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### ~~~ v'" 'LPRO~ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460

,~. OFFK;EOF AIR AND RADIA TK>N
David Moody, Manager Carlsbad Field Office U.S. Department.ofEnergy P.O. Box 3090 Carlsbad,

NM 88221-3090
Dear Dr. Moody:
This letter providesthe resultsof the U.S. Environmental Protection

Agency's (EPA) inspection

of the Central Characterization Project's (CCP) transuranic (TRU) waste characterization

program implemented

at the Savannah

River Site (SRS) (InspectionNumber EPA-SRS-CCP-IO.O5-08). SRS-CCP

is characterizing

TRU waste

for disposalat the Waste Isolation Pilot Plant (WIPP).
From October 31 to November 3, 2005, EP A conducted

a baseline

inspection of SRSCCP to assess

the characterization

of TRU waste in accordance with EP A regulations (40 CFR I 94.8(b)(3),

40 CFR 194.8(c)

and 40 CFR 194.24). During the inspection,EPA assessed the technicaladequacy

of the characterization

of contact-handled

(CR), retrievably-stored and newlygenerated

debris and soils/gravel

waste. With this letter, EPA approves the disposalofTRU debrisand soiVgravel

wasteat WIPP, as characterized by SRS-CCP,

according

to the conditions specifiedby this letter and inspectionreport. This letter andthe final inspectionreport have been placed in the EP

A docket (Air Docket No. A-98-49, II-A4-65) and posted on the EP A website at www .epa.gov/radiation/Wi~~.
October/November

2005 BaselineIns~ction
EP A examined

the following wastecharacterization activities during our site inspection:



## .

.

.

. Acceptableknowledge (AK) and load management for contact-handled

(CH) retrievablystoredand newly-generated TRU debris waste(S5000) and soils/gravel

wastes (S4000) Visual examination(VE) as quality control (QC) checkof real-time radiography(RTR) for CH retrievably-stored TRU debris waste(S5000) and soils/gravel

wastes (S4000) Visual Examination Technique (VET) for CH newly-generated debris waste (S5000) Real-Time Radiography (RTR) for CH retrievably-stored TRU debris waste (S5000)

internet Address (URLj 

# . hiip;iiwwW.8pti.goV Recycled/Recyclabl8 

# . Pmted wfth Vegetable 01 Based Inks on Recycled Paper (Mlninum 30% postconsumer)Nondestructive assay (NDA) and the WIPP Waste Infomlation System (WWIS) for CH retrievably-stored

and newly-generated

TRU debriswaste(S5000)and soils/gravel (S4000) ,. 

## .

EPA's inspection

team identified one finding and five concerns.The one finding and two of the concerns

required a response

from DOE. Personnel

from SRS,

the Carlsbad

Field Office (CBFO), and the CCP provided information regarding the finding and concerns to the EP A inspection

team prior to the inspectioncloseout on site and subsequent

to the inspection. The EPA inspectionteam members evaluated

all responses

for completeness

and adequacy,

and concluded

that each was resolvedsatisfactorily. EP A considers

all concerns

and the finding to be resolved, and there are no open issues resulting from this inspection.
In accordance

with 40 CFR 194.8,EP

A issued a Federal Register notice on March 16, 2006, announcing

EPA's proposed

approvalof the TRU wastecharacterization program at SRSCCP (71 FR 13592). This Federal Registernotice also opened a 45-day public comment period on our proposed

approval and announced the availability of the inspectionreport (Air Docket No: A-98-49; II-A4-68).
EP A receivedone set of public comments on the proposed

SRS-CCP

Inspection Report. AttachmentE of the enclosed inspectionreport summarizes the comments

and EPA's responses.
A:R:Rroval

Surnm~ With this letter, EP

A approves

the following TRU wastecharacterization processes

and equipment

at SRS-CCP: (1) The AK and load management process for CH retrievably-stored TRU debris and soil/gravel (2) The IQ3 NDA system for assaying

soil/graveland debriswaste (3) The IP

AN NDA system

for assaying

debriswaste (4) VE as a QC check of the RTR process for retrievably-stored

soil/gravel and debris waste (5) The VET process

for newly-generated

debrisand soil/gravelwastes (6) The nondestructive

examination

process ofRTR for retrievably-stored soil/gravel and debris wastes

-- (7) The WWIS process

for tracking of wastecontents of debrisand soil/gravel wastes Any changes

to the WC activities from the dateof the baseline inspection

must be reportedto and, if applicable,approved by EP A, according

to the following table.Table 1. Tiering of TRU WC Processes Implemented by SRS-CCP (Based on October 31-November 3,2005, Baseline Inspection) WC Process Elements SRS-CCPWC Process

SpecificTI Chan2es SRS-CCP WC Process Specific T2 Chao!!es* SRS-CCP General T2 Chan!!es* algorithms

specific to load management discussed in Section8.1 of this report approved waste category (see Section 8.1)

INDA New equipment or physical modifications

to approved equipment** Changes in load management

status of approved

waste stream(s) Changes to software

for approved

equipment

(see Section8.2) Changes to site procedures requiring CBFO approvals and other changes

as discussed

in Section8.2 of this report Extension

or changes

to approved

calibration range for approved

equipment

(see Section 8.2) Changes to operating range(s) upon CBFO approval

RTR N/A New equipment or changes to approved

equipment Changes to site procedures requiring CBFO approvals and other changes

as discussed

in Section8.3 of this report VE and VET N/A Changes in vendor perfonning VE and/orVET Changes to site procedures requiring CBFO approvals and other changes

as discussed

in Section 8.4 of this report WWIS N/A N/A

I Changes to site procedures
! requiring CBFO approvals and other changes including algorithms specific to load management

as discussed in Section 8.5 of this report * Upon receiving EPA approval,SRS-CCP will report all T2 changes to EPA everythree months. ** Modifications to approved equipment

include all changes

with the potentialto affect NDA data relative to waste isolation and excludeminor changes, suchas the addition of safety-related equipment. Changes to the approved

wastecharacterization

program that are designated

as Tier 1 must be reported

to EP A prior to implementation. DOE may implementTier 2 changes prior to EPA approval, however,DOE must provide periodic reportsof these changes to EPA. The attached inspectionreport providesadditional details on the typesof activities that are considered Tier 1 and Tier 2.If you have any questions, please contactEd Feltcom at (202) 343-9422or Rajani J()glekar at (202) 343-9462. 

# ~;;~/Z :- 

# C~

Bonnie C. Gitlin, Acting Director Radiation ProtectionDivision
Enclosure

cc Kerry Watson, CBFO Ava Holland, CBFO Frank Marcinowski, DOE/EM (w/o enclosure) Lynne Smith, DOE/EM (w/o enclosure) Ines Triay, DOE/EM (w/o enclosure) EP A Air Docket