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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

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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, CTAC 
Scope 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.