Second Set of EPA Completeness Comments 1

Second Set of EPA Completeness Comments For CRA 2014

194.23 MODELS AND COMPUTER CODES 

2-23-1 ROM Salt Panel Closures Locations. Please provide the WIPP configuration layout (a 

plan view) used for the 2014 CRA that includes all locations where the ROM salt panel closures 

are to be placed. Provide text that provides the exact location, dimensions and properties for the 

set of panel closures that lie furthest north in the repository.

2-23-2 Provide An Update of the Derivation of the Shaft Properties at the Repository 

Horizon. In the BRAGFLO grid for the 2004 and 2009 CRA Performance Assessments (PAs),

the modeled lower portion of the shaft included an effective permeability that incorporated both 

the concrete portion of the shaft (at the repository horizon level) and the furthest north panel 

closures located just south of the waste and exhaust shafts. The material properties of the 

modeled shaft (the concrete monolith segment) were combinations of the shaft properties and the 

Option D panel closure properties (Camphouse and Clayton 2011, ERMS 555204). Now, 

however, there is a new panel closure system that uses run of mine salt instead of the Option D 

design, and the properties of new panel closure system are different than that of the concrete 

portion in the lower shaft. In the CRA 2014 PA, however, it appears the material properties of 

the shaft at the repository horizon have not been updated to reflect the change. Please confirm 

this and identify how the properties would change to reflect the change in the panel closure 

design.

194.33 Future Drilling

2-33-1 Future Drilling Into Nitrate Waste. Please provide the probability and describe the 

potential consequence(s) to PA calculations of drilling into the nitrate waste. 

194.43 Passive Institutional Controls

2-43-1 Changes in Passive Institutional Controls (PICs). Recent Nuclear Energy Agency and 

International Atomic Energy Agency reports describe changes and developments in international 

approaches to PICs. These are referenced in INIS-US-13-WM-13145 which states “The 

DOE/CBFO WIPP PIC's program in place today meets the regulatory criteria, but complete 

feasibility of implementation is questionable, and may not be in conformance with the 

international guidance being developed.” Please explain this feasibility concern. Please also 

provide the complete INIS-US-WM-13145 report (the Web link only provides an Abstract) and 

any other recent studies or reports that may impact PICs planning in the future.

Reference:

INIS-US-13-WM-13145, “The Revised WIPP Passive International Controls Program – A 

Conceptual Plan – 13145, Dated 2013-07-01,

Web link: http://www.osti.gov/scitech/biblio/22225507

194.44 Engineered Barriers

2-44-1 MgO Physical Segregation. In Franco (2012) DOE notified EPA that MgO 

emplacement has been modified by placing a 3,000 pound supersack of MgO on every other 
Second Set of EPA Completeness Comments 2

waste stack or on each waste stack in every other row. In the Franco 2012 letter the “effective 

diffusion penetration length of CO2” was considered but the information on physical segregation 

is limited. 

Please provide updated documentation to more explicitly and clearly address whether the larger 

lateral separation distance still allows sufficient reactions between MgO and CO2.

References:

Franco, J.R. 2012. Letter to A. Perrin (Subject: “Planned Change Notice for Placement of MgO 

Supersacks," with enclosure (Analysis of an alternative placement scheme for MgO supersacks). 

February 14, 2012. Carlsbad, NM: U.S. Department of Energy Carlsbad Field Office.

U.S. Department of Energy (DOE). 2009. Title 40 CFR Part 191 Subparts B and C Compliance 

Recertification Application for the Waste Isolation Pilot Plant, Appendix MgO-2009. 

Magnesium Oxide as an Engineered Barrier. DOE/WIPP 09-3424. Carlsbad, NM: Carlsbad 

Field Office.

Vugrin, E.D., M.B. Nemer, and S.W. Wagner. 2006. Uncertainties Affecting MgO Effectiveness

and Calculation of the MgO Effective Excess Factor (Rev. 0, November 17). ERMS 544781. 

Carlsbad, NM: Sandia National Laboratories.

194.46 Removal of Waste

2-46-1 CCA Appendix WRAC Waste Removal Documentation Needs Updating.

