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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 Paper 
1. 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, 

I ! 

pze'~' 

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