UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

Mr. J. R. Stroble 

Manager, National TRU Program 

Carlsbad Field Office 

U.S. Department of Energy 

P.O. Box 3090 

Carlsbad, NM 88221-3090 

Dear Mr. Stroble: 

JAN 2 9 2013 

OFFICE OF 

AIR AND RADIATION 

On August 13,2012 and October 1, 2012, the U.S. Department of Energy (DOE), Carlsbad Field Office 

(CBFO) requested the U.S. Environmental Protection Agency (EPA) to approve the addition of the 

following two Tier 1 (Tl) changes to the Advanced Mixed Waste Treatment Project's (AMWTP) 

contact-handled (CH) transuranic (TRU) waste characterization program implemented by the Idaho 

Treatment Group (ITG): 

• Debris (S5000) and solids (S3000) from the Argonne National Laboratory-East (ANLE); and 

• Debris (S5000) from the Material Fuel Complex (MFC) at the Idaho National Laboratory (INL). 

The Tl requests were for the acceptable knowledge (AK) process implemented by AMWTP-ITG, 

therefore, EPA approval is limited to AK as discussed in the enclosed report (see EPA Docket No. A98-49: II-A4- 169). With this approval of the AK aspect of the characterization process, AMWTP-ITG 

(responsible since late 2011 for AMWTP's CH TRU waste characterization program), may characterize 

physical and radiological contents ofthese two waste types using the equipment, processes and 

procedures that EPA approved during October 2006 baseline approval (see EPA Docket No A-98-49: IIA4-66, October 3, 2006). AMWTP-ITG needs to confirm the AK using Nondestructive Assay (NDA) 

and Nondestructive Examination (NDE) by generating batch data reports (BDR) for these waste types 

for EPA review before the subject waste is disposed of at the Waste Isolation Pilot Plant (WIPP). 

Previously, when issuing the October 2006 AMWTP baseline approval, EPA identified the addition of a 

new Summary Category Group from other DOE sites such as Hanford, ANLE and MFC, as a Tier 1 

change. According to the requirements of 40 CFR 194.8 (b), DOE appropriately requested approval as a 

Tier 1 change to the AMWTP's CH TRU baseline approval. 

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

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer) 
During August through November 2012, EPA conducted a desktop evaluation of AK documentation 

supporting the two Tl changes. During the evaluation, EPA did not identify any findings or concerns. 

Based on this evaluation and the continued compliance inspection mentioned below, EPA has 

determined that the AK characterization of the subject ANLE and MFC waste types by AMWTP-ITG is 

adequate. This approval, however, makes changes to the tiering table provided with the baseline 

approval; these changes are shown in bold. 

In October 2012, during a continued compliance inspection ofiTG implemented CH TRU waste 

characterization program at AMWTP, EPA evaluated AK and NDE for technical adequacy. EPA 

identified two concerns which AMWTP-ITG addressed to EPA's satisfaction. Subsequently, EPA 

determined the program implementation was technically adequate. 

During the evaluation, EPA noticed that many of the AMWTP document titles include the phrase, 

"Baseline Report." In the WIPP regulations, the term "baseline" has specific regulatory significance, 

such that it is reserved for EPA actions and, therefore to prevent confusion, no DOE WIPP-related 

documents prepared for EPA review should use the term "baseline." 

If you have any questions regarding this approval, please contact Ed Feltcorn at (202) 343-9422 or 

Rajani Joglekar at (202) 343-9462. 

Enclosure 

cc: Electronic Distribution 

Joe Franco, CBFO 

Tom Morgan, CBFO NTP 

Marcus Pinzel, CBFO NTP 

Norma Castaneda, CBFO NTP 

Courtland Fesmire, CBFO QA 

Ben Roberts, DOE ID 

Jerry Wells, DOE ID 

Dave Haar, AMWTP ITG 

Tim Hall, NMED 

Raymond Lee, EPA HQ 

Site Documents 

Sincerely, 

~~~O 

A , /7 ~ r?P 

To~ ~ Dif:ctor 

Center for Waste Management and Regulations