Evaluation of Contact-Handled Transuranic Waste Acceptable Knowledge Confirmation Using Headspace Gas Sampling and Analysis

The Waste Isolation Pilot Plant (WIPP) Hazardous Waste Facility Permit (HWFP) limits the allowable emissions of volatile organic compounds (VOCs) from contact handled (CH) transuranic (TRU) waste. The environmental Performance standard within the HWFP, Module IV, Table IV.D.1, prescribes the allowed VOC emissions from the waste to ensure protection of human health and the environment. Compliance with the performance standard to ensure control of VOC emissions is based on VOC concentrations and monitoring in the underground. One of the mechanisms used to ensure compliance with the emissions standards is measuring the VOC concentration in the headspace gas of waste containers prior to disposal. Headspace gas sampling and analysis is the waste characterization activity used to determine the concentration of VOCs in the headspace of waste containers. In addition to being used to demonstrate compliance with the emissions standards of Module IV, Table IV.D.1, the results of the headspace gas sampling and analysis are used to confirm the hazardous wastes identified in the acceptable knowledge (AK) process. Headspace gas sampling and analysis has been an ongoing part of the CH TRU waste characterization program and therefore data are now available concerning its use and applicability. The information from approved Waste Stream Profile Forms (WSPFs) and the headspace gas sampling and analysis results for over 16,000 containers of CH TRU waste were considered as part of this study. The headspace gas sampling and analysis results are based on data from the WIPP Waste Information System (WWIS). These results were evaluated to determine the usefulness of headspace gas sampling and analysis for confirming AK information. The evaluation shows that the reliability of using the results of headspace gas sampling and analysis to confirm AK information can be grouped by mixed and non-mixed waste streams. In general, for mixed waste streams due to VOCs (i.e., carrying VOC-related hazardous waste numbers), there is no reliable comparison that can be made for the detection of a particular target analyte and its associated hazardous waste number(s) based on the AK information on a compound by compound basis. However, for non-mixed waste streams, the results of headspace gas sampling and analysis show a better correlation to the AK information