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### MAR 2 82

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### -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 Paperthat 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,

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# p zx/--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 Site Documents