DOCKET NO: A-98-49, II-A4-72 

WASTE CHARACTERIZATION INSPECTION REPORT 

EPA BASELINE INSPECTION NO. EPA-INL-CCP-RH-6.06-8 

OF THE CENTRAL CHARACTERIZATION PROJECT 

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION 

PROGRAM AT THE IDAHO NATIONAL LABORATORY 

June 12–16, and August 9 and 29, 2006 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center of Federal Regulations 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

January 2007
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TABLE OF CONTENTS 

Section Page

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

2.0 Purpose of Inspections ........................................................................................................ 5 

3.0 Purpose of This Report ....................................................................................................... 6 

4.0 Scope of Inspection............................................................................................................. 7 

5.0 Inspection-Related Definitions ........................................................................................... 8 

6.0 Personnel............................................................................................................................. 8 

6.1 EPA Inspection Team ............................................................................................. 8 

6.2 Personnel Contacted................................................................................................ 9 

7.0 Performance of the Inspection ............................................................................................ 9 

8.0 Technical Waste Characterization Areas.......................................................................... 11 

8.1 Acceptable Knowledge ......................................................................................... 11 

8.2 Radiological Characterization............................................................................... 36 

8.3 Visual Examination............................................................................................... 64 

8.4 Real Time Radiography ........................................................................................ 69 

8.5 WIPP Waste Information System ......................................................................... 69 

9.0 Response to Comments..................................................................................................... 69

10.0 Summary of Results.......................................................................................................... 70 

10.1 EPA Findings and Concerns ................................................................................. 70 

10.2 Conclusions........................................................................................................... 70 

11.0 References......................................................................................................................... 73 
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ATTACHMENTS 

Attachment A.1 Acceptable Knowledge (AK) Checklist 

Attachment A.2 Dose To Curie (DTC) Checklist 

Attachment A.3 Visual Examination (VE) Checklist 

Attachment B.1 EPA Inspection Issue Tracking Form, EPA Issue No. 

INL-CCP-RH-VE-06-001F/INL-CCP-RH-VE-06-001CR, Revision 1 

Attachment B.2 EPA Inspection Issue Tracking Form, EPA Issue No. 

INL-CCP-RH-VE-06-002CR 

Attachment B.3 EPA Inspection Issue Tracking Form, EPA Issue No. 

INL-CCP-RH-VE-06-003CR/INL-CCP-RH-VE-06-003F 

Attachment B.4 EPA Inspection Issue Tracking Form, EPA Issue No. 

INL-CCP-RH-AK-06-005CR, Revision 1 

Attachment B.5 EPA Inspection Issue Tracking Form, EPA Issue No. 

INL-CCP-RH-AK-06-006CR, Revision 1 

Attachment B.6 EPA Inspection Issue Tracking Form, EPA Issue No. 

INL-CCP-RH-AK-06-007CR, Revision 1 

Attachment B.7 EPA Inspection Issue Tracking Form, EPA Issue No. 

INL-CCP-RH-AK-06-008CR, Revision 1 

Attachment B.8 EPA Inspection Issue Tracking Form, EPA Issue No. 

INL-CCP-RH-RH-VE-06-009C 

Attachment C Public Comments and EPA’s Responses 
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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. EPA-INL-CCP-RH-6.06-8 of the Central 

Characterization Project’s (CCP) waste characterization (WC) program for remote-handled (RH) 

transuranic (TRU) waste at the U.S. Department of Energy’s (DOE) Idaho National Laboratory 

(INL) located outside of Idaho Falls, Idaho. EPA conducted a baseline inspection of the site’s 

program to characterize RH TRU wastes proposed for disposal in the Waste Isolation Pilot Plant 

(WIPP). This inspection occurred in three segments: 

• On-site inspection at INL on June 12–16, 2006 

• Follow-up inspection on August 9, 2006, at DOE’s Carlsbad Area Field Office (CBFO), 

for the purpose of assessing mass spectrometry data used to support one element of the 

INL RH WC program 

• Follow-up inspection at CBFO on August 29, 2006, for the purpose of resolving open 

issues from the previous two inspections 

Additionally, there were ongoing technical discussions during July and August 2006 between 

members of the EPA inspection team and CBFO technical contractors related to technical 

aspects of the INL-CCP RH WC program. 

On November 2006, EPA issued a Federal Register (FR) notice (71 FR 65488, November 8, 

2006) announcing the proposed approval of the RH waste characterization (WC) program 

implemented at INL by CCP. The FR notice opened a 45-day comment period to solicit public 

comment on the proposed approval of INL-CCP’s RH WC program and the INL Baseline 

Inspection Report (EPA Air Docket A98-49, II-A4-69). The comment period ended 

December 26, 2006. EPA received one set of public comments. (See EPA Docket ID No. 

EPA-HQ-OAR-2006-0881). EPA evaluated and responded to the public comments (see 

Attachment C of this report), and made changes to the proposed approval decision, where 

appropriate. This report discusses EPA’s approval of the RH waste characterization (WC) 

program implemented at INL by CCP. 

 

EPA must verify compliance with 40 CFR 194.24 before waste may be disposed of at the WIPP, 

as specified in Condition 3 of the Agency’s certification of the WIPP’s compliance with disposal 

regulations for TRU radioactive waste (63 Federal Register (FR) 27354 and 27405, May 18, 

1998). This was the first inspection of RH WC activities conducted by EPA at INL-CCP. EPA 

Baseline Inspection No. EPA-INL-CCP-RH-6.06-8 was performed in accordance with the 

provisions of 40 CFR 194.8(b), as issued in a July 16, 2004, FR notice (Vol. 69, No. 136, 

pp. 42571–42583). The purpose of the INL-CCP RH WC inspection was to evaluate the 

adequacy of the site’s WC programs for one (1) RH debris waste stream to be disposed of at the 

WIPP. The activities examined during the inspection and approved for implementation included 

the following: 
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• Acceptable knowledge (AK) for RH retrievably-stored TRU debris waste (S5000). 

• Radiological characterization as described in this report for RH retrievably-stored TRU 

debris waste (S5000). 

• Visual examination (VE) of audio/video media for RH retrievably-stored TRU debris 

waste (S5000) containers. 

 

EPA’s inspection team determined that INL-CCP’s RH WC program activities were technically 

adequate. EPA is approving the INL-CCP RH WC program in the configuration observed 

during the baseline and follow-up inspections, described in this report, and documented in detail 

in the checklists in Attachment A. The approval includes the following: 

(1) The AK process for RH retrievably-stored TRU debris in one waste stream, designated 

by INL as INL Waste Stream No. ID-ANLE-S5000, Lots 1 through 20, which are defined 

by INL-CCP as a debris waste stream in CCP-AK-INL-500, Revision 3 

(2) The radiological characterization process using dose-to-curie (DTC) and modelingderived scaling factors for assigning radionuclide values to one RH waste stream for 

which the scaling factors are applicable, as described in CCP-AK-INL-501, Revision 1 

(3) The VE of audio/video media process used for a total of nineteen (19) retrievably-stored 

RH debris waste drums included in three batch data reports (BDRs) – BDR Nos. 

RHINLVE60001, RHINLVE60002, and RHINLVE60003. (See Section 8.3 for further 

explanation.) 

During the comment period for the proposed approval, INL-CCP provided EPA with additional 

information related to an improved VE technique as well as an additional VE BDR. (See EPA’s 

response to Comments Nos. 8 and 12 in Attachment C of this report.) EPA has begun this 

evaluation and the results of the Tier 1 (T1) evaluation will be provided upon completion 

separately. If appropriate, EPA could expand its approval to the VE process evaluated as a T1 

change.

EPA is not approving the WIPP Waste Information System (WWIS) for entry and tracking of the 

waste contents of RH debris wastes at this time. Although the WWIS is currently approved by 

EPA for tracking contact-handled (CH) waste, INL-CCP had not demonstrated its adequacy to 

enter and track RH waste contents during this baseline inspection. During the comment period 

for the proposed approval CBFO notified EPA that the WWIS was operational for RH wastes 

and was ready for EPA evaluation as a T1 change. EPA has begun this evaluation and the results 

of EPA’s T1 evaluation will be provided upon completion separately.

EPA is also not approving real-time radiography (RTR) at this time. INL-CCP did not have an 

operational RTR unit in place at the time of the inspection. This final baseline inspection 

requires the use of RTR as a T1 change. Therefore, INL-CCP cannot ship RH waste to the WIPP 

using RTR as a WC technique until it is approved by EPA. EPA received a request for an 

evaluation and approval of a RTR process. Once the evaluation is complete, the results of the T1 

evaluation will be provided separately. 
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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 Table 1. Please note that each T1 and Tier 2 

(T2) change listed in Table 1 is followed by a reference to the report section where the technical 

basis for the T1 or T2 designation is presented. 

In October 2006, EPA concurred with CBFO’s request for allowing INL-CCP to submit T2 

changes implemented at the EPA-approved TRU sites four times a year at the end of each fiscal 

quarter. (See EPA letter to CBFO dated October 26, 2006; EPA Air Docket No. A-98-49, 

II-A4-76). INL-CCP may submit all T2 changes discussed in this report on the same schedule. 
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Table 1. Tiering of RH TRU WC Processes Implemented by INL-CCP 

 (Based on June 12–16 Baseline and August 9 & 29, 2006, Follow-Up Inspections)

RH WC Process Elements INL-CCP RH WC Process - T1 Changes INL-CCP RH W

Acceptable Knowledge (AK) Modification of the approved waste stream ID-ANLE-S5000 to 

include additional containers, i.e., K Cell or other debris wastes; AK (1) and AK (5) Any new waste streams not approved under this baseline; AK (1) and AK (7)Substantive modification(s)*** that have the potential to affect the characterization process: CCP-AK-INL-500, CCP-AK-INL-501, or CCP-AK-INL-502; AK (6) and AK (7) Load management for any RH waste stream; AK (16) 

Notification to EPA wheCCP-INL-AK-501, and by CBFO; AK (4) Notification to EPA wheas a result of WCPIP revCRR); AK (7) and AK (Notification to EPA wheSummary Form is compcontainers in this waste upon measured dose rateassayed containers; AK Notification to EPA oncdebris waste stream, and including the CRR and AAK (14) Notification to EPA that complete for RH containidentified in AK Referenreports prepared annuall

Radiological Characterization, including Dose-to-Curie (DTC) 

Application of new scaling factors for isotopic determination other than those documented in CCP-AK-INL-501; RC (8.2.2 and 8.2.3) Use of any alternate radiological characterization procedure other than 

DTC with established scaling factors as documented in CCP-TP-504 or substantive modification of the DTC procedure***; RC (8.2.2 and 8.2.3) Any new waste stream not approved under this baseline or addition of containers to Waste Stream ID-ANLE-S5000 that requires changing the established radionuclide scaling factors; RC (8.2.3)

Revisions of CCP-AK-INrequire CBFO approval; 

Visual Examination of audio/video media (VE) 

Implementation of VE following this baseline approval; if INL-CCP decides to use VE in the future, EPA approval is necessary 

Real-Time Radiography (RTR) Any use of RTR requires EPA approval WIPP Waste Information System (WWIS) Any use of WWIS requires EPA approval prior to RH waste disposal 

* Upon receiving EPA approval, INL-CCP will report all T2 changes to EPA every three months. ** Excluding changes that are editorial in nature or are required to address administrative concerns. *** Substantive modification refers to a change with the potential to affect INL-CCP’s RH WC process, e.g., the use of an inherently differen

or the use of the high-range probe as described in CCP-TP-504. 
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EPA will notify the public of the results of its evaluations of T1 and T2 changes established as 

part of today’s approval through the EPA Web site and by sending e-mails to the WIPPNEWS 

list (see Section 2.0, below, for a brief discussion of tiering). All T1 changes must be submitted 

for approval before their implementation and will be evaluated by EPA. Upon approval, EPA 

will post the results of the evaluations through the EPA Web site and the WIPPNEWS list, as 

described above. 

2.0 PURPOSE OF INSPECTIONS 

On May 18, 1998, EPA certified that the WIPP will comply with the radioactive waste disposal 

regulations in 40 CFR Part 191. In this certification, EPA also included Condition 3, which 

states that “the Secretary shall not allow shipment of any waste from...any waste generator site 

other than LANL [Los Alamos National Laboratory] for disposal at the WIPP until the Agency 

has approved the processes for characterizing those waste streams for shipment using the process 

set forth in §194.8.” The approval process described at 40 CFR 194.8 requires DOE to 

(1) provide EPA with information on AK1

 for waste streams proposed for disposal at the WIPP, 

and (2) implement a system of controls used to confirm that the total amount of each waste 

component that will be emplaced in the WIPP will not exceed limits identified in the WIPP 

Compliance Certification Application (CCA). 

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, FR notice, EPA must 

perform a 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. Specifically, EPA’s 

inspection team verifies compliance with 40 CFR 194.24(c)(4), which states the following: 

Any compliance application shall: . . . Provide information which demonstrates 

that a system of controls has been and will continue to be implemented to confirm 

that the total amount of each waste component that will be emplaced in the 

disposal system will not exceed the upper limiting value or fall below the lower 

limiting value described in the introductory text of paragraph of this section.2

The system of controls shall include, but shall not be limited to: measurement; 

sampling; chain of custody records; record keeping systems; waste loading 

schemes used; and other documentation. 

 1

 As of the FR notice of July 16, 2004, EPA has replaced the term process knowledge with acceptable 

knowledge. Acceptable knowledge refers to any information about the process used to generate waste, material 

inputs to the process, and the time period during which the wastes were generated, as well as data resulting from the 

analysis of waste conducted prior to or separate from the waste certification process authorized by an EPA 

certification decision to show compliance with Condition 3 of the certification decision. 

2

 The introductory text of 40 CFR 194.24(c) states, “For each waste component identified and assessed pursuant 

to [40 CFR 194.24(b)], the Department shall specify the limiting value (expressed as an upper or lower limit of 

mass, volume, curies, concentration, etc.), and the associated uncertainty (i.e., margin of error) for each limiting 

value, of the total inventory of such waste proposed for disposal in the disposal system.” 
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In other words, the purpose of the baseline inspection is to implement the requirements of 

40 CFR 194 by assessing whether DOE sites that characterize TRU waste prior to disposal at the 

WIPP are capable of characterizing and tracking the waste. EPA may also conduct follow-up 

inspections to address issues remaining from the baseline inspection or to seek further 

clarification/discussion related to WC processes evaluated during a baseline inspection. By 

approving the WC systems and processes at INL-CCP applied to retrievably-stored RH debris 

waste, EPA confirms that the Agency has evaluated the capabilities of systems and processes 

implemented by a site to accomplish two tasks: (1) the identification and measurement of waste 

components (such as plutonium (Pu)) that must be tracked for compliance,3 and (2) the 

confirmation that the waste in any given container has been properly identified as belonging to 

the group of approved waste streams. 

Based on the adequacies of the WC processes demonstrated during the baseline inspection, 

including all conditions and limitations, EPA specifies which subsequent WC program changes 

or modifications must undergo further EPA inspection or approval under 40 CFR 194.24. This is 

accomplished by assigning a tier level to each aspect of the characterization program, i.e., T1 and 

T2 activities. T1 activities have more stringent reporting and EPA notification requirements and 

require EPA approval prior to implementation. T2 activities are reported to EPA based on the 

frequency established in the inspection report. DOE may choose to characterize and dispose of 

the waste from T2 activities at risk while EPA considers the T2 changes. If INL-CCP 

contemplates a change that is not identified in this report, EPA recommends that the site, in 

consultation with CBFO, discuss the nature of the change with EPA. This would minimize the 

possibility of EPA not approving the site-assigned tiers. The rule applying to this baseline 

inspection can be found in the FR (Vol. 69, No. 136, pp. 42571–42583, July 16, 2004). 

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

conduct additional inspections to evaluate and approve, if necessary, changes to the site’s 

approved WC program under the authority of 40 CFR 194.24(h). Under 40 CFR 194.24, EPA 

also 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. 

3.0 PURPOSE OF THIS REPORT 

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

Inspection No. EPA-INL-CCP-RH-6.06-8 in terms of findings or concerns. Specifically, this 

report does the following: 

 3 The potential contents of a single waste stream or group of waste streams determine which processes can 

adequately characterize the waste. For example, if AK suggests that the waste form is heterogeneous, the site should 

select the matrix-appropriate radiological characterization technique to obtain adequate radionuclide measurements. 

VE serves to confirm and quantify waste components, such as cellulosics, rubbers, plastics, and metals. Once the 

nature of the waste has been confirmed, characterization techniques quantify selected radionuclides in the waste. In 

some cases, a TRU waste generator site may be able to characterize a range of heterogeneous waste streams or only 

a few. A site’s stated limits on the applicability of proposed WC processes govern the scope of EPA’s inspection.
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• Describes the characterization systems proposed for approval 

• Provides objective evidence of the approval basis for all WC systems 

• Identifies all relevant limitations and or conditions for each WC system 

• Provides objective evidence of outstanding findings or concerns in the form of 

documentation, as applicable 

• Describes any tests or demonstrations completed during the course of the inspection and 

their relevance to EPA’s approval decision 

The completed checklists attached to this report in conjunction with the listings in each section 

reference the documents that the EPA inspection team members reviewed in support of the 

technical determination. To see or obtain copies of any items identified in the attached 

checklists, write to the following address: 

Quality Assurance Manager 

USDOE/Carlsbad Field Office 

P.O. Box 3090 

Carlsbad, NM 88221 

EPA’s final approval decision regarding the INL-CCP WC program is conveyed to DOE 

separately by letter. This information is also available on EPA’s Web site at 

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

4.0 SCOPE OF INSPECTION 

The scope of Baseline Inspection No. EPA-INL-CCP-RH-6.06-8 included the technical 

adequacy of the WC systems in use at INL-CCP to characterize RH TRU wastes. These systems 

were evaluated with respect to their ability to perform the following: 

• Identify and quantify the activities of the 10 WIPP-tracked radionuclides (241Am, 137Cs, 

238Pu, 239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U, and 238U) using a combination of AK and 

radiological characterization, including DTC and radionuclide scaling factors derived 

from modeling 

• Assign waste material parameters (WMPs) correctly using VE for RH retrievably-stored 

debris waste 

Specifically, these systems consisted of the following components: 

• The AK process that supports retrievably-stored S5000 debris wastes from one (1) RH 

debris waste stream (INL Waste Stream No. ID-ANLE-S5000, Lots 1 through 20) 

• The system of radiological characterization including DTC and the application of 

radionuclide scaling factors derived by modeling for one RH debris waste stream (INL 

Waste Stream No. ID-ANLE-S5000) 

• VE for retrievably-stored S5000 RH debris wastes 
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During an inspection, EPA does not approve characterization data; that function is the sole 

responsibility of the site being evaluated during the inspection, in this case INL-CCP. EPA 

evaluated the WC processes implemented by the site to characterize RH retrievably-stored debris 

waste. The evaluation consists of interviewing personnel, observing equipment operations that 

are controlled through site procedures, and inspecting records related to each of the WC 

processes within the inspection’s scope. An important aspect of this evaluation is the objective 

evidence that documents the effectiveness of the WC processes. Objective evidence typically 

takes the form of BDRs for radiological characterization and VE, AK accuracy reports, and VE 

tapes. During an inspection, EPA typically selects samples of each of these items, based on the 

number and variety of items that were completed and available for each WC process, consistent 

with standard auditing techniques. Because the RH TRU characterization program is new, there 

was initially only one completed BDR for VE and radiological characterization available for the 

EPA inspection team’s evaluation. By the end of the inspection process, INL-CCP had produced 

two more VE BDRs for a total of three. The EPA inspection team evaluated all of the drums in 

the three VE packages and the one radiological characterization package. Based on the 

evaluation of the WC processes in conjunction with the objective evidence, EPA determined the 

technical adequacy of the WC processes within the inspection’s scope. 

5.0 INSPECTION-RELATED DEFINITIONS 

During the course of an inspection, EPA inspectors may encounter items or activities that require 

further inquiry for their potential to adversely affect WC and/or isolation within the repository. 

The two main categories relevant to WC inspections are identified below: 

Finding: A determination that a specific item or activity does not conform to 

40 CFR 194.24(c)(4). A finding requires a response from CBFO. 

Concern: A judgment that a specific item or activity may or may not have a negative effect on 

compliance and, depending on the magnitude of the issue, may or may not require a 

response. (Concerns not requiring a response do not have to be addressed prior to 

program approval.) 

6.0 PERSONNEL 

6.1 EPA Inspection Team 

The members of the EPA WC inspection team are identified in Table 2. 

Table 2. EPA Inspection Team Members

Inspection Team Member Position Affiliation

Ms. Rajani Joglekar Inspection Team Leader U.S. EPA ORIA 

Mr. Ed Feltcorn Inspector U.S. EPA ORIA 

Ms. Connie Walker Inspector S. Cohen & Associates, Inc. 

Ms. Dorothy Gill Inspector S. Cohen & Associates, Inc. 

Mr. Patrick Kelly Inspector S. Cohen & Associates, Inc. 
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6.2 Personnel Contacted 

EPA and its support personnel conducted interviews with INL-CCP personnel in several 

disciplines. The personnel contacted represented a sample of the CH TRU WC staff, and they

are listed in Table 3, along with their affiliation and technical area. 

Table 3. Personnel Contacted During Inspection

Personnel Affiliation Area of Expertise 

Eric D’Amico CCP AK, DTC, SPM 

Jene Vance CCP AK/DTC; Scaling Factors-MS Data 

Lisa Price CCP AK, AKE 

Larry Porter CCP AK, SPM; Scaling Factors-MS Data 

Steve Schafer CCP AK, AKE 

Kevin Peters CCP AK, AKE 

Lee Smith CCP RTR, SME & Operator 

Ed Gulbransen CCP DTC, SME 

Mark Doherty CCP/WTS DTC & Scaling Factors-MS Data 

Joe Harvill CCP/WTS DTC & Scaling Factors 

Keith B. Farmer CWI DTC, Nuclear Facility Manager 

Ken Pierce CWI DTC, Shift Manager 

Chris Davis CWI DTC, Dose-Rate Operator 

Suay Andrews CWI DTC, Dose-Rate Operator 

Mark Hawker CWI DTC, Rad Con Technician 

Swami Raman CCP VE, Operator/ITR 

Tommy Mojica CCP Operator/ITR, SME/OJT, VEE 

Patrick Boyd CCP Operator/ITR 

John Hegsted CCP Operator/ITR 

Irene Quintana WTS SPM 

During the baseline inspection, INL-CCP provided a list of RH TRU WC personnel from which 

EPA selected the individuals to be interviewed. The EPA inspectors reviewed the qualifications 

and training records of these individuals relative to their WC responsibilities. Based on this 

evaluation, EPA determined that INL-CCP WC personnel responsible for characterizing RH 

TRU waste and certifying it as TRU waste were qualified and had received adequate training to 

perform their assigned function. If key WC personnel changes occur, EPA may request 

qualification and training records of the new individuals identified as key WC personnel. EPA 

will review these records and may interview the personnel to determine their abilities to produce 

quality data. This personnel qualification evaluation and review of training records would be the 

equivalent of the evaluation done by the EPA inspection team on site during this inspection. 

7.0 PERFORMANCE OF THE INSPECTION 

Site Background and History

INL is located in southeastern Idaho, about 60 miles outside of Idaho Falls, Idaho. The site 

encompasses approximately 890 square miles. The U.S. government established INL in 1949 as 

the National Reactor Testing Station, and its original mission was the design, construction, and 
10

testing of prototype nuclear reactors. Over the years, site activities have shifted from reactor 

development to multi-program research, hazardous and radioactive waste management and 

cleanup, and the development of environmental technologies. In January 1997, the site, then 

known as the Idaho National Engineering Laboratory (INEL), changed its name to the Idaho 

National Engineering and Environmental Laboratory (INEEL) to highlight its role in developing 

waste cleanup and other environmental technologies. In February 2005, the site’s name was 

changed to the Idaho National Laboratory (INL)4

 to better reflect its role in the development of 

nuclear-related technologies. 

The 2004 Compliance Recertification Application5

 states that there are eight individual RH 

waste streams currently in storage at INL. These wastes originated from a variety of DOE 

generators, including Argonne National Laboratory-East (ANL-E) and Argonne National 

Laboratory-West (ANL-W), Battelle Columbus Laboratories, and INL6. The wastes are 

expected to consist primarily of debris, including metal waste, laboratory wastes, Pu-neutron 

source metallic wastes and heterogeneous debris; one RH sludge waste stream is identified. INL 

has approximately 202 cubic meters (m3) of RH TRU waste in storage, and it is projected that no 

additional RH waste streams will be generated. It is worth noting that the number of actual 

waste streams may change as a function of the requirements of the WC Program Implementation 

Plan (WCPIP). 

Inspection Process Overview

EPA Inspection No. EPA-INL-CCP-RH-6.06-8 occurred in three segments: 

• On-site inspection at INL on June 12–16, 2006 

• Follow-up inspection on August 9, 2006, at DOE’s CBFO for the purpose of assessing 

mass spectrometry data used to support one element of the INL-CCP RH WC program 

• Follow-up inspection at DOE’s CBFO on August 29, 2006, for the purpose of resolving 

open issues from the above-listed inspections 

The inspection had the scope described in Section 4.0, above, for the purpose of determining the 

site’s compliance with 40 CFR 194.24. The inspection was conducted in the following steps: 

 

(1) Obtaining and reviewing site procedures, reports, and other technical information related 

to RH WC activities at INL-CCP in advance of the inspection 

(2) Preparing draft checklists and technical questions specific to WC areas prior to the 

inspection, as appropriate 

 4

 Documentation cited in this report may bear an identification number from INL, INEEL, or INEL, depending 

on the document’s time of generation. These distinctions are not significant. 

