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DOE OSTI2020

Using the CAP88 Plume Model & Dose Assessment Code for the FTWC Project

The Environmental Protection & Compliance Division (EPC) uses the Clean Air Act Assessment Package – 1988 (CAP88) plume model and dose assessment code to evaluate measured emissions or projected emissions of airborne radionuclides from Los Alamos National Laboratory (LANL) facilities. This software package will use facility data (e.g., stack height and exit velocity), emissions parameters (chemical form and quantity), and environmental data (wind speed and direction) to predict downwind concentrations of radioactive material and subsequent dose to a member of the public at that location. The United States Environmental Protection Agency (EPA) has approved CAP88 for use in demonstrating compliance with the Radionuclide NESHAP2, that portion of the Clean Air Act addressing emissions of airborne radioactive material from Department of Energy facilities. EPC Division has two procedures which discuss the use of CAP88.

61 RADIATION PROTECTION AND DOSIMETRY↗
DOE OSTI2020

Argonne National Laboratory Site Environmental Report (CY2019)

This report discusses the status and the accomplishments of the environmental protection program at Argonne National Laboratory for calendar year 2019. The status of Argonne environmental protection activities with respect to compliance with the various laws and regulations is discussed, along with environmental management, sustainability efforts, environmental corrective actions, and habitat restoration. To evaluate the effects of Argonne operations on the environment, samples of environmental media collected on the site, at the site boundary, and off the Argonne site were analyzed and compared with applicable guidelines and standards. A variety of radionuclides were measured in air, surface water, groundwater, and bottom sediment samples. In addition, chemical constituents in surface water, groundwater, and wastewater were analyzed. External penetrating radiation doses were measured, and the potential for radiation exposure to off-site population groups was estimated. Results are interpreted with respect to the origin of the radioactive and chemical substances (i.e., natural, Argonne, and other) and are compared with applicable standards intended to protect human health and the environment. A U.S. Department of Energy (DOE) dose calculation methodology, based on International Commission on Radiological Protection (ICRP) recommendations and the U.S. Environmental Protection Agency’s (EPA) CAP-88 Version 4 computer code, was used in preparing this report.

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2020

Applicability of Public Dose Limits to Individuals on the Nevada National Security Site

Historically all persons working on the Nevada National Security Site (NNSS) were considered subject to worker dose limits when calculations of potential dose from the air pathway were conducted to demonstrate compliance with Title 42 United States Code (USC) Chapter 85, “The Clean Air Act,” and Title 40 Code of Federal Regulations (CFR) Part 61, Subpart H, “National Emission Standards for Hazardous Air Pollutants (NESHAP).” Calculations were also conducted for the all-pathways potential dose to demonstrate compliance with U.S. Department of Energy (DOE) Order DOE O 458.1 Chg. 3, “Radiation Protection of the Public and the Environment.” The need to evaluate environmental air sampling locations and past regulator questions about the existence of persons potentially subject to public dose limits being on the NNSS drove this assessment (letter from EPA [U.S. Environmental Protection Agency] Region 9 to DOE/Nevada Operations Office, dated September 3, 1999). This assessment also supports determining those persons subject to public dose limits from the all pathways perspective. A person that is a member of the public is subject to public dose limits.

61 RADIATION PROTECTION AND DOSIMETRY↗
DOE OSTI2021

Biological Treatment of Flue Gas Desulfurization Wastewater

In order to limit and mitigate the environmental impacts associated with coal combustion, flue gas desulfurization (FGD) systems have been put into place to reduce the release of contaminates. The main constituent targeted by FGD systems is sulfur oxide gasses (SOx). While FGD systems have been able to achieve high removal rates of SOx gasses, the wastewater effluent requires treatment before release back into the environment. The release of wastewater is heavily regulated by the U.S. Environmental Protection Agency (EPA) and their effluent guideline limitations rule (ELG). The ELG rule set new limits on discharges containing constituents such as selenium, nitrogenous species, mercury, and arsenic in the effluent. This report seeks to give background on abiotic removal methods as well as highlight the most important issues when utilizing biological treatment to treat the FGD wastewater for the constituents of interest mentioned. This report also seeks to discuss the issues of foaming which can occur during biological treatment.

