UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHING T ON, D.C. 20460

Mr. J. R. Stro ble , Manager National TRU Pro g ram Carlsbad Field Office U.S. Department of E nerg y P.O. Box 3090 Carlsbad. NM 88221-3090 Dear Mr. S trobl e: 

## FEB 1 1 2014 OFFICE OF AIR AND RADIATION

This letter provides the re sults ofthe U.S. Environmental Protection Agency"s (EPA) continued comp li ance inspection of the Centra l Charac teri zat i on Pr oject (CCP) waste characterization (WC) pro g ram for contact-handled (CH) transuranic (TRU) waste at the Los A lamos National Laboratory (LANL). This inspection occurre d on November 19- 2 1. 20 1 3. As a result of this continued co mplian ce inspection. EPA contitms that the CH TRU waste charac terization program implemented by the CC P at LANL is technically adequate and compliant with 40 CFR 1 94.24 re quirement s . The enclosed rep o rt (EPA Air Docket No. A-98-49; II-A4-179) g iv es the details of E PA 's evaluation of the program. EPA initially approved waste characterization acti vi ties at LANL

- CCP for CH waste in June 2007 (EPA Air Dock et No. A-98-49; II-A4-88). S ince then EPA performed a continued compliance inspection in February2011 (EPA A ir Docket No. A -98- 49; fl

- A4-14 1 ), and seven (7) Tier I change a pproval s addressi n g changes to prcviously-approYed radi oassay equipment. and appr ova l of th e addition of the solids (S3000) s ummary category g roup. In accordance with 40 CFR 194.8(b). during this o n- site inspection, EPA sampled the following TRU waste characterization activi tie s a nd processes:
• Acceptable kno\vkdgc (AK): evaluation took place on site at LANL. • four nondestructive assay (NDA) sys tem s: Two High Efficiency Neutron Co unters (HENCs). the Super High Efticiency Neutron Counter (SuperHENC or S HENC) and the Mobile In Situ Object Counting System (ISOCS) Large Container Counter (MILCC): evaluation took place on si te at LA NL. • R ea l-time radiography

**(RTR)~** eva luation pctformed as a de skto p evaluation. • Visual Examination (VE); evaluation performed as a desktop evaluation.

Internet Address (URL) • http : //www.epa

. gov Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper

### In ad diti on this continued comp liance insp ection followed EPA ' s improved ev aluation and de cis ion process to s upp ort DO E sites' state-mandated cleanup needs (see Section 2.0 of the 

### e

n

cl

osed report). During this inspection, E PA did not issue a ny findings or concerns. However, EPA observed seve ral errors specific to AK document and record management mentioned in the enclosed report . EPA informed CCP and CBFO that a varying degree of s imilar errors has been obse rv e d in th e past at other T RU S it es. CBFO and CCP need to address this systemic problem. EPA will continue to review CC P ' s documen t a nd reco rd manage men t during future continued comp li a nce in spections and Tl eva lu ations of aU CC P TR U was te c h aracteri z ation programs. EP A continues to approve CCP ' s CH TRU WC programs at LANL in the configuration observed during this inspection, and which i s o perat ed in a manner co nsi stent w ith the limitat ion s de sc ribed in th e base lin e inspection report and subsequent Tier 1 appr ovals cited in Attachments A of the enclo s ed report. EPA co nfirm s that LA N L-CCP has approp riately implem e nted and informed EPA ofTier 2 changes since Ju ne 2007. If yo u have any que stio ns , pl ease contact Raj ani Jogl eka r (202 343 -94 62) or Ed Fe l tcorn (202 343- 9422).

Enclosure
cc: electronic distri b ution Alton H arri s , DOE EM Joe F ranco, CBFO Norma Castane da , CBFO Marcus Pinzel , CBFO T om M o rgan , C BFO Ed Gulbranson, CCP Trais Kliphui s , NMED Site Documents, CBFO/ LANL Jon Edwards, EPA Sincere ly,



# ~u Tom Peake, Director Center for Wa ste Manageme nt and Regulations