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This work aims to determine the potential risk of directly storing waste salt from the electrorefining process of used nuclear fuel in a geologic repository. To accomplish this, the solubility limit and dissolution rate of four representative chloride salt mixtures (solutes) in water and two brine solutions (solvents) are observed and documented.
From its inception in the early 1950s through the end of the Cold War in the early 1990s, the Savannah River Site (SRS) produced nuclear materials for national defense in five reactors. Additionally, irradiated reactor fuel and target tubes were dissolved in nitric acid to recover plutonium and uranium using the PUREX (Plutonium Uranium Reduction EXtraction) process. Liquid waste from these chemical separations processes was then stored onsite in 51 underground tanks. Eight waste storage tanks have been operationally closed (i.e. cleaned and grouted) and the remaining tanks hold a mixture of liquids, insoluble solids, and precipitated salts (SRMC-LWP-2022-00001), the latter generated by evaporating water from the liquid waste. Waste is currently being retrieved from tanks and separated into 1) high-radioactivity, low-volume, and 2) low-radioactivity, high-volume components, principally through the Salt Waste Processing Facility (SWPF) (SRMC-LWP-2023-00001). The former waste stream is vitrified in the Defense Waste Processing Facility (DWPF), stored onsite, and destined for offsite disposal in a deep geologic repository. The latter stream is mixed with dry cementitious materials in the Saltstone Production Facility (SPF) and the wet slurry placed in onsite Saltstone Disposal Units (SDUs) within the Saltstone Disposal Facility (SDF), where it hardens into a cement waste form termed saltstone. A low-infiltration surface cover system will be placed over the SDF at closure, where SDUs will then be in the subsurface post-closure (SRR-CWDA-2019-00001).
The Waste Isolation Pilot Plant (WIPP) is developed by the U.S. Department of Energy (DOE) for the deep geologic disposal of transuranic (TRU) waste in southeast New Mexico. The purpose of performance assessment (PA) is to estimate probability of potential radionuclide releases from the repository to the environment for a regulatory period of 10,000 years after its closure. The use of PFLOTRAN has been proposed to enhance PA with more physically realistic flow and transport models in 3D. PFLOTRAN is a state-of-art massively parallel subsurface flow and reactive transport code. This paper introduces the progress of implementation of PFLOTRAN in the PA and the preliminary results for undisturbed repository conditions. (authors)
The nuclear waste attributes of near-term deployable SMRs were assessed using established nuclear waste metrics, which are the DU mass, SNF mass, volume, activity, decay heat, radiotoxicity, and decommissioning LLW volumes. Metrics normalized per unit electricity generation were compared to a reference large PWR. Three SMRs, VOYGR, Natrium, and Xe-100, were selected because they represent a range of reactor and fuel technologies and are active designs deployable by the decade’s end. The SMR nuclear waste attributes show both some similarities to the PWR and some significant differences caused by reactor-specific design features. The DU mass is equivalent to or slightly higher than the PWR. Back-end waste attributes for SNF disposition vary, but the differences have a limited impact on long-term repository isolation. SMR designs can vary significantly in SNF volume (and thus heat generation density). However, these differences are amenable to design optimization for handling, storage, transportation, and disposal technologies. Nuclear waste attributes from decommissioning vary depending on design and decommissioning technology choices. Given the analysis results in this study and assuming appropriate waste management system and operational optimization, there appear to be no major challenges to managing SMR nuclear wastes compared to the reference PWR.
