DOCKET NO: A-98-49; II-A4-91 

WASTE CHARACTERIZATION REPORT 

TIER 1 CHANGE: 

DESKTOP EVALUATION OF THE EXTENSION OF THE 

OPERATIONAL RANGE OF THE HIGH EFFICIENCY NEUTRON COUNTER No. 2 

(HENC 2) NON DESTRUCTIVE ASSAY (NDA) SYSTEM AT THE 

CENTRAL CHARACTERIZATION PROJECT (CCP) 

AT THE LOS ALAMOS NATIONAL LABORATORY (LANL) 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center of Federal Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

October 2007
i

TABLE OF CONTENTS 

Section Page

1.0 Executive Summary ............................................................................................................ 1 

2.0 Purpose of Inspections ........................................................................................................ 1 

3.0 Purpose of This Report........................................................................................................ 2 

4.0 Scope of Review.................................................................................................................. 2 

5.0 Evaluation Team ................................................................................................................. 3 

6.0 Evaluation of the LANL-CCP HENC 2.............................................................................. 3 

7.0 Summary of Results ............................................................................................................ 9 

7.1 Conclusions ............................................................................................................. 9 
ii

ATTACHMENTS 

Attachment A LANL-CCP HENC 2 Evaluation Checklist 
1 

1.0 EXECUTIVE SUMMARY 

In accordance with 40 CFR 194.8(b), the U.S. Environmental Protection Agency (EPA or the 

Agency) conducted Baseline Inspection No. LANL-CCP-05.06-8 of the Central Characterization 

Project Waste Characterization Program at the Los Alamos National Laboratory (LANL-CCP). 

On June 21, 2007, EPA approved the LANL-CCP waste characterization (WC) program with 

conditions and limitations, as documented in the LANL Baseline Final Inspection Report (see 

EPA Docket No. A-98-49, II-A4-88). This approval specified three nondestructive assay (NDA) 

systems: the Portable Tomographic Gamma Scanner (PTGS); the High Efficiency Neutron 

Counter No. 1 (HENC 1); and the High Efficiency Neutron Counter No. 2 (HENC 2). 

On August 1, 2007, the Carlsbad Field Office (CBFO) requested EPA approval of a Tier 1 (T1) 

change in the form of extending the operational range of the HENC 2 NDA system, an action 

that was identified as a T1 change in the LANL baseline inspection report. EPA conducted a T1 

evaluation of the extension of the HENC 2’s operational range using a desktop review of 

documents provided by LANL-CCP and a teleconference on September 12, 2007. Based on 

EPA’s evaluation as detailed below, EPA approves the range extension for the HENC 2 for 

assaying contact-handled (CH) transuranic (TRU) wastes in 55-gallon (208-liter) drums, 

consistent with the system’s operational ranges and limitations discussed in this report. 

This report serves as EPA’s public notification of the results of the proposed T1 change and its 

evaluation. This information will be provided through the EPA website and by sending e-mails 

to the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3). This approval does not make 

any changes to the tiering table provided with the baseline approval. 

 

2.0 PURPOSE OF INSPECTIONS 

Any changes to the WC activities from the date of the baseline inspection must be reported to, 

and, if applicable, approved by EPA, according to the tiering requirements set forth in the LANL 

Baseline Final Report cited above. 

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, Federal Register notice, 

EPA must perform a single baseline inspection of a TRU waste generator site’s WC program. 

The purpose of the baseline inspection is to approve the site’s WC program based on the 

demonstration that the program’s components, with applicable conditions and limitations, can 

adequately characterize TRU wastes and comply with the regulatory requirements imposed on 

TRU wastes destined for disposal at the WIPP. An EPA inspection team conducts an on-site 

inspection to verify that the site’s system of controls is technically adequate and properly 

implemented. 

Following EPA’s approval of WC processes evaluated during the baseline inspection, EPA is 

authorized to evaluate and approve, if necessary, changes to the site’s approved WC program by 

conducting additional inspections under the authority of 40 CFR 194.24(h). Under 

40 CFR 194.24, EPA has the authority to conduct continued compliance inspections to verify 

that the site continues to use only the approved WC processes to characterize the waste and 

remains in compliance with all the regulatory requirements. Based on the adequacies of the WC 
2 

processes demonstrated during the baseline inspection, including all conditions and limitations, 

EPA specified which subsequent WC program changes or modifications must undergo further 

EPA inspection or approval under 40 CFR 194.24. This was accomplished by assigning a tier 

level to each aspect of the LANL-CCP’s characterization program. T1 activities have more 

stringent reporting requirements and require that DOE notify EPA, and that EPA provide 

approval prior to implementation. The rule under which baseline inspections are conducted can 

be found in the Federal Register (Vol. 69, No. 136, pages 42571–42583 of July 16, 2004). 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of the EPA’s evaluation of a T1 change of the extension of the 

operational range of the LANL-CCP HENC 2 NDA system for assaying CH TRU wastes. This 

inspection report documents the basis for EPA’s approval decision and explains the results of the 

technical evaluation of the system’s range extension. 

EPA’s approval decision regarding the LANL-CCP HENC 2 has been conveyed to DOE 

separately by letter. As discussed previously, EPA will also announce the decision on its website 

at www.epa.gov/radiation/WIPP, in accordance with 40 CFR 194.8(b)(3). 

4.0 SCOPE OF REVIEW

The scope of this evaluation was the extension of the operational range of the LANL-CCP 

HENC No. 2 NDA system located at LANL, as described in this report. CBFO defined the 

requested changes for the HENC No. 2 as follows: 

1. The extension of the neutron calibration range from 16.28 grams of 240Pueff to 

34.96 grams of 240Pueff for predominantly 238Pu materials 

2. The extension of the gamma efficiency calibration range to an upper density limit of 

2.1 g/cc1

The HENC No. 2 was evaluated with respect to the ability of the extended operational ranges to 

identify and quantify the activities of the 10 WIPP-tracked radionuclides and their uncertainty, 

determine a technically appropriate lower limit of detection (LLD), and provide technical 

support for the changes to the system’s Total Measurement Uncertainty (TMU), as appropriate. 

