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~ G 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 ( 239 Pu), plutonium-240 ( 240 Pu) and plutonium241 ( 241 Pu) to americium-241 ( 241 Am). Further, use of the MCS/ISOCS for determining the scaling factor for plutonium-238 ( 238 Pu) 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).
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# 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