Regulatory Compliance Strategy For Recovery-Driven Underground Ventilation System Changes - 16355
The Waste Isolation Pilot Plant (WIPP) facility is managed and operated by Nuclear Waste Partnership LLC (NWP) for the U.S Department of Energy (DOE). On February 14, 2014, a radiological event occurred in the WIPP facility underground repository, which resulted in the release of transuranic isotopes contaminating a portion of the underground primarily along the ventilation path from Panel 7, the location of the incident. The release was initially detected by an underground continuous air monitor (CAM) which caused an automatic switch of the ventilation system to filtration mode and ventilation was directed through high-efficiency particulate air (HEPA) filtration banks located in the surface exhaust building. When the HEPA filtration was engaged, the underground normal ventilation was reduced from 425,000 standard cubic feet per minute (scfm) to 60,000 scfm. Since the event, all exhaust air is filtered through HEPA filters at 60,000 scfm to minimize the possibility of exposure to workers, the public and the environment. Ventilation of fresh air to the WIPP underground is a primary limitation to performing underground recovery activities; therefore, recovery-driven ventilation changes are needed. The safe recovery of the WIPP facility and resumption of normal waste emplacement activities require an increase in ventilation capacity to be accomplished in three phases: 1) Interim Ventilation System, 2) Supplemental Ventilation System and 3) Permanent Ventilation System. Each phase adds increased air flow to the underground and allows for underground activities to be performed concurrently. The regulatory strategy for ventilation recovery focuses on ensuring that needed changes to the WIPP facility are protective of human health and the environment. Recovery-driven ventilation changes are implemented using the procedures, processes, and regulations that are required by the two primary regulatory agencies for the WIPP facility: the U.S. Environmental Protection Agency (EPA) and the New Mexico Environment Department (NMED) as well as DOE requirements. Regulatory compliance is being achieved for the three ventilation phases to restore underground ventilation by providing the regulators and stakeholders opportunities for involvement during the design and development processes. A strategy for a tiered NMED permitting process and a plan for developing required EPA documentation are under consideration. The Project's objective is to resume normal waste emplacement activities with safety, protection of the public, the worker and the environment as the highest priorities. Important elements of ensuring that WIPP facility recovery and future waste emplacement activities occur as planned are transparency and communication with the regulatory community. (authors)