High-Level Dollars, Low-Level Sense:
Overview and Critique of the Current Approach to Radioactive Waste Management
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Endnotes found at end of file.
Environmental and Financial Risks of Current Programs
Transuranic Wastes at WIPP41
In 1970, after some 25 years of burying transuranic-contaminated wastes in shallow trenches, the Atomic Energy Commission (the DOE's predecessor agency) decided that transuranic waste was potentially dangerous and therefore unsuitable for shallow-land burial. The AEC began requiring that transuranic waste which contained more than 10 nanocuries per gram be stored in retrievable containers, pending its permanent disposal in a deep geologic repository.
The Waste Isolation Pilot Plant (WIPP) is DOE's geologic repository project for the disposal of transuranic wastes in the salt beds of southeastern New Mexico, at a site about 25 miles from the town of Carlsbad.
The origins of WIPP go back to the early 1970s, when the Atomic Energy Commission moved the focus of its search for waste disposal to New Mexico in the wake of its failure in Lyons, Kansas. Originally conceived as a pilot facility for commercial and military high-level waste disposal, WIPP has since 1979 been slated for use as a disposal site for military transuranic wastes only.42 As a DOE project, WIPP is not subject to NRC licensing, but the DOE has agreed with New Mexico that it will be subject to EPA standards.43 At what point such compliance must be demonstrated, however, has become a point of contention, with the DOE wanting to begin loading waste for "experimental" demonstration purposes before showing compliance. Other federal agencies and independent scientists have questioned the need for this, and assert that compliance with final EPA standards should be shown before any wastes are loaded into WIPP.44
Unlike the DOE's program at Yucca Mountain, WIPP is partly built.45 Located 650 meters below surface, the $1 billion repository consists of a 112-acre underground area, and has a capacity of about 880,000 55-gallon drums, enough to contain slightly less than 160,000 cubic meters (5.6 million cubic feet) of waste.46
Numerous technical issues related to the geology and hydrology of the WIPP site and the nature of the transuranic waste intended to be placed there raise questions about its suitability and the DOE's management of the program. These issues include:
Pressurized water pockets below WIPP. WIPP is mined out of the lower part of a 2,000-foot thick geological formation called the Salado formation. The Salado is directly above another formation called the Castile formation which has been discovered to contain brine (salt water) pockets under pressure. Boreholes drilled from ground level which have breached these brine reservoirs have typically experienced brine flows to the surface of several hundred gallons a minute.47
The initial WIPP site was abandoned in 1975 when the first WIPP borehole encountered brine and was moved to a different location a few miles away. The planned orientation of WIPP then had to be adjusted in 1981 when the new location was discovered to be within 500 vertical feet of a brine reservoir estimated to contain 700 million gallons of pressurized brine. A 1987 DOE study shows that a pressurized brine reservoir may be present 800 feet below the current repository location, posing the risk that at some point in the future, brine could breach the repository and carry radioactivity to the surface.48
- Water leakage into WIPP. The DOE first encountered water seepage into WIPP excavations in 1983. In 1986, a member of the National Academy of Sciences (NAS) panel on WIPP warned that in a few hundred years sufficient brine might seep into the repository rooms to saturate them. The water leakage issue became public in the fall of 1987 when a group of New Mexico scientists (called the Scientists Review Panel) concluded that the salt formation at WIPP contains much more water than the DOE had anticipated. They warned that over a period of time the brine could corrode the waste drums, forming a "radioactive waste slurry" consisting of a mixture of brine and nuclear waste which might eventually reach the surface.49
- Wall cracking and ceiling collapse. Cracks have appeared in the ceilings and floors of several large waste storage rooms, and in three areas, the ceiling has also collapsed. The cracking and collapse are the result of a rate of room closure two to three times faster than was anticipated. When the first storage rooms were excavated in 1983, the DOE expected it would take 25 years for the creeping salt walls to completely close in on each other, locking the barrels of waste into a mass of solid salt rock. However, at the rate the rooms are closing, it may take them only 13 years or less before complete closure. This rapid rate of closure resulted in the initial cracking, which, although known about by the DOE since 1987, was not publicly revealed until the cracks were also discovered by the New Mexico state Environmental Evaluation Group in May 1989 -- a month after the DOE closed the rooms to workers because of fears that sections of the ceiling might fail and collapse.50
On June 19, 1990, a 100-ton section of the ceiling of a test room did collapse, just 18 days after a technician was in the room for an inspection.51 A 1,400-ton rockfall occurred in the same area in February 1991, despite the fact that the DOE had installed bolts in the ceiling to improve its stability. As of June 1991, two additional rockfalls have also been reported.52
The DOE maintains that the cracks were not important enough to mention publicly because simple mining techniques could make them harmless, and that the ceiling collapses are an expected result of an experiment to see how fast the closure took. But the more significant issue is the existence of yet another unanticipated behavior, which again raises the question: if the DOE is unable to anticipate repository behavior on the scale of a few years, what confidence can there be in its behavior over the next several thousand centuries?
