PATHS TO CLOSURE
CARLSBAD AREA OFFICE
JUNE 1998
I. Operations/Field Overview
CAO Mission
The mission of the Carlsbad Area Office (CAO) is
to protect human health and the environment by opening and operating
the Waste Isolation Pilot Plant (WIPP) for safe disposal of transuranic
(TRU) waste and by establishing an effective system for management
of TRU waste from generation to disposal. It includes personnel
assigned to CAO, WIPP site operations, transportation, and other
activities associated with the National TRU Program (NTP). The
CAO develops and directs implementation of the TRU waste program,
and assesses compliance with the program guidance, as well as
the commonality of activities and assumptions among all TRU waste
sites.
This executive summary addresses the
activities associated with the NTP managed by CAO. The CAO programmatically
reports to the Assistant Secretary for Environmental Management
and receives administrative support through the Albuquerque Operations
Office.
A cornerstone of the Department of
Energy's (DOE) national clean-up strategy, the WIPP is designed
to permanently dispose of TRU waste generated by defense-related
activities. Located in southeastern New Mexico, 26 miles east
of Carlsbad, project facilities include disposal rooms excavated
2,150 feet underground (about a half mile) in an ancient, stable
salt formation. TRU waste consists primarily of tools, gloves,
clothing and other such items contaminated with trace amounts
of radioactive elements, mostly plutonium.
Defense Authorization Act of 1979 (PL
96-164) authorized the DOE to provide a research and development
facility for demonstrating the safe disposal of radioactive waste
produced by national defense activities. DOE's decision to proceed
with WIPP followed a thorough National Environmental Policy Act (NEPA) review and was announced in a 1981 Record of Decision (ROD).
The WIPP Land Withdrawal Act of 1992 (LWA) (PL 102-579) modified
by the WIPP Land Withdrawal Amendment Act of 1996 (LWAA) (PL 104-201)
transferred public land to the DOE and established the regulatory
framework and specific requirements to begin waste disposal operations.
The WIPP Disposal Phase Final Supplemental Environmental Impact
Statement defines the alternatives reviewed for TRU waste management
and disposal. The ROD, approved in January 1998, selects WIPP
as the desired alternative.
Current CAO assumptions support operations
of the WIPP facility, including its infrastructure, as an operational
nuclear facility capable of receiving CH-TRU waste at an initial
disposal rate of 5 shipments per week and ramping to 17 shipments
per week for optimum throughput. Disposal of RH-TRU waste begins
in FY 2003. The statutory requirement to pay impact assistance
to the State of New Mexico is funded. The CAO baseline provides
adequate funding to meet the National TRU Waste Management Plan (NTWMP), Rev. 1. Escalation has been applied to the activities
in accordance with the DOE Environmental Management guidelines.
The CAO estimates for life cycle costs
are based on an established baseline of 35 years for operation
of the WIPP site followed by 5 years of dismantling and decommissioning
the site. During this 5 year period, controls will be established
for the 100 year Active Institutional Control Period as specified
in the LWAA. Costs from FY 1998 through FY 2008 have been developed
using Activity Based Management methodologies (i.e. establishing
best cost estimates for scope and schedule). As specified in the LWAA, WIPP is authorized to dispose of 175,600 cubic meters of
TRU waste. The CAO has developed a TRU waste system model to help
determine the optimum disposal rates. Model output is based on
the TRU waste sites' ability to characterize TRU waste, transportation
systems, and the WIPP site's ability to receive waste. Results
of modeling efforts are published in the NTWMP, Rev.1, December
1997. The current schedule includes opening WIPP in 1998, increasing
CH-TRU waste throughput to the optimum level by FY 2000, initiating
RH TRU Waste in FY 2003, and the first re-certification submission
to EPA in FY 2002. The re-certification cycle is every five years
and costing has been developed to reflect this cyclical process.
The transportation and disposal process will become relatively
steady during the periods FY 2005 through FY 2033. There will
be major equipment replacements for mining equipment approximately
every 10 years. The dismantling period of FY 2033 to FY 2038 will
require additional funding to close and seal the shafts. Berms
will be used with land restrictions for the 16 square miles surrounding
the WIPP site. Limited presence will be required for the ensuing
100 years of active institutional controls.
