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LANL Waste Management

All waste at Los Alamos National Laboratory (LANL or the Laboratory) is subject to one or more types of regulations and must be managed properly. This document describes LANL requirements for waste generated and managed by waste generators and Treatment and Storage Facilities (TSFs) to ensure compliance with legal mandates and Laboratory requirements as necessary to protect human health, safety, and the environment. This document has been revised as part of a process in which the Laboratory systematically plans, documents, executes, and evaluates its management of regulated waste streams.

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Fueling Nuclear Research at MFC: The Environmental Backbone of Nuclear Operations

The National Environmental Policy Act (NEPA) review guidelines are an essential part of the approval process of any construction or modification being done at Idaho National Laboratory (INL). The Material and Fuels Complex (MFC) Environmental team is responsible for writing and reviewing Environmental Impact Statements (EISs), Environmental Assessments (EAs), Environmental Compliance Permits (ECPs), Air Permitting Applicability Determinations (APADs), and other NEPA compliance documentation. This documentation allows for innovation in MFC research by permitting the introduction of new laboratory equipment, research facilities, and materials for researchers to use in their experiments. Without the work of the Environmental team, nuclear research and operations at MFC would not be possible.

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Performance Assessment for the E-Area Low-Level Radioactive Waste Disposal Facility at the Savannah River Site: Chapter 9

This chapter summarizes the results of PA compliance against all relevant PA POs and measures. The final inventory limits presented in Chapters 7 and 8, as well as the methodology employed, provide assurance that POs will be met throughout the compliance periods. Deterministic and stochastic closure analyses also demonstrate a minimal likelihood of exceeding POs. Potential peaks post compliance are also addressed where future work is proposed to improve the understanding in actual uncertainties.

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Nitrate and Nitrite at Hanford – From Tanks to Natural Attenuation

Washington River Protection Solutions, LLC (WRPS) contracted Pacific Northwest National Laboratory (PNNL) in support of their maturation testing and analysis to develop and deploy an ambient temperature solidification/stabilization process for low-activity waste (LAW) (referred to as “grout” in this report). The intent of this effort is to support a sample-and-send regulatory and processing strategy in the Hanford 200 West Area, specifically considering grout waste forms disposal at Hanford in the Integrated Disposal Facility (IDF). Currently the disposal of grouted LAW is not an option because the IDF is not permitted to receive this waste form. The material presented in this report is intended to help inform the U.S. Department of Energy (DOE), the site operating contractors, regulatory agencies, and stakeholders of the future implications of IDF disposal of a grouted LAW waste form, specifically for the behavior of nitrate (NO 3 - ) and nitrite (NO 2 - ) at the Hanford. The only calculation of nitrate release from a hypothetical grouted LAW inventory in the IDF showed that the overall release was slightly above the compliance limit of 45 mg/L nitrate and 3.32 mg/L nitrate after 1000 years (Asmussen et al. 2019). As such, uncertainty around the impact of nitrate and nitrite release from the IDF was identified in the recent National Academies of Sciences study of Hanford supplemental LAW by both the national laboratory team and Hanford stakeholders (Bates et al. 2023). However, these calculations (and others for the IDF involving secondary waste grout) may be conservative as no nitrate and nitrite retention in the grout waste form was assumed, nor any attenuation in the subsurface. There is evidence from the literature of processes that can attenuate nitrate migration both in the waste form and in the Hanford subsurface. If found to be technically defensible and likely to occur in the IDF and associated subsurface, then these processes should be included in modeling of the IDF to represent the behavior of nitrate and nitrite more accurately. Doing so would remove unnecessary conservatism in the modeling projections and reduce the uncertainty in assessments of facility compliance of a grouted LAW waste form in the IDF.

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Glass Formulation and Testing with RPP-WTP HLW Simulants (Final Report)

This report presents the results from HLW glass formulation work that was conducted at the Vitreous State Laboratory of The Catholic University of America during Part B1 of the RPP-WTP Project (formally known as TWRS-P) in support of the Privatization contractor, BNFL, Inc. Glass formulation development is required to provide data that are essential for design of the vitrification facility in the near term and for safe and reliable operation of that facility in the longer-term. These data also form the bases from which contractually and technically acceptable immobilized high-level waste (IHLW) products will be devised. Glass formulation therefore impacts many aspects of the vitrification facility design, overall process economics, and contractual compliance. As an integral part of the overall system design, development of glass formulations requires input from many sources including tank waste characterization, pretreatment process definition, flow sheet development, and processing schedules. Accordingly, the glass formulation effort must be responsive to new information as the facility design basis evolves.