5

 Appendix data, Attachment F, Annex J 

6

 As a result of the incorporation of the facility formerly known as ANL-W into INL, the facility in Argonne, 

Illinois, that was formerly known as ANL-E is now called ANL. The ANL-W facility is now called the Materials 

and Fuel Complex. The terms ANL-E and ANL-W may be used in this report to maintain consistency with specific 

references. 
11

(3) Evaluating INL-CCP’s implementation of WC processes for adequacy and demonstrating 

compliance with 40 CFR 194.24 requirements 

(4) Participating in several conference calls with CBFO technical support contractors to brief 

the EPA inspection team members regarding technical details related to the INL-CCP RH 

WC program 

(5) Interacting with CBFO and INL-CCP personnel to arrange inspection logistics 

(6) Conducting initial baseline inspection visit at INL-CCP to verify the technical adequacy 

or qualifications of RH WC personnel, procedures, processes, and equipment by means 

of interviews, observation, and demonstrations, and recording the results 

(7) Making one follow-up visit to CBFO headquarters in Carlsbad, New Mexico, to perform 

an independent technical evaluation of analytical data used to support the development of 

radionuclide scaling factors 

(8) Making one follow-up visit to CBFO headquarters in Carlsbad, New Mexico, to complete 

the evaluation of specific RH WC technical aspects 

(9) Holding ongoing technical discussions between members of the EPA inspection team and 

INL-CCP technical support contractors for the purpose of clarifying technical aspects of 

the RH WC program 

(10) Recording all concerns on EPA issue-tracking forms, which were completed and 

provided to CBFO and site personnel as they were generated (see Attachment B) 

(11) Communicating all pertinent information with CBFO and INL-CCP personnel on site and 

in other meetings, as appropriate 

(12) Pursuing resolution of all identified issues prior to completion of the inspection and after 

the inspection by discussions with CBFO and INL-CCP personnel 

(13) Conducting entrance, exit, and daily briefings for CBFO and INL-CCP management 

personnel at INL and CBFO, as appropriate 

(14) Preparing the draft inspection report 

8.0 TECHNICAL WASTE CHARACTERIZATION AREAS 

8.1 Acceptable Knowledge 

EPA examined the AK process and associated information to determine whether the INL-CCP 

RH program demonstrated compliance with 40 CFR 194.8 requirements for RH retrievablystored debris waste. 

Waste Characterization Element Description 

As part of the inspection, EPA reviewed the following with respect to the use of AK for WC: 

• Waste stream definition and identification, including radiological content 

• Identification of high-level waste, TRU versus non-TRU, spent nuclear fuel 
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• Role of AK in the characterization methodology (including alternative characterization 

methods related to AK) 

• Compilation of AK documentation and assembly of required information 

• Adequacy of WCPIP AK process implementation and AK Summary Report 

• AK data traceability 

• AK source document sufficiency 

• WCPIP interpretation with respect to AK qualification 

• Confirmatory Test Plan preparation and plan adequacy 

• Characterization Reconciliation Report preparation and report adequacy 

• Correlation and Surrogate Summary Form and contact-handled (CH)-RH correlation 

• Personnel training 

• Traceability of mass spectrometry data used to support radionuclide scaling factors 

• Nonconformance reports (NCRs) and AK discrepancy resolution 

• AK accuracy 

• Implementation of load management 

• Identification of the method for determining data quality objectives (DQOs) including 

those to be attained by AK qualification 

• Attainment of DQOs 

The checklist included as Attachment A.1 identifies the objective evidence reviewed by the EPA 

inspector. AK is used to provide information regarding several aspects of TRU wastes at 

INL-CCP, including the following: 

• Defense waste status 

• Material parameters 

• Waste stream 

• Radionuclide composition 

• Waste matrix codes (WMCs) 

Documents, Waste Containers, and Batch Data Reports Reviewed

• DOE/WIPP-02-3214, Remote Handled TRU Waste Characterization Program 

Implementation Plan, Revision 0D, October 30, 2003 

• DOE/WIPP-02-3122, Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot 

Plan, Revision 5, effective date TBD 

• CCP-PO-002, CCP Transuranic Waste Certification Plan, Revision 16, approved May 8, 

2006 

• CCP-QP-002, CCP Training and Qualification Plan, Revision 20, effective date May 3, 2006 

• CCP-AK-INL-500, Central Characterization Project Acceptable Knowledge Summary 

Report for Remote-Handled Transuranic Debris Waste from Argonne National LaboratoryEast Stored at the Idaho National Laboratory, Waste Stream ID-ANLE-S5000, Revision 2, 

June 1, 2006 and Revision 3, July 7, 2006 
13

• CCP-AK-INL-501, Central Characterization Project Remote-Handled Transuranic 

Radiological Characterization Technical Report for Remote-Handled Transuranic Debris 

Waste from Idaho National Laboratory, Revision 1, June 6, 2006 

• CCP-AK-INL-502, Central Characterization Project Confirmatory Test Plan for Waste 

Stream: ID-ANLE-S5000, Revision 0, May 5, 2006 

• CCP-AK-INL-502, Central Characterization Project Confirmatory Test Plan for Waste 

Stream ID-ANLE-S5000, Revision 1, May 31, 2006 

• CCP-TP-506, CCP Preparation of the Remote-Handled Transuranic Waste Acceptable 

Knowledge Characterization Reconciliation Report, Revision 1, effective date May 5, 2006 

• Interoffice correspondence (for audit demonstration purposes only), to I. Quintana from A.J. 

Fisher, Acceptable Knowledge Accuracy Report: Idaho National Laboratory Waste Stream 

Number ID-ANLE-S5000 Lot 1, June 8, 2006 

• EDF-6946, Engineering Design File Project No. 23048, Identification of Additional Fuel 

Elements/Materials Examined in the Alpha Gamma Hot Cell Facility for ANL-E TRU 

Waste, Revision ID:0, effective date May 19, 2006 

• FUEL PIN data source documents (CD), provided June 2006 

• P593, Engineering Design File, Quantifying Special Actinides in RH-TRU Waste from 

Irradiated Fuel Examined at ANL-E, EDF-2555, Revision 0, December 16, 2002 

• P592, Evaluation of Radionuclide contents in RH-TRU Waste Drums 728 through 737 Based 

on Reported Irradiated Fuel Examination INEEL/EXT-02-00168, Revision 0, September 

2003 

• Fuel Element Examination Sheets (Fuel Element Examined at Argonne National 

Laboratory), AG Nos. 421A, 429A 

• Drum number list, Waste Stream INL-ANL-E-S5000, provided June 2006 

• EDF-6685, Engineering Design File, Project No. 23048, Information on Fuel Elements 

Examined at the AGHCF7 at ANL from November 1971 to August 7, 1995, Based on Waste 

Consolidation Records, Revision ID:0, effective date May 19, 2006 

• Characterization Reconciliation Report (CRR), draft, for Waste Stream CRR-INL-AGHCFS5000-001 and for Waste Stream ID-ANLE-S5000, June 9, 2006 

• AK Qualification Card, Kevin Peters, August 6, 2003 

• NCR-RHINL-0004-06, Revision 0 (note reason for NCR not provided on sheets) 

• Waste Can Inventory Sheets, Can Nos. 105, 107, and 108, March 31, 1993 

• Waste Package Data Sheet, Drum Nos. 00739 (top can 107, bottom can 105), April 22, 1993 

• Waste Can Inventory Sheets, Can Nos. 118 and 119, March 26, 1993 

• Waste Package Data Sheet, Drum Nos. 00743 (top can 118, bottom can 119), April 30, 1993 

 7

 AGHCF is the Alpha-Gamma Hot Cell Facility at ANL-E. 
14

• Waste Package Data Sheet, Drum Nos. 00742 (top can 117, bottom can 115), April 30, 1993 

• Waste Can Inventory Sheets, Can Nos. 117 and 115, April 30, 1993 

• Waste Package Data Sheet, Drum Nos. 00741 (top can 110, bottom can 112), April 23, 1993 

• Waste Can Inventory Sheets, Can Nos. 110 and 112, April 2, 1993 

• Waste Package Data Sheet, Drum Nos. 00740 (top can 109, bottom can 108), April 23, 1993 

• Waste Can Inventory Sheet, Can No. 109, April 2, 1993 

• Waste Package Data Sheet, Drum No. 00738 (top can 102, bottom can 104), April 17, 1993 

• Waste Can Inventory Sheets, Can Nos.102 and 104, April 1, 1993 (camera was off for 

No.104) 

• DR11, Waste Requisition and Video Discrepancies, June 13, 2006 

• DR10, Discrepancy Resolution Regarding the Volume of 7-Gallon Waste Cans, K. Peters, 

June 6, 2006 

• Source Documents Reference List (CCP-TP-005, Revision 17, Attachment 4), June 13, 2006 

• Sample/Fuel Element and Other AK Data for Index 293 (see EDF-6685, Revision 11, 

page 23) 

• Data for AG No. 421A, UBA-15, end installation date April 19, 1990 

• ICP/EXT-05-0886, Project 23048, ILTSG Drum Retrieval Completion Report, Revision 0, 

October 2005 

• ID-ANLE-S5000, Draft Waste Stream Profile Form for Audit Purposes Only, June 2006 

• DTC BDR and related attachments: (1) CCP-TP-504, Revision 2, Attachment 8, SPM 

Checklist for BDR INL RH DTC 06001; (2) CCP-QP-005, CCP NCR Report 

RHINL-0500-06, for containers 00745 and 00746 (with container rejected because dose rate 

less than 10 times background), Revision 10; (3) CCP-TP-504, Revision 2, Attachment 4, 

BDR Cover Sheet INL RH DTC 06001; Attachment 5, BDR Table of Contents; Attachment 

6, BDR Narrative Summary; Attachment 7, ITR Review Checklist; Attachment 1, 

Measurement Control Reports (various dates); Attachment 2, Individual Container Data 

Sheets for Containers 771, 70, 73, 739, 743, 738, 742, 744, 747, 740, 741, 745, and 746; 

Waste Container Dose-to-Curie Conversion Record (same container numbers); 

(4) NCR-RHINL-0004-06, measured container dose rate not at least 10 times greater than 

background for Container 00763 

• RH TRU Waste Correlation and Surrogate Summary Form for ID-ANLE-S5000, undated 

and unsigned 

• Solid Radioactive Waste Disposal Requisition Date Sheets, various containers, provided 

June 2006 

• C003, Intralaboratory Memorandum to H. Welsh Re: Dimensions of Intermediate TRU 

Waste Containers, prepared by D. Donahue, September 14, 1989 
15

• P002, Central Characterization Project Acceptable Knowledge Report for Argonne National 

Laboratory-East Contact Handled TRU Waste Facility Maintenance and Laboratory 

Operations; CCP-AK-ANLE-001, Revision 11, December 31, 2003 

• C024, Intralaboratory Memorandum to W.C. Kettman from L.A. Neimark IPR, Clarification 

of 00 No. 29 with Regard to Inventory of 8 Inch Storage Holes, December 7, 1993 

• C058, Intralaboratory Memorandum to R. Boule from R. Ditch, Re: Needs Prior to Shipment 

of Neimark’s TRU-RH Drums to Idaho, March 1, 1990 

• C060, Intralaboratory Memorandum to R. Boule from A.C. Smith, Re: Status: Resumption 

of Shipments of TRU Waste to INEL, March 30, 1990 

• C066, Record of Communication between B. Kettman and D. Donahue, Re: AGHCF 

Operations and Waste Packaging, recorded by J. Whitworth and M. Wyco, August 7, 2001 

• C067, Record of Communication with F. Pausche and T. Bray, by J. Whitworth and M. 

Wyco, Re: Calculation of U/Pu Ratios in Waste Containers, August 8, 2001 

• C084, Intralaboratory Memorandum to Building 212 Personnel, Re: Disposal of Solid 

Radioactive Waste, F.P. Marchetti, February 4, 1986 

• C108, Correspondence to J.T. Case, USDOE Idaho Field Office from T.L. Clements, TLC224, 92, Re: Strategy Plan for Long-Term Management and Storage of Remote-Handled 

(RH) Transuranic (TRU) Waste, November 30, 1992 

• C121, Record of Communication with L. Neimark, A. Cohen, and F. Pausche by J. 

Whitworth and J. Biedscheld, and P. Kuan, R. Bhatt, and S. Kheriche, Re: ACHCF 

Radiological Characterization of RH-TRU Waste Shipped to INEEL, December 19, 2001 

• C330, Memorandum to I. Triay, CBFO from F. Marcinowski, Determination and Findings, 

Defense Origin of Nuclear Waste, Kerr-McGee Waste, April 15, 2005 

• C331, Memorandum to CCP Central Records from K. Peters, Re: Evaluation of Kerr-McGee 

Production and FFTF History, June 26, 2004 

• C332, Memorandum to CCP Central Records from D.B. Becker, Re: Assessment of Waste 

Material Parameters for Waste Stream ID-ANLE-S5000, January 3, 2006 

• C333, Memorandum to CCP Central Records from D.B. Becker, Re: Assessment of Waste 

Material Parameters for Waste Stream AERHDM, January 2006 

• C350, Memo to CCP File, DRAFT — Evaluation for Radiological Waste Stream Delineation 

for Waste Stream ID-ANLE-S5000 (AK Reference C350), K. Peters, September 1, 2006

• C348, Evaluation of Generator Reported Radionuclides for Waste Stream ID-ANLE-S5000, 

Steve Schafer, INL-CCP, June 30, 2006

• P001, ACHCF Operations Manual, Argonne National Laboratory, IPS-2-00-00, Revision 2, 

September 10, 1990 

• P006, Safety Analysis for Twenty Year Retrievable Storage of Intermediate Gamma Level 

Transuranic Waste, W.D. Jackson Alpha-Gamma Hot Cell Facility, Argonne National 

Laboratory, June 1, 1976 
16

• P009, TRU-RH Waste Certification Plan for Waste Management Operations, R.W. Ditch and 

G. Griggin, J0306-0033-SA, Revisions 2 and 4, November 10, 1986, and April 16, 1991 

• P023, Argonne National Laboratory-East Remote Handled Waste, W.M. Hellaeson, 

EDF-RWMC-759, August 29, 1994 

• P030, Radiological Acceptable Knowledge Report for Drums 728 through 737, J. Whitworth, 

Shaw Environmental Team Lead, INEEL/EXT-02-00527, July 31, 2002 

• P032, Procedure for Sorting Remote-Handled TRU Waste (30-Gallon Intermediate-Level 

Waste), Alpha-Gamma-Hot Cell Facility Irradiation Performance Section Materials and 

Components Technology Division, January 7, 1987 

• P055, [ANL-E] Waste Handling Procedures, C.L. Cheever, Manager, Waste Management 

Operations, September 18, 1986 

• P587, Program Scoping Plan for the Fast Flux Test Facility, A Nuclear Science and 

Irradiation Services User Facility, PNNL-12245, Revision 1, August 1999 

• P590, Methodology to Determine Radioisotope Contents in RH TRU Waste Drums from 

Irradiated Fuel Examination at ANL-E, INEEL/EXT-02-001 69, Revision 0, September 2003 

• P591, Engineering Design File, Estimation of Inventory of Significant Isotopes in RH-TRU 

Waste Drums 728 through 737, EDF-1979, Revision 1, March 19, 2003 

• P592, Evaluation of Radionuclide Contents in RH TRU Waste Drums 728 through 737 

Based on Reported Irradiated Fuel Examination, INEL/EXT-02-00168, Revision 0, 

September 2003 

• P593, Engineering Design File, Quantifying Special Actinides in RH-TRU Waste from 

Irradiated Fuel Examined at ANL-E; EDF-255, Revision 0, December 16, 2002 

• P595, Engineering Design File, Verification and Validation of a Portion of ORIGEN2 Code 

Used for RH-TRU Radiological Characterization, EDF-1980, Revision 0, March 2002 

• P596, Peer Review of Proposed Radiological Characterization Methodology for RemoteHandled Transuranic Waste Stored at the Idaho National Engineering and Environmental 

Laboratory, INEEL/EXT-03-01182, September 2003 

• P599, The Defense Programs Origin of Transuranic Waste at Argonne National LaboratoryWest, H.F. McFarlane, ANLE-NT-192, November 2001 

• U001, AGHFC Position Statement Regarding Defense Versus Non Defense TRU Waste, no 

author cited, April 7, 2000 

• U013, Waste Stream Fissile Content [AGHCF], March 23, 1990 

• U015, RH-TRU 1995, Book 5 Drums 798 to 809, no author cited, January 1, 1995 

• U022, TH-TRU 1985-1987, Book 3 Drums 617 to 686, no author cited, undated 

• U040, Spreadsheet Correlating Number Quota with Quota Title and Number Project, no 

author cited, July 31, 2002 
17

• U041, Videotape Log Data [Cans 100, 102–187, 217–231, and 234–246], C.L. Schulz, 

September 15, 2001 

• U042, RH-TRU 1976 to 1982, Book 1 [AGHCF], no author cited, undated 

• U072, Material Safety Data Sheets, various components, no author cited, undated 

Waste Container and Batch Data Reports Reviewed

The BDRs for RH waste containers that were examined are provided in Table 4, below. 

Table 4. BDRs Reviewed

Drum Number VE BDR No. DTC BDR No. Waste Lot 

Number 

00738 RH INL VE 06001 INL RH DTC C06001 17 

00739 RH INL VE 06001 INL RH DTC C06001 17 

00740 RH INL VE 06001 INL RH DTC C06001 17 

00742 RH INL VE 06001 INL RH DTC C06001 17 

00743 RH INL VE 06001 INL RH DTC C06001 17 

Waste Stream ID-ANLE-S5000 has been characterized by AK with respect to almost all of the 

DQOs, and “confirmatory testing” was performed to confirm AK information. Unlike CH TRU 

waste, RH containers will not be tested for AK confirmation using a nondestructive assay 

(NDA). Instead, the confirmation of AK-reported radiological contents of the RH debris waste 

containers, TRU waste designation, and activity-related DQOs is performed through the 

application of the DTC technique in conjunction with AK-based scaling factors that were derived 

through ORIGEN2.2 modeling. Input parameters to this modeling were not individual drum AK 

data, but rather fuel pins that contributed to radionuclides in various waste drum lots. The data 

for individual fuel pins were used as input to the ORIGEN2.2 code. The evaluation presented in 

this section assesses the AK process and related activities necessary to the determination of 

physical and radiological waste composition. The development of modeling parameters and the 

determination of scaling factors is addressed in Section 8.2. 

Technical Evaluation

(1) Waste Stream ID-ANLE-S5000 was examined with respect to whether the stream is 

adequately defined. 

The WCPIP defines waste stream as “waste material generated from a single process or activity, 

or as waste with similar physical, chemical, and radiological properties.” The waste stream 

examined, ID-ANLE-S5000, is a debris waste stream generated in the ANL-E hot cell and K 

cell. The physical and radiological composition of the waste with respect to waste stream 

definition is evaluated below. At the time of EPA’s inspection, EPA found that the definition of 

waste stream was not fully supported in CCP-AK-INL-500. This was discussed with AK 

personnel and EPA included this on an EPA Inspection Issue Tracking Form (See Attachment B. 

of this report for this form). It is discussed below, as well, under item (4). 
18

EPA Concern No. INL-CCP-RH-AK-06-005CR, Revision 1: EPA’s concern addressed the 

lack of clear support for the waste stream’s definition. Specifically, the document needs to make 

a better argument that the wastes generated in the cells were never segregated by fuel pin or 

generator, so there is no way a specific fuel pin or radionuclide content can be assigned to 

individual waste containers. Therefore, the radiological characteristics of the fuel pins must be 

assigned as a whole to the entire population. This assumption must be supported and justified in 

the AK Summary. 

Resolution: In response to EPA’s concern, INL-CCP revised CCP-AK-INL-500 to state: 

Waste stream ID-ANLE-S5000 meets the WCPIP waste stream definition...[because] all 

of the containers in the stream were generated by AGHCF processes that remained 

relatively unchanged containing the same type of materials in approximately the same 

relative percentages. As described in Section 5.3, period campaigns were conducted in 

the ABHCF to prepare shipments of containers to be sent to INL. Waste were generally 

collected at individual work stations then moved to the waste packaging area in WS5 to 

be stockpiled until the next packaging campaign. Technicians in WS5 visually examined, 

sorted, and loaded the waste. Due to these waste management practices, in conjunction 

with the destructive nature of the examinations performed in the AGHC, further 

delineation of this waste stream based on radiological contamination is not possible. In 

addition, the waste stream contains waste materials generated during maintenance and 

waste management activities that could contain any radiological materials contaminating 

the cell surfaces and equipment (References C332, C333, C347, P006, P009, P023, 

U042). 

EPA examined INL-CCP’s response and each of the cited references. References C332, C333, 

and C347 address the physical characteristics of the waste, while P006, P009, and U042 address 

waste packaging and records related to radiological characterization of the waste. P023 

addresses chemical components (lead) in the waste. 

INL-CCP assessed the characteristics of the waste stream to determine whether the composition 

of the waste stream generated from 1990–1995 is physically similar (C332, C333). This analysis 

showed that for the wastes examined, on average the containers consisted of approximately 79% 

inorganic waste (non combustible) and 21% organic waste (combustible) (noting that individual 

containers may be highly variable). Reference C347 is dated 1976 and states that wastes were 

segregated into combustible and non combustible material at that time, due to radiolysis 

concerns, so there is evidence to suggest that procedures required waste separation very early in 

the program. While no other written references were prepared by INL-CCP that summarize their 

assessment of pre-1990 waste, INL-CCP presented its analysis in interviews with the EPA 

inspection team member(s). INL-CCP representatives indicated that prior to 1984, waste form 

was identified only as “combustible” or “non-combustible”, with no other additional descriptors. 

INL-CCP representatives also indicated that between 1984 and 1990, more detailed descriptions 

could be found, but upon examination, each data sheet showed that the site identified nearly the 

same waste contents for each container. Therefore, INL-CCP representatives felt that only post1990 data were of sufficient detail to support the detailed analysis that was presented in C332 

and C333. EPA examined the references provided (e.g., U022) and agrees that available 
19

information is not amenable to detailed physical drum content assignment for drums generated 

prior to 1990. INL-CCP indicated, during interviews, that it had compared the number of 

containers identified prior to 1984 as being combustible or noncombustible and compared that to 

the detailed analysis. Pre-1990 containers were approximately 75% noncombustible and 25% 

combustible, which agreed with INL-CCP’s detailed analysis of the post-1990 waste 29% 

combustible, 71% noncombustible). The WCPIP allows the assumption to be made that all 

debris waste containers are filled with plastic, so detailed identification of RH WMPs for the 

purposes of WWIS input is not required. However, according to EPA regulations, assessment 

and documentation of physical and chemical WMPs are necessary to ensure that the waste 

stream is appropriately assigned. 

Radiological data pertaining to content of waste drums is addressed in several documents, 

including those referenced by INL-CCP in the response to EPA’s comments on the AK 

procedure as well as EDF-6946 and EDF-6685. EDF-6685, Appendix A, presents the 

radiological composition (Pu and 235U) for each fuel pin identified by INL-CCP. In general, 

EPA’s examination of EDF-6685 showed that 72% of the identified pins contain both Pu and U, 

with 28 percent containing only 235U. EPA also examined available data (EDF-6685 and EDF6946) for each waste lot to ensure that each lot and therefore each drum contained TRU material 

as identified through AK. EPA’s evaluation showed that for Lots 0–208, at least one fuel pin 

containing both Pu and U is associated with each lot, verifying that some level of Pu could be 

expected in each drum based upon available AK. These documents did not fully address EPA’s 

concerns regarding radiological contents of waste drums reported in AK documents. EPA, 

therefore, conducted additional interviews with INL-CCP AK personnel to understand and assess 

how data are used to develop the gross radiological characteristics of the waste and radiological 

components within the waste and assign the waste stream designation with respect to 

radiological constituents. These interactions assisted EPA in determining that the waste stream 

was appropriately assigned and its radiological contents were reported. 

To further evaluate whether the waste stream was appropriately assigned from a radiological 

perspective, EPA examined the AK-identified radionuclide (i.e., Pu and 235U) ratios found in the 

AK records with EDF-6685 to assess common elements between waste streams. This evaluation 

showed that the Pu/U ratio for Lots 1–20 varied by two orders of magnitude, i.e., 0.06 to 1.389

. 

INL-CCP identified additional data in EDF-6946 that were not included in the fuel pin and lot 

assignments presented in EDF-6685. Inclusion of the values from EDF-6946 tightened the 

Pu/235U distribution such that 21 of the 25 lots and sub-lots examined in EDF-6946 had Pu/235U 

ratios between 0.4 and 0.85, with three values above 1 (Lots 2, 10, and 16) and one value below 

0.1 (Lot 11). The purpose of this analysis was to assess the common elements of the 

radionuclide content among specific wastes based on available data, and it was not intended as a 

measure of expected waste content. This examination showed that when additional INL-CCP 

data are taken into account, the waste stream exhibits a similar radiological content. 

 8

 In some cases Lots 0-20 were subdivided into Sub-lots, resulting in a total of 25 groupings. 

9

 This estimate is based solely on AK Lot Records, not on individual fuel pin data. However, individual fuel 

pin ratios presented in EDF-6685 show a similar Pu/235U distribution for pins containing both 235U and Pu, i.e., 

0.007 to 0.49. 
20

INL-CCP personnel were interviewed to understand their perspective on AK determination of 

radiological constituents in each drum as assigned through AK. Additional references (C348 and 

C350) were provided during the interview to clarify INL-CCP’s position. INL-CCP personnel 

indicated that drum-specific radiological data are available for each container (C348), these data 

confirm EPA’s assessments that AK indicates each drum would contain TRU material, and the 

Pu/U ratios are equivalent to the ranges identified by EPA. However, INL-CCP also pointed out 

that the type of radiological data available for each drum is highly variable and that many 

identify only the 235U and Pu (presumably 239Pu) content. INL-CCP identified several additional 

fuel pins and other information that may conflict with this AK information on a drum-by-drum 

basis. EPA agrees that there are uncertainties associated with the historic drum-specific 

assignments made by ANL-E, but the overall data show that the waste consists of materials that 

are similar with respect to radiological content. EPA concludes that the available data indicate 

that the waste stream is appropriately assigned from a radiological perspective. This approval 

applies only to the waste stream examined during this inspection. Specifically, it applies only to 

the waste stream as specified in AK documentation for Lots 1–20 that the EPA inspection team 

reviewed, and does not apply to wastes that originated outside of the AGHCF, e.g., K Cell. Any 

new waste stream(s) or additions or modifications to INL Waste Stream No. ID-ANLE-S5000 

Lots 1 through 20 is a T1 change. (See Table 1, where this is included as a T1 change.) 

