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APR 2 5 2013 OFFICE OF 

AIR AND RADIATION 

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 waste characterization (WC) program for contact-handled (CH) 

transuranic (TRU) waste at the Advanced Mixed Waste Treatment Project (AMWTP) located at 

the Idaho National Laboratory (INL) in Idaho Falls, ID. This inspection occurred on two separate 

occasions, namely, October 30 — November 1, 2012 and February 26, 2013. As a result of this 

continued compliance inspection, EPA confirms that the CH TRU waste characterization 

program implemented by the Idaho Treatment Group (ITG) is technically adequate and 

compliant with 40 CFR 194.24 requirements. The enclosed report (EPA Air pocket No. A-98- 

49; II-A4-173) gives the details of the EPA evaluation of the program. 

In October 2006, EPA approved CH TRU waste characterization activities at AMWTP 

performed by another entity (see EPA's Baseline Approval Report A-98-49; II-A4-66, in the 

EPA Air pocket). In October 2011, ITG took over the AMWTP's waste characterization 

program and in doing so, ITG adopted "as is" the existing CH TRU waste characterization 

program (see Item (2), section 6.1 of the enclosed report for details). ITG also adapted relevant 

CH TRU waste characterization documents, and they serve as a basis for the continued 

characterization of CH waste containers from the Idaho Cleanup Project and other DOE TRU 

sites with small quantities of CH TRU wastes. The continued compliance inspection discussed in 

this report, therefore, was necessary to determine technical adequacy of the ITG-implemented 

processes, procedures, equipment and training of personnel involved. 

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 wastes 

• Nondestructive assay (NDA) systems used for characterizing CH TRU wastes 

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

Recycled/Recyclable 9 Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper 
• Real-time radiography (RTR) for CH TRU waste 

• Visual Examination (VE) for newly generated CH TRU waste 

During the inspection, EPA issued two concerns in the area of AK and RTR which have been 

resolved. 

EPA continues to approve ITG's CH TRU WC program in the configuration observed during the 

two inspections and is consistent with the limitations described in the baseline inspection report 

and the January 2013 Tier 1 approval report cited in Attachment A. EPA confinms that ITG has 

appropriately implemented and informed EPA of Tier 2 changes since October 2011. 

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

343- 9422). 

Sincerely, 

Tom Peake, Director 

Center for Waste Management and Regulations 

Enclosure 

cc:electronic distribution 

Alton Harris, DOE EM 

Joe Franco, CBFO 

Norma Casteneda, CBFO 

Marcus Pinzel, CBFO 

Ben Robert, DOE ID 

Gerry Wells, DOE ID 

Dave Haar, ITG 

Site Documents, CBFO/LANL 

Jon Edwards, EPA