01 COAL, LIGNITE, AND PEAT↗
DOE OSTI2021

Processing Meteorological Data for the CAP-88 PC Model at Los Alamos National Laboratory

The Environmental Protection and Compliance-Compliance Programs (EPC-CP) group at Los Alamos National Laboratory (LANL) uses the Clean Air Act Assessment Package 1988 (CAP-88, Littleton 2020) PC model (Version 4.1) to estimate radiological doses for a set of areal sectors surrounding a release location, in order to satisfy the Environmental Protection Agency (EPA) National Emission Standards for Hazardous Air Pollutants (NESHAP) dose calculation requirement in 40 CFR 61 Subpart H. Among several types of data that must be prepared for CAP-88 input is a text file of meteorological data (“WIND” file), consisting of the joint frequency of wind direction, wind speed, and atmospheric stability categories. EPC-CP produces customized WIND files by running a CAP-88 utility program on a user generated text file of wind data in a different format, known as a STability ARray (STAR) file (Turner, 1964). At LANL, EPC-CP meteorologists prepare customized STAR files with data over desired time periods at selected meteorological towers. A custom program written in Precision Visuals -Workstation Analysis and Visualization Environment (PV-WAVE), a commercial Fortran-like language, is used to read LANL meteorological data and write a STAR file; the executable filename is “Star.out”. However, the outdated PV-WAVE utility program is being phased out by EPC-CP, due to the inefficient process to run it and an inability to modify the code. To preserve the ability to create customized meteorological data for CAP-88 in a way that will be easy to use and maintain, a new replacement utility program, written in the Python programming language, has been developed. The new, improved program reads a data file from any LANL meteorological tower, and at each desired observation time, determines the wind direction, wind speed, and stability categories defined in the CAP-88 documentation. The frequencies of all combinations of the three sets of categories are calculated and written to a file in the STAR format, which can later be converted to a WIND file for input into CAP-88.

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2021

Uranium Immobility in Tims Branch Wetland

The objective of this study was to address an item identified by the Low-Level Waste Disposal Facility Federal Review Group (LFRG) panel during their review of the Savannah River Site’s Composite Analysis. Their concern was that the Tims Branch wetland, which has elevated levels of uranium (U) originating from site operations between 1952 to 1985, may be a secondary source term, posing a human health risk. This report briefly describes three studies dealing with: 1) quantifying the mass of U remaining in the wetland, 2) quantifying the tendency of U to release from Tims Branch sediment, and 3) describing the distribution of U in aqueous and suspended solids in Tims Branch water during episodic storm events. The Tims Branch wetland has been extremely effective for the last 50 years at immobilizing U released to the system. A detailed map including 270,000 gamma spectra of the U distribution in the wetland indicated that 84% of the initial 43,500 kg U introduced in the system remain there after 50 years (Kaplan et al., 2020). The effectiveness of immobilizing U is supported by stream water measurements collected over the last several decades indicating that U concentrations have been consistently below drinking water regulatory limits (i.e., the EPA Maximum Contaminant Level, 30 pg/L (SRNS, 2019)). Furthermore, using contaminated Tims Branch sediments, in situ desorption Kd values (ratio of U sediment/U Water) were extremely high, ranging from 104to 106 L/kg, suggesting the U is strongly bound to these wetland sediments. Finally, a detailed study of Tims Branch stream water properties during episodic rain events indicated that essentially all the U transported in this stream was associated with suspended solids (Batson et al., 1996). Together these findings indicate that the Tims Branch wetland is extremely effective in its present state at immobilizing U and that the small masses of U released downstream will be predominantly in association with suspended solids.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗
DOE OSTI2021

Closeout of Department of Energy Grant – DE-FG02-91CH10493

A Federal Facility Interagency Agreement (lAG), dated February 28,1992, was executed by the State of New York, U.S. Environmental Protection Agency (EPA), and the U.S. Department of Energy (DOE) to address contamination of operations at the Brookhaven National Laboratory (BNL) National Priorities List (NPL) site (site). Section XXXII of the IAG permits New York State to recover expenses for providing administrative and technical services pertaining to the site. The initial mechanism for recovery of State expenses was a DOE grant, identified as DE-FG02-91CH10493, which was established on September 30, 1991. Due to administrative requirements at DOE, the grant was no longer extended and was terminated on May 31, 2020. A Memorandum of Agreement (MOA) was executed on June 1, 2020, to facilitate reimbursement of State expenses moving forward. The grant contained closeout requirements, which included the submission of a report summarizing activities performed by the State of New York. The following sections present the site history and activities performed by New York State as well as the findings and conclusions.