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Integrating the Safety Evaluation for a Molten Salt Reactor Operation and Fuel Cycle Facility Application

Molten salt reactor (MSR) sites may include additional elements of the nuclear fuel cycle beyond those of the existing fleet. In the existing fleet, the individual elements of the fuel cycle typically have been located on different sites and licensed separately. Providing robust separation between hazards remains a useful safety practice for MSRs. Although the different elements of the fuel cycle at a nuclear site that includes MSRs may transfer material between processes more frequently than prior practices, providing adequate separation between distinct facilities avoids the potential for adverse interactions. Additionally, some elements of the MSR fuel cycle, such as fuel salt preparation or waste stabilization, may be more efficient to share among multiple nearby reactors, and nuclear sites that include MSRs may also include other reactor classes. Hence, discrete MSR fuel cycle facilities located at a common site could be physically separated with robust barriers—albeit potentially connected by piping—and licensed individually. This report describes the hazards of individual elements of representative MSR fuel cycle facilities, including their relationship to overall site level hazards. The report maps the regulatory compliance aspects of the individual MSR fuel cycle elements (e.g., fuel salt preparation, reactor, waste stabilization) to existing and developing regulations, as well as describes current and developing site-level regulations from an MSR perspective.

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Interactive Visualizations for Communicating Compliance and Sustainability Statements in Annual Site Environmental Reports - 20419

The annual reports of organizations are a recurring type of public disclosure that communicates what an organization has done and/or plans to do. Worldwide, organizations use annual reports as powerful instruments for communication that is rich in narrative content and visuals. From the perspective of the leadership of an organization, statutory annual reports are communication devices to stakeholders. By analogy, from the perspective of stakeholders, the annual reports are learning devices that presents stakeholders with contents to generate knowledge about an organization. We have chosen the online accessible U.S. Department of Energy (DOE) Annual Site Environmental Reports (ASERs) as a collection of resources for communicating and learning the environmental management strategies on environmental compliance and environmental sustainability. Environmental Compliance 'consists of regulatory compliance and monitoring programs that implement federal, state, and local requirements, agreements, and permits.' Environmental Sustainability 'promotes and integrates initiatives such as energy and natural resource conservation, waste minimization, green remediation, and the use of sustainable products and services.' Interactive visualizations of textual data designed with visual analytics software can allow stakeholders to interact with statements on the environmental management strategies by performing diverse actions that promote learning. These actions include annotating, comparing, filtering, navigating, selecting and sharing relevant statements. We expect that the possibility of these multiple actions in an interactive manner help stakeholders to learn more effectively about the environmental strategies at U.S. DOE sites. The current case study for the project is a collection of 1,894 annotated (value-added) statements (sentence text) from the eight chapters of the 2017 Savanah River Site (SRS) annual site environmental report. The preliminary interactive visualizations are available online. (authors)

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Update to the Performance Assessment for the Savannah River Site Saltstone Disposal Facility - 20124

