# 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 CO UNTER 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. Enviro nmental 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 A lamos National Laboratory (LANL-CCP).

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

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

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

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

Counter No. 1 (HENC 1); and the High Efficiency Neut ron 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 ran ge of the HENC 2 NDA system, an action

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

evaluation of the extension of the HENC 2’s operati onal 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 th e range extension for the HENC 2 for

assaying contact-handled (CH) transuranic (TRU) was tes 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 thro ugh 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 t he baseline inspection must be reported to,

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

Baseline Final Report cited above.

Under the changes to 40 CFR 194.8 promulgated in th e 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 approv e the site’s WC program based on the

demonstration that the program’s components, with a pplicable 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 E PA inspection team conducts an on-site

inspection to verify that the site’s system of cont rols 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, c hanges to the site’s approved WC program by

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

40 CFR 194.24, EPA has the authority to conduct con tinued 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 requi rements. Based on the adequacies of the WC

# 2

processes demonstrated during the baseline inspecti on, including all conditions and limitations,

EPA specified which subsequent WC program changes o r modifications must undergo further

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

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

stringent reporting requirements and require that D OE notify EPA, and that EPA provide

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

be found in the Federal Register (Vol. 69, No. 136, pages 42571–42583 of July 16, 20 04).

3.0 PURPOSE OF THIS REPORT

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

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

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

technical evaluation of the system’s range extensio n.

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 t he 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 240 

# Pu eff 

# to

34.96 grams of 240 

# Pu eff 

# for predominantly 238 

# Pu materials

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

2.1 g/cc 1



# The HENC No. 2 was evaluated with respect to the abil ity 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 Measu rement 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 a ddressed 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 un changed 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 239 

# Pu. Non-multiplying means wastes that

consist primarily of 238 

# Pu. These terms are used interchangeably in the LA NL-CCP calibration report and this

report.

# 3

5.0 EVALUATION TEAM

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

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

supplemented by a teleconference on September 12, 2 007, with EPA, CBFO, and LANL-CCP

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

LANL-CCP modified the report that presented the tec hnical documentation for the range

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

discussed in Section 6.0, below. All personnel inv olved 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 evaluati on.

Table 1. Personnel on September 12, 2007 Teleconfe rence

Personnel Affiliation Inspection Function - Area of Expertise

Edward Feltcorn U.S. EPA ORIA EPA Inspection Team L eader

Patrick Kelly SC&A EPA Inspector, Technical Lead

Sean Stanfield Canberra Industries LANL HENC Techni cal 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 p repared to support the range extensions

of the LANL HENC 2 system that will be used to chara cterize 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 h ad most recently inspected this

system at LANL in April of 2007, and it had remaine d 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 ch ange. 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 procedur es to support the extended range

of operation

• Knowledge and understanding of the personnel involv ed 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 as sess the LANL-CCP HENC 2:

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

Gamma Spectrometer Calibration and Confirmation, Re vision 2, June 18, 2007

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

Gamma Spectrometer Calibration and Confirmation, Re vision 3, September 14, 2007

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

comments

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

Integral Gamma Spectrometer, Revision 0, April 10, 2006

• Memorandum Pu-238 Mass Conversion, Los Alamos Nation al Laboratories NWIS-TP2005-0156 Internal Memorandum, J. Veillux and J. Wa chter

• CCP-TP-063, CCP Operating the High-Efficiency Neutr on 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 Repo rting Procedure for the HighEfficiency Neutron Counter Using NDA 2000, Revision 7 , November 16, 2006

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

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

below.

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

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 Inspe ction Report cited earlier. The 2007

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

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

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

October of 2003, under LANL’s WC program prior to t he implementation of the CCP. It was

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

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

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

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

polyethylene liners at LANL, and the original calib ration 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 240 

# Pu Eff 

# , and the density

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

concerns regarding the operational history of the L ANL 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. Th e passive neutron counter uses multiple 3 

# He

proportional counters, along with a multiplicity sh ift register and an external 252 

# Cf source for the

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

content of waste containers, referred to as the 240 

# Pu Effective 

# ( 240 

# Pu Eff 

# ). The 240 

# Pu Eff 

# is defined as the

amount of 240 

# Pu 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 240 

# Pu Eff



# by applying the ratios of other TRU or target radi onuclides, including all

spontaneously fissioning radionuclides (i.e., 235 

# U). Isotopic ratios are determined primarily by

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

gamma-ray spectrometer, as discussed below. Isotop ic 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 241 

# Am and Pu isotopics are

“determined by MGA or FRAM 2 

# software,” although the use of FRAM had not yet be en

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

FRAM during several previous inspections, specifica lly 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 opera tion would be unchanged. The