The cited removal plan is basically the same as that given during the 1996 CCA and does not 

reflect updates and modifications to the repository design and waste characteristics. The Agency 

found discrepancies between what was used as the removal plan listed in 1996 CCA Appendix 

WRAC, “Waste Removal after Closure,” with the current 2014 repository design, waste, and 

container characteristics. These are listed below. Please update the waste retrieval plan to address 

these discrepancies. Please assure that 40 CFR 194.46 requirements “Removal of Waste” still

comply and are aligned with expected repository conditions at the time of closure, and that 

removal of waste remains feasible. 

 The repository is no longer mined on one contiguous level [CCA Appendix WRAC

page WRAC-7], the southern portion of the mine was moved up to the Clay Seam G 

level.

 The waste containers have changed. The CCA assumed two principal types of containers 

(55-gallon drums and standard waste boxes) [CCA Appendix WRAC, page WRAC-8] 

but with the introduction of large waste boxes, shielded RH-TRU containers, pipe over 

packs, and super-compacted waste, these assumptions are no longer valid.

 The waste characteristics have changed with the introduction of nitrate waste potentially 

subject to exothermic reactions.
Second Set of EPA Completeness Comments 3

 The run-of-mine salt panel closure replaced the original concrete-based Option D panel 

closure design, which can no longer be used “as markers for locating panels and drifts” 

[CCA Appendix WRAC, Section WRAC.6.4].

 Given the use of shielded containers CH and RH wastes no longer must be segregated in 

the waste panels [CCA Appendix WRAC, Sections WRAC.4.3, WRAC.6, WRAC.6.4] 

and can no longer be removed using separate retrieval operations where the RH shielded 

containers are comingled with CH waste containers.

 CCA Appendix WRAC refers to performance assessment (PA) modeling to predict future 

characteristics of repository waste rooms. The PA assumptions, models, parameters, and 

inventory have changed since the CCA. Please include these changes in the waste 

removal reevaluation. 

 CCA Appendix WRAC, Section WRAC.4.3 takes credit for the effectiveness of active 

and passive controls to deter human intrusion for up to 700 years after closure. However, 

this credit was denied by EPA because of difficulty predicting the future. This should be 

removed from the waste removal reevaluation.

References:

U.S. Department of Energy (DOE). 1996. Title 40 CFR Part 191 Compliance Certification 

Application for the Waste Isolation Pilot Plant (October). CCA Appendix WRAC, Waste 

Removal After Closure”. DOE/CAO-1996-2184. Carlsbad, NM: Carlsbad Area Office.

U.S. Department of Energy (DOE). 1996. Title 40 CFR Part 191 Compliance Certification 

Application for the Waste Isolation Pilot Plant (October). CCA Chapter 7.0, “Assurance 

Requirements”. DOE/CAO-1996-2184. Carlsbad, NM: Carlsbad Area Office.

U.S. Department of Energy (DOE). 2004. Title 40 CFR Part 191 Compliance Recertification 

Application for the Waste Isolation Pilot Plant (March). CRA-2004 Chapter 7.0, “Assurance 

Requirements”. DOE/WIPP 2004-3231. Carlsbad, NM: Carlsbad Field Office. 

U.S. Department of Energy (DOE). 2009. Title 40 CFR Part 191 Compliance Recertification 

Application for the Waste Isolation Pilot Plant (March). CRA-2009 Section 46, “Removal of 

Waste” DOE 09-2434. Carlsbad, NM: Carlsbad Field Office.

194.55 Results of Compliance Assessments

2-55-1 Incorrect Reference. Appendix IGP-2014, Section IGP-2.1 makes reference to 

194.55(b)(1), should this be 194.54(b)(1) “Existing boreholes...”?

Chemistry Comments

2-C-3 Data Supporting Water Balance Assumptions. The CRA-2014 PA calculations include 

the effects of MgO hydration, microbial degradation of CPR and iron sulfide formation on 

repository water balance. For PA, it is assumed that hydrogen sulfide created by CPR 
Second Set of EPA Completeness Comments 4

degradation preferentially reacts with iron hydroxide versus metallic iron (CRA-2014 Appendix 

MASS, page MASS-57). These hydrogen-sulfide reactions are:

Fe(OH)2(s) + H2S(g) → FeS(s) + H2O(l) (1)

Fe(s) + H2S(g) → FeS(s) + H2(g) (2)

The assumption that hydrogen sulfide preferentially reacts with iron hydroxide increases brine 

production and decreases gas production compared to the assumption that all or some of the 

hydrogen sulfide reacts with metallic iron. 