Natural resource issues. Natural resources, especially oil and gas, are known to exist in the region of the WIPP repository. There are proven reserves in the area, and even an existing oil and gas lease beneath the WIPP site.53 These resources could invite future intrusion into the site, a matter of particular concern in light of the existence of the pockets of pressurized brine discussed above.
The nature and characteristics of the transuranic waste intended to be emplaced in WIPP also pose potential problems.
- Compliance with hazardous waste law. Approximately 60 percent of the transuranic wastes slated for disposal in WIPP are also contaminated with hazardous chemicals.54 Thus, these transuranic wastes are also mixed waste, meaning they are also regulated under the law on hazardous wastes, the Resource Conservation and Recovery Act (RCRA).55
RCRA regulations require that the disposal of hazardous wastes be characterized in detail so that human health and the environment are adequately protected. However, according to the DOE, "a large volume of transuranic-mixed wastes to be sent to WIPP were generated in the distant past. Documentation on the chemical constituents of these wastes ... is often inadequate or does not exist."56 RCRA, however, contains a "land ban" provision which prohibits the disposal of uncharacterized or untreated hazardous wastes via land burial unless it can be shown that there will be no migration of the hazardous materials. Instead of going through the process of characterizing and treating the wastes, however, DOE sought a variance from EPA's regulations through a "no-migration" petition. Although not granting the DOE's request for a complete and permanent variance from RCRA's land ban, in the fall of 1990, EPA granted a temporary conditional 10-year variance for DOE's planned experimental demonstration phase at WIPP.57
Gas generation from waste. The chemical components of the wastes to be emplaced in WIPP are such that they are continuously, as a result of chemical breakdown processes, generating gases which are released from the waste. If the gas generation rate is sufficient, the concern is that after WIPP has been sealed, the repository could become pressurized, thereby either preventing proper closure from salt creep, or providing a mechanism to forcibly push the waste from the repository. Either way, proper isolation of the waste may not be achieved.58
There are serious questions about whether WIPP can meet the EPA's waste disposal standards,59 particularly due to concerns about the probability of human intrusion some time in the future due to the natural resources in the region, and due to concerns about gas build-up contributing to radionuclide release.60
In addition to the technical problems with the site itself, the risks and uncertainties associated with the program have only been exacerbated by the DOE's management. Problems include:
- Missing documentation. One part of the process of certifying the WIPP is the completion by the DOE of a safety analysis report. However, an internal DOE review of a 1988 draft report found that it "do[es] not contain sufficient information for us to independently conclude that the facility can be operated safely."61
Another preliminary review of the available information on WIPP by the DOE's Brookhaven National Laboratories criticized the lack of documentation of a design change that was made in the early stages of WIPP construction by a WIPP project panel. Said the Brookhaven reviewers, "No documentation of this process was found, nor was the listing of panel members made available to us."62 The Brookhaven review found that no conclusion could be drawn about the safety of WIPP design "due to the lack of documentation available..."63
The DOE officially completed what it referred to as a Final Safety Analysis Report in June of 1990. It is not actually final in any meaningful sense, however; even the document itself refers to upcoming amendments and additions that will be required over the next several years as various tests are completed.64 Outside reviewers have criticized the document as being incomplete even regarding the tests which have been conducted.65
- Construction Quality. Based on the limited information that was available, the DOE's review found reason to suspect that the construction quality at WIPP may not be adequate. Citing a 1986 accident at WIPP that involved a fire protection system which caused over $100,000 damage, the review noted that "[t]he accident was caused by failure to properly install the fire water system pipes. This occurrence raises questions about general construction quality."66
Misplaced Priorities. In hearings before the House Environment, Energy, and Natural Resources Subcommittee of the Committee on Government Operations in the fall of 1988, the DOE was criticized for devoting inadequate staff to assess the safety of WIPP and its ability to comply with environmental standards. "There are more DOE people lobbying for legislative authority to emplace waste than there are trying to make sure that facility can be run safely," noted Subcommittee Chairman Mike Synar (D-OK). "That is a formula for disaster."67
There are other problems related to the waste capacity of WIPP. The expected capacity of the facility is a little under 160,000 cubic meters. 68 The amount of transuranic waste in retrievable storage at the beginning of 1990 was about 62,000 cubic meters, and the net accumulation of this retrievable waste by the end of the next 20 years or so is expected to be almost 112,000 cubic meters. 69 WIPP's projected capacity is sufficient to accommodate this amount. However, as can be seen from Table 1, page 20 of the chapter on radioactive waste characteristics, this does not include the 190,000 cubic meters of buried transuranic wastes, or the 390,000 to 540,000 cubic meters of transuranic contaminated soil also present at various sites. Thus, the total amount of transuranic waste in all forms expected to be present by early next century is in the range of 443,000 to 592,000 cubic meters -- roughly two-and-one-half to three-and-one-half times the capacity of WIPP. The DOE has so far failed to make a determination about what it plans to do with this buried transuranic waste and transuranic-contaminated soil, yet it is this waste -- not the retrievably stored waste in monitored facilities -- which poses the greatest environmental risk.
