J~~SED STqr~s UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

s W WASHINGTON, D.C. 20460 

PROj~G~\ 

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MM 4 2009 

OFFICE OF 

AIR AND RADIATION 

Mr. Frank Marcinowski 

Deputy Assistant Secretary for Regulatory Compliance 

US Deparhnent of Energy Office of Environmental Management (EM-10) 

Forrestal Building 

1000 Independence Ave., S.W. 

Washington, DC 20585 

David Moody, Ph.D. 

Manager, Carlsbad Field Office 

U.S. Department of Energy 

P.O. Box 3090 

Carlsbad, NM 88221-3090 

Dear Mr. Marcinowski and Dr. Moody: 

This letter approves the use of visual examination. (VE) using audio/video (A/V) 

recordings from packaging of contact-handled (CH) transuranic (TRU) debris waste prepared by 

a small generator site (SGS). The details of the approval are given below and in the enclosed 

report (A-98-49, II-A4-110) that discusses the U. S. Environmental Protection Agency (EPA)'s 

evaluation of the issue. We have also placed the report in EPA's public docket. 

On November 13, 2008, the U. S. Department of Energy (DOE)'s Carlsbad Field Office 

(CBFO) notified EPA of a proposed Tier 2(T2) change to the EPA-approved CH TRU waste 

characterization program implemented by the Central Characterization Project (CCP) at the 

Idaho National Laboratory (INL). The change entails INL-CCP personnel utilizing procedures 

CCP-TP-163, CCP Standard Visual Examination of Records and CCP-TP-113, CCP Standard 

Contact-Handled Visual Examination for performing VE using A/V recordings or waste 

packaging records from packaging of CH TRU retrievably stored waste. EPA disagreed with 

CBFO's T2 designation for this change. In our November 25, 2008, letter we notified DOE that 

the change would be evaluated as a Tier 1 change. The reasons for the T1 designation are also 

discussed in the enclosed inspection report. 

EPA conducted an on-site evaluation on December 9-11, 2008, to evaluate this change. 

As a result of this evaluation, EPA identified seven (7) concerns. DOE responded to the 

concerns on January 23, 2009. EPA conducted a follow up inspection on February 2, 2009, to 

further evaluate the status of the resolution of the concerns. A few unresolved concerns required 

discussions among EPA, DOE Headquarters and CBFO staf£ 

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

Recycled/Recyclable • Printed with Vegetabie Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer) 
As a result of our discussions and the information in the attached report, EPA approves 

the process of generating VE information utilizing A/V recordings (CCP-TP-163) produced 

during the waste packaging process for all NTS debris waste containers. Using the approved VE 

process, INL-CCP will generate VE batch data reports (BDRs) in accordance with the 

previously-approved procedure CCP-TP-113. This approval requires that INL-CCP use the A/V 

recordings to confirm that the NTS debris waste has been packaged in empty containers. Note 

that, at this time, EPA is not approving the use of waste packaging records by themselves for 

characterizing TRU waste containers packaged by SGSs. EPA will determine separately whether 

these records may be used for this purpose. Such use of waste packaging records will also be 

evaluated as a T 1 change. 

In addition;after EPA notification, INL-CCP and other EPA-approved CCP sites may use 

this approved process for characterizing CH TRU debris waste packaged at other SGSs. When 

characterizing SGS-generated CH TRU debris waste, CCP may only use EPA-approved waste 

characterization procedures. 

If you have any questions regarding this approval, please contact Ed Feltcorn at 

(202) 343-9422 or Rajani Joglekar at (202) 343-9462: 

gan D. Edwards, Director 

iation Protection Division 

Enclosure 

cc: Electronic Distribution 

Alton Harris, DOE HQ 

Jonathan Edwards, EPA HQ 

Vernon Daub, CBFO 

Casey Gadbury, CBFO 

Ava Holland, CBFO 

Courtland Fesmire, CBFO 

Norma Castaneda, CBFO 

Martin Navarrete, CBFO 

Dennis Miehls, CBFO 

Allison Pangle, CTAC 

Wayne Ledford, CTAC 

Steve Zappe, NMED