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""'~i PAO~c. 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 datedOctober 27, 2005,the Department of Energy(DOE) requested the EnvironmentalProtection Agency's (EPA) approvalof acceptable knowledge(AK) for newlygenerated

wastecharacterized

by the Central Characterization Project (CCP) at the Idaho National Laboratory(INL). EP A received

AK documentation

for the Pit 4 wasteafter the baseline inspection

that EPA conducted

in May 2005. With this letter, EPA is approving CCP's wastecharacterization

program for characterizing

debris (85000), solids (83000), and soil & gravel (84000) from the ARP-I portion of Pit 4 andthe 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) wastein 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

approvalestablished

a tiered system

for evaluating

changes to the approved

INL CCP wastecharacterization program(EPA Air Docket No: A-98-49; II-A4-59). EPA's baseline approvalallowed the disposal at the WasteIsolation 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 wastefrom 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 requiresEP

A approvalprior to disposal of the waste

at WIPP.

Intemet Addl9ss (URL) 

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Tl Chan2e

Evaluation According to the requirements of 40 CFR 194.8(b), DOE appropriately requested approvalof 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 inspectionreport gives the details ofEPA's review. EPA did not identify any findings or concerns from this review. (For the wastein 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 wastein the Pit 4 and Pit 6 areas is technically adequate.

As a result, EPA's approvalof the INL CCP TRU waste characterization programis expanded

to include newly-generated wastefrom certainareas of Pit 4 and Pit 6.
Below is the updated

list of approved

wastecharacterization

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 debrisand solid wastesupplied by AMWTP; and b. newly-generated

CH- TRU debris,solid, and soil/gravelwaste from the ARP-I portion of Pit 4 andthe ARP-II portion of Pit 6, as shownin Figure I on page 4 of the enclosed

report (2) The NDA systems

(TGS, SGRS,

WAGS, and HENC) for assaying:
a. retrievably-stored

debrisand solid wastesupplied by AMWTP; and b. newly-generated

CH- TRU debris.solid, and soiVgravel wastefrom the ARP-I portion of Pit 4 andthe 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) checkof the RTR process for retrievably-stored

solid and debriswastesupplied

by AMWTP (4) The VET process

for newly-generated

debris,solid, and soil/gravelwastefrom the ARPportion of Pit 4 andthe 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 debriswastefrom AMWTP3

(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 andthe 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 November2005 (seeINL CCP InspectionReportA-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 andthe ARP-II portion of Pit 6, when available. If you haveany questions regarding

this approval,please

contact Rajani Joglekar

at (202) 343-9462. 

# ~cBonnie C. Gitlin. Acting Director Radiation ProtectionDivision
Enclosure Vernon Daub, CBFO Ava Holland, CBFO Courtland Fesmire,

CBFO EP A Air Docket 

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