Status of Concern: Based on the information examined, the EPA inspection team determined 

that the waste stream has been appropriately defined with respect to physical characteristics. 

This concern is also addressed under (4), below. Based on the discussions presented above, EPA 

considers this concern closed. 

(2) The identification of high-level waste (HLW), TRU versus low-level waste (LLW), and spent 

nuclear fuel (SNF) was examined. 

CCP-AK-INL-500 indicates that SNF is separated from the RH debris waste that was generated 

through testing of this fuel and is therefore not included in this waste stream. INL-CCP 

representatives interviewed indicated that HLW, by definition, is not included in this waste 

stream. See item (16), below, for a discussion of load management. 

(3) The detailed AK-based drum analysis process introduced in CCP-AK-INL-500 for drums 

728–737 was examined. 

The WCPIP requires that as much container-specific information as possible be assembled 

(Attachment A, Section 5.2). While a large quantity of detailed information for wastes has been 

assembled (much of which is drum or lot specific), INL-CCP did not perform detailed analyses 

of each item to develop AK-based drum radiological values. INL-CCP, however, did examine 

and present an analysis performed on a subset of these containers. 

The examined references, P030, P590, P591, P592, P593, P594, P595, and P596, document a 

detailed data assembly and analysis activity designed to assess and assign drum-specific 

radiological values based on AK and related calculations/modeling. The process also underwent 

peer review. The analysis was performed in 2002–2003 for a 10-drum population (Drums 728–
21

737) from Lot 1610, generated from 1990 to 1991. The approach focused first on determination 

of isotopic values for each drum based solely on the AK record, with modeling and other data 

manipulation or calculations performed to acquire the additional radiological data required in the 

WCPIP. Examination of records for these 10 drums was performed to determine actual waste 

contents provided pre- and post-irradiation fuel element compositions. Ultimately, these efforts 

resulted in the identification of fuel element compositions (pre- and post-irradiation values) and 

identification of 234U, 235U, 236U, 238U, 238Pu, 239Pu, 240Pu, 241Pu, 242Pu, 241Am, and 237Np. Postirradiation compositions were sometimes evaluated via computer code (BURNOUT, ORIGEN). 

The effort resulted in assignment of radionuclide compositions to the 10 examined containers, 

and several supporting references further document the approach used to generate “actual” 

radionuclide values based on AK (P590, P591, P592, P593, P594, P595, and P596). 

These documents show that detailed analyses of AK data assembled for each drum can be 

performed to determine, in some detail, the estimated radiological content of each lot, 

recognizing that the process to develop an accurate and complete picture requires analysis well 

beyond that performed by the generator site, ANL-E (see item (1), above, and reference C350). 

This activity is also an alternative approach to characterizing waste based on the AK record that 

does not use DTC in the manner currently proposed by INL-CCP, but instead uses various 

calculations and modeling efforts to determine values for the individual waste drums. INL-CCP 

has indicated, and EPA agrees, that this approach is time consuming (e.g., two years for 10 

drums alone), and various assumptions and questions may still remain that could bring 

considerable uncertainty to this approach (see reference C350). This alternative approach has 

not been used at INL–CCP; therefore, EPA did not evaluate it in depth. 

(4) Sufficiency of the AK summary was evaluated, as well as implementation of AK as required 

in Attachment A of the WCPIP. 

Attachment A of the WCPIP specifies that the following be included in AK summaries: 

• Executive summary 

• Waste stream identification summary 

• AK data and information description 

• Program information 

• Waste stream information 

• Qualification of AK information 

• Container-specific information 

Attachment A presents a process to collect and analyze data similar but not identical to what is 

used for CH waste that should be followed. Both the content of the AK summary and 

sufficiency of AK implementation were assessed. Note that based on the EPA requirements, the 

DQOs will require revision to include identification and quantification of the 10 EPA WIPPtracked radionuclides in CCP-INL-CCP-AK-500. The AK summary was found to not 

adequately address several issues, including the data assembly process, and these were combined 

 10 The intent is to reference a discreet number of containers (Drums 728-737) that the EPA inspection team 

thought were designated as Lot 16; however, these containers may in fact have a different lot designation. 
22

and recorded on one EPA Inspection Issue Tracking Form. (See Attachment B.4 of this report 

for this form.) This concern is also discussed under item (1), above, and is presented below in 

four parts: 

 

EPA Inspection Concern No. INL-CCP-RH-AK-06-005CR, Part 1, DQO and AK 

Qualification11: Attachment A of the WCPIP requires that for each DQO related to AK, AK 

personnel must identify the DQO and supporting AK information, justify the 

assignments/conclusions, reference the AK source documents and applicable pages supporting 

the assessment, and identify the qualification method in 40 CFR 194.22(b) that will be used to 

qualify the AK. 

Resolution: INL-CCP responded to EPA’s concern by revising Chapter 6 of CCP-AK-INL-500, 

Revision 3, to state that a "combination of methods" will be used to qualify AK information. 

Table 6 was added which presents the AK qualification method for each DQO. Table 6 shows 

that there is no qualification method for AK-derived defense determinations, consistent with the 

WCPIP and the fact that defense determination is based entirely upon AK and may not be 

qualified by measurement. 

Status of Concern: Upon reviewing INL-CCP’s response, EPA closed this part of the concern. 

EPA Inspection Concern No. INL-CCP-RH-AK-06-005CR, Part 2, Identification of 

Inundated Drums: EPA’s concern was that the AK summary implies that some containers in 

this population may have been submerged in a few of the vaults. The AK summary states that 

none of the approximately 70 containers whose videotapes were reviewed during VE were 

inundated, while others may have been. The discussion does not clearly indicate the total 

number of drums in the stream, the number of drums suspected of having been inundated, and 

how the inundated drums will be handled or otherwise managed. 

Resolution: INL-CCP responded to EPA’s concern by indicating that several drums were either 

submerged in vaults or showed evidence of having been submerged, thus indicating that there 

could be water present in these containers. INL-CCP revised the AK summary to state that of 

the 549 drums in the waste stream, 34 were either retrieved from water in the vault, retrieved 

from a vault that once contained water, or exhibited evidence that the drums were exposed to 

water. These 34 will undergo radiography to ensure that the drums have not been inundated with 

water. EPA expects that INL-CCP will tag and segregate drums in these categories for additional 

analysis. EPA also expects that radiography will be used to ensure that containers do not include 

any prohibited items, including liquids. 

Status of Concern: EPA will evaluate INL-CCP’s confirmation of the absence of water in these 

34 drums and other “suspect” drums when EPA inspects the use of radiography for INL-CCP’s 

RH WC program. EPA considers this part of the concern to be closed. 

EPA Inspection Concern No. INL-CCP-RH-AK-06-005CR, Part 3, Documentation of 

Defense Determination and Waste Stream Justification: Documentation for the waste’s 

 11 AK Qualification is the term used in the WCPIP, Revision 0D. Using DTC, INL-CCP is confirming AK and 

not qualifying AK in lieu of NDA, a measurement technique used for CH TRU waste. 
23

defense determination was not included in the records the EPA inspection team evaluated, and 

these records did not provide information that clearly supported the waste stream definition. 

Specifically, they did not fully document the basis for INL-CCP’s contention that the wastes 

generated in the cells were never segregated by fuel pin or generator, thus precluding INL-CCP 

from assigning a fuel pin or radionuclide specific content to individual waste containers. This is 

of key importance since it supports INL-CCP’s approach to assigning the radiological 

characteristics of the fuel pins to the entire population. 

Resolution: In response to EPA’s concern, INL-CCP revised the AK summary to include 

Table 6 listing AK source documents that INL-CCP uses to support the defense determination. 

As written, CCP-AK-INL-500, Revision 3, implies that many nondefense activities were 

performed at ANL-E and these activities generated wastes. INL-CCP stated that since some 

defense activities occurred at ANL-E and the wastes from these activities are commingled with 

the nondefense waste, all commingled waste is defense related. While CCP-AK-INL-500 does 

not clearly show that defense-related activities occurred early in the process, INL-CCP 

representatives pointed out that the defense-related activities were performed in the AGHCF 

throughout the time that waste was generated in the hot cell. 

Status of Concern: Based on the information INL-CCP provided and the subsequent 

discussion, EPA determined that this part of the concern is closed. 

EPA Inspection Concern No. INL-CCP-RH-AK-06-005CR, Part 4, Inclusion of Additional 

Radiological Data: The radiological data presented in the AK summary do not present a good 

understanding of the overall isotopic distributions that are applied to Waste Stream No. 

ID-ANLE-S5000 based on AK. While CCP-AK-INL-501 presents how each container is 

assessed, the AK summary in CCP-AK-INL 500 should still include a general discussion of the 

overall anticipated distribution on a waste stream basis, particularly since AK is used to address 

all DQOs. Page 40 presents information for drums from 1990–1995, but more information 

should be included for the entire waste stream. 

Resolution: INL-CCP responded to EPA’s concern by modifying CCP-AK-INL-500, 

Revision 3, Section 5.4.2.1, to include text and Table 5 that summarizes the reported radiological 

content of waste drums as reported by ANL-E. The text of the AK summary was also revised to 

state that “...the radionuclides reported by ANL-E varied significantly over the time period of 

waste shipment to INL, which is reflected in Table 5.” 

Status of Concern: Based on the information INL-CCP provided and the subsequent 

discussion, EPA determined that this concern is closed. EPA requires that INL-CCP notify EPA 

through a T2 change notice that CCP-AK-INL-500 has been revised or updated to include 

radiological and other information obtained through verification. Consistent with EPA’s 

authority under 194.24(h), EPA may request this information if EPA deems it necessary to 

ensure continued compliance with EPA regulations. (See Table 1 where this is included as a T2 

change.) 
24

 (5) Data traceability was examined. 

Traceability of data was assessed on various levels. Data traceability from the AK record to 

waste drum or waste lot content was assessed and is addressed herein. Note that there are 617 

drums of waste, 549 of which originated in the AGHCF. INL-CCP did not examine the other 68 

drums of waste, so they are not included in this waste stream nor are the post-1995 drums, which 

number 50–100 according to INL-CCP. When INL-CCP adds any of the 68 drums from the pre1995 time period or those generated since 1995, EPA will review this new information added to 

the AK for debris waste evaluated during this inspection as a T1 change, as discussed above. 

(See Table 1, where this is included as a T1 change.) 

 

Because the fuel pins contribute directly to the radionuclide content in waste generated through 

analysis of these pins, fuel pin data traceability was performed to understand the types of data 

available for each fuel pin. Data for Index Nos. 297 (AG 421E), 293 (AG 421A Fuel Element 

UBA-15) and 311 (AG 429A) were chosen for examination of data and traceability, and this 

information is also included in EDF 6685. Available data for each fuel pin includes: the Fuel 

Element Summary Sheet for ANL fuel pins prepared by INL-CCP; weight, radiological, and 

other data from the origination site; safeguards and materials management report data; individual 

pin burnup calculations; and fuel composition by AG or fuel pin number. Data for each fuel 

pin/index number may not be the same, but INL-CCP has attempted to collect all available data 

regarding each fuel element and summarized the available information. 

AK data traceability for Waste Can Inventory Sheets and Waste Package Data Sheets provided 

for Drum Nos. 00739, 00740, 00741, 00742, and 00743 was also examined. These sheets 

present general waste content information and measurement data, but do not provide isotopic 

information. Radionuclide information is conveyed upon Loss or Gain of Materials forms 

(SPM-23) and Fuel Element Listings that provide the fuel elements/waste lots and ultimately 

estimate the Pu and 235U quantities per drum in grams. Note that the AK summary states that 

once the Pu value per drum was obtained, “...the isotopes 239Pu, 240Pu, and 241Pu were calculated 

by multiplying the total value by a percentage to obtain the grams of each.” INL-CCP states that 

the values from 1990–1995 showed a relatively consistent distribution, and provided reference 

C348 that summarizes assembled radiological data for each. Several references (e.g., EDF-6685) 

include drum or lot-specific data. Based on this analysis, the traceability of available 

information for both fuel pins and drum/waste lot contents was demonstrated. 

(6) Sufficiency of AK support documents and related document tracking was evaluated. 

An AK Source Document Reference List was prepared using unique identifiers for the different 

document types following the format used by INL-CCP for CH wastes. The listing provided is 

based on CCP-TP-005 Revision 17, Attachment 4, and is dated June 13, 2006. The listing 

appears complete, and is easy to understand because it follows the same format that INL-CCP 

uses for CH waste streams. Several AK support documents were referenced in the text; those 

references examined to date address the element or issue that is referenced with the AK 

summary, although applicability does vary. It should be noted that EPA only examines support 

documentation specific to the technical element being referenced in the AK summary that caused 

that support reference to be selected for examination. If any information is added to either 
25

CCP-AK-INL-500 or CCP-AK-INL-501 that modifies the characterization approach or changes 

the understanding of radiological or physical content of wastes in the stream as currently defined, 

this would be considered a T1 change. (See Table 1, where this is included as a T1 change.) 

(7) Interpretation of WCPIP, with respect to contents of the Certification Plan and Confirmatory 

Test Plan (CTP) was evaluated. 

EPA’s RH WCPIP Framework approval letter indicated that sites must generate a Certification 

Plan that explains how RH waste characterization will take place at each site, as well as a CTP, 

when required. EPA’s intent was that the sites present how characterization is to take place on a 

waste stream basis, followed by a detailed plan explaining implementation of confirmatory 

testing when this is to take place. INL-CCP personnel interviewed had different interpretations 

of some aspects of the WCPIP, and hence different opinions as to what the Certification Plan 

should contain versus the CTP. EPA understands how this has occurred, as the WCPIP lends 

itself to different interpretations. EPA learned during the inspection that INL-CCP intends to use 

AK qualification for every DQO possible, and that they intend to prepare a CTP for each waste 

stream that describes, in detail, how that waste stream will be characterized including 

qualification methods (e.g., Peer Review) other than confirmation. EPA noted that “where” the 

detailed waste stream characterization process is presented should be clarified, and recorded 

these issues on EPA Inspection Issue Tracking Forms, as discussed below (see Attachments B.5 

and B.6, respectively, for these forms). INL-CCP-RH-AK-06-006CR is also discussed under 

item (15), below. 

EPA Concern Nos. INL-CCP-RH-AK-06-006CR and INL-CCP-RH-AK-06-007CR: 

Specifically, EPA’s concern in INL-CCP-RH-AK-06-006CR was that INL-CCP representatives 

stated that AK qualification will always be the approach used to meet DQOs. As such, INL-CCP 

will always prepare an AK CTP for each waste stream that presents a description of each DQO. 

The CTP must be revised to indicate that AK qualification is the selected DQO determination 

methodology for each DQO and to specify the qualification pathway selected, including a 

detailed discussion of confirmatory methods used. Based on EPA requirements, the DQOs will 

require revision to include identification and quantification of the 10 WIPP-tracked 

radionuclides. 

EPA Concern No. INL-CCP-RH-AK-06-007CR was based on the fact that INL-CCP 

representatives indicated that AK qualification will be the method by which DQOs will always 

be addressed. Based on this, EPA expects INL-CCP to examine site documents that discuss the 

characterization methodologies to ensure that each reflects the requirements presented in the 

WCPIP when AK qualification is used. For example, the WCPIP requires that [the] certification 

plan include how the DQOs will be addressed, and EPA indicated that this should include waste 

stream information. INL-CCP representatives indicated that a CTP will be prepared for each 

stream and will include this information. Therefore, EPA expects INL-CCP to ensure that this 

commitment is clearly cited in related documents such that the CTP always fulfills this 

requirement. Note that based on EPA requirements, the DQOs will require revision to include 

identification and quantification of the 10 WIPP-tracked radionuclides. 
26

Resolution: INL-CCP responded to EPA’s concerns by recognizing the conflicting requirement 

of providing detailed information in the Certification Plan (per EPA’s letter) versus their intent 

of including this information in a CTP. INL-CCP combined the CTP and Certification Plan 

(CCP-AL-INL-502, Revision 2), and included in this plan their intent to qualify almost each 

DQO using AK qualification. Chapter 1 of CCP-AK-INL-502, Revision 2, states that 

“Acceptable Knowledge will be used to document that each RH TRU waste Data Quality 

Objective (DQO), with the exception of the payload container based parameters, have been met.” 

Chapter 4 addresses the methodologies for the determination of DQOs. EPA acknowledges that 

each of the DQOs will be verified through the application of radiological characterization and 

VE/RTR. Payload container-based parameters such as the Land Withdrawal Act (LWA) limit 

of 23 curies per liter will also be determined via radiological characterization. 

INL-CCP created Revision 17 of CCP-PO-002 to address this modification. These modifications 

have adequately addressed the requirement to clarify that AK data is the source of all but one 

DQO, and there are various methods to verify the AK. Note that the document makes a single 

mention of the QA equivalency determination used to verify ORIGEN2.2 using the LANL mass 

spectrometry data. The technical aspect of this element was determined to be adequate by EPA 

(see Section 8.2). CCP-AK-INL-502 has been modified to state that the 10 WIPP-tracked 

radionuclides are to be identified and reported, but does not specifically state that they will be 

quantified. The approach discussed in CCP-PO-002 adequately addresses EPA’s concern. As 

INL-CCP adds new waste stream to AK or if the current plan is revised, EPA expects that INLCCP will prepare or revise the Certification/Confirmation Plan to address each waste stream. 

Changing the current plan for the approved waste stream is a T1 change. (See Table 1, where 

this is included as a T1 change.) 

Note that the revised Certification Plan, provided in response to EPA’s concern, has numerous 

changes that appear unrelated to this concern; EPA has not reviewed these changes for adequacy 

at this time. EPA notes that revisions to the WCPIP have been proposed. EPA requires that 

INL-CCP notify EPA through a T2 change notice if implementation of this revised WCPIP 

results in changes to the INL-CCP documents. Consistent with EPA’s authority under 194.24(h), 

EPA may request these revisions if EPA deems they are necessary to ensure continued 

compliance with EPA regulations. (See Table 1 where this is included as a T2 change.) 

Status of Concern: Based on the above discussions, EPA considers these concerns to be closed. 

(8) Content and technical adequacy of the Confirmatory Test Plan was evaluated. 

The WCPIP requires the following to be included in the Confirmatory Test Plan (CTP): 

• A description of the waste stream or waste stream lots to which the plan applies 

• A description of the confirmatory testing proposed, including the percentage of waste 

containers that will be subject to confirmatory testing 

• An explicit description of the waste characterization DQOs and QAOs that will be 

satisfied with the data being qualified 
27

• A description of the DQOs and QAOs that will not be confirmed with the data being 

qualified and an explanation of how compliance with those DQOs and QAOs will be 

demonstrated 

• A description of how the tested subpopulation will be representative of the waste stream 

or waste stream lot 

INL-CCP revised the CTP in response to EPA comments (see item 7, above). The revisions 

presented the proposed characterization plan for individual waste streams, and now is a 

combined CTP and Certification Plan. The revised CTP includes the required technical elements 

presented in the above listing. The requirement identifying the percentage of containers that 

undergo confirmatory testing is confusing because none of the actual containers at INL will 

undergo confirmatory testing. Instead, CCP sought to demonstrate that drums containing fuel 

pins that were assayed by mass spectrometry (MS) at LANL are comparable to the wastes at 

INL. The MS data would be qualified by the determination of an equivalent QA program, and 

the 400 pins that were assayed by MS would be considered to have undergone confirmatory 

testing. Physical form and residual liquid confirmation is achieved through 100 percent VE or, 

at a later date through radiography. This description is accepted as meeting the requirement 

presented in bullets 1 and 5, and the technical adequacy of the information and conclusions is 

addressed in Section 8.2.4. 

The revised CTP also addresses DQOs, and has a new section that deals with AK QAOs and 

application of AK accuracy. See item 15 for technical evaluation of this information, noting that 

inclusion of AK accuracy determinations under the DQO for Defense Determinations is 

inappropriate and the information should be included elsewhere or in a stand-alone section. The 

adequacy of DTC with respect to addressing related DQOs is addressed in Section 8.2.2. 

(9) Content and technical adequacy of the Characterization Reconciliation Report was evaluated. 

EPA evaluated CCP-TP-506, Revision 1, CCP Preparation of the Remote-Handled Transuranic 

Waste Acceptable Knowledge Characterization Reconciliation Report, to determine whether this 

document reflected the assembly of information required in the WCPIP. Additionally, EPA 

evaluated the Characterization Reconciliation Report (CRR) to see whether this report reflected 

requirements of CCP-TP-506, to ensure that the CRR addressed requirement elements as 

specified in the WCPIP, including: 

• Specification of applicable site and waste stream 

• A listing of each DQO 

• Data from the AK record that addresses each DQO 

• AK source document references that support/provide the data 

• A listing of AK record discrepancy resolutions, if any, that are relevant to each DQO 

• Documentation, including specific references, of how the AK data for each DQO were 

qualified, such as batch data reports, corroborative data, proceedings of a peer review, 

etc. 
28

• Radiography and/or visual examination summary to document that liquids greater than 

1 percent are absent from the waste and to confirm AK concerning the physical properties 

of the waste 

• A summary presentation of radiological measurement data used to meet the DQOs and to 

confirm AK 

• A complete AK summary 

• A complete listing of all container identification numbers used to generate the WSPF, 

cross-referenced to each batch data report 

• A listing of AK discrepancies generated by an AK qualification process and the 

corresponding resolutions 

• Signature of the SPM 

The example the EPA inspection team examined included all of the above requirements when 

taken as a whole. The CRR DQO worksheet (Attachment 3 of CCP-TP-506) lacks a listing of 

the 10 WIPP-tracked radionuclides as part of the DQO assessment process, and these 

radionuclides need to be specified, quantified, and assessed as part of the CRR. Site 

representatives declined to specifically address these because the WCPIP does not specifically 

require this inclusion, but EPA’s rule specifies de facto limits for the ten WIPP-tracked 

radionuclides based on modeled quantities. Therefore, EPA expects that INL-CCP include these 

radionuclides in the DQO analysis. EPA requires that INL-CCP notify EPA through a T2 

change notice upon completion of the CRR with related changes and the revised Waste Stream 

Profile Forms (see item (14), below). Consistent with EPA’s authority under 194.24(h), EPA 

may request this information when EPA deems it necessary to ensure continued compliance with 

EPA regulations. (See Table 1 where this is included as a T2 change.) 

(10) Use of a Correlation and Surrogate Summary Form was evaluated. 

Completion of a Correlation and Surrogate Summary (CSS) Form is required when AK 

information from a related CH waste stream is used in the RH waste characterization process. 

INL-CCP representative indicated that CH data was not used in this manner. However, a CSS 

was completed to support the use of LANL mass spectrometry data to verify ORIGEN2.2 model 

that is used to generate INL data. The use of a CSS for this purpose is satisfactory, but does not 

discuss why the form is required, e.g., in this case to allow use of destructive assay data 

performed on LANL fuel pins as representative or correlated to similar fuel pins at INL. If 

containers from this waste stream are ultimately determined to be CH waste and are segregated, 

NDA will be performed on these wastes. Data from the CH wastes would be available for 

comparison with the isotopic ratios applied to the waste stream under the RH radiological 

characterization protocol. According to INL-CCP’s approach observed during this baseline 

inspection, when this occurs the information will be documented on a CSS Form. In the 

proposed decision EPA required that INL-CCP provide this information under T2 change notice 

process. EPA received a comment objecting to obtaining this information as a T2 change. (See 

Attachment C, Comment No.10). Upon review of the comment EPA concurs with the reasoning 

provided by the Commenter and EPA agrees with the Commenter. (See Attachment C for the 

EPA response to Comment No. 10). EPA is requiring that INL-CCP notify EPA through a T2 
29

change notice regarding the inclusion of isotopic ratios obtained from NDA of a CH waste 

stream that was previously considered to be RH as a T2 change. Consistent with EPA’s 

authority under 194.24(h), EPA may request this information if EPA deems it necessary to 

ensure continued compliance with EPA regulations. (See Table 1 where this is included as a T2 

change.) 

(11) Personnel training was evaluated. 

Training records for Kevin Peters (AKE), Steve Schafer (AKE), Lisa Price (AKE), Larry Porter 

(SPM), Michael Walantine (SPQAO), and Jene Vance (SME) were evaluated with respect to: 

training to the RH TRU WCPIP; non conformance and corrective action processes; the AK 

procedure presented in Attachment A of the WCPIP; site-specific training relative to the contents 

of the subject waste stream(s); and determination of radiological contents of individual drums. 

Each person demonstrated training in the first four areas. With respect to determination of 

radiological contents of each drum, only Jene Vance’s expertise was examined since he 

assembled and assessed AK data that were used to derive the scaling factors. Although Mr. 

Vance did not show direct training with respect to this area, his resume showed considerable 

expertise suitable to demonstrating proficiency. 

(12) AK traceability of LANL mass spectrometry information and information/data 

relationships were examined. 

INL-CCP has proposed the use of mass spectrometry data obtained from LANL to verify the 

output of the ORIGEN2.2 for INL data. INL-CCP contends that the LANL and INL (ANL-E) 

pins have similar origins, overlapping experimenters, similar if not the same reactor irradiation 

or sources, and therefore have sufficiently similar radionuclide content, so the use of LANL data 

for this purpose is appropriate. Of the 506 fuel pins identified, approximately 62% are 

associated with EBR-II, and the rest are from various reactors, i.e., Unirad and Shippingport. 

Most fuel pins are from the Fast Breeder Fuel program, although some were also from light 

water and other reactor types. Specifically, INL-CCP states that: “Mass spectrometry results for 

a total of 400 fuel pins were located and retrieved. The mass spectrometry measurements were 

conducted under a QA program which has been evaluated to be equivalent ...to NQA-1 and, 

therefore, these data are acceptable as AK information.” INL-CCP also states that “...On the 

basis of the similarities between the two fuel pin examination programs, the fuel types, the 

sources of the pre-irradiation fuel composition and burnup information, and the identical reactors 

for a majority of the fuel pins, the LANL confirmatory sampling is sufficient to satisfy the 

qualification required for the INL AK information.” EPA found that the above statement 

required additional references to support the assertions and issued an EPA Inspection Issue 

Tracking Form (see Attachment B.7 for this form). This concern is discussed below. 

