Jo SED STq p

~
S UNITED STATES ENVIRONMENTAL PROTECTION AGENCY o mwo Q WASHINGTON, D.C. 20460

o C PROSVO

~ 2 

### 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 PaperIf 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 Site Documents