The LANL HENC 2 was evaluated using a checklist that is included as Attachment A. This 

checklist is a subset of the NDA checklist that was used for the system’s initial certification. For 

the sake of convenience, some items that were not addressed during this T1 evaluation were left 

in the checklist. These are marked Not Applicable or NA in the checklist in Attachment A. 

Additionally, some aspects were determined to be unchanged from EPA-LANL-CCP-05.06-8 

and these are marked No Change or NC in the checklist in Attachment A. 

 

1

The calibration report uses the terms multiplying waste streams and non-multiplying waste streams. For simplicity, 

in this context the term multiplying means wastes that consist primarily of 239Pu. Non-multiplying means wastes that 

consist primarily of 238Pu. These terms are used interchangeably in the LANL-CCP calibration report and this 

report. 
3 

5.0 EVALUATION TEAM 

This evaluation consisted of a desktop review of documents provided by LANL-CCP that 

provided the technical and regulatory support for the range extensions. This review was 

supplemented by a teleconference on September 12, 2007, with EPA, CBFO, and LANL-CCP 

technical personnel, during which specific issues were discussed. Based on the conference call, 

LANL-CCP modified the report that presented the technical documentation for the range 

extension (calibration report), as well as three LANL-CCP HENC 2 operating procedures, as 

discussed in Section 6.0, below. All personnel involved in the September 12, 2007 

teleconference regarding the LANL HENC 2 evaluation are listed in Table 1, along with each 

person’s affiliation and function for this evaluation. 

Table 1. Personnel on September 12, 2007 Teleconference

Personnel Affiliation Inspection Function - Area of Expertise 

Edward Feltcorn U.S. EPA ORIA EPA Inspection Team Leader 

Patrick Kelly SC&A EPA Inspector, Technical Lead 

Sean Stanfield Canberra Industries LANL HENC Technical Support 

Joe Wachter Canberra Industries LANL HENC Technical Support 

Joe Harvill CCP Technical Support 

6.0 EVALUATION OF THE LANL-CCP HENC 2 

EPA evaluated the documentation that LANL-CCP had prepared to support the range extensions 

of the LANL HENC 2 system that will be used to characterize CH TRU wastes at LANL-CCP. 

The inspection consisted of a desktop evaluation of technical records and a teleconference with 

LANL-CCP NDA personnel on September 12, 2007. EPA had most recently inspected this 

system at LANL in April of 2007, and it had remained unchanged except for the range extension. 

Accordingly, EPA personnel or their contractors did not deem it necessary to conduct an on-site 

inspection of the HENC 2 at LANL to evaluate this change. As part of the review, EPA 

evaluated the following elements of the LANL HENC 2 process: 

• Capability of the measurement hardware and software to perform the required analyses 

• Technical adequacy of the NDA documents and procedures to support the extended range 

of operation 

• Knowledge and understanding of the personnel involved in the LANL-CCP NDA 

program 
4 

Attachment A identifies the objective evidence that was examined for EPA’s evaluation. The 

following documents were among those examined to assess the LANL-CCP HENC 2: 

• HENC#2-NDA-1002, Calibration Report for the HENC#2 Including Passive Neutron and 

Gamma Spectrometer Calibration and Confirmation, Revision 2, June 18, 2007 

• HENC#2-NDA-1002, Calibration Report for the HENC#2 Including Passive Neutron and 

Gamma Spectrometer Calibration and Confirmation, Revision 3, September 14, 2007 

provided electronically on September 20, 2007 following incorporation of EPA’s 

comments 

• LANL-HENC2-TMU-101, Total Measurement Uncertainty for the HENC #2 with 

Integral Gamma Spectrometer, Revision 0, April 10, 2006 

• Memorandum Pu-238 Mass Conversion, Los Alamos National Laboratories NWIS-TP2005-0156 Internal Memorandum, J. Veillux and J. Wachter 

• CCP-TP-063, CCP Operating the High-Efficiency Neutron Counter Using NDA2000, 

Revision 10, Draft C, Effective Date not indicated 

• CCP-TP-064, Calibrating the High-Efficiency Neutron Counter Using NDA 2000, 

Revision 5, Draft E, Effective date not indicated

• CCP-TP-103, CCP Data Reviewing, Validating and Reporting Procedure for the HighEfficiency Neutron Counter Using NDA 2000, Revision 7, November 16, 2006 

During the desktop evaluation, the EPA inspection team assessed several technical elements of 

the extended range of the HENC system that are detailed in Attachment A and are discussed 

below. 

(1) The operational history of the LANL HENC 2 was assessed. 

 

The LANL HENC 2 system is located in Trailer B498 on Pad 10 of Area G within Technical 

Area 54 (TA-54) at LANL. This system was initially inspected in 2006, and ultimately approved 

by EPA as described in the 2007 LANL Baseline Inspection Report cited earlier. The 2007 

approval was the system’s first approval for performing WIPP assays in its current configuration. 

