UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

Mr. J. R. Stroble, Manager 

National TRU Program 

Carlsbad Field Office 

U.S. Department of Energy 

P.O. Box 3090 

Carlsbad. NM 88221-3090 

Dear Mr. Strobl e: 

FEB 1 1 2014 OFFICE OF 

AIR AND RADIATION 

This letter provides the results ofthe U.S. Environmental Protection Agency"s (EPA) continued 

compliance inspection of the Central Characteri zat ion Project (CCP) waste characterization 

(WC) program for contact-handled (CH) transuranic (TRU) waste at the Los A lamos National 

Laboratory (LANL). This inspection occurred on November 19-2 1. 20 13. As a result of this 

continued compliance inspection. EPA contitms that the CH TRU waste characterization 

program implemented by the CCP at LANL is technically adequate and compliant with 40 CFR 

194.24 requirements. The enclosed report (EPA Air Docket No. A-98-49; II-A4-179) gives the 

details of EPA's evaluation of the program. 

EPA initially approved waste characterization activities at LANL-CCP for CH waste in June 

2007 (EPA Air Docket No. A-98-49; II-A4-88). Since then EPA performed a continued 

compliance inspection in February2011 (EPA Air Docket No. A-98-49; fl-A4-14 1), and seven 

(7) Tier I change approvals addressi ng changes to prcviously-approYed radioassay equipment. 

and approval of the addition of the solids (S3000) summary category group. 

In accordance with 40 CFR 194.8(b). during this on-site inspection, EPA sampled the following 

TRU waste characterization activities and processes: 

• Acceptable kno\vkdgc (AK): evaluation took place on site at LANL. 

• four nondestructive assay (NDA) systems: Two High Efficiency Neutron Counters 

(HENCs). the Super High Efticiency Neutron Counter (SuperHENC or SHENC) and the 

Mobile In Situ Object Counting System (ISOCS) Large Container Counter (MILCC): 

evaluation took place on site at LANL. 

• Real-time radiography (RTR)~ evaluation pctformed as a desktop 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 addition this continued compliance inspection followed EPA's improved evaluation and 

decision process to support DOE sites' state-mandated cleanup needs (see Section 2.0 of the 

enclosed report). 

During this inspection, EPA did not issue any findings or concerns. However, EPA observed 

several errors specific to AK document and record management mentioned in the enclosed 

report. EPA informed CCP and CBFO that a varying degree of similar errors has been observed 

in the past at other TRU Sites. CBFO and CCP need to address this systemic problem. EPA will 

continue to review CCP's document and record management during future continued compliance 

inspections and Tl evaluations of aU CCP TRU waste characterization programs. 

EPA continues to approve CCP's CH TRU WC programs at LANL in the configuration observed 

during this inspection, and which is operated in a manner consistent with the limitations 

described in the baseline inspection report and subsequent Tier 1 approvals cited in Attachments 

A of the enclosed report. EPA confirms that LANL-CCP has appropriately implemented and 

informed EPA ofTier 2 changes since June 2007. 

If you have any questions, please contact Raj ani Joglekar (202 343-9462) or Ed Feltcorn (202 

343- 9422). 

Enclosure 

cc: electronic distribution 

Alton Harris, DOE EM 

Joe Franco, CBFO 

Norma Castaneda, CBFO 

Marcus Pinzel, CBFO 

Tom Morgan, CBFO 

Ed Gulbranson, CCP 

Trais Kliphuis, NMED 

Site Documents, CBFO/LANL 

Jon Edwards, EPA 

Sincerely, 

~u Tom Peake, Director 

Center for Waste Management and Regulations