The Second Opening of the Waste Isolation Pilot Plant? Review of Salient Characteristics and Unique Operational Considerations for Remote Handled Transuranic Waste

The U.S. Department of Energy (DOE) intends to dispose of remote handled (RH) transuranic (TRU) waste at the Waste Isolation Pilot Plant (WIPP) beginning in 2005. (1) Four principle regulatory agencies are involved in the process of approving the RH TRU waste activities. The DOE is responsible for operational activities. The U. S. Nuclear Regulatory Commission (NRC) approves the design and use of shipping containers. The U.S. Environmental Protection Agency (EPA) is responsible for assuring safe and environmentally effective long-term disposal of the radioactive component of the waste and operational environmental monitoring. The New Mexico Environment Department (NMED) is responsible for the handling and the disposal of the non-radioactive hazardous component of the waste. The Environmental Evaluation Group (EEG) is responsible for performing independent technical oversight of all WIPP activities, and will comment on documents and practices for the various regulated RH TRU waste activities. The DOE has already obtained the necessary approvals from the NRC, and has submitted a Class 3 Modification request to the NMED. On December 16, 2002 the DOE Carlsbad Field Office (CBFO) provided the EPA with a notice of proposed change, in accordance with 40 CFR 194.4 (b) (3), to receive and dispose of remote handled transuranic waste. (2) WIPP procedures for the management of RH TRU waste at the site are being developed. While there are no issues with current NRC Certificates of Compliance for the RH TRU waste shipping containers, it is likely that there will be some controversy over other aspects of the currently planned RH TRU waste program. These issues may include: (1) the published RH TRU waste inventory, (2) the characterization of the radionuclide portion of the waste, for which one planned method is to use dose-to-Curie conversions, and (3) the plans to use bounding estimates for the hazardous portion of the WIPP waste, rather than measuring VOCs on a container-by-container basis or by representative sampling as is done for contact handled transuranic (CH TRU) waste. This paper discusses the currently planned process and the possible issues related to the DOE's efforts to dispose RH TRU waste at the WIPP