of
Mining and Technology and continued the original contract DE-
AC04-79AL10752 through DOE contract DE-AC04-89AL58309. The
National Defense Authorization Act for Fiscal Year 1994,
Public Law 103-160, continues the authorization.
"EEG performs independent technical analyses of the
suitability of the proposed site; the design of the
repository, its planned operation, and its long-term
integrity; suitability and safety of the transportation
systems; suitability of the Waste Acceptance Criteria and
the generator sites' compliance with them; and related
subjects. These analyses include assessments of reports
issued by the DOE and its contractors, other federal
agencies and organizations, as they relate to the potential
health, safety and environmental impacts from WIPP. Another
important function of EEG is the independent environmental
monitoring of background radioactivity in air, water, and
soil, both on-site and off-site."
Forward to EEG-68, "Evaluation of the WIPP Project's
Compliance with the EPA Radiation Protection Standards for
Disposal of Transuranic Waste," March 1998, iii.
TESTIMONY OF ROBERT H. NEILL - March 1, 1999.
Dr. Neill received a M.S. in Radiological Medicine,
School of Public Health, Harvard University, 1962 and a M.E.
in Mechanical Engineering, Stevens Institute of Technology,
1951. Mr. Neill is currently the Director of EEG.
MAGNESIUM OXIDE BACKFILL: Magnesium oxide (MgO) backfill
is required by the EPA at WIPP. This backfill will limit
the release of radionuclides, increase the pH of the waste
environments, decrease the solubility of the actinides, and
reduce the ability of the radionuclides to migrate.
However, this backfill will have no bearing on the chemical
behavior of the RCRA regulated VOCs, metals, or solvents.
The DOE has deleted the requirement for magnesium oxide
backfill in its written Comments. Accident scenario
calculations were based on the presence of this backfill,
and if it is eliminated, scenarios should be recalculated.
Also, engineered barriers are desirable due to the inherent
uncertainty of calculations in predicting the long-term
behavior of the radionuclides. The mixed waste is
respirable, soluble, and contained in drums without any
PROHIBITION OF RH-TRU WASTE: EEG concurs with NMED to
exclude RH-TRU waste from the current permit. There is
uncertainty in future projections of quantities of RH-TRU
waste and data are not available for the hazardous component
in the RH-TRU waste. The Nuclear Regulatory Commission
(NRC) has not yet certified a shipping cask, and
characterization facilities do not exist yet for either the
radiological or hazardous components in the RH-TRU waste.
The Waste Analysis Plan, Quality Assurance Program Plan, and
TRU Waste Characterization Sampling and Analysis Methods
Manual are not applicable to RH-TRU mixed waste.
The dose rate is not the only difference between CH-TRU
and RH-TRU waste. CH-TRU waste predominantly contains alpha-
emitting radionuclides whereas RH-TRU waste contains
primarily fission products that are beta and gamma emitters.
Radiographic analysis of RH-TRU waste may not be
HIGHLIGHTS OF CROSS-EXAMINATION OF ROBERT NEILL:
Characterization of RH-TRU waste would be different
because the radionuclide inventory is different, and there
is a higher dose rate. The RTR of shielded RH containers is
possible, but the RTR facility would be different from the
CH-TRU facility. Gas generation sampling and analysis would
be different. Alpha emissions cause RADIOLYSIS, which can
create hazardous and flammable gases. RH-TRU waste has few
alpha-emitters (except for Americium), so hydrogen and other
gas generation would be less of a problem than in the CH-TRU
Magnesium oxide backfill will be necessary only on the CH-
TRU waste. The RH-TRU waste will be emplaced in the walls,
and the salt itself will be a barrier. The most likely path
of irradiation or contamination from the RH-TRU waste would
be through the wall boring. The contamination would meet
the magnesium oxide backfill when it moved into the closed
Isolation of radioactive waste usually uses multiple
barriers. Much of the CH-TRU waste is respirable (less than
10 microns particle size). The DOE had a 20-year
containment-life requirement for drums in the 1970s, but
this requirement has been deleted from the draft Permit.
There are no requirements to solidify the waste (which
EEG has recommended). The NRC has more restrictive rules
for solidifying low-level waste (LLW). The Idaho
Engineering and Environmental Laboratory (INEEL) will have
its CH-TRU waste treated and solidified at the Advanced
Mixed Waste Treatment Plant (Idaho). This facility will
also process existing alpha-emitting LLW into TRU waste.
Operation is planned to begin in 2006, but the schedule
There are respirable metals mixed in with the respirable
radioactive waste in the Rocky Flats process residues.
There is also uranium in the WIPP inventory though,
strictly speaking, uranium is not transuranic. It is not
expected that there will be measurable quantities of tritium
in the WIPP waste.
Fifty-eight percent (58%) of the drums visually examined
for the bin-scale tests were found to be incorrectly
characterized. Even though there was a different WAC in
place when the drums were opened in the early 1990's, the
reasons for their exclusion under the WAC (free liquids,
pressurized containers, etc.) have always been in the WAC.
The transportation exclusions for excessive decay heat were
related to an excess of hydrogen gas being in a drum.
Therefore, 58% of the drums were indeed miscertified.
RCRA does not have any container longevity requirements
for owners and operators of disposal facilities.