LANL HENC 2 Expert Analyst (EA) would obtain the gam ma 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 HP Ge 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 238 

# Pu, 239 

# Pu, 241 

# Pu, 241 

# Am, 233 

# U, 235 

# U, 238 

# U, 137 

# Cs, and 237 

# Np.

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

correct for photon attenuation inside the drum. Ca libration 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 o perational modes as follows:

• Passive neutron mode with an operational range of t he system’s LLD to 16.28 g 240 

# Pu Eff 

# for multiplying waste streams, i.e., wastes that ar e predominantly 239 

# Pu, with gammabased isotopics (original passive neutron calibrati on)

• Passive neutron mode with an operational range of t he system’s LLD to 35.0 g 240 

# Pu Eff 

# for non-multiplying waste streams, i.e., wastes tha t are predominantly 238 

# Pu, with

gamma-based isotopics (extension of original passiv e 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 (e xtension of original gamma efficiency

calibration)

2 

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

used software analysis routine for the purpose of d etermining isotopic ratios similar to MGA, also cal led PC FRAM.

# 6

Passive Neutron Calibration

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

empirically derived coefficients that relate the sy stem’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 an d generating a new curve with a higher upper

limit of 35.0 g 240 

# Pu Eff



# for wastes that are predominantly 238 

# Pu (non-multiplying wastes). The

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

16.28 g 240 

# Pu Eff



# still applies to wastes that are predominantly 239 

# Pu (multiplying wastes).

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

(HS) PuO 2 

# in diatomaceous earth that were double or triple e ncapsulated in welded stainless steel

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

manufactured by the LANL CMR Analytical Chemistry G roup (now called the Analytical

Chemistry Group of Los Alamos National Laboratory) a nd 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 239 

# Pu and from 0.24 g to 2.14 g for

238 

# Pu. By combining sources of varying Pu content in the PDP 3 

# -type empty matrix drum,

LANL-CCP obtained data for 239 

# Pu that spanned a range of 0.5 g to 237.14 g of tot al Pu, and a

range of 0.24 g to 10.19g for 238 

# Pu 4



# .

Gamma Calibration

All initial gamma efficiency calibrations were perf ormed using mixed gamma line sources that

feature prominent gamma emission lines of 152 

# Eu and 241 

# Am, as described in HENC#2-NDA1002, Table 4, Revision 3. In response to an EPA c omment, this table was modified to indicate

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

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

were performed with tin/copper filters mounted on t he detector’s face. The energy calibration

was set at approximately 0.75 keV per channel and t he 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 a ssays that provide the technical justification for

the requested range extension to 2.1 g/cc. The gam ma 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 pres ented in ASTM C 1133, there is no true upper

mass limit for the gamma calibration of the LANL HE NC 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 m aterial content. In practice, other

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

238 

# Pu and 239 

# Pu is a convention that actually reflects the range of standards that were assayed as

part of the system’s performance testing. Regardin g 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 acc omplished 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 Demonstr ation Program.

4 

# An equal mass of 238 

# Pu and 239 

# Pu will have a different 240 

# Pu EFF 

# 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-1 002, 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 perso nnel during the September 12, 2007

teleconference. There are no concerns regarding th e 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-track ed radionuclides and assign

isotopic distributions pertinent to CH TRU wastes w as assessed.

Instructions for operation of the LANL HENC 2 were c ontained 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 FR AM) and the 240 

# Pu EFF 

# determination or

direct gamma measurement provides for the quantific ation of 238 

# Pu, 239 

# Pu, 240 

# Pu, 241 

# Am, 237 

# Np,

233 

# U, 235 

# U, 238 

# U, and 137 

# Cs. The 242 

# Pu content is determined using the correlation tech nique of

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

facilities. Each waste container’s 234 

# U content is quantified by application of scaling f actors that

are based on observed values for 235 

# U and 238 

# U. The determination of 90 

# Sr is performed by

application of a scaling factor based on the sample ’s observed 137 

# Cs content. AK-based isotopics

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

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

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

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

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

measurement.

