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E- Area Low-Level Waste Facility Multitiered Groundwater and Intruder Radionuclide Screening

Solid Waste Management (SWM) operates the E- Area Low-Level Waste Facility (ELLWF) where low level on-site and off-site solid waste streams are buried. The facility has been in operation since late 1994 and is currently projected to remain in operation until 2065. This facility can accommodate a broad range of waste forms resulting from the six different types of disposal unit (DU) options (i.e., varying degrees of engineered barriers → trenches to concrete vaults). This facility is currently operating under a Performance Assessment (PA)issued back in 2008, along with several subsequent supporting Special Analyses (SA).

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E-Area Low-Level Waste Facility Multitiered Groundwater and Intruder Radionuclide Screening

Solid Waste Management (SWM) operates the E-Area Low-Level Waste Facility (ELLWF) where low level on-site and off-site solid waste streams are buried. The facility has been in operation since late 1994 and is currently projected to remain in operation until 2065. This facility can accommodate a broad range of waste forms resulting from the six different types of disposal unit (DU) options (i.e., varying degrees of engineered barriers → trenches to concrete vaults). This facility is currently operating under a Performance Assessment (PA) issued back in 2008 (WSRC 2008), along with several subsequent supporting Special Analyses (SAs). The Savannah River National Laboratory (SRNL) developed the prior PAs and SAs and was tasked to update the facility’s upcoming PA, most likely to be issued during FY2023. For operating the E-Area facility, a Consolidated Waste Tracking System (CWTS) is actively employed by waste generators where every radionuclide entering the facility, to be buried in one of its many DUs1, must be either directly or indirectly tracked. Since there are many radionuclides in existence (>3,000), the International Commission on Radiological Protection (ICRP), specially ICRP Publication 107, has provided guidance on the subset of radionuclides requiring further assessment in landfills such as the ELLWF. The ICRP 107 publication provides critical radiological information on 1,252 radionuclides consisting of 97 elements. This database, along with the current dose coefficients that have been developed for these radionuclides in DOE-STD-1196-2011 (DOE 2011), is the critical starting point for developing a consistent inventory limit system.

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FY2020 performance assessment annual review for the E-area low-level waste facility

The Savannah River Site (SRS) E-Area Low-Level Waste Facility (ELLWF) consists of six types of disposal units described in the Performance Assessment (PA) (WSRC, 2008): Low Activity Waste Vault (LAWV), Intermediate Level Vault (ILV), Trenches [Slit Trenches (STs), Engineered Trenches (ETs), and Component-in-Grout (CIG) Trenches], and Naval Reactor Component Disposal Areas (NRCDAs). The ELLWF is a part of the Solid Waste Management Facility (SWMF). SWMF is managed and operated by the SRS Management and Operations prime contractor, Savannah River Nuclear Solutions (SRNS). Within SRNS, the Solid Waste Management (SWM) organization is responsible for operating the SWMF, and the Savannah River National Laboratory (SRNL) is the technical agency responsible for preparing and maintaining the PA. SWMF operations have been performed at SRS since 1952. The mission of the SWMF is to provide storage, processing, disposal, and shipment of radioactive, hazardous, and mixed waste. The SWMF is committed to treat, store, and dispose of these waste products in a manner that protects the environment and the health and safety of the facility worker, the co-located worker, and the offsite general public. Wastes handled in the SWMF include low level waste, transuranic waste, hazardous waste, Toxic Substances Control Act waste, and mixed waste (containing both hazardous and radioactive constituents). The FY2020 PA Annual Review for the ELLWF affirms that the disposal facility continued to operate within the bounds of the current PA and Composite Analysis (CA) baseline and the subsequent SA’s and satisfied all the requirements, conditions, and limitations identified in the 2008 DAS (DOE 2008a), RWMB SRNL_STI-2020-00588 Revision 0 vi (McGill, 2020), and ELLWF Low-Level Waste Acceptance Criteria (SRS-1S, 2014). This annual review affirms that the supporting studies performed in FY2020 do not alter the conclusions of the ELLWF PA (WSRC, 2008) and that there is a reasonable expectation that the ELLWF will meet the performance objectives delineated in DOE Manual 435.1-1 (DOE 2011)

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FY2019 Performance Assessment Annual Review for the E-Area Low-Level Waste Facility

