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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460 Z a

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J UN 1 0 2010 OFFICE OF AIR AND RADIATION

Donald C. Gadbury Manager, National TRU Program Carlsbad Field Office U.S. Department of Energy P.O. Box 3090 Carlsbad, NM 88221-3090

Dear Mr. Gadbury:

The U.S. Department of Energy's Carlsbad Field Office (CBFO) submitted to the U.S. Environmental Protection Agency (EPA) a Tier 1(T1) change request on March 2, 2010. The Tl change request was for the Advanced Mixed Waste Treatment Project (AMWTP) at the Idaho National Laboratory to accept Hanford-characterized debris waste from the Plutonium Finishing Plant (PFP) area. This waste consists of approximately 1,034 55-gallon drums overpacked in 85- gallon containers. Based on EPA's evaluation of the T1 change documentation (discussed in the enclosed report with EPA Air pocket No. A-98-49, II-A4-127), EPA approves the proposed Tl change, and the Central Characterization Project (CCP) at Hanford can ship these Hanford overpacks to AMWTP to characterize the waste in overpacks as BN510 waste.

Back r g ound:

Between 2001 and August 2009, the Hanford Site, using EPA-approved contact-handled (CH) transuranic (TRU) waste characterization processes, characterized and certified thousands of 55-gallon drums and several hundred standard waste boxes from MPFPD, M231ZD, and M325D waste streams. The Hanford TRU program shipped several thousand of the drums from these three debris waste streams while the program was active. However, several hundred of these 55-gallon drums were damaged and required to be placed in overpack containers before being shipped to the Waste Isolation Pilot Plant (WIPP). Some of these overpacks remain at Hanford requiring disposal at WIPP.

Prior to termination of the Hanford TRU program in August 2009, Hanford characterized an additional several thousand drums of debris waste in the RLMPFPCD waste stream but could not certify them for WIPP disposal. In May 2009, the CBFO approved the Hanford-prepared acceptable knowledge summary report for this waste stream. A few hundred of the 55-gallon drums from this waste stream also required overpacking before shipment to WIPP for disposal. To date, none of the RLMPFPCD drums have been disposed of at the WIPP.

Intemet Address (URL) • http://www.epa.gov Recycled/Recyclable . Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)Future activities at AMWTP resulting from the EPA T1 approval:

The AMWTP plans to process the following CH TRU legacy debris waste from the PFP at Hanford in overpacks as BN510 (super-compacted debris) waste from Hanford for further processing.

• 131 drums of mixed PFP debris (MPFPD);

0 66 drums of mixed 231Z building debris (M231ZD); • 220 drums of mixed 325 building debris (M325D); and • 617 drums of mixed PFP debris from 234-5Z building only (RLMPFPCD).

The AMWTP will re-package these overpacks into 55-gallon crushable drums and characterize them using the EPA-approved CH TRU waste characterization processes. The newly-characterized drums will be crushed into "pucks" and loaded in 100-gallon containers for disposal at the Waste Isolation Pilot Plant. The AMWTP must provide to EPA the items listed below to verify that the Hanford debris waste has been adequately characterized:

• Revised Acceptable Knowledge (AK) documentation for BN510 showing how Hanford AK and other documentation have been incorporated; • The revised waste stream profile form for AMWTP's BN510 waste stream to include Hanford waste; • Batch data reports from visual examination for physical contents and nondestructive assay for radiological contents of BN510 debris; and • Tracking of Hanford debris waste in AMWTP's waste tracking system.

The EPA will review the above documentation while CBFO certifies the new BN510 waste stream for WIPP disposal.

If you have any questions regarding this approval, please contact Rajani Joglekar (202- 343-9462) or Ed Feltcorn (202) 343-9422.

Sincerely,



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Tom Peake, Director Center for Waste Management and Regulations Enclosurecc: Electronic Distribution

Christine Gelles, DOE HQ Alton Harris, DOE HQ Dave Moody, CBFO Vernon Daub, CBFO Nonma Castaneda, CBFO Courtland Fesmire, CBFO J R Stroble, CBFO Ava Holland, CBFO Dennis Miehls, CBFO Martin Navarrete, CBFO Jerry Wells, DOE ID Larry Romine, DOE RL Joni Norton, DOE RL James Werntz, EPA Region 10 Steve Zappe, NMED Don Hancock, SRIC Kiki Torrez, AMWTP Eric Schweinsberg, AMWTP Dave Haar, WTS-CCP Mike Sensibaugh, WTS-CCP Mark Pearcy, WTS-CCP Mike Walentine, WTS-CCP Allison Pangle, CTAC Wayne Ledford, CTAC