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Recommendations to Improve the Nuclear Regulatory Commission Reactor Licensing and Approval Process

Due to the urgency around climate change and associated goals for clean energy transition, and Battelle Energy Alliance's (BEA) and Idaho National Laboratory's (INL) role as the nation's nuclear energy laboratory, numerous stakeholders have asked for BEA’s thoughts and recommendations to reduce the time and costs associated with licensing new reactors at the U.S. Nuclear Regulatory Commission (NRC). As an M&O contractor for an FFRDC, BEA is a long-term partner with the Government in seeking to achieve clean energy goals, yet has a level of independence needed to appropriately evaluate this topic. The views herein are informed by extensive BEA experience supporting nuclear energy endeavors including ongoing discussions with current and former regulators, applicants, and licensees. With this background in mind, the United States benefits from having an agency such as the NRC, which is viewed internationally as the leader in nuclear safety licensing and regulation. Nonetheless, while acknowledging the important nuclear safety role satisfied by the NRC, it is apparent that one of the most significant time and resource intensive activities for new reactor developers is the NRC licensing process. The time and cost to obtain NRC licenses add significant financial stress for new reactor projects and may result in abandonment of projects or failure to even begin new projects. The challenge is particularly acute for advanced reactors which may raise unique or new regulatory questions and may be smaller in size, resulting in a much higher proportional impact from regulatory and cost challenges. This situation presents a particularly troublesome risk for the nation given the urgency in which utilities are working to transition to clean, non-carbon-emitting energy sources like nuclear energy. Reforms to the NRC licensing process have the potential to greatly increase certainty and support the successful progress of new reactors. The NRC can retain its world-class nuclear safety reputation while becoming a world leader for regulatory efficiency and a critical enabler to the clean energy transition. This report describes potential NRC reforms, focusing on those with a statutory connection. Recognizing the potential tradeoffs with any proposed changes, the report attempts to highlight those considerations in the analysis of the reforms. The recommendations are presented as a set of options for consideration. Unless noted, they are independent options, offering stakeholders the option to select a subset for further consideration. Although difficult to calculate precise time improvements for some of the changes, the reforms have the potential for substantial improvements, perhaps even by a factor of two.

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

Continuous-Energy ENDF/B-VIII.0 Cross Section and SCALE 6.2.4 Performance for Nuclear Criticality Safety Applications: 1 H, C, 58,60 Ni, 182,183,184,186 W, 235,238 U, 239 Pu

As part of the nuclear data evaluation and validation cycle, the ENDF/B-VIII.0 cross-section library released in 2018 requires testing to determine areas of improvement and deterioration. Previous work by the authors investigated the performance of 16 O, 56 Fe, and 63,65 Cu cross sections, with this study acting as an extension of the prior work. In addition to the isotopes and nuclear criticality safety benchmarks of interest to the prior work, benchmarks from the International Criticality Safety Benchmark Evaluation Project Handbook were selected for their k eff sensitivity to 1 H, C, 58,60 Ni, 182,183,184,186 W, 235,238U, or 239 Pu cross sections and were modeled in the SCALE code system maintained by Oak Ridge National Laboratory. In total, 253 benchmark configurations were selected for their sensitivities and modeled using SCALE 6.2.4 Criticality Safety Analysis Sequences (CSAS) continuous-energy Monte Carlo k eff calculations. This collection includes and expands upon the 99 benchmarks in the prior work. The AMPX-processed ENDF/B-VIII.0 library was decomposed into individual ENDF/B-VIII.0 datum libraries for each isotope of interest. Doing so allowed for the individual substitution of an ENDF/B-VIII.0 cross section in the place of ENDF/B-VII.1, determining isotope-specific effects of ENDF/B-VIII.0 relative to ENDF/B-VII.1. Full library calculations with entirely ENDF/B-VII.1 data or entirely ENDF/B-VIII.0 data were also executed. As a measure of performance, the average relative deviation was determined as the ratio of the deviation between calculated and experimental keff to the propagated calculational and experimental uncertainty. With calculated full library and isotope-specific ENDF/B-VIII.0 k eff ’s, an optimized combination of data libraries was estimated and confirmed with SCALE calculations. This showed that reverting 239 Pu, 58 Ni, 16 O, and 65 Cu cross sections to ENDF/B-VII.1 resulted in improved performance relative to the full ENDF/B-VIII.0 library. Across all 253 benchmarks, the average relative deviation was 1.29σ for the full ENDF/B-VII.1 library, 1.17σ for the full ENDF/B-VIII.0 library, and 0.97σ for the optimized combination. The reversion of 239 Pu, 58 Ni, 16 O, and 65 Cu cross sections to ENDF/B-VII.1 in the 99 benchmarks of the prior work resulted in further improved experimental agreement compared to the previously reported improvement from 16 O and 65 Cu alone. Therefore, it is suggested that applications with significant sensitivities to 239 Pu, 58 Ni, 16 O, and 65 Cu consider their choice of nuclear data library.

