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A'Z UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

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(~ y OFFICE OF 

U EC 15 2`0 10 AIR AND RADIATION 

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 December 6, 2010, the U.S. Department of Energy (DOE), Carlsbad Field Office 

(CBFO) sent a letter to the U.S. Environmental Protection Agency (EPA) requesting concurrence 

with changes to the DOE's Waste Acceptance Criteria (WAC) document used for accepting 

transuranic (TRU) waste for disposal at the Waste Isolation Pilot Plant (WIPP). These changes 

were necessary to make the WAC compatible with the recent changes to the hazardous waste 

facility permit that the State of New Mexico issued earlier this year. EPA comments are attached 

in the enclosed Attachment A. Upon addressing EPA comments CBFO can issue the revised 

WAC for implementation at TRU waste sites characterizing waste for WIPP disposal and 

seeking DOE's initial certification or annual recertification for waste disposal. EPA concurs with 

the proposed changes as compatible with EPA regulations at 40 CFR 194.24. Please forward a 

courtesy copy of the revised WAC when distributed for implementation. 

In 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 & Regulations 

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

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100 % Postconsumer, Process Chlorine Free Recycled Paper 
cc: Electronic Distribution 

Alton Harris, DOE EM 

Ed Ziemianski, CBFO 

Courtland Fesmire, CBFO 

Norma Castaneda, CBFO 

Martin Navarrete, CBFO 

Dennis Miehls, CBFO 

Steve Zappe, NMED 

Allison Pangle, CTAC 

Patrick Kelly, SCA 
A"Q'"rACHMENT A 

Below are EPA comments on Department of Energy's transuranic waste acceptance criteria for 

the Waste Isolation Pilot Plant (DOE-WIPP-032-3122, Revision 7.0, Draft O), which EPA 

reviewed for concurrence. 

(:eneral Comments: 

1. Page 21, Section 3.1.4.1 EPA Compliance Recertification llecision........ The results o/* 

thfs determinatfon are reported in the WWIS database on a payload ba.sis. The methods 

used to quantify the above waste components for purposes of EPA compliance are 

discussed in Appendices A, F and G. EPA compliance is also detailed in the Waste 

Analysis Plan (WAP) and the Remote-Handled Waste Characterization Program 

lmplementation Plan (WCPIP). The purpose of this comment is to point out that while 

WAC guidance may be helpful, other documents may provide more useful information 

pertinent to the overall system of controls, particularly for Acceptable Knowledge (AK). 

EPA recommends that CBFO inserts the following text in the Executive Summary: 

"When implementing the WAC a TRU Site should refer to other WIPP-related 

documents, namely the Waste Analysis Plan (WAC), Revision _, dated and the 

Remote-Handled Waste Characterization Program Implementation Plan (WCPIP), 

Reviison _, dated , for information pertinent to the system of controls including 

compilation of Acceptable Knowledge (AK)." 

2. Page 10, List of Acronyms: The term QAO has been deleted from the list of acronyms but 

still appears in the text, i.e., pages 103 and 108. 

3. Pages 103 and 108, Appendix G: The 3`dparagraph of G.1 states "Visual examination 

does not require audio/visual recordings of the examination; the examination is 

documented on a data form and certified with signatures from two qualified VE 

operators". However, the first bullet in G.3 states "The video/audio media shall record 

the waste packaging event..." These two statements appear contradictory. Suggest 

rewording the G.1 text to read " Visual examination does not require audio/visual 

recordings of the examination if the examination is documented. " 

Comments Specific to Appendix A: 

1. Page 63, 13` hline from the bottom: "Scaling Factor(s)" appears many times in Appendix 

A, but no general definition or explanation of this term has been provided. 
2. Section A.2.2.1, page 64, 9`hline of the paragraph. The sentence reads: "Assumptio»s 

made in this delineation shall be identified." Recommend that the sentence read: 

"Assumptions made in this delineation shall be identified and the basis or rationale.for 

each shall be technically justified." 

3. Page 65, 2"dbullet from top, 3`dline: It is suggested that the word "comprise" be replaced 

with "contribute to" to read "... radionuclides that contribute to 95% of the radiological 

hazard ..." to be consistent with Appendix A and the main document. 

4. Section A.2.2.2, page 65, 2" dbullet: Special nuclear material is not defined. A definition 

is needed to distinguish "special nuclear material (SNM)" from "nuclear material." 

5. Page 66, Table A-1. It is suggested that all acronyms/notations employed in the table be 

defined in a footnote to the table to make the table clear and independent of the text. 

6. Page 67, middle of last paragraph; also, page 69, close to the end of the first paragraph 

Percent recovery (%R) and its relationship to accuracy should be explained when it is said 

that "Accuracy is reported as %R." 

7. The definition of "accuracy" is missing from Appendix C(Glossary). 

8. Page 69, the sentence before the last in the first paragraph: The sentence reads 

"Precision is reported as percent relative standard deviation (% RSD)." Appendix C 

states that precision is "often expressed as a standard deviation or relative percent 

difference. "% RSD, which is the same as the coefficient of variation, and relative 

percent difference (RPD) are not defined in Appendix C. (RPD appears in the third 

column of Table A-4 on page 73.) 

9. Page 69, Table A-2: The footnote identifier "a" is not provided in the table. Clarification 

and/or a reference for the inequality appearing in the footnote of the table would be 

useful. 

10. Page 73, Table A-4: The footnote text to identifer "e" for the column Corrective Action. 

See Radioisotopic Tracer is not provided. The terms in the column labeled QC Sample 

are not defined in Appendix C, e.g., Matrix Spike, Laboratory Control Sample and 

Radioisotopic Tracer. 
11. Global Editorial conunent. Throughout the document (the main body and the 

appendices), whenever a section has been referenced, the first letter of the word section 

has been changed from upper case "S" to lower case "s." This change has not been made 

consistently.