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Case Study – WIPP Radiological Release NSE 515 11/21/2018

The Waste Isolation Pilot Plant (WIPP) was authorized by congress in 1979, when it began to be apparent that the nation needed a long-term solution for disposal of transuranic wastes (TRU). The WIPP is located near Carlsbad, New Mexico in a bedded salt mine. This is a geologically stable, water-free salt cavern which will slowly encapsulate the nuclear wastes over time, providing a stable long-term solution for storage of nuclear waste.

Construction of the facility was completed in 1989, but the facility did not begin accepting waste until 1999, due to an agreement between the U.S. Department of Energy and the State of New Mexico that the facility would not be able to accept wastes until it received a Resource Conservation and Recovery Act (RCRA) Part B Permit, for treatment, storage and disposal of regulated hazardous wastes.

In 1999, the facility begins receiving TRU waste shipments from DOE facilities including Los Alamos National Lab, Idaho National Lab, Rocky Flats Environmental Technology Site, Argonne National Lab, and Hanford. The facility operated safely from 1999 to 2014.

WIPP is operated by prime contractor Nuclear Waste Partnership LLC, which is a joint entity lead by AECOM Corporation (full disclosure: I am an employee of AECOM on a different Department of Energy contract). In 2014, waste receiving was temporarily shut down due to a fire on a salt hauling truck. A few days later, the facility experienced a radiological release from a waste drum in Room 7, Panel 7, with airborne contamination released to the environment.

The facility was inspected by the U.S. Environmental Protection Agency for compliance with 40 CFR Part 191, Subpart A Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes, and 40 CFR Part 61 Subpart H National Emissions Standards For Emission of Radionuclides Other than Radon from Department of Energy Facilities, both of which regulations address radioactive dose to the public by exposure to contaminants in the air released from Department of Energy radioactive waste disposal facilities.

The release occurred in a single drum of TRU waste from Los Alamos National Lab. This drum contained TRU waste materials which had been packed with an absorbent called Swheat Scoop™. Absorbent materials are used to cushion and absorb any leakage from smaller containers packed into a drum, in a process known as lab packing or over packing. Traditionally, diatomaceous earth (kitty litter) or vermiculite are used for this purpose, as they are compatible, or non-reactive, with most reactive and hazardous chemicals. A replacement product, Swheat Scoop™, was purchased as an alternative to diatomaceous earth. Personnel did not realize that Swheat Scoop™ is an organic-based absorbent, and is incompatible with strong oxidizers and other reactive chemicals.

The drum which reacted and breached at WIPP contained a mixed-waste, which is a RCRA hazardous waste which is also a TRU radioactive or nuclear waste. In this case, the waste was RCRA hazardous because of reactivity, as it contained a strong oxidizer. The oxidizer slowly reacted with the organic Swheat Scoop™ absorbent, and after 70 days in storage, the container breached and released air-borne radioactive materials contamination. The release was detected by a Continuous Air Monitor (CAM) monitoring WIPP’s Panel 7. When the alarm activated the air exhaust system automatically switched to a HEPA filtration system, which was designed to prevent releases of radioactive material which might impact members of the public.

This alarm triggered activation of WIPP’s emergency response organization, including the Alternate Emergency Operations Center (AEOC) and Joint Information Center (JIC). WIPP emergency management directed employees to shelter in place and began emergency management operations. Radiological control personnel performed site surveys and found radioactive materials contamination present in the HEPA filters, but no on-site or off-site contamination of facilities or public areas.

Most of the air-borne radioactive contaminant released was collected in an HEPA filtered air exhaust system, but some radioactive contaminant was released to the environment. Bioassay was performed on 150 employees of the facility, with the result that 21 personnel had positive results indicating that they received minor exposures during this incident.

An air sampling station 0.6 miles from WIPP detected a small release of radioactive particles from the facility. After extensive monitoring and surveying, DOE found that levels released to the public from the facility were minor and well below the levels set in 40 CFR 61.92, “Emissions of radionuclides to the ambient air from Department of Energy facilities shall not exceed those amounts that would cause any member of the public to receive in any year an effective dose equivalent of 10 mrem/yr.”