The following table provides a comparison of the
life cycle costs (in FY 1998 dollars) from the 1996 Baseline Environmental
Management Report (BEMR), the June 1997 Discussion Draft, the
current Initial National Plan:
NOTE:
- All estimates exclude the cost of the federal
work force at Carlsbad, New Mexico.
- The costs from FY 1977 - FY 1996 are actual costs
without being adjusted to FY 1998 dollars.
- The cost for privatization has been included
in the Initial Site Plan ($41 million) but was not included in
the BEMR or the Discussion Draft.
Since 1994, the CAO has institutionalized
a formal program planning and budget execution process. The confidence
level of cost estimates for the next three years is very high
(+/- 5 percent). Out year estimates through FY 2008 have been
developed with a confidence level of +/- 10 to 20 percent. Estimates
from FY 2009 through completion are within +/- 30 percent. There
are no contingency funds included in the CAO estimates.
II. End State, Future Use,
And Stewardship
TRU waste management activities for
both CH- and RH-TRU wastes are projected to be completed by FY
2039 after completing the Disposal Phase in FY 2033, five years
for decommissioning of the surface facilities, and permanently
closing the underground. In accordance with the LWAA, DOE will
have disposed of 175,600 cubic meters of TRU waste in the WIPP
facility. Starting in FY 2039, a reduced Federal staff and technical
contractor support will maintain the active institutional controls
associated with the land withdrawal and records of the WIPP. Monuments
and markers will be built at the site to warn people of the presence
of radioactive waste. Active institutional controls over the site
will be maintained for 100 years. Low risk has been assigned based
upon performance assessments included in the licensing of the
facility, which requires no migration of hazardous or radioactive
material for 10,000 years. Following completion of the project,
there will be no access to the underground. The surface area will
be unrestricted for recreational and agricultural uses with the
exception of 124 acres which constitutes the exclusive use passive
institutional control area.
III. Strategies And Prioritization
Planned Accomplishments by FY 2006
Through FY 2006, WIPP will have received approximately
43,580 cubic meters of waste. This is approximately 7,469 shipments.
Through FY 2006, 43 percent of the WIPP's CH-TRU and 18 percent
of the RH-TRU waste handling capacity is used, and 93 percent
of the affected population will no longer be exposed to the potential
hazards of stored defense generated TRU waste. The following waste
volumes are planned to be disposed at WIPP by FY 2006:
The following table represents the
shipments by TRU waste site through FY 2006.
DOE will have completed the first five
year re-certification cycle by FY 2002. This re-certification
is required by the LWAA and may result in additional certainty
experiments.
DOE's NTWMP, Rev. 1, addresses the strategies required
by the DOE complex to achieve the significant reductions in surveillance
and maintenance cost at the TRU waste sites. For example, the
Rocky Flats Environmental Technology Site (RFETS) cannot restore
the site by FY 2006 unless TRU waste is removed. This is true
for all sites that have TRU waste. The Plan configuration is expected
to yield the maximum benefit toward reducing the mortgage associated
with TRU waste. Expenditures are expected to be high initially
to support the rigorous schedules set forth in the NTWMP, Rev.
1, configuration. However, this will result in an earlier decrease
in the financial burden associated with on-site TRU waste management
and storage. Additionally, the NTWMP, Rev. 1, configuration identifies
site-specific waste processing rates that are coordinated with
an optimal shipping fleet to complement the WIPP`s waste handling
and disposal capacities. Shipments of CH-TRU waste to WIPP through
FY 2006 closely match the waste handling and disposal capabilities
of WIPP. By the end of FY 2006, RFETS, Mound, Nevada Test Site (NTS), and selected small quantity sites will have completely
disposed of all CH-TRU waste at WIPP. Shipments of RH-TRU waste
begin in FY 2003 at 148 shipments per year and increases to approximately
500 shipments per year in FY 2005.
The CAO privatization program includes
funding in FY 1998 ($21 million) to privatize TRUPACT II containers
necessary to fully implement the CH transportation system. The
FY 1999 request ($19.6 million) is required to privatize the 72-B
cask which will be used to transport RH TRU waste. These two privatization
efforts are expected to save over $290 million in WIPP related
funding requirements over the next 35 years. The privatization
efforts are expected to lessen peak annual expenditures by amortizing
project costs over the life of the project.