In 2019, Savannah River Remediation developed a revision to the performance assessment (PA) on behalf of the U.S. Department of Energy (DOE) Savannah River Operations Office (SR) for the near-surface disposal of low-level waste at the Savannah River Site (SRS) Saltstone Disposal Facility (SDF). Soluble waste from SRS Tank Farms undergoes salt processing to remove cesium and other high activity constituents. The low-activity decontaminated salt solution (DSS) is then immobilized by mixing it into a cementitious waste form known as saltstone. After mixing, the saltstone is poured into leak-tight concrete vaults, known as saltstone disposal units (SDUs), where the waste form cures. By the time of facility closure, the SDF is expected to consist of 15 SDUs with a combined capacity of 1.06 E+09 L (280 Mgal) of cured saltstone. The facility operates under a Disposal Authorization Statement (DAS) from DOE and a permit from the South Carolina Department of Health and Environmental Control (SCDHEC). Since the start of operations in 1990, the SDF has received almost 6.7 E+07 L (18 Mgal) of DSS, resulting in the safe disposal of 2.7 E+16 Bq (7.3 E+05 Ci) of activity. Due to the radioactive decay of short-lived contaminants, the total remaining activity in the disposed waste is estimated to be approximately 1.4 E+16 Bq (3.9 E+05 Ci), as of September 2018. The Disposal Authorization Statement requires a demonstration that the system of engineered and natural features of the disposal facility will limit releases from the facility and be protective of human health and the environment for at least the next 1,000 years. The long-term performance of the facility was evaluated under the requirements of the DoE's Radioactive Waste Management Manual (US DOE Manual 435.1-1). Simulations were performed to demonstrate that the disposal facility would meet performance objectives specified in the manual. The evaluation was based on numerical models that simulate the releases of contaminants from the saltstone waste form. Contaminants were transported through groundwater and air pathways to points of assessment to evaluate compliance. In addition, the potential consequences of an inadvertent human intrusion (IHI) were also evaluated. In accordance with the guidance and recommendations in US DoE's technical standard for DAS, deterministic and probabilistic analyses were performed to demonstrate the SDF system, which includes the engineered cover system, the SDUs, the waste form, and the natural features of the site, provides a reasonable expectation that saltstone disposal will meet performance objectives. Post-closure doses to future members of the public (MOP) were evaluated; dose estimates from the air pathway were well below the 1.0 E-04 Sv/yr (10 mrem/yr) performance objective within 1,000 years, and the calculated doses to the MOP from all exposure pathways, including the groundwater and air pathways, were well below the 2.5 E-04 Sv/yr (25 mrem/yr) performance objective within 1,000 years. Doses following an assumed intrusion event within the facility boundaries were well below the IHI performance objectives, where the acute IHI dose was below the acute IHI dose performance objective of 5.0 E-03 Sv (500 mrem) and the chronic IHI dose was below the chronic IHI dose performance objective of 1.0 E-03 Sv/yr (100 mrem/yr) within 1,000 years. (author)

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2020 NEPA Polychlorinated Biphenyl (PCB) Risk Assessment

The Waste Isolation Pilot Plant (WIPP) facility is a U.S. Department of Energy (DOE) operating repository 654 m below the surface in a thick salt formation in southeastern New Mexico. The DOE disposes transuranic (TRU) waste produced from atomic energy defense activities at the WIPP facility. A portion of the waste shipped to the WIPP facility contains TRU radionuclides co-mingled with polychlorinated biphenyls (PCBs), which fall under U.S. Environmental Protection Agency (EPA) regulations implementing the Toxic Substances Control Act (TSCA). This report documents the risks of PCBs co-mingled with TRU waste (hereafter designated as PCB/TRU waste) designated for disposal at the WIPP facility. This analysis is input to the National Environmental Policy Act (NEPA) assessment by the DOE Carlsbad Field Office (CBFO) for the proposed increase of the WIPP facility disposal area to include additional waste panels (but not to increase the legislated WIPP volume). This analysis is not a compliance calculation to support a certification renewal nor does it support a planned change request (PCR) or planned change notice (PCN) to be submitted to the EPA.

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Hanford Site Composite Analysis Special Analysis: Inventory and Solid Waste Release Modeling for the LLBG Sensitivity Case - UCAQ-22-01 Inventory Discrepancies for 218-E-12B, 218-W-3A, and 218-W-3AE in the Hanford Site Composite Analysis

