UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WA S HIN GT O N , D.C. 20460



### Mr. J. R. Strobl e Manager , National TRU Program Carlsbad F ield Office U.S. Depa rtme nt of Energy P.O

. Box 3 090 Carlsbad , NM 88221-3090
Dear Mr. Strob le: 

### 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 O ffice (CBFO) requested the U.S. Environmental Protection Agency (EPA) to approve the addition of the following t wo Tier 1 (Tl ) changes to the Advanced Mixed Was te Treatment Project ' s (AMWTP ) contact-handled (C H ) transuranic (TRU) waste characterization program implemented by the Idaho Treatment Group (ITG):

• Deb ri s (S5000) and solids (S3000) from the Argonne National Laboratory-East (ANLE); and
• Deb ris (S5000) from the Material Fuel Comp lex (MFC) at th e Idaho National Laboratory (INL).
The Tl requ ests were for the acceptable knowledge (AK) process implemented by AMWTP-ITG , th erefore, EPA approval i s limited to AK as discussed in the enclosed report (see EPA Docket No. A98-49: II -A4- 1 69). With this approval of the AK aspect of the characterization process, AMWTP-ITG (responsib le s in ce late 2011 for AMWTP's CH TRU waste characterization program), may characterize physic a l and radio logical contents ofthese two waste types using the e quipment, processes and proc ed ures that EPA approved during October 2006 base li ne approval (see EPA Docket No A-98-49: IIA4-66, October 3, 2006)

. AMWTP-ITG needs to confirm th e 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 issu ing the October 2006 AMWTP ba se line approval, E PA identified the addition of a ne w Summary Catego ry Group from other DOE sites suc h as Hanford , ANLE and MFC, as a Tier 1
c h ange
. According to the requirements of 40 CFR 194.8 (b) , DOE appropriate ly 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 20 12, 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 -I TG 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 prog ram 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 th e 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 te rm "baseline" has specific regulatory significance, such that it is reserved for EPA actions and, therefore to prevent confusion, no DOE WIPP-related document s 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 Ra ymon d Lee, EPA HQ Site Documents Sincerely, 

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