The current five-year contract (FY
1995-FY1999) with the managing and operating contractor, Westinghouse,
Waste Isolation Division (WID), is structured so that each fiscal
year's scope and contract type is re-negotiated. WID comprises
approximately 50 percent of the Carlsbad Area Office funding requirements.
Within the current year's contract for WID, over 63 percent is
fixed price incentive, 22 percent firm fixed price and 15 percent
cost plus award fee with contract incentives. The remainder of
the CAO funding is directed towards certification and recertification
to regulators criteria, the CAO's mission of managing the National
TRU Waste program, and maintaining a TRU waste transportation
system. The work by the CAO Scientific Advisor, Sandia National
Laboratories, and enhanced laboratory work at Los Alamos National
Laboratory is performed under cost plus fixed fee contracts which
represents 23 percent of CAO's funding requirement. The contract
for the CAO's technical support contractor, CTAC, has been negotiated
for five years starting in FY 1996 as a task order contract (7
percent of CAO's requirement). Other contract types (20 percent)
include grants, cooperative agreements, stakeholder and oversight
funding , emergency management commitments with the Southern States
Energy Board and the Western Governors' Association, and payments
of over $20 million annually to the State of New Mexico for impact
assistance as specified in the LWAA. Also included in the other
categories are the funds to pay the privatized contractor for
both CH- and RH-TRU waste transportation from the TRU waste sites
to the WIPP. These contracts should be fixed price when they are
negotiated.
The CAO works closely with the EM Mixed
Waste Focus Group and other Environmental Management Offices of
Science and Technology groups to identify and deploy new and innovative
technologies. The technology development activities being supported
by the CAO are in five categories:
- waste characterization
- waste certification or disposal
- treatment
- transportation
- regulatory compliance
The initiatives currently funded or requested, benefit
the program by reducing the cost of activities necessary to send
waste to WIPP or making more waste available for disposal at WIPP.
Today a portion of the WIPP eligible waste cannot meet transportation
and packaging limits. Several research programs are in progress
that will increase the amount of waste that can be shipped without
expensive treatment or repackaging such as the gas generation
studies, matrix depletion studies and hydrogen getter studies.
In addition, much of the waste cannot be readily and economically
characterized to meet transportation and disposal data quality
objectives. Work with radioassay techniques to quantify radioactive
isotopes has resulted in some improvements that will increase
the amount of TRU waste that can be readily characterized. Continuing
research will reduce the cost of characterization per container.
With over 810,000 containers destined for WIPP, a reduction in
the cost of characterization by $100 results in major cost savings.
The research can be applied to other radioactive waste types and
is not limited to TRU waste.
IV. Scope, Cost, And Schedule
The site mission has been divided into
five projects to help define the work scope to be completed. The
mission of disposing of the nation's TRU waste cannot be accomplished
without fully funding each project since they are totally dependent
on each other. Project Baseline Summaries (PBSs) provide full
details of the scope, schedule, and cost of each project. The
following table provides the current cost estimates for each project:
These numbers are slightly different than those included
in the National Plan, and reflect only minor adjustments in resources
with limited impact on scope.
These projects are described in the following sections.
The Base Operations project includes
all activities required to maintain waste receipt and disposal
operations including mining, waste handling and facility operations.
Also included in this project are activities required to maintain
and operate WIPP that are not directly related to waste disposal,
such as:
- maintaining compliance with federal and state
laws, regulations and standards not related to radioactive or
hazardous waste
- providing a safety and health program that includes
radiation safety, industrial safety and emergency management
- quality assurance; performing maintenance on
22 systems and associated subsystems and equipment
- operating and monitoring facility systems on
a 24 hour per day, 7 days a week
- maintaining the underground facilities (currently,
the underground facilities consist of 2,400,000 square feet of
horizontal openings and 4 vertical shafts, each over 2,150 feet
deep)
- administrative services and program management
activities required to achieve day-to-day and long term objectives
of the site
- make the payment to the State of New Mexico for
impact assistance as directed by the LWAA
This project includes all of the M
& O's, Scientific Advisor's and supporting laboratories experimental,
compliance, and performance assessment work in support of certification
and operational performance improvement for the WIPP site and
the national TRU system; and establishes a focused international
nuclear waste disposal research development program. The DOE will
conduct experimental activities to:
- support WIPP operations, by maintaining compliance
certification and enhancing WIPP and national TRU system operations
- support future waste management needs, by establishing
a focused international nuclear waste disposal research and development
program and by enhancing proactive response to emerging DOE TRU
waste management needs. This activity is intended to provide the
framework to maintain the WIPP as an international leader in nuclear
waste management research and development activities during the
disposal phase.
