2005  EPA  WIPP
How has the WIPP TRU Waste Inventory Changed
Since the 1998 Certification Decision?
As DOE proceeds with site clean-ups across the country,
knowledge about TRU waste improves. At the time of the
1998 Certification Decision, no waste had been emplaced
in WIPP, therefore the entire waste inventory was an es-
timation of the waste DOE might put in WIPP. The recer-
tification waste inventory contains the actual data for the
waste that has been disposed of in WIPP as of September,
2002, and an estimate of the waste that will fill the rest of
the repository.

Will All Waste in the TRU Waste Inventory be
Shipped to WIPP?
Just because waste is included in the TRU waste inven-
tory, does not mean that DOE will necessarily seek to ship
it to WIPP or that EPA will approve it for disposal at WIPP.
Before any waste is shipped or disposed of at WIPP, EPA
seeks to ensure that the waste meets the waste accep-
tance criteria for WIPP and that DOE can characterize  and
track the waste.

Does the Current WIPP Waste Inventory Contain
High-level Waste (HLW)?
According to the WIPP Land Withdrawal Act, HLW cannot
be disposed of at WIPP. EPA will  not allow DOE to ship
any waste that does not meet the legal and technical re-
quirements for disposal at WIPP.  However, the recertifica-
tion waste inventory does contain a small amount of tank
waste from the Hanford site that is currently managed  as
high-level waste. None of this waste  has been approved by
EPA for disposal at WIPP.

DOE has provided documentation that indicates that these
Hanford tank wastes will be treated and will eventually be
able to meet the WIPP waste acceptance criteria. For the
purpose of Recertification, EPA is allowing DOE to put  this
waste in the projected inventory used in the performance
    What is the Transuranic (TRU) Waste Inventory?
    The TRU waste inventory describes the type, volume, and
    radioactivity of waste already disposed of in the WIPP,
    as well as waste at various sites across the country that
    could potentially be sent to WIPP. This information is
    used in the performance assessment (PA) calculations to
    demonstrate compliance with EPA's disposal regulations.

    Before the disposal of any waste at WIPP, EPA inspects
    the site that generated the waste to confirm that DOE
    can measure and track the amount, and radioactive and
    physical form of the waste. Since 1998, EPA has conduct-
    ed over 100 inspections at DOE waste generator sites.

    EPA also inspects operations at the WIPP site annually.
    During annual inspections EPA verifies tracking of waste
    being shipped from other DOE  sites, and confirms that
    WIPP continues to meet the waste limits established by
    EPA's certification.
assessment. EPA believes that it is prudent to include the
characteristics of waste that may potentially be disposed
of at WIPP to  ensure compliance with the agency's dispos-
al regulations  for TRU defense waste. Prior to disposal at
WIPP, EPA will ensure that all wastes meet the legal and
technical requirements for disposal.

Can Waste that is not Currently in the Inventory go
to WIPP?
As DOE continues to characterize waste throughout its
facilities, waste will continue to be identified for disposal
at WIPP.  TRU waste that is not included in the current
waste inventory may still be allowed for disposal at WIPP,
but only if all  of the following conditions are met:
         United States Environmental Protection Agency  I Office of Air and Radiation (6608J) I EPA402-F-05-007  I June 2005

1. EPA determines that the waste
   characteristics meet the limits for
   WIPP disposal,
2. Waste characteristics are reflected
   in the performance assessment,
3. The waste meets all the criteria
   for acceptability at WIPP.

EPA Requested Additional  Infor-
mation on the Waste Inventory
EPA asked for additional informa-
tion  on the Hanford Tank Waste and
K-Basin Sludges that were included
in the waste inventory for recertifica-
tion. EPA specifically asked DOE for
further explanation on how this waste
does or could meet the criteria for
WIPP waste. For more information
on this, see Issue  Paper #3, Hanford
Tank Wastes and K-Basin Sludges.

As part of the completeness review of
the Recertification Application,  EPA
also asked DOE to provide additional
information on volumes and weights
of all  materials placed in the reposi-
tory, including the waste containers
and packaging material. EPA has
also requested DOE's waste inventory

EPA's Technical Evaluation
During EPA's technical evaluation of
the Recertification Application,  EPA
will focus on the following aspects of
the updated TRU waste inventory:

1) EPA will examine DOE's process
   forgathering information about
   the waste inventory from the gen-
   erator sites.
2) EPA will verify that DOE appro-
   priately followed its process for
   gathering information about the
   waste inventory.
3) EPA will make sure that the infor-
   mation about the waste inventory
   is appropriately incorporated into
   the recertification  performance
              Locations of WIPP Generator Sites
     Major DOE TRU Waste Sites
     Major site with all WIPP waste
     already shipped
     Small Quantity Sites
  Approximately 28,000 cubic meters (990,000 cubic feet) of CH waste
  have been disposed of at the WIPP facility as of June  1, 2005. No RH
  waste has been disposed of at WIPP to date. Approximately 102,000 cubic
  meters (3,600,000 cubic feet) of CH waste, and about 7,080 cubic meters
  (250,000 cubic feet) of RH waste, are currently stored at DOE sites across
  the country and are awaiting disposal at WIPP.
Waste Limits

The WIPP Land Withdrawal Act (LWA)
limits the amount of TRU waste that
can be disposed of at WIPP to 6.2 mil-
lion cubic feet (175,570 cubic meters).
Of this amount, DOE is limited to
disposal of 250,000  cubic feet (7,080
cubic meters) of remote handled waste
according to an agreement with  the
State of New Mexico.

Contact handled (CH) waste is TRU
waste with  a surface dose not greater
than 200 millirem per hour. This waste
is typically  disposed  of in 55-gallon
steel drums, 100 gallon drums, ten
drum overpacks, standard waste boxes
or similar containers.

Remote handled (RH) waste is TRU
waste with  a surface dose rate of 200
millirem per hour or greater.  Because
this waste has higher radioactivity it
must be disposed  of at WIPP using re-
motely operated equipment.  Specialized
containers have been developed  for this
type  of waste.  This waste will be placed
in walls of the repository. The LWA puts
several limits on RH  TRU waste includ-
ing the radioactivity  concentration that
any one RH container may contain, the
total curies of waste activity that may
be emplaced, and the maximum  surface
dose rates of RH containers.

EPA has approved DOE's general plans
for the disposal of RH waste as WIPP.
The next step will be for DOE to request
EPA approval of site-specific plans to
characterize RH waste. EPA will then
conduct a thorough review of waste
characterization activities at each site.
                                                                               Fact Sheets in this Series:
                                       Recertification Overview   Fact Sheet No. 1
                                       Public Involvement        Fact Sheet No. 2
                                       Performance Assessment  Fact Sheet No. 3
                                       TRU Waste Inventory      Fact Sheet No. 4
                     Fact Sheet No. 5
                     Fact Sheet No. 6
          United States Environmental Protection Agency I  Office of Air and Radiation (6608J) I EPA402-F-05-007  I June 2005