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2020

Integrated Monitoring Volume: A Summary of Monitoring Studies Conducted in Niagaran Carbonate Pinnacle Reefs During Enhanced Oil Recovery with CO 2

The Midwest Regional Carbon Sequestration Partnership (MRCSP) was founded in 2003 as part of the U.S. Department of Energy’s (DOE’s) Regional Carbon Sequestration Partnership initiative. Since its founding, MRCSP has made significant strides toward making CCUS a viable option for states in the region. The public/private consortium, funded through the DOE Regional Carbon Sequestration Initiative, brings together nearly 40 industry partners and 10 states. Battelle, as the project lead, oversees research, development and operations and coordinates activities among the partners. The incremental, phased approach has built a valuable knowledge base for the industry and paved the way for commercial-scale adoption of CCUS technologies. From 2008 to 2020, MRCSP Phase III focused on the development of large-scale injection projects. This report is part of a series of reports prepared under the Midwestern Regional Carbon Sequestration Partnership (MRCSP) Phase III (Development Phase). These reports summarize and detail the findings of the work conducted under the Phase III project. During the MRCSP Phase III monitoring period, over 1 million metric tons of CO 2 was injected into ten Silurian-age (Niagaran) pinnacle reef reservoirs in Otsego County, Michigan that are operated by Core Energy, LLC. There are over 800 pinnacle reefs in northern Michigan, and collectively, these geologic features have sufficient capacity to store several hundred million metric tons of CO 2 . Moreover, most of the reefs are oil-bearing and went through primary production in the 1970s and 1980s; therefore, by injecting CO 2 into the reefs, there is a real opportunity to realize additional (enhanced) oil recovery (EOR) and to permanently store CO 2 after EOR. A key objective of the MRCSP Phase III project is to evaluate the effectiveness of various technologies for monitoring CO 2 that has been injected into deep geologic formations. Monitoring may be required at CO 2 storage sites for a variety of reasons, including to meet UIC Class II (EOR sites) or Class VI (storage only sites) permit requirements or EPA greenhouse gas reporting rule requirements or to qualify for tax credits under the 45Q tax credit rule. The results of this monitoring study should prove useful to operators considering using carbonate pinnacle reefs of Northern Michigan for CO 2 storage.

01 COAL, LIGNITE, AND PEAT↗
DOE OSTI2020

State Charlton & MRCSP 1 Characterization Well Report

The Midwest Regional Carbon Sequestration Partnership (MRCSP) was founded in 2003 as part of the U.S. Department of Energy’s (DOE’s) Regional Carbon Sequestration Partnership initiative. Since its founding, MRCSP has made significant strides toward making CCUS a viable option for states in the region. The public/private consortium, funded through the DOE Regional Carbon Sequestration Initiative, brings together nearly 40 industry partners and 10 states. Battelle, as the project lead, oversees research, development and operations and coordinates activities among the partners. The incremental, phased approach has built a valuable knowledge base for the industry and paved the way for commercial-scale adoption of CCUS technologies. From 2008 to 2020, MRCSP Phase III focused on the development of large-scale injection projects. This report is part of a series of reports prepared under the Midwestern Regional Carbon Sequestration Partnership (MRCSP) Phase III (Development Phase). These reports summarize and detail the findings of the work conducted under the Phase III project. This report describes the efforts to drill and complete a well in the St. Peter sandstone for characterization and evaluation of storage potential in norther Michigan. However, as presented in this report, the well was not drilled and completed up to the intended target intervals due to drilling related difficulties. While the drilling issues were being resolved, the new Class VI injection well regulations were finalized by the US EPA. MRCSP efforts focused on evaluating CO 2 storage and containment using site characterization, modeling, and monitoring in conjunction with the ongoing CO 2 -EOR operations in the same area. This report describes work associated with the initial test well, the State Chester and MRCSP Well No. 1, drilled to a depth of about 7,968 feet TVD, and subsequently plugged and designated as temporarily abandoned. A high-level overview of data collected and analyzed is provided for shallower units.

