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Mechanistic Source Term Considerations for Advanced Non-LWRs

This report is a functional review of the radionuclide containment strategies of fluoride-salt-cooled high temperature reactor (FHR), molten salt reactor (IVISR) and high temperature gas reactor (HTGR) systems. This analysis serves as a starting point for further, more in-depth analyses geared towards identifying phenomenological gaps that still exist, preventing the creation of a mechanistic source term for these reactor types. As background information to this review, an overview of how a mechanistic source term is created and used for consequence assessment necessary for licensing is provided. How mechanistic source term is used within the LMP is also provided. Third, the characteristics of non-LWR mechanistic source terms are examined This report does not assess the viability of any software system for use with advanced reactor designs, but instead covers system function requirements. Future work within the Nuclear Energy Advanced Modeling and Simulations (NEAMS) program will address such gaps.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Engineered Barrier System R&D and International Collaborations – LANL (FY20): Spent Fuel and Waste Disposition

The United States Department of Energy’s Spent Fuel and Waste Disposition (SFWD) program is investigating the design and safety function of generic nuclear geologic repositories in a variety of geologic settings (salt, argillite, and crystalline rock). Different configurations and loadings of spent nuclear fuel and waste within disposal canisters are also being investigated, some of which have the potential to generate repository temperatures higher than previously considered (i.e., temperatures >100ºC) by foreign and domestic concepts. This report expands on engineered barrier material stability in a high temperature crystalline rock repository through high temperature hydrothermal experiments. Experiments were designed to develop engineered barrier system (EBS) concepts in a hightemperature crystalline environment in 1) bentonite-Grimsel Granodiorite interactions, 2) bentonite-cement reactions, and 3) interaction between waste canister materials and bentonite. Experiment results are applied to understanding long-term repository performance in terms of radionuclide isolation. One hydrothermal experiment was completed in the rocking autoclaves at LANL in FY-20: IEBS-6 (Grimsel Granodiorite + Wyoming bentonite + cured ordinary Portland cement + Grimsel Granodiorite synthetic groundwater, 250ºC/150 bar, 8 weeks). Several other experiments were planned but were delayed due to the COVID-19 pause in laboratory work. In addition, some characterization of the reaction products of experiments conducted in FY-20 was prevented by COVID-19. Mineral phase chemistry was not measured via electron microprobe analyses for IEBS-6. Quantitative X-ray diffraction results from IEBS-6 and HBT-1 were not completed. The missing analyses and discussion of the results will be included in next year’s report. New characterization that was completed includes scanning electron microscopy of reaction products from IEBS-6, quantitative X-ray diffraction results are presented from IEBS-1 through IBES-5, preliminary scanning electron microscope images and chemical analyses for IEBS-6, X-ray diffraction of the clay fraction from all experiments, measurement/imaging of mineral growth on the surface of steel coupons. Major observations pertaining to bentonite stability in a Grimsel Granodiorite environment include the stability of Na-montmorillonite at 250°C, the formation of trace CSH phases, and the formation of bentonite colloids on experiment cooling. The addition of a cured chip of Portland cement to the bentonite-Grimsel system results in slightly higher pH values and the formation of diverse secondary mineral phases that were not observed in the previous experiments (e.g., analcime, garronite, CSH phases). The new characterization efforts related to the interaction of stainless-steel coupons and bentonite clay focused on thickness and mineralogy of phases that formed at the steel surface. In Wyoming bentonite + Grimsel Granodiorite systems, newly formed minerals at the bentonitesteel coupon interface included alteration of the outermost steel edge to Fe,Cr-oxide phases, followed by Fe-rich phyllosilicates (Fe-saponite, chlorite) and interbedded Fe,Cr,Ni-sulfide phases (pentlandite). Hydrothermal experiments were completed to assess uranium-carbonate complexation at conditions relevant to high-temperature disposal. Autoclave solubility experiments were conducted at 150 to 250ºC with a range of carbonate and uranium concentrations. The experiment results were characterized via situ UV-Visible spectroscopy and synchrotron-based in situ XAS techniques. Results show a significant decrease in the stability of uranyl-carbonate complexes at temperatures above 100ºC along with the precipitation of uranium oxides. Further, at T > 200ºC, results show that uranyl-hydroxyl complexes control solubility of uranium instead of the previously predicted uranyl-carbonate species. These results are significant for understanding the mobility of uranium in the EBS, which will likely contain carbonate-rich fluids. International research efforts focused on three main areas: 1) participation in international conferences, 2) building collaborations with foreign repository programs, and 3) the initiation of an experimental program to complement the full-scale HotBENT test at the Grimsel test site. This experiment included Wyoming bentonite + low carbon steel + Grimsel Granodiorite synthetic groundwater and was run at the planned maximum temperature of the HotBENT test (200°C). Complete characterization of reaction products was hindered by disruptions to laboratory work but will be reported in the next FY. The experimental results obtained in FY-20 continue to document the wide-ranging effects of bulk composition and pressure-temperature conditions in the mineralogical and geochemical evolution of a high-temperature repository environment. Concepts developed will be used to inform models of long-term material stability in a generic crystalline rock-hosted repository.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Crystalline Disposal R&D at LBNL: FY20 Progress Report

