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### Ed Ziemianski Acting Manager, Carlsbad Field Office U.S. Department of Energy P.O. Box 3090 Carlsbad, NM 88221-3090

Dear Mr. Ziemianski:
This letter approves contact-handled (CH) transuranic (TRU) waste characterization activities implemented by the Hanford Central Characterization Project (CCP) to characterize CH TRU waste. This approval is based on the conditions and limitation discussed and presented in Table 1 of the attached report (EPA Docket No. A-98-49, II-A4-138).
Between Apri127-29, 2010, the U.S. Environmental Protection Agency (EPA) conducted a baseline inspection of CCP's demonstration to characterize Hanford's CH TRU debris waste (Inspection Number EPA-Hanford-CCP-CH-04.10-8). During this inspection, EPA assessed the technical adequacy of the characterization performed through acceptable knowledge (AK), visual examination (VE), real-time radiography (RTR), dose-to-curie (DTC), and the Waste Data System (WDS) for TRU waste tracking from characterization to disposal.
In accordance with 40 CFR 194.8, EPA issued 

### a Federal Register notice on September 8, 2010, announcing EPA's proposed approval of the CH TRU waste characterization program at Hanford-CCP (75 FR 54631-54634). This 

### Federal Register notice also opened a 45-day public comment period on our proposed approval and announced the availability of the inspection report (Air pocket No: A-98-49; II-A4-128). The comment period ended October 25, 2010. EPAreceived one set of public comments on the proposed approval and the accompanying HanfordCCP inspection report. EPA addressed the public comments and made relevant changes which are discussed in Section 9.0 of the enclosed report.
Apuroval Summary
EPA determined that the records documenting Hanford-CCP's CH WC program implemented to characterize retrievably-stored CH debris waste were technically adequate. In the future, Hanford-CCP can request EPA approval of other CH waste categories and additional waste characterization processes, equipment, and procedures identified as tiering changes in Table 1 and discussed throughout the enclosed inspection report. EPA is approving the following WC activities:

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

Recycled/Recyclabie o Printed with Vegetable Oil Based Inks on 1 00% Postconsumer, Process Chlorine Free Recycled Paper

### • Acceptable knowledge (AK) for CH retrievably-stored TRU debris waste (S5000)

• Two nondestructive assay (NDA) systems, the Canberra Gamma Energy Analysis System Units A and B(GEA-A and GEA-B) for characterizing debris (S5000) wastes • Real-time radiography (RTR) for CH retrievably-stored TRU debris waste (S5000) • Visual Examination (VE) for CH retrievably-stored TRU debris waste (S5000) • WIPP Waste Data System (WDS) for CH retrievably-stored TRU debris waste (S5000)
During the inspection, Hanford-CCP personnel stated that the Hanford-CCP was not seeking approval to perform load management, and EPA excluded evaluation of load management from the scope of this inspection [see report Section 8.1(13)]. Therefore, this approval does not include load management for Hanford-CCP.
Based on EPA's evaluation of public comment (discussed in Section 9.0 of the attached report), EPA concludes that the practice of estimating liquid volume using calculations is not consistently implemented at different CH TRU Sites serviced by CCP. If CBFO wants to allow CCP to use calculations for estimating liquid volume in containers at CH TRU Sites around the Complex, then following steps are necessary.
• Maintenance of auditable records when liquids in a container are calculated using mathematical formulae; • Revision and simplification of the "Measurement Conversion Chart" to make it better suited to match operator's skill level; • Improved on-the job training of RTR Operators to make it consistent among different operators to minimize subjectivity; and • Submission of the revised training material to EPA for evaluation and approval, test questions for operator qualification, and test results prior to implementation. Unless these steps are taken, the CCP is prohibited to use mathematical formulae for different liquid shapes to calculate liquid volume in containers.
Changes to the approved waste characterization program that are designated in the enclosed table as Tier 1 must be reported to EPA prior to implementation. DOE may implement Tier 2 changes prior to EPA approval; however, DOE must notify EPA of these changes at the end of each quarter of the fiscal year. The enclosed table (excerpted from the report) identifies the types of activities that are considered Tier 1 and Tier 2.
This letter and the final inspection report have been placed in the EPA docket (Air Docket No. A-98-49, II-A4-138) and posted on the EPA website at www.epa.gov/radiation/wipp.