This report documents the initial algorithm that could be used by the Waste Treatment and Immobilization Plant (WTP) in batching high-level waste (HLW) and glass-forming chemicals (GFCs) in the HLW melter feed preparation vessel (MFPV) (HFP-VSL-00001 and -00005). Not all Hanford tank waste can be accommodated by the models developed for this report and significant expansion of the model boundaries could be achievable to reduce the WTP mission life and total canister production count. The immobilized HLW (IHLW) must meet a series of constraints to be acceptable for disposal in the Monitored Geologic Repository, which are contained in the Specification 1 of the Contract (DOE 2000), the Waste Acceptance Product Specifications (WAPS, DOE 1996), and the Waste Acceptance System Requirements Document (WASRD, DOE 2007). The IHLW Waste Form Compliance Plan (WCP, 24590-HLW-PL-RT-07-0001, Rev 3) specifies that the formulation algorithm will be developed and used to comply with the constraints associated with glass composition and properties. This report is not an engineering calculation, does not provide design input, and is not an engineering study. Algorithm inputs include the chemical analyses of the blended HLW in the HLW blend vessel (HBV) (HLP-VSL-00028, the volume and composition of the MFPV heel, the volume and composition of the MFPV after waste addition, the volume and composition of MFPV batch after GFC addition, the compositions of individual GFCs, and the mass of glass in each canister. In addition to these inputs, uncertainties in the HLW composition and processing parameters are included in the algorithm. Using the above inputs, the algorithm calculates the following outputs: 1) the volume of HLW to be transferred from the HBV to the MFPV, 2) the mass of each GFC for addition to the MFPV, 3) the composition of the glass that will be produced along with uncertainties, and 4) the predicted properties, with associated uncertainties, of the resulting IHLW. The algorithm uses the property-composition models to calculate properties with associated uncertainties and compares them with various constraints to ensure that a processable feed is formulated and a compliant IHLW is produced. The GFC additions are determined using an optimization approach to provide high confidence that the HLW glass will meet all product quality requirements and key processing constraints. For most HLW batches there are many possible glass compositions that meet all constraints. In these cases, the glass composition is optimized for a series of target component concentrations and target property values. The algorithm also incorporates process measurement and product quality uncertainties, based on the work of Piepel et al. (2005). Estimates of the various process and measurement uncertainties that affect glass compositions and predicted glass properties have been previously reported (Piepel et al. 2005, 2006) and the impacts of these estimated uncertainties on the IHLW composition envelope that meets product quality and processing-related properties with sufficient confidence were evaluated. The details of work performed to date to develop this initial GFC addition and batching algorithm are summarized in Sections 4 and 5. An example data set is used to illustrate the calculations of the algorithm summarized in Section 6. Finally, in Section 7, there is a statement of the required work to achieve a final operational IHLW formulation control algorithm. This report is not an engineering calculation, does not provide design input, and is not an engineering study.
On Wednesday, February 5, 2014, an underground mine fire involving a salt haul truck occurred at the Waste Isolation Pilot Plant (WIPP). There were 86 workers in the mine when the fire occurred. All workers were evacuated. Nine days later, on Friday, February 14, 2014, there was an incident in the underground repository at WIPP which resulted in the release of americium and plutonium from one or more transuranic (TRU) waste containers into the environment. The release was detected by an underground continuous air monitor and then directed through high-efficiency particulate air (HEPA) filter banks located in the surface exhaust building. However, a measurable portion bypassed the HEPA filters via leakage through two ventilation system dampers and was discharged directly to the environment from an exhaust duct. No personnel were determined to have received external contamination; however, some individuals that were on site were identified through bioassay to have initially tested positive for low level amounts of internal contamination. Trace amounts of americium and plutonium were detected off-site.While significant to day-to-day operations, these events have no impact to the long-term performance of the repository. Because WIPP's re-certification is based solely on the post-closure performance of the repository (40 CFR 191, Subparts B and C), these recent events do not affect the long-term performance predictions or its technical and scientific basis. In this paper we will further explore the requirements for WIPP's re-certification, and the basis for our contention that the recent WIPP operational events do not impact long-term repository performance or have any implications on salt as a geologic disposal media, and that re-certification efforts should continue uninterrupted. (authors)
Bentonite-based engineered barrier system (EBS) is a key component of many repository designs for the geological disposal of high-level radioactive waste. Given the complexity and interaction of the phenomena affecting the barrier system, coupled thermo-hydro-mechanical (THM) numerical analyses are a potentially useful tool for a better understanding of their behaviour. In this context, a Task (the Horonobe EBS experiment) was undertaken to study, using numerical analyses, the thermo-hydro-mechanical (and thermo-hydro) interactions in bentonite based engineered barriers within the international cooperative project DECOVALEX 2023. One full-scale in-situ experiment and four laboratory experiments, largely complementary, were selected for modelling. The Horonobe EBS experiment is a temperature-controlled non-isothermal experiment combined with artificial groundwater injection. The Horonobe EBS experiment consists of the heating and cooling phases. Six research teams performed the THM or TH (depended on research team approach) numerical analyses using a variety of computer codes, formulations and constitutive laws. Finally, for each experiment, the basic features of the analyses are described and the comparison between calculations and laboratory experiments and field observations are presented and discussed.