The Department of Energy issued a Preliminary Notice of Violation (PNOV) to Nuclear Waste Partnerships in February 2016 for violations of worker safety and health and nuclear safety requirements under 10 CFR 851 Worker Safety and Health Program, 10 CFR 820.11 Information Requirements, 10 CFR 830 Nuclear Safety Management, and 10 CFR 835 Occupational Radiation Protection. The New Mexico Environment Department also issue compliance orders to both WIPP and Los Alamos National Lab, and issued civil penalties against these facilities of $17.7 million to WIPP and $36.6 million to Los Alamos National Lab.

WIPP reopened and began accepting waste shipments in April 2017.

As an employee of AECOM on a Department of Energy contract, these events had a major effect on our manner of doing business. However, the release of radioactive particles to the public was minor and will have no lasting environmental or public health implications. The employees working in the WIPP and Los Alamos National Lab have, no doubt, learned a valuable lesson about complacency and the long-term consequences of their actions on their

work place and their communities. This incident was used as a teachable moment throughout the Department of Energy complex, with hundreds of thousands of federal and contract employees receiving safety training on the specific details of this incident and the behaviors that enabled it to occur.

Most of the long-term effects of this incident will be related to the community’s relationship to this facility, and their comfort with having the nation’s only active TRU waste disposal facility in their near vicinity, and the possible implications for this on their community’s health and safety. The community will be watching and scrutinizing the actions and behaviors at WIPP with an eye to the community’s safety and with an enhanced skepticism. Hopefully, the personnel operating WIPP will understand the risks to themselves and the community and perform their jobs with the level of care and diligence necessary to provide a safe environment within and without the facility.

References

NPR, “Official Report: Nuclear Waste Accident Caused By Wrong Cat Litter” March 26, 2015, Geoff Brumfiel, https://www.npr.org/sections/thetwo-way/2015/03/26/395615637/official- report-nuclear-waste-accident-caused-by-wrong-kitty-litter

WIPP History and Timeline, http://wipp.energy.gov/historytimeline.asp

Environmental Protection Agency, Radiation Protection, 2014 Radiological Event at WIPP, https://www.epa.gov/radiation/2014-radiological-event-wipp#response

EPA Subpart A Inspection Report EPA Air DOCKET NO: A-98-49; II-B3-129; September 2014 https://www.epa.gov/sites/production/files/2015-05/documents/Subpart-A-Inspection-Report- Response-Incident-February2014.pdf

U.S. Department of Energy, Office of Environmental Management Accident Investigation Report, Phase 1, Radiological Release Event at the Waste Isolation Pilot Plant February 14, 2014; April 2014 http://www.wipp.energy.gov/Special/AIB_Final_WIPP_Rad_Release_Phase1_04_22_2014.pdf

U.S. Department of Energy, Office of Environmental Management Accident Investigation Report, Phase 2, Radiological Release Event at the Waste Isolation Pilot Plant February 14, 2014; April 2015 http://www.wipp.energy.gov/Special/AIB_WIPP%20Rad_Event%20Report_Phase%20II.pdf

NEWS RELEASE December 6, 2014 Contact: Jim Winchester Communications Director New Mexico Environment Department (505)231-8800 / [email protected] New Mexico Environment Department Issues Compliance Orders to U.S. Department of Energy to Protect Safety and Success of Waste Isolation Pilot Plant https://www.env.nm.gov/OOTS/PR/2014/PR120614%20State%20Issues%20Compliance%20Or ders%20&%20Fines%20For%20WIPP%20Radiological%20Release.pdf

Department of Energy Cites Nuclear Waste Partnership, LLC and Los Alamos National Security, LLC for Violations Related to Worker Safety and Health and Nuclear Safety. February 19, 2016 https://www.energy.gov/articles/department-energy-cites-nuclear-waste-partnership-llc-and- los-alamos-national-security-llc

U.S. Department of Energy, Office of Environmental Management, WIPP Receives First Shipment Since Reopening, April 17, 2017 https://www.energy.gov/em/articles/wipp-receives-first-shipment-reopening