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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

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JUL ® 9 2013 

OFFICE OF 

AIR AND RADIATION 

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: 

On February 20, 2013, the U.S. Department of Energy (DOE), Carlsbad Field Office (CBFO) requested 

the U.S. Environmental Protection Agency (EPA) to approve, as a Tier 1(T1) change, the addition of 

the following two contact-handled (CH) transuranic (TRU) debris waste types to the BN-510 waste 

stream. This waste is being characterized at the Advanced Mixed Waste Treatment Project's (AMWTP) 

by the Idaho Treatment Group (ITG): 

• Direct shipment (uncompacted) and supercompaction of contact-handled (CH) debris [Summary 

Category Group (SCG) S5000]; and 

• Direct shipment of homogenous solid waste (SCG S3000). 

The T1 change request was only for the acceptable knowledge (AK) process being implemented by ITG 

at AMWTP, therefore, EPA review was limited to AK as discussed in the enclosed report (see EPA 

Docket No. A-98-49: II-A4-174). Per the October 3, 2006 baseline approval, no radiological and 

physical analyses of debris waste containers can occur until EPA approves AK for the debris waste 

containers from other TRU Sites (such as Hanford, LANL, ANLE and MFC) being added to the BN-510 

waste originating at INL. With this approval of the AK , ITG may characterize physical and radiological 

contents of these two waste types using the equipment, processes and procedures that EPA approved 

during the October 2006 baseline approval (see EPA Docket No A-98-49: II-A4-66, October 3, 2006). 

EPA's January 2013 approval of T1 changes for ANLE and MFC wastes required that NDA and NDE 

BDRs be submitted for EPA review prior to the first shipment of those wastes to Waste Isolation Pilot 

Plant (WIPP) for disposal. In this case, however, this requirement has been modified so that these BDRs 

can be submitted along with the Tier 2 changes AMWTP routinely submits on a quarterly basis. EPA 

has determined that ITG can adequately prepare BN-510 BDRs for recording radiological and physical 

contents of waste containers managed at the site. This determination was made at EPA's evaluation of 

NDA and NDE BDRs during the Continued Compliance Inspection of February 2013 and EPA's 

February 2013 review of the ANLE and MFC BDRs. Therefore, no BDR submission is necessary prior 

to the first shipment of the subject waste to WIPP for disposal. 

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

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 1 QO% Postconsumer, Process Chlorine Free Recycled Paper 
If you have any questions regarding this approval, please contact Ed Feltcorn at (202) 343-9422 or 

Rajani Joglekar at (202) 343-9462. 

Sincerely, 

Tom Peake, Director 

Center for Waste Management and Regulations 

Enclosure 

cc: Electronic Distribution 

Joe Franco, CBFO 

Tom Morgan, CBFO NTP 

Marcus Pinzel, CBFO NTP 

Norma Castaneda, CBFO NTP 

Acting Manager, CBFO QA 

Ben Roberts, DOE ID 

Jerry Wells, DOE ID 

Dave Haar, AMWTP ITG 

Tim Hall, NMED 

Trais Kliphuis, NMED 

Raymond Lee, EPA HQ 

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