However, this system was initially designated the LANL HENC 1 as a fixed-base system 

operated at the Radioassay and Nondestructive Testing (RANT) Facility at TA-54-38 until 

October of 2003, under LANL’s WC program prior to the implementation of the CCP. It was 

removed from service in early 2004, and was modified by adding a gamma detection system and 

NDA 2000 software, and was converted into a mobile unit. Following these modifications, the 

system was designated the LANL HENC 2 and was operated under the CCP WC. This system 

had been certified to assay CH TRU wastes in 55-gallon (208-liter) drums with or without 

polyethylene liners at LANL, and the original calibration was applicable to S3000 homogenous 

solid wastes and S5000 debris wastes. At the time of EPA’s baseline approval of the HENC 2, 

the passive neutron calibration range was stated as the LLD to16.28g 240PuEff, and the density 

range for the gamma efficiency calibration was stated as 0.018 to 1.64 g/cc. There are no 

concerns regarding the operational history of the LANL HENC 2 system. 
5 

(2) The design, calibration, calibration confirmation, operation, and performance testing of 

the LANL HENC 2 system were assessed. 

The LANL HENC 2 system incorporates two measurement modalities—a passive neutron 

counter and an integral gamma-ray spectrometer. The passive neutron counter uses multiple 3He 

proportional counters, along with a multiplicity shift register and an external 252Cf source for the 

Add-a-Source (AaS) matrix correction function, to determine the spontaneously fissioning mass 

content of waste containers, referred to as the 240PuEffective (

240PuEff). The 240PuEff is defined as the 

amount of 240Pu that would produce the observed true coincidence rate, after correcting for the 

neutron moderation properties of the waste matrix. The quantities of individual radionuclides are 

related to the 240PuEff by applying the ratios of other TRU or target radionuclides, including all 

spontaneously fissioning radionuclides (i.e., 235U). Isotopic ratios are determined primarily by 

Multi Group Analysis (MGA) of the gamma-ray spectrum obtained with the system’s integral 

gamma-ray spectrometer, as discussed below. Isotopic ratios are also based on Acceptable 

Knowledge, when appropriate. Regarding the method of determining a sample’s isotopic ratio 

by measurement, the HENC 2 calibration report states that 241Am and Pu isotopics are 

“determined by MGA or FRAM2

 software,” although the use of FRAM had not yet been 

implemented, according to LANL-CCP personnel. EPA evaluated the technical aspects of 

FRAM during several previous inspections, specifically EPA Inspection Nos. LANL-CCP04.05-8 in April 2005, and LANL-CCP-05.06-8 in 2006. If FRAM were used for isotopic 

determinations, the system’s data acquisition operation would be unchanged. The 

LANL HENC 2 Expert Analyst (EA) would obtain the gamma spectrum in the routine manner 

described below, followed by a separate analysis of the spectrum on a separate computer using 

FRAM. The integral gamma-ray spectrometer is an HPGe detector used to acquire the gammaray spectrum to be analyzed by MGA (or FRAM) and to provide direct quantification of a 

number of radionuclides, including 238Pu, 239Pu, 241Pu, 241Am, 233U, 235U, 238U, 137Cs, and 237Np. 

The gamma spectrometer uses a multicurve efficiency calibration based on the waste density to 

correct for photon attenuation inside the drum. Calibration of the HENC 2 is controlled by 

CCP-TP-064, Calibrating the High-Efficiency Neutron Counter Using NDA 2000. 

Based on the range extension, the HENC 2 has three operational modes as follows: 

• Passive neutron mode with an operational range of the system’s LLD to 16.28 g 240PuEff

for multiplying waste streams, i.e., wastes that are predominantly 239Pu, with gammabased isotopics (original passive neutron calibration) 

• Passive neutron mode with an operational range of the system’s LLD to 35.0 g 240PuEff

for non-multiplying waste streams, i.e., wastes that are predominantly 238Pu, with 

gamma-based isotopics (extension of original passive neutron calibration) 

• Gamma mode with an operational mode of 0.018 to 2.1 g/cc in terms of density and an 

efficiency calibration range of 122 to 1,212 keV (extension of original gamma efficiency 

calibration) 

 

2

FRAM is an initialization for Fixed-Energy Response Function Analysis with Multiple Efficiencies, a commonly 

used software analysis routine for the purpose of determining isotopic ratios similar to MGA, also called PC FRAM. 
6 

Passive Neutron Calibration

For purposes of clarification, there is a single calibration for this system, i.e., one set of 

empirically derived coefficients that relate the system’s observed response to a known 

disintegration rate for specific radionuclides over a range of conditions. The calibration 

extension that is the subject of this T1 evaluation consists of incorporating additional passive 

neutron points to the original calibration curve and generating a new curve with a higher upper 

limit of 35.0 g 240PuEff for wastes that are predominantly 238Pu (non-multiplying wastes). The 

initial calibration for the HENC 2 that defined the operational range as the system’s LLD to 

16.28 g 240PuEff still applies to wastes that are predominantly 239Pu (multiplying wastes). 

The sources used for the passive neutron calibration were all high purity WG or Heat Source 

(HS) PuO2 in diatomaceous earth that were double or triple encapsulated in welded stainless steel 

cylinders. All neutron sources were Working Reference Material (WRM) that had been 

manufactured by the LANL CMR Analytical Chemistry Group (now called the Analytical 

Chemistry Group of Los Alamos National Laboratory) and all sources are traceable to the 

national standards base. A copy of the certificate for each source was included in the calibration 

report. The sources ranged in mass from 0.47 g to 46.53 g for 239Pu and from 0.24 g to 2.14 g for 

238Pu. By combining sources of varying Pu content in the PDP3

-type empty matrix drum, 

LANL-CCP obtained data for 239Pu that spanned a range of 0.5 g to 237.14 g of total Pu, and a 

range of 0.24 g to 10.19g for 238Pu4

. 