Within the Spent Fuel & Waste Science and Technology (SFWST) Program, research work continues further with the goal to better understand long-term performance of disposal systems in three main geologic rock types: clay/shale, salt, and crystalline rock. This report documents LBNL’s research activities related to investigations of crystalline host rock according to the scope of two work packages: SF-20LB01030207 “Crystalline International Collaborations – LBNL,” and SF-20LB01030203 “Crystalline Disposal R&D – LBNL.” These research activities correspond are related to key Features, Events, and Processes (FEPs), ranked in importance from medium to high, as listed in Table 7 of the Used Fuel Disposition Campaign Disposal Research and Development Roadmap (FCR&D-USED-2011-000065 REV0) (Nutt, 2011). Specifically, these research activities address FEP 2.2.01, Excavation Disturbed Zone (EZD). The results of these research activities provide important insights into understanding and predicting flow and transport processes that could occur in low-permeability crystalline rocks, in which fractures might serve as main conduits for fluid flow and radionuclide transport. The evolution of the EDZ during the excavation of the tunnel as well as the evolution of microcrack growth within the EDZ after the emplacement of backfill are critical for predicting the long- term behavior of the EDZ. A number of factors including stress, temperature, water activity, capillary pressure, chemistry, and mineralogy can affect the rock evolution, which require advanced experimental tools to study it.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Engineered Barrier System Research Activities at LBNL (FY2020 Progress Report)

The design of a radioactive waste repository typically involves a multi-barrier system, including the natural barrier system (NBS), i.e., the host rock and its surrounding subsurface environment, and an engineered barrier system (EBS). The EBS is to be constructed from the man-made, engineered materials placed within a repository. The repository includes the waste form, waste canisters, buffer materials, backfill, and seals. The most common buffer material for EBS is compacted bentonite, which features low permeability and high retardation of radionuclides. Extensive studies concerning the behavior of bentonite backfill in crystalline and argillite/shale geologic environments for nuclear waste disposal have been conducted by means of laboratory experiments, numerical modeling, and large-scale in situ tests in Underground Research Laboratories (URLs) in Switzerland, France, Belgium, and Japan. This report includes the results of LBNL’s research activities conducted according to the objectives and scope of the work packages “SF-20LB01030802 Engineered Barrier System R&D - LBNL” and “SF-20LB01030806 Engineered Barrier System International Collaborations - LBNL” of the Spent Fuel and Waste Science and Technology (SFWST) (formerly called Used Fuel Disposal) Campaign of the Department of Energy’s (DOE) Office of Nuclear Energy. LBNL research studies included laboratory scale tests and modeling of the evolution of the EBS bentonite and associated coupled processes, and impacts of high temperature on parameters and processes relevant to the performance of crystalline and argillite repositories, including the evaluation of the technical basis for applying the maximum allowable temperature. The results of these studies are being addressing the technical elements necessary to evaluate the EBS design concepts. Emphasis is on the study of thermal, mechanical, and chemical processes that influence the performance of EBS, and the development of modeling capability for reliable assessment of these processes, and ultimately supporting the development of the GDSA model with detailed coupled THMC process models.