98 NUCLEAR DISARMAMENT, SAFEGUARDS, AND PHYSICAL P↗

Hand Calculations for Nuclear Criticality Safety – Primer Revision

The document “ Hand Calculation Methods for Criticality Safety – A Primer, ” was published by the authors (Los Alamos National Laboratory report LA-14244-M) in December 2006 to provide an overview of the most common hand calculation methods used for criticality safety analysis. Hand calculation methods can be used as a starting point for more advanced calculations, and in many circumstances, they can provide sensitivity and perturbation information quicker than using a criticality code, such as KENO or MCNP. This report has been revised to augment existing basis information and example problems for each of the methods discussed: 1-group and modified 1- group diffusion theory, core-density conversions, buckling conversions, limiting surface density method, density analog method, surface density method, and solid angle method. This primer discusses the applicability of the various methods, illustrates how they are used, and provides an interpretation of the example problem results. The example problems provided are simple, practical problems, and the reference data to solve each example problem is provided. This paper will provide an overview of the Primer revision and how it can be useful for new Nuclear Criticality Safety practitioners.

73 NUCLEAR PHYSICS AND RADIATION PHYSICS↗

Considerations for a New Solution Reactor for Nuclear Criticality Safety Applications-a White Paper

This document presents considerations for a new solution reactor as noted in the United States (US) Department of Energy (DOE) Nuclear Criticality Safety Program (NCSP) Five Year Plan. The solution reactor tasking is noted in collaboration with the French Institut de Radioprotection et de Sûreté Nucléaire (IRSN). This document presents General Considerations (GC) and Specific Considerations (SC) that support the GCs.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

Hand Calculations for Nuclear Criticality Safety — Primer Revision [Abstract]

The document “ Hand Calculation Methods for Criticality Safety –A Primer, ” was published by the authors (Los Alamos National Laboratory report LA-14244-M) in December 2006 to provide an overview of the most common hand calculation methods used for criticality safety analysis. Hand calculation methods can be used as a starting point for more advanced calculations, and in many circumstances, they can provide sensitivity and perturbation information quicker than using a criticality code, such as KENO or MCNP. This report has been revised to augment existing basis information and example problems for each of the methods discussed: 1-group and modified 1-group diffusion theory, core-density conversions, buckling conversions, limiting surface density method, density analog method, surface density method, and solid angle method. This primer discusses the applicability of the various methods, illustrates how they are used, and provides an interpretation of the example problem results. The example problems provided are simple, practical problems, and the reference data to solve each example problem is provided. This paper will provide an overview of the Primer revision and how it can be useful for new Nuclear Criticality Safety practitioners.

96 KNOWLEDGE MANAGEMENT AND PRESERVATION↗

Benchmark of the Chlorine Worth Study Experiments in Support of Chlorine Nuclear Data Validation for Nuclear Criticality Safety