Gamma Calibration

All initial gamma efficiency calibrations were performed using mixed gamma line sources that 

feature prominent gamma emission lines of 152Eu and 241Am, as described in HENC#2-NDA1002, Table 4, Revision 3. In response to an EPA comment, this table was modified to indicate 

which specific photon lines were used in the efficiency calibration. The gamma energy, peak 

shape, and reference peak calibrations were performed in accordance with CCP-TP-064 and 

were performed with tin/copper filters mounted on the detector’s face. The energy calibration 

was set at approximately 0.75 keV per channel and the pulser rate was approximately 100 counts 

per second (cps) at 1150 keV. Figure 2 in Revision 3 of HENC#2-NDA-1002 is the gamma 

efficiency curve that includes the higher density assays that provide the technical justification for 

the requested range extension to 2.1 g/cc. The gamma operating range for this system is 

presented as “from the system’s LLD to 217 grams of weapons grade Pu,” because this is not a 

mass calibration in the strict sense, i.e., as presented in ASTM C 1133, there is no true upper 

mass limit for the gamma calibration of the LANL HENC 2. The calibration specifies a range in 

terms of photon energy, as discussed above, and all assays within that energy range that meet 

performance criteria with respect to transmission, dead-time, peak shape, and resolution should 

be acceptable, regardless of the sample’s nuclear material content. In practice, other 

programmatic limits take precedent and presenting the operational range in terms of mass of 

238Pu and 239Pu is a convention that actually reflects the range of standards that were assayed as 

part of the system’s performance testing. Regarding sample matrix, the efficiency calibration 

was performed to extend the range of densities from 0.018 to 2.1 g/cc from the previously 

established upper limit of 1.64 g/cc. This was accomplished by adding a concrete matrix drum 

(1.94 g/cc) to the previously assayed plastic foam (0.018 g/cc), Homasote (0.49 g/cc), particle 

 

3

 PDP is the CBFO sponsored NDA Performance Demonstration Program. 

4

 An equal mass of 238Pu and 239Pu will have a different 240PuEFF value. 
7 

board (0.69 g/cc), and sand (1.64 g/cc) matrices. Data from all assays were combined to produce 

the efficiency calibration plot shown in HENC#2-NDA-1002, Revision 3, Figure 2, as discussed 

above. Appendix 4 of HENC#2-NDA-1002 contains plots of the efficiency calibration for each 

of the five matrices. Revision 3 of HENC#2-NDA-1002 contains several modifications that 

were made in response to discussions with EPA personnel during the September 12, 2007 

teleconference. There are no concerns regarding the design, passive neutron and gamma 

efficiency calibrations, operation, and performance testing of the LANL HENC 2. 

(3) The LANL HENC 2’s ability to quantify the WIPP-tracked radionuclides and assign 

isotopic distributions pertinent to CH TRU wastes was assessed. 

Instructions for operation of the LANL HENC 2 were contained in CP-TP-063, CCP Operating 

the High Efficiency Neutron Counter Using NDA2000. This procedure delineates the 

responsibilities of the NDA Operator, Lead Operator (LO), and Expert Analyst (EA), and 

provides direction for system start-up, waste drum assay, and system shutdown. The 

combination of isotopic information from MGA (or FRAM) and the 240PuEFF determination or 

direct gamma measurement provides for the quantification of 238Pu, 239Pu, 240Pu, 241Am, 237Np,

233U, 235U, 238U, and 137Cs. The 242Pu content is determined using the correlation technique of 

Gunnik that has been evaluated previously on several Canberra NDA systems at other TRU WC 

facilities. Each waste container’s 234U content is quantified by application of scaling factors that 

are based on observed values for 235U and 238U. The determination of 90Sr is performed by 

application of a scaling factor based on the sample’s observed 137Cs content. AK-based isotopics 

may be used for debris waste stream, when such assignments are appropriately supported. 

However, the use of AK-based isotopics pertains only to debris wastes, because there are no 

established isotopics for homogeneous solids at this time. There are no concerns regarding the 

ability of the LANL HENC 2 to quantify the 10 WIPP-tracked radionuclides or assign isotopic 

distributions pertinent to LANL solid (S3000) and debris (S5000) CH TRU wastes by 

measurement. 

(4) The calibration confirmation of the LANL HENC 2 was assessed. 

The sources used for the passive neutron calibration confirmation were the same type as those 

used for the initial calibration, i.e., double or triple encapsulated WG or HS PuO2 in 

diatomaceous earth, but were physically different sources from those that were used for the 

system’s calibration. These sources were combined to provide a range of 0.562 g to 203.675 g of 

239Pu and from 0.5 g to 13.7 g of 238Pu. Each configuration was assayed six times in the 

PDP-type empty drum, and the results of all calibration confirmation assays were evaluated 

relative to the acceptance criteria in DOE-WIPP-02-3122 for precision and accuracy. The 239Pu 

and 238Pu drums passed the percent recovery acceptance criterion for accuracy (±30%) and the 

percent relative standard deviation criterion for precision (14% based on six replicates). The 

results of all calibration confirmations were acceptable. Confirmation of the gamma efficiency 

calibration was performed using the concrete matrix drum (1.94 g/cc) and a set of gammaemitting line sources (24.6 μCi) that were different from the sources used for the initial 

calibration. Six replicate measurements were made and the results of all calibration confirmation 

assays were evaluated relative to the acceptance criteria in DOE-WIPP-02-3122 for accuracy and 

precision. The concrete matrix drum passed the percent recovery acceptance criterion for 
8 

accuracy (±30%) and the percent relative standard deviation criterion for precision (14% based 

on six replicates). The results of the gamma efficiency calibration confirmation were acceptable. 

There are no concerns regarding the passive neutron and gamma efficiency calibration 

confirmations of the LANL HENC 2. 

(5) The TMU of assays performed on the HENC 2 had been determined and documented. 

The determination of the TMU for the LANL HENC 2 is documented in LANL-HENC2-TMU101. LANL-CCP NDA personnel stated that the calibration extension would not affect the 

system’s TMU determination. Upon review of the TMU report, EPA concurs with LANL-CCP 

regarding the acceptability of the determination of TMU for the LANL HENC 2 at this time. 

