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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

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FEB 18 2009 

OFFICE OF 

AIR AND RADIATION 

Doriald C. Gadbury 

Director, National TRU Program 

Carlsbad Field Office 

Department of Energy 

P.O. Box 3090 

Carlsbad, NM 88221 

Dear Mr. Gadbury: 

We received your letter dated February 13, 2009, requesting the Environmental 

Protection Agency's (EPA's) concurrence on the draft certification memo the Carlsbad Field 

Office (CBFO) plans to issue to the Central Characterization Project (CCP) at the Oak Ridge 

National Laboratory (ORNL). This request is in accordance with the CBFO procedures that are 

intended to ensure that the Department of Energy's (DOE) Waste Isolation Pilot Plant (WIPP) 

site certifications correlate appropriately with EPA approvals for waste characterization activities 

at DOE transuranic (TRU) waste generator sites. 

In November 2007, EPA performed a baseline inspection of ORNL CCP's contacthandled (CH) TRU waste characterization program (EPA-ORNL-CCP-CH-11.07-08) for 

compliance with EPA regulations as required by 40 CFR 194.8 (69 FR 42571-42583). On 

August 21, 2008, EPA issued a final inspection report and a letter approving several aspects of 

the ORNL CCP CH waste characterization program (EPA Air pocket No. A-98-49, Item II-A4- 

103). From June 30-July 2, 2008, EPA performed a baseline inspection of ORNL CCP's remotehandled (RH) TRU waste characterization program (EPA-ORNL-CCP-RH-06.08-08) for 

compliance with EPA regulations. On February 3, 2009, EPA issued a final inspection report 

and a letter approving several aspects of the ORNL CCP RH waste characterization program 

(EPA Air pocket No. A-98-49, Item II-A4-111). 

Upon review of the draft expansion letter for ORNL CCP, EPA determines that it 

appropriately authorizes characterization and certification of both CH and RH TRU, retrievablystored, debris (S5000) waste at ORNL CCP. The EPA limitations concerning the TRU waste 

characterization program for CH and RH retrievably-stored waste contained in EPA's August 21, 

2008 and February 3, 2009 approval letters remain applicable and are appropriately included in 

Attachment 4 of your site certification. We concur that the waste characterization equipment, 

procedures and waste streams encompassed in your draft for ORNL CCP agree with EPA's 

existing approvals at the site. 

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

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper 
Additionally, there were some document references that were inaccurate in the report as 

issued for the final approval of ORNL CCP RH. The changes made are highlighted in the 

enclosure. Please replace the pages in the issued report with the enclosed version. 

Thank you for providing us with an opportunity to review the draft certification memo for 

ORNL CCP. If you have any questions or concerns ;please contact Ed Feltcorn (202-343-9422) 

or Rajani Joglekar (202-343-9462). 

Sincerely, 

Tom Peake, Director 

Center for Waste Management and Regulations 

Enclosure 

cc: (Electronic Distribution) 

Alton Harris, DOE HQ 

Vernon Daub, CBFO 

Ava Holland, CBFO QA 

Courtland Fesmire, CBFO 

Norma Castaneda, CBFO 

J. R. Stroble, CBFO 

Martin Navarrete, CBFO QA 

Dennis Miehls, CBFO QA 

A1lison Pangle, CTAC 

Wayne Ledford, CTAC 

Jonathan Edwards, EPA 

Raymond Lee, EPA 

Lloyd Generette, EPA Region 4 

Steve Zappe, NMED