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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

o ~ Q WASHINGTON, D.C. 20460 

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MAR 2 82~ -0 12 OFFICE OF 

AIR AND RADIATION 

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: 

On December 15, 2011, the Carlsbad Field Office (CBFO) requested that the U.S. Environmental 

Protection Agency (EPA) approve a T1 change to add containers generated from Waste Groups 

PKE00027/54 and PKE00047 to Waste Stream SNL-HCF-S5400-RH, which EPA approved in 

November 2011. EPA has reviewed the information provided by the Central Characterization Project 

(CCP) responsible for characterizing remote-handled (RH) transuranic (TRU) waste at the Sandia 

National Laboratory (SNL) and approves the addition of these containers to the above mentioned waste 

stream. The enclosed report, EPA Docket No. A-98-49; II-A4-160, supports EPA's approval decision. 

SNL-CCP collected and analyzed samples from both new waste groups to develop scaling factors for 

characterization by DTC, as described in CCP-AK-SNL-501, Revision 2, Appendices A and B. for 

PKE00027/54 and PKE00047, respectively. CCP-AK-SNL-500, Revision 4, and related source 

documents provided additional infonnation and justification that supports (a) why the waste containers 

in these two waste groups are similar to those waste containers in the waste group PKE00044 which 

EPA approved in November 2011, (b) why new scaling factors were developed, and (c) why the waste 

containers in these two waste groups do not warrant designation as separate waste streams as required by 

the WCPIP, Revision 2. 

In the case of PKE00027 waste grouping, SNL-CCP collected five waste samples for radioassay. The 

analytical results for four out of five waste samples, however, were not RH or TRU. "T'he documentation 

we reviewed, namely, the post-sampling memorandum, did not adequately describe the use of these data 

for developing scaling factors and the disposition of waste containers belonging to this waste group. 

EPA discussed this issue with CBFO and SNL-CCP and stated that SNL-CCP should revise the postsampling memorandum discussing explicitly how waste sample data were used. At CBFO's suggestion, 

SNL-CCP added a footnote "data are valid" to one of the tables where the data were presented. EPA 

informed CBFO that this change was inadequate objective evidence and asked CBFO to provide a better 

rationale. CBFO's letter explained which waste sample data were used. This CBFO response is 

satisfactory. 

To better support EPA's approval, EPA recommends that changes be made to the WCPIP the next time 

it is revised. These changes would specify the importance of agreement between the objective evidence 

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

Recycled/Recyclabte 0 Printed with Vegetable Oil Based Inks on 100%, Postconsumer, Process Chlorine Free Recycled Paper 
that documents a waste characterization process and the process itself, and would prevent recurrence of 

the situation EPA encountered with the documentation for PKE00027/54. 

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

Ed Feltcorn at (202) 343-9422. 

Sincerely, 

d~~" pzx/--P~ 

Tom Peake, Director 

Center for Waste Management and Regulations 

Enclosure 

cc: Electronic Distribution 

Christine Gelles, DOE EM 

Alton Harris, DOE EM 

Joe Franco, CBFO 

Ed Ziemianski, CBFO 

Marcus Pinzel, CBFO NTP 

Tom Morgan, CBFO 

Courtland Fesmire, CBFO QA 

D K Ploetz, WTS-CCP 

Mike Sensibaugh, WTS-CCP 

Irene Quintana, WTS-CCP 

John Kieling, NMED 

Trais Kilphuis, NMED 

Tim Hall, NMED 

Raymond Lee, EPA HQ 

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