This environmental calculation file (ECF) documents the methodologies, assumptions, and results of four sensitivity analyses that reevaluate the representativeness of solid-waste radionuclide inventory and release rate from three solid waste sites included in the recently completed Hanford Site Composite Analysis (CA) (DOE-RL-2019-52, Composite Analysis for Low-Level Waste Disposal in the Hanford Site Central Plateau (FY 2020), Rev. 1) (hereinafter called the CA Update). Specifically, this ECF reevaluates the representativeness of the base case inventory and radionuclide waste release rates from three solid waste sites (i.e., 218-E-12B, 218-W-3A, and 218-W-3AE) and two radionuclides (i.e., carbon-14 [C-14] and technetium-99 [Tc-99]). These three waste sites and two radionuclides were identified as being the most significant contributors to groundwater contamination and dose in the CA Update for the Inner Area boundary at times periods after the compliance period. This ECF first evaluates the representativeness of the C-14 and Tc-99 inventory and second, radionuclide release rates for the three waste sites1. If the inventory and release rates assumed in the CA Update are determined to be not representative, as hypothesized in the CA Update, then this ECF evaluates the impact of more representative inventories and release rates on the transfer of radionuclides to the vadose zone. The four analyses described in this ECF are as follows: 1) 218-E-12B C-14 Inventory and Release Rate Sensitivity Case – Determine the representativeness of the C-14 inventory and associated waste release rate from the 218-E-12B waste site assumed in the CA Update. If the inventory and associated waste release are more appropriately characterized as being different from the assumptions in the CA Update, then update the predicted C-14 release rate and compare the results to the results presented in the CA Update (DOE/RL-2019-52); 2) 218-W-3A C-14 Inventory and Release Rate Sensitivity Case – Determine the representativeness of the C-14 inventory and associated waste release rate from the 218-W-3A waste site assumed in the CA Update. If the inventory and associated waste release are more appropriately characterized as being different from the assumptions in the CA Update, then update the predicted C-14 release rate and compare the results to the results presented in the CA Update (DOE/RL-2019-52); 3) 218-W-3AE Tc-99 Release Rate Sensitivity Case – Determine the representativeness of the Tc-99 inventory and associated waste release rate from the 218-W-3AE waste site assumed in the CA Update. If the inventory and associated waste release are more appropriately characterized as being different from the assumptions in the CA Update, then update the predicted Tc-99 release rate and compare the results to the results presented in the CA Update (DOE/RL-2019-52); 4) 218-W-3AE Tc-99 Release Footprint Sensitivity Case – Determine the representativeness of the Tc-99 waste area footprint for the 218-W-3AE waste site assumed in the CA Update. If the footprint of the waste is more appropriately characterized as being different from the assumptions in the CA Update, then update the predicted Tc-99 release rate and compare the results to the result presented in the CA Update (DOE/RL-2019-52).

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NEVADA NATIONAL SECURITY SITE 2021 WASTE MANAGEMENT MONITORING REPORT AREA 3 AND AREA 5 RADIOACTIVE WASTE MANAGEMENT SITES

Environmental monitoring data are collected at and around the Area 3 and Area 5 Radioactive Waste Management Sites (RWMSs) within the Nevada National Security Site (NNSS). This report summarizes the 2021 environmental data to provide an overall evaluation of RWMS performance and to support environmental compliance and performance assessment (PA) activities.

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Application of GOTHIC to Groundwater Transport Analysis - 20152

Migration of pollutants and hazardous wastes, potentially containing radioactive isotopes, via groundwater transport is a concern at most waste cleanup sites. Predictive analysis can be used to evaluate mitigating actions intended to minimize impact on the environment and public exposure. GOTHIC is a multipurpose thermal hydraulics code that is used extensively in the nuclear industry for design, licensing and operation evaluations. It combines the capabilities of typical one-dimensional system codes and the essential features of Computational Fluid Dynamics (CFD) codes for three-dimensional analysis. There are other codes that are specifically developed for groundwater transport analysis and the results presented here are consistent with prior analyses. However, GOTHIC has some unique features that offer advantages for applications related to nuclear waste. Most importantly, it has been developed and maintained under a Quality Assurance program in compliance with the requirements of 10CFR50 Appendix B [2] and applicable portions of ASME NQA-1 [3] since 1995. Available GOTHIC capabilities that make the code especially useful for groundwater transport of nuclear materials include: - Tracking of any number of tracer elements for contaminants and other species of interest; - Radioactive decay and progeny of tracer elements; - Adsorption/desorption of tracer elements; - Tracking of any number of dissolved gases; - Release and absorption for dissolved gases; - Vapor phase tracking; - Non-Newtonian fluid modeling. The general porous body modeling approach makes GOTHIC well suited to groundwater transport analysis. The multi-region modeling approach used by GOTHIC simplifies model construction for regions of varying hydrologic characteristics and focuses the computational effort on regions of particular interest while simultaneously capturing the macroscopic response and any feedback effects across the larger domain. The applicability of GOTHIC to groundwater transport applications is demonstrated by comparing code results with available analytic or semi-analytic solutions for groundwater behavior. (authors)

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Issue Resolution During the Development of the Performance Assessment for the Savannah River Site Saltstone Disposal Facility - 20125