The Savannah River Site (SRS) E-Area Low-Level Waste Facility (ELLWF) consists of six types of disposal units described in the Performance Assessment (PA) (WSRC, 2008): Low Activity Waste Vault (LAWV), Intermediate Level Vault (ILV), Trenches [Slit Trenches (STs), Engineered Trenches (ETs), and Component-in-Grout (CIG) Trenches], and Naval Reactor Component Disposal Areas (NRCDAs). The ELLWF is a part of the Solid Waste Management Facility (SWMF). SWMF is managed and operated by the SRS Management and Operations prime contractor, Savannah River Nuclear Solutions (SRNS). Within SRNS, the Solid Waste Management (SWM) organization is responsible for operating the SWMF, and the Savannah River National Laboratory (SRNL) is the technical agency responsible for preparing and maintaining the PA. SWMF operations have been performed at SRS since 1952. The mission of the SWMF is to provide storage, processing, disposal, and shipment of radioactive, hazardous, and mixed waste. The SWMF is committed to treat, store, and dispose of these waste products in a manner that protects the environment and the health and safety of the facility worker, the co-located worker, and the offsite general public. Wastes handled in the SWMF include low level waste, transuranic waste, hazardous waste, Toxic Substances Control Act waste, and mixed waste (containing both hazardous and radioactive constituents).

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FY2019 Performance Assessment Annual Review for the E-Area Low-Level Waste Facility

The Savannah River Site (SRS) E-Area Low-Level Waste Facility (ELLWF) consists of six types of disposal units described in the Performance Assessment (PA) (WSRC, 2008): Low Activity Waste Vault (LAWV), Intermediate Level Vault (ILV), Trenches [Slit Trenches (STs), Engineered Trenches (ETs), and Component-in-Grout (CIG) Trenches], and Naval Reactor Component Disposal Areas (NRCDAs). The ELLWF is a part of the Solid Waste Management Facility (SWMF). SWMF is managed and operated by the SRS Management and Operations prime contractor, Savannah River Nuclear Solutions (SRNS). Within SRNS, the Solid Waste Management (SWM) organization is responsible for operating the SWMF, and the Savannah River National Laboratory (SRNL) is the technical agency responsible for preparing and maintaining the PA. SWMF operations have been performed at SRS since 1952. The mission of the SWMF is to provide storage, processing, disposal, and shipment of radioactive, hazardous, and mixed waste. The SWMF is committed to treat, store, and dispose of these waste products in a manner that protects the environment and the health and safety of the facility worker, the co-located worker, and the offsite general public. Wastes handled in the SWMF include low level waste, transuranic waste, hazardous waste, Toxic Substances Control Act waste, and mixed waste (containing both hazardous and radioactive constituents).

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Air Pathway Dose Modeling for the E-Area Low-Level Waste Facility

Dose-release factors (DRFs) were calculated for potential atmospheric releases of several radionuclides from the E-Area Low-Level Waste Facility (ELLWF). The ELLWF receives solid low-level radioactive waste from across the Savannah River Site (SRS) and offsite for disposal. These factors represent the maximum dose a receptor would receive if standing at either 100 m or 11,410 m (Site Boundary) from the edge of an ELLWF disposal unit which are points of assessment (POA) for Department of Energy (DOE) Order 435.1 performance assessments (PA). The DRFs were calculated for 1 Ci of the specified radionuclide being released from the ground surface to the atmosphere (mrem per curie released). The calculation conservatively represented the ELLWF as a point source, and conservatively assumed the receptor was positioned at the center of the contaminant plume and continuously exposed for a period of one year. These DRFs can be refined to take into consideration disposal unit size, proximity and timing of peak dose to establish less conservative radionuclide specific disposal limits. DRFs were calculated for H-3 and C-14 in Revision 0 of this report. H-3 as HTO and C-14 as CO 2 were identified as volatile radionuclides of potential concern in earlier radionuclide screening studies. In Revision 1, DRFs were calculated for eight additional radionuclides identified by an updated screening analysis as potentially important volatile radionuclides. These include Ar-37, Ar-39, Ar-42, Hg-194, Hg- 203, Kr-81, Kr-85, and Xe-127.