The Chlorine Worth Study (CWS) was a critical experiment to address an urgent need for thermal chlorine nuclear data validation in plutonium systems. This urgent need is tied directly to plutonium recycle and recovery operations in the plutonium facility at Los Alamos National Laboratory, where exceptionally conservative criticality safety limits are used because no credit is taken for the neutron capture by chlorine. The experiment used weapons-grade plutonium metal plates clad in stainless steel, known as the PANN (plutonium aluminum no nickel) ZPPR (zero power physics reactor) plates. The plutonium was reflected and moderated by high-density polyethylene and included combinations of polyvinyl chloride (PVC) and chlorinated polyvinyl chloride (CPVC) as absorbers. The experiment and benchmark included three configurations mimicking 30 g 239 Pu/L plutonium, 300 g 239 Pu/L plutonium, and 600 g 239 Pu/L plutonium in an aqueous chloride solution. Uncertainties in the benchmark included five broad categories: (1) criticality measurement, (2) mass and density, (3) dimensions, (4) material compositions, and (5) positioning. The largest contribution to the overall uncertainties for all three cases came from the material compositions, in particular the PVC and CPVC absorber compositions. A detailed model was created to be a near match (that is within expectations of transport code users) and a simplified model was created to minimize offset dimensions and expedite modeling for code validation. Sample calculations were completed in MCNP6.3 with ENDF/B-VIII.0 and ENDF/B-VII.1 nuclear data. For the detailed and simplified models, the average difference between the computed and experimental k eff was 951 pcm. CWS will serve as the key validation experiment for nuclear criticality safety in support of aqueous chloride operations. The sensitivity to the chlorine capture cross section is orders of magnitude greater than other existing benchmarks. The current limits, as defined by nuclear criticality safety, are 520 g Pu per batch, i.e. the minimum critical mass of the Pu solution infinitely reflected by water [Criticality Handbook: Volume II, (1969)]. This extremely conservative critical mass limit does not credit any neutron capture by chlorine (in particular neutron capture by 35 Cl) and greatly impedes the throughput required for current and future operations.

73 NUCLEAR PHYSICS AND RADIATION PHYSICS↗

Importance of a Safety Culture

Objectives: By the end of this offering, participants will be able to: Identify what does and does not define culture; Specify the main drivers of why we need a Nuclear Safety Culture; Detail the primary contributors to LANL's Nuclear Safety Culture history; Explain how LANL's values, behaviors, and actions demonstrate our commitment to a Nuclear Safety Culture; Indicate at least one new piece of knowledge as a result of this course.

61 RADIATION PROTECTION AND DOSIMETRY↗

Radiological Safety Analysis Computer (RSAC 7.2) Presentation

This presentation will be for the graduate seminar class for the University of New Mexico. We will discuss the Radiological Safety Analysis Computer (RSAC) version 7.2, a critical tool in radiological consequence analysis within the nuclear safety domain. We will begin with an introduction to radiological consequence analysis and the importance of dose modeling in nuclear safety, referencing key regulatory frameworks such as DOE-STD-3009 and 10 CFR 20. The presentation will provide an overview of RSAC, including its history, primary functions, and the inputs and outputs involved in its calculations. A detailed examination of RSAC's atmospheric dispersion model, based on the Gaussian plume methodology, will be presented, highlighting how meteorological factors influence the results. We will discuss the regulatory alignment of RSAC with DOE and NRC guidelines, emphasizing the assumptions required for compliance and the balance between conservative and realistic inputs. The presentation will also address the limitations and assumptions inherent in RSAC, comparing it with other consequence analysis codes like MACCS, HotSpot, and RASCAL. An example RSAC run will be demonstrated, showcasing a hypothetical accident scenario and interpreting the resulting dose calculations. Finally, we will introduce new ideas to enhance the current RSAC framework. This future work aims to provide multi-industry adaptability and integration with new dispersion models, addressing the evolving needs of DOE and NRC. The presentation will conclude with a discussion on RSAC's ongoing role in nuclear safety and the opportunities for future innovation.

computer program↗

Qualitative and Quantitative Evaluation for Representative Human Reliability Analysis Methods

The Korea Institute of Nuclear Safety (KINS) is the regulatory expert organization established by the Korean government to strengthen the nation’s technical capabilities relating to nuclear safety regulation. KINS oversees the technical aspects of nuclear safety regulation, including safety reviews, inspections, education, and safety research—all conducted based on technical knowledge and accumulated regulatory experience. In 2023, KINS requested that Idaho National Laboratory (INL) validates representative human reliability analysis (HRA) methods used throughout the world, thus affording KINS with a basis for determining an HRA method adequate for its domestic regulatory purposes. The present paper mainly examines INL’s efforts in this regard. The resulting INL study covered four representative HRA methods widely used by nuclear utilities and regulatory institutes. These methods were qualitatively evaluated by applying specific evaluation criteria and determining how well each method reflected critical HRA issues. For this assessment, INL benchmarked the Halden International HRA Empirical Study. Using the Halden empirical data, along with information on human failure events (HFEs), the present study employed the selected HRA methods to estimate human error probabilities (HEPs) for the HFEs. It also performed statistical analyses to compare the HEPs predicted via the HRA methods against those from the Halden empirical data.

