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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

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OFFICE OF 

AIR AND RADIATION 

David Moody, Ph.D. 

Manager, Carlsbad Field Office 

U.S. Department of Energy 

P.O. Box 3090 

Carlsbad, NM 88221-3090 

Dear Dr. Moody: 

On October 21, 2009, the Carlsbad Field Office (CBFO) requested that the U.S. 

Environmental Protection Agency (EPA) approve a proposed Tier 1 change containing three 

retrievably stored, remote-handled (RH) transuranic (TRU) debris waste streams (ID-ANLES5000, ID-HFEF-S5400, and ID-INTEC RH) for disposal at the Waste Isolation Pilot Plant 

(WIPP). This letter approves two (ID-ANLE-S5000 and INL-HFEF-S5400, Lot 1 A) of the three 

waste streams. Our evaluation of the waste streams is discussed in detail in the enclosed report 

(EPA Docket No. A-98-49; II-A4-122) which has been placed in the Agency's public docket. 

Idaho National Laboratory (INL) may dispose of these two waste streams at the WIPP. 

The Central Characterization Project (CCP) characterized these wastes using remotehandled waste characterization processes approved by EPA in February 2007. As a result of our 

evaluation, EPA identified two concerns speeific to one waste stream (ID-HFEF-S5400-RH, Lot 

1 A), which CCP staff satisfactorily resolved. EPA detenmined that the procedure and processes 

used by INL-CCP staff for the two waste streams (ID-ANLE-S5000 and ID-HFEF-S5400, Lot 

1 A) wastes were adequate. As a result of our evaluation, we revised the tiering table found in the 

body of the enclosed report. Revisions to the table are in bold and were made to reflect the tiering 

changes that might be needed to address smaller waste streams at INL requiring EPA approval. 

Waste not approved in this action includes 1) the third INL remote-handled waste stream, 

ID-INTEC RH, consisting of two containers, and 2) more than 50 casks of ID-HFEF-S5400-RI1, 

Lot 1 B. Listed below are the reasons why we are not approving these waste items at this time: 

• In the case of the ID-INTEC-RH waste, CCP used waste sampling and radiochemical 

analysis procedures that were not approved by EPA. As a result, on December 9, 2009, 

EPA informed CBFO and INL-CCP that the waste could be approved only after EPA 

evaluates implementation of these procedures for generating radiological data. EPA 

expects to finish this evaluation over the next several weeks and can issue our decision 

in early Spring. 

• During the review of the acceptable knowledge (AK) documentation related to INHFEF-S5400-RH, EPA noticed that adequate AK has been generated for only 28 casks 

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

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100 % Postconsumer, Process Chlorine Free Recycled Paper 
fthan D. Edwards, Director 

iation Protection Division 

(in Lot lA) out of morc than 80 casks making up this waste stream. As a result, CCP 

must seek EPA approval of the remaining Lot 1B casks as a Tier I change. 

If you have any questions regarding this approval, please contact Rajani Joglckar at (202) 

343-9462 or Ed Feltcorn at (202) 343-9422. 

Sincerely 

Enclosure 

cc: Electronic Distribution 

Christine Gelles, DOE EM 

Alton Harris, DOE EM 

Vernon Daub, CBFO 

Casey Gadbury, CBFO 

Ava Holland, CBFO 

J R Stroble, CBFO 

Courtland Fesmire, CBFO 

Martin Navarrete, CBFO 

Dennis Miehls, CBFO 

Jerry Wells, DOE ID 

D K Ploetz, WTS-CCP 

Mike Sensibaugh, WTS-CCP 

Allison Pangle, CTAC 

Wayne Ledford, CTAC 

Steve Zappe, NMED 

EPA Region X