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o~ 44 PROSe UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460

9 2010 OFFICE OF SEP AIR AND RADIATION Donald C. Gadbury Manager, National TRU Program Carlsbad Field Office U.S. Department of Energy P.O. Box 3090 Carlsbad, NM 88221-3090
Dear Mr. Gadbury:

On May 20 and 21, 2010, the Carlsbad Field Office (CBFO) requested that the U.S. Environmental Protection Agency (EPA) approve addition of remote-handled (RH) transuranic (TRU) debris waste from Argonne National Laboratory (ANL) K-Wing to a previously approved ANL debris waste stream (AERHDM) at as a Tier 1 change. This letter approves the addition of K-Wing waste containers and as a result, INL may dispose of this waste at the Waste Isolation Pilot Plant (WIPP). The enclosed report (EPA Docket No. A-98-49; IJ-A4-132) supports EPA's approval decision.The Central Characterization Project (CCP) characterized this waste using remotehandled (RH) waste characterization processes approved by EPA in January 2007. EPA determined that the procedures and processes used by ANL-CCP staff for characterizing debris waste stream AERHDM were adequate. As a result of our evaluation, EPA has made several changes to the tiering table (See Table 1 of the enclosed report). The revised Tier 1 and Tier 2 changes will apply to all CCP's RH TRU waste characterization activities at ANL. While previous Tier 1 changes adding RH waste streams have been container limited, this approval is not limited to a specific number of waste containers of K-Wing waste added to AERHDM. ANL-CCP may add K-Wing waste containers to the approved waste streams, if: • Additional containers have similar pedigree as the approved waste stream; and • ANL-CCP can demonstrate that the radionuclide scaling factors used for the RH waste stream (AERHDM) are technically appropriate for use in the Dose-to-Curie (DTC) determination of the radiological characterization of the additional containers. Any addition of new K-Wing waste containers to the approved waste stream must comply with the revised ANL-CCP tiering table (see Table 1 of the enclosed report), including the following:

Intemet Address (URL) s http://www.epa.gov Recycled/Recyclable 0 Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper1. EPA notification: When notifying EPA, an INL-CCP must (a) identify the approximate

number of additional containers and the approximate additional volume of waste, and (b) provide the timeframe for waste generation, characterization and disposal.

2. Submission of documents: Upon characterizing a sufficient number of containers to generate 1-2 Batch Data Reports, INL-CCP must provide the list of characterized containers and a revised AKSR and supporting source documents, and an updated radiological characterization report. If any of the documents'a' r`e not changed, CBFO should make that clear to EPA. From this list, EPA may select a few containers for a detailed review to verify that the additional containers belong to the approved waste stream.
EPA expects CBFO to notify us of the addition of containers to this waste stream during our weekly call.
If you have any questions regarding this approval, please contact Rajani Joglekar at (202) 343-9462 or Ed Feltcorn at (202) 343-9422.


### Sincerely,



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# ~ ' Tom Peake, Director Center for Waste Management and Regulations

Enclosure

cc: Electronic Distribution Christine Gelles, DOE EM Alton Harris, DOE EM David Moody, CBFO Ava Holland, CBFO QA J R Stroble, CBFO Courtland Fesmire, CBFO Martin Navarrete, CBFO QA Dennis Miehls, CBFO QA D K Ploetz, WTS-CCP Mike Sensibaugh, WTS-CCP Mark Pearcy, WTS-CCP Allison Pangle, CTAC Wayne Ledford, CTAC Steve Zappe, NMED