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### SEP 14 ?011

OFFICE OF AIR AND RADIATION Frank Marcinowski Deputy Assistant Secretary for Regulatory Compliance E:M-10 tJ.S. Department of Energy Washington, DC 20585
Ed Ziemianski, Manager Carlsbad Field Office tJ.S. Department of Energy P.O. Box 3090 Carlsbad, NM 88221
Dear Mr. Marcinowski and Mr. Ziemianski: I'his letter is to notify you that on September 20, 2011, US Environmental Protection Agency (L:PA) is performing an unannounced, continued compliance inspection of the transuranic (TRU) waste characterization program at the Idaho National Laboratory (INL) at Idaho Falls, ID. For the past six years the Central Characterization Project (CCP) has been characterizing contact-handled (CH) TRU waste at INL. EPA approved CCP's CH TRU waste characterization program in November 2005. 1'his inspection, conducted under our authority in 40 CFR 194.21 and 24(h), is occurring concurrently with a similar inspection being conducted by EPA at CCP's Carlsbad Office in Carlsbad, NM. The purpose of these concurrent inspections is to evaluate CCP's characterization of waste from Nuclear Radiation Development (NRD). For the past few years, INL-CCP has been characterizing Cl-I 'I'RlJ waste from small generator sites (such as Lawrence Berkeley Laboratory, NRD, and Lawrence Livermore Laboratory). To date, EPA has not evaluated in full INL-CCP's characterization of'I'RU waste froni these sites. This inspection of NRD waste is a snap shot of TRU waste characterization activities INI.-CCP has undertaken when characterizing TRU waste from small generator sites. NRD is a small generator site located near Grand Island, NY, that produced waste from manufacturing and/or recycling of smoke detector foils. During this inspection, EPA will evaluate the quantification of the radiological contents of NRD waste containers, including the measurement systems used and supporting documentation. Mr. Ed Feltcorn and EPA support contractor is conducting the inspection. Please provide them your full cooperation, including unfettered access to all areas as they request.

Intemet Address (URL) • http://www.epa.gov Recycled/Recyclable o Printed with Vegetable Oil Based Inks on 100% Poetconsumer, Process Chlorine Free Recycled Paper'I'he enclosed scope identifies the components of the TRU waste characterization system of controls that

will be evaluated during the inspection and the inspection schedule. The inspection team may inspect additional items if they deem it necessary. Please contact Ms. Rajani Joglekar, NRD CH Unannounced Inspection Team Lead, at 202-465-5529, if you have any questions.
Since

Edwards, Director i Protection Division Enclosure

cc: Electronic Distribution Christine Gelles, DOE HQ EM Alton Harris, DOE HQ EM George Basabilvazo, CBFO J R Stroble, CBFO Norma Castaneda, CBFO Marcus Pinzel, CBFO Randy Unger, CBFO Courtland Fesmire, CBFO Jerry Wells, DOE ID Eric Schweinsberg, AMWTP Jim Werntz, Idaho Field Office, EPA Region 10 1'aul Giardina, EPA Region 2 Jeanctte Eng, EPA Region 2 Nick Stone, EPA Region 6 John Kieling, NMED Tim Hall, NMED Charles Burns, NYDH Bruce LaRue, Idaho Dept Environmental Quality Dave Haar, WTS-CCP D K Ploetz, WTS-CCP Mike Sensibaugh, WTS-CCP Site Documents, CBFO Donna Sellmer, CTACScope of EPA's Unannounced Continued Compliance Evaluation of

Central Characterization Project's Contact-Handled Waste Characterization Activities at

Idaho National Laboratory, Idaho Falls, ID

DOE Site: Organizations Notified:

Inspection Dates: Idaho National laboratory-Central Characterization Project (INL-CCP) Department of Energy — Carlsbad Field Office Department of Energy — Idaho Office EPA Regions 2, 6, and 10 New Mexico Environment Department New York Department of Health Idaho Department of Environmental Quality September 20, 2011 Inspection Schedule: Tuesday 8:00 am Contact DOE ID and INL-CCP Tuesday 9:00 am — 4:00 pm Conduct Inspection Tuesday 4:30 pm Close-Out Meeting*

EPA Inspection Team:
Inspection Scope: * With DOE ID, CBFO National TRU Program, INL-CCP Management and technical leads ' Mr. Ed Feltcorn, EPA Mr. Patrick Kelly, EPA Support Contractor (SC&A)

EPA is conducting an unannounced inspection to evaluate the continued compliance of the technical processes implemented by INL-CCP to quantify radiological contents of NRD waste containers. EPA will evaluate nondestructive assay (NDA) system(s) and supporting documentation for characterizing contact-handled transuranic (CH TRU) waste produced by the Nuclear Radiation Development (NRD) sire near Grand Island, NY, from manufacturing and/or recycling of smoke detector foils. EPA Replicate Assay: EPA will select up to three (3) NRD waste containers for replicate analysis. INL-CCP will assay the selected drums using the EPA replicate assay protocol and will provide the assay results to EPA electronically no later than October 11, 2011. Inspection Logistics: A pre-evaluation conference/Kick-Off Meetings will be held on Tuesday, September 20, 2011 around 8:30 am• A post-evaluation EPA briefing/Close-Out* ivleeting will be on "I'uesday, September 20, 2011, at

4:30 pm *lf EPA evaluation cannot be completed during the allotted tinie, the lead inspector will inform CBFO/CCP of the elements that could not be completed and any documentation needed by EPA to complete its inspection offsite.