The U.S. Department of Energy's (DOE) Waste Isolation Pilot Plant (WIPP), located in southeastern New Mexico, has been construction for the disposal of long-lived transuranic (TRU) waste. The New Mexico Environment Department (NMED) issued a Hazardous Waste Facility Permit (the Permit) to dispose of mixed waste at WIPP effective November 26, 1999. This Permit does not regulate the radioactivity in the waste. The DOE emplaced 44 shipments of non-mixed transuranic waste in Room 7 of Panel 1 before the Permit became effective. There also are a large number of waste containers at the generating sites that have been at least partially characterized prior to the effective date of the Permit. Section IV.B.2.b of the NMED Permit contained language which appeared to prohibit emplacement of non-mixed wastes that were not characterized in accordance with the requirements of the Permit's Waste Analysis Plan (WAP). This report provides a technical evaluation, conclusions, and recommendations of the following Section IV.B.2.b issues: (1) A comparison of pertinent WAP requirements with pre-Permit waste characterization; and (2) A risk analysis of the pre-Permit waste emplaced in Room 7. Expected and bounding risks from routing operations and possible accidents are evaluated.