It is also assumed for PA that carbon dioxide preferentially reacts with brucite instead of 

unreacted MgO. The carbonation reactions are:

1.25 Mg(OH)2(s) + CO2(g,aq) → 0.25 Mg5(CO3)4(OH)2•4H2O(s) (3)

1.25 MgO(s) + CO2(g,aq) + 1.25 H2O(l) → 0.25 Mg5(CO3)4(OH)2•4H2O(s) (4)

The assumption that carbon dioxide preferentially reacts with brucite increases brine production 

in the repository.

Please provide supporting data for these water-balance assumptions and evaluate the potential 

magnitude of the effects of these assumptions on the water balance.

2-C-4 Hydromagnesite Conversion Rate. Clayton (2013) formulated the conversion reaction 

from hydromagnesite to magnesite for inclusion in the BRAGFLO calculations as:

Mg5(CO3)4(OH)2•4H2O(s) → 4 MgCO3(s) + Mg(OH)2(s) + 4 H2O(l) (5)

Clayton (2013) calculates a range for the hydromagnesite conversion rate based on reaction 

times of 100 years to 10,000 years. However, the minimum reaction time for this conversion is 

uncertain. SCA (2008) reviewed the available experimental and natural analogue data and 

concluded that hydromagnesite conversion is best represented by a range of zero conversion 

(only hydromagnesite remains after 10,000 years) to complete conversion (only magnesite 

remains after 10,000 years), with a uniform distribution across this range. Please provide an 

explanation as to why the specific upper and lower limits used in the PA were picked.

The effect of using zero rather than 100 years as the minimum conversion rate is likely to be less 

brine production in the water balance, based on equation (5). Please provide an explanation of 

the effects on PA if the lower limit of the hydromagnesite conversion rate is set to zero while the 

upper limit is decreased by a variety of plausible factors that are less than what Clayton had 

adopted. 
Second Set of EPA Completeness Comments 5

References:

Clayton, D.J. 2013. Justification of Chemistry Parameters for Use in BRAGFLO for AP-164, 

Rev. 1. Sandia National Laboratories, ERMS 559466. 

SCA (S. Cohen and Associates). 2008. Review of MgO-Related Uncertainties in the Waste 

Isolation Pilot Plant. Final Report prepared for the U.S. Environmental Protection Agency Office 

of Radiation and Indoor Air, Washington, D.C., January 24, 2008. 

2-C-5 Cumulative Effects of Water Balance Assumptions on PA. The result of several water 

balance assumptions is to increase brine production from waste reactions in the repository. These 

assumptions include that hydrogen sulfide will preferentially react with iron hydroxide instead of 

metallic iron (Comment 2-C-3); that carbon dioxide will preferentially react with brucite instead 

of MgO (Comment 2-C-3); and that the minimum rate of hydromagnesite conversion to 

magnesite is greater than zero (Comment 2-C-4). Please provide a description of the cumulative 

effects of these assumptions on the water balance calculations for the CRA-2014 PA.

2-C-6 MgO Hydration Rate. MgO has been supplied for the WIPP engineered barrier by three 

vendors: National Magnesia Chemicals, Premier Chemicals, and, currently, from Martin Marietta 

Magnesia Specialties (Martin Marietta). The majority of the MgO in the repository is from 

Premier Chemicals and Martin Marietta. Clayton (2013) used MgO hydration rates obtained 

from experiments conducted with MgO supplied by Premier Chemicals to establish the hydration 

rates used in PA. However, Wall (2005) performed preliminary tests with the Martin Marietta 

MgO and concluded that it reacted to form brucite faster than Premier MgO. Given the multiple 

vendors that supply MgO a summary of the following information needs to be provided; 

 The inundated and humid MgO hydration rates for MgO from the three vendors.

 The potential effects of the variable MgO hydration rates on repository 

performance.

 The amounts of National Magnesia Chemicals, Premier MgO and Martin Marietta 

MgO that will be present in the WIPP repository at the time of closure, and 

assumptions regarding the future source(s) of MgO.

References:

Clayton, D.J. 2013. Justification of Chemistry Parameters for Use in BRAGFLO for AP-164, 

Rev. 1. Sandia National Laboratories, ERMS 559466.

Deng, H., M. Nemer, and Y. Xiong. 2007. Experimental Study of MgO Reaction Pathways and 

Kinetics Rev. 1. Sandia National Laboratories TP 06-03. 

