2nd Response Submittal to the EPA Enclosure 3

Completeness Question

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40 CFR 194.15(A)(2) MONITORING 

1-15-1 Water Level Fluctuations in SNL-13. 

DOE/WIPP-12-3489 p. 143 states "SNL-13 was also excluded [from the Culebra groundwater 

analysis] due to a sudden rise and then sudden stabilization following the drilling of a new oil or 

gas well nearby." Please address the following:

1. Identify and provide the location, depth, and purpose of the 'new' nearby wells.

2. What activities took place at the nearby wells during the time of the changes in SNL-13, 

such as fluid injection? Provide pressure histories, volumes and fluid types, fluid enhancements 

(e.g. fracking fluids or proppants).

3. Provide a chronological history of the activities in the nearby wells compared to the 

"sudden" changes in adjusted freshwater heads recorded in SNL-13.

4. Were water levels in other monitoring wells influenced by activities at nearby wells?



40 CFR 194.15(A)(2) MONITORING 

1-15-2 Shaft Extensometers Not Taking Recordings. 

DOE is not replacing the failed monitoring instruments in the shaft. However, EPA Section 42, 

Monitoring requirements expects, " ...extent of deformation ..." and "...brittle deformation..." to 

be monitored. Please provide a justification to discontinue measuring these characteristics in 

the WIPP shafts as these measurements are used to calibrate numerical models and predict 

closure rates. Additionally, identify how this requested information will be addressed in the 

future.



EPA's Completeness Questions Received December 17, 2014

1
2nd Response Submittal to the EPA Enclosure 3

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40 CFR 194.15(A)(2) MONITORING 

1-15-3 Derivation of Annual Culebra Water Level Map. 

CRA-2014 Section 42.8 Changes or New lnformation Since the CRA-2009 discusses changes 

to the process used to derive the Culebra groundwater flow parameters that is used to prepare 

the annual water level map. Please address the following:

1. For each yearly calculation (ERMS 558589, Section 2.3.2.2), if the monitored freshwater 

heads have changed, do the 100 calibrated T-Fields need to be recalculated? If not, why?

2. ERMS 557633 Section 2.1 states, "The PA MODFLOW model T (transmissivity), A 

(anisotropy) and R (recharge) input fields are appropriately averaged across 100 realizations, 

producing a single average MODFLOW flow model." Provide information as to how averaging 

is done with examples.

3. For the averaged MODFLOW model, T (transmissivity), A (anisotropy) and R (recharge) 

are fixed while a subset of the boundary conditions is modified (ERMS 557633, Section 2.1). 

Please describe how the new boundary conditions are determined and implemented. If this 

simply involves raising or lowering the heads along the boundaries to best match the observed 

water levels within the modeled area, describe how well the assigned boundaries honor the 

water levels in the nearest monitoring wells both inside and outside the model area.

4. If the step-by-step creation of the annual Culebra water level map is the same as that 

provided during 2012 and 2013 inspections, please denote as such. If generating the annual 

water level map differs from what has been provided during inspections, please provide these 

steps.

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2nd Response Submittal to the EPA Enclosure 3

Completeness Question

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40 CFR 194. 23 MODELS AND COMPUTER CODES

1-23-1 Continuing Validity of Kds. 

CRA-2014 Appendix PA, Table PA-1 states that the Culebra Matrix Partition Coefficients (Kds) 

are, "Carried over from CRA-2009 PABC ." Please provide the rationale for the assumption that 

the CRA 2014 Kds can be same as those used in the CRA-2009 despite the changes in the 

organic ligand content and the 2012 inventory since the last PA. Additionally, provide a 

discussion of the potential impacts of the organic kitty litter added to the LANL waste on the 

Culebra Kds.



Note: The 

discussion of 

the potential 

impacts of the 

organic kitty 

litter added to 

the LANL 

waste on the 

Culebra Kds 

will be 

addressed in 

the response to 

1-C-1

40 CFR 194. 23 MODELS AND COMPUTER CODES

1-23-2 Continuing Validity of T-Fields. 

