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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

APP 18 2012 

OFFICE OF 

AIR AND RADIATION 

Mr. Jose R. Franco 

Manager, Carlsbad Field Office 

U.S. Department of Energy 

P.O. Box 3090 

Carlsbad, NM 88221-3090 

Dear Mr. Franco: 

With this letter the U.S. Environmental Protection Agency approves remote-handled (RH) transuranic 

(TRU) waste characterization activities implemented by the Savannah River Site (SRS) Central 

Characterization Project (CCP) to characterize RH TRU waste. This baseline approval of SRS-CCP's 

RH TRU waste characterization program allows SRS-CCP to characterize RH waste from Waste Stream 

SR-RH-FBL.OI in accordance with the conditions and restrictions discussed and summarized in Table 1 

of the enclosed report (A-98-49; II-A4-161) docketed in the EPA Air pocket. SRS-CCP may dispose of 

additional RH debris waste stream(s) at the WIPP that have companion CH waste stream(s) with the 

following attributes. The companion CH waste stream(s) must (a) belong to the same summary category 

group with same waste stream definition, and same radiological and physical properties as the subject 

RH waste stream and (b) be characterized using the approved radiological scaling factor development 

process. 

The EPA conducted a baseline inspection of CCP's demonstration to characterize SRS's RH "I'RlJ debris 

waste (Inspection Number EPA-SRS-CCP-RH-08.11-8) in two stages between August and December 

2011. EPA assessed the technical adequacy of the characterization perfonmed through acceptable 

knowledge (AK), Real-Time Radiography (RTR), and Radiological Characterization (RC). 

In accordance with 40 CFR 194.8, EPA issued a Federal Register notice on February 24, 2012, 

announcing EPA's proposed approval of CCP's RH TRU waste characteriz.ation program at SRS (77 FR 

11112-11115). The notice also opened a 45-day public comment period on our proposed approval and 

announced the availability of the inspection report cited above. The comment period ended April 9, 

2012. EPA received no public comment on the proposed approval and the associated documents 

docketed in the accompanying EPA Air pocket. 

Approval Summary 

EPA approves the SRS-CCP waste characterization program implemented to characterize RH debris 

waste from Waste Stream SR-RH-FBL.01. This program was evaluated during the baseline inspection 

process and the results of the evaluation are documented in the enclosed report. This final approval 

includes the following: 

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

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100 % Postconsumer, Process Chlorine Free Recycled Paper 
(1) The AK process for RH TRU debris waste streams that have companion CH debris waste streams 

(2) The radiological characterization of eight drums in Waste Stream SR-RI4-FBL.01 using DTC 

and scaling factors generated through use of the ORTEC/ISOCS prior to the baseline inspection 

and historical assays of companion CH debris waste streams for assigning radionuclide values, 

according to the limitations discussed in Section 8.2 of the enclosed report 

(3) The radiological characterization process using DTC and scaling factors generated through use of 

the Mobile Characterization Services (MCS)/ISOCS and historical assays of companion CH 

debris waste streams for assigning radionuclide values for RH waste, as documented in 

CCP-AK-SRS-581, Revision 1, supported by the calculation packages (or equivalent 

documentation) and subject to the limitations discussed in Section 8.2 of the enclosed report 

(4) The RTR process to identify WMPs and the physical form of RH TRU debris waste 

Use of the MCS/ISOCS is limited to the generation of scaling factors for specific radionuclides, i.e., the 

activity ratios of plutonium (Pu) isotopes plutonium-239 (

239Pu), plutonium-240 (240Pu) and plutonium241 (241Pu) to americium-241 (241Am). Further, use of the MCS/ISOCS for determining the scaling 

factor for plutonium-238 (238Pu) or for direct quantification of any radionuclide is prohibited. 

If you have questions, please contact Rajani Joglekar (202 343-9462) or Ed Feltcorn (202 343-9422). 

Si 

J

on than D. Edwards, Director 

' iation Protection Division 

Enclosure 

cc: Electronic Distribution 

Christine Gelles, DOE HQ 

Alton Harris, DOE HQ 

Ed Ziemianski, CBFO 

J.R. Stroble, CBFO NTP 

Marcus Pinzel, CBFO NTP 

Randy Unger, CBFO QA 

D K Ploetz, WTS CCP 

Mike Sensibaugh, WTS CCP 

Irene Quintana, WTS CCP 

Tim Hall, NMED 

Site Documents, CBFO 

Ray Lee, EPA