Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot Plant Interim Report (2001) / Chapter Skim
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3 Regulatory Context for the Disposal of RH-TRU Waste
3 Regulatory Context for the Disposal of RH-TRU Waste
Pages 18-21
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The term "WIPP" means the Waste Isolation Pilot Plant project authorized to demonstrate the safe disposal of radioactive waste materials generated by atomic energy defense activities.
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WIPP's Certification Requirements for the Characterization of Transuranic Waste In 1998, EPA certified that WIPP is in compliance with the radioactive waste disposal regulations set forth in 40 CFR 191 and 40 CFR 194 and in compliance with EPA standards set forth by the Land Withdrawal Act of 1992. A characterization program to meet these requirements was developed for TRU waste and is now applied to CHTRU waste.
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. The current RCRA Permit also excludes RH-TRU waste, any waste container that does not have volatile organic compound concentrations reported for the headspace, any waste container that has not undergone radiographic or visual 3The limitation of free liquid to 1 percent of the waste volume is primarily a transportation requirement.
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From page 21... ...
. This review of the CH-TRU waste characterization procedures by DOE-CBFO revealed that"there is no regulatory requirement to conduct homogeneous waste sampling and analysis, however, in an effort to meet the intent of 40 CFR 264.13, WIPP has imposed additional characterization requirements on the waste generators." DOE also informed the 1998 Committee that "there is no regulatory requirement to conduct headspace gas sampling and analysis, however, in an effort to meet the intent of 40 CFR 264.13, WIPP has imposed additional characterization requirements on the waste generators." Finally, the 1998 Committee found that there is no legal requirement for the verification of radiography results by visual examination.7 According to the study by DOE-CBFO and according to the 1998 Committee, DOE developed self-imposed waste restrictions in the waste acceptance criteria (DOE-CAO, 1996b, 1999b)
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