EPA Concern No. INL-CCP-RH-AK-06-008CR: EPA’s concern was that CCP-AK-INL-501 

includes several statements, assumptions, and arguments that lacked references to calculations or 

other information to support the arguments. In particular, several other documents (CCP-AKINL-500, CCP-AK-INL-502, etc.) state that CCP-AK-INL-501 shows that LANL and INL fuel 

pins had many common elements. The brief discussion on page 33 states that: “On the basis of 

the similarities between the two fuel pin examination programs, the fuel types, the sources of the 
30

pre-irradiation fuel compositions and burnup information, and the identical reactors for a 

majority of the fuel pins, the LANL confirmatory sampling is sufficient to satisfy the 

qualification required for the INL AK information.” However, the document does not cite 

references or other detailed information to support this assertion. The document provides charts 

and other comparisons between pins and INL fuel pins, but the specific INL fuel pin numbers 

and related data and calculations are not referenced. Table 5-1 presents a summary of sponsors 

associated with ANL-E and LANL pins, but of the top three sponsors for LANL and ANL-E, 

only one was common to both. Additional information that better supports the commonalities 

between the two sites in the text of CCP-AK-INL-501 is necessary, e.g., the 33 calculation 

packages that support the development and application of ORIGEN2.2. The documentation 

lacked a strong link between the INL and LANL fuel pins. Accordingly, EPA was unable to 

confirm the findings and results. 

Resolution: INL-CCP responded by adding references to the calculation packages, as well as by 

adding text and a table to Section 5.0 in CCP-AK-INL-501. This information presented 

experimenters common to LANL and INL, and locations of fuel pins to show that seven of the 

experiments involved in the fast breeder program were conducted at both ANL-E and LANL. 

INL-CCP’s description, however, does not clarify whether these fuel pins also had MS data 

associated with them. 

Status of Concern: The relationship established by INL-CCP for the LANL and INL pins is 

sufficient. EPA considers this concern to be closed. 

INL-CCP found seven different experimenters who shipped fuel pins to both LANL and INL for 

examination. Two of the seven experimenters sent more than one PIN/AG to each, so a total of 

nine fuel pins were common to LANL and INL. The fuel pins identified were examined during 

creation of waste Lots 2, 3, 7A, 7C, and 8B; all but one of the fuel pins were irradiated at 

EBR-II. Upon interview, it was determined that the above analysis is the most significant 

traceability identified by INL-CCP between the INL (ANL-E) and LANL fuel pins. While the 

data do show that there are at least seven individual experimenters common to both sites, it does 

not show that the LANL MS data were common to pins at both LANL and INL. It is understood 

that a majority of fuel pins associated with both sites were irradiated at EBR-II, and would 

therefore have a common isotopic signature. INL-CCP has not directly established that the fuel 

pins with MS data are equivalent to or representative of LANL fuel pins or a significant 

population thereof, and that these fuel pins are “equivalent” to or representative of the INL fuel 

pins (in whole or in part). It should be noted that the MS results are used to verify the 

ORIGEN2.2 output and are not used as direct input to any of the adjustments or scaling factors 

for INL RH waste. Therefore, establishment of this relationship in the manner presented by 

INL-CCP is sufficient, since the MS data are not directly used in the INL calculations other than 

to verify the model. Note that this analysis does not address the graphic presentation of data 

representativeness shown in Chapter 5 of AK-INL-CCP-501; evaluation of these presentations is 

presented in Section 8.3 of this report. 

It must also be pointed out that INL-CCP makes the basic assumption that material from all fuel 

pins may be present in every waste container. INL-CCP bases the analysis presented in 

AK-INL-CCP-501 upon this assumption, and builds the remainder of the analysis on fuel pin 
31

commonalities. EPA’s examination showed that each lot contained material from pins that were 

irradiated by EBR-II and, assuming that EBR-II imparted a common radiological signature, each 

waste lot has this common thread, thus supporting INL-CCP’s contentions regarding common 

radiological constituents. However, INL-CCP proposes a “waste stream” rather than a “waste 

container” approach that is applicable only for this RH waste stream. 

(13) Non Conformance Reports (NCRs) and Discrepancy Resolution (DR) Forms were 

examined. 

NCR-RHINL-0004-06 is among those provided to EPA to assess documentation of NCRs. 

Unfortunately, this NCR did not include enough information to determine the reason for the 

NCR. Discrepancy Resolutions (DR) DR11 and DR10 were also provided for examination. 

DR11 addresses waste requisition and video discrepancies, while DR10 concerns a discrepancy 

regarding the volume of a 7-gallon waste can. This information suggests that INL-CCP can 

adequately prepare NCRs and DRs to document nonconforming items or containers, as well as 

the types of discrepancies presented for review. EPA was not provided a specific example of an 

AK-AK discrepancy resolution involving radiological composition of waste, although INL-CCP 

representatives indicated that drum/lot AK data had been assessed and was not called upon to 

provide an absolute or qualitative comparison on a drum or lot basis. EPA expects that INLCCP will include AK-AK discrepancies in the AK record as they are identified.

(14) A waste stream profile form was examined. 

An example Waste Stream Profile Form was examined for Waste Stream Number 

ID-ANLE-S5000. The form included required line items as presented in the WCPIP, 

Attachment 4; the CRR and RH AK summary are also required for submission to CBFO to allow 

assessment of the WSPF. EPA understands that this form is abbreviated because it was provided 

for audit purposes only, and expects that the completed form will include more AK data, 

checklists, etc., to better present the required information. See comments above pertaining to 

CRR and AK Summary for additional information. In the proposed approval, EPA required that 

INL-CCP submit this information to EPA through a T2 change notice. Instead, EPA is requiring 

that INL-CCP notify EPA regarding the availability of the completed, final WSPF with all 

related documentation, including any subsequent revisions to this approved WSPF, through a T2 

change notice. Consistent with EPA’s authority under 194.24(h), EPA may request this 

information when EPA deems it necessary to ensure continued compliance with EPA 

regulations. (See Table 1 where this is included as a T2 change.) 

(15) AK accuracy was assessed. 

AK accuracy was assessed with respect to the required contents as presented in the WCPIP. The 

WCPIP requires AK accuracy to be assessed in three areas: reassignment of the waste to a 

different Summary Category Group; reassignment of the waste to a different waste stream; and, 

stream-specific assessment of radiological parameter accuracy. AK accuracy of the first two 

parameters was adequately documented for the containers in the lot that were examined. 

INL-CCP stated that only one radiological DQO, comparison of survey results with AK data that 

classify the waste as RH, shall be a measure of AK radiological accuracy. However, if INL-CCP 
32

uses confirmatory testing for any radiological parameter, EPA expects that the evaluation of AK 

accuracy for that parameter will be performed. EPA presented this on an EPA Inspection Issue 

Tracking Form (see Attachment B.5 for this form) and it is discussed in item (7), above, as well 

as below. 

EPA Concern No. INL-CCP-RH-AK-06-006CR: This concern stated that the CTP includes 

the proposed approach for assessing [radiological] AK accuracy, which is only the verification 

that waste is RH as identified by AK. The CTP also assumes that the CCP-501 document has 

established “no significant discrepancies” between AK information and confirmation of 

modeling/sampling. However, this assumes that the LANL MS data are demonstrated to be 

applicable, and EPA has not fully assessed CCP-AK-INL-501, which presumably includes this 

information. Since AK qualification and confirmatory testing are used for all radiological 

parameters, it would appear that each radiological DQO should be evaluated with respect to how 

the confirmatory data collected will be assessed as part of AK accuracy (if this is not feasible, a 

detailed argument should be included). The accuracy report should be revised accordingly. 

Resolution: INL-CCP responded by revising CCP-AK-INL-502 to produce Revision 2 that 

addresses the determination of AK accuracy for the AK-based radiological parameters that are 

discussed below.

 

TRU Waste Determination: AK accuracy was determined in two parts. Part 1, isotopic 

abundance assessment, has already been completed, and CCP-AK-INL-501 states that there are 

no significant discrepancies between AK information used in the modeling and the qualification 

of that AK (modeling and sampling). Part 2 of the AK accuracy determination will be 

accomplished through measurement comparison against AK documentation that shows the waste 

as being TRU waste. EPA’s analysis of this with regard to Part 1 was that fuel pin data and 

related burnup are used in modeling, and the results of this modeling were verified by LANL MS 

data. INL-CCP does not address how the content of the drums with respect to TRU 

radionuclides as defined by AK will be compared to the ultimate radionuclide content assigned 

to that drum using the application of DTC/scaling factors. INL-CCP representatives contend that 

the AK-identified content is insufficient (see item 1 above and reference C350), although 

detailed analysis has been performed on a select waste drum population for which AK accuracy 

could be determined. In the proposed decision EPA identified a comparison of radionuclide 

values based on AK with radionuclide values derived by the application of the application of 

DTC/scaling factors as a T2 change. The Commenter objected to such a comparison. (See 

Attachment C, CBFO Comment No. 9). Upon review, EPA concurs with the reasoning provided 

by the Commenter and EPA agrees with the Commenter. (See Attachment C for EPA response 

to Comment No. 9). Upon completion of the final DTC determination for each of the RH 

containers numbers 728 through 737, as identified in AK Reference P030, INL-CCP must notify 

EPA that these determinations are complete through a T2 change notice. EPA may then request 

these results or other related data from INL-CCP in order to compare how the data sets compare. 

Consistent with EPA’s authority under 194.24(h) EPA may request new or additional 

information when it is necessary to ensure continued compliance with EPA regulations. 

Providing notification of the completion of the final DTC determination for each of these 

containers is a T2 change. (See Table 1, where this is included as a T2 change). 

 
33

RH Waste Determination: INL-CCP stated that AK accuracy will be determined by comparing 

the actual survey results with AK information identifying the waste as RH wastes. EPA agrees 

that containers where the external dose rate is less than RH levels because of radioactive decay 

of the container’s contents since collecting AK data should not be considered an actual AK 

discrepancy, and the AK-classified RH containers that are not currently RH whose status change 

cannot be attributed to decay alone on the basis of calculations would be considered against AK 

accuracy. 

Activity Determination: As with TRU waste determination, the Part 1 response deals with 

modeling input vs. MS data, not a comparison of the radionuclide content/quantities per drum as 

identified by AK compared to that assigned by DTC/scaling. AK confirmation and AK record 

comparison for activity determination will be accomplished in two parts. Part 1, isotopic 

abundance assessment, has been completed and INL-CCP states that there are no significant 

discrepancies between AK information used in the modeling and the qualification of that AK 

(modeling and sampling); this includes the “identification and reporting” of the 10 WIPP-tracked 

radionuclides. Part 2 is a comparison of the measurement results (curies per liter) with the LWA 

limit of 23 curies per liter. Containers with greater than 23 curies/liter based on DTC will be 

counted against AK accuracy. In the same manner as for TRU waste identification discussed 

above, EPA’s position is that INL-CCP’s Part 1 response deals with modeling input from the 

inventory (i.e., PIN data), compared to MS results after both have been input to ORIGEN2.2. 

The response does not address comparison of radionuclide content of the waste drums as 

identified through AK, recognizing that drums contain several different fuel pins that can have 

different U and Pu contents. The application of DTC/scaling essentially superimposes an overall 

isotopic distribution on the waste stream, regardless of whether AK has shown individual 

containers or groups of containers to be dissimilar. INL-CCP representatives have indicated that 

AK assembled by ANL-E has a number of assumptions associated with it, and is not an accurate 

representation of lot or drum contents, so an AK-DTC comparison would not be meaningful 

(reference C350). However, a detailed analysis has been performed on a select waste drum 

population and that information is useful for comparison purposes to verify the scaling factor 

approach used by INL-CCP. When RH containers numbers 728 through 737, as identified in AK 

Reference P030 (Lot 16) is characterized, EPA expects INL-CCP to notify EPA through a T2 

change notice. Consistent with EPA’s authority under 194.24(h) EPA may request this 

information if EPA deems it necessary to ensure continued compliance with EPA regulations. 

(See Table 1, where this is included as a T2 change). 

Status of Concern: Based on the discussions described above, EPA considers this concern 

closed. 

An example AK memo was presented, and the memo stated that the comparison between the 

modeling results using fuel pins and the ORIGEN2.2 and MS data show good agreement. Also 

please see the commentary above concerning the AK accuracy calculations. To date, only six 

containers have undergone complete characterization so meaningful accuracy calculations cannot 

be made. If future reports show accuracies less than 100%, EPA expects the report to address 

any accuracy issues that arise and how the containers in question have been managed. EPA 

requires that INL-CCP notify EPA when AK accuracy reports are completed and available for 

EPA evaluation through a T2 change notice. EPA expects that INL-CCP will complete these 
34

reports on a yearly basis, at a minimum. Consistent with EPA’s authority under 194.24(h) EPA 

may request these reports if EPA deems them necessary to ensure continued compliance with 

EPA regulations. (See Table 1, where this is included as a T2 change). 

(16) Load management was assessed. 

The possibility that containers may exhibit less than 100 nCi/g TRU was evaluated. AK data 

presented in EDF-6685 were evaluated to determine the average Pu drum value, understanding 

that this value is a gross estimate because additional data presented in EDF 6946 could impact 

the gram values. As such, the data were assessed only to evaluate the possibility that some 

containers may ultimately be determined to contain less than 100 nCi/g Pu (e.g., drums in 

Lot 11). Data suggested that INL-CCP may encounter containers that measure less than 

100 nCi/g, requiring the implementation of load management. However, INL-CCP 

representatives also indicated that a container would have to measure less than 10 mR/hr at 1 

meter to result in a TRU content less than 100 nCi/g using the scaling factors from 

CCP-INL-AK-501. At that point, INL-CCP personnel stated that the container would be 

considered CH and would be segregated for shipment in a different waste stream. Note that the 

CTP states, “In the rare event that a waste container might be 200 mrem/hr at its surface (and as 

such, RH waste), but less than 200 mrem/hr at the surface when three such containers are loaded 

into an RH-72B canister, the canister will still be considered RH waste as defined in the LWA.” 

EPA expects that every container emplaced in the canister will exhibit ≥ 200 mrem/hr prior to 

loading. If a container has a contact reading of less than 200 mrem/hr, the waste will be 

considered CH waste and will be removed from the waste stream. When such segregation is not 

considered and INL-CCP determines that a RH container is to be handled as CH waste, EPA 

requires notification of the decision to take these actions and the supporting rationale 

concurrently when the issue is first presented to CBFO. This is a T1 change. (See Table 1, 

where this is included as a T1 change). 

(17) Verification methods for each DQO were assessed. 

INL-CCP representatives indicated that all DQOs except for RH waste determination will be met 

through verification of AK, see item (7), above. INL-CCP indicates that confirmatory testing 

will be used for each DQO, but also implies that establishment of an equivalent QA program 

may be used when using the mass spectrometry data to verify the ORIGEN2.2 output. Revision 

of various INL-CCP documents to clarify that AK qualification will be performed for almost all 

DQOs is addressed in other parts of this section. 

(18) Attainment of DQOs was evaluated. 

As a result of the analysis presented in items (1)–(17), above, EPA was able to assess how each 

DQO will be addressed. The following DQOs must be addressed as per the WCPIP: 

- Defense determination 

- TRU waste determination 

- RH waste determination 
35

- Activity determination (TRU Alpha activity per canister, including quantification and 

identification of 10 WIPP-tracked radionuclides) 

- Residual liquids 

- Physical form, including metals and CPR 

All of these DQOs, except for RH waste and defense determination, are based on AK that is 

confirmed through various WCPIP-allowed techniques or variants thereof. RH status is 

determined through direct dose rate measurement. Defense determination is based on AK alone 

and cannot be confirmed. As indicated above, EPA required clarification regarding how DQOs 

would be met and, if done by AK, the specific confirmation pathway. As a result of information 

provided and EPA’s analysis of these data, EPA concludes that INL-CCP has adequately 

presented how DQOs will be obtained. 

Summary of AK Findings and Concerns

The EPA inspection team identified the concerns related to AK that are discussed above. Copies 

of the EPA Inspection Issue Tracking Forms are provided in Attachments B.4 through B.7. EPA 

considers all findings and concerns to have been adequately addressed and there are no open 

finding or concerns related to AK resulting from this inspection. 

AK Baseline Approval

EPA is approving the AK process evaluated during this baseline inspection. Specifically, the 

approval is limited to Waste Stream ID-ANLE-S5000 RH retrievably- stored debris waste, Lots 

1 through 20, consistent with the limitations described in CCP-AK-INL-500, Revision 3. 

AK Tiers 

Based on the inspection and the results discussed above, EPA assigns the following tiers: 

T1 AK changes that will require EPA review and approval prior to implementation and apply to 

any new waste category not evaluated during the baseline inspection include the following: 

• Any new waste streams not approved under this baseline (e.g., solids) 

• Modification of the approved waste stream ID-ANLE-S5000 to include additional 

containers, i.e. K Cell or other debris wastes. 

• Load management for any RH waste stream. 

• Substantive modifications that have the potential to affect the characterization process: 

CCP-AK-INL-500, Revision 2; CCP-AN-INL-501, Revision 1; or CCP-AK-INL-502, 

Revision 0 

T1 changes will be reported and documentation will be submitted when INL-CCP is ready for 

EPA review. Upon initial review, EPA will inform INL-CCP and CBFO whether a site 

inspection is necessary. EPA may request additional information, choose to conduct a desktop 
36

review, and/or confer with INL-CCP AK personnel. Upon AK evaluation with or without site 

inspection, EPA will issue a decision. Only upon receiving EPA written approval may INL-CCP 

implement T1 changes. 

T2 AK changes that do not require EPA approval prior to implementation but require reporting 

and a brief description of the changes to the documents, include the following: 

• Notification to EPA when updates to CCP-INL-AK-500, CCP-INL-AK-501, and CCPINL-AK-502 are approved by CBFO; 

• Notification to EPA when changes to AK documentation as a result of WCPIP revisions 

have been made (e.g., CRR); 

• Notification to EPA when a Correlation or Surrogate Summary Form is completed for 

each of the RH containers in this waste stream identified as CH based upon measured 

dose rates that present NDA results for assayed containers 

• Notification to EPA once waste stream data package for debris waste stream, and any 

modifications to the WSPF including the CRR and AK Summary are completed; 

• Notification to EPA that the final DTC determination is complete for RH containers 

numbers 728 through 737, as identified in AK Reference P030; all other AK accuracy 

reports prepared annually at a minimum; 

Following EPA approval, INL-CCP will provide EPA with information concerning T2 changes 

on a quarterly basis. EPA will evaluate these changes and communicate with INL-CCP as to 

whether the changes raise any concerns and require an INL-CCP response, or whether INL-CCP 

can continue to implement the changes. Consistent with EPA’s authority under 194.24(h) EPA 

may request information relative to these changes if EPA deems the information is necessary to 

ensure continued compliance with EPA regulations. 

8.2 Radiological Characterization 

EPA inspected the method by which the required radiological constituents for each waste 

container were determined. The nature of RH TRU wastes presents considerable difficulty with 

respect to obtaining meaningful measurement data. Apart from the obvious workers’ exposure 

considerations associated with external radiation fields in excess of 200 mrem/hr, RH TRU waste 

containers typically contain concentrations of 137Cs that prevent a meaningful isotopic 

determination in the same manner as is done for CH TRU wastes. At this time, INL-CCP has not 

proposed to assay RH containers for radiological contents. An alternative approach is the use of 

a scaling factor, which allows the correlation of an easily measurable gamma emitter such as 

137Cs with difficult-to-measure actinides and transuranic radionuclides. This is the essence of 

INL-CCP’s approach to radiological characterization. This method is a complex process and the 

inspection focused primarily on the following two aspects: 
37

• The application of the Dose-to-Curie (DTC) technique to determine a container’s external 

gamma exposure rate12 (dose rate) by correlating the measured dose rate to an activity 

concentration for 137Cs 

• Using scaling factors to convert the derived 137Cs activity to activity values for the other 

9 of the 10 WIPP-tracked radionuclides, including the uncertainty for each 

This section provides an overview of the INL RH radiological characterization process and 

discusses EPA’s evaluation of the adequacy of INL-CCP’s radiological characterization 

program. The checklist in Attachment A.2 identifies the objective evidence that was examined 

and used to complete the technical assessment for the DTC aspect. Evaluation of the scaling 

factors was not amenable to a checklist, and this aspect is discussed in the text directly. 

8.2.1 Overview of INL Radiological Characterization Program 

The radiological characterization aspect of the INL RH WC program that EPA evaluated focused 

on techniques to characterize containers from a single RH TRU waste stream, ID-ANLE-S5000. 

This stream consists of debris wastes that were transferred to INL between 1976 and 1995 and 

were generated at ANL-E in the Alpha Gamma Hot Cell facility (AGHFC) during the 

examination of irradiated and un-irradiated fuel pins from various reactor programs at ANL-W 

and other DOE and commercial reactors. Based on the nature of the waste materials and the 

types and quantities of information available, INL-CCP chose the approach of developing a 

waste characterization protocol that, in their opinion, was best suited for characterizing the 

population of all RH TRU waste containers within INL Waste Stream ID-ANLE-S5000. 

Specifically, a single scaling factor was assigned to fuel pin-related wastes generated from a 

variety of fuel types, an approach which begs the question whether a single waste stream can 

contain materials that are so dissimilar with respect to radiological composition. This aspect was 

discussed in detail during all phases of this inspection and these discussions are reflected in the 

text that follows. 

The actual measurement aspect, formalized in INL-CCP procedures, consists of four simple 

external gamma readings of each waste container (the average value is used), all of which are 

attributed to a single photon-emitting radionuclide, 137Cs. From a radiometric perspective, this is 

a simple task. The complexity of radiological characterization is contained in the development 

of the DTC approach that transforms each container’s measured dose rate into a 137Cs activity 

value which, in turn, is used in conjunction with scaling factors to produce concentrations for the 

remaining 9 of the 10 WIPP-tracked radionuclides and their corresponding uncertainties. 

 12 The external exposure rate is a numerical value expressed in units of rem per unit time (typically mrem/hr) 

that includes the contributions of all radiations, i.e., neutron, gamma, beta, and alpha. The formal determination of a 

container’s RH status is documented in mrem/hr, but for the DTC procedure only a photon (gamma) determination 

is performed and this is referred to informally as a dose rate. For consistency, term dose rate is used throughout this 

report. 
38

INL-CCP generated the scaling factors using the MCNP5, ORIGEN2.2, and MicroShield 

computer codes and compared them to mass spectrometry (MS) data that were generated at 

LANL. Beginning in the 1970s, destructive analyses were performed on 400 fuel pins at LANL 

to determine the relative abundances of Pu and uranium (U) isotopics, along with isotopes of 

neodymium (148Nd). Neodymium-148 is a fission product that is used to calculate burn-up in 

fuel and is analogous to the fission product 137Cs. INL-CCP refers to this use of the MS data as 

qualifying the ORIGEN2.2 results with the LANL MS data, and the scaling factors were adjusted 

as a result of the comparison. In general, MS is an excellent analytical technique and use of the 

MS data to adjust the isotopic scaling factors provided the opportunity to verify the results of the 

application of the codes mentioned previously. A technical assessment of the LANL MS data is 

addressed in Section 8.2.4. 

Figure 1 presents a flow chart of the INL-CCP radiological characterization process given in 

CCP-TP-501, Revision 1. Documentation of the conceptual basis for the DTC approach and 

development of the scaling factors is documented in 35 calculation packages that are listed in 

Section 8.2.5, as well as other technical documents, all of which were reviewed as part of this 

inspection. 

8.2.2 Radiological Characterization Element: Dose-to-Curie Procedure 

DTC Overview

INL-CCP’s approach was based on translating the measurable external gamma radiation from 

137Cs into an activity value using the Monte Carlo Neutron-Photon (MCNP) code, as documented 

in INL-RH-03. All of the measured gamma radiation was attributed to 137Cs, as discussed in 

LANL-RH-10, INL-RH-09, and INL-RH-08, including contributions from 60Co and other 

gamma emitting members of the 232U decay series, e.g., 228Ac and 208Tl. Once the container’s 

measured gamma dose rate was converted into a 137Cs activity, the other nine WIPP-tracked 

radionuclides were scaled to the 137Cs activity using a single set of scaling factors that were 

applied to all waste containers within the Waste Stream ID-ANLE-S5000. An example 

calculation using the observed dose rate in the DTC procedure is presented in Section 8.2.3, 

along with a discussion of the development of radionuclide scaling factors. 

INL-CCP formalized the 137Cs measurement in the Dose-to-Curie (DTC) procedure, 

CCP-TP-504, Dose-to-Curie Survey Procedure for Remote Handled Transuranic Waste, 

Revision 2. This procedure was evaluated prior to and during the inspection. The DTC process 

was evaluated relative to the following: 

• Capability of the DTC hardware to adequately determine a container’s external gamma 

exposure (dose) rate 

• Technical adequacy of the radiological characterization program’s documents, 

procedures, and controls 

• Knowledge and understanding of the personnel involved in the radiological 

characterization program 
39

Figure 1. Flow Chart of RH TRU Radiological Characterization Process

DeveQuan

Pin Characteristics from Fuel Suppliers and Reactor Operators U-235 Enrichment Pu-240 Enrichment U/Pu Ratio Burnup 

Locate and Retrieve Relevant LANL Records 

Calculate Fuel Composition for 603 Pins 

Make ORIGEN2.2 Runs for 603 Pins 

Output 

Mass Spectrometry Results for 400 LANL PinsU and Pu Relative Abundances 

Compare Mass Spec Results to ORIGEN22 Output for 400 Pins 

Determine Average Adjustment Factors to Apply to ORIGEN Results 

Post-Irradiation Forms for 400 LANL Pins U-235 Enrichment Pu-240 Enrichment U/Pu Ratio Burnup 

Calculate Fuel Composition for 400 Fuel Pins 

Make ORIGEN22 Runs for 400 Pins 

Output

Apply Average Adjustment Factors to ORIGEN Results for Fast Reactor Pins and Adjust RERTR Outputs 

Calculate Isotope/Cs-137 Scaling Factors from isotope totals for 506 Pins 

DeveloRelatioDrums Density 

DiDR

Cin 

DDga

Locate and Retrieve Relevant INL Records 
40

The external dose rate determination was done empirically using measurements that took place 

on-site at INL within the Idaho Chemical Processing Plant, Idaho Nuclear Technology 

Engineering Center (INTEC), Building No. CCP-659, Rooms 302 and 306, for instruments and 

operators, respectively. This approach is explained in CCP-AK-INL-501, Revision 1, and is 

formalized in procedure form in CCP-TP-504, Revision 2, both of which were reviewed for this 

inspection. The requirements of these two documents were used to formulate a basis by which 

the EPA inspection team evaluated the DTC process. Additionally, several of the calculation 

packages listed in Section 8.2.5 supported technical aspects of the DTC approach, and these were 

reviewed and discussed at length at INL in June and during subsequent telephone conversations 

between Patrick Kelly and Jene Vance, Jim Holderness, and Mark Doherty that took place 

throughout the month of July 2006. The purpose of these conversations was to obtain answers to 

specific technical questions that were not addressed during the INL site visit. 

