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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Q WASHINGTON, D.C. 20460 

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Mr. Jose R. Franco 

Manager, Carlsbad Field Office 

U.S. Department of Energy 

P.O. Box 3090 

Carlsbad, NM 88221-3090 

Dear Mr. Franco: 

SEP 4 2012 OFFICE OF 

AIR AND RADIATION 

This letter is to inform the U.S. Department of Energy (DOE) that the U.S. Environmental Protection 

Agency has completed review of DOE's remote-handled (RH) transuranic (TRU) Waste 

Characterization Program Implementation Plan (WCPIP), DOE/WIPP-02-3214, Revision 3, Draft E 

provided to EPA on August 16, 2012. EPA concurs with the RH waste characterization requirements 

described in Revision 3 with the exception of the two items discussed below. 

Prior to issuing this revision, DOE must delete the last bolded bullet shown in strike out in the 

paragraph on Page 64 of the document cited below. This deletion is necessary because it goes beyond 

the requirements of 40 CFR 194.22. 

5.0 Qualification of AK Information 

As described in Section 3.0, AK information used dircctly, in whole or in part, to detei -inine in .. 

combination of the following four methods: 

• Peer review, conducted in a manner compatible with NUREG-1297, Peer Review for 

High-Level Nuclear Waste Reposftories, February, 1988. 

• Corroborating data. 

• Confirmatory testing. 

• Evidence of a QA program that is equivalent in effect to ASME NQA-1-1989 edition, 

ASTM NQA-2a-1990 addenda, part 2.7, of ASME NQA-2-1989 edition, and ASME 

NQA-3-1989 edition (excluding 2.1 (b) and (c) and Section 17.1). 

On December 16, 2010, when concurring with the RH WCPIP, Revision 2, we restricted the use of 

con-oborating data to qualify Acceptable Knowledge (AK) information, since the method has never been 

used for AK qualification. In our letter, we stated that: 

"... Upon receiving DOE's approval of this process, but before its implementation at an 

RH site, EPA will review relevant process documentation. This will include a report 

discussing the use of the corroborating data selection process, type and nature of 

corroborating data to be used, and other primary information....... 

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

RecycledlRecyclable - Printed with Vegetable Oil Based Inks on 100% Postconsumer. Process Chlorine Free Recycied Paper 
EPA requests the addition of the relevant text from our letter dated December 16, 2010, as a footnote in 

Section 5.0 of the RH WCPIP, Revision 3, Draft E. When these changes are made, please provide us a 

final copy. 

If you have any questions regarding this concurrence, please contact Rajani Joglekar (202-343-9462) or 

Ed Feltcorn (202-343-9422). 

Sincerely, 

-- ~- ! P~ . 

Tom Pcake, Director 

Center for Waste Management and Regulations 

Enclosure 

cc (electronic distribution): 

Christine Gelles, DOE EM 

Doug Tonkay, DOE EM 

Alton Harris, DOE EM 

J R Stroble, CBFO 

Randy Unger, CBFO 

Court Fesmire, CBFO QA 

Marcus Pinzel, CBFO NTP 

Norma Castaneda, CBFO NTP 

D K Ploetz, WTS-CCP 

Mike Sensibaugh, WTS-CCP 

Irene Quintana, WTS-CCP 

Trais Kliphuis, NMED 

Tim Hall, NMED 

Jonathan Edwards, EPA 

Alan Perrin, EPA 

Raymond Lee, EPA 

Patrick Kelly, SCA