This 2002 Facility Work Plan (FWP) has been prepared as required by Module VII, Permit Condition VII.U.3 of the Waste Isolation Pilot Plant (WIPP) Hazardous Waste Facility Permit, NM4890139088-TSDF (the Permit) (New Mexico Environment Department [NMED], 1999a), and incorporates comments from the NMED received on December 6, 2000 (NMED, 2000a). This February 2002 FWP describes the programmatic facility-wide approach to future investigations at Solid Waste Management Units (SWMU) and Areas of Concern (AOC) specified in the Permit. The Permittees are evaluating data from previous investigations of the SWMUs and AOCs against the most recent guidance proposed by the NMED. Based on these data, and completion of the August 2001 sampling requested by the NMED, the Permittees expect that no further sampling will be required and that a request for No Further Action (NFA) at the SWMUs and AOCs will be submitted to the NMED. This FWP addresses the current Permit requirements. It uses the results of previous investigations performed at WIPP and expands the investigations as required by the Permit. As an alternative to the Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFI) specified in Module VII of the Permit, current NMED guidance identifies an Accelerated Corrective Action Approach (ACAA) that may be used for any SWMU or AOC (NMED, 1998). This accelerated approach is used to replace the standard RFI Work Plan and Report sequence with a more flexible decision-making approach. The ACAA process allows a facility to exit the schedule of compliance contained in the facility's Hazardous and Solid Waste Amendments (HSWA) permit module and proceed on an accelerated time frame. Thus, the ACAA processcan be entered either before or after an RFI Work Plan. According to the NMED's guidance, a facility can prepare an RFI Work Plan or Sampling and Analysis Plan (SAP) for any SWMU or AOC (NMED, 1998). Based on this guidance, a SAP constitutes an acceptable alternative to the RFI Work Plan specified in the Permit. The NMED accepted that the Permittees are using the ACAA in a letter dated April 20, 2000.