Deng, H., Y. Xiong, M. Nemer and S. Johnsen. 2009. Experimental Work Conducted on MgO 

Long-Term Hydration. Sandia National Laboratories ERMS 551421. 
Second Set of EPA Completeness Comments 6

Wall, N.A. 2005. Preliminary Results for the Evaluation of Potential New MgO. Sandia National 

Laboratories ERMS 538514.

2-C-7 MgO Hydration Rate Data File. Please provide a copy of the Microsoft Excel file 

“hydration kinetics Q & HY2 & HH djc 5-1-07.xls” used by Nowak and Clayton (2007) to 

calculate the MgO hydration rates.

References:

Nowak, E.J. and D. Clayton. 2007. Analysis of MgO Hydration Laboratory Results and 

Calculation of Extent of Hydration and Resulting Water Uptake versus Time under Postulated 

WIPP Conditions. Sandia National Laboratories ERMS 546769.

2-C-8 Iron and Lead Corrosion Rate Data. Please provide spreadsheets containing the iron 

and lead corrosion data listed in Appendix A, Tables A-1 and A-2 from Roselle (2013). 

References:

Roselle, G.T. 2013. Determination of Corrosion Rates from Iron/Lead Corrosion Experiments to 

be Used for Gas Generation Calculations. Sandia National Laboratories ERMS 559077.

194.32 Scope of Performance Assessment

Since the original certification decision changes have been made to the repository, it is our 

observation that, for many of the features, events, and processes (FEPs) we have reviewed, DOE 

has not fully considered all of the relevant changes to the repository. Additionally, DOE has not 

fully considered updates relevant to activities within the WIPP vicinity. Table FEP-1 lists our 

comments on specific FEPS; immediately below we discuss general FEP screening issues that 

need further attention.

2-32-G1 Obsolete FEP Screening Arguments, Curtailed FEP Screening Arguments, and

Completeness Considerations. The screening arguments in the CRA-2014, Appendix SCR2014 for many FEPs have been carried forward from past baseline reviews and do not 

necessarily reflect changes that have occurred in the past several years. This especially applies to 

information on how some FEPs are accounted for in PA. Some FEPs need to be updated to 

reflect current repository design and new knowledge of repository behavior. These are identified 

in Table FEP-1. 

For some FEPs, the screening argument needs to provide a more complete discussion of the FEP 

and how it is determined to be screened-in or screened-out. The supporting arguments, along 

with documents incorporated by references, need to provide a basic understanding of how the 

FEP is accounted for in PA calculations, where the FEP is accounted for in the repository region 

and surrounding geosphere, and when in the regulatory time frame the FEP is accounted for. 

Those FEPs with inadequate or curtailed screening arguments are provided in Table FEP-1.
Second Set of EPA Completeness Comments 7

For some FEPs that DOE has reported “no change”, EPA disagrees and believes that DOE 

should reconsider and update the FEP discussion. Table FEP-1 includes those FEPs in this 

category that EPA has identified, to date, as being incomplete. 
Second Set of EPA Completeness Comments 8

FEP-1. EPA Specific Comments on Incomplete DOE CRA-2014 FEPs

FEP DOE Reported 

Change

EPA Comments

H21 Drilling 

Fluid Flow

No Change 2-32-S1. Screening argument considers only boreholes intersecting the waste region. Please 

supplement the argument with a discussion of boreholes that intersect the non-waste regions

and the consequence to PA calculations. Provide references and specific information as to 

whether boreholes penetrating non-waste regions could result in the transport of

radionuclides between the waste and non-waste regions, to overlying units, or to the surface.

Provide information, either directly or by reference, as to how deep boreholes penetrating 

the non-waste and waste regions of the repository are accounted for in the PA.

H22 Drilling 

Fluid Loss

No Change 2-32-S2. The screening argument considers flow into the repository from boreholes that intercept 

pressurized fluid in underlying formations but only for boreholes intersecting the waste region. In 

the current BRAGLO model gas and brine readily flow between the waste and non-waste regions. A 

discussion and analysis of boreholes that could intersect the non-waste regions and their impact on 

the PA needs to be provided.

H23 Blowouts Updated with new 

value of parameter 

GLOBAL:PBRINE

2-32-S3. Screening argument considers only boreholes intersecting the waste region and 

also pressurized Castile brine. In the current BRAGLO model gas and brine readily flow 

between the waste and non-waste regions. Please supplement the argument with a 

discussion and analysis of boreholes that could intersect the non-waste regions on the PA. 