In recent decades, interest in plutonium mobility has increased significantly due to the need of the United States, as well as other nations, to deal with commercial spent nuclear fuel, nuclear weapons disarmament, and the remediation of locations contaminated by nuclear weapons testing and production. Although there is a global consensus that geologic disposal is the safest existing approach to dealing with spent nuclear fuel and high-level nuclear waste, only a few nations are moving towards implementing a geologic repository due to technical and political barriers. Understanding the factors that affect the mobility of plutonium in the subsurface environment is critical to support the development of such repositories. The importance of redox chemistry in determining plutonium mobility cannot be understated. While Pu(IV) is generally assumed to be immobile in the subsurface environment due to sorption or precipitation, Pu(V) tends to be mobile due to its relatively low effective charge and weak complex formation. This review highlights one particularly important aspect of plutonium behaviour at the mineral–water interface—the concept of surface-mediated reduction, which describes the reduction of plutonium on a mineral surface. It provides a conceptual model for and evidence supporting or refuting each proposed mechanism for surface-mediated reduction including (i) radiolysis at the mineral surface, (ii) electron transfer via ferrous iron or manganese in the mineral structure, (iii) electron shuttling due to the semiconducting properties of the mineral, (iv) disproportionation of Pu(V), (v) facilitation by proton exchange sites, (vi) stabilisation of Pu(IV) due to the increased concentration gradient within the electrical double layer, and (vii) a Nernstian favourability of Pu(IV) surface complexes and colloids. It also provides new perspectives on future research directions.
U.S. knowledge in deep geologic disposal in crystalline rock is advanced and growing. U.S. status and recent advances related to crystalline rock are discussed throughout this report. Brief discussions of the history of U.S. disposal R&D and the accumulating U.S. waste inventory are presented in Sections 3.x.2 and 3.x.3. The U.S. repository concept for crystalline rock is presented in Section 3.x.4. In Chapters 4 and 5, relevant U.S. research related to site characterization and repository safety functions are discussed. U.S. capabilities for modelling fractured crystalline rock and performing probabilistic total system performance assessments are presented in Chapter 6.
[Poster] The U.S. Department of Energy (DOE) is responsible for managing spent nuclear fuel (SNF) currently in its possession, as well as SNF that will come into its possession in the future. DOE will rely upon the standardized canister to confine radionuclides and precluding the moderator in order to ensure safe, long-term management and disposition of SNF in its possession. This strategy helps minimize characterization costs (i.e., funds and exposure) and other technical challenges associated with the traditional approach of relying on fuel-specific properties to demonstrate compliance with the regulator. The use of the standardized canister offers the following benefits: • The standardized canister design is complete. It has been tested under a variety of drop and accident scenarios and was subsequently licensed under 10 CFR 72 as a storage system as part of the Foster Wheeler Environmental Corporation (FWENC) Facility. It is also part of the license submittal for Yucca Mountain. • There is high confidence that the standardized canister design can be stored within commercially-available storage casks and licensed as part of a transportation-system package. • A robust standardized canister simplifies accident analyses and does not rely on characterization of the contained waste. This simplifies safety analysis, provides a greater level of confidence with stakeholders and reduces cost and risk. • A common design for the associated packaging, closure, and loadout facilities results in significant savings. • The DOE standardized canister would simplify design efforts, procurement, and fabrication. • Standardizing handling activities and associated training, procedures, equipment, and tooling leads to enhanced safety and surety of operations. The standardized canister is the preferred package for these materials. It withstood scrutiny by the Yucca Mountain Repository License Application, the Nuclear Regulatory Commission’s (NRC) Advisory Committee on Nuclear Waste, the Nuclear Waste Technical Review Board, an American Society of Mechanical Engineers peer review, and the FWENC storage license application. This evaluation summarizes and documents the status of the design and rationale for the DOE standardized canister, and outlines remaining needs before deployment. In addition, it discusses the factors that have the potential to influence storage, transportation, and disposal of DOE SNF.