DTC Technical Evaluation

The EPA inspection team evaluated the following aspects: 

(1) Instrumentation for making dose rate measurements 

The EPA inspection team verified the following: 

• There are three ion chamber probes available for use with the RO-7 Ion Chamber: RO7LD with a full-scale range of 1,999 mR/hr and a resolution of 1 mR/hr (Low Range); 

RO-7BM, with a full-scale range of 199,900 mR/hr and a resolution of 100 mR/hr 

(Medium Range); and, RO-7BH with a full-scale range of 199,900,000 mR/hr and a 

resolution of 10,000 mR/hr (High Range). The calibrations are essentially probe-specific, 

allowing the probes to be interchanged between ion chamber bodies. 

• The Low Range Probe No. 802038 and the Medium Range Probe No. 801254 had been 

calibrated and were in calibration at the time of the inspection. The High Range probe 

was not observed in use, INL-CCP personnel stated that it had been neither calibrated nor 

source checked. INL-CCP personnel stated that there was no intention of using this 

probe in the foreseeable future. 

• The ion chamber used to measure the dose or exposure rate of containers for the DTC 

method had been calibrated, as evidenced by the calibration due dates on the ion chamber 

itself and the probes, see previous bullet. 

• Instrument calibration was performed by the Battelle Energy Alliance (BEA) Health 

Physics Instrument Laboratory (HPIL) located at INL, and this facility is on the WTS 

Qualified Suppliers List. Calibration was performed in accordance with HPIL Procedure 

CW1-240, Revision 2, which was reviewed during the inspection. INL-CCP personnel 

had a spare RO-7 Ion Chamber that had been calibrated but was not observed in use. 

• It was verified that the scale used to weigh the containers has been calibrated and that the 

scale has been checked daily. 

• The battery and performance checks for the instrument used to measure the dose or 

exposure rate of containers for the DTC method had been performed and documented at 

least once per day prior to the first measurement of the shift. 
41

• The background rate was measured and recorded. Measurement personnel stated that 

they would take actions to reduce the background if the measured background radiation 

levels are greater than one-tenth of the expected container dose or exposure rate, as 

required by the WCPIP and CCP-TP-504, Revision 1. 

(2) Execution of the dose rate measurements 

The EPA inspection team verified the following: 

• For the waste containers observed (Drum No. 00761), the dose rate was measured four 

times, each at a distance of 1 meter and the container was rotated on the turntable 90° 

between each measurement. 

• The INL-CCP personnel were working to the approved document, CCP-TP-504, 

Revision 1, and all measurements were taken at the center line of the drum’s height and 

were lined up to the center height of the active volume of the ion chamber probe. 

• The appropriate range probe for the ion chamber was used (Low Dose Probe No. 

802038). 

• The container, waste stream, and measurement data were entered into the “Waste 

Container Dose-to-Curie Conversion Record” spreadsheet. Information entered included: 

o Date of the gamma measurements with the RO-7 Ion Chamber and Probe SNs 

o Waste stream designation 

o Container number 

o Container gross weight 

o Estimated can size for Cans #1, #2, #3, as appropriate 

o Estimated fill percentage for Cans #1, #2, #3, as appropriate 

o Four quadrant dose rate measurements 

o Waste material type (e.g., steel, cement, organic) 

(3) DTC BDR 

The EPA inspection team verified that the one DTC BDR included the following: 

• BDR Cover Sheet, Attachment 4 

• BDR Table of Contents, Attachment 5 

• BDR Narrative Summary, Attachment 6 

• ITR Review Checklist, Attachment 7 

• Measurement Control Report, Attachment 1 

• Container Data Sheet(s), Attachment 2 

• Waste Container DTC Conversion Record(s), Attachment 3 

• Copies of NCR Nos. RHINL-0505-06, RHINL-0004-06, and RHINL-0501-06 

• Evidence of signatures by the ITR and a SPM 

• Type of waste in each container (steel, concrete, organics) 

• Fill height of the container: < 25% full; 25% - 66% full; 66% - 90% full; > 90% full 
42

(4) Meeting quality assurance objectives (QAOs) 

 

The EPA inspection team verified that: 

• Precision had been established and maintained within the manufacturer’s specifications 

for the RO-7 Ion Chamber by successful source checks made prior to obtaining dose rate 

measurements on actual waste containers. 

• Accuracy had been established and maintained by operating the instrument within the 

manufacturer’s recommendations. 

• Representativeness had been maintained by applying the dose rate measurement to the 

entire waste container. 

• Completeness had been achieved by measuring the dose rate for every container in the 

BDR, i.e., 100% assay. 

• Comparability had been achieved by using standardized instructions to design and 

implement the DTC protocol, including the dose rate measurements. 

(5) RH TRU determination 

It was not entirely clear at what point the formal determination regarding a waste container’s 

status would be made relative to the criteria for RH TRU. The EPA inspection team evaluated 

the two following aspects: 

• RH TRU containers must have a contact external dose equivalent rate in excess of 

200 mrem/hr: 

The DCT measurements that were observed and are discussed in this section represent 

only the photon (gamma) contribution to a container’s external radiation field. There was 

a neutron-sensitive instrument (Rem Ball) in the same area as the RO-7 that could be 

used to provide the necessary information to support a complete determination regarding 

a waste container’s status relative to the 200 mrem/hr criterion. INL-CCP personnel 

stated that the Rem Ball was used to measure each waste container, but the results were 

used primarily for health physics/ALARA purposes. However, the RH determination is 

typically made on the basis of the transportation package and is therefore not within the 

purview of this inspection. 

• RH TRU containers must have a concentration of TRU radionuclides greater than 

100 nCi/g: 

CCP-TP-504 requires the container’s dose rate to be at least a factor of ten greater than 

background and the lowest reading possible on the RO-7 is 1 mR/hr. This means that the 

minimum measured dose rate at 1 meter that is required for the proper execution of 

CCP-TP-504 at the 200 mR/hr criterion is 10 mR/hr, based on a factor of 20 difference 

between the measured dose rate at 1 meter from the container relative to the reading on 

contact with the container. The EPA inspection team was concerned that it may not be 

possible to ensure that a container with a 1-meter dose rate of 20 mR/hr did in fact 

contain greater than 100 nCi/g of TRU radionuclides. As a check, the spreadsheet shown 

in Figure 3 was used with input values for the 1-meter dose rate of less than 10 mR/hr. 
43

For this hypothetical case, the spreadsheet yields a value in excess of 3,000 nCi/g for 

TRU Alpha Activity, based on the application of the scaling factors encoded in the Excel 

spreadsheet. This indicates that a container may not qualify as RH based relative to the 

200 mR/hr criterion, but it would still qualify as TRU relative to the 100 nCi/g criterion. 

Of course, it was not clear at this time how containers that showed a contact dose rate of 

less than 200 mR/hr would be dispositioned, i.e., as CH or RH. If any containers that are 

currently considered RH from this waste stream are eventually dispositioned as CH TRU, 

it would be valuable to compare the NDA results for the containers with those generated 

using the application of DTC and scaling factors that are discussed in this report. 

EPA received a comment objecting to obtaining this information as a T2 change. (See 

Attachment C, CBFO Comment No.10). Upon review of the comment EPA concurs with 

the reasoning provided by the Commenter and EPA agrees with the Commenter. (See 

Attachment C for EPA response to Comment No. 10). EPA now requires that INL-CCP 

notify EPA through the T2 change notice process that updates to the above documents 

have been made, and that they have been approved by CBFO and are available for EPA 

evaluation. EPA may then request these updates under the authority of 40 CFR 198.24(h) 

for the purpose of determining continued compliance with EPA regulations. Providing 

notification to EPA that this has occurred would be a T2 change. (See Table 1, where this 

is included as a T2 change). Consistent with EPA’s authority under 194.24(h), EPA may 

request new or additional information when it is necessary to ensure continued 

compliance with EPA regulations. EPA understands that the comparison of radionuclide 

concentrations derived from the application of DTC and scaling factors and NDA may 

exhibit considerable variation and does not necessarily consider that such variations 

would be problematic. See Section 8.1 (10) for a more detailed discussion of this issue. 

The EPA inspection team did not have any technical concerns or issues with the execution of the 

DTC methodology observed at INL-CCP during this inspection, or with the method’s technical 

basis and documentation based on the objective evidence that was reviewed. The use of an 

alternate characterization technique other than DTC observed during this baseline inspection as 

documented in CCP-TP-504 or substantive modification of the DTC procedure is a T1 change. 

(See Table 1, where this is included as a T1 change) 

8.2.3 Radiological Characterization Element: Scaling Factor Development 

Scaling Factor Overview

As shown in the 33 calculation packages listed in Section 8.2.5, this was a complex task that 

incorporated information from ANL-E, ANL-W, INL, and LANL, including the following: 

• Fuel pin type and characteristics from fuel suppliers and reactor operators 

• 235U enrichment 

• 240Pu enrichment (for mixed oxide fuels) and burnup 

• U/Pu ratios (for mixed oxide fuels) 

• Examination of 603 fuel pins examined at ANL-E 

• Mass spectrometry results for destructive assay (DA) of 400 fuel pins (See Section 8.2.5) 

• Other records related to AGHCF activities, names of experimenters, etc. 
44

The scaling factors were incorporated in a drum characterization spreadsheet that required the 

following input: 

• Drum gross weight in kilograms (kg) 

• Identification of the can sizes (5-, 7- or 10-gallon) and number of cans in the drum 

• Estimates of the can fill heights in percent 

• Dose rate measurements at four quadrant points in mR/hr 

The drum’s gross weight is calculated as: 

 Gross drum weight – (drum weight + packaging materials + can weights) (1)

The weight values used for the various drum items are listed in Table 5. 

Table 5. Weights of Items Used to Calculate 

Waste Weight and Density

Items Weight, kg 

30-gallon drum 16.36 

Polyethylene liner 3.61 

Plastic pouch 1.73 

Cardboard sleeve 1.41 

Plastic lid 0.39 

Total minus cans 23.5 

7-gallon drum 2.84 

5-gallon drum 2.26 

10-gallon drum 3.42 

The container’s apparent weight density in g/ cm3 is calculated as: 

 Net Waste Weight / (can #1 %Hfill + can #2 %Hfill + can #3 %Hfill) (2)

 

Where the net waste weight is in units of grams and can fill volume is given by: 

 Csize * %Hfill * 3785 cm3/gal (3)

Where: 

Csize = can size in gallons 

%Hfill = estimated fill height of each can in percent, expressed as a decimal 

The input of the spreadsheet is shown in Figure 2 with hypothetical dose rates values that 

average 450 mR/hr, an assumed drum configuration of two 7-gallon cans each 100% full, an 

assumed net weight of 46.5 kg, and an apparent weight density. The drum’s 137Cs content is 

derived as follows: 

 137Cs Activity in Ci = dose rate / (11.91 * X2

- 82.126 * X + 194.64) (4)
45

Where: 

X = apparent waste density, g/cm3

A B C D E F G H 

Operating procedure CCP-TP-504 Rev. 2 8 

Date of survey 6/1/2006 9 

Waste stream designation ID-ANLE-S5000 10 

Container number 11 

Container gross weight 70 Kg 12 

Waste cans Can #1 Can #2 Can #3 13 

Can sizes 7 7 0 gallons 14 

Estimate fill percentages 100 100 78.5 % 15 

Container net weight 46.5 Kg 16 

Measured container dose rate 17 

 Quadrant #1 300 mR/hr 18 

 Quadrant #2 500 mR/hr 19 

 Quadrant #3 600 mR/hr 20 

 Quadrant #4 400 mR/hr 21 

Calculated average dose rate 450 mR/hr 22 

Waste material type (organic, steel, cement) 

Figure 2. EXCELTM (Version 2002, Release 10) Spreadsheet “DTC Spreadsheet.xls” 

Equation (4) is taken from INL-RH-03, pages 6 –7, and is based on a total of eight MCNP cases 

that were run with the waste material density varying from 0.0 g/cm3 to 1.4 g/cm3 in intervals of 

0.2 g/cm3, a range that spans the expected range of waste densities in INL drums. The results of 

the eight runs are presented in Table 6, below, and were used to generate a second-order 

polynomial curve to fit the data, shown in Figure 3. 

Table 6. Waste Density Versus Observed Dose Rate

Waste Density Dose Rate mR/hr 

0.0 193.993 

0.2 179.322 

0.4 164.203 

0.6 149.743 

0.8 136.207 

1.0 124.006 

1.2 112.991 

1.4 103.45 
46

Figure 3. MCNP Input – Observed Dose Rate As a Function of Waste Density 

Calculation of the 137Cs activity for a container allows the further calculation of the following 

quantities for each RH container measured: 

• Activity in curies (Ci) and mass in grams (g) for each of the 10 WIPP-tracked 

radionuclides, i.e., 137Cs, 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U, and 238U 

• Associated uncertainty for all values listed in previous bullet 

• Fissile gram equivalent (FGE) 

• Pu equivalent curies (PE Ci) 

• Decay heat in watts 

The constants and other values required for these calculations were taken from the appropriate 

sources (CH WAC and TRAMPAC) and were spot-checked for accuracy. These were found to 

be accurate and they are summarized in Table 7. The results of these calculations are shown in 

Table 8 using the hypothetical dose rate input from Figure 2. The values listed in the Activity 

and Mass columns are the actual data that would be reported on the container’s assay sheet to be 

included in the radiological characterization BDR. Note that the scaling factors are the same for 

all containers; the sample-specific variables are the container’s measured dose rate and density, 

as shown in Equation 5, taken from INL-RH-05, page 5, and duplicated below: 

 137Cs Activity in Ci = dose rate / (11.91 * X2

- 82.126 * X + 194.64) (5)

At a hypothetical value of zero density (X = 0), this equation becomes essentially a bare-source 

calculation; at higher densities, the effects of the waste’s self-shielding are evident. 
47

Table 7. Constants Used in Scaling Factor Development

Radionuclide 

Specific Activity 

(Ci/g) FGE/g PE-Ci/Ci Watts/g 

U-233 9.76E-03 9.00E-01 3.90 2.84E-04 

U-234 6.32E-03 0.00E+00 0.00 1.82E-04 

U-235 2.19E-06 6.43E-01 0.00 6.04E-08 

U-238 3.40E-07 0.00E+00 0.00 8.62E-09 

Pu-238 1.73E+01 1.13E-01 1.10 5.73E-01 

Pu-239 6.29E-02 1.00E+00 1.00 1.95E-03 

Pu-240 2.30E-01 2.25E-02 1.00 7.16E-03 

Pu-241 1.04E+02 2.25E+00 51.00 3.31E-03 

Pu-242 3.97E-03 7.50E-03 1.10 1.17E-04 

Am-241 3.47E+00 1.87E-02 1.00 1.16E-01 

Cs-137 8.80E+01 0.00E+00 0.00 9.74E-02 

Ba-137m 5.38E+08 0.00E+00 0.00 2.12E+06 

Sr-90 1.38E+02 0.00E+00 0.00 1.60E-01 

Y-90 5.44E+05 0.00E+00 0.00 3.01E+03 

Table 8. Summary of Reportable Values Using Hypothetical Input 

Radionuclide 

Curie 

Scaling 

Factors 

Activity 

(Ci) 

Mass 

Grams FGE PE-Ci Watts 

U-233 1.65E-04 5.35E-04 5.48E-02 4.94E-02 1.37E-04 1.56E-05

U-234 2.98E-04 9.68E-04 1.53E-01 0.00E+00 0.00E+00 2.79E-05

U-235 1.05E-05 3.43E-05 1.56E+01 1.01E+01 0.00E+00 9.45E-07

U-238 1.77E-06 5.74E-06 1.69E+01 0.00E+00 0.00E+00 1.46E-07

Pu-238 2.54E-02 8.24E-02 4.76E-03 5.38E-04 7.49E-02 2.73E-03

Pu-239 9.19E-02 2.99E-01 4.75E+00 4.75E+00 2.99E-01 9.26E-03

Pu-240 4.84E-02 1.57E-01 6.83E-01 1.54E-02 1.57E-01 4.89E-03

Pu-241 7.26E-01 2.36E+00 2.27E-02 5.11E-02 4.63E-02 7.51E-05

Pu-242 1.52E-05 4.96E-05 1.25E-02 9.36E-05 4.51E-05 1.46E-06

Am-241 4.46E-02 1.45E-01 4.18E-02 7.81E-04 1.45E-01 4.85E-03

Cs-137 1.00E+00 3.25E+00 3.69E-02 0.00E+00 0.00E+00 3.60E-03

Ba-137m 9.46E-01 3.07E+00 5.72E-09 0.00E+00 0.00E+00 1.21E-02

Sr-90 7.41E-01 2.41E+00 1.74E-02 0.00E+00 0.00E+00 2.79E-03

Y-90 7.41E-01 2.41E+00 4.42E-06 0.00E+00 0.00E+00 1.33E-02

Totals 1.42E+01 3.83E+01 1.49E+01 7.22E-01 5.37E-02

Scaling Factor Technical Evaluation

The technical basis and degree to which the scaling factors are representative of the RH TRU 

wastes for which INL-CCP requested approval were evaluated during this inspection. The 

following elements were evaluated and verified: 
48

(1) Waste stream definition 

This inspection focused on a group of wastes that INL-CCP stated were contained in a single 

waste stream, which included fuel pins that were dissimilar with respect to their radionuclide 

content. Specifically, they consisted of three fuel types: 

• U, low enriched U (LEU), and highly enriched U (HEU) 

• U and Pu 

• Thorium 

The following definition is taken from page 12 of the WCPIP: 

A waste stream is defined as waste material generated from a single process or 

from an activity, which is similar in material, physical form and radiological 

constituents. Only those containers that can be related to a particular waste 

stream will be contained in that waste stream. 

In light of the apparent differences among the three fuel types listed above, the consolidation of 

these drums in a single waste stream bears investigation. The radionuclide profiles of the three 

fuel types are clearly different; however, following irradiation these fuel types have a common, 

salient characteristic, i.e., the presence of fission and activation products. Of these, 137Cs is the 

main interest due to its physical half-life (~30.2 years) and high transition probability photon 

emission at 662 keV. There are other fission and activation products but these are not an issue to 

this approach because they have short physical half-lives and have decayed or, more importantly, 

their contribution is insignificant relative to 137Cs. In a sense, one could consider that these 

materials have been treated by their exposure to the intense neutron field produced during 

irradiation (fission). The materials’ characteristics that have bearing on DTC have been reduced 

to a common element, i.e., the predominance of 137Cs, after irradiation, and the differences of the 

fuel’s pre-irradiation composition do not affect the radiological characterization process. The 

EPA inspection team concluded that the assignment of all containers to a single waste stream 

was technically justified and technically supportable. 

(2) Technical aspects and derivation of scaling factors 

The EPA inspection team evaluated the following aspects: 

• Activity values that are used are derived from modeling and statistical metrics that 

support their use, and the statistical metrics include mean and standard deviation values 

for each measured radionuclide. 

• Isotopic activity values are normalized to the major radionuclide(s) responsible for the 

external container dose rate, i.e., 137Cs. 

• The calculated results used to develop the factors and convert the measured dose rate to 

radionuclide activity levels. 

• The expected dose rates at a distance of 1 meter from the outer surface of the waste 

container, at the mid-height of the container, have been calculated as a function of the 

waste’s activity, and the calculation accounts appropriately for container properties i.e., 
49

fill height or (apparent) density, waste type, shielding effects of the container and/or liner 

wall. 

• Calculations supporting the scaling factors are performed using appropriate shielding 

analysis techniques, i.e., MCNP5 and Microshield 7.00. 

• Computer programs (ORIGEN2.2) used for calculations of the activities of the WIPPtracked radionuclides account for the following: 

o The beginning conditions of the fuel used to produce the TRU isotopes 

o Exposure of fuel to neutron fields in a nuclear reactor (fission) 

o Change in radionuclides following irradiation 

o Reactor neutron energy spectrum is known or calculated in order to determine the 

effective cross-sections of radionuclides leading to the creation of WIPP-tracked 

radionuclides 

o Appropriate cross-sections are used or generated for each reactor condition 

o Fuel exposure history is used to calculate isotope generation and depletion 

(3) Documentation of technical aspects 

Development of the scaling factors is documented in 33 calculation packages that were prepared 

by Jene Vance and Jim Holderness (see Section 8.2.5). These packages address a variety of 

aspects, including: 

• Verification of MCNP5, Microshield 7.00 and ORIGEN2.2 

• Evaluation of all potential contributors to a container’s dose rate, specifically 60Co and 

other gamma emitting members of the 232U decay series, e.g., 228Ac and 208Tl 

• U and Pu relationship in the fuel pins from which the wastes originated 

• The nature and history of the fuel pins, reactor cross-sections, and operating histories 

• Potential sources of uncertainty, discussed below 

The EPA inspection team members reviewed a subset of these packages in detail and discussed 

them with the documents’ authors and Mark Doherty. During these discussions, several aspects 

were probed in detail and several modifications to the calculation packages were made in 

response to the EPA inspection team’s concerns. All potential concerns were resolved and, apart 

from minor discrepancies with respect to specific documentation details, the calculation 

packages were found to be technically adequate. 

(4) Evaluation of Total Measurement Uncertainty (TMU) 

 

The development of TMU for ID-ANLE-S5000 is based on the propagation of uncertainties 

present in all aspects of the determination of the radiological constituents of RH TRU waste. 

The TMU determination included the contributions of: 

• Drum weight measurement 

• Measurement uncertainty of 137Cs 

• MCNP5 issues 
50

• MicroShield issues 

• Other gamma emitters

• Individual pins to the total 

• Specific pins in a single drum

• Burnup history 

• Reported burnup 

• Internal code issues 

• Contributions from unirradiated pins 

• Modeling 

There was a technical concern regarding TMU with respect to the appropriateness of the 

statistical model, i.e., that all components of the uncertainty were statistically independent and 

could therefore be added in quadrature. Since the radionuclide values are derived from the 137Cs 

dose rate that is measured, this aspect cannot be considered independent and its contribution 

must be treated differently, i.e., it cannot be added using the square root of the sum of the 

squares. The TMU is expected to increase when the correct approach is taken and, in fact, the 

corrected calculation in INL-RH-06, Revision 1, shows a TMU that is approximately 1.5 times 

greater than the original, incorrect TMU value. The CTAC Technical Specialist identified the 

issue as well and INL-CCP acknowledged that the TMU equation required modification. As a 

result, INL-CCP issued Non Conformance Report (NCR) No. RH-INL-0501-06. This also 

resulted in the reissuing of BDR No. INLRHDTC-06001 and the calculation package 

INLRHDTC-06001 that provides the technical support for the calculation of TMU. The EPA 

inspection team reviewed the reissued BDR and the calculation package and determined that 

both had been appropriately corrected. The EPA inspection team reviewed the applicability of 

the reissued procedure to the INL RH waste stream and determined that it was technically 

appropriate. The EPA inspection team did not have any open technical issues or concerns 

relative to the development and application of radionuclide scaling factors based on the objective 

evidence reviewed during this inspection. The application of new scaling factors for isotopic 

determination other than those documented in CCP-AK-INL-501 and observed during this 

baseline inspection is a T1 change. (See Table 1 where this is listed as a T1 change.) 

8.2.4 Radiological Characterization Element: Evaluation of Mass Spectrometry Data to 

Support ORIGEN2.2 

The purpose of the ORIGEN2.2 modeling was to develop technically based scaling factors to 

allow a waste container’s measured dose rate to be transformed into activity values for each of 

the 10 WIPP-tracked radionuclides, including uncertainty. While this exercise was based 

essentially on modeling, there was a verification/validation of the ORIGEN2.2 output performed 

using data from 400 fuel pins that were sampled and assayed using mass spectrometry. The use 

of mass spectrometry (MS) data in support of ORIGEN2.2 derived scaling factors had been 

assessed on August 9, 2006, in Carlsbad, New Mexico. The INL-CCP and CBFO/CTAC 

representatives in attendance are listed in Table 3. The MS data and information EPA assessed 

had been located, identified, and compiled by INL-CCP’s AK personnel and ranged in date from 

1970 through 1984. As expected, the information gathered did not constitute a complete and 

continuous record. However, EPA determined that there was sufficient information and data 

available to make a determination with regard to the technical adequacy of the MS data for the 

stated purpose. 
51

Analytical Methods

The ultimate purpose of the procedures and analytical data reviewed was to establish the burnup 

rate for the fuel pins. Two processes were used to generate the data required to make this 

calculation. A spiked and a separate unspiked aliquot of the dissolved fuel pin were analyzed; 

the spiked results provided the atom percent fission in the U and Pu fuel and the unspiked results 

determined the isotopic compositions of U and Pu in the fuel. These two results were used to 

calculate the burnup rate. Although ORIGEN input consisted of the isotopic data only, the entire 

process used for burnup determinations was included in the review because generation of the 

spiked and unspiked data was part of the same process. Figure 4 is an example of a typical 

LASL burnup result sheet titled “Burnup Results for Irradiated Fuel.” 