In 2019, Savannah River Remediation developed a revision to the performance assessment (PA) on behalf of the U.S. Department of Energy (DOE) Savannah River Operations Office (SR) for the near-surface disposal of low-level waste at the Savannah River Site (SRS) Saltstone Disposal Facility (SDF). Soluble waste from SRS Tank Farms undergoes salt processing to remove cesium and other high-activity constituents. The low-activity decontaminated salt solution (DSS) is then immobilized by mixing it into a cementitious waste form known as saltstone. After mixing, the saltstone is poured into leak-tight concrete vaults, known as saltstone disposal units (SDUs), where the waste form cures. By the time of facility closure, the SDF is expected to consist of 15 SDUs with a combined capacity of 1.06 E+09 L (280 Mgal) of cured saltstone. The facility operates under a Disposal Authorization Statement from DOE and a permit from the South Carolina Department of Health and Environmental Control (SCDHEC). Since the start of operations in 1990, the SDF has received almost 6.7 E+07 L (18 Mgal) of DSS, resulting in the safe disposal of 2.7 E+16 Bq (7.3 E+05 Ci) of activity. Due to the radioactive decay of short-lived contaminants, the total remaining activity in the disposed waste is estimated to be approximately 1.4 E+16 Bq (3.9 E+05 Ci), as of September 2018. The Disposal Authorization Statement requires a demonstration that the system of engineered and natural features of the disposal facility will limit releases from the facility and be protective of human health and the environment for at least the next 1,000 years. The long-term performance of the facility was evaluated under the requirements of the DoE's Radioactive Waste Management Manual (US DOE Manual 435.1-1). Simulations were performed to demonstrate that the disposal facility would meet performance objectives specified in the manual. The evaluation was based on numerical models that simulate the releases of contaminants from the saltstone waste form. Contaminants were transported through groundwater and air pathways to points of assessment to evaluate compliance (i.e., 100 m from the SDUs). In addition, the potential consequences of an inadvertent human intrusion (IHI) were also evaluated. A number of issues were overcome during the development of these simulations. These issues were identified as part of internal technical reviews. Simulations are developed by people and people make mistakes, so the internal technical review process is a vital step in PA development. Specific examples of resolved issues include a unit-conversion error, an inappropriate definition for a model boundary condition, a model time-stepping issue, and an error in the calculation for the buildup of contaminants in soil. Actions taken to address these issues resulted in an improved product with a better supported technical basis and more defensible results. The identification and correction of these issues are discussed. By understanding these issues, model developers and technical reviewers working on PAs in the future may avoid repeating these types of mistakes. Transparency with respect to these mistakes builds trust between waste management sites, regulators, and stakeholders. (authors)

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EPC-ES WIPP WAC Appendix A Equivalence Support Measurements 2019-2020

Characterization of low-level waste (LLW) at Los Alamos National Laboratory (LANL) is primarily performed by the Environmental Protection and Compliance - Environmental Stewardship (EPC-ES) Characterization Services team and/or the Nuclear Process Infrastructure (NPI--9) Nuclear Material Support Services team (hereafter referred to as the gamma spectroscopy teams). The gamma spectroscopy teams use portable high-purity germanium (HPGe) detector systems for the nondestructive assay (NDA) characterization of LLW. Controlled-approved procedures and processes for the use of such systems to assay LLW items are currently in place. Additionally, a number of performance studies have been conducted by the gamma spectroscopy teams to support the efficacy and quality of assay results generated by the established NDA process.

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Thermal Process Technology for Nuclear Applications - 20379

ANSTO's Synroc technology has been developed to provide a safe, secure matrix for the immobilization and final disposal of radioactive waste. Synroc technology will be used to manage radioactive wastes from the production of the radioisotope Molybdenum-99 (Mo-99). This paper shall outline various stages of the process development with specific reference to the thermal treatment technology of calcination. Calcination is a key step in the Synroc process [1-2].The rotary thermal processing system includes: an advanced heating element design for increased robustness and ease of remote operation and maintenance, an enhanced modular design of components for ease of remote maintenance in a hot cell and in compliance with hot cell radioactive environment requirements for safety, reliability and maintainability. In addition to thermal treatment of waste from nuclear medicine production, this technology provides solutions for a variety of nuclear materials processing applications including sintering UO{sub 2} pellets for reactor fuel rods, oxidation of UO{sub 2} pellets, swarf, and powder to U{sub 3}O{sub 8}, de-nitration of Uranyl nitrate and hydrofluorination of UO{sub 2} pellets. The paper will also discuss thermal processing solutions for a range of nuclear applications. (authors)

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Annual Site Environmental Report (ASER) 2019 Summary

In order to maintain human and environmental health, Los Alamos National Laboratory follows state and federal environmental regulations, including compliance with permits, limits, and inspections. These regulations are in place to maintain radiation protection, waste management, and air and water quality.