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

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

used for the initial calibration, i.e., double or t riple encapsulated WG or HS PuO 2 

# in

diatomaceous earth, but were physically different s ources 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

239 

# Pu and from 0.5 g to 13.7 g of 238 

# Pu. Each configuration was assayed six times in th e

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

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

# Pu

and 238 

# Pu drums passed the percent recovery acceptance cri terion for accuracy (±30%) and the

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

results of all calibration confirmations were accep table. 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 differen t 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 cr iteria in DOE-WIPP-02-3122 for accuracy and

precision. The concrete matrix drum passed the per cent recovery acceptance criterion for

# 8

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

on six replicates). The results of the gamma effic iency 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 b een 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 calibra tion 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, yiel ds a measured value greater than

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

value which measurements of the background will exc eed 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. Sect ion 6 of HENC#2-NDA-1002 adequately

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

analogs) are provided for 242 

# Pu, 234 

# U and 90 

# Sr, and these are based on known relationships

between measured radionuclides and other target rad ionuclides that cannot be practically

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

100 nCi/g based on the assumptions provided in Sect ion 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 establis hed isotopics for homogeneous solids at this

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

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

Approval

The NDA system evaluated during this Tier 1 evaluati on 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 C H TRU wastes, consistent with the

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

# Pu EFF 

# and

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

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

for passive neutron and gamma efficiency assays.

# 9

Findings

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

LANL HENC 2 during this T1 change evaluation.

