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4 Description of DOE's Characterization Plan
Pages 22-27

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From page 22...
... , existing process information collected before an approved quality assurance program is in place must be qualified for use as AK. Presumably, this would apply to AK data for any retrievable stored RH-TRU waste.
From page 23...
... i` red DOE's Plan to Address EPA's Certification Requirements for RH-TRU Waste DOE's proposed method to meet EPA's certification requirements, addressing also the requirements in the Land Withdrawal Act, is to use AK to meet all or part of the characterization requirements of the approved quality assurance program plan. Where AK is deemed to be the sole source of characterization information, it will be subject to verification and validation using the requirements set forth in 40 CFR ~ 94.22(b)
From page 24...
... was used to demonstrate that the generation of volatile organic compounds from RH-TRU waste could be calculated without requiring headspace gas sampling and analysis. Moreover, according to DOE's analysis, cellulosics, plastic, rubber, ferrous metal, and free liquid in RH-TRU waste will not have a significant impact on repository performance, even at quantities much greater than expected.
From page 25...
... If sufficient information to determine the absence of prohibited items is not available through the use of one or more of these three waste characterization techniques, the waste is not acceptable for disposal at the WIPP facility. The remaining prohibited items in the RCRA Permit overlap with the prohibited items for transporting the waste in one of the RH-TRU waste shipping casks approved by the U.S.
From page 26...
... Generators are to use radiography or visual examination, headspace gas sampling and analysis, and/or solids sampling and analysis to confirm AK information accuracy. Effectiveness of the CH-TRU acceptable knowledge process is demonstrated by the AK Information Accuracy Reports from the various generator or storage sites (DOE-CBFO, 2001 e)
From page 27...
... Description of DOE's Characterization Plan for RH-TRU Waste 27 of 80 percent was achieved in the hazardous waste numbers determination because this site did not assign new codes on a container basis.


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