01 COAL, LIGNITE, AND PEAT↗
DOE OSTI2021

A Circular Economy for Solar Photovoltaic System Materials: Drivers, Barriers, Enablers, and U.S. Policy Considerations

As PV capacity increases, owners are also decommissioning older system assets. Estimates based on a 30-year lifetime assumption found that cumulative U.S. end-of-life (EoL) PV modules could total one million metric tons (Mt) by 2030 and up to 10 million Mt by 2050 (Weckend, Wade, and Heath 2016). Beyond maintenance replacements, early retirements that are due to efficiency upgrades and extreme weather, as well as PV deployment beyond earlier expectations, would increase these projections. PV system owners must evaluate equipment management options for used modules and system components retired during maintenance activities, refurbishment, repowering and system decommissioning. PV manufacturers must also evaluate material management options from customer returns, defects, and scrap. Management options for early retired and EoL PV system material include reuse, repair for reuse, recycling-based resource recovery, storage, and disposal. Disposal of PV system material increases the burden on landfill capacity, while reuse, repair for reuse, and recycling-based resource recovery (reuse/repair/recovery) options salvage valuable materials and provide secondary market opportunities and ancillary benefits (Weckend, Wade, and Heath 2016; EPA 2019c; SWEEP 2019). PV system owners may also decide store used modules and components as spares, or in the interim before a reuse or EoL management decision is made. Despite potential secondary market opportunities and the potential benefits associated with the repair/reuse/recovery of PV system material, anecdotal evidence suggests that in the United States decommissioned PV modules are stored, landfilled or otherwise disposed of (Salim et al. 2019; CPUC 2019b; DTSC 2019b; NREL 2019a). Some modules are being disposed of in municipal nonhazardous landfills and federally regulated hazardous treatment, storage, and disposal facilities, and others are being stored in warehouses until economically viable repair/reuse/recycling becomes available (CPUC 2019b; DTSC 2019b; NREL 2019a; Libby and Shaw 2018). As awareness of current practices grows, and the demand for critical PV module material increases, U.S. industry stakeholders, regulators, and policymakers are starting to (1) consider solutions to drive and enable environmentally sustainable materials management decisions and behaviors and (2) identify barriers to a circular economy for PV system materials. Circular economy principles attempt to transition from a "take-make-consume-dispose" linear economic system to a circular system that allows for the long life, and the reuse/repair/recovery of products and materials (Ellen MacArthur Foundation 2020). We begin this report by summarizing the drivers, barriers, and enablers to a circular economy for PV system materials in the United States. We then report on our analysis of federal and state regulatory considerations that may impact the repair/reuse/recovery of PV materials, and potential civil and criminal liabilities associated with noncompliance. We then discuss state policies and initiatives in the United States that expressly address PV system decommissioning and repair/reuse/recovery of PV materials. We conclude by providing case studies of U.S. business models for the repair/reuse/recovery of PV system materials. Our results are based on legal and literature-based research and interviews with solar industry stakeholders, regulators, and policymakers.

14 SOLAR ENERGY↗
DOE OSTI2021

Analytical Action Level Calculator in Turbo FRMAC (FY2020 Close-Out) [Slides]

Objectives: Automate the labor-intensive process of generating Analytical Action Levels (AALs) in Turbo FRMAC to shorten the timeline for planning sampling campaigns and sample analysis during a response. Make the tool output results in a format that is easily imported to RadResponder as a Mixture for use in Analysis Request Forms. Deliver training to EPA on using this new tool in Turbo FRMAC (Delayed due to COVID.

