WIPP Facility Work Plan for Solid Waste Management Units

Abstract

This Facility Work Plan (FWP) has been prepared as required by Module VII,Section VII.M.1 of the Waste Isolation Pilot Plant (WIPP) Hazardous Waste Permit, NM4890139088-TSDF (the Permit); (NMED, 1999a). This work plan describes the programmatic facility-wide approach to future investigations at Solid Waste Management Units (SWMUs) and Areas of Concern (AOCs) specified in the Permit. This FWP addresses the current Permit requirements. It uses the results of previous investigations performed at WIPP and expands the investigations as required by the Permit. As an alternative to the Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFI) specified in Module VII of the Permit, current New Mexico Environment Department (NMED) guidance identifies an Accelerated Corrective Action Approach (ACAA) that may be used for any SWMU or AOC (NMED, 1998). This accelerated approach is used to replace the standard RFI Work Plan and Report sequence with a more flexible decision-making approach. The ACAA process allows a Facility to exit the schedule of compliance contained in the Facility’s Hazardous and Solid Waste Amendments (HSWA) permit module and proceed on an accelerated time frame. Thus, the ACAA process can be entered either before or after an RFI Work Plan. According to NMED’s guidance, a facility can prepare an RFI Work Plan or Sampling and Analysis Plan (SAP) for any SWMU or AOC (NMED, 1998). Based on this guidance, a SAP constitutes an acceptable alternative to the RFI Work Plan specified in the Permit. The scope of work for the RFI Work Plan or SAP is being developed by the Permittees. The final content of the RFI Work Plan or SAP will be coordinated with the NMED for submittal on May 24, 2000. Specific project-related planning information will be included in the RFI Work Plan or SAP. The SWMU program at WIPP began in 1994 under U.S. Environmental Protection Agency (EPA) regulatory authority. NMED subsequently received regulatory authority from EPA. A Phase I RFI was completed at WIPP as part of a Voluntary Release Assessment (VRA). The risk-based decision criteria recommended by EPA for the VRA were contained in a proposed Corrective Action rule for SWMUs (EPA, 1990). EPA Region VI has issued new risk-based screening criteria applicable to the WIPP SWMUs and AOCs.