UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

Courtland Fesmire 

Acting Director, National TRU Program 

Carlsbad Field Office 

Department of Energy 

P.O. Box 3090 

Carlsbad, NM 88221 

Dear Mr. Fesmire: 

JIJN 1 8 2009 OFFICE OF 

AIR AND RADIATION 

We received your letter dated June 17, 2009, requesting the Environmental Protection 

Agency's (EPA's) concurrence on the draft recertification memo the Carlsbad Field Office 

(CBFO) plans to issue to the Central Characterization Project (CCP) at the Oak Ridge National 

Laboratory (ORNL). The draft recertification memo addresses CCP's waste characterization 

program to characterize contact-handled (CH) transuranic (TRU) debris waste at ORNL. This 

request is in accordance with the CBFO procedures that are intended to ensure that the 

Department of Energy's (DOE) Waste Isolation Pilot Plant (WIPP) site certifications correlate 

appropriately with EPA approvals for waste characterization activities at DOE TRU waste 

generator sites. 

In November 2007, EPA performed a baseline inspection ofORNL CCP's CH TRU 

waste characterization program for compliance with EPA regulations at 40 CFR 194.8 (69 FR 

42571-42583). On August 21, 2008, EPA approved CH TRU program detailed in EPA Air 

Docket No. A-98-49, II-A4-103. Since then EPA approved two Tier 1 (T1) changes applicable 

to the CH TRU approval. These were: October 2008, EPA approval to extend calibration range 

of the Segmented Gamma System and January 2009, EPA approval to extend calibration range 

ofthe Integrated Passive Active Neutron equipment. Note that on February 3, 2009, EPA also 

approved ORNL-CCP's RH TRU waste characterization program for characterizing and 

disposing at the WIPP the RH TRU retrievably-stored, debris (S5000) waste at ORNL (See EPA 

Air Docket No. A-98-49, II-A4-111). 

The EPA limitations concerning the TRU waste characterization program for CH 

retrievably-stored debris waste contained in the above mentioned EPA approval letters remain 

applicable and are appropriately included in Attachment 4 of the draft site recertification letter 

sent for EPA concurrence. We concur that the waste characterization equipment, procedures and 

processes implemented to characterize CH TRU debris waste encompassed in the draft 

recertification memo for ORNL CCP are in agreement with EPA's existing approvals at the site. 

Internet Address (URL) • http://www.epa.gov 

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper 
Thank you for providing us with an opportunity to review the draft certification memo for 

ORNL CCP. If you have any questions or concerns, please contact me (202-343-9462). 

Enclosure 

cc: (Electronic Distribution) 

Alton Harris, DOE HQ 

Dave Moody, CBFO 

Vernon Daub, CBFO 

Casey Gadbury CBFO NTP 

Ava Holland, CBFO QA 

Norma Castaneda, CBFO NTP 

J. R. Stroble, CBFO NTP 

Martin Navarrete, CBFO QA 

Dennis Miehls, CBFO QA 

Jonathan Edwards, EPA 

Tom Peake, EPA 

Raymond Lee, EPA 

Lloyd Generette, EPA Region 4 

Steve Zappe, NMED 

~'~(f;fL Rajani Joglekar 

Center for Waste Management and Regulations