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Goldsim Modeling of Vadose Zone Transport for E-Area Naval Reactor Component Disposal Areas: Model Description and Benchmarking

This report documents the development of a GoldSim® model of flow and radionuclide transport to the water table through the Naval Reactor Components Disposal Area (NRCDA) waste disposal sites and underlying vadose zones. The model is designed to be used for Monte Carlo uncertainty analysis in support of the E-Area Performance Assessment (PA). This report describes the model and shows results obtained from benchmarking the model to best-estimate deterministic results obtained using a PORFLOW model of NRCDA vadose zone transport. The PORFLOW model is three-dimensional while the GoldSim model is a simplified one-dimensional treatment. Nevertheless, the GoldSim model was able to accurately reproduce PORFLOW results with some adjustment to the nominal dispersion coefficient and vadose zone flow area used as “tuning” parameters. An example of the results obtained comparing GoldSim and PORFLOW calculation of releases of I-129, Tc-99, C-14 and Ni-59 from waste disposal containers at the 643-26E site is shown in Figure 1 below. For all of the test cases evaluated, GoldSim predicted peak concentrations within 6% of the PORFLOW values and peak times agreed within 8% with the majority of the results in better agreement. The close agreement between the two models provides confidence that GoldSim will give results accurately reflecting the behavior of releases from the NRCDA under off-normal operating conditions for sensitivity and uncertainty analysis

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Composite Analysis Solid Waste Release Data Reduction of Activity Flux from Waste Sites to the Vadose Zone for Baseline Assessment

This environmental calculation file (ECF) describes the data reduction methodology for the solid waste release datasets generated by the Composite Analysis Solid Waste Release (CASWR) model (CP-62766, Model Package Report: Composite Analysis Solid Waste Release Model [CASWR Model]) and documents the resulting reduced datasets for the updated Composite Analysis (CA) baseline assessment. This ECF is in support of the updated Hanford Site CA. The purpose of the updated Hanford Site CA is to provide an estimate of the cumulative radiological impacts from active and planned low-level radioactive waste disposals and other potentially interacting radioactive waste disposal sources that will remain following Hanford Site closure. The vadose zone modeling activities associated with the CA includes solid waste forms as contaminant sources. To support the modeling of solid waste transport from the vadose zone to the groundwater at the Hanford Site, the CASWR model was designed to generate deterministic radionuclide release rates for the Hanford Site Central Plateau solid waste disposal sites. The complete CASWR model-generated dataset for the CA Baseline Assessment consists of 2,378,831 sets of time and release rates (1,073,869 sets for the 200 East Area and 1,304,962 sets for the 200 West Area), representing a course of the simulation from year 1953 to year 12,069, 16 radiological contaminants of potential concern (COPCs), and 237 solid waste sources as documented in ECFHANFORD- 19-0112, Solid Waste Release Calculations for the Composite Analysis Baseline Assessment. For several of the STOMP vadose zone models, the number of release rate data pairs required for release at all waste sites would exceed the limitations imposed by the STOMP modelling software package used to simulate contaminant transport through the vadose zone. As a result, a data reduction of the CASWR dataset is required prior to its use as a source input for the CA vadose zone modeling activities.

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Comparison of Extended and Accelerated VOG Tests