99 - GENERAL AND MISCELLANEOUS↗

Availability of Critical Benchmark Experiments for the Pebble Tanker Transportation Model for Nuclear Criticality Safety Validation of TRISO Pebbles

This study addresses the need for comprehensive investigations into TRi-structural ISOtropic (TRISO) fuel pebble transportation validation. In this work, an exploratory model, the pebble tanker(PT), was developed with the aim of facilitating the validation of nuclear criticality safety calculations in the context of industrial-scale transportation of TRISO fuel. The PT model was designed to investigate the availability and applicability of critical benchmark experiments crucial for assessing the transportation of these pebbles. This work incorporated sensitivity/uncertainty (S/U) similarity studies to quantify the applicability of critical benchmark experiments and to address nuclear data uncertainties in the context of TRISO transportation. Two container models were investigated: one for the Hermes-type pebble and one for the Pebble Bed Modular Reactor (PBMR)–type pebble. The models were simplified, considering fuel, containment, and either water or air, to enable a focus on the underlying physics of applications involving TRISO fuel pebbles using the PT model. A crucial aspect under consideration was the capacity of the transport package to hold pebbles while ensuring subcriticality in the flooded state. An approach in the criticality validation process involves assessing the similarity between systems through an integral index parameter evaluation. This involves calculating a correlation coefficient (referred to as c k ) based on shared nuclear data–induced uncertainty between a benchmark experiment and the application of the PT model. To facilitate this analysis, the SCALE tools, particularly the CSAS6-Shift, TSUNAMI-3D-Shift, and TSUNAMI-IP sequences, were employed for comprehensive studies in neutronics and S/U analysis. Our findings showed that there are sufficient critical experimental benchmarks to perform this validation of the PT model in the most reactive state, i.e. when the tanker is flooded. This paper provides valuable insights into validating a transport package for Generation IV TRISO fuel pebbles.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Y-12 Nuclear Criticality Safety Program Health Model: Development, Use and Benefits

The Y-12 National Security Complex (Y-12) operates seven diverse enriched uranium processing facilities and maintains a comprehensive nuclear criticality safety (NCS) program. Given the magnitude of the hazard, the NCS program receives significant oversight. Describing the scope and health of the Y-12 NCS program to sometimes non-expert stakeholders with limited time had historically focused on recent events and “hot topics” which did not always convey sufficient context (i.e., how to differentiate between an individual performance issue and a systemic concern). Y-12 created the NCS Program Health (NCSPH) Model to provide a complete and holistic framework to quantify and communicate NCS program health. The model is constructed in a tiered fashion with the top tier broken into three (3) Tier 2 elements, fourteen (14) Tier 3 elements, and 104 Tier 4 and 5 elements. This granularity ensures every feature of the NCS Program is accounted for and stakeholders can see how these features support the collective whole. The model is used as the framework for NCS communications including program plans, reports, health surveys, and meeting agendas. The model has substantially improved stakeholder appreciation for the entirety of the NCS program and how events and assessment results factor into an overarching conclusion on NCS program health. While some details are Y-12 specific, the NCSPH model can easily be tailored for any other site with an NCS program.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Improved Verification and Validation Testing and Tools including Nuclear Criticality Safety Applications with the MCNP6.3® Code [Abstract]

A new Python-based framework has been developed to enable a more consistent layout with automatable setup, execution, and documentation of all verification and validation (V&V) test suites previously established for use with the MCNP code. In this paper, the new general framework for the V&V test suites is discussed, including information on all of the current capabilities and plans for future capabilities. For nuclear criticality safety applications, the existing V&V benchmark problems within the criticality, extended criticality, and analytic k-effective test suites have been ported into this new framework. In addition, the status and updates to the Rossi-alpha and subcritical multiplicationtest suites will be discussed. Some V&V results exercising new MCNP6.3 capabilities will be demonstrated.

