Evaluation of the WIPP Project`s compliance with the EPA radiation protection standards for disposal of transuranic waste

Abstract

The US Environmental Protection Agency`s (EPA) proposed rule to certify that the Waste Isolation Pilot Plant (WIPP) meets compliance with the long-term radiation protection standards for geologic repositories (40CFR191 Subparts B and C), is one of the most significant milestones to date for the WIPP project in particular, and for the nuclear waste issue in general. The Environmental Evaluation Group (EEG) has provided an independent technical oversight for the WIPP project since 1978, and is responsible for many improvements in the location, design, and testing of various aspects of the project, including participation in the development of the EPA standards since the early 1980s. The EEG reviewed the development of documentation for assessing the WIPP`s compliance by the Sandia National Laboratories following the 1985 promulgation by EPA, and provided many written and verbal comments on various aspects of this effort, culminating in the overall review of the 1992 performance assessment. For the US Department of Energy`s (DOE) compliance certification application (CCA), the EEG provided detailed comments on the draft CCA in March, 1996, and additional comments through unpublished letters in 1997 (included as Appendices 8.1 and 8.2 in this report). Since the October 30, 1997, publication of the EPA`s proposed rule to certify WIPP, the EEG gave presentations on important issues to the EPA on December 10, 1997, and sent a December 31, 1997 letter with attachments to clarify those issues (Appendix 8.3). The EEG has raised a number of questions that may have an impact on compliance. In spite of the best efforts by the EEG, the EPA reaction to reviews and suggestions has been slow and apparently driven by legal considerations. This report discusses in detail the questions that have been raised about containment requirements. Also discussed are assurance requirements, groundwater protection, individual protection, and an evaluation of EPA`s responses to EEG`s comments.