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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 program 

represented 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. ~ov ~radiation/wi~. 

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