Concerns

The EPA Inspection Team did not identify any concer ns 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 an y 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 ChecklistNONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: LANL–CCP T1 ChangeInspection Date: September 12, 2007NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)A-1Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceSystem DescriptionIdentify the NDA system by name, locationand number, as appropriate.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe system is the LANL-HENC #2,previously known as the MCS HENC,that is housed in Building No.54506(trailer) located Technical Area 54 (TA54), Area G, Pad 10 at LANL. Thesystem has not been moved since EPAinspection EPA-LANL-CCP-05.06-8.Y Visual observation of the LANLHENC #2 system in place atArea G of TA-54 at LANLduring EPA-LANL-CCP-05.06-8, March 2007.Describe the system’s operational historyincluding deployment at other DOE sites.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe LANL-HENC #2 was initiallydeployed at LLNL and was firstevaluated during EPA-LLNL-CCP04.08.8, August 2004, and mostrecently during EPA-LANL-CCP05.06-8.YEPA Waste CharacterizationReports: EPA Inspection Nos.EPA-LANL-CCP-05.05.8, May2005; EPA-LLNL-CCP-05.04-8,May 2004; EPA-LANL-CCP05.06-8, March 2007For systems that have been deployed atmultiple DOE sites, document pertinentaspects of each system’s development, e.g.,installation of new or different detectors,software, or other relevant features.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe LANL-HENC #2 had beenmodified prior to EPA lastevaluation/approval. No physicalmodifications associated with this T1change.Y HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007System PerformanceIdentify the period of performance relevant tothis T1 evaluation if this NDA system hasprior EPA approval(s).Y CCP-PO-002, CCP TransuranicWaste Certification PlanThis evaluation was limited to theT1change described previously.NA Not ApplicableIdentify the type and number of wastecontainers this system assayed during theperiod of performance. Of these, indicatehow many Batch Data Reports (BDRs) wereassembled and how many of the assembledBDRs have been promoted through ProjectLevel Review.Y CCP-PO-002, CCP TransuranicWaste Certification PlanBDRs were not reviewed during this T1evaluation. The BDRs that wereevaluated during EPA-LANL-CCP05.06-8 are listed in subsequent entriesof this checklist.NA Not ApplicableNONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: LANL–CCP T1 ChangeInspection Date: September 12, 2007NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)A-2Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceGeneral Reporting RequirementsAssay systems must report quantitativevalues and uncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr, and137Cs.Y CCP-PO-002, CCP TransuranicWaste Certification PlanQuantitative values and uncertaintiesfor238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr, and137Cs arereported.NC BDRs LANDA0124,LANDA0361, 1LANDA0390,LANDA0227Each container characterized and intendedfor disposal at WIPP must contain TRUwaste.Y CCP-PO-002, CCP TransuranicWaste Certification PlanContainers assayed for WIPP are TRUwaste, i.e., they contain >100 nCi/g oftransuranic alpha activity.NC BDRs LANDA0124,LANDA0361, 1LANDA0390,LANDA0227NDA instruments and procedures areappropriate for the waste streams beingassayed.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe LANL HENC #2 and supportingprocedures are appropriate for thewastes currently being assayed.NC BDRs LANDA0124,LANDA0361, 1LANDA0390,LANDA0227NDA instruments and procedures result inunbiased values for the cumulative activity ofthe WIPP radionuclide inventory.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe radionuclide values produced bythe LANLHENC #2 are appropriate forsupporting the cumulative activity ofthe WIPP radionuclide inventory.NC BDRs LANDA0124,LANDA0361, 1LANDA0390,LANDA0227Some radionuclides are quantified by theapplication of scaling factors or correlationtechniques. Identify all radionuclides that arequantified in this manner.Y CCP-PO-002, CCP TransuranicWaste Certification Plan234U,242Pu and90Sr are derived by theapplication of scaling and/or correlationfactors.NC CCP-TP-103, Revision 6,Appendix 1, pages 15 - 24Assess the technical adequacy of thecalculations involving the application ofscaling factors and/or correlation techniques.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe scaling and/or correlation factorscited in the preceding checklist item aretechnically adequate and appropriatelydocumented.NC CCP-TP-103, Revision 6,Appendix 1, pages 15 - 24Identify the procedures that govern thisfunction and where the results of thesecalculations are documented.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe procedure that governs theapplication of scaling factors isidentified and the results of thesecalculations are documented.NC CCP-TP-103, Revision 6,Appendix 1, pgs. 15 – 24; BDRsLANDA0124, LANDA0361,1LANDA0390, LANDA0227NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: LANL–CCP T1 ChangeInspection Date: September 12, 2007NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)A-3Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceAcceptable Knowledge (AK)If isotopic ratios based on AK are used, thevalues are qualified by confirmatory testing.Y CCP-PO-002, CCP TransuranicWaste Certification PlanIsotopic ratios used in quantifyingradionuclides are qualified byconfirmatory testing when AK is usedNC CCP-TP-103, Revision 6,Appendix 1, pages 15 – 24Do NDA personnel use AK-derived isotopicvalues to calculate radionuclide values? Ifso, is this function performed according to aformal procedure? Assess the technicaladequacy of this process(s).Y CCP-PO-002, CCP TransuranicWaste Certification PlanNDA personnel using AK derivedisotopic values to calculateradionuclide values do so according toa formal procedure, the technicaladequacy of which is adequate.NC CCP-TP-103, Revision 6,Appendix 1, pages 15 – 24Identify the procedure and where the resultsof these calculations are documented.