97 MATHEMATICS AND COMPUTING↗

A Benchmarking Framework for Evaluating Large Language Model Capabilities in Nuclear Reactor Safety Applications

Large language models (LLMs) are increasingly capable of answering technical questions, synthesizing domain knowledge, and supporting engineering workflows. For nuclear science and engineering, these capabilities require careful, domain-specific evaluation before they can be credibly incorporated into safety-related activities, regulatory review, or technical decision support. This paper presents preliminary results from benchmarking framework for evaluating LLM capabilities in nuclear contexts. The framework is organized into three evaluation categories: nuclear fundamentals, general dual-use knowledge, and plant specific knowledge. These categories are intended to distinguish general nuclear engineering competence from broader technical reasoning and more context-dependent nuclear knowledge. Initial evaluations focus on nuclear fundamentals using questions representative of the knowledge expected of a nuclear professional engineer. Results indicate that contemporary frontier models perform at a high level and substantially exceed the performance of older model generations, with some models approaching saturation of the current benchmark. These findings suggest both the rapid improvement of LLM capabilities in specialized technical domains and the need for more discriminating evaluation methods. The paper presents the benchmark structure, preliminary model-comparison results, and ongoing work. This work supports development of verifiable, responsible, and safety-conscious methods for assessing AI systems in nuclear engineering applications.

21 - SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLAN↗

Post-closure Nuclear Criticality Safety Evaluations for Disposition of Criticality Control Overpacks at the Waste Isolation Pilot Plant

The Waste Isolation Pilot Plant (WIPP) is a geological repository in southern New Mexico that provides for disposal of transuranic (TRU) wastes from atomic energy defense activities. The Sandia National Laboratories (Sandia) Report, Consideration of Nuclear Criticality When Disposing of Transuranic Waste at the Waste Isolation Pilot Plant, addresses nuclear criticality safety based on the projected inventory characteristics for the initial compliance certification application of WIPP in 1996. As the inventory, waste forms, and disposal package designs change, revised or new analyses are necessary to demonstrate acceptability for these configurations within the WIPP safety basis and compliance with 10,000-year post-closure standards of the US Environmental Protection Agency (EPA). Saylor and Scaglione evaluated criticality control overpacks (CCOs) in 2017 based on conservative assumptions for post-closure repository structural conditions with resulting effects on containers and container spacing, The Saylor and Scaglione evaluation of CCOs addressed a single waste configuration that represents the Surplus Plutonium Disposition Program’s dilute and dispose waste form and composition. This initial CCO study demonstrated that 50 grams of boron carbide (B 4 C) per CCO is sufficient to ensure post-closure criticality safety based on a well-mixed waste composition, and Oak Ridge National Laboratory (ORNL) subsequently determined that this amount of B 4 C does not require constraints on moisture or plastic present as moderator. The Saylor and Scaglione analysis conservatively assumes repository room closure that eliminates all space between fissile gram equivalent (FGE) 239 Pu masses. The close-packed array was selected based on limited availability of repository salt creep modeling results at that time. In 2019, Brickner provided additional evaluations for pipe overpack containers (POCs), building on the conservative basis provided by Saylor and Scaglione. Brickner’s 2019 analysis made use of new geomechanical data for post-closure spacing that rely on advances in repository modeling as documented in the work by Reedlunn and Bean. This current CCO evaluation for generic waste materials expands on earlier work performed at ORNL and includes evaluation of CCOs across a much broader range of possible waste compositions and geometries. This evaluation is intended to provide input for the required feature, event and process (FEP) screening to determine if post-closure criticality must be included as an event in the 10,000-year regulatory evaluation. As such, the approach to modeling post-closure criticality presented in this report has been coordinated with the Sandia team responsible for FEP screening. The resulting analysis supports disposition of fissile materials in the CCO containing up to 380 FGE 239 Pu and expands conditions acceptable for disposal of fissile material in CCOs. This evaluation builds on the methodology of Saylor and Scaglione and Brickner, using the most recently available geomechanical data for CCO spacing under salt creep compaction scenarios provided by Reedlunn and Bean. The broad range of fissile material configurations analyzed in this report are intended to account for configurations that may occur during the post-closure disposal time period, and it also includes waste configurations that are not physically possible to support analysis of conditions that influence neutron fluence.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

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.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