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## AUG 2 6 2005

OFFICE OF AIR AND RADIATION



### David C. Moody, Ph.D. Manager, Carlsbad Field Office U.S. Department of Energy P.O. Box 3090 Carlsbad, NM 88221-3090 Dear Dr. Moody:With this letter, the U.S. Environmental Protection Agency (EPA) approves the remotehandled (RH) transuranic (TRU) waste characterization activities implemented by the General Electric Vallecitos Nuelear Center (GEVNC) Central Characterization Project (CCP) to characterize debris waste stream GEVNC.01 for disposal at the Waste Isolation Pilot Plant (WIPP). On December 2-4, 2008, EPA conducted a baseline inspection of the CCP processes usedto characterize GEVNC's RH TRU debris waste (Inspection Number EPA-GEVNC-CCP-RH12.08-8). During this inspection, EPA assessed the following items for technical adequacy:

• The use of acceptable knowledge (AK); • Visual examination (VE); • Dose-to-curie (DTC); and • The WIPP Waste Infonmation Systern (WWIS) used to track TRU waste from characterization to disposal. In accordance with 40 CFR 194.8, EPA issued a Federal Register notice on June 23, 2009 announcing the Agency's proposed approval of the RH TRU waste characterization program at GEVNC (74 FR 2994-29697). This Federal Register notice also opened a 45-day public comment period on our proposed approval and announced the availability of the inspection report (Docket No: A-98-49; II-A4-113). The official comment period closed on August 7, 2009. EPA received one set of public comments on the proposed approval and the accompanying ORNL-CCP inspection report. The enclosed inspection report (Docket No: A-98-49; II-A4-115) is EPA's final baseline approval for GEVNC-CCP RH.

Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper

### Apnroval Summary



### DOE used records to document GEVNC-CCP's RH waste characterization program involving one RH debris waste stream, GEVNC-01. GEVNC-01 waste was generated from the decommissioning and demolition (D&D) of Hot Ce114 in Building 102. EPA finds that DOE's records are technically adequate and demonstrate that the waste stream has been appropriately characterized. The approval discussed in the enclosed report is specific to RH TRU debris waste stream GEVNC.01. - This RH approval is neither limited to a specific number of RH waste canisters (e.g., Los Alamos National Laboratory RH waste) nor a specific number of RH waste drum liners (e.g., Savannah River Site RH waste). EPA is approving the following WC activities: • The AK process for the RH TRU debris waste stream designated as Waste Stream GEVNC.01 generated during the D&D of Hot Cell 4. • The radiological characterization process using DTC and scaling factors for assigning radionuclide values to Waste Stream GEVNC.01 that is documented in CCP-AK-GEV-501, Revision 1, as supported by the revised calculation packages and detailed in this report. • The VE process to identify wastc material parameters (WMPs) and the physical fonn of the waste. • The WWIS to submit data for both characterization and certification for RH TRU waste. • The attainment of pertinent data quality objectives (DQOs). Any additional RH waste stream generated at GEVNC will require a separate baseline approval before the waste can be disposed of at WIPP. Table 1(included in the report) identifies Tier 2 items which DOE may implement without EPA approval; however, DOE must provide EPA with notification summarizing these changes at the end of each fiscal year quarter. In addition, EPA includes the following two notification requirements (see the Executive Summary of the enclosed report for details) which are unique to GEVNC. • In lieu of a quarterly report, a one-time T2 information submission to EPA notifying the end of the characterization activity will be necessary. • Upon characterizing these GEVNC CH containers,lNL-CCP must provide EPA withdocumentation on how CH container-specific AK information was handled, nondestructive assay (NDA) data on the individual drums, and other supporting information. Also, as stated in the Executive Summary of the enclosed report, DOE must revise the Waste Characterization Program Implementation Plan (WCPIP) for RH TRU waste to address EPA

### issues concerning the adequacy of the WCPIP and relevance to the sites' RH waste

characterization efforts and seek the Agency's concurrence. EPA will evaluate new RH sites only if the site procedures implemented reflect the revised WCPIP. We have received a draft of the proposed revision of the WCPIP from your office and will be providing comments on it soon. This letter and the final inspection report have been placed in the EPA docket (Air Docket No. A-98-49, I1-A4-115) and posted on the EPA website at
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### -w.epa.gov/radiation/wipp. If you have any questions, please contact Rajani Joglekar at (202) 343-9462 or Ed Feltcorn at (202) 343-9422. Sincerely

D. Edwards, Director Protection Division
Enclosures

cc: Electronic Distribution Frank Marcinowski, DOE HQ EM Christine Gelles, DOE EM Alton Harris, DOE EM John Lee, DOE OAK Vernon Daub, CBFO Casey Gadbury, CBFO Ava Holland, CBFO Courtland Fesmire, CBFO J.R. Stroble, CBFO Martin Navarrete, CBFO Dennis Miehls, CBFO Steve Zappe, NMED D K Ploetz, WTS/CCP Allison Pangle, CTAC Wayne Ledford, CTAC Patrick Kelly, SC&A Site DocumentsTiei-ing of RI-ff TRU WC l'e

- ocesses Ianplerr ented by GEV1VC-C(:P13ased on Iyecernbee• 2--4, 2008 13aseline Vnspection

RIi WC Process Elements GEVNC-CCP RH WC - Tl Chan es GEVNC C'C'P RH WC - T2 Chan es* Notification and submission ol'the following itenis: Acceptable Knowledge (AK) None**

- Correlation and Surrogatc Suinniary Form: (AK 2)

- Revisions to the AK Summary CCP-AK-GEV-500. including changes to the associated Relcrencc List: (AK G)

- Updates and revisions to CCP-AK-GL'.V-501; (AK 12)

- Revision of reference M007: (AK 12)

- Additional discrepancy resolutions; (AK 13)

- Final Waste Stream Profile Form and related attachments, and subsequent changc rcquests: (AK 14)

- AK Accuracy reports for this wastc strcani: (AK 15) ftadiological Characterization. None** Notification and submission of the following iteins: Dosc-to-Curie (DTC), and the application of radionuclide- - Revisions of CCP-AK-GLV-501 or CCY=1'P-504 that specitic scaling factors require CBFO approval; (RC 3)

- Generation of ineasuremcnt data for any GI:VNC Rl l TRU container(s) that subsequently qualiiies as C}i and is subject to NDA; (RC 8) Visual Fxamination (VE) None** Notification and submission ofthe following items:

- Any change to VE procedure(s) that requires CBFO approval; (VE 2)***;
WIPP Wa.ste Information None at this time Notification and submission of the following itenis: Systcm (WWIS)
- Changes to WWIS proccdure(s) that require CBFO approval; (WWIS 2)***;

- Changes to the Excel spreadsheet titicd WWIS Data Entry Summary Characterization and Certification: (WWIS 2) * AII applicable "I'2 changes must be provided to EPA in a one-time submission following completion of the last shipment ol' Gf3VNC RI I debris proposcd for approval to WIPP for disposal ** No additional RI-I waste from GEVNC will be characterized using the site processes evaluated during thc inspcction *** F.xcluding changes that are editorial in nature or are required to address administrative concerns