WIPP Issue Capacity of Storage Space

Transcription

1 WIPP Issue Capacity of Storage Space Current DOE estimates of EM-related wastes already or subscribed to be emplaced have accounted for 171,000 of the 175,564 m 3 of WIPP s legal limit WIPP s mission is to enable the cleanup of the nuclear complex s legacy wastes DOE/NNSA has already started to dispose of 6 MT of surplus Pu at WIPP No EIS for WIPP of this has been performed ROD EIS did not consider impact on WIPP If MOX is terminated, an additional 34 MT of surplus plutonium will be added The total amount of surplus DOE/NNSA plutonium is 61.5 MT According to the DOE/NNSA plan, the volume of plutonium waste to be shipped to WIPP (assuming 50% loading efficiency) 37,000 m 3 (34 MT) - surplused through agreement with Russia 44,000 m 3 (40 MT) includes 6 additional tons of surplus non-mox plutonium 67,390 m 3 (61.5 MT) includes the all surplus plutonium in NNSA s possession Average loading of a WIPP Panel ~ 15,000 m 3 44,000 m 3 requires 3 additional panels These would intrude into the buffer zone

2 WIPP Issue Criticality of Stored Pu 239 WIPP design basis assumed 21.1 MT of FGE Pu 239 distributed uniformly in 175,564 m 3 of relatively incompressible waste Design basis fissile concentration was 0.12 kg/m 3 ANSI/ANS limit for criticality 7.3 kg/m 3 Sandia analysis limit for criticality 3.0 kg/m 3 Criticality Control Overpack maximum loading 380 g per drum Concentration of the plutonium in the Criticality Control Container 29.2 kg/m 3 The as-built concentration in the CCO is 1.8 kg/m 3 However, the drum will collapse due to corrosion and the creep of the salt resulting in a concentration approaching a concentration of 29.2 kg/m 3 This concentration is 240 times greater than the design basis and 4 times greater than the ANSI/ANS limit

3 WIPP Issue - Pu 239 Inventory WIPP design assumed 21.1 MT of FGE Pu 239 evenly distributed across the 175,564 m 3 of WIPP volume DOE/NNSA is proposing to exceed the design by: 6 MT 40 MT, or 61.5 MT All is much less volume and higher concentration These are all significant departures from the design basis None of these conditions have been analyzed to determine that they are acceptable The concentrations are higher than the design basis The containers (CCOs) are substantially different than the design basis

4 WIPP Issues Longevity of Facilities WIPP was constructed in 1988 with an engineered design life of 25 years - until 2013 WIPP began placing wastes in 1999 WIPP experienced a salt truck fire in 2014 WIPP had a radiological event in 2014 that shut down the site WIPP began receiving waste again in 2017 Based on the processing rate, the D&D option will force WIPP to operate until 2062 at least 49 years longer than the design life The D&D program would triple the design life without any planned upgrades to infrastructure - suggesting less than reliable operations and additional equipment replacement

5 WIPP Issue - Regulatory Non-Compliance WIPP permitted by EPA under 40 CFR 191/194 EPA re-certified every five years EPA re-certified WIPP in July 2017 based on application from DOE (CRA) that omitted Planned tripling of the fissile inventory Planned increase in fissile concentration by two orders of magnitude Deposition of surplus Pu 239 in a TRU repository The proposed use of an unapproved waste container (CCOs) Shipment of Special Nuclear Material to a facility with only an industrial security system

6 Regulatory Non-Compliance continued: D&D option violations Additional waste volume exceeds the legal limit for WIPP Waste makeup inconsistent with the legal mandate for WIPP Proposed 40 to 60 metric tons of weapons grade Pu 239 be added to WIPP above the design basis of 21.1 MT Proposed a concentration of Pu-239 of 29.2 kg/m 3 in new waste form compared to the design basis concentration of 0.12 kg/m 3 CCO/CCC container has not been approved for use at WIPP Terminating safeguards for this Special Nuclear Material has not been explained and appears to be problematic Neither the EPA nor NMED have been involved in planning with the DOE

7 Transportation Issue Shipping 40 MTs of Pu would require over 5,500 shipments (46% packing efficiency) 11,000 total shipments including deadhead returns This would take 22 years at 10 shipments per week Each shipment would require the termination of safeguards before shipment At maximum concentration, each shipment contains a critical mass of plutonium Contents of each load are still capable of being used in a nuclear weapon

8 Safeguards Issue Pu 239 in surplus weapon pits Are classified and fall into the Attractiveness Level B, Category I (including the current material residing at SRS) There does not exist any clear path to terminate Safeguards for the material proposed to be shipped to and deposited in WIPP Nuclear materials requiring Safeguards cannot be shipped or stored at WIPP DOE has cited a successful effort to terminate safeguards on legacy wastes from Rocky Flats as a precedent Rocky Flats waste met the intent of the law that authorized WIPP The material attractiveness C before packaging The material was packaged at a concentration that reduced Attractiveness level to D There was only 180 kg of plutonium in the Rocky Flats material

9 Graded Safeguards

10 Currently Required Safeguards Security Physical barriers defense in depth Security designed to defeat motivated and well equipped threats Multiple simultaneous threats Armed guards lethal authority Protection envelop extends to all processes involving SNM including Storage Transportation Processing DOE Proposes Suspending These Requirements for Surplus Plutonium

11 Closing

12 The Academy Recommendation and the Future South Carolina s interest is simple we want the plutonium out of the state the fastest way possible. Demonstrated the many unresolved issues surrounding the use of WIPP for D&D. Even with all of the unresolved issues DOE is going to close MOX the only proven solution to the disposition of the plutonium. MOX does not face any of these issues it is simply a matter of finishing the project. Perform a real baseline cost estimate for MOX and D&D compare and then set public policy How will your report be used - The tie breaker respected organization not subject to politics. Two options: Disapprove D&D» Conduct a real baseline evaluation of the cost to complete» Appropriate more money but less than the DOE says» Keep 2000 people working» Create $50B in commercial value» Meet the obligations of the PMDA and maybe bring the Russians back to the table Approve D&D» SC likely becomes a permanent plutonium storage state» Likely will not overcome the obstacles to implementation in the near future» Close MOX, 2000 people unemployed» Effectively ends the PMDA agreement with the Russians» Ends monitoring of Russian Pu activities» Reduce the possibility of future cooperation or agreements to control nuclear weapons and plutonium The D&D proposal is rife with technical problems, unproven cost basis and an unpredictable outcome. Urge you to conclude that D&D has a low probability of success. That MOX is the only viable solution to the disposition of the plutonium as your colleagues did in 1994.