oFFiCE oF 

AIR AND RADIATION 

David C. Moody, Ph.D. 

Manager, Carisbad Field Office 

ti.S. Department ofEnergy 

P.O. Box 3090 

Carlsbad, NM 8 822 1-3 090 

Dear Dr. Moody: 

On July 17-19, 2007, the U.S. Environmental Protection Agency (EPA) conducted a 

baseline inspection of the remote-handled (RH) transuranic (TRI) waste characterization 

program implemented by the Savannah River Site (SRS) Central Characterization Project (CCP) 

for RH debris waste packaged in 87 drunlliners from Batteile Columbus Laboratory 

Decommissioning Project (BCLDP), and whieh are in interim storage at SRS (Inspection 

Number EPA-SRS-CCP-RH-07.07-8). EPA conducted follow-up inspections on July 31—August 

2, 2007 and December 4-5, 2007. During these inspeetions. EPA assessed the technical 

adequacy of the characterization performed through acceptable knowledge (AK) and radiological 

characterization (RC). 

In accordance with 40 CFR 194.8, EPA issued a Federal Regdster notice on May 21, 

2008, announcing EPA's proposed approval of the RII TRU waste characterization program at 

SRS-CCP (73 FR 29504-29507). This I'ederal Register notice also opened a 45-day public 

eomment period on our proposed approval and announced the availability of the inspection report 

(Air pocket No: A-98-49; II-A4-99). EPA received one publie eomment on the proposed SRSCCP inspection report. In the enelosed inspection report (Air pocket No: A-98-49; II-A4-104), 

Section 9 contains the public comment and EPA's response. 

Approval Summary 

The EPA deternlined that the records documenting SRS-CCP's RH WC program for the 

RH debris waste from BCLDP represented activities that were technically adequate. EPA, 

therefore, is approving the SRS-CCP RII WC program limited to the 87 RH T'RU waste druni 

liners for BCLDP RH debris Waste Stream SR-RL-BCI.DP.001 evaluated during the baseline 

inspection described and documented in the enclosed report. EPA is approving the following 

WC activities: 

.'nternetAdaress(UP,k)s http://www.epa.gov 

Recycled/5iecyefa6ie a Printed with Uegetabie Gii 3ased inks on 700 % Postcnnsu.mer, Process Chiorino Free Recycled Paper 
(1) The AK process for the 87 drum liners of RH retrievably stored TRU debris in the waste 

stream designated as Waste Stream SRS-RL-BCLDP.001 currently stored at the TRU 

storage pads in the E Area of SRS. 

(2) The radiological characterization process using dose-to-curie (DTC) and modelingderived scaling factors, supported by radionuclide data from the analysis of 69 swipe 

samples, for assigning radionuclide values to 87 drum liners of RII retrievably stored 

TRU debris in one waste stream, designated as SRS-RL-BCLDP.001, that is documented 

in CCP-AK-LANL-501. Revision 2, and detailed in this report. 

(3) "I'he visual examination (VE) process to identify waste material parameters and the 

physical form of the waste. 

(4) The WIPP Waste Information System (WWIS) to submit both characterization and 

certification data for RH TRU waste. 

(5) The attainment of pertinent data quality objectives (DQOs). 

Since no additional WC activities are expected to occur relative to the 87 drum liners of RH 

debris waste, changes to the WC activities evaluated during the baseline inspection are hot 

anticipated. As stated in Section 9.0 of the enclosed report, any non-BCL RH waste generated at 

SRS or brought to SRS for eharacterization will require a new baseline inspection. 

In the event that SRS-CCP makes changes to the EPA-approved W C components discussed 

in the enclosed report and implements them to characterize additional waste from the BCLDP 

activity (e.g., solids or soiUgravel) associated with D&D activities at Building JN-1 at the BCL, 

EPA will consider changes that have the potential to affect WC activities to be Tl changes. In 

addition, SRS-CCP must provide to EPA a copy of the W WIS-controlled spreadsheet showing 

the manual data entries that were downloaded from CCP-AK-SRS-501 upon completion as a 

one-time T2 change. 

This letter and the frnal inspection report have been placed in the EPA docket (Air 

Docket No. A-98-49, II-A4-104) and posted on the EPA website at u~ovjradiation/mpp. 

If you have any questions, please contact Rajani Joglekar at (202) 343-9462 or Ed 

Feltcorn at (202) 343-9422. 
Enclosures 

cc: Electronic Distribution 

Frank Marcinowski, DOE HQ 

Alton Harris, DOE HQ 

Vernon Daub, CBFO 

Casey Gadbury, CBFO 

Ava Holland, CBFO 

Courtland Fesmirew CBFO 

J.R. Stroble, CBFO 

Martin Navarrete, CBFO 

Dennis Miehls, CBFO 

Steve Zappe, NMED 

Allison Pangle, C1'AC 

Wayne Ledford, CTAC