### If you have any questions, please contact Rajani Joglekar at (202) 343-9462 or Ed

Feltcorn at (202) 343-9422.

an D. Edwards, Director ion Protection Division

Enclosures

cc: Electronic Distribution Frank Marcinowski, DOE HQ Christine Gelles, DOE HQ Alton Harris, DOE HQ Bill Lattin, DIE ID Jerry Wells, DOE ID Tally Jenkins, DOE ID J.R. Stroble, CBFO Courtland Fesmire, CBFO Norma Castaneda, CBFO Martin Navarrete, CBFO Dennis Miehls, CBFO Steve Zappe, NMED David Haar, WTS/CCP David Ploetz, WTS/CCP Allison Pangle, CTAC Charlie Riggs, CTAC Patrick Kelly, SC&A

### Table 1. Tiering of TRU Waste Characterization Processes Implemented by Hanford-CCP Based on April 27-29, 2010 Site Baseline Inspection as issued on December 15, 2010

Acceptable Knowledge (AK) Implementation of load management (AK 13) Notification to EPA upon completion of new versions or updates/ substantive changes b of the following: Implementation of AK for wastes other than

- Modification of CCP-TP-005, Revision 18 (AK 4) retrievably-stored debris (i.e., retrievably-stored

- Availability of modifications to the AKSR (AK 5) soiUgravel and/or solids) (AK 1)

- Availability of all final WSPF with related attachments (AK 9)

- Availability of all AK Accuracy Reports (AK 12)

- Availability of successful training records (AK 10)

- Availability of the AK-NDA memorandum (AK 14) Non Destructive Assay (NDA) New equipment or physical modifications to Notification to EPA upon completion of changes to software for approved approved equipment` (NDA 1) equipment, operating range(s), and site procedures that require CBFO approval (NDA 2) Extension or changes to approved calibration range for approved equipment (NDA 2) Real-Time Radiography (RTR) There are no T1 changes at this time Notification to EPA upon the following:

- Modification' to approved equipment, RTR units A and B(RTR 2)

- Completion of changes to site RTR procedures requiring CBFO approvals (RTR 2)

- Addition of new SCG to the RTR processes that are subject to this approval (RTR 2) Implementation of a different type of RTR equipment (RTR 2) Visual Examination (VE) Performance of VE by any method other than using Notification to EPA upon the following: two trained operators to perform actual VE at the

- Completion of changes to site VE procedure(s) requiring CBFO time of packaging (VE 1) approvals (VE 2)

- Addition of new SCG to the VE processes that are subject to this approval (VE 2) Waste Data System (WDS) There are no T1 changes at this time Notification to EPA upon the following:

- Completion of changes to WDS procedure(s) requiring CBFO approvals (WDS 2). ___ _— ----

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~ - - Changes to the Excel spreadsheet titled WDS Master Template.xls, Revision 2, Addendum #2, SCO #1065 (WDS 2) a Upon receiving EPA approval, Hanford-CCP will report all T2 changes to EPA at the eiid of each fiscal quarter. Note: EPA may request specific T2 items before the end of a fiscal quarter.

b "Substantive changes" are changes with the potential to impact the site's waste characterization activities or documentation thereof, excluding changes that are solely related to ES&H, nuclear safety, or RCRA, or that are editorial in nature. `Modifieations to approved equipment include all changes with the potential to affect NDA data relative to waste isolation and exclude minor changes, such as the addition of safety-related equipment.