The reprocessing of used nuclear fuel would release volatile radionuclides into the off-gas streams of a processing plant, including ¹²⁹I. The dissolver off-gas and more dilute vessel off-gas streams (VOG) must both be targeted when mitigating ¹²⁹I environmental release because each contains some amount of iodine. Iodine-129 will likely be found as elemental iodine (I₂) and methyl iodide (CH₃I) in these off-gas streams. Reduced silver-exchanged mordenite (AgZ or Ag⁰Z) has been investigated as a potential sorbent for iodine abatement and is studied here under prototypic VOG conditions. Because of the relatively low iodine abundance and high flow rates of the VOG, total iodine concentrations are expected to be in the parts per billion range. Thus, VOG experiments need to run for extended durations at low concentrations to reach sorbent saturation. Because the sorbent will be exposed to oxidizing gas streams for extended periods of time, aging effects and sorbent degradation need to be considered when designing a sorbent-based abatement system. Three sets of experiments were performed with the aim of determining how the adsorption of iodine by AgZ is affected by differing test durations and gas compositions. The first tested the capacity of sorbent aged for 8 months under a humid air stream. The second tested differences in sorbent capacity and mass transfer zone (MTZ) length during high-concentration (1200 ppb v ) CH₃I loading in a humid nitrogen gas (N₂) stream and a humid air gas stream over 28 days. The third tested sorbent capacity and MTZ length during low concentration (< 200 ppb v ) CH₃I and I₂ loading in a humid air stream over 9 months. The results of these tests suggest that AgZ capacity drops by ~50% after 1 month of aging, by ~60% after 2 months of aging, and then does not continue to decrease significantly at up to 8 months of aging. One-month aging tests that compared N₂ and air as the gas stream diluent resulted in similar maximum loading capacities and overall loading curves, indicating that the effects of aging cannot be mitigated by avoiding air as the balance gas. The 9-month extended VOG tests did not result in clear sorbent saturation at the inlet, but it can be inferred using an assumption of a maximum capacity of 45 mg I/g AgZ. Applying this assumption, then the MTZ of CH₃I is 12.8 cm, and the MTZ of I₂ is 12.4 cm. These results are similar to previous tests. Comparisons to tests completed at Idaho National Laboratory suggest that the CH₃I MTZ may be dependent on concentration. Future work should re-evaluate the design of the VOG iodine capture system with this updated data and should seek to understand fundamental characteristics of CH₃I adsorption by AgZ, such as the effect of concentration, gas velocity, and gas composition.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Summary of Analytical Results from Samples Supporting Tank Closure Cesium Removal (TCCR) Batch 3 and Modeling Results for Cs Loading on CST

Savannah River Remediation (SRR) is currently operating the Tank Closure Cesium Removal (TCCR) process to remove 137 Cs from tank waste supernate using an ion exchange process. As part of that process, Savannah River National Laboratory (SRNL) receives and analyzes samples in support of the qualification of each batch to be processed. SRNL recently received supernate samples retrieved from Tank 10H as well as in-tank batch contact samples for characterization in support of qualifying Batch 3 for processing through the TCCR unit. Some results from analysis of those samples have been previously reported. This report documents the remaining analyses of the in-tank batch contact samples as well as the results of ZAM (Zheng, Anthony, Miller) isotherm modeling performed for comparison to the measured results. Results of the additional analyses include analysis of the loading of other radionuclides besides 137 Cs on the crystalline silicotitanate (CST) contained within the in-tank batch contact test samples. Results from those analyses revealed the next highest contributor to the activity on the CST was 90 Sr with an average loading of 2.76E+08 dpm/g CST compared to 3.56E+10 dpm/g CST for the 137Cs. Isotopes of plutonium were also detected on the samples. ZAM modeling was performed using the measured composition of the Tank 10H Batch 3 qualification samples. The modeling predicted a maximum Cs loading approximately 2.2x higher than the measured result. This is a slightly lower ratio (expected/measured) compared to what was observed for the prior TCCR in-tank batch contact testing performed for Batches 1A and 2 where the ZAM results were 2.7-2.8x higher than the measured values.

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AniMACCS User Guide

AniMACCS is a utility code in the MELCOR Accident Consequence Code System (MACCS) software suite that allows for certain MACCS output information to be visually displayed and overlaid onto a geospatial map background. AniMACCS was developed by Sandia National Laboratories for the U.S. Nuclear Regulatory Commission. MACCS is designed to calculate health and economic consequences following a release of radioactive material in the atmosphere. MACCS accomplishes this by modeling the atmospheric dispersion, deposition, and consequences of the release, which depend on several factors including the source term, weather, population, economic, and land-use characteristics of the impacted geographical area. From these inputs, MACCS determines the characteristics of the plume, as well as ground and air concentrations as a function of time and radionuclide.

63 RADIATION, THERMAL, AND OTHER ENVIRON. POLLUTAN↗

Argonne National Laboratory Site Environmental Report (CY2019)

This report discusses the status and the accomplishments of the environmental protection program at Argonne National Laboratory for calendar year 2019. The status of Argonne environmental protection activities with respect to compliance with the various laws and regulations is discussed, along with environmental management, sustainability efforts, environmental corrective actions, and habitat restoration. To evaluate the effects of Argonne operations on the environment, samples of environmental media collected on the site, at the site boundary, and off the Argonne site were analyzed and compared with applicable guidelines and standards. A variety of radionuclides were measured in air, surface water, groundwater, and bottom sediment samples. In addition, chemical constituents in surface water, groundwater, and wastewater were analyzed. External penetrating radiation doses were measured, and the potential for radiation exposure to off-site population groups was estimated. Results are interpreted with respect to the origin of the radioactive and chemical substances (i.e., natural, Argonne, and other) and are compared with applicable standards intended to protect human health and the environment. A U.S. Department of Energy (DOE) dose calculation methodology, based on International Commission on Radiological Protection (ICRP) recommendations and the U.S. Environmental Protection Agency’s (EPA) CAP-88 Version 4 computer code, was used in preparing this report.