The DOE plans to begin disposal operations
at WIPP following receipt of certification by the EPA. The disposal
phase is expected to last for 35 years, and will include certification
activities no less than once every five years. The WIPP Disposal
Phase Certification and Experimental Program contains the experimental
program to be conducted during the initial 5-year certification
period. It also forms the basis for longer-term activities to
be carried out throughout the 35-year disposal phase.
This project includes all site activities
required to meet the NTWMP, Rev. 1. These activities include:
Emergency Response training; establishing and opening transportation
corridors; CH and RH-TRU waste packaging initiatives; carrier
services; and stakeholder interfaces related to transportation.
Primary locations where TRU waste is currently stored are: Idaho
National Engineering and Environmental Laboratory (INEEL), Los
Alamos National Laboratory (LANL), Rocky Flats Environmental Technology
Site (RFETS), Oak Ridge National Laboratory (ORNL), Savannah River
Site (SRS), Hanford Reservation (Hanford), Nevada Test Site (NTS),
Lawrence Livermore National Laboratory (LLNL), Argonne National
Laboratory - East (ANL-E), and Mound Plant (Mound). Other sites
have small quantities of TRU waste that will be disposed at WIPP.
The TRU waste sites scheduled to initially ship CH-TRU waste to
WIPP in FY 1998, are INEEL, LANL, and RFETS. Using the shipment
schedules in the NTWMP, Hanford, ANL-E, Mound, SRS, and selected
small quantity sites will begin shipping waste to WIPP in FY 1999
while LLNL and NTS will begin shipments in FY 2000. By FY 2000,
the WIPP facility will be at a full throughput rate of 17 CH shipments
per week. In FY 2003, CAO will begin receiving shipments of RH-TRU
waste from ORNL and LANL at a rate of two shipments per week and
work up to ten shipments per week by FY 2004.
The cost of opening corridors includes
cooperative agreements with all Native American tribes along each
corridor, state emergency response training, and agreements with
the Western Governors' Association and the Southern States Energy
Board. CAO also coordinates transportation schedules and plans
through the National Governors' Association.
CAO must open and maintain transportation
corridors across the United States between each TRU waste site
and WIPP. Currently, one corridor from INEEL, RFETS, and LANL
is open. Activities to open other corridors require approximately
two years prior to shipment campaigns beginning at the sites.
The phasing of corridors correspond with site shipping schedules
and eliminates the need for corridor maintenance thus reducing
TRU waste complex costs.
This project includes ongoing TRU integration
activities and programs which are directed by the CAO civilian
work force. The CAO is the lead office for the management, planning,
and integration of the transuranic (TRU) waste program. Its activities
include:
- Integration and infrastructure activities required
to prepare the DOE TRU waste complex for waste shipments to WIPP
- waste characterization certification
-TRU waste sites quality assurance project plans (QAPjP)
- Integrated activities to improve the envelope
of performance for transportation system and treated TRU waste
acceptance
- matrix depletion studies
- performance demonstration activities for all TRU waste sites
- Support to Secretarial commitments to the community
- Carlsbad Environmental Monitoring and Research Center (CEMRC)
- Carlsbad Department of Development (DoD) Advanced Training Facility
- Expert support from oversight groups such as
the Environmental Evaluation Group (EEG), the National Academy
of Sciences (NAS), and the Bureau of Land Management
The purpose of this project is to describe
the effort for privatizing a dedicated TRU waste transportation
system for CH and RH TRU waste. This project only includes the
capital equipment costs funded through the Office of Management
and Budget (OMB) Privatization program. All costs associated with
operating, executing, and maintaining the TRU waste transportation
system are reported in Project CAO-3.
