PREPARATIONS AND PLANNING FOR EPA RECERTIFICATION OF THE WASTE ISOLATION PILOT PLANT

摘要

The Waste Isolation Pilot Plant (WIPP) Recertification Project was established to meet thernrequirement of the WIPP Land Withdrawal Act (LWA)1 to demonstrate continued compliancernwith U.S. Environmental Protection Agency (EPA) disposal regulations at five-year intervals.rnThis paper delineates the objective of the first recertification effort, sets out project goals, andrnestablishes guiding assumptions. It describes the overall direction for a highly complex andrninterdependent set of tasks leading to recertification of the WIPP repository in 2004.rnThis paper also lays out a high-level schedule for producing the WIPP CompliancernRecertification Application (CRA). The major principle behind recertification is that the EPArnrecertification decision will not involve rulemaking or judicial review. To ensure that the EPA isrnable to retain this principle, the U.S. Department of Energy (DOE) will not be incorporatingrnchanges through the recertification process. Only changes previously approved by the EPA willrnbe included in the CRA. The EPA can approve significant changes to the current WIPPrnCertification through rulemaking. Non-significant changes are approved without rulemakingrnthrough the planned change reporting process [Title 40 Code of Federal Regulations (CFR),rnSection 194.4(b)].rnThe EPA WIPP Recertification Guidance2 is clear in that, if the DOE proposes significantrnchanges to the WIPP disposal system, those changes must be reviewed and approved by the EPArnprior to or following recertification, through a “planned change” process. Integral to thernrecertification effort is the concept of a “blackout period” during which the DOE will not submitrnto the EPA significant changes to the WIPP Compliance Certification. This blackout period isrnintended to allow the EPA sufficient time to act on planned change requests prior tornrecertification, anticipating that a rulemaking may be required for such allowances.rnAs planned, the DOE will provide, as part of the CRA, the results of impact, performance, andrncompliance assessments that examine the combined effects of changes made to the disposalrnsystem since the initial WIPP Compliance Certification. This assessment will be performedrnutilizing repository monitoring data and the results of any compliance-related experiments.rnCompliance areas that have not changed since the submission of the first applicationrn(Compliance Certification Application, or CCA) will be incorporated into the CRA by reference.rnThe first CRA will be precedent setting, in that any processes developed and materials submitted