(6) The Lower Limit of Detection (LLD) of the LANL HENC 2 has been determined and 

documented. 

The LLD was defined in CCP-PO-002, “CCP Transuranic Waste Certification Plan,” as: 

That level of radioactivity which, if present, yields a measured value greater than 

the critical level with a 95% probability, where the critical level is defined as that 

value which measurements of the background will exceed with 5% probability. 

The LANL HENC 2 will be used to discriminate TRU and non-TRU wastes. This requires that 

the system’s LLD be less than 100 nCi of TRU alpha activity per gram (nCi/g) of waste and that 

it be documented and technically appropriate. Section 6 of HENC#2-NDA-1002 adequately 

documents typical LLD values for both passive neutron and gamma. Reporting thresholds (LLD 

analogs) are provided for 242Pu, 234U and 90Sr, and these are based on known relationships 

between measured radionuclides and other target radionuclides that cannot be practically 

measured in this context. All operational modes demonstrate LLD values that are below 

100 nCi/g based on the assumptions provided in Section 6 of HENC#2-NDA-1002. As stated 

under (3), above, when these relationships require the use of AK-based isotopics, they pertain 

only to debris wastes because there are no established isotopics for homogeneous solids at this 

time. There are no technical concerns regarding the technical derivation and application of 

LLDs and reporting thresholds (LLD analogs) relative to the LANL HENC 2. 

Approval

The NDA system evaluated during this Tier 1 evaluation consists of the LANL HENC 2 that is 

used to provide quantitative values for the 10 WIPP-tracked radionuclides and their uncertainties 

in 55-gallon (208-liter) drums of S3000 and S5000 CH TRU wastes, consistent with the 

limitations described in this report. These values are based on passive neutron 240PuEFF and 

gamma isotopic distribution values, as described the HENC 2’s operating procedures and the 

system’s calibration report. The LANL HENC 2 is approved to assay using the extended range 

for passive neutron and gamma efficiency assays. 
9 

Findings 

The EPA Inspection Team did not identify any findings relative to the range extension of the 

LANL HENC 2 during this T1 change evaluation. 

Concerns 

The EPA Inspection Team did not identify any concerns relative to the range extension of the 

LANL HENC 2 during this T1 change evaluation. 

7.0 SUMMARY OF RESULTS 

During this evaluation, the EPA did not identify any concerns or findings related to the range 

extension of the LANL HENC 2 NDA system. 

7.1 Conclusions 

During this T1 change evaluation, EPA examined the range extension of the LANL HENC 2 

NDA system. Based on the results of this evaluation, EPA is approving the passive neutron and 

gamma efficiency range extension of the LANL HENC 2 NDA system for assaying CH TRU 

wastes in the configurations described above. 
10 

Attachment A 

LANL HENC 2 T1 Evaluation Checklist 
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: LANL–CCP T1 Change 

Inspection Date: September 12, 2007

NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)

A-1 

Required Technical Elements Y/N Location Verification of Activity Y/N 

System Description Identify the NDA system by name, location and number, as appropriate. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The system is the LANL-HENC #2, 

previously known as the MCS HENC, 

that is housed in Building No.54506 (trailer) located Technical Area 54 (TA 54), Area G, Pad 10 at LANL. The system has not been moved since EPA inspection EPA-LANL-CCP-05.06-8. 

Y V

HAd

Describe the system’s operational history including deployment at other DOE sites. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The LANL-HENC #2 was initially deployed at LLNL and was first evaluated during EPA-LLNL-CCP04.08.8, August 2004, and most recently during EPA-LANL-CCP05.06-8. 

Y E

RE2M0

For systems that have been deployed at multiple DOE sites, document pertinent aspects of each system’s development, e.g., installation of new or different detectors, software, or other relevant features. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The LANL-HENC #2 had been modified prior to EPA last evaluation/approval. No physical modifications associated with this T1 change. 

Y H

RIGa

System Performance Identify the period of performance relevant to this T1 evaluation if this NDA system has 

prior EPA approval(s). 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

This evaluation was limited to the T1change described previously. 

NA 

Identify the type and number of waste containers this system assayed during the 

period of performance. Of these, indicate 

how many Batch Data Reports (BDRs) were assembled and how many of the assembled BDRs have been promoted through Project Level Review. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

BDRs were not reviewed during this T1 evaluation. The BDRs that were evaluated during EPA-LANL-CCP05.06-8 are listed in subsequent entries of this checklist. 

NA 
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: LANL–CCP T1 Change 

Inspection Date: September 12, 2007

NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)

A-2 

Required Technical Elements Y/N Location Verification of Activity Y/N 

General Reporting Requirements Assay systems must report quantitative values and uncertainties for 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 233U, 234U, 238U, 90Sr, and 137Cs. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Quantitative values and uncertainties for 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 

233U, 234U, 238U, 90Sr, and 137Cs are 

reported. 

NC B

LL

Each container characterized and intended for disposal at WIPP must contain TRU waste. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Containers assayed for WIPP are TRU waste, i.e., they contain >100 nCi/g of transuranic alpha activity. 

NC B

LL

NDA instruments and procedures are 

appropriate for the waste streams being assayed. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The LANL HENC #2 and supporting 

procedures are appropriate for the 

wastes currently being assayed. 

NC B

LL

NDA instruments and procedures result in 

unbiased values for the cumulative activity of the WIPP radionuclide inventory. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The radionuclide values produced by the LANL 

HENC #2 are appropriate for supporting the cumulative activity of 

the WIPP radionuclide inventory. 

NC B

LL

Some radionuclides are quantified by the application of scaling factors or correlation techniques. Identify all radionuclides that are quantified in this manner. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

234U, 242Pu and 90Sr are derived by the 

application of scaling and/or correlation factors. 