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe procedure for AK calculations isidentified and results are documentedin the two BDRs that were evaluatedduring EPA-LANL-CCP-05.06-8.NC CCP-TP-103, Revision 6,Appendix 1, pages 15 – 24;BDRs LANDA0124,LANDA0361, 1LANDA0390,LANDA0227Isotopic DeterminationIdentify the radionuclides that are measureddirectly and the type of radiation that ismeasured (gamma, Active or PassiveNeutron).Y CCP-PO-002, CCP TransuranicWaste Certification Plan240PuEFFis directly measured based onpassive neutron emission. Otherradionuclides (238Pu,239, Pu242, Am241,etc.) are derived from240PuEFFbased onisotopics determined by gamma-basedMGA or direct gamma determination.Y HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007Identify the method(s) used to derive theisotopic contribution for the unmeasuredradionuclides, e.g., MGA, PC FRAM, orother technique.Y CCP-PO-002, CCP TransuranicWaste Certification PlanMGA is used to derive the isotopiccontribution for unmeasuredradionuclides. All containers (100%)are subject to routine gamma assayalthough useable data may not beavailable for each container. FRAMmay be used for isotopics in the future.AK-based isotopic values are used inthe absence of useable MGA (orFRAM) values when data to supportAK are documented in AK/NDAY HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: LANL–CCP T1 ChangeInspection Date: September 12, 2007NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)A-4Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceMemoranda. There are no approvedAK isotopic values for S3000 solidsNONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: LANL–CCP T1 ChangeInspection Date: September 12, 2007NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)A-5Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceLower Level of Detection (LLD)The LLD for each NDA system must bedetermined. For multi-modal systems thismay require a separate determination for eachmode.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe LLD for the LANL HENC #2 hasbeen determined for the passiveneutron and gamma mode.YHENC#2-NDA-1002, CalibrationReport for the HENC#2 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 3,September 14, 2007.LLD determinations must account for sitespecific environmental backgrounds andcontainer-specific interferences.Y CCP-PO-002, CCP TransuranicWaste Certification PlanSite-specific environmentalbackgrounds and container specificinterferences are accounted for in LLDdeterminations.YHENC#2-NDA-1002, CalibrationReport for the HENC#2 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 3,September 14, 2007.NDA instruments performing TRU/NonTRU waste discrimination measurements arerequired to have an LLD no greater than100 nCi/g.Y CCP-PO-002, CCP TransuranicWaste Certification PlanBoth the passive neutron and gammamodes have LLDs less than 100 nCi/gfor debris and solid matricesYHENC#2-NDA-1002, CalibrationReport for the HENC#2 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 3,September 14, 2007.The technical basis and derivation for LLDsmust be technically adequate andappropriately documented.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe technical bases and derivation forthe passive neutron and gamma modesare technically adequate andappropriately documented.YHENC#2-NDA-1002, CalibrationReport for the HENC#2 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 3,September 14, 2007.For radionuclides that are not determined bymeasurement, an LLD analog must be usedwhen it is technically feasible. Identify allinstances when this occurs and the form ofthe documentation of these activities.Y CCP-PO-002, CCP TransuranicWaste Certification PlanA reporting threshold (LLD analog) hasbeen determined for90Sr,234U and242Pu. These are technically adequateand appropriately documented.YHENC#2-NDA-1002, CalibrationReport for the HENC#2 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 3,September 14, 2007.NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: LANL–CCP T1 ChangeInspection Date: September 12, 2007NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)A-6Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceIdentify any/all instances where an LLDvalue for anon-measuredradionuclide is notprovided based on a lack of technicalfeasibility.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThere are no instances where an LLDvalue for anon-measuredradionuclideis not provided basis on a lack oftechnical feasibility are documented.YHENC#2-NDA-1002, CalibrationReport for the HENC#2 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 3,September 14, 2007.Are LLD values container/assay eventspecific or are typical LLD values applied toa class or type of wastes, i.e., those withsimilar attributes? If LLD values are notcontainer/assay event specific, identify theattributes or characteristics whereby wastecontainers are grouped.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe LLD values listed in the calibrationreport are typical values thatdemonstrate the LANL HENC #2’ssensitivity with the understanding thatthese values listed may not be obtainedfor every assay event.Y HENC#2-NDA-1002, CalibrationReport for the HENC#2 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 3,September 14, 2007.Total Measurement Uncertainty (TMU)The method used to calculate the TMU for allrequired quantities must be documented andtechnically justified.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe method used to calculate the TMUfor the LANL HENC #2 is documentedand technically justified.NCTotal Measurement Uncertaintyfor the MCS HENC #2 WithIntegral Gamma Spectrometer,Document #CI-HENC-TMU-101,Revision 1, March 24,2005TMU determination accounts for all sourcesof uncertainty, specifically: background;calibration; isotopic determination; matrixheterogeneity; difference between waste andmatrix specific calibration; source positioneffects; end effects; self shielding; and,neutron multiplication.