**1** DOCKET NO: A-98-49, II-A4-94

Enclosure

EPA’s October 16, 2007 Inspection Report

**On October 16, 2007, under the authority of 40 CFR 194.21(a)(1), EPA inspected certain** 

**TRU waste activities of AMWTP and ARP-CCP at INL. The sections below discuss**  **inspection purpose and results.**

1.0 AMWTP Inspection:

1.1 Purpose:

**The purpose of the unannounced inspection was as fo llows:** 

• **Evaluate actions taken to complete Corrective Actio ns #7, #9 and #10 from CAR** 

**28920**

• **Examine the tracking/segregation and payload assemb ly process at AMWTP** 

• **Evaluate the interface between AMWTP’s internal Was te Tracking System**  **(WTS) and the WIPP Waste Information System (WWIS)**

• **Evaluate the DOE-Idaho (DOE-ID) oversight related i nteraction with AMWTP** 

**As part of the inspection conducted under the 40 CF R 194.21(a)(1) authority, EPA**  **wanted to review relevant objective evidence and ve rify that AMWTP continues to**  **implement changes required by the corrective action s necessitated to address an**  **erroneous shipment an uncertified waste container o verpacked in an SWB.** 

1.2 Individuals Contacted:

**The inspection was opened with a conference call at 8:30 MST. Following**  **individuals participated in the in-brief and out-br ief: DOE ID - Don Rasch, Talley**  **Jenkins, Jerry Wells, and Jim Wolski; Paul Contrera s, DOE ID, DOE CBFO -Casey**  **Gadbury, Courtland Fesmire, J R Stroble, Norma Casta neda, Kenneth Licklitter, Martin**  **Navarrete, and Dennis Miehls; ID DEQ - Craig Halvers on and Bruce LaRue; and BBWI**  **– Paul Divjak, Lee Sygitowicz, Scott Raisch, Doug W ale, Kiki Torres, Neil Brill, Clint**  **Sisson, Jeff Mousseau, and Elvin Dumas.**

1.3 Background:

**In June 2007, AMWTP shipped an uncertified TRU wast e container overpacked in a**  **standard waste box (SWB) to WIPP for disposal and i mmediately upon finding the error**  **voluntarily stopped TRU waste shipments to WIPP. D OE informed EPA of the incident**  **and the stop shipment decision as part of the corre ctive action until the site and CBFO**  **completed the investigation and the site implements appropriate corrective actions. In** **2**

**early July 2007, EPA inspected AMWTP’s implementati on of corrective actions ranging**  **from immediate to long-term to preclude recurrence. On July 16, 2007, EPA sent a letter**  **to DOE concurring with DOE’s decision to resume INL shipments to WIPP. EPA had**  **not received objective evidence for some of the lon g-term corrective actions (completed**  **since the EPA July inspection).**

1.4 Discussion:

**Below is the description of EPA’s inspection result s.** 

A. Actions taken to complete Corrective Actions #7 , #9 and #10 from CAR 28920

**Elvin Dumas (AMWTP-QA) indicated that CAR 28920 is closed and provided**  **documents that detail the process still underway at the site to preclude recurrence of the**  **shipment of errant drum to WIPP. The documentation covers the period since the EPA**  **inspection of July 2007. EPA evaluated the evidenc e provided and found it to be**  **adequate. EPA requested the site provide updates t o EPA as these actions are completed.** 

**Attachment A lists the AMWTP action items that addr ess the CAR corrective actions #7,**  **#9, and #10 completed since the EPA inspection.**

B. Examine the tracking/segregation and payload as sembly process at AMWTP

**AMWTP personnel made available an OPS Tech (operati ons technician), Mr.Doug**  **Pearson, to demonstrate the tracking and segregatio n of containers in building WMF-630.**  **The EPA inspector requested Mr. Pearson barcode sca n container #1020565. This**  **container had an NCR (Non-Conformance Report) associ ated with it because it contained**  **prohibited liquids. The NCR is shown below:**

**When the barcode for container 10020565 was scanned the display showed the following:** **3**

**When this screen opens the ops tech must acknowledg e the warning to clear the screen.**  **Any attempt to move this container would be denied by the WTS (Waste Tracking**  **System).**

**EPA then requested that a fully characterized but n ot WWIS certified container be moved**  **to the payload assembly area of building WMF-630 us ing the barcode scanner and WTS**  **interface. The following was displayed by the scan ner:** **4**

