Kenneth Fletcher
WC Monitor
1/9/2015
The recovery plan in place for the resumption of operations at Waste Isolation Pilot Plant “is not fully sufficient to ensure safe conditions underground,” with chief concerns involving ventilation rates for workers while diesel equipment is being operated, according to a recently released Department of Energy review. DOE’s Office of Enterprise Assessments, which covers enforcement and oversight, has released two reviews of recovery efforts at WIPP following the February 2014 truck fire and radiological release. “The current version of this Recovery Plan is not fully sufficient to ensure safe conditions underground. The most significant concern is that NWP does not have a sound engineering approach for determining the minimum ventilation rates that will ensure safe conditions for underground workers,” states the Recovery Plan for Operating Diesel Equipment with Available Underground Airflows, dated Dec. 29.
At issue is the use of high efficiency air particulate air filters, required since the radiological release to process radioactive particles and mitigate further releases, according to the report. Because the filters significantly restrict airflow below to about one-seventh of what had been available during normal operations, they also impact the ability to use diesel equipment underground that is needed for the facility’s recovery effort. The necessary equipment includes roof bolters and forklifts. Other issues highlighted by the review regard the WIPP ventilation plan, which “does not reflect current conditions and is missing some key information necessary for managing safety,” the report states. “Further, some diesel engines at WIPP have not been approved for use by the [Mine Safety and Health Administration], and WIPP lacks enough information about this equipment to determine the minimum ventilation needed to protect workers. The identified deficiencies are significant and need to be addressed before WIPP begins to use diesel engines underground.”
DOE, NWP Have Taken Positive Steps
While operating diesel engines underground “will be challenging,” according to the report, it is possible with proper safety controls and restrictions. Since the initial review, DOE and WIPP managing contractor Nuclear Waste Partnership have taken steps to address issues such as evaluating compensatory measures and obtaining external advice, the report states. “Although these steps are encouraging, increased management attention is needed to ensure that the required improvements are made before WIPP starts to operate diesel engines underground,” the report states. “In addition, management attention is needed to ensure that WIPP receives all the needed technical support and expertise to ensure the return to underground diesel generator operations is safe.”
DOE and NWP are also “revising ventilation plans based on the current mine ventilation configuration and conditions and implementing air sampling programs that provide continuous air sampling for diesel particulates and other gases necessary to monitor air quality in the underground facility,” according to a DOE release. “Engineered modeling and real-time monitoring of diesel emissions in the underground facility helps ensure safe, breathable air for all employees.”
Review Finds Improvements in Maintenance Plan
A second Office of Enterprise Assessments review focused on the WIPP recovery plans for conduct of maintenance. Issues with maintenance were found to have led to the truck fire, which was caused by a buildup of flammable fluid on the truck. The subsequent DOE Accident Investigation Board report found numerous deficiencies with the NWP maintenance program.
But the new review found improvements in the latest plan. “EA determined that the NWP plan for enhancing Conduct of Maintenance was adequately justified and appropriately scheduled, the required initial recovery activities effectively managed, early deliverables were provided on schedule, and the revised or new content generally satisfied the required corrective actions,” the plan states. But it also notes that the normal maintenance program hasn’t been fully implemented due to the recovery underway. “As a result, the adequacy of the WIPP Conduct of Maintenance Recovery effort cannot yet be fully assessed and will need to be reevaluated by EA after the program stabilizes and normal implementation processes resume,” it states.
Two Maintenance Program Deficiencies Uncovered
The review also identified two areas in which the maintenance program did not meet DOE requirements. “Specifically, NWP had not performed an assessment of the maintenance program every three years as required and has not performed periodic assessments of all engineered safety systems,” the reports state. “EA also identified opportunities for improvement for NWP consideration in such areas as predictive maintenance, documentation of annual system walkdowns, documentation of system health reports, and timely evaluation of impaired equipment.”
DOE’s Carlsbad Field Office is committed to reopening WIPP and values the “evaluation and feedback” in the reports, a DOE spokesman said in a statement. “We are already addressing issues raised in these reports as we continue to make safety, health and protection our workers, the public and the environment our highest priority. We are making good progress in recovering the Waste Isolation Pilot Pant and resuming waste disposal operations in a safe, systematic manner,” according to DOE. NWP referred request for comment to DOE.