J~,SEO STq TFS 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Z a WASHINGTON, D.C. 20460 

02 

PAOS"S\ 

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 rg 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, 

e---

I 

Tom Peake, Director 

Center for Waste Management and Regulations 

Enclosure 
cc: 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