Sample Number WARD W8-37 WARD 8-57 WARD W31-20 

LASD Job Number 1226-L 1227-L 1228-H 

Total U Atoms* 8.171E16 1.222E17 1.952E17 

Total Pu Atoms* 2.447E16 3.770E16 4.864E16 

Nd-148 Atoms* 2.025E14 3.142E14 1.996E14 

Isotopic Distributions 

U, Atom % 233 - - - 

 234 .673 .664 .868 

 235 61.12 61.01 77.81 

 236 2.04 2.03 1.25 

 238 36.17 36.29 20.08 

Pu, Atom % 238 .139 .215 .052 

 239 88.62 88.57 90.06 

 240 10.50 10.48 9.24 

 241 .672 .670 .592 

 242 .068 .068 .058 

Burnup, Atom % Fission 10.24 10.52 4.67 

 ** 

* All three elements determined on the same sample aliquot. 

** Calculated using Nd-148 fission yield data reported in ENDF VB. 

Fission yield value used = 0.01672, 0.01670 

Remarks: _________________________________________________________________________ 

___________________________________________________________________________ 

___________________________________________________________________________ 

Analyst: HJK, CB, PGA, MEO, JA, RMA Date: 3/17/82 Group Leader: ____________ 

Figure 4. Los Alamos Scientific Laboratory Group CMB-1 Burnup Results For Irradiated 

Fuel, Reproduced From Original Data Sheet Provided by Jene Vance, 

Original Was Initialed By RMA and Displayed the Initials of the Group Leader 
52

By reviewing quarterly reports, analytical result sheets, and logbooks, it was determined that the 

following procedures were used to control the preparation and analysis of fuel pin samples for 

the purpose of establishing the isotopic ratios of U and Pu: 

• ANC-DE-1-HC-3 “The Dissolution of Irradiated Materials”: This was used to 

prepare the fuel pins for analysis. Revision 2, Section 3.1 of this procedure, dated 

August 22, 1973, required that SRM13 U-500 (U) be used to prepare calibration standards 

for the mass spectrometer. Section 3.2 required at least one sample of SRM 946 (Pu) be 

processed by this procedure every five days. The procedure required control charts to be 

maintained of the 239/240 atom ratio data. Control charts were not located by INL-CCP 

and this was the only revision of this procedure found. 

• ANC-DE-1-MS-2 “Determination of Atom Percent Fission in Uranium and 

Plutonium Fuel”: This used the triple spike technique. Two revisions of this procedure 

were located, Revision 2 dated August 22, 1973, and Revision 3 dated March 24, 1976. 

The procedure required the use of SRM U-500 (U), SRM 960 (Pu) and SRM 950 (Pu) 

and referenced procedure ANC-DE-1-HC-3 for sample preparation. SRMs were required 

to be analyzed every 5 days and for control charts of the 239/240 atom ratio data to be 

maintained. Control charts were not available for review. Five or more mass spectra 

were recorded for each sample (Section 4.5.3) in Revision 2 of the procedure but this 

requirement was reduced to three or more spectra in Revision 3. Acceptance criteria for 

quality control (QC) samples were provided in Section 3.1, as well as corrective action to 

be implemented if the SRM failed to meet acceptance criteria. Section 4.5.5 provides the 

calculations used to determine the burnup and the atom percent fission. 

• ANC-DE-1-MS-3 “Determination of the Isotopic Compositions of Uranium and 

Plutonium”: This was used to analyze unspiked aliquots of the fuel pin solutions by 

mass spectrometry to determine the isotopic compositions of U and Pu. Revision 3 of 

this procedure dated August 22, 1973, and Revision 4 dated April 13, 1981, were 

available for review. SRMs U-500 (U) and 946 (Pu) were required to be analyzed every 

five days and control charts maintained. Acceptance limits were specified, as were 

corrective actions to be taken if the standard results were outside of those limits. The 

procedure listed the reagents used and the storage conditions required for those reagents. 

Instructions for introducing the samples into the MS system were provided and Section 

4.5.4 required at least five mass spectra to be recorded for each sample. Review of the 

available raw data demonstrated that the minimum number of spectra requirement was 

met. Although Section 4.5.5 states that atom percent abundances of the U and Pu 

isotopes are calculated, the procedure does not provide the calculation used. 

• Quarterly Reports: Many reports were recovered by INL-CCP for the period of interest 

(1972–1984) and some of them contain useful but limited information for this 

assessment. The following information was used to help EPA make a determination with 

regard to the acceptability of the mass spectrometry data used for ORIGEN input: 

- Progress Report, LA-5067-PR, April 1 to June 30, 1972, page 9: “The quality 

assurance procedures written... include: Dissolution of Irradiated Material and 

Determination of Atom Percent Fission in Uranium and Plutonium Fuel.” It is 

 13 SRM is Standard Reference Material. 
53

assumed that these two procedures were ANC-DE-1-MS-2 and ANC-DE-1-HC-3, 

although the report did not specifically identify the methods as such. 

- Progress Report, LA-5390-PR, April 1 through June 30, 1973, page 1: 

“Characterization of unirradiated and irradiated fuels by analytical chemistry will 

continue and additional methods will be modified and mechanized for hot cell 

application. ...” 

- Page 39: Development of Burnup Method Using Conventional Low-Cost Apparatus. 

“Mass spectrometry is the most reliable technique for determining nuclear fuel 

burnup using the triple spike technique.” The triple spike technique was used to 

generate the “spiked” data used in the burnup calculation. 

- Progress Report, LA-9372-PR, January 1 – March 31, 1982, page 3: “Chemical 

separation of uranium, plutonium, and neodymium.... followed by mass 

spectrometric.... measurement currently is used to determine burnup”. 

- Progress Report, LA-9959-PR, July 1 – October 31, 1983, page 2, III Analytical 

Chemistry: Reports that 15 fuel samples were dissolved for burnup analysis by mass 

spectrometry. 

The above information demonstrates that analytical procedures that were developed early in the 

project continued to be used throughout the period of interest (see Section 1-3 in Analytical 

Methods). 

Accuracy

Records of replicate analyses of isotopic SRMs were available from March 26, 1979. SRMs 

U-005 (U) and 947 (Pu) were analyzed five times, one set of samples was subjected to chemical 

separation and one set of samples was not. The average and standard deviation (SD) of the 

results were calculated and the results are provided below in Tables 9a and 9b for the 

unseparated and separated aliquots for DRM U-005, respectively, and 10a and 10b for 

unseparated and separated aliquots for SRM Pu 947, respectively. These results demonstrate 

acceptable precision (PRD # 3.3%) and accuracy (Recovery # 103.4%) of the analytical method 

ANC-DE-1-MS-3 for U and Pu isotopes. 

Table 9a. SRM U-005 Analytical Results, Unseparated Aliquots 

Analysis Date Certified 234U 

0.00218 

Certified 235U 

0.4895 

Certified 236U 

0.00466 

Certified 238U 

99.503 

3/15/79 0.0024 0.4923 0.0050 99.5002 

3/16/79 0.0024 0.4922 0.0051 99.5004 

3/16/79 0.0022 0.4913 0.0050 99.5016 

3/16/79 0.0022 0.4907 0.0050 99.5020 

3/16/79 0.0022 0.4912 0.0049 99.5018 

SD 0.00011 0.00069 0.00007 0.00084 

Average 0.00228 0.49154 0.0050 99.50120 

% Recovery 104.6 100.4 107.3 99.998 

RPD 4.5 0.41 7.04 <0.01 
54

Table 9b. SRM U-005 Analytical Results, Separated Aliquots

Analysis Date Certified 234U 

0.00218 

Certified 234U 

0.00218 

Certified 236U 

0.00466 

Certified 238U 

99.503 

3/19/79 0.0024 0.4924 0.0052 99.4999 

3/19/79 0.0024 0.4928 0.0051 99.4997 

3/19/79 0.0022 0.4911 0.0050 99.5016 

3/19/79 0.0024 0.4932 0.0050 99.4993 

3/19/79 0.0025 0.4918 0.0054 99.5003 

SD 0.00011 0.00083 0.00017 0.00088 

Average 0.00238 0.49226 0.00514 99.50016 

% Recovery 109.2 100.6 110.3 99.997 

RPD 8.8 0.56 <0.1 <0.1 

Table 10a. SRM Pu 947 Analytical Results, Unseparated Aliquots 

Analysis Date Certified 238/239Pu 

0.003688 

Certified 240/239Pu 

0.241461 

Certified 242/239Pu 

0.015594 

3/14/79 0.003735 0.241545 0.015577 

3/14/79 0.003726 0.241487 0.015611 

3/14/79 0.003723 0.241474 0.015589 

3/15/79 0.003743 0.241521 0.015586 

3/15/79 0.003723 0.241497 0.015581 

SD 0.000009 0.000028 0.000013 

Average 0.003730 0.241505 0.015589 

% Recovery 101.1 100.0 99.97 

RPD 1.1 <0.1 <0.1 

Table 10b. SRM Pu 947Analytical Results, Separated Aliquots

Analysis Date Certified 238/239Pu 

0.003688 

Certified 240/239Pu 

0.241461 

Certified 242/239Pu 

0.015594 

Date Pu 238/239 Pu 240/239 Pu 242/239 

3/16/79 0.003760 0.24124 0.015546 

3/16/79 0.003812 0.241310 0.015611 

3/16/79 0.003949 0.241444 0.015614 

3/16/79 0.003780 0.241492 0.015587 

3/16/79 0.003772 241296 0.015589 

SD 0.000078 0.000107 0.000027 

Average 0.003815 0.241356 0.015589 

% Recovery 103.4 100.0 100.0 

 RPD 3.3 <0.1 <0.1 

 RPD = (C1-C2) / (C1+C2 /2) x 100 
55

Precision

Only two samples with duplicate analyses that were analyzed on March 20, 1980, were located, 

fuel pins WARD-W33-27 and WARD-W32-20. The results for U and Pu radionuclides are 

provided in Tables 11a and 11b below: 

Table 11a. Analytical Results, Replicate Analysis 

Radioisotope WARD-W33-27 

Atom % WARD-W33-27, Atom %, RPD 

U-233 <0.001 <0.001 0.00 

U-234 0.868 0.871 0.35 

U-235 77.59 77.52 0.10 

U-236 1.34 1.34 0.00 

U-238 20.20 20.27 0.35 

Pu -238 0.037 0.036 2.74 

Pu-239 89.92 89.90 <0.1 

Pu-240 9.30 9.33 0.16 

Pu-241 0.670 0.670 0.00 

Pu-242 0.070 0.070 0.00 

Table 11b. Analytical Results, Replicate Analysis

Radioisotope SRM WARD-W32-20 

Atom % 

SRM WARD-W32-20 

Atom % RPD 

U-233 <0.001 <0.001 0.00 

U-234 0.851 0.864 1.52 

U-235 78.37 78.36 <0.01 

U-236 0.891 0.904 1.45 

U-238 19.89 19.87 0.20 

Pu -238 0.037 0.031 17.64* 

Pu-239 90.40 90.37 <0.01 

Pu-240 8.86 8.90 0.45 

Pu-241 0.641 0.633 1.26 

Pu-242 0.062 0.060 3.28 

 RPD = (C1-C2) / (C1+C2 /2) x 100 

* This value was excluded from consideration because it appears to be an outlier. 

The acceptability of the precision of the above measurements is adequately demonstrated by the 

calculated RPD values that range from 0.00 to 3.28%. Replicates for SRMs U-005 and Pu 947 

were analyzed and demonstrated acceptable precision for the analytical method used. The results 

of these replicate measurements are presented in Tables 9a, 9b, 10a, and 10b above. 
56

Bias

Bias in analytical methods is typically assessed from blank results, but the results of analytical 

standards may also be used. Based on reviewing the available logbooks and analytical methods, 

EPA Inspectors realized that blanks were not analyzed for this project, which complicates the 

evaluation of bias. However, the lack of bias in the analytical method is also demonstrated by 

the percent recoveries obtained for SRMs U-005 and Pu 947, as shown in Tables 9a and 9b and 

10a and 10b, above. 

Blind Sample Analysis (Performance Evaluation)

SRM standards were analyzed on a routine basis for this program, as well as performance 

evaluation samples that were made by ANL and supplied to LANL as QC samples. Analytical 

data, original data, and original calculations were available for five samples of this type, BU-1-

77, BU-1-78, BU-1-79, BU-3-112 and BU-3-113 that were analyzed on May 1, 1979, and are 

shown in Table 12, below. Although the result data sheet does not unambiguously identify these 

as performance evaluation samples, the result sheet for BU-1-80 and BU-2-95, analyzed on 

February 28, 1979 and July 16,1979, respectively, was titled “Analysis of ANL Synthetic 

Burnup Standard.” It is reasonable to infer that these other “BU-1-xx” samples were part of this 

QC program. The expected burnup value for these QC samples was provided in the records 

reviewed. Using the original data shown in Table 13, J. Vance made an independent calculation 

of the burnup values. As the data used for ORIGEN input is part of the burnup calculation, it is 

reasonable to assume that the RPD for the isotopic abundances did not exceed the burnup RPD 

provided in Table 12. These results demonstrate that LANL analyzed the QC samples with 

acceptable accuracy (recovery #107%) and precision (RPD #6.76%). 

Table 12. Available LASL Quality Control Samples 

QC Sample LANL Observed ANL Known % Recovery RPD 

BU-1-77 2.13 2.0 106.5 4.90 

BU-1-78 2.19 2.0 109.5 6.67 

BU-1-79 2.13 2.0 106.5 4.90 

BU-1-112 4.25 4.0 106.3 6.06 

BU-1-113 4.28 4.0 107.0 6.76 

 RPD = (C1-C2) / (C1+C2 /2) x 100 

Standards

The Certificates of Analysis for some of the standards used in method ANC-DE-1-MS-3 were 

available for review. Only two of the SRMs listed below were identified as having been assayed, 

U-005 and Pu 947 as discussed above and shown in Tables 9a and 9b, and 10a and 10b, above. 

The other SRMs for which we examined objective evidence of the SRM’s certified values are 

listed below: 

U SRMs: U-500, U-0002, U-005, U-010U-015, U-020, U-030, U-050, U-100, U-150, U-200, 

U-350, U-500, U-750, U-800, U-850, and U-900 

Pu SRMs: 946, 947, and 948 
57

Table 13. Mass Spectrometry Calculations for Fuel Pin WARD-W8-37, LANL-1226-L 

The data in light green are provided in the worksheets attached to the burnup results sheet. 

The numbers in yellow are the calculated numbers that can be checked against the 

corresponding values on the worksheets. 

 

Nd-148 Yield 0.01672 

Grams Spike 1.03809

These data are from attached data sheets for 

fuel pin 1226-L for WARD-W8-37 

Atoms of U233/g 3.9989E+16 

Atoms of Pu242/g 1.2440E+16 

Atoms of Nd150 9.5302E+13

 

Uranium Data 

 Unspiked Spiked 

1 U-233 0 33.688 

U-234 0.673 0.446 These data are from attached data 

U-235 61.116 40.528 sheets for fuel pin1226-L for 

U-236 2.04 1.352 WARD-W8-37 

U-238 36.172 23.986 

 

2 U-233 Spiked Sample Corrected for U-233 from Sample 

 

 U-233csx 33.688 

3 Uranium Sensitivity Factor 

 SF(u) 1.2323E+15 

4 Total Atoms of Uranium in Sample 

 U 8.17132E+16 OK 

 

5 Uranium Percent of Sample Computed from Spiked Sample Data Correction 

 

 (F)u 1.508022681 

 Spike Corrected 

 U-233 0 OK 

 U-234 0.673 OK 

 U-235 61.117 OK 

 U-236 2.039 OK 

 U-238 36.171 OK 

 

Pu Data 

 Unspiked Spiked 

1 Pu-238 0.139 0.091 

Pu-239 88.624 58.013

These data are from attached data sheets for 

fuel pin 1226-L for WARD-W8-37 

Pu-240 10.497 6.872 
58

Table 13. Mass Spectrometry Calculations for Fuel Pin WARD-W8-37, LANL-1226-L 

Pu-241 0.672 0.44 

Pu-242 0.068 34.585

 

2 Pu-242 of Spiked Sample Corrected for Pu-242 from Sample 

 

Pu-242 

csx 34.54048741 

3 Pu Sensitivity Factor 

 (SF)pu 3.7388E+14 

4 Total Atoms of Pu in Sample 

 (Pu) 2.44737E+16 OK 

 

5 Pu Atom Percent of Sample Computed from Spiked Sample Data Corrected for Spike 

 

 (F)pu 1.527661848 

 Spike Corrected 

 Pu-238 0.139 OK 

 Pu-239 88.624 OK 

 Pu-240 10.498 OK 

 Pu-241 0.672 OK 

 Pu-242 0.068 OK 

 

 Neodymium Data 

 Unspiked Spiked 

1 Nd-142 0 0.978 

Nd-143 1 1

Nd-144 1 1

These data are from attached data sheets for 

fuel pin 1226-L for WARD-W8-37 

Nd-145 1 1 

Nd-146 1 1 

Nd-148 1 49.927

Nd-150 0.484 48.329

 

2 Nd-150 of Spiked Sample Corrected for Nd-150 from Sample 

 

 (Nd-150)s 24.28067528 

3 Apparent Natural Nd Contamination Based on Mass 142 

 (142)c 0.708484504 

3a 0.708484504 

4 

Correction of Unspiked 

Data 
59

Table 13. Mass Spectrometry Calculations for Fuel Pin WARD-W8-37, LANL-1226-L 

 Unspiked 

 Nd-142 0 

 Nd-143 1 

 Nd-144 1 

 Nd-145 1 

 Nd-146 1 

 Nd-148 1 

 Nd-150 0.484 

 

5 Correction of Spiked Data 

 (142)c 0.708484504 

 Nd-142 0.269515496 

 Nd-143 0.681961306 

 Nd-144 0.376746182 

 Nd-145 0.783062045 

 Nd-146 0.549970643 

 Nd-148 49.77722638 

 Nd-150 48.18213116 

 

4 

Nd-150 of Spiked Sample Corrected for Nd-150 from Sample and Corrected 

for 

 Natural Nd Contamination 

 

(Nd150)cs 24.20593877 

 

5 

Neodymium Sensitivity 

Factor 

 

 (SF)nd 4.0871E+12 

6 Atoms of Nd Isotopes in Sample 

 Nd-142 

 Nd-143 Not calculated for burnup determination 

 Nd-144 

 Nd-145 

 Nd-146 

 Nd-148 2.02465E+14 OK 

 Nd-150 

 

7 Burnup Using Nd-148 

 F 1.21092E+16 OK 

 Burnup 10.236% OK 
60

Conclusion

EPA has determined that there is sufficient information and data available to demonstrate that the 

isotopic data used to verify the ORIGEN2.2 output were technically sound. Based on the 

objective evidence evaluated during the inspection, the data were generated by an analytical 

system with acceptable accuracy, precision, and bias to support its use in supporting the 

radionuclide scaling factors derived using ORIGEN2.2 for INL-CCP RH TRU wastes. 

8.2.5 Documents, Waste Containers, and Batch Data Reports Reviewed 

The list of documents provided below includes all documents related to the INL-CCP RH 

radiological characterization program that were evaluated to support this inspection: 

• CPP-PO-002, CCP Transuranic Waste Certification Plan, Revision 16 

• CCP-AK-INL-500, Central Characterization Project Acceptable Knowledge Summary 

Report for Remote-Handled Transuranic Debris Waste from Argonne National LaboratoryEast Stored at the Idaho National Laboratory, Revision 2 and Revision 3 

• CCP-AK-INL-501, Central Characterization Project Remote-Handled Transuranic 

Radiological Characterization Technical Report for Remote Handled Transuranic Debris 

Waste from Idaho National Laboratory, Revision 0 

• CCP-AK-INL-501, Central Characterization Project Remote-Handled Transuranic 

Radiological Characterization Technical Report for Remote Handled Transuranic Debris 

Waste from Idaho National Laboratory, Revision 1, June 6, 2006 

• CP-AK-INL-502, Central Characterization Project Confirmatory Test Plan for Waste Stream: 

ID-ANLE-S5000, Revision 0 

• CCP-TP-504, Dose-to-Curie Survey Procedure for Remote-Handled Transuranic Waste, 

Revision 2 

• CCP-TP-506, CCP Preparation of the Remote–Handled Transuranic Waste Acceptable 

Knowledge Characterization Reconciliation Report, Revision 1 

• Information on Fuel Elements Examined at the AGHCF at ANL from November 1971 to 

August 7, 1995, Based on Waste Consolidation Records; Project No. 23048, EDF-6695, 

Revision 0, Effective Date May 19, 2006 

• Identification of Additional Fuel Elements/Materials Examined in the Alpha-Gamma Hot 

Cell Facility for ANL-E TRU Waste; Project No. 23048, EDF-6946, Revision 0, Effective 

Date May 19, 2006 

• Neutron and Gamma-Ray Dose Conversion Factors from 1 Meter to Contact for Argonne 

National Laboratory-East Remote Handled Transuranic Waste; Project No.32-48, EDF-7069, 

Revision 0, Effective Date June 08, 2006 

• INL Batch Data Report No. INL-RH-DTC 06001: Twenty nine drums 

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-01, Fuel Composition 

Calculations 
61

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-02, Scaling Factor 

Development 

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-03, U and Pu 

Isotopic Relationships in Fuel 

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-03, Dose-to-Curie 

Derivations for Cs-137 in 30-Gallon Drums 

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-04, MCNP5 Sensitivity 

Studies 

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-05, Mass 

Spectrometry Results Input Check Calculation 

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-05, Cs-137 Dose-toCurie Uncertainty 

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-06, Drum 

Characterization, DTC and Related Calculations for Drum Characterization 

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-06, Drum 

Characterization, DTC and Related Calculations for Drum Characterization, Revision 1 

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-07, Uncertainty 

Analysis for Drums 

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-08, Evaluation of 

Isotope Contribution to the Total Radiological Hazard 

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-09, ORIGEN2.2 

Verification Check 

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-09, Dose-to-Curie for 

Cs-137 and Co-60, Shielded and Unshielded 

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-08, Microshield 7.00 

Verification 

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-18, MCNP5 Code 

Verification Check 

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-09, ORIGEN2.2 

Verification 

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-15, ORIGEN2.2 Data 

Extraction 

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-14, ORIGEN2.2 

Input Generation 

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-10, Fission Product 

Contribution to Total Dose Rate 

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-11, RERTR 

Adjustment Factor Development 
62

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-12, Evaluation of 

PotentialCs-137 Migration 

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-12, Disposition of 

Identified Radioactive Materials from AGHCF 

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-13, Modification of 

ORIGEN2.2 Input Files for Specific Fuel Pins 

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-13, Evaluation of 

One-Step Irradiation Input to ORIGEN2.2 

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-14, Co-60 Dose Rate 

Contribution 

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-14, ORIGEN2.2 

Input Generation 

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-15, Burnup Estimates 

for Thorium Pins 

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-15, ORIGEN2.2 

Output Data Extraction 

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-16, Scaling Factor 

Sensitivity Study 

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-16, Mass 

Spectrometry Comparison to ORIGEN2.2 Results 

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-18, MCNP5 

Verification Check 

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-29, Sensitivity of 

ORIGEN2.2 to Other Fast Reactor Cross Sections 

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-30, Evaluation of 

Reactor Operating History 

• MS Exhibit 1: Typical MS result sheet 

• MS Exhibit 2: Manual calculation of burn-up rate from data generated for fuel pin WARDW8-37, LASL Job Number 1226-L (Courtesy of Jene Vance) 

• ANC-DE-1-HC-3 “The Dissolution of Irradiated Materials,” Revision 2, Sections 3.1, 3.2, 

August 22, 1973 

• ANC-DE-1-MS-2 “Determination of Atom Percent Fission in Uranium and Plutonium Fuel,” 

Revision 2, August 22, 1973 and Revision 3, March 24, 1976 (Section 4.5.3; 4.5.5) 

• ANC-DE-1-MS-3 “Determination of the Isotopic Compositions of Uranium and Plutonium,” 

Revision 3, August 22, 1973, and Revision 4, April 13, 1981 (Sections 4.5.4, 4.5.5) 

• Quarterly Reports: 

o Progress Report, LA-5067-PR, April 1 to June 30, 1972 

o Progress Report, LA-5390-PR, April 1 through June 30, 1973 
63

o Page 39: Development of Burnup Method Using Conventional Low-Cost Apparatus. 

o Progress Report, LA-9372-PR, January 1 – March 31, 1982 

o Progress Report, LA-9959-PR, July 1 – October 31, 1983, page 2, III Analytical 

Chemistry 

Summary of Radiological Characterization Findings and Concerns - DTC and Scaling 

Factor Development

The EPA inspection team did not identify any concerns or findings relative to DTC or the 

development of radionuclide scaling factors as part of the radiological characterization technique 

evaluated during this inspection. There are no open issues related to radiological 

characterization resulting from this inspection. 

Radiological Characterization Baseline Approval

EPA approves the INL_CCP radiological characterization program that the EPA inspection team 

evaluated during this baseline inspection and consists of the following two techniques used 

jointly for containers of RH TRU in one waste stream, ID-ANLE-S5000: 

 

• The determination of the 10 WIPP-tracked radionuclides based on the DTC procedure 

presented in CCP-TP-504 

• The application of radionuclide scaling factors derived as documented in 

CCP-AK-INL-501 and supported by the 33 calculation packages referenced in 

Section 8.2.5 

Radiological Characterization Tiers

Based on the inspection and the results discussed above, EPA assigns the following tiers: 

T1 Radiological Characterization changes that require EPA review and approval prior to 

implementation are the following: 

• Application of new scaling factors for isotopic determination other than those 

documented in CCP-AK-INL-501 

• The use of an alternate characterization technique other than DTC and the application of 

established radionuclide scaling factors as documented in CCP-TP-504 or substantive 

modification of the DTC procedure14 

• Addition of a new waste stream not approved under this baseline or addition of containers 

to Waste Stream ID-ANLE-S5000 that requires changing the established radionuclide 

scaling factors 

 14 Substantive modification refers to the use of an inherently different type of measurement instrument or the use 

of the high range probe described for INL-CCP-504, since both of these would constitute a WC component not 

previously evaluated by EPA. 
64

T1 changes will be reported and documentation will be submitted when INL-CCP is ready for 

EPA review. In case of T1 NDA changes, EPA will inform INL-CCP and CBFO whether a site 

inspection is necessary. EPA may request additional information, choose to conduct a desktop 

review, and/or confer with INL-CCP personnel. Upon evaluation (with or without site 

inspection), EPA will issue an approval letter and only upon receiving the EPA approval can 

INL-CCP continue to use the equipment affected by the change. 