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E-Area Low-Level Waste Facility GoldSim System Model

This report documents the development of the E-Area Low-Level Waste Facility (ELLWF) trench system model. The GoldSim® Monte Carlo simulation software is utilized to model the release and transport of radiological inventory disposed (both currently and in the future) within Engineered and Slit Trenches. This model is in support of the sensitivity and uncertainty analysis for the ELLWF Performance Assessment. The ELLWF system model utilizes a hybrid-approach to accurately describe the disposal system. The Hydrologic Evaluation of Landfill Performance model provides the infiltration data to both PORFLOW and GoldSim. PORFLOW is used to calibrate the GoldSim model to ensure confidence in the stochastic results. Finally, the concentrations from GoldSim transport simulations are fed into the SRNL Dose Toolkit to calculate dose impacts and assess plume interaction

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Selection of Well Locations for Saturated Zone Monitoring at the E-Area Low Level Waste Facility

Savannah River Site (SRS) has adopted a revised approach to performance monitoring of the E- Area Low Level Waste Facility (ELLWF) that adds a saturated zone component to the existing vadose zone monitoring program (Kubilius, 2019). The revised monitoring approach specifies that eight additional water table wells be installed near Slit Trench 1 (ST1) and Engineered Trench 2 (ET2). Six wells will be installed at locations characterized in 2017 and 2018. These include four wells near ET2 (ELF001D, ELF002D, ELF003D, and ELF004D) at locations identified by Kubilius (2019) and two wells north of ST1 (ELF005D and ELF006D) at locations finalized in this report. Additionally, two wells (ELF007D and ELF008D) are to be installed at locations south of ST1 based on characterization work completed in 2020 and documented in this report. This area is near well cluster BGX-2 between the Mixed Waste Management Facility (MWMF) and the ELLWF. The area is upgradient of ELLWF and, contamination in the water table aquifer is sourced from MWMF.

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E-Area Low-Level Waste Facility Inadvertent Human Intruder Limits and Doses in Support of the PA2022

This report documents the inadvertent human intruder (IHI) analysis for the E-Area Low-Level Waste Facility (ELLWF) at the Savannah River Site (SRS), near Aiken, South Carolina. This analysis supports the 2022 Performance Assessment for ELLWF, complying with the Department of Energy standard for operation of low-level waste disposal facilities (USDOE, 2017). The ELLWF is an operating waste disposal facility and is scheduled to continue accepting waste to 2065. One task of the 2022 Performance Assessment (PA) is to establish waste inventory limits for the various disposal units at ELLWF. This is done by modeling future contaminant release and transport through applicable pathways to human receptors, comparing predicted doses per disposed curie with applicable performance measures, to obtain inventory limits which will assure that doses to receptors do not exceed performance measures.

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E-Area Low-Level Waste Facility Inadvertent Human Intruder Limits and Doses in Support of the PA2022

