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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

AUG 32006

OFFICE OF

A~ AND RADIATION

Dr. David Moody, Manager

Carlsbad Field Office

U.S. Department of Energy

P.O. Box 3090

Carlsbad, NM 88221-3090

Dear Dr. Moody:

In a letter dated October 27, 2005, the Department of Energy (DOE) requested the

Environmental Protection Agency's (EPA) approval of acceptable knowledge (AK) for newlygenerated waste characterized by the Central Characterization Project (CCP) at the Idaho

National Laboratory (INL). EP A received AK documentation for the Pit 4 waste after the

baseline inspection that EPA conducted in May 2005. With this letter, EPA is approving CCP's

waste characterization program for characterizing debris (85000), solids (83000), and soil &

gravel (84000) from the ARP-I portion of Pit 4 and the ARP-II portion of Pit 6, as shown in

Figure 1 on page 4 of the enclosed report.

Background

From May 3-5, 2005, EPA conducted a baseline inspection ofINL CCP Onspection

Number EPA-INL-CCP-05.05-08) to assess the characterization oftransuranic (TRU) waste in

accordance with EP A regulations (40 CFR 194.8(b )(3), 40 CFR 194.8( c) and 40 CFR 194.24).

EP A's baseline approval established a tiered system for evaluating changes to the approved INL

CCP waste characterization program (EPA Air Docket No: A-98-49; II-A4-59). EPA's baseline

approval allowed the disposal at the Waste Isolation Pilot Plant (WIPP) of two categories of the

contact-handled (CH), retrlevably-stored TRU waste (83000 and 85000) from the Advanced

Mixed Waste Treatment Plant (AMWTP) characterized by INL CCP. EPA also approved

radioassay and visual examination processes implemented for newly-generated TRU waste from

INL characterized by CCP. EP A did not review AK documentation for newly-generated debris

(85000), solids (83000), and soil and gravel (84000) from the Pit 4 and Pit 6 areas at the time of

the inspection. In the baseline approval, EP A identified AK for new wastes as a Tier 1 change,

which requires EP A approval prior to disposal of the waste at WIPP.

Intemet Addl9ss (URL) . http:/iwww.epa.gov

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Tl Chan2e Evaluation

According to the requirements of 40 CFR 194.8 (b), DOE appropriately requested

approval of AK documentation for newly-generated waste from Pit 4 and Pit 6, as a Tier I

change to the INL CCP baseline approval.

EP A reviewed the AK documentation for newly-generated waste from ARP I and II areas

that encompass part of Pit 4 and Pit 6, respectively. The enclosed inspection report gives the

details ofEPA's review. EPA did not identify any findings or concerns from this review. (For

the waste in the area covered in this review, see Figure 1 in the attached report: EPA Air Docket

No: A-98-49; II-A4-67.)

Annroval Summarv

EP A determines that the AK documentation for waste in the Pit 4 and Pit 6 areas is

technically adequate. As a result, EPA's approval of the INL CCP TRU waste characterization

program is expanded to include newly-generated waste from certain areas of Pit 4 and Pit 6.

Below is the updated list of approved waste characterization processes implemented by the

INL-CCP for characterizing TRU waste at INL.

( I) The AK and Load Management process for:

a. retrievably-stored CH- TRU debris and solid waste supplied by AMWTP; and

b. newly-generated CH- TRU debris, solid, and soil/gravel waste from the ARP-I

portion of Pit 4 and the ARP-II portion of Pit 6, as shown in Figure I on page 4 of

the enclosed report

(2) The NDA systems (TGS, SGRS, WAGS, and HENC) for assaying:

a. retrievably-stored debris and solid waste supplied by AMWTP; and

b. newly-generated CH- TRU debris. solid, and soiVgravel waste from the ARP-I

portion of Pit 4 and the ARP-II portion of Pit 6, as shown in Figure I on page 4 of

the enclosed report

(3) VE as a quality control (QC) check of the RTR process for retrievably-stored solid and

debris waste supplied by AMWTP

(4) The VET process for newly-generated debris, solid, and soil/gravel waste from the ARPportion of Pit 4 and the ARP-II portion of Pit 6, as shown in Figure I on page 4 of the

enclosed report

(5) The NDE (RTR) process for retrievably-stored solid and debris waste from AMWTP
3

(6) The WWIS process for tracking of waste contents of newly-generated debris, solid, and

soil/gravel waste from the ARP-I portion of Pit 4 and the ARP-II portion of Pit 6, as

shown in Figure 1 on page 4 of the enclosed report

The tiering for changes to the INL CCP TRU waste characterization program originally

assigned in November 2005 (see INL CCP Inspection Report A-98-49; II-A4-59) remains

applicable with the following change. Upon evaluation of AK for Pit 4 and Pit 6 wastes, EP A

adds a new T2 c~ge item that requires CCP to submit a revised AK Summary Report for the

waste from the ARP-I portion of Pit 4 and the ARP-II portion of Pit 6, when available.

If you have any questions regarding this approval, please contact Rajani Joglekar at

(202) 343-9462.

~cBonnie C. Gitlin. Acting Director

Radiation Protection Division

Enclosure

Vernon Daub, CBFO

Ava Holland, CBFO

Courtland Fesmire, CBFO

EP A Air Docket

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