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UNITED STATES ENVIRONMENTAL PROTECTION ACENCY W 

WASHINGTON, D.C. 20460 

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AUG 2 J 2010 OFFICEOF 

AIR AND RADIATION 

Donald C. Gadbury 

Director, National TRU Program 

Carlsbad Field Office 

Department of Energy 

P.O. Box 3090 

Carlsbad, NM 88221 

Dear Mr. Gadbury: 

We received your letter dated August 24, 2010, requesting the U.S. Environmental 

P>-otection Agency's (EPA's) concurrence on the draft certification expansion memo you plan to 

issue to the Central Characterization Project (CCP) at the Idaho National Laboratory (INL). 

Your request is in accordance with the Carlsbad Field Office (CBFO) procedures that are 

intended to ensure that the U.S. Department of Energy's (DOE) Waste Isolation Pilot Plant 

(WIPP) site certifications correlate appropriately with EPA approvals for waste characterization 

activities at DOE transuranic (TRU) waste generator sites. 

EPA concurs that all waste characterization equipment, procedures and waste streams 

encompassed in DOE's draft certification expansion memo comport with all of EPA's existing 

approvals for contact-handled (CH) and RH waste at INL-CCP. This certification expansion adds 

the EPA Tier l approvals for the following: 

• Two 30-gallon drums overpacked in 55-gallon drums characterized using the 

EPA-approved remote-handled (RH) waste characterization 

processes/procedures implemented by INL-CCP (EPA Air pocket No. A-98- 

49; II-A4-130); 

• INL RH TRU debris containers belonging to the waste stream ID-HFEFS5400-RH, Lot 1 B characterized using the EPA-approved RH waste 

characterization processes/procedures implemented by INL-CCP (EPA Air 

Docket No. A-98-49; II-A4-131); and 

• OSPREYTM amma measurement system for repo rting the dose-rate fraction 

for 60Co and ~37Cs used by INL-CCP (EPA Air pocket No. A-98-49; 11-A4- 

131). 

ln addition, Attachment 4 of the certification expansion memo includes the revised tiering table 

reflecting changes made to the tiering designations since the baseline approval of January 12, 

2007. 

Intemet Address (URL) • http://www.epa.gov 

Recycled/Recyclable - Printed wfth Vegetable Oit Based Inks on Recycled Paper (Minimum 30 % Postconsumer) 
EPA has also received and reviewed Tier 2 tiering reports covering the waste characterization 

program implemented by CCP at INL and have found all changes made to be acceptable. EPA 

has concurred with the T2 changes implemented at INL-CCP. 

On November 2, 2005 and January 12, 2007, EPA respectively, approved INL-CCP's 

TRU waste characterization program for characterizing CH and RH waste prior to disposal at the 

Waste Isolation Plant. The inspection reports are available in the EPA Air pocket No. A-9$-49 

(Items II-A4-59 and II-A4-72). 

Thank you for providing us with an opportunity to review the draft certification 

expansion memo for INL-CCP. If you have any questions or concerns, please contact Rajani 

Joglekar at (202) 343-9462 or Ed Feltcorn at (202) 343-9422. 

Sincerely, 

Rajani Joglekar 

Center for Waste Management and Regulations 

cc: Electronic Distribution 

Ava Holland, CBFO 

Vernon Daub, CBFO 

Courtland Fesmire, CBFO 

J. R. Stroble, CBFO 

Norma Castaneda, CBFO 

Martin Navarrete, CBFO 

Dennis Miehls, CBFO 

J Wells, DOE-ID 

Allison Pangle, CTAC 

Wayne Ledford, CTAC 

Steve Zappe, NMED