“Scripting Alert: Send of (Container #) FAIL. Ops C ertification row violation- container is not

certified”

**This is adequate to ensure that uncertified contain ers cannot be moved to an area where**  **WIPP certified containers can be staged.**

C. Evaluate the interface between AMWTP’s internal Waste Tracking System (WTS) and the WIPP Waste Information System (WWIS)

**EPA requested to meet with a TCO (Transportation Ce rtification Officer) who gives final**  **approval for the payload assembly interfacing with both the WTS and WWIS systems.**  **TCO Randy Richmond was interviewed. Mr. Richmond d escribed that the WWIS**  **system provides a population of containers eligible for disposal at WIPP. From this**  **population he selects containers based on waste str eam, weights, and other transportation**  **criteria. He then places move orders into the WTS (Waste Tracking System) that allows**  **the containers to be moved to a special roped off a nd marked area in building WMF-630.**  **The containers are moved by the OPS Tech after the barcode of the individual containers** 

**are scanned and the destination of the certified ro w is placed in the system, with the final**  **check being that no system flags are displayed by t he barcode scanner. Examples of the**  **documentation for this process are Attachments B an d C. EPA was satisfied that the**  **WTS/WWIS interface and the associated review proces s was adequate.** **5**

**As a result of the Item 10 under the heading Action s to Preclude Recurrence of CAR**  **28920, certain chain of custody activities will be taken over by the Central**  **Characterization Project (CCP) in coming months. D uring discussion with AMWTP**  **personnel it was apparent that the AMWTP’s and CCP’ s chain of custody procedures**  **differ. For example, AMWTP uses WTS, an internal e lectronic system that tracks CH**  **TRU waste containers through the characterization p rocesses up to and including loading**  **direct loaded or overpacked containers that are loa ded into TRUPAC IIs or half-pacs.**  **AMWTP must maintain the WTS component as it is part of the AMWTP’s hazardous**  **waste permit issued by the Idaho Department of Envi ronmental Quality. CCP uses a**  **non-electronic (paper based) container management s ystem. EPA is concerned that the**  **CCP system may not be directly compatible with the WTS implemented by AMWTP**  **thereby requiring extra steps that to interface wit h and integrate the AMWTP’s waste**  **container tracking and movement system when CCP tak es over portions of AMWTP’s**  **existing chain of custody process. EPA, therefore, intends to inspect and evaluate the**  **process for adequacy as AMWTP and CCP implements ch anges stemming from Item 10**  **under the heading Actions to Preclude Recurrence of CAR 28920.** 

D. Evaluate the DOE-ID oversight related interacti on with AMWTP

**EPA received from DOE-ID a listing of all weekly me etings held between the DOE-ID**  **office staff and the AMWTP staff. (See Attachment D ) Mr. Jim Wolski, a Facility**  **Representative (FR) from the DOE-ID office to the A MWTP facility described the FR**  **program and how it provides day-to-day operational oversight to the AMWTP facility.** 

**Mr. Wolski stated that there are three FRs at the A MWTP site. He stated that a minimum**  **of 40% of their time is spent in the field observin g operations. EPA was provided a**  **listing of all FRs in the DOE complex and the DOE S tandard for Facility Representatives**  **(DOE-STD-1063-2006 of April 2006) which describes t he FR program in detail. EPA** 

**was satisfied that the interface between the site a nd the DOE-ID office was adequate.** 

1.5 Conclusion:

**Based on the information obtained and evaluation of the implemented procedures, EPA**  **concludes that AMWTP’s current operational activiti es will ensure that only fully**  **characterized and certified TRU waste containers (d irect loaded and overpacked) will be**  **shipped to WIPP for disposal are for WIPP disposal.**

**As discussed under Section 1.4.C above, EPA wants t o be informed and intends to**  **inspect, evaluate, and verify procedure(s) implemen ted when CCP takes over from**  **AMWTP certain of the chain of custody components as required by Item 10 under the**  **heading Actions to Preclude Recurrence of CAR 28920**

**. 6** 

2.0 ARP-CCP Inspection

2.1 Purpose:

**The purpose of the inspection was to obtain informa tion about the TRU waste belonging**  **to four waste streams (IN-ICP-002, IN-ICP-003, IN-I CP-004, and IN-ICP-005) from pre** 

