RH TRU Waste is radioactive waste that requires shielding in addition to that provided by the container to protect people nearby from radiation exposure. By definition, the radiation dose rate at the outer surface of the container is greater than 200 millirem per hour and less than 1,000 rem per hour. The DOE is proposing a process for the characterization of RH TRU waste planned for disposal in the WIPP. This characterization process represents a performance-driven approach that satisfies the requirements of the New Mexico Hazardous Waste Act, the Environmental Protection Agency (EPA) regulations for WIPP long-term performance, the transportation requirements of the Nuclear Regulatory Commission (NRC) and the Department of Transportation, as well as the technical safety requirements of RH TRU waste handling. The transportation, management and disposal of RH TRU waste is regulated by external government agencies as well as by the DOE itself. Externally, the characterization of RH-TRU waste for disposal at the WIPP is regulated by 20.4.1.500 New Mexico Administrative Code (incorporating 40 CFR 261.13) for the hazardous constituents and 40 CFR 194.24 for the radioactive constituents. The Nuclear Regulatory Commission certifies the shipping casks and the transportation system must meet DOT regulations. Internally, the DOE evaluates the environmental impacts of RH TRU waste transportation, handling and disposal through its National Environmental Policy Act program. The operational safety is assessed in the RH TRU Waste Safety Analysis Report, to be approved by the DOE. The WIPP has prepared a modification request to the Hazardous Waste Facility Permit that includes modifications to the WIPP facility for the safe receipt and handling of RH TRU waste and the addition of an RH TRU waste analysis plan. Modifications to the facility include systems and equipment for safe handling of RHTRU containers.
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