H28 

Enhanced Oil 

and Gas 

Production

No Change 2-32-S4. Please address whether enhanced production techniques are being used in the 

Delaware basin and in the vicinity of WIPP. Please also address the potential for these 

techniques to create a preferential pathway for radionuclide releases through a second well.

H58 Solution 

Mining

Updated with 

information 

regarding solution 

mining activities in 

the region

2-32-S5. This FEP is screened out partially on the basis that solution mining will not occur 

in low ambient temperature conditions. However, solution mining is occurring in the nearby 

Eddy mine under similar conditions that exist in the vicinity of WIPP. Please provide text

that reconciles the basis of the screening argument and the conditions at the Eddy mine 

where solution mining is taking place.

W1 Disposal 

Geometry

Updated with new 

information 

2-32-S6. In the screening argument please provide evidence that the modeled excavated 

volume is the expected mined volume of the underground workings at the time of closure.

W3 

Heterogeneity 

Updated to reflect 

the inventory data 

2-32-S7 The screening argument citation of the CCA as the source of information on the 
Second Set of EPA Completeness Comments 9

FEP DOE Reported 

Change

EPA Comments

of Waste 

Forms

sources used for the 

CRA-2014 PA

heterogeneity of waste forms ignores changes that have occurred in the past 15 years, 

including supercompacted waste and mingling RH waste in shielded containers with CH 

waste. Please update the information to reflect current waste forms.

W5 Container 

Material 

Inventory

Updated to reflect 

the inventory data 

sources used for the 

CRA-2014 PA

2-32-S8. Please supplement the screening argument with an explanation of the 

implementation in PA of the material inventory of shielded containers containing RH waste.

W18 

Disturbed 

Rock Zone 

(DRZ)

Updated to include 

new panel closure

implementation

2-32-S9. The screening argument for this FEP states “This excavation-induced, host-rock 

fracturing is accounted for in PA calculations (the CCA, Chapter 6.0, Section 6.4.5.3).” The 

cited CCA text indicates that the DRZ is modeled in the same way around all repository 

excavations. However, the DRZ is now expected to vary spatially. Provide an updated 

description of the DRZ in the waste and non-waste locations of the repository.

W19 

ExcavationInduced 

Changes in 

Stress

Updated to include 

new panel closure 

implementation

2-32-S10. Screening argument was combined with that for W18 Disturbed Rock Zone 

(DRZ); please see comments for FEP W18.

W20 Salt 

Creep

Updated to include 

new panel closure 

implementation

2-32-S11. Please supplement the screening argument with a discussion of salt creep and 

consolidation specific to the ROM salt in the ROMPCS, and healing of the adjacent DRZ. 

Such a discussion can be found in Camphouse et al. (2012, Section 2.0. ERMS 557396). 

The screening argument for this FEP states that “Salt creep in the Salado is accounted for in 

PA calculations (the CCA, Chapter 6.0, Section 6.4.3.1).” The cited CCA section discusses 

these FEPs only in the context of the waste region. In addition, this is the only FEP that 

addresses DRZ healing, which is expected to vary spatially.

W21 Changes 

in the Stress

Updated to include 

new panel closure 

implementation

2-32-S12. Screening argument was combined with that for W20 Salt Creep; please see 

comments for FEP W20. Additionally, please supplement the screening argument with 

discussions of 1) the coupling between consolidation of the ROM salt in the ROMPCS and 

healing of the adjacent DRZ (DRZ healing cannot occur until the ROM salt is consolidated 

and applies a back stress sufficient to compress and heal the DRZ); and 2) lateral extrusion 

of the ROM salt when under compressive stress from drift creep closure.
Second Set of EPA Completeness Comments 10

FEP DOE Reported 

Change

EPA Comments

W25 

Disruption 

Due to Gas 

Effects

No Change 2-32-S13. Please supplement the screening argument with a discussion of the potential for 

high waste panel gas pressures to delay the consolidation of the ROM salt, thereby 

maintaining a higher permeability in the PCS for a longer period of time.

W27 Gas 

Explosions

No change 2-32-S14. Please update the screening argument to reflect the LANL inventory with nitrates 

and added organic matter that resulted in an exothermic reaction.