NC C

A

Assess the technical adequacy of the calculations involving the application of scaling factors and/or correlation techniques. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The scaling and/or correlation factors cited in the preceding checklist item are technically adequate and appropriately documented. 

NC C

A

Identify the procedures that govern this function and where the results of these calculations are documented. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The procedure that governs the application of scaling factors is identified and the results of these calculations are documented. 

NC C

AL
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: LANL–CCP T1 Change 

Inspection Date: September 12, 2007

NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)

A-3 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Acceptable Knowledge (AK) If isotopic ratios based on AK are used, the values are qualified by confirmatory testing. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Isotopic ratios used in quantifying radionuclides are qualified by confirmatory testing when AK is used 

NC C

A

Do NDA personnel use AK-derived isotopic values to calculate radionuclide values? If so, is this function performed according to a formal procedure? Assess the technical adequacy of this process(s). 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

NDA personnel using AK derived 

isotopic values to calculate radionuclide values do so according to a formal procedure, the technical adequacy of which is adequate. 

NC C

A

Identify the procedure and where the results of these calculations are documented. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The procedure for AK calculations is identified and results are documented in the two BDRs that were evaluated during EPA-LANL-CCP-05.06-8. 

NC C

ABLL

Isotopic Determination Identify the radionuclides that are measured directly and the type of radiation that is measured (gamma, Active or Passive 

Neutron). 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

240PuEFF is directly measured based on 

passive neutron emission. Other 

radionuclides (238Pu, 239, Pu242, Am241, 

etc.) are derived from 240PuEFF based on 

isotopics determined by gamma-based MGA or direct gamma determination. 

Y H

RIGa

Identify the method(s) used to derive the isotopic contribution for the unmeasured radionuclides, e.g., MGA, PC FRAM, or other technique. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

MGA is used to derive the isotopic contribution for unmeasured radionuclides. All containers (100%) are subject to routine gamma assay although useable data may not be available for each container. FRAM may be used for isotopics in the future. AK-based isotopic values are used in the absence of useable MGA (or FRAM) values when data to support AK are documented in AK/NDA 

Y H

RIGa
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: LANL–CCP T1 Change 

Inspection Date: September 12, 2007

NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)

A-4 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Memoranda. There are no approved AK isotopic values for S3000 solids 
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: LANL–CCP T1 Change 

Inspection Date: September 12, 2007

NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)

A-5 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Lower Level of Detection (LLD) The LLD for each NDA system must be determined. For multi-modal systems this may require a separate determination for each mode. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The LLD for the LANL HENC #2 has 

been determined for the passive 

neutron and gamma mode. 

Y H

RPSCS

LLD determinations must account for sitespecific environmental backgrounds and container-specific interferences. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Site-specific environmental 

backgrounds and container specific 

interferences are accounted for in LLD determinations. 

Y H

RPSCS

NDA instruments performing TRU/NonTRU waste discrimination measurements are 

required to have an LLD no greater than 100 nCi/g. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Both the passive neutron and gamma modes have LLDs less than 100 nCi/g for debris and solid matrices 

Y H

RPSCS

The technical basis and derivation for LLDs must be technically adequate and appropriately documented. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The technical bases and derivation for the passive neutron and gamma modes are technically adequate and appropriately documented. 

Y H

RPSCS

For radionuclides that are not determined by measurement, an LLD analog must be used when it is technically feasible. Identify all instances when this occurs and the form of the documentation of these activities. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

A reporting threshold (LLD analog) has 

been determined for 90Sr, 234U and 

242Pu. These are technically adequate 

and appropriately documented. 

Y H

RPSCS
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: LANL–CCP T1 Change 

Inspection Date: September 12, 2007

NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)

A-6 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Identify any/all instances where an LLD value for a non-measured radionuclide is not 

provided based on a lack of technical 

feasibility. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

There are no instances where an LLD value for a non-measured radionuclide 

is not provided basis on a lack of technical feasibility are documented. 

Y H

RPSCS

Are LLD values container/assay event specific or are typical LLD values applied to a class or type of wastes, i.e., those with similar attributes? If LLD values are not container/assay event specific, identify the attributes or characteristics whereby waste containers are grouped. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The LLD values listed in the calibration report are typical values that demonstrate the LANL HENC #2’s sensitivity with the understanding that these values listed may not be obtained for every assay event. 

Y H

RPSCS

Total Measurement Uncertainty (TMU) The method used to calculate the TMU for all required quantities must be documented and technically justified. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The method used to calculate the TMU for the LANL HENC #2 is documented and technically justified. 

NC T

fI

DR

TMU determination accounts for all sources of uncertainty, specifically: background; calibration; isotopic determination; matrix heterogeneity; difference between waste and matrix specific calibration; source position effects; end effects; self shielding; and, neutron multiplication.

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The LANL HENC #2 RDSs evaluated during EPA-LANL-CCP-05.06-8 included all required elements. 

NC T

fI

DR

Methods to determine TMU must be documented, reviewed, and approved by CBFO for each NDA instrument. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

CBFO Technical Specialist D. Stuenkel confirmed that the TMU report had 

been reviewed and approved during 

EPA-LANL-CCP-05.06-8. 

NC O

ad
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: LANL–CCP T1 Change 

Inspection Date: September 12, 2007

NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)

A-7 

Required Technical Elements Y/N Location Verification of Activity Y/N 

System Calibration Each NDA instrument must be calibrated 

before its initial use. Determine the date of 

the system’s calibration of record and where this is documented. For multi-modal systems, specify the calibration for each mode. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The LANL HENC #2 was originally calibrated in 2004. There have been several revisions to the calibration report and the system’s current calibration is documented in Revision 3. The passive neutron and gamma calibrations are technically adequate. 