42 ENGINEERING↗
DOE OSTI2021

Air Pathway Dose Modeling for the E-Area Low-Level Waste Facility

The US Department of Energy (DOE) Order 435.1 performance assessment (PA) process (USDOE 1999) prescribes a performance objective (10 mrem y -1 ) for evaluating atmospheric releases of radionuclides from DOE low-level waste (LLW) disposal facilities. The potential dose to an individual from exposure to radionuclides released into the atmosphere from LLW disposals can be estimated by application of radionuclide -specific dose-release factors (DRFs) (mrem Ci -1 ) to estimated flux rates (Ci y -1 ) at a particular time and location. In Revision 0 of this report, Lee (2006) calculated DRFs for potential atmospheric releases of 15 volatile radionuclides from seven ELLWF disposal units in support of the 2008 ELLWF PA (WSRC 2008). The mainframe version of the US Environmental Protection Agency’s (EPA) dose model CAP88 was used in the Revision 0 assessment. In Revision 1 of this report (Dixon and Minter 2017), the site-specific Savannah River National Laboratory (SRNL) atmospheric dose models MAXDOSE-SR version 2013 (Stone and Jannik 2013a) and MAXINE version 2017 (Bell 2017) were used to calculate DRFs for ten radionuclides. This work (Revision 2) supersedes Revision 0 (Lee 2006) and Revision 1 (Dixon and Minter 2017) of this report. The Revision 2 method for estimating new DRFs for the ELLWF disposal units is described in this report.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗
DOE OSTI2021

Soil Sample Workplan in Support of the Site 300 Explosives Waste Treatment Facility Ecological Risk Assessment Pursuant to the Hazardous Waste Facility Permit (Part V, Special Condition #14 a-f)

The Department of Toxic Substances Control issued the Final Hazardous Waste Facility Permit to Lawrence Livermore National Laboratory, Site 300 in 2017. As part of the continual process to ensure waste treatment emissions are not impacting ecological receptors, LLNL analyzed soil samples in the vicinity of the Explosive Waste Treatment Facility (EWTF) Burn Units (i.e., Burn Cage and Burn Pan) and the Detonation Pad. Soil samples were analyzed by EPA Solid Waste 846 Methods for furans, explosives, metals, and semi-volatile compounds. In all samples, furans, explosives, and semi-volatile organic compounds were not detected. Metals were detected at concentrations below background levels. This soil sample plan will sample the same four downwind areas of the Burn Units and the same downwind areas of the Detonation, as well as including four new sample locations. The four new locations will be located to the northeast and southwest of the Burn Units and Detonation (as shown in Figure 3). The constituents to be analyzed are in Tables 7 and 8. Perchlorate was not identified as a constituent of concern in the 2007 Soil Sampling Plan. However, for this plan, all soil samples will be analyzed for perchlorate. Nitrate and all CAM17 metals have been added to the sampling plan to comply with DTSC comments received in correspondence dated June 4, 2021. After completion of the sampling event, a soil sample report will be submitted to DTSC in accordance with requirements specified in the Hazardous Waste Facility Permit, Part V, Special Conditions 16 a-f. This proposed soil sampling plan will be fully implemented no later than one year after receiving DTSC approval, in accordance with the Hazardous Waste Facility Permit, Part V, Special Condition 15.

45 MILITARY TECHNOLOGY, WEAPONRY, AND NATIONAL DEF↗
DOE OSTI2021

CY20 AIHA Internal Audit of ALAB and NIF-HPL and CY20 Management Review of ALAB

An internal audit was performed in ALAB to ISO 17025:2017; EPA LQST and AIHA requirements using the current AIHA Checklist. The scope of the internal audit was the annual review of AIHA-accredited industrial hygiene methods performer in both ALAB and NIF HPL. The Internal audit resulted in 3 deficiencies and 3 comments.

37 INORGANIC, ORGANIC, PHYSICAL, AND ANALYTICAL CH↗
DOE OSTI2021

Notice of Submittal – 2020 Radionuclide Air Emissions Report for Los Alamos National Laboratory

Enclosed is the Calendar Year 2020 Radionuclide Air Emissions Report for the Los Alamos National Laboratory (LANL). The submittal is in compliance with 40 CFR 61 Subpart H. The highest effective dose equivalent to any member of the public from LANL operations in 2020 is 0.29 millirem. This maximally exposed individual location is a business at 132 DP Road, Los Alamos, NM. The annual dose is well below the EPA standard of 10 millirem per year as established in Subpart H.