The methodology used for developing
the scope of activities for privatizing a dedicated TRU waste
transportation system was defined by Congress. These guidelines
allow for Congress to fund the initiation of projects with private
vendors including any required capital equipment. Congressional
allocations provide the DOE with "Budget Authority (BA)"
the first year contracts are awarded. Because the privatization
funding is not intended to fully fund the projects, vendors will
be required to fund the project start-up and re-coop operating
investments through the products or services they render. After
one year from receiving the BA, DOE will begin reimbursing the
vendor for their initial capital outlay. This reimbursement will
be amortized over a five year period. Throughout this process,
DOE does not purchase or have claim to ownership for any of the
equipment or facilities. In the case of the TRU waste transportation
system, the vendor will be responsible for all the transportation
activities to meet the full throughput of the WIPP.
The EM enhanced performance strategy
impacts the TRU waste disposal activities by increasing the volumes
"Road Ready" at the TRU waste sites. Should the enhanced
strategy work, then all TRU waste related compliance agreements
can be achieved at the TRU waste sites. The WIPP disposal facility
and transportation system must be capable of processing the available
TRU waste. The only difference between the enhanced performance
strategy and the baseline is the goal of achieving the scope at
a reduced cost through economies or technological breakthroughs.
Most costs are driven by the WIPP regulators such as the Environmental
Protection Agency, Nuclear Regulatory Commission, and Department
of Transportation. Some reductions can only be achievable through
changes in regulatory requirements.
V. Regulatory Compliance
Most regulatory compliance requirements
result from efforts to meet provisions of the Federal Facility
Compliance Act of 1992. Under the NTWMP, Rev. 1, configuration
all but one site complies with current regulatory requirements,
consent orders, and agreements. Due to a reduction in the budget, RH-TRU waste operations at the WIPP have been deferred until January
2003. The delay causes ORNL to miss a compliance milestone, calling
for shipments of RH- TRU waste sludges to begin by September 30,
2002. CAO would require an additional $4 million in FY 1998 and
$5 million in FY 1999 to remedy the RH-TRU waste non-compliance
milestone at ORNL. Regulatory compliance at the INEEL will be
maintained by the narrowest of margins. However, integration of
waste management efforts provided by the NTWMP, Rev. 1, configuration
benefits other sites by enabling them to accelerate activities
necessary for compliance.
Most of the agreements between the
state regulatory agencies and the DOE sites are predicated on
the assumption that mixed and non-mixed TRU waste will be disposed
at WIPP without having to meet RCRA treatment standards for land
disposal. At some of the sites, consent orders and agreements
allow sites the flexibility to prepare plans for the construction
and operation of facilities that enable TRU waste to be shipped
to the WIPP.
The TRU waste disposal facility and
transportation system must be operational to maximize receipt
of TRU waste from the TRU waste sites or the sites may become
non-compliant. Enhanced performance is predicated on the assumption
that current operations or future cost estimates can be reduced
through economies in support costs, technology breakthroughs,
or relaxing regulatory requirements. The CAO is committed to explore
all avenues to reduce future costs. If additional savings cannot
be achieved, then the scope discussed in this site plan will not
be achievable and numerous compliance agreements could be at risk
throughout the DOE complex.
VI. Stakeholder and Tribal
Nationals Involvement
CAO has undertaken continuous interactions
with state and local stakeholders relating to transportation of
TRU waste. In addition, storage versus disposal positions have
been communicated through the WIPP Supplemental Environmental
Impact Statement public hearings and the Environmental Protection
Agency hearings on the Compliance Certification Application. CAO
continues to follow stakeholder concerns in accordance with its
stakeholder plan. The NTWMP, Rev. 1 was submitted to the National
Governors' Association for comments. The CAO has made presentations
to the Western Governors' Association and the Southern States
Energy Board on the NTWMP, Rev 1.
No comments were received on the CAO's draft strategy
document.
For Additional Information
For additional copies of the CAO's
initial Accelerating Cleanup: Paths to Closure strategy
document, for further information, or to ask questions, please
contact the WIPP Information Center at 1-800-336-9477. The document
is also available on the World Wide Web at http://www/em.doe.gov/closure.
Requests for copies of the National Paths to Closure report should
be directed to the Center of Environmental Management Information (CEMI) at 1-800-736-3282.
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