An Alternative to Performing Remote-Handled Transuranic Waste Container Headspace Gas Sampling and Analysis

The Waste Isolation Pilot Plant (WIPP) is operating under a Resource Conservation and Recovery Act (RCRA) Hazardous Waste Facility Permit (HWFP) for contact-handled (CH) transuranic (TRU) waste. The HWFP contains limitations on allowable emissions from waste disposed in the underground. This environmental performance standard imposed on the WIPP consists of limiting volatile organic compound (VOC) emissions from emplaced waste to ensure protection of human health and the environment. The standard is currently met by tracking individual waste container headspace gas concentrations, which are determined by headspace gas sampling and analysis of CH TRU waste containers. The WIPP is seeking a HWFP modification to allow the disposal of remote-handled (RH) TRU waste. Because RH TRU waste is limited to approximately 5% of the waste volume and is emplaced in the disposal room walls, it is possible to bound the potential RH TRU waste contribution to VOC emissions using conservative upper bounds. These conservative upper bounds were developed as an alternative to RH TRU waste canister headspace gas sampling and analysis. The methodology used to perform the calculations used to evaluate VOC emissions from emplaced RH TRU waste canisters applied the same equations as those used to evaluate VOC emissions in the original HWFP application