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David C. Moody, PhD, Manager 

Carlsbad Field Office 

IJ.S. Department of Energy 

P.O. Box 3090 

Carisbad, NM 88221-3090 

Dear Dr. Moody: 

This letter provides the U.S. Environmental Protection Agency's (EPA) baseline approval 

of the contact-handled (CH) transuranic (TRU) waste characterization program implemented by 

the Centrai Characterization Projeet (CCP) at the Los Alamos National Laboratory (LANL) 

(Inspection Number EPA-I,ANL-CCP-05.06-08). The enclosed report (Air poeket No. A-98-49; 

II-A4-88) describes the basis for EPA's baseline approval results and tiering designations for 

each of the waste characterization processes evaluated as part of inspections conducted between 

May 2006 and March 2007. 

In May 2006, EPA condueted a baseline inspection of LANL-CCP's CH "I -RU waste 

eharacterization program to assess the characterization of waste in accordance with EPA 

regulations (40 CFR 194.8(b)(3), 40 CFR 194.8(c) and 40 CFR 194.24). During the inspection. 

EPA assessed the technical adequacy of the characterization performed through acceptable 

knowledge (AK), non-destructive assay (NDA), real time radiography (R"I'R), visual examination 

(VE), and WIPP Waste Information System (WWIS) for tracking the contents of the waste 

destined for the disposal at WIPP. EPA's inspection team identified one finding and seven 

concerns in the areas of visual examination and acceptable knowledge. The Department of 

Energy's (DOE) Carlsbad Field Offiee (CBFO) adequately responded to EPA's findings and 

concerns and no issues resulting from this inspection remained open when EPA issued the 

proposed approval decision for publie eomment. 

In accordance with 40 CFR 194.8, EPA isstted a Federal Register notice on April 18, 

2007, announcing EPA's proposed approval of the CH TRU waste characterization program at 

LANL-CCP. This F'ederal Register notice also opened a 30-day public comment period on our 

proposed approval and announced the availability of the inspection report (Air pocket No: A-98- 

49; II-A4-87). EPA received one set of public comments on the proposed LANL-CCP inspection 

report. In the enclosed inspection report. Section 9 and Attachment D discuss the public 

comments and EPA's responses. 

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After consideration of public comments on the proposed baseline approval, EPA 

approves the disposal of CH TRU debris and solid wastes, as characterized by LANL-CCP, 

according to the conditions and limitations specified by this letter and inspection report. 'I'his 

letter and the frnal inspeetion report have been placed in the EPA docket (Air pocket No. A-98- 

49, II-A4-88) and posted on the EPA website at www.eRa.aov/radiation/wjpp. 

EPA approves the following CH TRU waste characterization processes and equipment at 

LANL-CCP: 

(1) The AK and load management process for CH retrievably-stored TRU debris and solid 

wastes and for newly-generated debris wastes from the Offsite Sealed Source Recovery 

Program (OSRP) 

(2) The LANL High Efficieney Neutron Counter (IIENC #1) and LANL HENC #2 NDA 

systems for assaying CH solid and debris wastes 

(3) The portable tomographic gamma scanner NDA system for assaying CH debris waste 

(4) V E as a Quality Control (QC) check of the RTR process and in lieu of the RTR process 

for retrievably-stored solid and debris wastes and Visual Exaniination Technique (VET) 

of newly-generated debris wastes from the OSRP. However, DOE is not required to 

maintain the ability to perform VE as a QC check of RTR (see EPA letter of December 6, 

2006, see Air poeket A-98-49, II-A4-78). 

(5) The nondestructive examination process of RT R for CH retrievably-stored solid and 

debris wastes 

(6) The WWIS process for traeking of waste contents of solid and debris wastes, including 

debris from the OSRP. As required by 40 CFR 194.8, any changes to these waste 

characterization activities from the date of the baseline inspeetion must be reported to, 

and, if applicable, approved by EPA, according to the enclosed table. 

Changes to the approved waste characterization program that are designated in the 

enclosed tabie as Tier 1 must be reported to EPA prior to implementation. DOE may implement 

Tier 2 changes prior to EPA approval; however, DOE must provide EPA with notification 

summarizing these changes at the end of each fiscal year quarter. Please note that the 

notification of Tier 2 changes is different from past praetice, in which DOE had to supply the 

documentation. The enclosed table (excerpted from the report) identifies the types of activities 

that are considered Tier 1 and Tier 2. 

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

Feltcorn at (202) 343-9422. 
Enclosures 

cc: Electronic Distribution 

Frank Marcinowski, DOE HQ 

Lloyd Piper, CBFO 

Vernon Daub, CBFO 

Casey Gadbury, CBFO 

Courtland Fesmire, CBFO 

J.R. Stroble, CBFO 

Norma Castaneda, CBFO 

Martin Navarrete, CBFO 

Dennis Miehls, CBFO 

Allison Pangle, CTAC 

Wayne Ledford, CTAC 

Steve Zappe, NMED 
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