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O ~■ ', OFFICE OF AIR AND RADIATION Dr. David Moody, Manager Carisbad Field Office U.S. Department of Energy P.O. Boa 3090 Carlsbad, NM 88221-3090 Dear Dr. Moody: This letter provides the reaults of the L.S. Environmental Protection Agency's (EPA) baseline inspection of the remote-handled (RIH) transuranic (TRU) waste characterization program inlplemented by the Central Charaeterization Project (CCP) at the Los Alamos National Laboratory (LANL) (Inspection Number EPA-LANL-RH-CCP-05.07-08). On May 8-10 2007, the EPA conducted a baseline inspection of LANL-CCP's RH TRU waste eharacterization program to assess the characterization of RIH TRli waste in accordance with EPA regulations (40 CFR 194.8(b)(3), 40 CFR 194.8(c) and 40 CFR 194.24). During the inspection, EPA assessed the technical adequacy of the characterization performed through acceptable knowledge (AK) and radiological characterization (RC). EPA's inspection team identified two eoncerns, one in each evaluation area. RC and AK. The Department of Energy's (DOE) Carlsbad Field Office (CBFO) adequately responded to EPA's concerns and there are no open issues resulting from this inspection. In accordance with 40 CFR 194.8, EPA issued 

### a Federal Register notice on August 22 2007, announcing EPA's proposed approval of the RI I TRU waste characterization program at LANL-CCP. This 

### F'ederal Register notice also opened a 45-day public comment period on our proposed approval and announced the availability of the inspection report (Air poeket No: A-98- 49; II-A4-89). EPA received one set of public comments and a set of late comments from the sanie commenter on the proposed LANL-CCP inspection report. In the enclosed inspection report, Section 9 and Attachment B discuss the pubiic comments and EPA's responses. Approval Summary The EPA determined that the records documenting LANL-CCP's RH WC programrepresented activities that were technically adequate. EPA, therefore, is approving the LANLCCP RH WC program limited to the sixteen RH TRU canisters in LANL RH Waste Stream No. LA-MHD03-002 evaluated during this baseline inspection that is described and doeumented in this report. This approval includes the following:

InternetAddress(URL) e httpi/www.epa.gov RecyciedlFtecyciable f Printetl with Vegeta6le Okt Based Inks on 1 00 % Postconsumer, Process Chlorine Fres Recycled Paper(1) The AK process for sixteen canisters of RH retrievably-stored TRU debris in the waste

stream designated LANL RH Waste Stream No. LA-MHD03-002. (2) The RC process using dose-to-fissile gram, dose-to-curie (DTC), curie-to-dose and modeling-derived scaling factors for assigning radionuclide values to sixteen canisters of RH retrievably-stored TRU debris in one waste stream, designated as LANL RH Waste Stream No. LA-MHD03-002 and documented in CCP-AK-LANL-501. Revision 0 and detailed in this report. This letter and the final inspection report have been placed in the EPA docket (Air Docket No. A-98-49, II-A4-96) and posted on the EPA website at www.e a.

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Since no additionai WC aetivities will occur relative to the sixteen canisters of RH debris waste that are the subject of this approval, changes to the WC activities evaluated during the baseline inspection are not expected to occur. Accordingly, the report that aceompanies this letter does not list any Tier I(TI) or "Fier 2(T2) designations relative to this waste and waste characterization components covered by this approval. Approval of any future or other past RH WC aetivities at LANL-CCP will require a new EPA baseline inspection. If you have any questions, please contact Rajani Joglekar at (202) 343-9462 or Ed Feltcorn at (202) 343-9422. 

### Sincerely,


# ~ Juan Reyes, Director Radiation Proteetion Division


### Enclosures

cc: Electronic Distribution Frank Marcinowski, DOE HQ Vernon Daub, CBFO Ava Holland, CBFO Courtland Fesmire, CBFO J.R. Stroble, CBFO Martin Navarrete, CBFO Dennis Miehls. CBFO Brian Littleton, EPA Steve Zappe, NMED Allison Pangle, CTAC Wayne Ledford, CTAC