This report documents the inadvertent human intruder (IHI) analysis for the E-Area Low-Level Waste Facility (ELLWF) at the Savannah River Site (SRS), near Aiken, South Carolina. This analysis supports the revised ELLWF Performance Assessment (PA), complying with the Department of Energy standard for operation of low-level waste disposal facilities (USDOE, 2017). The ELLWF is an operating waste disposal facility and is scheduled to continue accepting waste to 2065. One task of the revised PA is to establish waste inventory limits for the various disposal units at ELLWF. This is done by modeling future contaminant release and transport through applicable pathways to human receptors, comparing predicted doses per disposed curie with applicable performance measures, to obtain inventory limits which will assure that doses to receptors do not exceed performance measures. This report documents results of modeling future doses to one class of receptor, the inadvertent human intruder. It is assumed that after site closure, public knowledge of the site is lost, and IHIs will engage in activities on the ELLWF that will disrupt the closure cap, causing dose to the IHI. Following USDOE (2017), six different stylized exposure scenarios are considered, simulating activities by an IHI which could result in a radiological dose. The six scenarios are: • Acute – Basement Construction: IHI constructs a basement and encounters waste during excavation which is inadvertently mixed with clean soil and diluted. • Acute – Well Drilling: IHI drills a water well through waste and is exposed to drill cuttings mixed with clean soil that are brought to the surface. • Acute – Discovery: IHI begins constructing a basement but stops when encountering the riprap in the final closure cap and is exposed to photon radiation from unexcavated material residing in the undisturbed waste zone. • Chronic – Agriculture: Resident IHI is exposed to waste that was excavated for basement construction and mixed with native soil in the intruder’s vegetable garden. • Chronic – Post-Drilling: Resident IHI is exposed to waste from drill cuttings mixed with native soil and scattered in the garden area. • Chronic – Residential: Resident IHI is exposed to external radiation while in home located above waste with shielding provided by the concrete basement floor and any soil or engineered material remaining between the basement and waste. Dose calculations are performed using the SRNL Dose Toolkit (Aleman, 2023), following the approach of Smith et al (2019). Calculations are performed separately for 27 of the 33 disposal units (DUs) at ELLWF and are radionuclide specific. The results of the IHI analysis include: • Dose Factors: mrem per disposed curie (acute) and mrem/yr per disposed curie (chronic) for each parent radionuclide, for each DU. • Inventory Limits: in curies, for each parent radionuclide, for each DU. • Estimated Dose to IHI: mrem (acute) and mrem/yr (chronic), for each DU, given its projected closure inventory without inventory biases applied. Most DU-specific IHI inventory limits are in the range of 10 3 to 10 7 curies per nuclide. The lowest inventory limits are associated with gamma-emitters such as Sn-126, Ra-226, Th-232, and Cm-248. Radionuclides with short half-lives such as Pu-241, and nuclides which are pure beta emitters or which decay by electron capture, such as Ni-59 and Ni-63, have the highest limits. For the 27 evaluated DUs, predicted IHI doses are shown in Table ES-1. The maximum acute dose is 1.18 mrem, at ST23, much less than the DOE performance measure of 500 mrem (USDOE, 2017). The highest chronic dose is 37.2 mrem/yr at ST02, below the DOE performance measure of 100 mrem/yr. Also shown are estimated inventory sums of fractions (SOFs) at closure in 2065, for groundwater (GW) and IHI pathways. For each DU, the inventory is constrained by the GW pathway. For most DUs, the IHI SOFs are approximately 1000 times lower than the GW SOF values, and the IHI pathway does not drive risk for any disposal unit.

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GoldSim E-Area Low-Level Waste Facility Aquifer Zone Model Calibration Methodology

This report documents the development and calibration of the E-Area Low-Level Waste Facility (ELLWF) Gold Sim aquifer model. It provides a methodology on how a Gold Sim aquifer model can be calibrated to specific PORFLOW-based aquifer predictions. The calibration activity presented within this report focuses on the Slit Trench #06 (ST06) location that resides within the center set of Slit Trenches. This Gold Sim-based aquifer model is a generic model capable of being calibrated to any of the other trench locations within E-Area. In addition, subsequent activities (beyond the scope of this effort) will couple this GoldSim-based aquifer model to various GoldSim-based trench models, with the intent of performing stochastic analyses that couple all pertinent fate and transport processes from the ground surface up to the 100-m point of assessment (POA).

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Special Analysis: Impact of Updated GSA Flow Model on E-Area Low-Level Waste Facility Groundwater Performance

In March 2018, the Savannah River National Laboratory (SRNL) notified Solid Waste Management (SWM) of new information that could potentially impact groundwater (GW) disposal limits and possibly require temporary protective measures (Crowley 2018). GW flow directions in the E-Area Low-Level Waste Facility (LLWF) Slit Trenches (STs), Engineered Trenches (ETs), and the Low Activity Waste Vault (LAWV) have notably changed in the new 2018 General Separations Area (GSA) flow model (Flach 2018a). The 2018 GSA flow model had been updated using 20 years of new hydrologic field data and model calibration methods that employed mathematical optimization software. It was later determined that the primary reason for the change in GW flow directions was due to the influence of low permeability caps that had been placed over the Old Burial Grounds and the Low Level Radioactive Waste Disposal Facility (LLRWDF). Updated flow directions in the model produce a higher degree of plume overlap for disposal units (DU’s) in the southeastern portion of E-Area than had been predicted in the 2008 E-Area LLWF Performance Assessment (PA). SWM and SRNL outlined the scope for this Special Analysis (SA) and proposed a set of interim measures (IM’s) to protect trench operations from exceeding Performance Objectives (PO’s) during the preparation of this SA, both of which were approved by the SWM Performance Assessment Review Committee (PARC) (Mooneyhan 2018).