CRA-2014 Appendix PA, Table PA-1 states that the Culebra Transmissivity Fields are, "Carried 

over from CRA-2009 PABC ." It appears that the last update to the geologic well data analysis 

was performed in 2007 (Powers 2007a and Powers 2007b). Specific questions and requests 

the Agency has related to the T-Fields are listed below. 

1. Have changes in the Culebra well data during the past seven years changed the T-Field 

derivation in any way?

2. Has any additional hydraulic testing been performed that could be used for additional 

calibration of the T-Fields?

3. Has the saturated thickness of the Culebra remained constant since the original derivation 

of the T-Fields?

4. Provide justification that new well information and water level changes since the 2009 

PABC do not need to be included in the T-Field derivation and that the 2009 T-Fields are still 

valid for use in the CRA-2014 PA.

5. Provide justification for the continued use of the CRA-2009 T-fields.

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40 CFR 194. 23 MODELS AND COMPUTER CODES

1-23-3 REGION ROMPCS

The Agency agreed to the adopted parameter values used for the panel closure change 

request to isolate the effects and facilitate a comparison of the proposed panel closure design 

on the baseline PA and, at the time of the planned changed request, there was uncertainty in 

the emplacement technique to be used. The Agency would like DOE to address the following 

comments on several parameters related to the panel closures:

1. Identify and technically justify that ranges of porosity and permeability for the ROM salt PCS 

during the time period 0 to 100 years (material PCS_T1) are consistent with initial emplacement 

of the ROM salt material without wetting or compaction.

2. Provide technical justification for applying a capillary pressure model that assumes zero 

threshold pressure to region ROMPCS during time periods 100 to 10,000 years (T2 and T3).

3. Provide a technical justification for selecting the ranges for the residual brine and gas 

saturations (SAT_RBRN and SAT_RGAS) during time periods T2 and T3; the justification 

should include adopting a zero value as the low end.

4. Provide technical justification for using the same value for the bulk compressibility of ROM 

salt during the T1, T2 and T3 time periods (from 0 to 100, 100 to 200, and 200 to 10,000 

years).

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40 CFR 194. 23 MODELS AND COMPUTER CODES

1-23-4 REGION DRZ PCS

The Agency would like DOE to address the following comments related to the parameter values 

adopted for the DRZ_PCS:

1. Provide technical justification for assigning the same sampled value of porosity to the 

material in DRZ_PCS region for both early and late time periods (T2 and T3) when the DRZ is 

undergoing consolidation and healing.

2. Provide technical justification for the apparent discrepancy created by independently 

sampling the permeability of material DRZ_PCS, representing a healed DRZ, from a 

distribution that can provide a sampled permeability as much as seven orders of magnitude 

higher than the permeability of intact halite.

3. Provide technical justifications for assigning zero values to the residual brine and gas 

saturations (SAT_RBRN and SAT_RGAS) in CRA-2014 for the region DRZ_PCS during the T3 

time period (200 to 10,000 years).

4. Provide technical justification for applying a capillary pressure model that assumes zero 

threshold pressure in region DRZ_PCS during the T3 time period (200 to 10,000 years).

5. Provide technical justification for the value of the bulk compressibility of the DRZ_PCS 

region, and applying that same value during both early and late time periods (T2 and T3) when 

the material in that region is undergoing consolidation.



40 CFR 194. 23 MODELS AND COMPUTER CODES

1-23-5 Waste Shear Strength. 

Please address the following:

1. Provide horsetail plots of the remaining fraction of uncorroded iron in the repository 

throughout the 10,000-year regulatory time frame from the CRA-2009 PABC from each of the 

three replicates and each scenario.

2. Provide horsetail plots of the remaining fraction of undegraded CPR in the repository 

throughout the 10,000-year regulatory time frame from the CRA-2009 PABC from each of the 

three replicates and each scenario.

3. Provide and justify the criteria used in advancing the surrogate waste samples during the 

shear strength tests when the eroded sample face was not smooth but irregular.

4. Identify and justify the consequences of using the proposed uniform distribution rather than 

the currently approved log-uniform distribution for TAUFAIL.