Y H

RIGa

The range of applicability of the system’s calibration(s) must be specified in site 

procedures or other formal documentation. 

Identify the manner in which the range is expressed, i.e., curies or Pu/SNM mass for activity and salient physical characteristics for matrix. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The operating range is the system LLD to 16.278 g 240PuEFF for passive neutron 

assays of predominantly 239Pu-bearing 

wastes and LLD to 35.0 g 240PuEFF for 

assays of predominantly 238Pu-bearing 

wastes; LLD to 217 g Pu total for gamma, but gamma range is best expressed in an energy range of 122 to 1212 keV limited by dead time. Matrix density range for gamma is 0.018 to 2.1 g/cc for S3000 and S5000 wastes. 

Y H

RIGa

Any matrix/source surrogate waste combinations must be representative of the activity ranges and relevant waste matrix characteristics currently in use or planned for use by the system. The system must be calibrated to 100% recovery. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Matrix/source waste combinations are representative of routine samples currently measured by the LANL HENC #2. The system is calibrated to 100% recovery. 

Y H

RIGa

The use of consensus standards for calibration is required, when such standards exist. If consensus standards do not exist, the calibration technique must be approved by CBFO. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Consensus standards have been used for calibrating the LANL HENC #2, see checklist item below. 

Y H

RIGa
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: LANL–CCP T1 Change 

Inspection Date: September 12, 2007

NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)

A-8 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Identify the specific consensus standards that were used for the system calibration or, in their absence, the alternate technique. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The specific consensus standards used for calibration are: ASTM-C1030-95, ASTM C-1133-96, ASTM C-1207 and ASTM C-1500. 

Y H

RIGa

Primary standards must be obtained from suppliers maintaining a nationally accredited measurement program. Identify the program. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Primary gamma standards have been obtained a commercial supplier; Pu sources for passive neutron calibration were obtained from R. Marshall’s group in the LANL CMR. Both organizations maintain a nationally accredited measurement program. 

Y H

RIGa

List the standards used for calibration and verify the pedigree of each standard. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The calibration standards are listed and the pedigree of each has been verified. 

Y A

H

N

C

Calibration Verification & Confirmation Verification of an NDA instrument’s calibration must be performed after any of the following: major system repairs and/or modifications, replacement of the system’s components, significant changes to the system’s software, or system relocation. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The LANL HENC #2 has been recalibrated several times since the system’s initial calibration at LANL in 2004. Previous recalibrations have 

been confirmed and documented 

appropriately as discussed above in this checklist. The most recent calibration is documented appropriately. 

Y H

RIGa

Recalibration of the system must occur if the calibration verification demonstrates that the 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

This T1 change was an extension of the 

previous calibration 

NA 
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: LANL–CCP T1 Change 

Inspection Date: September 12, 2007

NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)

A-9 

Required Technical Elements Y/N Location Verification of Activity Y/N 

system’s response has significantly changed. The system calibration must be confirmed by 

performing replicate measurements of a noninterfering matrix. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The LANL HENC #2’s calibration has 

been confirmed and documented 

appropriately following each calibration. 

Y H

RIGa

Replicate measurements must be performed with containers of the same nominal size and according to the same procedures used for actual waste assays. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Replicate measurements have been 

performed with 55-gallon (208-liter) 

drums and the operating and data review procedures that are used for routine waste assays. 

Y H

RIGa

Replicate measurements must be performed using nationally recognized standards or standards derived from nationally recognized standards that span the range of use of the instrument with respect to disintegration rate and/or matrix effects. Identify all standards that were used and indicate their application (verification or confirmation). 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Replicate measurements have been 

performed using nationally recognized 

standards or standards derived from nationally recognized standards that span the range of use of the instrument with respect to disintegration rate and/or matrix effects. All standards that were used have been identified and their application documented. 

Y H

RIGa

Identify the nationally accredited measurement program. List the standards used for verification/confirmation and verify the pedigree of each standard. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The standards used for verification and/or confirmation and their pedigree are listed. 

Y A

H

N

C
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: LANL–CCP T1 Change 

Inspection Date: September 12, 2007

NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)

A-10 

Required Technical Elements Y/N Location Verification of Activity Y/N 

The standards used for calibration confirmation must be different from the sources used for the system’s calibration of record. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The standards used for calibration confirmation are different from those used for the system’s calibration of record. 

Y A

H

N

C

Requirements for accuracy, expressed as %R, and precision, expressed as %RSD, must be met as specified in DOE/WIPP-02-3122, Appendix A, Table A-3.2 for precision and ∀30% for accuracy. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Requirements for accuracy and 

precision have been met as specified in 

DOE/WIPP-02-3122, Appendix A, Table A-3.2 for precision based on the number of replicates assayed and ∀30% for accuracy. 

Y H

RIGa
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: LANL–CCP T1 Change 

Inspection Date: September 12, 2007

NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)

A-11 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Quality Control All radioassay and data validation must be 

performed by appropriately trained and 

qualified personnel. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

All radioassay and data validation has 

been performed by appropriately 

trained and qualified personnel 

NC C

IAE

Identify the name, title, and function of all 

personnel performing NDA data validation. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The name, title and function of all 

NDA personnel performing data 

validation for the LANL HENC#2 are documented. 

NC C

IAE

The site must participate in relevant measurement comparison programs sponsored or approved by CBFO, including the NDA PDP. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The site has participated successfully in Cycle 13A of the CBFO sponsored 

NDA PDP. The conditional approval 

of the LANL HENC #2 effective in July 2006 was made permanent upon successful implementation of the LANL Corrective Action Plan that addressed the Cycle 13A PDP failures for the glass matrix container with HS Pu. 