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2021

Argonne National Laboratory Site Environmental Report (CY2020)

This report discusses the status and the accomplishments of the environmental protection program at Argonne National Laboratory for calendar year 2020. The status of Argonne environmental protection activities with respect to compliance with the various laws and regulations is discussed, along with environmental management, sustainability efforts, environmental corrective actions, and habitat restoration. To evaluate the effects of Argonne operations on the environment, samples of environmental media collected on the site, at the site boundary, and off the Argonne site were analyzed and compared with applicable guidelines and standards. A variety of radionuclides were measured in air, surface water, groundwater, and bottom sediment samples. In addition, chemical constituents in surface water, groundwater, and wastewater were analyzed. External penetrating radiation doses were measured, and the potential for radiation exposure to off site population groups was estimated. Results are interpreted with respect to the origin of the radioactive and chemical substances (i.e., natural, Argonne, and other) and are compared with applicable standards intended to protect human health and the environment. A U.S. Department of Energy (DOE) dose calculation methodology, based on International Commission on Radiological Protection (ICRP) recommendations and the U.S. Environmental Protection Agency’s (EPA) CAP 88 Version 4.1 computer code, was used in preparing this report.

37 INORGANIC, ORGANIC, PHYSICAL, AND ANALYTICAL CH↗
DOE OSTI2020

Quality Assurance Plan for Federal Guidance Report 16

Federal Guidance Report No. 16 will provide risk coefficients for use in projecting the probability of cancer morbidity or mortality from exposure to environmental radionuclides. The derivation of nuclide-specific risk coefficients involves multiple steps, with each step relying on the accuracy of the previous step as well as the numerical data utilized within each step. Thus, to ensure the quality of the derived risk coefficients, it is necessary to evaluate and confirm the quality and proper implementation of input data at each step of the derivation. The Oak Ridge National Laboratory (ORNL) dosimetry research team currently has two largely independent software codes for deriving radiation dose estimates, dose coefficients, and cancer risk coefficients for internally deposited radionuclides: DCAL and QCAL. The agreement of derived values based on alternate codes is an important step in quality assurance (QA) of the risk coefficients produced in this project. DCAL is an integration of the dosimetric software and numerical databases developed at ORNL over the past 25 years for the EPA’s Office of Radiation and Indoor Air (ORIA). QCAL was developed in 2015 to serve as a substitute for DCAL while DCAL was undergoing revision and to provide QA for the updated version of DCAL. The complex methodology employed in the derivation of cancer risk coefficients presents a challenge for QA, and as such, this report describes the QA steps used by the ORNL dosimetry team in this process as implemented in DCAL and QCAL for Federal Guidance Report No. 16.

61 RADIATION PROTECTION AND DOSIMETRY↗
DOE OSTI2020

Nuclear Criticality Safety Assessment of Criticality Control Containers without Moderation Control at the Waste Isolation Pilot Plant