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Plutonium Oxidation State Distribution under WIPP Relevant Conditions (Rev. 2)

The oxidation state of plutonium in the Waste Isolation Pilot Plant (WIPP) environment has been a topic of interest since the initial compliance certification application. Plutonium (Pu) was initially expected to be present primarily as Pu(IV), but since the presence of Pu(III) could not be ruled out, it was also included in performance assessment (PA) calculations. The redox of the other variant actinides, uranium (U) and neptunium (Np), are also coupled to the plutonium redox. This led to a position in performance assessment calculations that is commonly referred to as “50/50”. In which half of the PA realizations assume solubility is dominated by the low oxidation state [U(IV), Np(IV), Pu(III)] and the other half assume solubility is dominated by the higher oxidation state [U(VI), Np(V), Pu(IV)]. Recently, a joint group of WIPP project participants from Los Alamos National Laboratory (LANL), Sandia National Laboratories (SNL), and the Department of Energy’s Carlsbad Field Office (DOE-CBFO) agreed on a new path forward for the oxidation state model in PA which will decouple the redox active actinides and will instead consider their redox as a function of E h . This will take the current binary approach and turn it into a system with four possible redox states.

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Development of a Conditioned System-Level Groundwater Model to Evaluate Long-Term Groundwater Impacts within a Performance Assessment - 20115

A preliminary performance assessment (PA) of single-shell tank Waste Management Area (WMA) A-AX located at the U.S. Department of Energy (DOE)'s Hanford Site in southeastern Washington is being conducted to satisfy the requirements of DOE Order 435.1 [1] as it relates to closure of the single-shell radioactive waste tanks in the WMA A-AX tank farms. A PA assesses the fate, transport, and impacts of radionuclides within a low-level radioactive waste disposal facility in its assumed closure configuration and the subsequent potential doses to humans over a 1,000-year compliance period and a 10,000-year performance evaluation period. The WMA A-AX preliminary PA evaluation is structured around the complementary use of process-level and system-level models to calculate the facility performance against established DOE Order 435.1 [1] performance objectives. Process-level models are those that represent a detailed phenomenological representation of processes of concern in the PA. Process models typically only represent one or a few of the components of the PA, such as groundwater flow and transport, and must be integrated with other modeling elements to perform PA calculations. System-level models are those that are abstracted from the process models, retaining the essential features of the process model, while allowing integration of all aspects of the PA in a single modeling framework. System-level models are often characterized by coarser numerical discretization, lower dimensionality, or other similar simplifications compared to the process-level model. Traditionally, a three-dimensional (3-D) process-level model is utilized primarily to evaluate the long-term impact on groundwater and the potential doses to individuals who consume contaminated groundwater. System-level models are also utilized to evaluate the groundwater pathway in PAs. These models typically have reduced dimensionality (1-D) and are conditioned utilizing flow fields (Darcy fluxes) and moisture content distributions that are abstracted from the process level models. The abstraction approach assures that the flow field in both models is consistent for a specific set of input parameters for flow, differing only in the discretization and dimensionality of the two models. The preliminary WMA A-AX PA incorporates a detailed representation of the geological system and hydraulic properties within the 3-D model STOMP{sup C} numerical code so that the effects of relevant features and processes on water flow and radionuclide transport in the subsurface can be evaluated. The complementary system-level model is developed utilizing the GoldSim{sup C} code to implement a simplified, 1-D equivalent model to represent the groundwater pathway. Contaminant transport through the vadose zone and unconfined aquifer for Tc-99 and I-129 were evaluated in each of the models. Adjustments to the saturated portion of the GoldSim{sup C} 1-D model were required to mimic the dispersion effect captured with the 3-D STOMP{sup C} model. Once this conditioning was conducted, highly similar results for the transport of Tc-99 and I-129 were achieved at the point of calculation, located 100 m downgradient from the WMA A-AX fenceline. These radionuclides represent elements that are regarded as primary dose drivers in the PA groundwater pathway analysis. The high degree of conformance between the two models suggests that the use of the equivalent 1-D system model is suitable for evaluating the full suite of radionuclides that will be released from the tank sources within WMA A-AX over the 1,000-year compliance period and over the 10,000-year evaluation period. (authors)

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