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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

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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: 

This letter provides the results of the U.S. Environmental Protection Agency's (EPA) continued 

compliance inspection of the Central Characterization Project (CCP) waste characterization 

(WC) program for contact-handled (CH) and remote-handled (RH) transuranic (TRU) waste at 

the Oak Ridge National Laboratory (ORNL) near Oak Ridge, TN. EPA initially approved waste 

characterization activities at ORNL-CCP for CH waste in August 2008 (EPA Air pocket No. A98-49; II-A4-103) and for RH waste in Feb 2009 (EPA Air pocket No. A-98-49; II-A4-111). 

DOE suspended waste characterization activities at ORNL due to programmatic and budget 

issues in June 2011. 

In November 2013, the Carlsbad Field Office (CBFO) informed EPA that ORNL-CCP resumed 

waste characterization activities on October 1, 2013 and CBFO notified EPA that ORNL-CCP 

would be ready for an inspection in January 2014. After evaluating ORNL-CCP's documented 

resumption process EPA concluded that a new baseline inspection and approval would not be 

necessary. Instead, EPA would conduct a continued compliance inspection in accordance with 

Title 40 of the Code of Federal Regulations 40 CFR 194.24(h). This inspection occurred on 

February 4-6, 2014. 

In accordance with 40 CFR 194.8(b), during this on-site inspection, EPA sampled the following 

TRU waste characterization activities and processes: 

• Acceptable knowledge (AK) for CH and RH wastes 

• The NDA system (IQ3) used to characterize CH TRU waste 

• Dose to Curie process for characterizing RH TRU waste 

• Real-time radiography (RTR) for CH TRU waste 

• Visual Examination (VE) for RH TRU debris waste 

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

Recycled/Recyclable 0 Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper 
During the inspection, EPA issued two concerns in the area of RTR which have been resolved. 

These are discussed in the enclosed report. 

As a result of this continued compliance inspection, EPA confirms that the CH TRU waste 

characterization program implemented by the CCP at ORNL is technically adequate and 

compliant with 40 CFR 194.24 requirements. Concurrent with the continued compliance 

inspection, EPA performed a Tier 1(T1) inspection of the changes made to the Nondestructive 

Assay System (NDA) identified as the IQ3. The IQ3 was added to the ORNL-CCP CH waste 

characterization approval with the approval of the ORNL-CCP T1 request by EPA in March 

2010. The enclosed report (EPA Air pocket No. A-98-49; II-A4-186) gives the details of the 

EPA evaluation of the program in the continued compliance inspection and approves the changes 

made to the IQ3 system submitted to EPA as a Tier 1 change. 

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

343-9422). 

Sincerely, 

J 

1'om Peake, Director 

Center for Waste Management and Regulations 

Enclosure 

cc:electronic distribution 

Alton Harris, DOE EM 

Joe Franco, CBFO 

Thomas Morgan, CBFO 

Norma Casteneda, CBFO 

Marcus Pinzel, CBFO 

Trais Kliphuis, NMED 

Site Documents, CBFO/LANL 

Jon Edwards, EPA