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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 wastecharacterization 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 PaperDuring 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