54 ENVIRONMENTAL SCIENCES↗

Predictive Flow Simulation with the P2R Model for the Composite Analysis Base Case

In order to meet the requirements of U.S. Department of Energy (DOE) in DOE O 435.1 Chg. 1, Radioactive Waste Management, a Composite Analysis (CA) must be completed for the Central Plateau at the Hanford Site. The CA requires estimates of fate and transport of radionuclides in the groundwater from multiple sources within the modeling domain. This document details the application of the P2R Model version 8.3 to predict the flow of groundwater on the Central Plateau for the 10,000-year simulation to support the CA. The simulated flow field will support the simulation of fate and transport of contaminants for use in predicting dose as part of the CA.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Predictive Flow Simulation with the P2R Model for the Composite Analysis Base Case

In order to meet the requirements of U.S. Department of Energy (DOE) in DOE O 435.1 Chg.1, Radioactive Waste Management, a Composite Analysis (CA) must be completed for the Central Plateau at the Hanford Site. The CA requires estimates of fate and transport of radionuclides in the groundwater from multiple sources within the modeling domain. This document details the application of the P2R Model version 8.3 to predict the flow of groundwater on the Central Plateau for the 10,000-year simulation to support the CA. The simulated flow field will support the simulation of fate and transport of contaminants for use in predicting dose as part of the CA.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Total Residual Radiation Source Term Produced by the Hiroshima Detonation

Residual radiation from a nuclear detonation consists of fission products and activation products produced by the excess neutrons released during the explosion. The ability to accurately predict nuclear fallout begins with a calculation of the residual radiation source term. The intent of this paper is to define the residual radiation source term for the Hiroshima detonation. The calculation was performed using the Livermore Weapon Activation Code (LWAC), which is a simplified three-region model that estimates the residual radiation associated with the fission products, the unburnt fuel, and activation products produced in the weapon components, the surrounding air, and the ground in the vicinity of ground zero. For the Hiroshima detonation, ~1200 radionuclides were produced. A time-dependent solution for the total activity of each of the major residual radiation source terms is provided in the Appendices. In addition, the timedependent exposure rates produced by the activation rings are included in the report.

45 MILITARY TECHNOLOGY, WEAPONRY, AND NATIONAL DEF↗

Machine Learning in Environmental Chemistry: Application to Surface Complexation Modeling

Environmental chemistry – or biogeochemistry – is the scientific discipline typically invoked when examining and quantifying groundwater or surface water contamination, and nutrient cycling in the environment. Over the last three decades, there have been significant advances in mechanistic model development to describe and predict these complex biogeochemical processes. In particular, surface complexation models (SCMs) have been developed to describe the rock/soil surface reactions of metals and radionuclides, and their partitioning between various mobile species in the aqueous phase or immobile species sorbed on solid surfaces. Often represented by a simplified linear isotherm constant – Kd – in reactive transport models, these reactions play a critical role in many environmental science applications; particularly in contamination risk assessments and nuclear waste disposal performance assessments. In the past several decades, efforts by various institutions across the world have focused on developing SCMs based on datasets from laboratory measurements, including the identification of key parameters such as equilibrium constants.

54 ENVIRONMENTAL SCIENCES↗

Component-In-Grout Model Implementation for the E-Area Low-Level Waste Facility's Performance Assessment

The component-in-grout (CIG) disposal units are below grade earthen trenches that contain grout encapsulated waste components. Components disposed of within the CIG segments consist of large radioactively contaminated equipment and smaller waste forms (e.g., B-25 boxes and SeaLand containers) to fill the space around and above the large equipment. In the 2022 revision of the E-Area Low-Level Waste Facility’s (ELLWF) performance assessment, groundwater radionuclide contaminant transport through the vadose zone will be modeled using the PORFLOW software package for nine existing CIG segments located within the Slit Trench (ST) 23 footprint - no additional CIG segments are planned for at this time. The nine CIG segments have been placed within two of the nominally 20-foot-wide by 656-foot-long ST segments and are surrounded by no less than 1 foot of grout on all sides and up to 4 feet of backfill material. The two most recently placed CIG segments have an additional reinforced concrete mat to improve structural stability.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Evaluation of a Combined Raffinate Waste Stream for Mo-99 Production

