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!!Nl7ED S"rATES ENVIRONMENTAI PROTEC'i6Oh1 AGENCy 

3 Q WASHINGTON, D.C. 20460 Z = 

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QFFICE OF 

AIR AND RADIA.TION 

David C. Moody, Manager 

Carlsbad Field Office 

Department of Energy 

P.O. Box 3090 

Carlsbad, NM 88221 

Dear Dr. Moody: 

On Oetober 30, 2006, the Environmental Protection Agency (EPA) received the 

Department of Energy's (DOE) "Transuranic (TRU) Waste Acceptance Criteria (WAC) 

for the Waste Isolation Pilot Plant, Revision 6.0, DOE/WIPP-02-3122" for review. 

EPA's review of Revision 6.0 of the WAC determined that this document 

eontains few changes that are specific to the radioactive eoniponent of the waste. It does 

however, remove the requirement for performing visual examination (VE) on a 

statistically determined sample of the waste eontainers to verify the results of 

radiography, also referred to as "VE as a QC check of radiography." (See 2 °aparagraph 

under Section G.1, Appendix G of the WAC, Rev. 6). Based on EPA's current waste 

characterization inspection experience, EPA concurs that, for TRU wastes that have well 

defined acceptable knowledge (AK), VE as a verification check for radiography may be 

unnecessary as a routine test. 

IHowever, EPA is concerned that in the future, as a result of the Iimitations of AK 

or due to the complex nature of a waste stream, the estimation of cellulosics, plastic, and 

rubber (CPR) contents of the waste containers by radiography alone may be difficult and 

could result in an erroneous quantification of the waste material parameters (WMPs) and 

assignment of the waste summary category group (SCG). This may result in over or 

underestimation of CPR quantities which in tun2 may affeet future WIPP performance 

assessment results. Therefore, EPA expects the Carlsbad Field OFfice to ensure that 

waste generator sites retain the capability to perform"VE as a QC check on radiography" 

as an option for retrievably-stored, contact-handled (CI1) T RU waste. Therefore, during 

EPA inspections, EPA may require generator sites to perform VE on a select number of 

retrievably-stored CH TRU containers that have undergone radiography to 

verifylcompare CPR values obtained via radiography. Such a comparison would ensure 

that the CPR quantifred by radiography are of suffrcient aecuracy and provide a 

defensible input value necessary for the future WIPP performance assessments. 

1,ntemetA4eress(uRF) o hrPJrw°,rrv.ep2.gov 

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EPA previously deternlined that the WAC contains signi tic ~~ ?t3y less detail on the 

characterization techniques used for remote-handlerl (Rii i-. aste than on th.e techniques 

used for CH waste (A-98-49, II-B3-99). Because ihese d' °ercet ,ernain ia Revision 6 

of the WAC, EPA continues to expect eacli RI1 sisc __ & .oa t s€ characterization 

plans based on the Waste Characterization Pro14S €1z ZInPl: n~;:io ' ~.~~ 1 (WCPIP). 

Thank you for providing us with an opportunity to 1 -=svie,v the Revision 6.0 of the 

WAC. If you have any questions or concerns, please contact Rajani Joglekar (202-343- 

9462) or Ed Feitcorn (202-343-9422). 

Sincerely, 

Juan 1?eves, Dirrcto. 

Raoa.F0:1P°ott 'tio;. D;Visio3: 

cc: (Electronic Distribution) 

Lloyd I'iper, CBFO 

Vernon Daub, CBFO 

Courtland Fesmire_ CBFO 

Ava Holland, CBFO 

Norma Castaneda, CBFO 

Martin Navarrete, CBFO 

Dennis Miehls, CBFO 

Allison, Pangle, CTAC 

Wayne Ledford, CTAC