WIPP PA Sensitivity Studies in Support of CRA-2014 Completeness Determination and Compliance Decision - 18209

The Waste Isolation Pilot Plant (WIPP) has been developed by the U.S. Department of Energy (DOE) for the geologic (deep underground) disposal of transuranic (TRU) waste. Containment of TRU waste at the WIPP is regulated by the U.S. Environmental Protection Agency (EPA). The DOE demonstrates compliance with the containment requirements by means of performance assessment (PA) calculations. WIPP PA calculations estimate the probability and consequence of potential radionuclide releases from the repository to the accessible environment for a regulatory period of 10,000 years after facility closure. Since TRU waste was first received at the WIPP in 1999, compliance recertification applications (CRAs) have been required by the EPA on five-year cycle. The latest CRA (CRA-2014) was submitted by the DOE to the EPA in 2014. As part of the application, a formal set of PA calculations (CRA-2014 PA) was performed and results were documented in detail. The CRA-2014 PA incorporated several parameter updates based on new data, as well as the implementation of a different model for panel closures, barriers planned for the opening of each waste panel. The results presented as part of the CRA-2014 showed via the required complementary cumulative distribution function (CCDF) release curves that the estimated releases were within compliance limits. As part of their process for reviewing the completeness of the CRA-2014 [1], the EPA formally requested that the DOE perform sensitivity studies based on EPA-requested changes to model parameters. The DOE performed and documented the results of three sensitivity studies described below: CRA14-SEN2 [2], CRA14-SEN3 [3], and CRA14-SEN4 [4]. In each case, the new analysis results were compared to CRA- 2014 PA (CRA14) results to determine the impact of the EPA-requested changes. CRA14-SEN2: the application of EPA-requested modified parameters in the operations and experimental (non-waste) areas of the repository to simulate an accelerated (instantaneous) creep closure, the inclusion of capillary pressure effects on relative permeability, and an increase in initial/residual brine saturation and residual gas saturation. The modifications to the repository model resulted in increased pressures and decreased brine saturations in waste areas and increased pressures and brine saturations in the operations and experimental areas. However, the overall effects on total high-probability mean releases from the repository were entirely insignificant. It was concluded that the modeling assumptions associated with the operations and experimental areas of the repository have an insignificant effect on the prediction of total releases from the repository and/or adequacy of the current (CRA14) model to demonstrate compliance with the regulatory limits. CRA14-SEN3: the application of EPA-requested modified parameters in the panel closure areas and operations and experimental (non-waste) areas of the repository to simulate an accelerated (instantaneous) creep closure, the inclusion of capillary pressure effects on relative permeability, and an increase in initial/residual brine saturation and residual gas saturation. The modifications to the repository model predominantly result in increased pressures and decreased brine saturations in waste areas, increased pressures and brine saturations in the operations and experimental areas, and decreased brine and gas flows across all panel closures. The pressure increases in repository waste regions yielded slightly decreased brine saturations (on average) in those areas. However, the overall effects on total high-probability mean releases from the repository are entirely insignificant. It was concluded that the modeling assumptions made for this sensitivity study which were associated with the panel closures and north end areas of the repository have only a small effect on the prediction of total releases from the repository and/or adequacy of the current (CRA14) model to demonstrate compliance with the regulatory limits. CRA14-SEN4: the application of several changes to the current WIPP PA model (CRA14), including: parameter changes, use of an updated code, and a revised computational grid for the BRAGFLO code. The modifications to the repository model resulted in increased releases in all primary release mechanisms. The impacts of each EPA-requested change to CRA14 were analyzed with respect to each release mechanism in the CRA14-SEN4 study. Overall, total high-probability predicted mean releases from the repository were increased by about 15%. Total low-probability predicted mean releases were increased by about 107%. It was concluded that the EPA-requested changes to the CRA14 result in increases to the predicted total releases from the repository. However, releases calculated in the CRA14-SEN4 analysis remained below regulatory limits, demonstrating continued compliance of the WIPP. In January 2017, the EPA determined that CRA-2014 was complete and then began a technical evaluation of CRA-2014 to determine whether the WIPP continued to comply with the radiation protection standards for disposal. During their evaluation, the EPA utilized the sensitivity study results to inform their ultimate determination in July 2017 that the WIPP continues to comply with regulatory standards. (authors)