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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

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OFFICE OF 

APR 2 1 2010 AIR AND RADIATION 

Donald C. Gadbury 

Manager, National TRU Program 

Carlsbad Field Office 

C1.S. Department of Energy 

P.O. Box 3090 

Carlsbad, NM 88221- ~ 090 

Dear Mr. Gadbury: 

On August 28, 2009, Carlsbad Field Office (CBFO) requested that the U. S. 

Environmental Protection Agency (EPA) approve a proposed Tier 1(T1) change to add PreSETF (Pre-Solvent Extraction Test Facility) wastes (generated April 1972 — November 1978), to 

the EPA-approved remote handled (RH) waste stream OR-REDC-RH-HET generated at the Oak 

Ridge National Laboratory (ORNL). The Central Characterization Project (CCP) is responsible 

for characterizing this waste for disposal at the Waste Isolation Pilot Plant (WIPP). This letter 

approves the proposed T1 change based on the results of our T1 evaluation discussed in the 

enclosed report placed in the Agency's public docket (EPA Docket No. A-98-49; II-A4-124). 

ORNL may dispose of the Pre-SETF waste at the WIPP. 

The Central Characterization Project (CCP) characterized the Pre-SETF debris waste 

using the system of controls that the EPA approved in February 2009 (see EPA Docket No. A98-49,1I-A4-111). Earlier this year, EPA conducted the evaluation of the proposed Tl change 

and identified no Findings or Concerns requiring resolution. However, EPA determined that the 

sarnpling plan implemented to obtain waste samples for radiological analysis was not adequate. 

That is, the plan did not describe the process for sample selection and collection activities that 

actually occurred. EPA did not raise this as an issue because the data collected were analyzed in 

conjunction with the data obtained for contact-handled (CH) Pre-SETF waste. The two data sets 

in combination were technically adequate for the development of scaling factors. 

Whenever laboratory analysis is necessary, the site should implement a well-documented 

sampling plan. For EPA, the lack of an adequate RH waste sampling plan has been an ongoing 

concern since the EPA began approval of the RH Waste Characterization Programs. The current 

Waste Characterization Program Implementation Plan (WCPIP) does not explicitly require the 

need for a well-documented sampling plan when sarnpling the RH waste for radiological 

characterization. EPA expects that the RH WCPIP, which is currently being revised, will 

incorporate this as a requirement. 

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

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100 % Postconsumer, Process Chlorine Free Recycled Paper 
If you have any questions regarding this approval, please contact Rajani Joglekar at (202) 

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

Sincerely, 

C,> j Tom Peake, Director 

Center for Waste Management and Regulations 

Enclosure 

cc: Electronic Distribution 

Christine Gelles, DOE EM 

Alton Harris, DOE EM 

David Moody, CBFO 

Vernon Daub, CBFO 

J R Stroble, CBFO 

Ava Holland, CBFO 

Courtland Fesmire, CBFO 

Martin Navarrete, CBFO 

Dennis Miehls, CBFO 

Bill McMillan, ORNL 

Mike Sensibaugh, WTS-CCP 

Allison Pangle, CTAC 

Wayne Ledford, CTAC 

Steve Zappe, NMED 

Lloyd Generette, EPA Region 4