The U.S. Department of Energy (DOE) is responsible for managing spent nuclear fuel (SNF) currently in its possession, as well as SNF that will come into its possession in the future. DOE will rely upon the standardized canister to confine radionuclides and precluding the moderator in order to ensure safe, long-term management and disposition of SNF in its possession. This strategy helps minimize characterization costs (i.e., funds and exposure) and other technical challenges associated with the traditional approach of relying on fuel-specific properties to demonstrate compliance with the regulator. The use of the standardized canister offers the following benefits: - The standardized canister design is complete. It has been tested under a variety of drop and accident scenarios and was subsequently licensed under 10 CFR 72 as a storage system as part of the Foster Wheeler Environmental Corporation (FWENC) Facility. It is also part of the license submittal for Yucca Mountain. - There is high confidence that the standardized canister design can be stored within commercially-available storage casks and licensed as part of a transportation-system package. - A robust standardized canister simplifies accident analyses and does not rely on characterization of the contained waste. This simplifies safety analysis, provides a greater level of confidence with stakeholders and reduces cost and risk. - A common design for the associated packaging, closure, and loadout facilities results in significant savings. - The DOE standardized canister would simplify design efforts, procurement, and fabrication. - Standardizing handling activities and associated training, procedures, equipment, and tooling leads to enhanced safety and surety of operations. The standardized canister is the preferred package for these materials. It withstood scrutiny by the Yucca Mountain Repository License Application, the Nuclear Regulatory Commission's (NRC) Advisory Committee on Nuclear Waste, the Nuclear Waste Technical Review Board, an American Society of Mechanical Engineers peer review, and the FWENC storage license application. This evaluation summarizes and documents the status of the design and rationale for the DOE standardized canister, and outlines remaining needs before deployment. In addition, it discusses the factors that have the potential to influence storage, transportation, and disposal of DOE SNF. (authors)
Abstract. For the underground disposal of high-level nuclear waste in rock salt formations, the safety concept includes the backfilling of open cavities with crushed salt. For the prognosis of the sealing function of the backfill for the safe containment of the radioactive waste, it is crucial to have a comprehensive process understanding of the crushed-salt compaction behavior. The crushed-salt compaction process is influenced by internal properties (e.g., grain size, mineralogy, and moisture content) and boundary conditions (e.g., temperature, stress state, and compaction rate) and, therefore, involves several coupled thermal–hydro–mechanical (THM) processes (Hansen et al., 2014; Kröhn et al., 2017). With the paradigm shift from the limited release of radionuclides to safe containment due to the German Repository Site Selection Act passed in 2017, the importance of crushed salt as geotechnical barrier has increased, with a focus on the evolution of its hydraulic properties. Based on the knowledge gaps in the current process understanding, the “Compaction of crushed salt for safe containment” (KOMPASS) projects were initiated to improve the scientific basis behind using crushed salt for the long-term isolation of high-level nuclear waste within rock salt repositories. The efforts to improve the prediction of crushed-salt compaction begun during the first phase of the KOMPASS projects (Czaikowski et al., 2020) and were followed up in a second phase ending in June 2023. The primary achievements of the projects are as follows (Czaikowski et al., 2020; Friedenberg et al., 2022): specification of the KOMPASS reference material, an easily available and reproducible synthetic crushed-salt material, for generic investigations; development of pre-compaction methods and successful production of samples in the short term and under in situ loading conditions; formulation of an extended laboratory program addressing the isolated investigation of known relevant factors influencing the compaction behavior of crushed salt (Düsterloh et al., 2022); execution of long-term compaction tests addressing isotropic and deviatoric load changes, temperature, and compaction state; construction of a backfill body using the KOMPASS reference material in the Sondershausen mine through collaboration with the SAVER (Entwicklung eines salzgrusbasierten Versatzkonzepts unter der Option Rückholbarkeit) project (Schaarschmidt and Friedenberg, 2022); advancement of the tools for microstructure investigation methods (Svensson and Laurich, 2022); generation (first stages) of a microphysical process list combining literature research with our own findings; benchmarking of long-term compaction test for model development and optimization of various existing models as well as the development of new models; application of a virtual demonstrator (2D model representing a backfilled drift in rock salt) for the visualization of developments and the quantification of the models (Rabbel, 2022). In summary, the KOMPASS projects contributed to the reduction of uncertainties and the strengthening of the safety case for using crushed salt within rock salt repositories.