T2 Radiological Characterization changes that do not require EPA approval prior to 

implementation but require reporting and a brief description of the changes to the documents, 

include the following: 

• Changes made to CCP-INL-AK-501, Revision 2, or CCP-TP-504, Revision 2 that require 

CBFO approval 

Following EPA approval, INL-CCP will provide EPA with information concerning T2 changes 

on a quarterly basis. EPA will evaluate these changes and communicate with INL-CCP as to 

whether the changes raise any concerns and require an INL-CCP response, or whether INL-CCP 

can continue to implement the changes. Consistent with EPA’s authority under 194.24(h) EPA 

may request information relative to these changes if EPA deems the information is necessary to 

ensure continued compliance with EPA regulations. 

8.3 Visual Examination 

Waste Characterization Element Description

The VE process for RH waste consists of reviewing existing audio/visual recordings that were 

made at the time of packaging for the purpose of generating VE data. Using CCP-TP-500, 

Revision 2, Remote-Handled Waste Visual Examination, two VE operators identified and 

documented the waste contents of the containers examined by this process. VE determines the 

following aspects of RH TRU Waste Characterization: 

• Confirmation that the waste matches the waste stream description given in AK 

• Description of the container contents including waste material parameters (WMP) 

• Confirmation of the presence or absence of residual liquid that exceeds one percent of the 

volume of the waste container 

Documents Reviewed

The following documents, procedures and other pieces of objective evidence were reviewed to 

assess whether VE operations follow the appropriate approved procedures and meet VE 

requirements: 

• CCP-TP-500, Revision 1, Remote-Handled Waste Visual Examination, April 27, 2006 

• CCP-TP-500, Revision 2, Remote-Handled Waste Visual Examination, June 19, 2006 
65

• CCP-QP-002, Revision 20, Training and Qualification Plan, May 3, 2006 

• Remote-Handled TRU Waste Characterization Program Implementation Plan, Revision 0D, 

October 30, 2003 

• VE Batch Data Report (BDR) RHINLVE60001, consisting of 19 containers, 5 of which were 

subject to a CCP Non Conformance Report (NCR) 

• VE BDR RHINLVE60002, consisting of 19 containers, 17 of which were subject to a CCP 

NCR 

• VE BDR RHINLVE60003, consisting of 20 containers, 17 of which were subjected to a CCP 

NCR 

• Audio/visual recording for BDRs RHINLVE60001, RHINLVE60002, and RHINLVE60003 

The following records were reviewed: 

• Visual Examination Operator/ITR/TS/FQAO 

• Qualification Card for one VEE 

• List of qualified VE personnel 

• List of currently qualified VE personnel 

• Qualification cards for three Visual Examination Operators 

• Comprehensive examination for VE Operators 

• AK Summary training material

• Daily Production Report, dated June 13, 2006

• List of exempted software

• Review of CY 2000 Retrieved RH-TRU Drums for Water (report)

Technical Evaluation

During the inspection, the technical elements of the VE process were evaluated using the 

checklist contained in Attachment A.2. These areas are summarized below. Please note that 

during the on-site inspection, EPA Issue No. INL-CCP-RH-VE-06-001F was originally 

designated as a finding and EPA Issue No. INL-CCP-RH-VE-06-003CR was designated as a 

concern requiring a response. Following discussions after the conclusion of the inspection, EPA 

changed the status of each concern, which produced the concern INL-CCP-RH-VE-06-001CR 

(formerly INL-CCP-RH-VE-06-001F) and the finding INL-CCP-RH-VE-06-003F (formerly 

INL-CCP-RH-VE-06-003CR). This is discussed in the sections below. 

(1) Overall procedural technical adequacy and implementation 

The visual examination procedure is documented in CCP-TP-500 and was written to provide 

instructions to VE personnel when they perform actual VE. EPA identified a concern with this 

process that was recorded on EPA Issue Inspection Issue Tracking Form (see Attachment B.2 for 

this form). The concern is discussed below. 
66

EPA Concern No. INL-CCP-RH-VE-06-002CR: For the RH waste containers processed 

to generate BDR RHINLVE60001 at the time of the inspection, VE consisted of reviewing 

existing VE audio/visual recordings. During this process VE operators had to “interpret” the 

instructions in the VE procedure to adjust them to what they were actually doing. 

Resolution: In response to EPA’s concern, INL-CCP revised the procedure to include 

instructions for performing VE by reviewing the audio/visual recordings, and INL-CCP VE 

personnel generated BDRs RHINLVE60002 and RHINLVE60003 using the revised procedure, 

both of which were available during the follow-up inspection. 

Status of Concern: EPA considers this concern to be closed. 

(2) Characterization of WMPs and prohibited items were evaluated 

EPA did not observe the RH VE process during the initial on-site inspection. The data sheets 

contained in BDR RHINLVE60001 were reviewed in conjunction with the audio/visual 

recordings to ensure consistency between the visual and written records. Upon inspection of 

these records, EPA generated an EPA Issue Inspection Issue Tracking Form (see Attachment B.3 

for this form) to address the issue discussed below, as well as in item (3): 

EPA Finding No. INL-CCP-RH-VE-06-003F: EPA’s review determined that all waste items 

in the containers were not recorded on the data sheets, resulting in incomplete inventories for the 

RH containers. 

Resolution: In response to EPA’s concern, INL-CCP provided additional training to the VE 

operators and VEE during the initial on-site inspection. 

Status of Concern: EPA considered this finding to be closed. 

The presence or absence of prohibited items and confirmation that the waste matched the waste 

stream description given in the AK were determined and documented as required. During the 

follow-up inspection, EPA reviewed the audio/visual recordings and data sheets for selected 

containers in BDR RHINLVE60003. During this review, a VE operator explained the process 

and how decisions were made with regard to identification of WMPs. EPA identified a concern 

that was captured on an EPA Inspection Issue Tracking Form (see Attachment B.8 for this form) 

that is discussed below. 

EPA Concern No. INL-CCP-RH-VE-009C: EPA determined that although INL-CCP had 

provided additional training to VE operators, the original inventories recorded for containers in 

BDR RHINLVE60003 were still incomplete. INL-CCP had identified this issue prior to EPA’s 

follow-up inspection and had revised the container inventories as needed. Additionally, when 

the ITR reviewed and approved this data package, he did not identify that the QAO for 

representativeness for all three of the containers that were not subject to an INL-CCP NCR was 

not met. This concern also impacted the documentation of VE activities and is also discussed 

under item (3), below. 

Resolution: INL-CCP was not required to provide a formal response to EPA’s concern, but 

INL-CCP provided additional training to the VE personnel. 
67

Status of Concern: EPA considers this concern closed. 

(3) Documentation of VE activities was examined 

During the initial on-site inspection, EPA reviewed data package RHINLVE60001 to verify that 

the VE data were documented correctly and completely. EPA generated an EPA Inspection 

Issue Tracking Form (see Attachment B.8 for this form) to capture the issue discussed below. 

EPA Finding No. INL-CCP-RH-VE-06-003F, Revision 2: EPA determined that the VE data 

was incomplete. Operators were not recording all waste items identified in containers, and hence 

the waste can inventories were incomplete. This concern also impacted the characterization of 

WMPs and prohibited items and is also discussed in item (2), above. 

Resolution: INL-CCP prepared a briefing addressing this issue and presented it to VE operators 

during the initial on-site inspection. At the follow-up inspection, EPA reviewed an additional 

two BDRs, RHINLVE60002 and RHINLVE60003. 

Status of Concern: EPA considered this concern to be closed. 

EPA Concern No. INL-CCP-RH-VE-06-009C: Although RHINLVE60003 was generated 

after the additional training the original data sheets did not contain a complete inventory of waste 

items. INL-CCP had identified this issue prior to EPA’s follow-up inspection and had revised 

the container inventories. EPA generated an EPA Issue Inspection Issue Tracking Form to 

capture this issue (see Attachment B.8 for a copy of this form). Completed data generation and 

project-level review checklists were included in the data package that was reviewed. The VEE 

who performed the ITR review on BDR RHINLVE60003 failed to recognize that all data were 

not being recorded, which was included in Concern No. INL-CCP-RH-VE-06-009C. 

Resolution: Concern No. INL-CCP-RH-VE-06-009C did not require a formal response from 

INL-CCP. 

Status of Concern: EPA considers this concern closed. 

(4) Training for VE personnel was examined 

The site maintains a list of qualified individuals, which is used to ensure that all training is 

current. During the inspection, the qualification packages for the three RH VE operators were 

reviewed and found to document adequate training for VE personnel. Upon examination of the 

qualification packages, EPA generated an EPA Inspection Issue Tracking Form (see Attachment 

B.1 for a copy of this form) to capture the issue discussed below. 

 

EPA Concern No. INL-CCP-RH-VE-06-001CR: In accordance with the requirements of the 

WCPIP and CCP-TP-500, VE operators are only considered to be qualified when they have 

completed the required on-the-job training (OJT) and passed a written examination with a grade 

of 80% or better. At the time the BDR RHINLVE60001 was generated, the operators had not 

taken the comprehensive examination and were not therefore qualified to perform the VE event 

according to the WCPIP and CCP-TP-500. 
68

Resolution: In response to EPA’s issue, INL-CCP’s RH VE expert reviewed the data in 

RHINLVE60001 and determined that data quality was not affected. VE operators took and 

passed the required examination prior to generation of BDRs RHINLVE60002 and 

RHINLVE60003, both of which were reviewed during the follow-up segment of this inspection. 

Status of Concern: EPA considers this concern closed. 

Summary of VE Findings and Concerns

The EPA inspection team identified the findings and concerns related to VE that are discussed 

above. Copies of the EPA Inspection Issue Tracking Forms are provided in Attachments B.1 

through B.3, and B.8. EPA considers all findings and concerns to have been adequately 

addressed, and there are no open findings or concerns related to VE resulting from this 

inspection. 

VE Baseline Approval

EPA approves the VE of audio/video media process for RH waste that the EPA inspection team 

evaluated during this baseline inspection and which consisted of the following: 

• Trained personnel: VE operators, VEE 

• Approved and controlled operating procedures CCP-TP-500, Revision 2; CCP-QP-002, 

Revision 20 

• VE records and supporting data: Visual Examination Data Forms, CCP-TP-500 review 

checklists, and three VE BDRs (VE BDR Nos. RHINLVE60001, RHINLVE60002 and 

RHINLVE60003) 

• INL RH S5000 Debris Waste Stream ID-ANLE-S5000, 19 drums total from the three 

BDRs listed in the previous bullet 

Based on the results of this inspection, EPA proposed this process of VE by review of existing 

audio/visual recordings for approval for S5000 waste. The VE process EPA evaluated as part of 

this inspection is based on the three VE BDRs (listed above) that INL-CCP generated during the 

inspection. Based on this review, EPA proposed a limited approval by identifying eight (8) 

drums that can be disposed of at WIPP. EPA received comments questioning the proposed 

limited approval (See Comment Nos. 8 and 12 in the EPA Docket ID No. EPA-HQ-OAR-2006-

0881). Also, during the comment period for the proposed approval, INL-CCP provided EPA 

with additional information related to an improved VE technique as well as an additional VE 

BDR (No. RHINLVE60004). Upon examination of this additional information, EPA determined 

the proposed baseline approval incorrectly limited the approval to eight (8) drums. The final 

baseline approval is corrected to state that nineteen (19) drums of retrievably-stored RH debris 

waste from the 3 BDRs reviewed by EPA are approved for disposal. EPA also determined that 

the improved VE process that was identified by DOE during the comment period is subject to a 

T1 evaluation (See Attachment C, EPA’s response to Comment Nos. 8 and 12). EPA has begun 

this evaluation and the results of the T1 evaluation will be provided upon completion separately. 
69

VE Tiers 

EPA assigns a T1 change designation for the VE process based on the understanding that (a) the 

VE process used to examine 58 RH debris waste containers discussed in three BDRs listed above 

was not to be used for VE of the INL RH waste containers in the future; and, (b) these containers 

were to be reexamined using a real-time-radiography process. In the event that INL-CCP 

decides to use the VE process observed during this baseline inspection as described in this 

section to examine RH waste containers in the future, EPA review and approval are necessary 

prior to implementation as a Tier 1 change 

8.4 Real Time Radiography 

The technical area of RTR was not evaluated during this inspection. If INL-CCP wishes to use 

RTR to characterize RH TRU wastes, EPA approval (separate from what is contained in this 

report) is required. 

EPA is not approving RTR at this time. INL-CCP did not have an operational RTR unit in place 

at the time of the inspection. This final baseline inspection requires the use of RTR as a T1 

change. Therefore, INL-CCP cannot ship RH waste to the WIPP using RTR as a WC technique 

until it is approved by EPA. EPA received a request for an evaluation and approval of a RTR 

process. Once the evaluation is complete, the results of the T1 evaluation will be provided 

separately. 

8.5 WIPP Waste Information System 

The technical area of WWIS was not evaluated during this inspection. Prior to INL-CCP using 

the WWIS to characterize RH TRU wastes, EPA approval separate from what is contained in this 

report is required. 

EPA is not approving the WWIS for entry and tracking of the waste contents of RH debris 

wastes at this time. Although the WWIS is currently approved by EPA for tracking CH waste, 

INL-CCP had not demonstrated its adequacy to enter and track RH waste contents during this 

baseline inspection. During the comment period for the proposed approval CBFO notified EPA 

that the WWIS was operational for RH wastes and was ready for EPA evaluation as a T1 change. 

EPA has begun this evaluation and the results of EPA’s T1 evaluation will be provided upon 

completion separately.

9.0 RESPONSE TO COMMENTS 

By the end of the comment period (December 26, 2006), EPA received one set of public 

comments. (Comments are available from EPA Docket ID No. EPA-HQ-OAR-2006-0881.) 

EPA evaluated those comments and revised the report accordingly. Attachment C provides the 

public comments and EPA’s response. 
70

10.0 SUMMARY OF RESULTS 

10.1 EPA Findings and Concerns 

The findings and concerns issues identified during the inspection, as well as INL-CCP’s 

responses, are discussed in the preceding sections of this report. Copies of the EPA Inspection 

Issue Tracking Forms that capture these issues are included in Attachment B. INL-CCP 

responded to all EPA findings and concerns that required a response prior to the inspection 

closeout on site, as well as subsequent to the inspection. The EPA inspection team members 

evaluated all responses for completeness and adequacy, and concluded that each EPA issue 

requiring a response had been resolved satisfactorily. No EPA issues remain open at this time. 

10.2 Conclusions 

EPA’s inspection team determined that INL-CCP’s RH WC program activities were technically 

adequate. EPA is approving the INL-CCP-RH WC program in the configuration observed 

during this inspection, described in this report, and documented in detail in the checklists in 

Attachment A. The approval includes the following: 

• The AK process for RH retrievably-stored TRU debris in one waste stream, Waste 

Stream No. ID-ANLE-S5000, Lots 1 through 20, as defined in CCP-AK-INL-500, 

Revision 3 

• The radiological characterization process using DTC and modeling-derived scaling 

factors for assigning radionuclide values to one RH waste stream for which the scaling 

factors are applicable, as described in CCP-AK-INL-501, Revision 1 

• The VE of audio/video media process used for a total of nineteen (19) retrievably-stored 

RH debris waste drums included in three batch data reports (BDR Nos. 

RHINLVE60001, RHINLVE60002, and RHINLVE60003 

As stated in Attachment C (see response to Comment Nos. 8 and 12), EPA is reviewing 

additional information submitted during the comment period for the proposed approval regarding 

an improved VE procedure. Upon examination, EPA determined that this VE information is 

subject to a T1 evaluation. EPA has begun the evaluation of this new VE information and the 

results of the T1 evaluation will be provided upon completion. 

EPA is not approving the WWIS for tracking the waste contents of RH debris wastes at this time. 

Although the WWIS is currently approved by EPA for tracking CH waste, INL-CCP had not 

demonstrated its adequacy to track RH waste contents during this baseline inspection. During 

the comment period for the proposed approval CBFO notified EPA that the WWIS was 

operational for RH wastes and was ready for EPA evaluation as a T1 change. EPA is in the 

process of reviewing the WWIS database that has been populated with actual RH waste content 

data. The results of the T1 evaluation will be provided upon completion. No RH waste can be 

shipped to WIPP for disposal until EPA approves the WWIS as a T1 change. 

EPA is not approving RTR. INL-CCP did not have an operational RTR unit in place at the time 

of the inspection. EPA requires that INL-CCP provide notification when RTR is ready for EPA 
71

inspection as a T1 change. INL-CCP cannot ship RH waste to WIPP using RTR as a WC 

technique until it is inspected and approved by EPA. 

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 Table 14.
72

Table 14. Tiering of RH TRU WC Processes Implemented by INL-CCP 

 (Based on June 12–16 Baseline and August 9 & 29, 2006, Follow-Up Inspections)

RH WC Process Elements INL-CCP RH WC Process - T1 Changes INL-CCP RH W

Acceptable Knowledge (AK) Modification of the approved waste stream ID-ANLE-S5000 to 

include additional containers, i.e., K Cell or other debris wastes; AK (1) and AK (5) Any new waste streams not approved under this baseline; AK (1) and AK (7)Substantive modification(s)*** that have the potential to affect the characterization process: CCP-AK-INL-500, CCP-AK-INL-501, or CCP-AK-INL-502; AK (6) and AK (7) Load management for any RH waste stream; AK (16) 

Notification to EPA wheCCP-INL-AK-501, and by CBFO; AK (4) Notification to EPA wheas a result of WCPIP revCRR); AK (7) and AK (Notification to EPA wheSummary Form is compcontainers in this waste upon measured dose rateassayed containers; AK Notification to EPA oncdebris waste stream, and including the CRR and A(14) Notification to EPA that complete for RH containidentified in AK Referenreports prepared annuall

Radiological Characterization, including Dose-to-Curie (DTC) 

Application of new scaling factors for isotopic determination other than those documented in CCP-AK-INL-501; RC (8.2.2 and 8.2.3) Use of any alternate radiological characterization procedure other than 

DTC with established scaling factors as documented in CCP-TP-504 or substantive modification of the DTC procedure***; RC (8.2.2 and 8.2.3) Any new waste stream not approved under this baseline or addition of containers to Waste Stream ID-ANLE-S5000 that requires changing the established radionuclide scaling factors; RC (8.2.3)

Revisions of CCP-AK-INrequire CBFO approval; 

Visual Examination of audio/video media (VE) 

Implementation of VE following this baseline approval; if INL-CCP decides to use VE in the future, EPA approval is necessary 

Real-Time Radiography (RTR) Any use of RTR requires EPA approval WIPP Waste Information System (WWIS) Any use of WWIS requires EPA approval prior to RH waste disposal 

* Upon receiving EPA approval, INL-CCP will report all T2 changes to EPA every three months. ** Excluding changes that are editorial in nature or are required to address administrative concerns. *** Substantive modification refers to a change with the potential to affect INL-CCP’s RH WC process, e.g., the use of an inherently differen

or the use of the high-range probe as described in CCP-TP-504. 
73

11.0 REFERENCES 

U.S. Department of Energy, Carlsbad Area Field Office, “Contact-Handled Transuranic Waste 

Acceptance Criteria for the Waste Isolation Pilot Plant (CH-WAC),” Revision 3, DOE/WIPP-02-

3122, Carlsbad, New Mexico, April 25, 2005. 

New Mexico Environment Department, Waste Isolation Pilot Plant Hazardous Waste Facility 

Permit, NM48901 139088-TSDF, Santa Fe, New Mexico, 1989. 

U.S. Environmental Protection Agency, “Criteria for the Certification and Recertification of the 

Waste Isolation Pilot Plant’s Compliance with the Disposal Regulations: Certification Decision; 

Final Rule,” Federal Register, Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405. 

U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 191, “Environmental 

Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level 

and Transuranic Radioactive Wastes.” 

U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 194, “Criteria for the 

Certification and Re-Certification of the Waste Isolation Pilot Plant’s Compliance with the 

40 CFR Part 191 Disposal Regulations.” 

U.S. Department of Energy, Carlsbad Area Field Office, “Remote Handled TRU Waste 

Characterization Program Implementation Plan”, DOE/WIPP-02-3214, Revision 0D, Carlsbad, 

New Mexico, October 30, 2003. 

U.S. Department of Energy, Title 40 CFR Part 191, Compliance Certification Application for the 

Waste Isolation Pilot Plant, DOE/CAO 1996-2184, Carlsbad, New Mexico, 1996. 

U.S. Department of Energy, Title 40 CFR Part 191, SUBPART D AND C, Compliance 

Recertification Application 2004, DOE/WIPP/2004-3231. 

U.S. Department of Energy, Carlsbad Area Field Office, “Quality Assurance Program 

Description (QAPD)”, DOE/CBFO-94-1012, Revision 7, Carlsbad, New Mexico, July 2005. 

U.S. Nuclear Regulatory Commission, “Contact-Handled Transuranic Waste Authorized 

Methods for Payload Control (CH-TRAMPAC).” 
Attachments A.1 through A.3 
AK-1 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: JRequired Technical Elements Procedure Location/Adequacy Verification of Activity ObjeImplementation of Characterization Methods to Satisfy DQOs (WCPIP Section 4.2) How are the following DQOs being addressed—any of these that AK is used to determine must be qualified/verified as per section 4.3, except for the first bullet (defense): 

• Defense determination • TRU waste determination • RH waste determination • Activity determination (total and activity per 

canister) 

• Residual liquids • Physical form • Metals • Cellulosics, plastics, rubber 

WCPIP Revision 0D, Section 4.2; CCP-P0-002, Rev. 17. 

Interview of AKEs including Steve Schafer, Kevin Peters, Lisa Price; Mark Doherty; Examination of objective evidence. 

Examples include buCCP-AK-IINL-501 RCCP-TP-5ID-ANLE-WSPF, CRAddition oidentificati10 radionuwith EPA CTP, Certidocuments process by as determiverificatioinstances. to any and documents WCPIP. Ebe providerevisions o

Qualification/Verification of AK Data (WCPIP Section 4.3)Is AK Qualification/verification required because characterization information exists that was generated prior to an established QA Program? 

WCPIP Revision 0D, Section 4.3, CCP-P0-002, Rev. 17. 

Interview of AKEs including Steve Schafer, Kevin Peters, Lisa Price, Mark Doherty; examination of objective evidence. 

Examples include buCCP-AK-I500 RevisiAll wastes generated approved Q

a. If yes, what Qualification approach is used and for which characterization data (e.g. Peer Review, 

WCPIP Rev. D, Section 4.3, CCPP0-002, Rev. 17. Interview of AKEs including Steve Schafer, 

Kevin Peters Lisa Price;

Examples include bu
AK-2 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: JRequired Technical Elements Procedure Location/Adequacy Verification of Activity ObjeConfirmatory Testing, Equivalent QA) Kevin Peters, Lisa Price; 

examination of objective evidence. 

CCP-AK-I500 

b. If Peer Review performed, does it follow requirements presented in Section 4.3.1 of the PIP? 

WCPIP Rev. D, Section 4.3, CCPP0-002, Rev. 17. Interview of AKEs including Steve Schafer, 

Kevin Peters, Lisa Price. 

Examples include buCCP-AK-I500 Revs. Peer Reviesubmitted method; Precord. 

c. If Confirmatory Testing is performed, does it follow requirements presented in Section 4.3.3 of the PIP and which methods are used? 

• 100 percent VE at time of packaging 

• 10-10-all • Representative sample collection to confirm 

isotopic distribution 

• 100% NDA • DA • DTC 

• Other as described in a Confirmatory Testing Plan: 

- VE by review of a percentage of 

audio/videotapes 

- Analysis of representative samples for 

radiological data 

- VE/radiography of a subpopulation of waste - Qualification of existing radiological sampling 

and analytical info via modeling (e.g. ORIGEN) 

WCPIP Rev. D, Section 4.3, CCPP0-002, Rev. 17. Interview of AKEs including Steve Schafer, 

Kevin Peters, Lisa Price. 

Examples include buCCP-AK-ITracking Sconversion 00738, 007CCP is to pall VE tapCTP descrcontents oidentificatibelow). 
AK-3 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: JRequired Technical Elements Procedure Location/Adequacy Verification of Activity Obje

• Did the generator submit a Confirmatory Test Plan 

as described in Section 4.3.3 of the PIP? If so, has CBFO audited and approved the process? Did it contain the following and was it adequate: - Description of the waste stream or waste 

stream lots to which the plan applies 

- Explicit description of DQOs and QAOs that 

will be satisfied with the data being qualified 

- Description of DQOs and QAOs that will 

NOT be confirmed with the data being qualified and an explanation of how compliance with those DQOs and QAOs will be demonstrated 

- Description of the confirmatory testing 

proposed, including the percentage of waste containers subject to confirmatory testing 

- Description of how the tested subpopulations 

will be representative of the waste stream or waste stream lot 

- Quantitative acceptance criteria for 

determining that the AK information in question can be qualified as characterization data. 

General Checklist Questions Is the scope of the waste for which approval is sought defined? What is it? 

WCPIP Rev. 0D, CCP-P0-002, Rev. 17. 

Interview of AKEs including Steve Schafer, Kevin Peters, Lisa Price. 

Examples include buCCP-AK-IApproval sID-ANLEwastes (e.gSummary identified wstream to irequire EP
AK-4 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: JRequired Technical Elements Procedure Location/Adequacy Verification of Activity Obje

of any new changes to 500 and 50process reqapproval. 

 Is the waste TRU by definition as presented in the LWA? 

(P.L.102-579) 

WCPIP Rev. 0D, CCP-P0-002, Rev. 17. 

Interview of AKEs including Steve Schafer, Kevin Peters, Lisa Price; review of objective evidence. 

Examples include buCCP-AK-ITRU WACU072, U04INL-CCP this streamnotificatioinclusion othat were odetermined measurem

Are any wastes considered (or previously considered) HLW? HLW are prohibited. 