5. Provide the quality control procedures used during the shear strength tests and provide 

evidence that the tests were performed consistent with those procedures.

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2nd Response Submittal to the EPA Enclosure 3

Completeness Question

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40 CFR 194. 23 MODELS AND COMPUTER CODES

1-23-6 Probability of Encountering a Castile Brine Pocket. 

Please address the following comments:

1. TDEM results are site specific and indicate the presence of potentially large volumes of 

brine beneath some waste panels. Explain why TDEM data is not used in DOE's proposed 

approach for estimating PBRINE.

2. DOE's approach ignored the presence of high electrical conductivity zones identified 

beneath four of the ten WIPP waste panels. Please explain how this omission affected the 

comparison of the TDEM approach with DOE's newly derived drilling data approach.

3. ERMS 558724 asserts that brine encounters of sufficient size to impact the repository would 

be noticed and logged by a driller. The approach does not acknowledge the potential of 

encountering a low yield and high volume brine pocket which would not be noticed by the driller 

in calculating PBRINE. Please address the basis for not considering the low yield, high volume 

brine pockets.

4. DOE reported the same count of 34 brine intrusions out of 678 Castile wells in 2008. It is 

unclear whether 2008 was the last time a brine intrusion was observed at the time of collecting 

data for the CRA-2014 or if 2008 was the cut-off date for recoding a brine intrusion. Please 

clarify.

5. The circular regions in Figure 5 of ERMS 558724 were selected to include a known brine 

pocket encounter. Please provide information as to whether this radius would bias the results 

and the sensitivity of the results to the radius size.

6. Provide information as to how the well depths, for each well that did and did not encounter a 

brine pocket, were incorporated into the drilling data analysis.

7. The ratios in Table 2 of ERMS 558724 include double-counting of many wells. Please 

provide information as to how this affected the results.

8. ERMS 558724 states that pressurized brine is associated with near-vertical fractures. 

However, WIPP-12 yielded large volumes of brine that is assumed to have been stored and 

transmitted through the extensive and primarily interconnected horizontal to sub-horizontal 

fractures. Please provide an explanation as to how the near-vertical fracture model adopted by 

DOE's modified PBRINE parameter is consistent with evidence that WIPP-12 releases are 

attributed to horizontal and sub-horizontal fractures.

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2nd Response Submittal to the EPA Enclosure 3

Completeness Question

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This 

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Previously 

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40 CFR 194. 23 MODELS AND COMPUTER CODES

1-23-7. Volume of Repository Operations and Experimental Areas. 

Please address the following:

1. Explain how DOE arrived at a volume of 148,011 m3 for the underground.

2. In the diagram of repository ventilation during recovery (see attached, labeled Phase 2B 

Underground Map , dated March/17/2014) a large portion of the north experimental area is 

denoted as 'backfilled'. Please provide information of the material properties of these backfilled 

areas and how they are modeled during the 10,000 year regulatory period in the CRA-2014 PA.



40 CFR 194.23 MODELS AND COMPUTER CODES

1-23-8 Fluid Flow in Repository Operations and Experimental Areas. 

There have been numerous refinements of conceptual and numerical models of repository fluid 

flow since the 1994-95 time frame as well as changes to the panel closure system that may 

also change repository fluid flow. Please provide updated technical justifications for the 

following parameter values adopted for the experimental and operations areas:

1. Setting the permeability of the operations and experimental rooms to a constant value of 

value 10-11 m2 throughout the modeled period.

2. Setting the porosity of the operations and experimental rooms to a constant 18%

throughout the modeled period.

3. Setting the porosity and permeability of the DRZ adjacent to the operations and 

experimental room to the same sampled value as the DRZ surrounding a waste panel 

throughout the modeled period.

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2nd Response Submittal to the EPA Enclosure 3

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40 CFR 194.23 MODELS AND COMPUTER CODES

1-23-11 EQ3/6 and Supporting Files. 

Please provide the following computer files related to the actinide source term modeling 

calculations and the determination of the cumulative distribution functions for the actinide 

solubilities:

1. The EQ3/6 database file DATA0.FM1 used for the CRA-2014 solubility calculations, (also 

known as DATA0.FMT.R2).