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe LANL HENC #2 RDSs evaluatedduring EPA-LANL-CCP-05.06-8included all required elements.NCTotal Measurement Uncertaintyfor the MCS HENC #2 WithIntegral Gamma Spectrometer,Document #CI-HENC-TMU-101,Revision 1, March 24,2005Methods to determine TMU must bedocumented, reviewed, and approved byCBFO for each NDA instrument.Y CCP-PO-002, CCP TransuranicWaste Certification PlanCBFO Technical Specialist D. Stuenkelconfirmed that the TMU report hadbeen reviewed and approved duringEPA-LANL-CCP-05.06-8.NC Observed CBFO review andapproval of the TMU reportduring EPA-LANL-CCP-05.06-8.NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: LANL–CCP T1 ChangeInspection Date: September 12, 2007NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)A-7Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceSystem CalibrationEach NDA instrument must be calibratedbefore its initial use. Determine the date ofthe system’s calibration of record and wherethis is documented. For multi-modalsystems, specify the calibration for eachmode.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe LANL HENC #2 was originallycalibrated in 2004. There have beenseveral revisions to the calibrationreport and the system’s currentcalibration is documented in Revision3. The passive neutron and gammacalibrations are technically adequate.YHENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007The range of applicability of the system’scalibration(s) must be specified in siteprocedures or other formal documentation.Identify the manner in which the range isexpressed, i.e., curies or Pu/SNM mass foractivity and salient physical characteristicsfor matrix.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe operating range is the system LLDto 16.278 g240PuEFFfor passive neutronassays of predominantly239Pu-bearingwastes and LLD to 35.0 g240PuEFFforassays of predominantly238Pu-bearingwastes; LLD to 217 g Pu total forgamma, but gamma range is bestexpressed in an energy range of 122 to1212 keV limited by dead time. Matrixdensity range for gamma is 0.018 to 2.1g/cc for S3000 and S5000 wastes.Y HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007Any matrix/source surrogate wastecombinations must be representative of theactivity ranges and relevant waste matrixcharacteristics currently in use or planned foruse by the system. The system must becalibrated to 100% recovery.Y CCP-PO-002, CCP TransuranicWaste Certification PlanMatrix/source waste combinations arerepresentative of routine samplescurrently measured by the LANLHENC #2. The system is calibrated to100% recovery.Y HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007The use of consensus standards forcalibration is required, when such standardsexist. If consensus standards do not exist, thecalibration technique must be approved byCBFO.Y CCP-PO-002, CCP TransuranicWaste Certification PlanConsensus standards have been usedfor calibrating the LANL HENC #2,see checklist item below.Y HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: LANL–CCP T1 ChangeInspection Date: September 12, 2007NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)A-8Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceIdentify the specific consensus standards thatwere used for the system calibration or, intheir absence, the alternate technique.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe specific consensus standards usedfor calibration are: ASTM-C1030-95,ASTM C-1133-96, ASTM C-1207 andASTM C-1500.Y HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007Primary standards must be obtained fromsuppliers maintaining a nationally accreditedmeasurement program. Identify the program.Y CCP-PO-002, CCP TransuranicWaste Certification PlanPrimary gamma standards have beenobtained a commercial supplier; Pusources for passive neutron calibrationwere obtained from R. Marshall’sgroup in the LANL CMR. Bothorganizations maintain a nationallyaccredited measurement program.Y HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007List the standards used for calibration andverify the pedigree of each standard.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe calibration standards are listed andthe pedigree of each has been verified.Y Appendix 1, HENC#2-NDA1002, Calibration Report for theHENC#2 Including PassiveNeutron and GammaSpectrometer Calibration andConfirmation, Revision 3,September 14, 2007Calibration Verification & ConfirmationVerification of an NDA instrument’scalibration must be performed after any ofthe following: major system repairs and/ormodifications, replacement of the system’scomponents, significant changes to thesystem’s software, or system relocation.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe LANL HENC #2 has beenrecalibrated several times since thesystem’s initial calibration at LANL in2004. Previous recalibrations havebeen confirmed and documentedappropriately as discussed above in thischecklist. The most recent calibrationis documented appropriately.Y HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007Recalibration of the system must occur if thecalibration verification demonstrates that theY CCP-PO-002, CCP TransuranicWaste Certification PlanThis T1 change was an extension of theprevious calibrationNA Not ApplicableNONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: LANL–CCP T1 ChangeInspection Date: September 12, 2007NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)A-9Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidencesystem’s response has significantly changed.The system calibration must be confirmed byperforming replicate measurements of a noninterfering matrix.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe LANL HENC #2’s calibration hasbeen confirmed and documentedappropriately following eachcalibration.Y HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007Replicate measurements must be performedwith containers of the same nominal size andaccording to the same procedures used foractual waste assays.Y CCP-PO-002, CCP TransuranicWaste Certification PlanReplicate measurements have beenperformed with 55-gallon (208-liter)drums and the operating and datareview procedures that are used forroutine waste assays.Y HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007Replicate measurements must be performedusing nationally recognized standards orstandards derived from nationally recognizedstandards that span the range of use of theinstrument with respect to disintegration rateand/or matrix effects. Identify all standardsthat were used and indicate their application(verification or confirmation).Y CCP-PO-002, CCP TransuranicWaste Certification PlanReplicate measurements have beenperformed using nationally recognizedstandards or standards derived fromnationally recognized standards thatspan the range of use of the instrumentwith respect to disintegration rateand/or matrix effects. All standardsthat were used have been identified andtheir application documented.Y HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007Identify the nationally accreditedmeasurement program. List the standardsused for verification/confirmation and verifythe pedigree of each standard.