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.