The U.S. Department of Energy (DOE) is responsible for managing spent nuclear fuel (SNF) that is currently in, or will in the future come into, its possession. DOE must continue to safely store that SNF, transport it to an interim storage site or a repository, and dispose of it. These fuels come from a wide range of reactor types, such as light- and heavy-water-moderated reactors, graphite-moderated reactors, and breeder reactors, with various cladding materials and enrichments. Many of these reactors, now decommissioned, had unique design features, such as core configuration, fuel element and assembly geometry, moderator and coolant materials, operational characteristics, and neutron spatial and spectral properties resulting in a large diversity of reactor and fuel designs. Because of the wide variety and condition of SNF, a robust canister termed the DOE Standardized SNF Canister was proposed that would confine radionuclides and preclude moderator. The DOE Standard SNF Canister had four variations consisting of a 10- or 15-foot length and an 18- or 24-inch diameter. For ultimate disposal in the Yucca Mountain Repository these canisters were to be grouped with 24-inch diameter HLW canisters in a codisposal waste package. The 18-inch DOE Standardized SNF Canister could be placed in the middle of five HLW canisters. The 24-inch DOE Standardized SNF Canister would take the place of one the five HLW canister on the outer ring in the codisposal waste package. No DOE Standardized SNF Canisters have been loaded, and many fuel types can be loaded in multiple canisters. Depending on the selected diameter of the DOE Standardized SNF Canister for a particular fuel, the number of potential codisposal waste packages could vary. In addition, different types of DOE SNF may be able to be combined in a single canister. This could significantly change the number of DOE SNF canisters that are loaded and result in a decrease of the number of total potential codisposal waste packages. Ultimately, if too many HLW canisters need disposition, then a reduction in the number of DOE Standardized SNF Canisters will change the final total of codisposal waste packages very little. Likewise, if the ratio of DOE Standardized SNF Canisters to HLW canister produced is too high, then DOE Standardized SNF Canisters will not have enough HLW canisters to surround them in the codisposal waste package. This paper examines the results of differing loading strategies for a few DOE SNFs. It also compares the ranges of DOE Standardized SNF Canisters that may be produced to the ranges of HLW canisters that may be produced in order to determine potential scenarios.
WOW presents its revolutionary technology and equipment for liquid radioactive waste treatment: outperforming ultimate water decontamination and purification process, enhanced sludge concentration, no secondary waste nor consumables, fully automated, remote controlled and self-decontaminating device. The WOW's technology is based upon a never before observed discovery of fluid dynamics science: the possibility of performing a molecular separation between solute and suspended elements and the solvent. The combination of such a molecular separation process with a standard vacuum evaporation improves the abatement performances by thousands of times, with respect to those of the state of the art vacuum evaporators. In addition to this, no secondary waste is produced during the process, as no filters, membranes, resins or additives are used. WOW equipment, automated and remote controlled, self decontaminates after use and can be designed and constructed either tailored to the application needs or with a modular approach for enhanced transportability and application flexibility. After the preliminary verification by CNR, the Italian National Research Center, WOW Technology's decontamination device was tested c/o LENA, the Laboratory of Applied Nuclear Energy of the University of Pavia, Italy with a simulated solution 6000 times more contaminated than the nuclear reactor's cooling water of Fukushima-Daiichi NPP. In addition to that, WOW's technology was also used in a real case at the Radiochemistry laboratory of the Pavia's University Chemistry department. Both the above mentioned contaminated fluids have been successfully decontaminated without production of additional or secondary waste. WOW's technology has already performed on industrial scale c/o the Nuclear Repository of S.S.M. in Saluggia, Italy: 45000 liters of acid radioactive solution have been successfully decontaminated to a Decontamination Factor (DF) of 335000 for Cs-137 by one single evaporation step and without using any additional tool to control steam. [Performances independently certified by: National Physics Laboratory (UK) and Pavia University Radiochemistry Laboratory, Chemistry Department (Italy)]. The high decontamination factors and the high volume reduction of the sludge make this technology suitable for the ultimate treatment of highly contaminated liquid waste such as the Fukushima-Daiichi nuclear reactor's cooling water. The WOW's technology addresses as well to interventions in both, operating and decommissioning nuclear power plants and any other nuclear and radioactive facility whose produced and/or stored radioactive liquid solutions, including acid liquid solutions, can be successfully treated, the waste volume reduced and no secondary waste produced. (authors)
Radioiodine capture and immobilization is not only important to consider during the operation of reactors (i.e., I-131), during nuclear accidents (i.e., I-131 and I-129) or nuclear fuel reprocessing (i.e., I-131 and I-129), but also during disposal of nuclear wastes (i.e., I-129). Most disposal plans for I-129-containing waste forms (including spent nuclear fuel) propose to store them in underground repositories. Here, iodine can be highly mobile and, given its radiotoxicity, needs to be carefully managed to minimize long-term environmental impacts arising from disposal. Typically, any process that has been used to capture iodine from reprocessing or in a reactor is not suitable for direct disposal, rather conversion into a wasteform for disposal is required. The objectives of these materials are to use either chemical immobilization or physical encapsulation to reduce the leaching of iodine by groundwaters. Some of the more recent ideas have been to design capture materials that better align with disposal concepts, making the industrial processing requirements easier. Research on iodine capture materials and wasteforms has been extensive. This review will act as both an update on the state of the research since the last time it was comprehensively summarized, and an evaluation of the industrial techniques required to create the proposed iodine wasteforms in terms of resulting material chemistry and applicability.
