The amended Waste Isolation Pilot Plant (WIPP) Land Withdrawal Act (LWA) of 1996, P. L. 104-201, 110 Stat. 2422 [1], requires the U.S. Department of Energy (DOE) to prepare and submit documentation demonstrating continued compliance with the Environmental Protection Agency's (EPA's) radioactive waste disposal standard 40 CFR Part 191 [2] every five years starting after first waste receipt in accordance with the criteria of 40 CFR 194 [3]. The DOE submitted the WIPP Compliance Certification Application (CCA) [4] to EPA in 1996 and it was approved by EPA in 1998. The first shipment of waste was received for disposal at WIPP on March 26, 1999. Subsequently, the first Compliance Recertification Application (CRA) [5] was submitted to EPA on March 26, 2004. Reflecting on lessons learned from the previous applications, the DOE is proposing a change in the format for the next CRA due on March 26, 2009.The DOE has an objective to communicate plans, schedules and recertification methodology as early as possible to EPA and stakeholders. With that objective in mind, the DOE began communicating the proposed new application strategy to the EPA in mid-2006. For the 2009 CRA submittal, the DOE is proposing to align the document's format to match each section to the requirements of the WIPP compliance criteria at 40 CFR Part 194 [3] and the EPA recertification support documents.The benefits of the revised format include improved integration of all regulatory, operational, and programmatic activities; easier access to historical information and decisions; a decreased level of effort for DOE, EPA and Stakeholder review; enhancing the likelihood of a quicker recertification decision; and potentially reducing DOE's post-submittal CRA tasks.This paper will provide insight to those wishing to understand and be kept abreast of changes in the WIPP's certification process.
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