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 60.5C (141F) 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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