The goal of the Fifth Worldwide Review is to document evolution in the state-of-the-art of approaches for nuclear waste disposal in geological formations since the Fourth Worldwide Review that was released in 2006. The last ten years since the previous Worldwide Review has seen major developments in a number of nations throughout the world pursuing geological disposal programs, both in preparing and reviewing safety cases for the operational and long-term safety of proposed and operating repositories. The countries that are approaching implementation of geological disposal will increasingly focus on the feasibility of safely constructing and operating their repositories in short- and long terms on the basis existing regulations. The WWR-5 will also address a number of specific technical issues in safety case development along with the interplay among stakeholder concerns, technical feasibility, engineering design issues, and operational and post-closure safety. Preparation and publication of the Fifth Worldwide Review on nuclear waste disposal facilitates assessing the lessons learned and developing future cooperation between the countries. The Report provides scientific and technical experiences on preparing for and developing scientific and technical bases for nuclear waste disposal in deep geologic repositories in terms of requirements, societal expectations and the adequacy of cases for long-term repository safety. The Chapters include potential issues that may arise as repository programs mature, and identify techniques that demonstrate the safety cases and aid in promoting and gaining societal confidence. The report will also be used to exchange experience with other fields of industry and technology, in which concepts similar to the design and safety cases are applied, as well to facilitate the public perception and understanding of the safety of the disposal approaches relative to risks that may increase over long times frames in the absence of a successful implementation of final dispositioning.
The Department of Energy (DOE); Triad National Security, LLC (Triad); and Newport News Nuclear BWXT-Los Alamos, LLC (N3B) are holding training on the contents and use of the Los Alamos National Laboratory (LANL) Electronic Public Reading Rooms (EPRRs). The EPRR is an information repository for environmental and administrative information and correspondence required by Permit Section 1.10 of the LANL Hazardous Waste Facility Permit, issued November 2010. LANL Electronic Public Reading Room and the Los Alamos Legacy Cleanup Electronic Public Reading Room can be accessed at http://eprr.lanl.gov.
The Used Nuclear Fuel-Storage, Transportation & Disposal Analysis Resource and Data System (UNF-ST&DARDS) is a software tool that integrates a used nuclear fuel (UNF) or spent nuclear fuel (SNF) relational database and key analysis capabilities to simplify and automate numerous UNF management and fuel cycle–related activities. UNF-ST&DARDS is being developed for the US Department of Energy’s Office of Nuclear Energy Spent Fuel and Waste Disposition program. UNF-ST&DARDS provides an integrated framework that uses advanced modeling and simulation to predict the behavior of SNF over the timescales associated with permanent disposal in a geologic repository. After leaving the spent fuel pool, SNF is transferred to dry storage in a dual-purpose canister (DPC). DPCs are considered “dual purpose” because they are designed for both storage and transportation, removing the need to transfer the fuel to a separate transportation cask. However, much research has been conducted investigating the feasibility of directly disposing of DPCs in geologic repositories. Direct disposal of DPCs could reduce worker exposure during repackaging, reducing the amount of low-level waste from the discarded DPCs and potentially saving billions of dollars. Therefore, direct disposal of as-loaded DPCs is desirable if it can be done safely.