Niowave, Inc., based in Lansing, Michigan, intends to produce Mo-99 from the fission of low enriched uranium (LEU) targets. In FY20, SRNL was tasked to provide technical assistance in identifying the primary waste raffinate present in Niowave’s commercial scale system and evaluating methods for disposal. Due to limited information on Niowave’s complete flowsheet and isotope recovery plans, a combined raffinate stream including the entire radionuclide inventory from the irradiated fuel was used for this evaluation. Results of the evaluation indicated the majority of the waste generated can be expected to be Class A; however radioisotopes such as Pu-239, Cs-137, Sr-90, and some of the shorter lived (< 5 year half-life) may challenge Niowave’s ability to meet the waste acceptance criteria for land burial. With appropriate waste management strategies, it is probable that Niowave’s waste could meet Class C requirements for all constituents, with the possible exception of Pu-239. More detailed information of Niowave’s processes are needed to form a more accurate understanding required to execute and effective, economic, and feasible waste management strategy.

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Risk Informed, Performance-Based, Technology-Inclusive Regulatory Infrastructure: Technology-Inclusive Determination of Mechanistic Source Terms for Offsite Dose-Related Assessments for Advanced Nuclear Reactor Facilities

This report summarizes a risk informed, performance-based and technology-inclusive approach to determine source terms for dose related assessments at advanced nuclear facilities. This approach uses a graded process which allows both the non-mechanistic source terms calculation methods, which adopt conservative approaches and assumptions based on known physical and chemical principles, and more importantly the mechanistic source term calculation methods, which consider design-specific scenarios and use best estimate models with uncertainty quantification for a range of licensing basis events (LBEs), to be used for the design and licensing of advanced nuclear technologies. The source terms developed with this graded approach, and radionuclide inventories elsewhere in the facility that are determined during source term analysis, can be used to address licensing issues to support the application processes of 10 CFR Part 50 for a construction permit and operating license or 10 CFR Part 52 for a Combined Operating License (COL), Standard Design Certification, Early Site Permit, Standard Design Approval or Manufacturing License. They can also be used for other purposes including equipment environmental qualification, control room habitability analyses, and assessments of severe accident risks in environmental impact statements. There are many advanced reactor concepts being developed including high temperature gas-cooled reactor (HGTR), sodium-cooled fast reactor (SFR), lead-cooled fast reactor (LFR), molten salt reactor (MSR), micro-reactor, etc. The graded approach presented in this report for source terms determination is, to the extent possible, generic to any of these reactor designs and to future reactor designs. This report provides information on the review of the regulatory foundation for use of conservative bounding source terms as well as event-specific mechanistic source terms for advanced nuclear reactor designs.

07 ISOTOPE AND RADIATION SOURCES↗

2020 NEPA Polychlorinated Biphenyl (PCB) Risk Assessment

The Waste Isolation Pilot Plant (WIPP) facility is a U.S. Department of Energy (DOE) operating repository 654 m below the surface in a thick salt formation in southeastern New Mexico. The DOE disposes transuranic (TRU) waste produced from atomic energy defense activities at the WIPP facility. A portion of the waste shipped to the WIPP facility contains TRU radionuclides co-mingled with polychlorinated biphenyls (PCBs), which fall under U.S. Environmental Protection Agency (EPA) regulations implementing the Toxic Substances Control Act (TSCA). This report documents the risks of PCBs co-mingled with TRU waste (hereafter designated as PCB/TRU waste) designated for disposal at the WIPP facility. This analysis is input to the National Environmental Policy Act (NEPA) assessment by the DOE Carlsbad Field Office (CBFO) for the proposed increase of the WIPP facility disposal area to include additional waste panels (but not to increase the legislated WIPP volume). This analysis is not a compliance calculation to support a certification renewal nor does it support a planned change request (PCR) or planned change notice (PCN) to be submitted to the EPA.

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