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Case Study 3: Disposal Requirements for the Waste Isolation Pilot Plant WIPP

Case S-3 (WIPP). 2. Meeting the RCRA Challenge. RCRA is one of the principal regulatory statutes of concern to EM managers because it regulates the mixed waste found at many facilities . . . its dual regulation by the Resource Conservation and Recovery Act (RCRA) and the Atomic Energy Act cause some

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Case Study 3: Disposal Requirements for the Waste Isolation Pilot Plant WIPP

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    1. Case S-3 (WIPP) 1 Case Study 3: Disposal Requirements for the Waste Isolation Pilot Plant (WIPP)

    2. Case S-3 (WIPP) 2 Meeting the RCRA Challenge RCRA is one of the principal regulatory statutes of concern to EM managers because it regulates the mixed waste found at many facilities . . . its dual regulation by the Resource Conservation and Recovery Act (RCRA) and the Atomic Energy Act cause some challenges in its management.

    3. Case S-3 (WIPP) 3 Land disposal restrictions (LDRs) require waste to be treated to certain standards before disposal Treatment capacity for mixed waste is limited Meeting the RCRA Challenge

    4. Case S-3 (WIPP) 4 Meeting the RCRA Challenge Considerable difficulties occur in the attempt to implement RCRA at EM sites: According to RCRA standards, considerable amounts of mixed waste cannot be: Treated Stored, or Disposed of

    5. Case S-3 (WIPP) 5 EM Guiding Principles Safety First Risk Reduction Scientific Orientation Management Accountability Decision Transparency Stewardship

    6. Case S-3 (WIPP) 6 Case Study Introduction Disposal Requirements for the Waste Isolation Pilot Plant (WIPP) explores: Applying for the first No-Migration Variance (NMV) ever submitted in the history of the Environmental Protection Agency (EPA) Demonstrating regulatory compliance for a transuranic (TRU) waste repository

    7. Case S-3 (WIPP) 7 The WIPP The WIPP is an underground geologic repository for the permanent disposal of TRU waste.

    8. Case S-3 (WIPP) 8 WIPP Facility

    9. Case S-3 (WIPP) 9 The WIPP In 1984, Congress enacted the Hazardous and Solid Waste Amendments prohibiting land disposal of hazardous waste unless: Waste is treated to meet EPA requirements The EPA determines that the LDRs are not applicable

    10. Case S-3 (WIPP) 10 The WIPP For the EPA to determine that the LDRs are not applicable, it must be demonstrated to a “reasonable degree of certainty that there will be no migration of hazardous constituents from the disposal unit for as long the waste remains hazardous.”

    11. Case S-3 (WIPP) 11 The WIPP Under the NMV, the EPA must consider: Long-term land disposal Management of the hazardous waste Persistence, toxicity, mobility, and bioaccumulative potential of the waste

    12. Case S-3 (WIPP) 12 RH-TRU & CH-TRU Disposal Room in WIPP

    13. Case S-3 (WIPP) 13 The WIPP A NMV was required because the wastes shipped to the facility will be radioactive mixed wastes that contain: Transuranic radioisotopes RCRA-listed or -identified chemical constituents

    14. Case S-3 (WIPP) 14 The WIPP On November 14, 1990, the EPA’s NMD concluded . . . that the DOE had demonstrated . . . that hazardous constituents will not migrate from the WIPP disposal unit during the Test Phase . . . .

    15. Case S-3 (WIPP) 15 WIPP and New Mexico Regulations In 1996, DOE submitted a RCRA Part B Permit to the State of New Mexico In 1998, New Mexico issued a revised Draft RCRA Part B permit

    16. Case S-3 (WIPP) 16 WIPP and the NMV In 1993, DOE’s approach for the test phase changed and the NMV issued by EPA in 1990 became immaterial In June 1996, DOE submitted a new NMV to EPA In September 1996, Congress amended the WIPP Land Withdrawal Act deleting the need for NMV

    17. Case S-3 (WIPP) 17 The WIPP This case study illustrates the regulatory process for WIPP, which culminated in the first shipment of waste to the site on March 26, 1999

    18. Case S-3 (WIPP) 18 Review Question WIPP did not have to obtain a “No Migration Variance” to begin operation because: a. The “No Migration Determination” received from EPA for the test phase also addressed the operation of the facility. b. Congress removed the requirement to obtain a “No Migration Determination” in the FY 1997 Defense Authorization Bill. c. As a deep geologic repository, WIPP is not considered land disposal, and therefore RCRA does not apply.

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