Department of Energy 

Carlsbad Field Offlce 

P. O. Box 3090 

Carisbad, New Mexico 88221 

July 25, 2007 

Mr. Ron Curry, Secretary 

New Mexico Environment Department 

1190 St. Francis Dr., Suite N4050 

Santa Fe, New Mexico 87502 

Subject: Permittees' Assessment of the Potential Impacts to Human Health and the 

Environment from Leaving the SWB Containing Drum BN10161094 

Emplaced in the WIPP 

Dear Secretary Curry: 

As committed in our letter on July 20, 2007, this letter presents the permittees' assessment 

of the potential impacts to human health and the environment from leaving the standard 

waste box (SWB) oontaining drum BN10161094 emplaced in the Waste Isolation Pilot Plant 

(WIPP). This letter also describes the WIPP waste emplacement activities that the 

permittees have implemented to provide your office time to review this submittal. 

Assessment of Potential Impacts to Human Health and the Environment 

The permittees have reviewed information known about the contents of this drum and have 

concluded that leaving the emplaced container in the WIPP repository is protective of 

human health and the environment. Enclosure 1 to this letter provides a detailed 

explanation of the contents of drum BN10161094 (contained in a SWB) which indicates that 

the drum contains debris waste from an approved waste stream (ID-RF-S5300-A). This 

drum is not part of either BNINW216 or BNINW218 waste streams and, as a result, actions 

relating to this drum are not reportable under Compliance Order HWB 04-07(CO). 

Because of the significant knowledge of the waste stream, the process used to generate the 

waste, specific information on the drum, and specific information on over 100 drums in the 

waste stream generated in the same time period, there is sufficient certainty about the drum 

to assess its potential impact on human health and the environment. 

This drum was part of an approved lot covered by headspace gas sampling data and 

Enclosure 1 shows that the appropriate hazardous waste numbers were assigned. In 

addition, underground ventilation monitoring covering this room shows that there has been 

no increase in volatile organic compounds since emplacement of the drum (see Enclosure 

2). At estimated emplacement rates, the subject SWB will be isolated from underground 

ventilation within approximately two months. 

The presence of, and the potential impact from, prohibited items is addressed in Enclosure 

1. The only prohibited item contained in drum BN10161094 is the presence of liquid in two 

internal containers totaling less than 0.75 cups (which are most probably water-based 

solutions). Enclosure 1 rules out the characteristics of ignitability, reactivity, and corrosivity 

and then addresses the potential impacts as if the liquid were actually corrosive. 

CBFO: NT P: DCG: G S:07-1701: U FC5822.00 
Secretary Curry -2- July 25, 2007 

As illustrated, even if it is assumed that the liquid in drum BN10161094 is an acid, the acid 

would not likely reach the outside of the drum even if it was spilled from its internal 

containers, and particularly not breach the SWB. The permittees strongly believe that the 

evidence provided in Enclosure 1 demonstrates that leaving drum BN10161094 in place is 

protective of human health and the environment. 

Waste Emplacement Strategy 

Drum BN10161094 is contained in a SWB in Room 6, Panel 4 with Room 5 being the next 

room to be filled. In order to provide an opportunity for the New Mexico Environment 

Department (NMED) to determine if retrieval of the subject SWB is necessary, the 

permittees have altered the typical waste emplacement process. Before resuming 

emplacement activities in Room 6, waste will be emplaced in Room 5 to the extent possible. 

WIPP can only accommodate 20 rows of CH waste in Room 5 in order to allow adequate 

ventilation to accommodate later access to Room 6. Based on the current inventory of 

waste on the surface at the site, WIPP can receive 19 additional CH shipments which 

should provide sufficient CH waste to fill 20 rows of waste in Room 5. It is estimated that 

the downloading of 20 rows of CH waste to Room 5 will be accomplished within 

approximately two weeks. Once 20 rows of CH waste have been emplaced in Room 5, 

waste emplacement activities for Room 6 will resume. 

It is estimated that Room 6 will be filled approximately two months after resumption of 

emplacement of CH waste in Room 6. Once full, Room 6 is projected to contain 

approximately 168 rows of CH waste. If the decision is made to retrieve the SWB 

containing drum BN10161094 after Room 6 is full, it will take approximately four months to 

move the necessary CH waste, retrieve the SWB, and re-emplace the CH waste in Room 6. 

During this period, disposal of additional CH waste at WIPP will be suspended. Any 

decision to require retrieval of the subject SWB after the day waste emplacement in Room 5 

is suspended, and waste emplacement in Room 6 resumes, would start increasing the 

impacts on both the ability to retrieve the subject SWB and the ability to continue 

operations. 

In summary, 20 rows of waste can be emplaced in Room 5 without impact to the retrieval 

plan. As Room 6 is filled, retrieval operations become increasingly difficult up to the point 

Room 6 is full. Following full emplacement in Room 6(isolation from the ventilation system) 

retrieval operrations become impractical. 

Corrective Action Plan (CAP) for AMWTP Corrective Action Reoort (CAR) # 28920 

Our letter to you on July 20, 2007, provided a description of the occurrence and the 

associated root cause analysis. Subsequent to the issuance of the letter, the permittees 

have approved the AMWTP CAR# 28920 corrective action plan identifying actions required 

for long term program compliance. The CAR (including the CAP) is provided as Enclosure 

3. Independent of the AMWTP, the permittees will implement onsite oversight of AMWTP 

payload assembly and transportation related activities prior to resumption of shipments. 

The Carlsbad Field Office (CBFO) will transition the transportation authorization at AMWTP 

to Central Characterization Project (CCP) as quickly as practical as a long term corrective 

action. 

CBFO: NTP: DCG:GS:07-1701: U FC5822.00 
Secretary Curry -3- July 25, 2007 

Conclusion 

As demonstrated in this letter and enclosures, the subject SWB containing drum 

BN10161094 poses no risk to human health and the environment, and if allowed to remain 

in WIPP, WIPP will continue to be protective of human health and the environment. 

The work associated with retrieval of the subject SWB, if required, poses additional risks of 

industrial accidents and radiological exposure, which increase with time as the subject SWB 

in Room 6 has more waste placed in front of it. 

The permittees will monitor the implementation and effectiveness of the corrective actions 

specified in AMWTP CAR #28920 and its required CAP. CBFO will notify NMED when 

actions are completed that will allow shipments of waste from AMWTP to resume. Prior to 

final CAR closure, CBFO will verify completion of corrective actions with a surveillance. 

If you have questions or require additional information, please contact David Moody at (505) 

234-7300. 

Sincerely, 

David C. Moody, e ic ard D. Raaz, General Manager 

Carlsbad Field 0 shington TRU Solutions LLC 

Enclosure(s) 

cc: w/enclosures 

I. Triay, EM-3 *ED 

F. Marcinowski, EM-10 ED 

L. Piper, CBFO ED 

V. Daub, CBFO ED 

J. Plum, CBFO ED 

C. Gadbury, CBFO ED 

K. Watson, CBFO ED 

M. Navarrete, CBFO ED 

R. Patterson, CBFO ED 

E. Sellers, NE-ID ED 

P. Divjak, BBWI ED 

J. Goldstein, NMED ED 

J. Bearzi, NMED ED 

S. Zappe, NMED ED 

J. Reyes, EPA ED 

T. Peake, EPA ED 

D. Raaz, WTS ED 

D. Haar, WTS ED 

T. Sellmer, WTS ED 

W. Wiercbicki, WRES ED 

WIPP Operating Record 

CBFO QA File 

CBFO M&RC 

CBFO: NTP: DCG:GS:07-1701: UFC5822.00