NC J

M

RN

Jfuo

Background and Performance Checks Assay system background measurements must be taken daily, unless otherwise approved by CBFO. Contributions to 

backgrounds from nearby radiation sources 

must be carefully controlled, or more frequent backgrounds must be measured. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Daily background are taken and recorded. Contributions to backgrounds from high activity containers that are stored or staged in proximity to the LANL HENC #2 Trailer do affect the 

background but NDA personnel control 

this. 

NC H

RIGa
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: LANL–CCP T1 Change 

Inspection Date: September 12, 2007

NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)

A-12 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Assess how often background radiation was 

problematic to the extent that measurement personnel had to make adjustments. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Background control charts are used to document the system’s performance over time. 

NC H

RIGa

Identify the criteria used to evaluate instrument backgrounds and assess the nature, i.e., statistical or administrative, and technical adequacy of this criterion 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Backgrounds are evaluated against 

predetermined upper and lower boundaries and are non-statistical in 

nature. Initial control limits are based on the system’s first month of operations and each day’s measurements are automatically compared to the established limits 

Y H

RIGa

Identify the number of data points required to derive the initial control limit. At what interval(s) will new limits be calculated? 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Initial control limits for all performance measurements were based on six measurements. Limits will be recalculated as more data are acquired or the system is recalibrated. 

Y H

RIGa

System performance checks must be 

performed at least once per operational day. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Performance checks have been 

performed at least once per operational 

day and all checks have been documented. 

Y H

RIGa

System performance checks must include, as applicable, efficiency, matrix correction checks, and systems peak position and resolution for spectrometric systems. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Performance checks include: 121 keV 

peak centroid and FWHM, 964 peak 

centroid and FWHM and weighed average of 152Eu activity. 

Y H

RIGa
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: LANL–CCP T1 Change 

Inspection Date: September 12, 2007

NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)

A-13 

Required Technical Elements Y/N Location Verification of Activity Y/N 

At a minimum of once per operational week an interfering matrix must be assayed to assess the long-term stability of the NDA instrument and its matrix corrections and how this performance is documented. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Two matrix drums are available, a debris and homogeneous solid. They are used with a variety of PDP-type Pu sources that span a range of activity. The acceptance criteria for the Weekly Interfering Matrix checks were not assessed during inspection EPALANL-CCP-05.06-8. 

Y H

RIGa

Interfering surrogate waste matrices must be constructed in a way that the salient matrix characteristics do not change over time. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Interfering surrogate waste matrices have been constructed such that the salient matrix characteristics do not change over time. 

NC V

dCe

The radionuclide sources used for 

performance checks must be long-lived and 

of activity to provide statistically sufficient results over a short measurement time. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The 241Am, 152Eu and Pu sources used 

for performance checks are of sufficient activity to provide statistically sufficient results over a short measurement time. 

NC I

N

LddC

Radioactive sources are decay corrected as a function of their physical half-life, as appropriate, specifically133Ba, 252Cf, 137Cs, 75Se, and 109Cd. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The 241Am and 152Eu sources are decay 

corrected as a function of their physical half life. Decay correction is not applicable to 239Pu sources. 

NC I

N

LdE

Performance checks must be quantitative and 

based on 2 and 3 sigma limits. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Limits are based on Student t-test for 

95% (warning limit) and 99% (control limit) confidence intervals. 

NC C

H

N

CHL
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: LANL–CCP T1 Change 

Inspection Date: September 12, 2007

NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)

A-14 

Required Technical Elements Y/N Location Verification of Activity Y/N 

L

Identify how many data points are used for the initial evaluation and at what interval(s) new limits are calculated. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

NC C

H

N

C
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: LANL–CCP T1 Change 

Inspection Date: September 12, 2007

NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)

A-15 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Data Management All radioassay data must be reviewed and approved by qualified personnel before 

being reported to WWIS. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Individual Radioassay Data Sheets (RDS) were reviewed during inspection EPA-LANL-CCP-05.06-8. All were acceptable. 

NC LA

duLA1L

Identify the name, title, and function of the individual(s) performing technical review and approval of NDA BRDs. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The name, title and function of the individual(s) performing technical review and approval of NDA BRDs are documented. 

NC LA

duLA1L

Radioassay BDRs must consist of the following elements: 

• Testing facility name, testing batch 

number, container numbers, and signature of the Site Project Officer (SPO) or designee(s) 

• Table of Contents 

• Background and performance check 

data or control charts for the relevant time period. 

• Data validation per the QAPD and site 

procedures 

• Separate testing report sheets for each 

container. 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The LANL HENC #2 BRDs reviewed during inspection EPALANL-CCP-05.06-8.his inspection contained all required elements. 

NC LA

duLA1L

Radioassay data sheets (RDS) must include: 

• Title “Radioassay Data Sheet” 

• Method/procedure used 

• Date of radioassay 

• Activities and associated TMU for 

individual radionuclides 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

The LANL HENC #2 RDSs reviewed during inspection EPALANL-CCP-05.06-8 contained all required elements. 

NC R

EPfoH

LALA
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: LANL–CCP T1 Change 

Inspection Date: September 12, 2007

NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)

A-16 

Required Technical Elements Y/N Location Verification of Activity Y/N 

• TRU alpha concentration and its 

associated TMU 

• Operator signature 

• Reviewer signature 

1L

The following nonpermanent records must 

be maintained at the radioassay-testing 

facility or forwarded to the site project office: 

• Testing batch reports 

• All raw data, including instrument 

readouts, calculation records, and radioassay QC results 

• All applicable instrument calibration 

reports 

Y CCP-PO-002, CCP Transuranic 

Waste Certification Plan 

Nonpermanent records are 

maintained in the LANL HENC #2 trailer in TA-54, Area G, and all raw data are included on two compact discs that are submitted with each BDR to the CCP office. 

NC In

op

N

in05