High-Level Dollars, Low-Level Sense:
Chapter 3
Overview and Critique of the Current Approach to Radioactive Waste Management

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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:

The nature and characteristics of the transuranic waste intended to be emplaced in WIPP also pose potential problems.

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:

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.

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Institute for Energy and Environmental Research

Comments to Outreach Coordinator,
Takoma Park, Maryland, USA

Last Updated October, 1996

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.
48. Ibid.
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.