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe standards used for verificationand/or confirmation and their pedigreeare listed.Y Appendix 1, HENC#2-NDA1002, Calibration Report for theHENC#2 Including PassiveNeutron and GammaSpectrometer Calibration andConfirmation, Revision 3,September 14, 2007NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: LANL–CCP T1 ChangeInspection Date: September 12, 2007NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)A-10Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceThe standards used for calibrationconfirmation must be different from thesources used for the system’s calibration ofrecord.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe standards used for calibrationconfirmation are different from thoseused for the system’s calibration ofrecord.Y Appendix 1, HENC#2-NDA1002, Calibration Report for theHENC#2 Including PassiveNeutron and GammaSpectrometer Calibration andConfirmation, Revision 3,September 14, 2007Requirements for accuracy, expressed as %R,and precision, expressed as %RSD, must bemet as specified in DOE/WIPP-02-3122,Appendix A, Table A-3.2 for precision and∀30% for accuracy.Y CCP-PO-002, CCP TransuranicWaste Certification PlanRequirements for accuracy andprecision have been met as specified inDOE/WIPP-02-3122, Appendix A,Table A-3.2 for precision based on thenumber of replicates assayed and∀30% for accuracy.Y HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: LANL–CCP T1 ChangeInspection Date: September 12, 2007NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)A-11Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceQuality ControlAll radioassay and data validation must beperformed by appropriately trained andqualified personnel.Y CCP-PO-002, CCP TransuranicWaste Certification PlanAll radioassay and data validation hasbeen performed by appropriatelytrained and qualified personnelNC CCP-LANL List of QualifiedIndividuals, 5/22/2006, 10:30AM provided during inspectionEPA-LANL-CCP-05.06-8.Identify the name, title, and function of allpersonnel performing NDA data validation.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe name, title and function of allNDA personnel performing datavalidation for the LANL HENC#2 aredocumented.NC CCP-LANL List of QualifiedIndividuals, 5/22/2006, 10:30AM provided during inspectionEPA-LANL-CCP-05.06-8.The site must participate in relevantmeasurement comparison programssponsored or approved by CBFO, includingthe NDA PDP.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe site has participated successfully inCycle 13A of the CBFO sponsoredNDA PDP. The conditional approvalof the LANL HENC #2 effective inJuly 2006 was made permanent uponsuccessful implementation of theLANL Corrective Action Plan thataddressed the Cycle 13A PDP failuresfor the glass matrix container with HSPu.NC July 19, 2006 Memorandum fromM. Brown to C. FesmireScoringResults – Primary Cycle 13ANondestructive Assay PDP;January 19, 2007 Memorandumfrom M. Brown to C. Fesmireupdating status based on resultsof NDA PDP Primary Cycle 13ABackground and Performance ChecksAssay system background measurementsmust be taken daily, unless otherwiseapproved by CBFO. Contributions tobackgrounds from nearby radiation sourcesmust be carefully controlled, or morefrequent backgrounds must be measured.Y CCP-PO-002, CCP TransuranicWaste Certification PlanDaily background are taken andrecorded. Contributions to backgroundsfrom high activity containers that arestored or staged in proximity to theLANL HENC #2 Trailer do affect thebackground but NDA personnel controlthis.NC HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: LANL–CCP T1 ChangeInspection Date: September 12, 2007NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)A-12Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceAssess how often background radiation wasproblematic to the extent that measurementpersonnel had to make adjustments.Y CCP-PO-002, CCP TransuranicWaste Certification PlanBackground control charts are used todocument the system’s performanceover time.NC HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007Identify the criteria used to evaluateinstrument backgrounds and assess thenature, i.e., statistical or administrative, andtechnical adequacy of this criterionY CCP-PO-002, CCP TransuranicWaste Certification PlanBackgrounds are evaluated againstpredetermined upper and lowerboundaries and are non-statistical innature. Initial control limits are basedon the system’s first month ofoperations and each day’smeasurements are automaticallycompared to the established limitsYHENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007Identify the number of data points required toderive the initial control limit. At whatinterval(s) will new limits be calculated?Y CCP-PO-002, CCP TransuranicWaste Certification PlanInitial control limits for all performancemeasurements were based on sixmeasurements. Limits will berecalculated as more data are acquiredor the system is recalibrated.Y HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007System performance checks must beperformed at least once per operational day.Y CCP-PO-002, CCP TransuranicWaste Certification PlanPerformance checks have beenperformed at least once per operationalday and all checks have beendocumented.Y HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007System performance checks must include, asapplicable, efficiency, matrix correctionchecks, and systems peak position andresolution for spectrometric systems.Y CCP-PO-002, CCP TransuranicWaste Certification PlanPerformance checks include: 121 keVpeak centroid and FWHM, 964 peakcentroid and FWHM and weighedaverage of152Eu activity.Y HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: