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