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Infiltration Data Package for the E-Area Low-Level Waste Facility Performance Assessment

The infiltration data package contains the input parameters, the cap design and material properties assumptions, and the modeling results for the Hydrologic Evaluation of Landfill Performance (HELP) infiltration model simulations performed in support of the E-Area Low-Level Waste Facility Performance Assessment (PA). The infiltration estimates establish the upper boundary condition for the PORFLOW vadose-zone model and GoldSim model simulations for the following E-Area disposal unit types: Slit and Engineered Trenches, Low-Activity Waste Vault (LAWV), Intermediate-Level Vault (ILV), Componentin- Grout (CIG) special waste form trench segments, and the Naval Reactor Component Disposal Areas (NRCDAs). The infiltration data package builds upon relevant, foundational PA technical reports and memoranda from the past 15 years and is supported by three important components: the HELP model input parameter datasheets, HELP model input and output filenames and directory structure, and infiltration rates as a function of time for each scenario for each disposal unit type. For Slit and Engineered Trenches, a single best-estimate Bahia-grass case of two-percent slope and 585- foot slope length represents an upper bound on intact closure-cap infiltration rates over a 10,000-year period. Building upon the single, bounding, and intact case, two different approaches were considered for incorporating the effect of localized cap subsidence on infiltration rates in the PORFLOW flow and transport model simulations. In the first approach, a Monte Carlo probabilistic model was developed to calculate infiltration rates for 0.54%, 2%, 3.6%, and 4.9% subsidence scenariosa reflecting historical and future non-crushable content for the Slit and Engineered Trenches. The resulting blended (spatially and slope-length averaged) infiltration rates become an inflow upper boundary condition for the PORFLOW vadose zone model simulations. In the second and preferred approach, a Monte Carlo rectangle packing algorithm (Danielson, 2019) and a simplified equation for the total mass flux of water draining into a subsided compartment (Equation 1) will be employed to implement a weighted blending of radionuclide fluxes to the water table using the results of deterministic PORFLOW vadose zone simulations representative of specific subsidence cases. Finally, HELP-model results from sensitivity studies of the intact infiltration case were fit to a log-logistic function to generate infiltration profiles over a 10,000-year period for most-optimistic, more-optimistic, best-estimate, more-pessimistic, and most-pessimistic cases, for both the intact and four subsidence scenarios. For the LAWV and IL vaults, infiltration rate profiles for a 10,000-year period were developed for both an on-vault (above the concrete/metal vault roof) and an off-vault (10-foot soil zone adjacent to vault walls) scenario. The purpose of the off-vault simulations was to confirm that subsurface runoff from the concrete vault roof will adequately drain through the lowermost backfill layers adjacent to the vault walls. The LAWV and ILV infiltration profiles assume collapse of the concrete roof at relative Years 2,905 and 7,100, respectively. The identical Bahia-grass case with two-percent slope and 585-foot slope length assumed for the Slit and Engineered Trenches will represent an upper bound on intact infiltration rates for the NRCDAs and CIG special waste form as well. While the NRCDA casks are assumed to remain structurally intact (i.e., non-assumed to collapse 300 years after the end of operations. Because both rows of the existing CIG trench segments in ST23 (formerly CIG01) extend across the planned cap crest, the subsided CIG trench segments are treated conservatively in the HELP model as a 100%-subsidence case with zero subsurface run-on. The CIG special waste form trench segment infiltration profile, therefore, consists of an intact-cap period from relative Year 100 to Year 300, followed by a 100%-subsidence period from relative Year 300 to Year 10,100.

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E-Area Low-Level Waste Facility Vadose Zone Model: Confirmation of Water Mass Balance for Subsidence Scenarios

In preparation for the next revision of the E-Area Low-Level Waste Facility (LLWF) Performance Assessment (PA), a mass balance model was developed in Microsoft Excel to confirm correct implementation of intact- and subsided-area infiltration profiles for the proposed closure cap in the PORFLOW vadose-zone model. The infiltration profiles are based on the results of Hydrologic Evaluation of Landfill Performance (HELP) model simulations for both intact and subsided cases.

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Operation and Maintenance Manual for the Remote-Handled Low-Level Waste Facility Potable Water System (PWS #6120030)

The document is an Operations and Maintenance Manual for the Remote Handled Low Level Waste Disposal Facility (RHLLW) potable water system. This document is required by the State of Idaho Department of Environmental Quality. The document defines the system, components, interfaces with ATR, operations of the system, contains operating procedures and log sheets, component manufacturer sheets showing compliance with regulations and also contains signed Preventive Maintenance Justification forms for applicable components of the potable water system.