LANL–CCP T1 ChangeInspection Date: September 12, 2007NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)A-13Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceAt a minimum of once per operational weekan interfering matrix must be assayed toassess the long-term stability of the NDAinstrument and its matrix corrections andhow this performance is documented.Y CCP-PO-002, CCP TransuranicWaste Certification PlanTwo matrix drums are available, adebris and homogeneous solid. Theyare used with a variety of PDP-type Pusources that span a range of activity.The acceptance criteria for the WeeklyInterfering Matrix checks were notassessed during inspection EPALANL-CCP-05.06-8.Y HENC#2-NDA-1002, CalibrationReport for the HENC#2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 3,September 14, 2007Interfering surrogate waste matrices must beconstructed in a way that the salient matrixcharacteristics do not change over time.Y CCP-PO-002, CCP TransuranicWaste Certification PlanInterfering surrogate waste matriceshave been constructed such that thesalient matrix characteristics do notchange over time.NC Visual examination of matrixdrums, interviews with LANLCCP NDA personnel andevaluation of PDP submittalsThe radionuclide sources used forperformance checks must be long-lived andof activity to provide statistically sufficientresults over a short measurement time.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe241Am,152Eu and Pu sources usedfor performance checks are of sufficientactivity to provide statisticallysufficient results over a shortmeasurement time.NC Interviews with LANL-CCPNDA personnel and evaluation ofLANL HENC #2 performancedata and LANL HENC #2BDRsduring inspection EPA-LANLCCP-05.06-8.Radioactive sources are decay corrected as afunction of their physical half-life, asappropriate, specifically133Ba,252Cf,137Cs,75Se, and109Cd.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe241Am and152Eu sources are decaycorrected as a function of their physicalhalf life. Decay correction is notapplicable to239Pu sources.NC Interviews with LANL-CCPNDA personnel and evaluation ofLANL HENC #2 performancedata and BDRs during inspectionEPA-LANL-CCP-05.06-8.Performance checks must be quantitative andbased on 2 and 3 sigma limits.Y CCP-PO-002, CCP TransuranicWaste Certification PlanLimits are based onStudentt-testfor95% (warning limit) and 99% (controllimit) confidence intervals.NC CCP-TP-103; HENC#2-NDA1002, Calibration Report for theHENC#2 Including PassiveNeutron and GammaSpectrometer Calibration andConfirmation, Revision 3,September 14, 2007; LANLHENC #2 BDRs LANDA0124,LANDA0361, 1LANDA0390,NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: LANL–CCP T1 ChangeInspection Date: September 12, 2007NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)A-14Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceLANDA0227Identify how many data points are used forthe initial evaluation and at what interval(s)new limits are calculated.Y CCP-PO-002, CCP TransuranicWaste Certification PlanNC CCP-TP-103; HENC#2-NDA1002, Calibration Report for theHENC#2 Including PassiveNeutron and GammaSpectrometer Calibration andConfirmation, Revision 3,September 14, 2007NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: LANL–CCP T1 ChangeInspection Date: September 12, 2007NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)A-15Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceData ManagementAll radioassay data must be reviewed andapproved by qualified personnel beforebeing reported to WWIS.Y CCP-PO-002, CCP TransuranicWaste Certification PlanIndividual Radioassay Data Sheets(RDS) were reviewed duringinspection EPA-LANL-CCP-05.06-8. All were acceptable.NC LANL HENC #2 BDRs reviewedduring EPA-LANL-CCP-05.06-8:LANDA0124, LANDA0361,1LANDA0390, LANDA0227Identify the name, title, and function of theindividual(s) performing technical reviewand approval of NDA BRDs.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe name, title and function of theindividual(s) performing technicalreview and approval of NDA BRDsare documented.NC LANL HENC #2 BDRs reviewedduring EPA-LANL-CCP-05.06-8:LANDA0124, LANDA0361,1LANDA0390, LANDA0227Radioassay BDRs must consist of thefollowing elements:•Testing facility name, testing batchnumber, container numbers, andsignature of the Site Project Officer(SPO) or designee(s)•Table of Contents•Background and performance checkdata or control charts for the relevanttime period.•Data validation per the QAPD and siteprocedures•Separate testing report sheets for eachcontainer.Y CCP-PO-002, CCP TransuranicWaste Certification PlanThe LANL HENC #2 BRDsreviewed during inspection EPALANL-CCP-05.06-8.his inspectioncontained all required elements.NC LANL HENC #2 BDRs reviewedduring EPA-LANL-CCP-05.06-8:LANDA0124, LANDA0361,1LANDA0390, LANDA0227Radioassay data sheets (RDS) must include:•Title “Radioassay Data Sheet”•Method/procedure used•Date of radioassay•Activities and associated TMU forindividual radionuclidesY CCP-PO-002, CCP TransuranicWaste Certification PlanThe LANL HENC #2 RDSsreviewed during inspection EPALANL-CCP-05.06-8 contained allrequired elements.NC Reviewed RDSs reviewed duringEPA-LANL-CCP-05.06-8: asfollows:HENC #2 BDR Container No.LANDA0361: S844320, S3609LANDA0124: 60706, 59129NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: LANL–CCP T1 ChangeInspection Date: September 12, 2007NDA System: LANL High Efficiency Neutron Counter No. 2 (HENC 2)A-16Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidence•TRU alpha concentration and itsassociated TMU•Operator signature•Reviewer signature1LANDA0390: 57014, 56897The following nonpermanent records mustbe maintained at the radioassay-testingfacility or forwarded to the site projectoffice:•Testing batch reports•All raw data, including instrumentreadouts, calculation records, andradioassay QC results•All applicable instrument calibrationreportsY CCP-PO-002, CCP TransuranicWaste Certification PlanNonpermanent records aremaintained in the LANL HENC #2trailer in TA-54, Area G, and all rawdata are included on two compactdiscs that are submitted with eachBDR to the CCP office.NC Interviews with LANL HENC #2operator and other LANL-CCPNDA personnel reviewed duringinspection EPA-LANL-CCP05.06-8