J~,'(ED sl%,S 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

o ~ Q WASHINGTON, D.C. 20460 

0 

+lq4 PROS-G~ 2 

D EC 2 1 ZC,;;; OFFICE OF 

AIR AND RADIATION 

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. EPA 

received 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 bof 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) 
--_ . ___ _— ---- __ _ F-Han-ford,

_ _ _- 

Process Elements shges e ~ rt _., 

-- — 

Re~'ie» a 

` ~ - 

- 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.