Thus, the DOE's current transuranic waste policy is something of a paradox. On the one hand, DOE policy is that transuranic waste is so dangerous that it needs to be stored in a repository 650 meters underground to isolate it from the environment. On the other hand, DOE policy so far leaves unaddressed the permanent disposition of the majority of the transuranic waste contaminating the ground or lying in shallow pits and disposal cribs. 70 Because of its planned size, WIPP cannot provide a complete solution for the disposal of many of the transuranic wastes that are causing the greatest contamination problems.
Go to another section in Chapter 3:
- A. Spent Fuel, High-Level, and Transuranic Wastes
- B. Low-Level Waste
- C. Mill Tailings
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Full references available here.
41. Much of the material for this section is updated from Saleska 1989, pp. VII-10 to VII-14.
42. Carter 1987, pp. 177-182.
43. First Modification to the July 1, 1981 "Agreement for Consultation and Cooperation" on WIPP by the State of New Mexico and the U.S. Department of Energy, November 30, 1984. (Reference courtesy Don Hancock, Southwest Research and Information Center, Albuquerque, New Mexico.)
44. GAO 1988b, pp. 10-14, summarizes criticism along these lines from GAO, the National Academy of Sciences, the state of New Mexico's Environmental Evaluation Group, and the Scientists Review Panel, a group of New Mexico scientists.
45. Only about 15 percent of WIPP has actually been mined. This is because the natural phenomenon of "salt creep" (which is the tendency of salt to gradually "flow" and fill empty spaces) causes any rooms mined to close as the salt creeps in to refill the mined space. This gradual room closure is an anticipated part of any waste-disposal process in salt, but the rooms cannot be mined too far in advance of waste emplacement. The DOE therefore plans to mine the additional waste-disposal rooms as the time of permanent waste emplacement approaches. (DOE 1990d, p. 79)
46. The actual capacity of the repository has been the subject of a small controversy. At one point the DOE claimed (DOE 1989c) that the capacity was 1.1 million 55-gallon drums containing about 6.5 million cubic feet. The New Mexico Environmental Evaluation Group, however, estimated that the space only allowed for about 850,000 drums, after which the DOE apparently adjusted its estimate to 880,000 drums containing 5,598,000 million cubic feet (about 158,500 cubic meters). (DOE 1990f, Comments and response section of Vol. 3, and Table 3.1 in Vol. 1)
47. Testimony of Lokesh Chaturvedi, Deputy Director, New Mexico Environmental Evaluation Group, as contained in House 1988.
49. GAO 1988b, pp. 8-9.
50. Schneider 1989, p. 8.
51. Goessl 1990.
52. GAO 1991, pp. 10-11.
53. House 1991. A recent House bill, H.R. 2637 (passed by the House Interior Committee on June 26, 1991) contains a provision (section 11) which would condemn the existing lease. The DOE opposed this provision.
54. DOE 1989c, Vol. 2, p. B-22.
55. Regulations pursuant to RCRA are incorporated into 40 CFR Part 264.
56. DOE, RCRA Compliance at the Department of Energy's Waste Isolation Pilot Plant, DOE/WIPP 88-018, p. 12, June 1988, as contained in House 1988, pp. 135-155.
57. EPA 1990a, p. 47700.
58. Telephone conversation between Anthony Gallegos, Performance Assessment Specialist, New Mexico Environmental Evaluation Group, and Scott Saleska, IEER (6 November 1991). Sandia 1990, pp.VI-19 to VI-33, discusses attempts to model gas generation to determine whether it will interfere with the repository's ability to comply with environmental standards.
59. Those at 40 CFR 191.
60. Detailed consideration of WIPP's ability to comply with EPA standards is contained in Sandia 1990.
61. Memorandum from James P. Knight, DOE Office of Safety Appraisals (Sept. 2, 1988), as contained in House 1988, p. 116.
62. Brookhaven National Laboratory, Report on Trip to Waste Isolation Pilot Plant, p. 3 (August 24, 1988) (as contained in House 1988, pp. 120-128).
63. Ibid., p. 4.
64. DOE 1990g.
65. Letter from Robert Neill, Director, New Mexico Environmental Evaluation Group, to Arlen Hunt, WIPP Project Manager, August 9, 1991.
66. DOE, Memorandum to James P. Knight through Edward F. Branagan, Jr., regarding "Site Visit to Albuqurque Operations Office and the Waste Isolation Pilot Plant", p. 3, September1, 1988 (as contained in House 1988, pp. 102-108).
67. Exchange between Jill Lytle, Deputy Assistant Secretary for Nuclear Materials, U.S. Department of Energy, and Congressman Mike Synar, House 1988, p. 131.
68. DOE 1990f.
69. DOE 1990d, p. 81. The DOE's projections for transuranic waste generation go until the year 2013.
70. This same issue was first raised by the U.S. General Accounting Office in 1986. See GAO 1986c.