2. EQ3/6 input and output files used for calculating actinide solubilities for the actinide source 

term at different brine volumes (1x, 2x, 3x, 4x, 5x minimum brine volumes).

3. The Excel macro GetEQData.xls and all Excel spreadsheets that contain the output 

extracted with GetEQData.xls.

4. EQ3/6 input and output files used for calculating actinide solubilities for the +III and +IV 

actinide uncertainty analysis calculations.

5. Excel macros GetEQData_v101e.xls and GetEQData_v101f.xls; and

6. Excel files Thorium_Uncertainty_Results_2014_PA.xls and

Americium_Uncertainty_Results_2014_PA.xls.



40 CFR 194.23 MODELS AND COMPUTER CODES

1-23-12 WIPP-Specific Organic Complexation Data. 

Appendix SOTERM Section 3.8.2 provides a description and four graphs (Figure SOTERM-21) 

that relate to WIPP-specific experiments designed to evaluate the effects of organic chelating 

agents on +III and +IV actinide solubility in WIPP brines.

1. Please provide supporting documentation for these data, including a summary of the 

experimental approach, materials and analytical methods used to produce the data.

2. Please provide any available characterization data for the solid phases present in these 

experiments.



40 CFR 194.23 MODELS AND COMPUTER CODES

1-23-13 Missing Reference. 

Appendix SOTERM, Figure SOTERM-7 caption cites Altmaier (2011) but this reference is 

missing from the reference list. Please provide this reference.



40 CFR 194.24 WASTE CHARACTERIZATION- PERFORMANCE ASSESSMENT 

INVENTORY

1-24-1 Shielded Container Lead Inventory

1. Please provide information as to how lead shielding on RH shielded containers is included 

in the performance assessment.



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2nd Response Submittal to the EPA Enclosure 3

Completeness Question

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40 CFR 194.24 WASTE CHARACTER IZATION- PERFORMANCE ASSESSMENT 

INVENTORY

1-24-2 Inventory Report Text Unclear. 

Please address the following:

1. Provide information as to how the "projected-to-stored volume ratio" is derived for both RH 

and CH waste. Please provide an example of this derivation.

2. Provide information of the RH waste volume that has been and will be placed in the leaded 

containers on the waste panels floors.

3. Provide information that specifies how potential waste inventory listed in the inventory report 

estimate is used in the CRA-2014 performance assessment.



40 CFR 194.24 WASTE CHARACTER IZATION- PERFORMANCE ASSESSMENT 

INVENTORY

1-24-3 Emplaced Inventory Chemical Constituents

1. In the ATWIR 2012, Section 2.3, it is stated that, "Chemical constituents are not reported in 

the emplaced inventory". In the PAIR 2012 report, Section 4.3, it is indicated that "two additional 

analysis" were performed for chemical and other important constituents. It is unclear how the 

chemical constituents of emplaced inventory, identified in the PAIR report, are derived and 

calculated for the CRA-2014 PA, provide clarification.

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2nd Response Submittal to the EPA Enclosure 3

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40 CFR 194.24 WASTE CHARACTER IZATION- PERFORMANCE ASSESSMENT 

INVENTORY

1-24-4 Missing References. 

Please provide the following references:

French, D. 2009. Analysis of Container Material Masses , INV-SAR-19. Los Alamos National 

Laboratory - Carlsbad Operations, Carlsbad, NM.

Los Alamos National Laboratory - Carlsbad Operations (LANL-CO) 2010. Analyses , LCOQP9 - 

Los Alamos National Laboratory - Carlsbad Operations, Carlsbad, NM.

Los Alamos National Laboratory - Carlsbad Operations (LANL-CO) 2011a. Data Collection, 

Data Management, and Control for the Comprehensive Inventory , INV-SP-01. Los Alamos 

National Laboratory - Carlsbad Operations, Carlsbad, NM.

Los Alamos National Laboratory - Carlsbad Operations (LANL-CO) 2011b. Entry, Verification, 

and Validation of inventory Information in the Comprehensive Inventory Database , INV-SP02. Los Alamos National Laboratory - Carlsbad Operations, Carlsbad, NM.

