UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

Mr. J. R. Stroble 

Manager. National TRU Program 

Carlsbad Field Office 

U.S. Department of Energy 

P.O. Box 3090 

Carlsbad, NM 88221-3090 

Dear Mr. Stroble: 

FEB 1 1 2014 

OFFICE OF 

AIR AND RADIATION 

On August 15. 2013, the Carlsbad Field Office (CBFO) requested that the U.S. Environmental 

Protection Agency (EPA) approve, as a Tier I (Tl) change, the addition ofContact-Handled (CH) 

transuranic (TRU) debris waste (S5000) from the Idaho National Laboratory (fNL) to the 

supercompacted CH debris Waste Stream of the Advanced Mixed Waste Treatment Project (AMWTP) 

at the Idaho National Laboratory. The approval request also included characterization of homogenous 

solids (S3000) at AMWTP. The Idaho Treatment Group (TTG) at AMWTP is responsible for 

characterization of CH TRU waste using the EPA-approved CH TRU waste characterization processes. 

The enclosed report (EPA Air Docket No. A-98-49; H-A4-180) discusses EPA's evaluation ofT! 

change information addressing acceptable knowledge (AK) component of AMWTP's CH waste 

characterization program and our approval. As a result, upon characterization. AMWTP may dispose of 

the subject INL wastes at the Waste Isolation Pilot Plant (WIPP). 

In October 2006, EPA initially approved the CH TRU waste characterization processes at AMWTP (see 

EPA Docket No. A-98-49; U-A4-66). Since then EPA approved AMWTP to characteri ze the following 

sources of CH TRU wastes for WI PP disposal: Hanford (June 2010, A-98-49; ll-A4-127). ANLE and 

MFC (January 2013, A-98-49; H-A4-169), INL-exhumed SDA debris as supercompacted BN-51 0 waste 

stream and solids (July 20 13. A-98-49; II-A4-174). and LANL (September 2013. A-98-49; Il-A4-178). 

Since late 2011, lTG has been responsible for continued implementation ofthe EPA-approved CH TRU 

waste characterization program at AMWTP for CH TRU waste for WIPP disposal. In April2013, during 

a continued compliance inspection, EPA verified that JTG complies with EPA issued a report which 

verified ITO's continued compliance with EPA regulations at 40 CFR 194.24 (see EPA Docket No. 

A-98-49; II-A4- l 73). 

In 2012, the Department of Energy decided to utilize AMWTP's CH TRU waste characterization 

program to process legacy waste from different TRU Sites to meet their court-ordered deadlines for 

cleanup of legacy waste. This change required Tl change requests. For these T I change-based wastes 

approvals, EPA's focus has been to evaluate acceptable knowledge (AK) documentation that AMWTPITG developed by incorporating AK and supporting historical information provided by the host site (for 

example, Hanford). EPA approvals allowed AMWTP-ITG to characterize the radiological and physical 

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

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer. Process Chlorine Free Recycled Paper 
contents of the above wastes in accordance with the EPA-approved waste characterization program. EPA 

may review pertinent documents (for example, batch data reports) to verify documentation and 

conformance during the next continued compliance inspection. 

With past AMWTP Tl changes for adding wastes from other generator sites, EPA received drafts of key 

AK documents (such as RPT-TRUW-05 thru 07 and 12). As a practice, EPA does not and cannot 

proceed with evaluation of draft documents when making approval decisions. Waste characterization 

personnel prepared drafts are subject to CCP and CBFO's review process and as a result, may change 

before being deemed as official public records. Therefore, we expect that CBFO's Tl change requests 

will have accompanying final documents that are technically accurate, properly vetted and can be 

released as documents of record. 

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

Ed Feltcorn at (202) 343-9422. 

Enclosure 

cc: Electronic Distribution 

Doug Tonkay, DOE EM 

Alton Harris, DOE EM 

Joe Franco, CBFO 

Marcus Pinzel, CBFO NTP 

Tom Morgan, CBFO NTP 

Mark Pearcy, WTS-CCP 

Ben Roberts, DOE ID 

Jerry Wel ls, DOE ID 

Dave Haar, AMWTP-ITG 

George Byram, AMWTP-ITG 

Trais Kliphuis, NMED 

Raymond Lee, EPA HQ 

Site Documents 

Sincerely, 

~eCenter for Waste 

C~ Management and Regulations