ACCELERATING CLEANUP:
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.
Waste Isolation Pilot Plant (WIPP)
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:
| $ in Billions | |||
| FY 1997 - FY 1996 | FY 1997 - FY 2020 | TOTAL | |
| BEMR | $1.9 | $6.8 | $8.7 |
| Discussion Draft | $1.9 | $7.1 | $9.0 |
| Initial Plan | $1.9 | $7.7 | $9.6 |
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:
| TRU Waste Site | CH Volumes | RH Volumes |
| ANL-E | 118 | 0 |
| Hanford | 6,353 | 17 |
| INEEL | 11,795 | 0 |
| LANL | 10,263 | 135 |
| LLNL | 483 | 0 |
| Mound | 200 | 0 |
| NTS | 666 | 0 |
| ORNL | 507 | 1,164 |
| RFETS | 9,247 | 0 |
| SRS | 2,411 | 0 |
| SQS | 111 | 110 |
| Total | 42,154 | 1,426 |
The following table represents the shipments by TRU waste site through FY 2006.
| TRU Waste Site | CH Shipments | RH Shipments |
| ANL-E | 27 | 0 |
| Hanford | 770 | 19 |
| INEEL | 1,884 | 0 |
| LANL | 1,265 | 152 |
| LLNL | 54 | 0 |
| Mound | 45 | 0 |
| NTS | 89 | 0 |
| ORNL | 58 | 1,308 |
| RFETS | 1,370 | 0 |
| SRS | 269 | 0 |
| SQS | 35 | 124 |
| Total | 5,866 | 1,603 |
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.
WIPP Key to EM Mortgage Resolution Strategy
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.
Privatization of the TRU Waste Transportation System
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.
Science and Technology Developments
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:
| Project | FY1998 | FY1999 | FY2000 | FY2001-2006 | FY2007-2070 |
| CAO-1 WIPP Base Operations | 98,684 | 101,494 | 111,737 | 739,495 | 7,204,181 |
| CAO-2 Disposal Phase Certification & Experimental Program | 38,678 | 36,466 | 35,640 | 177,465 | 1,535,493 |
| CAO-3 WIPP Transportation | 11,982 | 23,734 | 24,382 | 178,860 | 1,320,903 |
| CAO-4 WIPP TRU Waste Sites Integration & Preparation | 24,522 | 21,897 | 21,849 | 127,281 | 2,419,045 |
| CAO-6 WIPP TRU Waste Transporation Privatization | 21,000 | 19,605 | 0 | 0 | 0 |
| Total (Current Year $000) | 194,866 | 203,196 | 193,608 | 1,223,101 | 12,479,622 |
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
CAO-2 WIPP Disposal Phase Certification and Experimentation Program
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.
CAO-4 WIPP TRU Waste Sites Integration and Preparation
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
CAO-6 WIPP TRU Waste Transportation Privatization
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.
Enhanced Performance Strategies
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
Federal Facility Compliance Act
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.
Enhanced Program Performance Implications
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 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.