Los Alamos National Laboratory - Carlsbad Operations (LANL-CO) 2011c. LANL-CO Software 

Quality Assurance Plan , LCO-QPD-02. Los Alamos National Laboratory - Carlsbad 

Operations, Carlsbad, NM.

Los Alamos National Laboratory- Carlsbad Operations (LANL-CO) 2011d. Software Quality 

Assurance , LCO-QP19-1. Los Alamos National Laboratory - Carlsbad Operations, Carlsbad, 

NM.

Los Alamos Nationa! Laboratory - Carlsbad Operations (LANL-CO) 2011e. Comprehensive 

Inventory Database , Version 2.0, Schema Version S2.00, Data Version D.10.01. Los Alamos 

National Laboratory - Carlsbad Operations, Carlsbad, NM.

Los Alamos National Laboratory - Carlsbad Operations (LANL-CO) 2012. Comprehensive 

Inventory Database , Version 2.01, Schema Version S2.01, Data Version D.11.00. Los Alamos 

National Laboratory - Carlsbad Operations, Carlsbad, NM.

Chemical and Cement Components 2011 Inventory Estimates . LANL-CO. INV-SAR-28, 

Revision 0, November 1, 2012. LANL-CO Record ID# INV-1211-01-01-01.

Estimation of Cellulose, Plastic, and Rubber Emplacement Materials in the Waste Isolation 

Pilot Plant (WIPP) . LANL-CO. INV-SAR-27, Revision 0, November 5, 2012. LANL-CO Record 

ID# INV-1211-02-01-01.

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2nd Response Submittal to the EPA Enclosure 3

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GENERAL: CRA-2014 DOCUMENTATION

1-G-1 Reference Appendix QAPD-2014 Not Provided. 

CRA-2014 Section 23, Models and Computer Codes, Section 23.5.7 states, "The DOE's quality 

assurance program, as applied to the CRA-2014, is contained in Appendix QAPD-2014." The 

appendix has not been provided. Please provide this document.



GENERAL: CRA-2014 DOCUMENTATION

1-G-2 Codes IDs Do Not Include Source Code Listing. 

CRA-2014 Section 23, Models and Computer Codes, Section 23.8.7 states, "The IDs include 

source-code listings..." EPA examined a number of code Implementation Documents; they 

include a reference to the location of the source-code listing, but not the actual listing of the 

code. Please provide the source-code listing for the following CRA-2014 codes: BRAGFLO 

6.02, MATSET 9.20, CCDFGF 6.0.



GENERAL: CRA-2014 DOCUMENTATION

1-G-3 New Codes EQ3/6 and JAS3D Documentation Incomplete. 

DOE states in CRA-2014 Section 23, 23.7.7, "The documentation for the new codes EQ3/6 and 

JAS3D may be found in their respective UM, AP, VD, ID, and RD/VVP." It does not appear that 

this documentation has been included in CRA-2014. Please provide this documentation.



11
2nd Response Submittal to the EPA Enclosure 3

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CHEMISTRY COMMENTS

1-C-1 LANL Waste Stream With Added Cellulosic Material

Organic kitty litter was used as an absorbent for nitrate salts for Waste Stream LA-MIN02-

V.001 (NMED 2014) and 349 drums of this waste were placed in Panels 6 and 7 (Wallace 

2014). Please address the following:

1. Provide a complete waste profile for the kitty litter; including; cellulosic content and other 

ingredients; emplaced volume and mass.

2. Specify the number of drums with kitty litter placed in either Panel 6 or 7.

3. Identify the type of waste emplaced in the drums with the kitty litter.

4. Indicate whether this cellulosic kitty litter has been used in other waste streams and whether 

the corresponding waste profile reports adequately describe the waste material parameters.

5. Describe the effects of omitting the organic kitty litter in the waste stream(s) on the CPR 

inventory and consequent effects on gas generation rates calculated for the CRA-2014 PA.

6. Provide information of the quantities of soluble organics, such as organic ligands or 

surfactants that could affect actinide solubilities when this material is leached.



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