### Department of Energy

P.O. Box 3090 Carlsbad, NM 88221

Dear Dr. Moody:

The Environmental Protection Agency (EPA) gives approval for the Department of Energy (DOE) to begin the characterization of retrievably-stored, remote-handled (RH), debris waste by the Central Charaeterization Program (CCP) at Los Alamos National Laboratory (LANL), in Los Alamos, New Mexico. This approval to begin the characterization of RH waste does not constitute an approval to dispose of any RH waste at the Waste Isolation Pilot Plant (WIPP). From March 20-22, 2007, EPA will conduct a baseline inspection of RH waste characterization at LANL CCP to confirm the adequacy of the implementation of RH waste characterization procedures. EPA's confirmation wiil be based on the demonstration of waste characterization activities and through the examination of objective evidence.

EPA's approval to begin characterization of RH waste is based on our review of the waste characterization procedures provided by LANL CCP and listed in the attached table. As the table shows, EPA has determined that many of the procedures appear to be technically adequate and will be further evaluated during the March 20-22, 2007 inspection. The adequacy of the procedures and application of their contents will be determined through discussions with subject matter experts and evaluation of objeetive evidence sueh as batch data reports, as required by 40 CFR 194.24. The final approval of the LANL CCP RH waste characterization program will be given only after EPA evaluates the results of the baseline inspection in accordance with the process described in 40 CFR 194.8.

If you have any questions or concerns, please eontact Rajani Joglekar (202) 343-

9462.



### Si erely,



# ~ "A/' 

# ~ Juan Reyes, Direetor Radiation Protection Division

Internet Address (URL) s ^ttpllwvnv.epa.gov Recycletllflecyclable 0 Printed nith k'egetabie Oii Sased Inks on 100 % Postconsumer. Process C^lor.ne Free Recycled Paper

### Fnclosure

cc: Electronic Distribution Frank Marcinowski, DOE HQ Lloyd Piper, CBFO Vernon Daub, CBFO Ava Holland, CBFO Courtland Fesmire, CBFO Norma Castaneda, CBFO Martin Navarrete, CBFO Dennis Miehls, CBFO Allison Pangle, CTAC Wayne Ledford, CTAC 2

### Procedures Provided for LANL RH Inspection

~:. ...: ~ .'.: ~ 

### pprovtid€or ~ 

### I«ncuzneit~~"4'~:- 3~eYisi#~ai'. ~aeit~~nt'3itle.,` Iits ctiuu?
CCP-PO-002 17 CCP Transuranic Waste Certitieation Plan Yes
CCP-TP-500 2 CCP Remote-Handled Waste Visual Examination Yes, will discuss Technique during ins ection
CCP-TP-504 i 3 CCP Dose-to-Curie Survey Procedure for Remote- Yes, will discuss Handled Transuranic Waste during inspection -
CCP-TP-506 2 CCP Preparation of the Remote-Handled Transuranic Yes, will discuss Waste Acceptable Knowledge Characterization during inspection
Reconciliation Re ort CCP-TP-509 0 CCP Remote-Handled Transuranic ContainerTrackin Not A licable
CCP-TP-530 2 CCP RH TRU Waste Certification and WWIS Data Yes, will discuss

~ Entry during ins ection
CCP-AK-LANL-500 1 LANL RH AK Summary Report Yes, will discuss during inspection
CCP-AK-I.ANL-501 0 Radiological Characterization Report for LANL RH Yes, will discuss
Waste durin = inspection CCP-AK-LANL-502 0 Site Specific Certification Plan and Confirmatory "I'est Yes, will discuss Plan for LANL RFl Waste during inspection CCP-AK-LANL-503 3 CCP LANL QA Equivalency Report Yes, will discuss i durine inspection CCP-AK-LANL-504 0 CCP LANL Qualification of PAN Assay System Yes, will discuss ' Software during inspection '



### Documents that are marked as Approved for Inspection are acceptable for use in conducting the Inspection. These doeuments may have technical details or issues that will be discussed during the inspection at LANL.