The Waste Isolation Pilot Plant (WIPP) provides for safe, permanent disposal of government-owned transuranic (TRU) and TRU mixed wastes. Receipt and disposal of waste at the WIPP site began in March 1999. The Sandia report, Consideration of Nuclear Criticality When Disposing of Transuranic Waste at the Waste Isolation Pilot Plant, addressed potential nuclear criticality safety issues based on the projected inventory characteristics known at the time [1]. As designs for inventory, waste forms, and disposal packages have changed, new analyses have been performed, and updates have been made to address any potential effects to the WIPP safety basis. New analyses performed include Saylor 2017 [2] and Brickner 2019 [3], which address certain waste containers with specified loadings under post-closure conditions. Both examined several hypothetical scenarios and included analyses to bound (from a criticality potential standpoint) credible configurations that could occur at WIPP during the repository regulatory post-closure disposal time period for feature, event, and process (FEP) considerations—10,000 years. During this post-closure period at WIPP, the screening of FEPs is governed by the risk-based standards and implementing regulations of the US Environmental Protection Agency (EPA) (i.e., 40 CFR 191 and 40 CFR 194, respectively) [4,5]. An FEP screening can be based on either a low-consequence or low-probability rationale. A low-probability rationale includes either (a) a qualitative rationale that the FEP is not credible or (b) a quantitative demonstration that the probability is less than 10-4 in 104 years. In this evaluation, a qualitative lowprobability rationale of not credible is used by demonstrating that bounding configurations of the waste are not critical. The demonstration of subcriticality is through quantitative calculations, but a probability of criticality is not evaluated. Rather, the rationale for this evaluation is that bounding configurations with an effective neutron multiplication factor (keff) well below the upper subcriticality limit (USL) make criticality incredible. Reference [2] documented a nuclear criticality assessment of the WIPP repository for disposal of dilute surplus plutonium materials using the Dilute and Dispose Approach and packaging in criticality control overpacks (CCOs). The CCO is the waste disposal container recently designed to allow for up to 380 fissile gram equivalent (FGE) 239 Pu per drum, which is a higher fissile loading than typical waste containers. The CCO consists of a criticality control container (CCC) positioned by upper and lower plywood spacers within a standard 55 gal drum. The CCC is used to establish a geometry control for fissile materials during transportation and WIPP emplacement operations. The current WIPP waste acceptance criteria for CCO payloads limit beryllium to less than or equal to 1% by weight of the waste contents and require the waste form to be non-machine compacted. Reference [2] considered two scenario progressions—room closure from salt creep, hereafter referred to as the reconfigured dry scenario, and flooding with brine, hereafter referred to as the reconfigured wet scenario. The subsequent drying out of the reconfigured wet scenarios was also considered. For all scenarios, subcriticality was maintained when 50 g of B 4 C (acting as a neutron absorber) per CCC was intermixed within the plutonium disposition waste form. The analysis used a waste form description that limits the amount of moderation that could be present within the waste form (i.e., it limits the amount of water and polyethylene that could be present based on planned processing conditions). This analysis to evaluate increased limits on the amount of moderation that could be present was performed as a companion to Reference [2] to address concerns associated with verifying moisture and/or plastic contents of waste materials following packaging of dilute surplus plutonium in the CCO. To that end, this analysis used the models and methods from Reference [2] to evaluate a more generic base waste form consisting of water and polyethylene that is more similar (and nearly identical) to the generic waste forms utilized in other models/analyses supporting the TRU Package Transporter Model II (TRUPACTII) safety analysis [6] (all are without moderation controls). The waste form in this analysis uses a base mixture of 75% water and 25% polyethylene, the total amount of which is varied to determine the optimum moderation to fissile material (H/Pu) ratio. The fissile loading is maintained at up to 380 FGE 239 Pu (modeled as PuO 2 ) per CCO with an additional 545 g of beryllium (to bound the 1% by weight contents restriction) and 50 g of B 4 C intermixed per CCO. The beryllium content (1% by weight) is based on the total allowed waste weight (this does not include packaging and container weights). Figures ES-1 and ES-2 display summary results, showing that with this model including 50 g of B 4 C per CCO, the system keff remains under 0.85 for all moderator amounts and provides a significant margin against post-closure criticality under postulated bounding conditions for compaction. Figure ES-1 compares an infinite model with a room model at the initial emplacement spacing and under full radial compaction. Full radial compaction places each CCC in direct contact and does not credit any anticipated spacing associated with current post-closure geomechanical modeling of the repository [7]. The effects of variations in the H/Pu ratio were evaluated by varying the amount of the water/polyethylene component of the waste model, with fissile loading maintained at 380 239 Pu FGE. Similarly, Figure ES-2 illustrates how various amounts of B 4 C per CCO influence k eff at different radial compactions, all at the H/Pu ratio of 200 (in the room array model). Therefore, while the results from Saylor 2017 [2] modeled more realistic process limits associated with packaging of dilute surplus plutonium, this analysis demonstrates that limits on moderation (plastic and water content) are not necessary to ensure subcriticality in the WIPP repository, provided the requisite B 4 C absorber is present.

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