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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

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OFFK;E OF

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 provides the results of 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) (Inspection Number

EPA-SRS-CCP-IO.O5-08). SRS-CCP is characterizing TRU waste for disposal at 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

technical adequacy of the characterization of contact-handled (CR), retrievably-stored and newlygenerated debris and soils/gravel waste. With this letter, EPA approves the disposal ofTRU

debris and soiVgravel waste at WIPP, as characterized by SRS-CCP, according to the conditions

specified by this letter and inspection report. This letter and the final inspection report 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 Baseline Ins~ction

EP A examined the following waste characterization activities during our site inspection:

.

.

.

.

Acceptable knowledge (AK) and load management for contact-handled (CH) retrievablystored and newly-generated TRU debris waste (S5000) and soils/gravel wastes (S4000)

Visual examination (VE) as quality control (QC) check of 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)

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Nondestructive assay (NDA) and the WIPP Waste Infomlation System (WWIS) for CH

retrievably-stored and newly-generated TRU debris waste (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 inspection closeout on site and subsequent to the inspection. The

EPA inspection team members evaluated all responses for completeness and adequacy, and

concluded that each was resolved satisfactorily. 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 approval of the TRU waste characterization program at SRSCCP (71 FR 13592). This Federal Register notice also opened a 45-day public comment period

on our proposed approval and announced the availability of the inspection report (Air Docket

No: A-98-49; II-A4-68).

EP A received one set of public comments on the proposed SRS-CCP Inspection Report.

Attachment E of the enclosed inspection report summarizes the comments and EPA's responses.

A:R:Rroval Surnm~

With this letter, EP A approves the following TRU waste characterization 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/gravel and debris waste

(3) The IP AN NDA system for assaying debris waste

(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 debris and soil/gravel wastes

(6) The nondestructive examination process ofRTR for retrievably-stored soil/gravel and

debris wastes

--

(7) The WWIS process for tracking of waste contents of debris and soil/gravel wastes

Any changes to the WC activities from the date of the baseline inspection must be reported to

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-CCP WC Process

SpecificTI Chan2es

SRS-CCP WC Process

Specific T2 Chao!!es*

SRS-CCP General T2

Chan!!es*

algorithms specific to load

management

discussed in Section 8.1 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

Section 8.2)

Changes to site procedures

requiring CBFO approvals

and other changes as

discussed in Section 8.2 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 Section 8.3 of

this report

VE and VET Changes in vendor N/A

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 every three months.

** Modifications to approved equipment include all changes with the potential to affect NDA data relative to

waste isolation and exclude minor changes, such as the addition of safety-related equipment.

Changes to the approved waste characterization program that are designated as Tier 1

must be reported to EP A prior to implementation. DOE may implement Tier 2 changes prior to

EPA approval, however, DOE must provide periodic reports of these changes to EPA. The

attached inspection report provides additional details on the types of activities that are considered

Tier 1 and Tier 2.
If you have any questions, please contact Ed Feltcom at (202) 343-9422 or Rajani

J()glekar at (202) 343-9462.

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Bonnie C. Gitlin, Acting Director

Radiation Protection Division

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