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The Port Hope Areas Initiative's Port Granby Project: The Decontamination of Site Equipment from a Low Level Waste Facility - 20330

The Port Hope Area Initiative (PHAI) is the Government of Canada's response to the community recommended solutions for the remediation and safe, long-term management of historic low-level radioactive waste (LLRW) that was the result of uranium and radium processing operations in the Municipality of Port Hope, Ontario from the 1930's to the 1980's. The Eldorado refinery, on the shores of Lake Ontario, began refining radium-226 from pitchblende ore, later transitioning to the refining of uranium ore. Process residues were deposited at the Welcome Waste Management Facility in Port Hope until the mid-1950's switching to the Port Granby Waste Management Facility (PGWMF), which continued to accept waste until the late 1980's. The Port Granby Project involves the construction of a new, secure long-term waste management facility (LTWMF) and supporting infrastructure, and the excavation and relocation of approximately 1,200,000 m{sup 3} of historic low-level radioactive waste and marginally contaminated soil from the PGWMF to the newly constructed LTWMF. Since the project's inception in 2016, the bulk of the material has since been moved to the final long term storage cell. This has taken over 500,000 person-hours and a large amount of one site heavy equipment to accomplish including excavators, bulldozers, rock trucks, baker tanks and vacuum trucks. While many of the pieces of heavy equipment and water management equipment has further work to do on site, several of the sites larger items have already undergone the decontamination process prior to release from the site. This process has posed a serious challenge as the waste has a caustic nature to it and over the last few years it has had time to work its way into the metallic structures and framework of the equipment. Coupled with the tight work spaces and in some cases confined work areas there have been many issues that needed to be addressed to successfully reach a state where items can be free released to the unrestricted limits of the sites license. This ongoing process has led to a more refined decontamination program at the Port Granby Facility and has had a rather high success rate considering the length of time the equipment has been exposed to the waste materials on site. This paper discusses the varied challenges of decontamination faced at a low-level radioactive waste facility with a focus on the following aspects: - Challenges faced regarding different equipment types and the solutions implemented by Wood to address these challenges; - An examination of various decontamination methods employed throughout the project; and - Lessons learned over three years of remediation work and how they impact the decontamination process. (authors)

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Porflow Implementation of Vadose Zone Conceptual Model for Slit and Engineered Trenches in the E-Area Low Level Waste Facility Performance Assessment

A summary of the conceptual models to be used in representing slit (ST) and engineered trenches (ET) in PORFLOW (ACRi 2018) simulations as part of the performance assessment (PA) of the E-Area Low Level Waste Facility (ELLWF) is presented. Key details that are discussed include: model geometries, spatially dependent hydro-stratigraphic representations, model dimensionality, and boundary conditions (i.e., infiltration rates, cover overhangs, subsidence). Accounting for differences in the percent of non-crushable materials, eighteen unique models, defined by seven hydro-stratigraphic groupings, will be used to represent slit and engineered trenches.

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A Monte Carlo Rectangle Packing Algorithm for Identifying Likely Spatial Distributions of Final Closure Cap Subsidence in the E-Area Low-Level Waste Facility

A Monte Carlo rectangle packing algorithm, summarized in Figure ES-1, has been developed to provide insights into the likely spatial distribution of subsided areas or holes in the final closure cap for the E-Area Low-Level Waste Facility (ELLWF) resulting from the placement of non-crushable waste containers within slit and engineered trench disposal units. Using historical records provided by Solid Waste Management as an indicator of future waste streams, a probability distribution of unique waste containers was constructed, and Monte Carlo sampling was used to sequentially select waste containers for placement in a rectangular region bounded by the disposal unit footprint. Within this Monte Carlo approach, the probability of any container type being selected is weighted by the fractional abundance relative to all other container types. For each Monte Carlo realization, the frequency of non-crushable waste containers appearing at each location on a spatially discretized mesh is updated. After many realizations, the location(s) with the highest frequencies of non-crushable waste containers are regarded as the most likely locations to experience subsidence (i.e., for a hole to form). Utilizing this approach has enabled the down-selection of a computationally intractable set of subsidence hole combinations to be explored in three-dimensional finite element groundwater flow and contaminant transport models. Such an approach can be applied to a number of different packaging problems.

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