W28 Nuclear 

Explosions

Updated to reflect 

the inventory used 

for the CRA-2014 

PA

2-32-S15. Please modify the screening argument to address whether, in addition to "a 

reduction of TRU radionuclides from previous estimates", the quantities of fissile 

radionuclides have also been reduced.

W40 Brine 

Inflow

Updated to reflect 

water balance 

implementation

in PA

2-32-S16. Please supplement the screening argument with information on the impacts of 

changes in GLOBAL:PBRINE and the PCS on brine inflow.

W42 Fluid 

Flow Due to 

Gas 

Production

Updated to reflect 

water balance 

implementation

in PA and new steel 

corrosion rates

2-32-S17. Please supplement the screening argument with information on the impacts of 

changes in GLOBAL:PBRINE and the PCS on the availability of brine in the waste panels.

W44 

Degradation 

of Organic 

Material

Updated to 

reference new 

inventory data

2-32-S18. Please supplement the screening argument with an expanded discussion of the 

importance of the availability of brine on the degradation of organic material. Changes that 

affect the availability of brine in a waste panel, such as the water balance implementation, 

the revised value of GLOBAL:PBRINE, and the properties of the ROMPCS and associated 

DRZ, will affect this FEP.

W45 Effects 

of 

Temperature 

on Microbial 

Gas 

Generation

Updated to 

reference new 

inventory data

2-32-S19. Please modify the screening argument to acknowledge the reduced thermal 

impact of seal concrete hydration because of the elimination of additional explosion walls 

and the Option D monolith.
Second Set of EPA Completeness Comments 11

FEP DOE Reported 

Change

EPA Comments

W53 

Radiolysis of 

Cellulose

Screening argument 

updated with new 

radionuclide 

inventory

2-32-S20.The reported reason for the screening argument update is not consistent between 

Table SCR-1, where the update is due to new radionuclide inventory, and Section SCR6.5.1.7.2 where the update is due to new cellulose inventory. The screening argument in 

Section SCR-6.5.1.7.3 refers only to the new radionuclide inventory. Please reconcile the 

information.

W72

Exothermic 

Reactions 

No change 2-32-S21. Please supplement the screening argument with a discussion of the impact of 

exothermic reactions in the waste panels.

W73 Concrete 

Hydration

Updated to reflect 

the inventory used 

for the CRA-2014 

and planned thermal 

experiments

2-32-S22. Please supplement the screening argument with a discussion of the impact on the 

PA based on a reduced concrete inventory due to DOE now not using the Option D concrete 

monoliths in the panel closure system. Update the analysis to include where explosion walls 

are or will be installed. 

W110 Panel 

Closure 

Physical 

Properties

Updated with new 

information on 

panel closure design

2-32-S23. Please update the screening argument to provide a description of the as-emplaced 

properties of the ROM salt now that in situ testing has been completed.

W111 Panel 

Closure 

Chemical 

Composition

Updated with new 

information on 

panel closure design

2-32-S24. Please update the screening argument to include the chemical composition of the 

steel bulkheads that are part of the panel closure design.

W113 

Consolidation 

of Panel 

Closures

Updated screening 

argument with new 

information 

regarding panel 

closure composition

2-32-S25. Please supplement the screening argument with information on consolidation 

specific to the ROM salt in the ROMPCS. Such a discussion can be found in Camphouse et 

al. (2012, Section 2.0. ERMS 557396). 

W115 

Chemical 

Degradation 

of Panel 

Closures

Updated screening 

argument with new 

panel closure 

materials

2-32-S26. The screening decision for this FEP was changed from UP (screened in) to SO-P 

(screened out – low probability). Please supplement the screening argument with a 

discussion of the chemical degradation of the steel bulkheads, which are part of the ROM 

salt panel closure system. Please also provide technical justification for the changed 

screening decision in light of the presence of the bulkheads.
Second Set of EPA Completeness Comments 12

References

Camphouse, R., M. Gross, C. Herrick, D. Kicker, and B. Thompson 2012b. Recommendations and Justifications of Parameter Values 

for the Run-of-Mine Salt Panel Closure System Design Modeled in the PCS-2012 PA. Sandia National Laboratories. Carlsbad, NM, 

May 3. ERMS 557396.

Kirkes, G.R. 2013. Features, Events and Processes Assessment for the Compliance Recertification Application—2014 (Revision 0). 

ERMS 560488. Carlsbad, NM: Sandia National Laboratories.