WIPP COMPLIANCE RECERTIFICATION – A LEANER, MEANER APPLICATION

The U.S. Department of Energy (DOE) submitted the Compliance Recertification Application (CRA) to the U.S. Environmental Protection Agency (EPA) in March 2004. The 2004 CRA is the second “application” and the first of several such renewal applications for the Waste Isolation Pilot Plant (WIPP). In contrast to the first application, Compliance Certification Application (CCA), the CRA is noticeably leaner. The layout of the 2004 CRA simplifies the type and amount of documentation that is utilized to demonstrate continued compliance. For example, the 2004 CRA is about 65% smaller than the CCA by page count, and the content is even more focused on addressing specific certification criteria, rather than describing a broader range of WIPP technical and regulatory topics. The 2004 CRA still provides extensive information that covers the general, containment, and assurance requirements, as well as describing the programs that protect human health and natural resources.

For future WIPP recertification efforts, DOE is dedicated to ensuring continued compliance while keeping the amount of produced documentation to a minimal level. There are two ways in which this has been addressed. First, by reducing the use and production of paper-intensive publications through implementation of electronic documentation and reporting systems, the regulatory reporting process can be more efficient. This will also help to ensure more timely notifications through modern delivery systems. Second, through restructuring and consolidating the framework of compliance applications, the supplied information is focused on directly responding to the EPA’s standards for deep geologic disposal of radioactive waste. Use of these methods, along with the concurrence of the EPA will allow DOE to efficiently fulfill a broad range of requirements throughout the next several decades.