**1970 buried waste at INL. These waste streams were included in the 2004 Compliance**  **Recertification Application documentation as potent ial TRU waste for which detailed**  **characterization data were lacking at that time. T hey were included in the subsequent**  **Performance Assessment (PA) calculations required b y EPA for the WIPP recertification.**  **The intent of the inspection was to understand TRU waste volume estimates used in the**  **TRU waste inventory for the WIPP performance assess ment required to support the CRA** 

**II due to EPA March 2009. The Central Characteriza tion Project (CCP) supports ARP’s** 

**TRU waste characterization activities at INL. EPA expected ARP-CCP to gather more**  **recent information about the projected volumes of T RU waste from these waste streams**  **as part of the acceptable knowledge process.**

2.2 Individuals Contacted:

**EPA staff met with Paul Contreras (208-526-5699, contreph@id.doe.gov**  **), Manager, DOE INL Accelerated Retrieval Project, and Tom John**  **sen (208-533-0559, 208-351- 8357,**  **Thomas.johnsen@icp.doe.gov ), and Brent Burton (208-526-8695, 208-520-0420,**  **Brent.Burton@icp.doe.gov ), INL Contractor staff, to gather information on b**  **uried waste being excavated as part of the Accelerated Retrieva**  **l Project (ARP) activity. Also present at the meeting were Chuck Ljundberg, DOE Idaho and**  **Bruce LaRue, Idaho Department of Environmental Quality.** 

2.3 Background:

**The Idaho Cleanup Project (ICP) is responsible for cleanup of waste from the subsurface**  **disposal area and the Advanced Retrieval Project (A RP) identifies, retrieves, and**  **prepares targeted waste for characterization and sh ipment to the WIPP. The Central**  **Characterization Project (CCP) is responsible for c haracterization of waste excavated**  **from ARP and AMWTP is responsible for its disposal at WIPP. In November 2005, EPA**  **approved CCP’s waste characterization program for t he TRU component of the**  **excavated waste from Pit 4 (ARP I) and Pit 6 (ARP I I). Since 2005 the waste from these**  **two pits has been disposed of at WIPP. TRU waste f rom ARP areas other than ARP I**  **and ARP II will require EPA approval for disposal a t WIPP.** 

2.4 Discussion:

**Below are the highlights of the discussion:**

• **Since 2004, these waste streams have been regrouped and classified into three**  **summary category groups (SCGs), namely, IN-ICP-002 (inorganic solids) and IN**  **ICP-003 (organic solids) as homogenous solids (S300 0), IN-ICP-004 (graphite)** **7 and IN-ICP-005 (filters) as debris (S5000), and soi**  **ls/gravel (S4000). The categorization of roasted oxides into one of these**  **SCGs is remains to be done. [The SCGs are the waste categories different waste**  **streams are grouped into when characterizing TRU waste for the disposal at WIPP.]** 

• **A new baseline plan (available for public comment) for the CERCLA/Superfund**  **Cleanup activity at INL estimates that the area req uiring excavation will be**  **approximately 4.8 acres as opposed to the original estimate of the ARP targeted**  **area of 2.8 acres. Currently waste covered under t he ARP is being excavated as**  **TRU waste for WIPP disposal. The ARP activity is e xpected to be completed** 

**around 2012.**

• **According to the current estimates more than 90% of the excavated waste is**  **anticipated to be TRU with the remaining waste clas sified as low-level waste or** 

**mixed TRU waste.**

• **ARP will begin excavating waste from Pits 3 and 6 f ollowed by Pits 1 and 2.**  **ARP-CCP expects that next Spring characterization o f the newly excavated waste**  **from these pits will begin.**

2.5 Conclusion:

**During the EPA inspection ARP-CCP was not able to p rovide sufficient information**  **specific to the main issue. Therefore, DOE (ARP) n eeds to provide the following** 

**information to EPA to resolve the concern.**

• **Provide the process used for regrouping the four wa ste streams into broad SCGs.** 

• **Provide the new volume estimates for TRU, mixed TRU and low-level waste**  **(LLW) per pit as shown in the Attachment E diagram and for each SCG.** 

• **Explain the basis for determining if the waste is T RU or LLW when developing**  **TRU waste volume estimates and compiling acceptable knowledge for these** 

**waste streams.**