(P.L.102-579) 

Are any wastes considered (or previously considered) Spent Nuclear Fuel? 

(P.L.102-579) 

WCPIP Rev. D, CCP-P0-002, Rev. 17. 

Interview of AKEs including Steve Schafer, Kevin Peters, Lisa Price; review of objective evidence. 

Examples include buCCP-AK-IP593, P59P023, P03

Personnel and Training Who are the AK Personnel? Upon interview, do they perform the duties presented in Attachment A, Section 3? Who is the Site Project Manager (SPM)? Upon interview, do they perform the duties presented in Attachment A, Section 3? Who is the Site Project Quality Assurance Officer (SPQAO)? Upon interview, do they perform the duties 

WCPIP Rev. D Attachment A; CCPP0-002, Rev. 17; CCP-QP-001, Rev. 20 

Interview of AKEs including Steve Schafer, Kevin Peters, Lisa Price, Larry Porter, A.J. Fisher; Jene Vance (SME); review of objective evidence. 

Examples include buQualificatiKevin PeteVance. Dupersonnel required by 
AK-5 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: JRequired Technical Elements Procedure Location/Adequacy Verification of Activity Objepresented in Attachment A, Section 3? Are the above trained in the following: 

• The RH TRU WCPIP • Non conformance and corrective action 

processes 

• The AK Procedure presented in Attachment A of 

the PIP 

• Site-specific training relative to the contents of 

the site’s waste streams 

• Determining radiological contents of individual 

containers 

Compiling AK Documentation and Defining the Waste Stream(s)AK documentation must be compiled. What documents have been compiled? Are they among the following: 

• Published documents/controlled databases • Unpublished data • Internal procedures and notes (log books, 

correspondence, etc.) 

• Engineering documents • Mission statements • Other 

Documentation is among the data used to define the waste stream. Has the waste stream been adequately defined as per the definition of waste stream as presented in the WCPIP: Waste stream is a waste material generated from a single process or from an activity which is similar in material, physical form, and radiological constituents. 

WCPIP Rev. D Attachment A Interview of AKEs 

including Steve Schafer, Kevin Peters, Lisa Price, Review of AK Summary and AK Source Document Reference List; examination of selected objective evidence. 

Examples include buCCP-AK-ISource DoAERHDMCorresponUnpublishby INL-CCdatabases, engineerinstatementsThe waste INL-500 walthough Rwas revisestream. EPindependethe waste spresented 
AK-6 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: JRequired Technical Elements Procedure Location/Adequacy Verification of Activity ObjeDoes additional documentation used to characterize waste and delineate the waste stream include the following: 

• Previous NDA, radiochemistry, dosimetry, and 

non destructive examination data 

• Waste generating procedures • Physical, chemical, and radionuclide inputs to 

the process 

• Time period that the process took place • Facilities involved • Types of waste generated (waste material 

parameters) 

• Process descriptions and flow diagrams • Packaging logs and videotapes • MSDS • Procurement records • Administrative/Process controls used as the basis 

for the absence of residual liquids 

• Container-specific information (AK data, i.e. 

waste container input forms, etc.). 

Were correlations made between CH and RH TRU Waste operations at a site including related CH waste characterization data? If so, are correlations documented 

on a Correlation and Surrogate Summary Form and is this form adequate and included in the AK Summary? 

WCPIP Rev. D Attachment A Interview of AKEs 

including Steve Schafer, Kevin Peters, Lisa Price, Jene Vance (SME, Mark Doherty; review of AK Summary and AK Source Document Reference List; examination of selected objective evidence 

Examples include buCCP-AK-ISource DoP592, EDF739, 740, 7P030, P03U072, U04Summary Note that tRH wastes

Were correlations and similarities with the RH TRU waste operations at other generator/storage sites made, including characterization information for that RH TRU waste stream? If so, are the correlations documented on the Correlation and Surrogate Summary Form and is this form adequate and included in the AK Summary? 

WCPIP Rev. D Attachment A Interview of AKEs 

including Steve Schafer, Kevin Peters, Lisa Price; review of AK Summary and AK Source Document Reference List; 

Examples include buCCP-AK-ICCP-AK-ICorrelation

P593 P59
AK-7 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: JRequired Technical Elements Procedure Location/Adequacy Verification of Activity Obje

examination of selected objective evidence 

P593, P59informatioIf containebe CH rathdrums wouwould be pSurrogate provided t

Has an AK Source Document Reference list been assembled for each AK Summary/waste stream, and have references been assigned unique identifier (Attachment 2 of the Attachment A of the PIP)? 

WCPIP Rev. D Attachment A Interview of AKEs/SPM 

including Steve Schafer, Kevin Peters, Lisa Price; review of AK Summary and AK Source Document Reference List 

Examples include buCCP-AK-IReference Reference follow. 

Have Source Document Summaries been developed per Attachment 5 and are these adequate? Do they identify data limitations? 

WCPIP Rev. 0D Attachment A Review of Source 

Document Summaries 

Examples include buSee all Souprovided (source docsummary areference tcontents andocumenti

AK-AK Discrepancy Resolution How are AK-AK discrepancy resolutions documented and does the documentation: 

• Identify the affected waste stream(s) • Identify all relevant AK source documents • State the nature of the discrepancy 

Has there been an instance where an AK-AK discrepancy cannot be resolved or if the resolution results in a failure of a DQO? If so, the waste cannot be shipped to WIPP without further evaluation. 

WCPIP Rev. 0D Attachment A Interview of AKEs/SPM 

including Steve Schafer, Kevin Peters, Lisa Price, Larry Porter, Mark Doherty; review of AK Summary and AK Source Document Reference List; examination of selected objective evidence 

Examples include buNo AK-AK EPA expecrecord as tDR011 shodocument resolutionsidentified t
AK-8 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: JRequired Technical Elements Procedure Location/Adequacy Verification of Activity ObjeCharacterization of the Waste – DQO Assessment Preparation of the AK Summary Report What DQOs are assigned by AK? How is each to be qualified/verified (peer review, confirmation, equivalent QA program)? 

• Defense determination • TRU waste determination • RH waste determination • Activity determination (total and activity per 

canister) 

• Residual liquids • Physical form • Metals • Cellulosics, plastics, rubber 

For each DQO related to AK, AK personnel must identify the DQO, supporting AK information, justify the assignments/conclusions, reference the AK Source Documents and applicable pages supporting the assessment, method of 40 CFR 194.22(b) will be qualified 

WCPIP Rev. 0D Section 4 Interview of AKEs/SPM 

including Steve Schafer, Kevin Peters, Lisa Price, Larry Porter, Mark Doherty; review of AK Summary and AK Source Document Reference List; examination of selected objective evidence 

Examples include buCCP-AK-IAK SummDQOs; Reinformatio(discussed process by including tqualificatioto the CTP offered to 

Have applicable DQOs been addressed as follows: 

• Has adequate review of AK information been 

performed to determine whether the waste was generated by defense activities or is commingled with RH TRU waste generated by defense activities? This determination will be established by the AK data compiled. 

• Review the AK information to determine the 

nuclear properties of the waste stream. The nuclear properties relevant to RH TRU waste include: TRU activity of the waste stream greater than 100 nCi/g of waste. Is this TRU waste? Will load management take place? 

WCPIP Rev. 0D Section 4 Interview of AKEs/SPM 

including Steve Schafer, Kevin Peters, Lisa Price, Mark Doherty, Larry Porter; review of AK Summary and AK Source Document Reference List; examination of selected objective evidence 

Examples include buCCP-AK-ICCP-AK-I502 Rev. 0ID-ANLEC330, U01C348, P03U040, U07C121, P00U013. P03AK record supporting 
AK-9 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: JRequired Technical Elements Procedure Location/Adequacy Verification of Activity Obje

waste? Will load management take place? 

• What information is included in the AK Record 

and AK Summary to demonstrate that the waste is RH waste? Dose equivalent rate equal to or greater than 200 mrem/hr and less than 1,000 rem/hr at the surface of the payload container. 

• Does the AK Record adequately present, support 

and report activity of the 10 required radionuclides (TRU isotopes 238Pu, 239Pu, 240Pu, 242Pu, and 241Am; and non-TRU isotopes 137Cs, 90Sr, 233U, 234U, and 238U)? Furthermore, Does 

AK provide information to determine the total activity in each canister. Must be less than 23 curies per liter. 

• Are AK records used to calculate, compute, or 

otherwise derive the total activity and/or TRU activity of the waste and the records? If so, were they qualified by peer review, confirmation, or equivalent QA (see relevant checklists/analyses for these elements, if performed)? Were data collected under an EPA-approved program? If so, the records alone may be used to satisfy DQOs; otherwise, the above characterization objectives must be met by collecting additional data during packaging, etc. Was data collected, that would be considered AK collected under an EPA qualified program, assembled and used? If so, what was it and how was it used? (e.g., identification of SCG for use in DTC) 

• Has AK been used to compile information 

regarding the waste stream waste material parameters to provide a detailed description of the waste stream in accordance with the format of the AK Summary Report? 

• Has AK information been used to to determine 

the absence of residual li

quids? This review 

data that suof waste nwill be mathan the AEPA 10 rarecord, and analysis bacontainer gBecause Dcontainers16 vs. the Note that cverificatiodeterminatdisposal rewaste streaVE tapes/rfrom the AEPA expecinformatiowould idendue to posmanagemeAK SumminformatioAlso, load would requit were donAccuracy to Lot 16 cthis lot (sebelow). 
AK-10 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: JRequired Technical Elements Procedure Location/Adequacy Verification of Activity Obje

may include waste packaging procedures and other documented administrative controls, such as training records that identify control of residual liquids. It may also include previous waste characterization data or information from waste-container-specific packaging logs. The criterion in the DQO is that residual liquids must be less than 1 percent by volume of the waste container. 

AK Summary Report Preparation Has an AK Summary been prepared and does it follow the format specified in Attachment 1? The report shall include the following: 

• Program and waste stream narrative • Sections as defined in the WCPIP. • Detailed description of the waste stream 

including information on, for example, specific waste matrix materials and fill volumes. 

• The report shall address all of the DQOs as noted 

in previous steps with appropriate justifications and references in the text. 

WCPIP Rev. 0D Attachment A Interview of AKEs 

including Steve Schafer, Kevin Peters, Lisa Price; review of AK Summary and AK Source Document Reference List; examination of selected objective evidence 

Examples include buCCP-AK-IThe AK Su500 includthe report radiologicaCCP revisinformatioradiologicanot include statements adequately spec data wdata. INLCCP-AK-Ithese issueare importprocess, so changes to impact the Changes to this proces
AK-11 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: JRequired Technical Elements Procedure Location/Adequacy Verification of Activity ObjeHave the following documents been completed in addition to the AK Summary; are they available for EPA review and are they technically adequate? 

• AK Waste Summary Report, • AK Source Document Reference List, • Correlation and Surrogate Summary Form, • AK discrepancy resolution documentation and 

the 

• AK source document summaries 

WCPIP Rev. 0D Attachment A Interview of AKEs 

including Steve Schafer, Kevin Peters, Lisa Price; review of AK Summary and AK Source Document Reference List; examination of selected objective evidence 

Examples include buCCP-AK-IReference Summary Document correspondunpublishe

Have all of these been provided to the SPM for review as required in Section 6.7 of the WCPIP Attachment A? Did the AK personnel recommend how the SPM should assess and qualify the information? (6.8) 

WCPIP Rev. 0D Attachment A Interview of AKEs 

including Steve Schafer, Kevin Peters, Lisa Price, Review of AK Summary and AK Source Document Reference List; examination of selected Objective Evidence. 

Examples include buCharacteriWaste Stre500 and 50Summary Interview winformatiofor reviewpersonnel assesses daindepende

Reconciling Compiled AK Information 

Has the SPM Reviewed the AK Summary Report, AK Source Document Reference List, Correlation and Surrogate Summary Forms, the referenced source document summaries, if applicable, batch data reports from any confirmatory activities such as VE or NDA and, if applicable, supplemental data collected during repackaging using an approved technique, to determine if the AK record is reconciled and is adequate to characterize the waste stream or waste stream lot and satisfy the relevant DQOs? 

WCPIP Rev. 0D Attachment A Interview of Larry Porter; 

review of the AK Summary Report, Correlation and Surrogate Summary forms, BDRs and other supporting verification activities. 

Examples include buCCP-AK-ISource DoCorrelation Forms; souincluded foprovided), 740, 742, 7
AK-12 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: JRequired Technical Elements Procedure Location/Adequacy Verification of Activity ObjeDiscrepancies between the AK record and confirmatory test results identified during this reconciliation process must be resolved and documented. What is the AKmeasurement discrepancy resolution process employed and is it satisfactory? Does it involve reevaluation of the AK record, reassignment of waste stream parameters, and a revision to the AK Summary Report? 

WCPIP Rev. 0D Attachment A Interview of AKEs/SPM 

including Steve Schafer, Kevin Peters, Lisa Price, Mark Doherty, and Larry Porter; review of AK Summary and AK Source Document Reference List; examination of selected objective evidence. 

Examples include buCRRs. No Record anwere founddetailed anAK using CCP at INbolster use factor assucomparablreport comAK for theand DTC/V

AK Accuracy Has the SQAO, consistent with the requirements of Section 4.1.1.2 of the WCPIP, reviewed the AK Summary Report, confirmatory test data and identified AK discrepancies, and prepared an AK Accuracy Report. This report will identify the percentage of containers that have been assigned to another SCG as well as radiological issue. 

WCPIP Rev. 0D Attachment A Interview of A.J. Fisher; 

examination of AK Accuracy report. 

Examples include buAK Accurwaste streaof an AK Aradiologicadrums (preresults is rAK Accuris also requ

How did the SQAO determine what is to be considered a “significant” radiological discrepancy and is this determination technically sufficient and adequate? 

WCPIP Rev. 0D Attachment A Interview of A.J. Fisher; 

examination of AK Accuracy report. 

Examples include buAK AccurINL-CCP to CCP-AK500 that boAK and Daccuracy, iINL-502 wthe mass scompariso
AK-13 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: JRequired Technical Elements Procedure Location/Adequacy Verification of Activity ObjeHas the AK Accuracy report been updated annually? Even if the report is only updated annually, will they continually assess AK Accuracy? 

WCPIP Rev. 0D Attachment A Interview of A.J. Fisher; 

examination of AK Accuracy report. 

Examples include buAK Accurpast, has pbasis. ProEPA as pre

Has the AK Accuracy fallen below 90%? If so, the site shall document this as a significant condition adverse to quality as defined by the CBFO QAPD. The site shall notify the CBFO of this condition and implement appropriate corrective actions before proceeding with further characterization activities on the affected waste stream(s). 

WCPIP Rev. 0D Attachment A Interview of A.J. Fisher; 

examination of AK Accuracy Report. 

Examples include buAccuracy rWCPIP anit is anticipshow that 90%. 

Preparation of the CRR Has the SPM reviewed the qualified AK characterization information and the corresponding required DQOs and documented this review in an RH TRU waste AK Characterization Reconciliation Report (CRR)? At a minimum the CRR shall include: 

• Specification of applicable site and waste 

stream. 

• A listing of each DQO • Data from the AK record that addresses each 

DQO 

• AK source document references that 

support/provide the data 

• A listing of AK record discrepancy resolutions, 

if any, that are relevant to each DQO 

• Documentation, including specific references, of 

how the AK data for each DQO were qualified, such as batch data reports, corroborative data, proceedings of a peer review, etc. 

WCPIP Rev. 0D Attachment A; CPTP-506 Rev. 2 Review of the CRR for select ANLE RH waste 

stream; Interview of Larry Porter, SPM. 

Examples include buWSPF and 00738, 739revised to recognize as a DQO. The CRR ithe WCPIP 
AK-14 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: JRequired Technical Elements Procedure Location/Adequacy Verification of Activity Obje

• Radiography and/or visual examination 

summary to document that liquids greater than 1 percent are absent from the waste and to confirm AK concerning the physical properties of the waste 

• A summary presentation of radiological 

measurement data used to meet the DQOs and to confirm AK 

• A complete AK summary • A complete listing of all container identification 

numbers used to generate the WSPF, crossreferenced to each batch data report. 

• A listing of AK discrepancies generated by an 

AK qualification process and the corresponding resolutions 

• Signature of the SPM 

Has the SPM verified that the applicable QAOs (accuracy, completeness, representativeness, and comparability) associated with the AK process have been met? 

WCPIP Rev. 0D Attachment A; CCP-TP-506 Rev. 2 

Review of the CRR for select ANLE RH waste stream; interview of Larry Porter, SPM. 

Examples include buWSPF, CRincluded o

Preparation of the Waste Stream Profile Form Has the SPM completed the Waste Stream Profile Form (WSPF) (Attachment 4) based on AK characterization and confirmation results and other relevant characterization data? Is the form complete and adequate/accurate? 

WCPIP Rev. 0D Attachment A Review of the WSPF and 

related attachments; interview of Larry Porter, SPM. 

Examples include buDraft WSPSummary See commSummary was a drafpurposes ofinal versiocompleted related atta
AK-15 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: JRequired Technical Elements Procedure Location/Adequacy Verification of Activity ObjeHave the WSPF, the RH AK Summary Report, and the Characterization Reconciliation Report, resulting from waste characterization activities, been transmitted to the Department of Energy Carlsbad Field Office (DOE/CBFO)? Only RH TRU waste that is characterized in accordance with the EPA requirements and WCPIP will be accepted for disposal at the WIPP. 

WCPIP Rev. 0D Attachment A Review of the WSPF and 

related attachments; interview of Larry Porter, SPM. 

Examples include buDraft WSPAK-INL-5available aprovided trelated attaapproved. 

Records Have the following records been generated and what is the disposition of these records? 

• AK Summary Report (Attachment 1) • AK Source Document Reference List 

(Attachment 2) 

• Correlation and Surrogate Summary Form 

(Attachment 3) 

• Waste Stream Profile Form (Attachment 4) • AK Source Document Summary (Attachment 5) 

• Characterization Reconciliation Report • AK Source Documents • AK Training Records • AK Discrepancy Resolution Documentation • AK Accuracy Report 

WCPIP Rev. 0D Attachment A Interview of AKEs Kevin 

Peters, Steve Schafer, Lisa Price, Sheila Pearcy; examination of required references as listed (objective evidence). 

Examples include buCCP-AK-ISource DoCorrelation draft WSPC, U, and records for DR010, D(current coMs. Pearcy included aNew Mexi

Confirmatory Test Plan 

 WCPIP Rev. 0D Attachment A Interview of AKEs Kevin 

Peters, Steve Schafer, and Mark Doherty, and examination of objective 

id

Examples include buCCP-AK-Iduring the 
AK-16 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: JRequired Technical Elements Procedure Location/Adequacy Verification of Activity Obje

evidence. regarding t

approach tof AK, and approach ucontaining characterizreflected ECertificatioinformatiomore clearthe documPlan. EPA document precisely pcharacterizstream, regto present 
Revision No.: 3 RC-DTC-1 

ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-T

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: J

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

Technical Documents/Procedures Identify all INL-CCP documents that provide technical information relative to performing and documenting the implementation of the DTC method, including operational procedures, and indicate the current revision of each. 

Y DOE/WIPP-02-3124, 

Rev. 0D 

All INL-CCP documents were reviewed before, during, or directly following this inspection. The correct revisions for each are noted in Objective Evidence in the cell to the left in this row. 

Y D

5R0pH

Dose-To-Curie Instruments Verify the following: 

• Specifications for the instruments 

used for dose rate measurements of RH TRU waste containers are provided in INL-CCP documents 

• Performance and measurement 

control criteria for dose rate instruments have been specified and integrated in INL-CCP operating procedure(s) 

• The instruments used to make dose 

rate measurements of RH containers are identified 

• The instruments identified in 

previous bullet have been appropriately calibrated 

• The scale used to weigh the 

containers has been calibrated and that the scale has been checked each operational day 

Y CCP-TP-504, Rev. 3, 

Section 4.1 

These technical aspects were verified by examination during the inspection 

Y C

IBDcMASADR3t

Verify that the instruments used for dose rate measurements of RH TRU containers are properly calibrated to provide data that are 

Y CCP-TP-504, Rev. 3, 

Section 4.1 

Calibration sheets for the ion chambers used were examined. 

Y I

R

(
Revision No.: 3 RC-DTC-2 

ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-T

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: J

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

consistent with those used in the calculation of the radionuclide-specific activity. 

(

Verify that the position of the detector relative to the waste container and any intervening shielding is consistent with that used in the calculation of the expected radiation dose. 

Y CCP-TP-504, Rev. 3, 

Section 4.1 

Detector position relative to the waste container and shielding is addressed appropriately. 

Y I

R(
Revision No.: 3 RC-DTC-3 

ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: J

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

General Technical Requirements DTC must provide information to support the reporting of quantitative values and uncertainties for 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 233U, 234U, 238U, 90Sr and 137Cs. 

Y DOE/WIPP-02-3124, Rev. 

0D, Attachment C, Section 8.0 

Quantitative values and uncertainties for 

238Pu, 239Pu, 240Pu, 242Pu, 241Am, 233U, 234U, 238U, 90Sr, and 137Cs are reported. 

Y I

R(

Verify that a waste container is classified as RH TRU only if the dose equivalent rate at the exterior of the surface of the container is between 200 mrem/hr and 1000 rem/hr and the concentration of alpha-emitting TRU radionuclides is greater than 100 nCi/g waste. 

Y DOE/WIPP-02-3124, Rev. 

0D, Attachment C, Section 12.0 

All containers in RH TRU waste stream ID ANLES5000 meet the criteria for TRU (concentration of alpha emitting TRU radionuclides greater than 100 nCi/g waste) and RH (dose equivalent rate at the exterior of the surface of the container between 200 and 1000 rem/hr) 

Y I

R

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

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 7.0 

The technical adequacy of the calculations involving the application of scaling factors and/or correlation techniques is addressed in Section 8.3. 

Y S

aIR

Measurements: Dose Rate and Background Verify the following: 

• Dose rates are measured four (4) 

times at a detector-to-container distance of 1 meter, with the container rotated 90° between each of the four measurements 

• The appropriate ion chamber and 

probe are used 

• The radiation field is measured at 

least two locations about the container at the mid-height of the 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 7.0 

INL-CCP DTC Batch Data Report No. INL-RH-DTC 06001 examined for this inspection documented technically appropriate collection of containerspecific dose rate data. 

Y I

RcMADRR
Revision No.: 3 RC-DTC-4 

ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: J

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

container and a distance of onemeter from the surface of the container. 

Verify that the background rate is measured and recorded and that actions are taken to reduce the background if the measured background radiation levels are greater than one-tenth of the expected container rate. 

Y CCP-TP-504, Rev. 3, 

Section 4.1 

INL-CCP DTC Batch Data Report No. INL-RH-DTC 06001 examined for this inspection documented technically appropriate background measurement data. 

Y I

RcCC

Measurement Documentation Verify that container number, waste stream identifier, and all pertinent container-specific measurement data are entered into the “Waste Container Dose-to-Curie Conversion Record” spreadsheet, including: 

• Date of the gamma measurements • Waste stream designation • Container number • Container gross weight • Estimated can size for Cans #1, #2, #3 • Estimated fill percentage for cans #1, 

#2, #3 

• Four (4) quadrant dose rates • Average of four (4) dose 

measurements 

• Expected container dose rate • Waste material type (matrix) 

Y DOE/WIPP-02-3124, Rev. 

0D; CCP-TP-504, Section 4.2 

INL-CCP DTC Batch Data Report No. INL-RH-DTC 06001 examined for this inspection contained all required documentation. 

Y I

RcC

ADRR
Revision No.: 3 RC-DTC-5 

ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: J

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

Verify that DTC BDR INL-RH-DTC 06001 contains the following items: 

• Batch Data Report Cover Sheet, 

Attachment 4 

• Batch Data Report Table of 

Contents, Attachment 5 

• Batch Data Report Narrative 

Summary, Attachment 6 

• ITR Review Checklist, 

Attachment 7 

• Measurement Control Report, 

Attachment 1 

• Container Data Sheet(s), 

Attachment 2 

• Waste Container Dose-to-Curie 

Conversion Record(s), Attachment 3 

• Copy of NCRs, if applicable • Evidence of a review by an ITR and 

SPM, as appropriate. 

Y CCP-TP-504, Rev. 3, 

Section 4.3 

INL-CCP DTC Batch Data Report No. INL-RH-DTC 06001 contained all required elements. 

Y I

R(

Verify that records generated in support of DTC are available for inspection. Records include the following, at a minimum: 

• Site-specific procedures developed 

to implement the DTC method 

• Technical basis for the 

determination of the waste stream’s “Standard Mix”, shielding

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 15.0 

All records related to DTC were available for this inspection on-site at INL and in CBFO Headquarters in Carlsbad, New Mexico. 

Y I

R(
Revision No.: 3 RC-DTC-6 

ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: J

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

calculations for waste containers 

• Technical basis for determination of 

radionuclide scaling factors 

• TMU technical support documents 
Revision No.: 3 RC-DTC-7 

ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: J

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

Technical Basis Verify the following: 

• Results of sampling and calculation 

form the basis for the development of radionuclide scaling factors used to convert measured dose rates to radionuclide-specific activities 

• Dose rates are measured at a 

distance of one meter from the outer surface of the waste container at the mid-height of the container 

• Calculations appropriately present 

the relationship between a container’s measured dose rate and the waste’s activity 

• Calculations account for all relevant 

container properties, specifically fill height (apparent density), waste type (matrix), and attenuation (shielding) of the container and/or liner wall 

• Calculations are performed using 

technically appropriate shielding analysis techniques 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 7.0; CCP-AK-INL-501, Rev. 0; CCP-TP-504, Rev. 3, Section 4.3 

These technical aspects were examined before, during, and following this inspection in consultation with CTAC technical personnel. 

Y C

RIR

Verify that waste containers contain only matrices for which the DTC methodology has been established. 

Y DOE/WIPP-02-3214, 

Rev. 0D, Attachment C, Section 5.0 

RH waste cans contain metals (steel), concrete, or organics with a minimum of mixing of dissimilar types of materials. Fill heights are specified for all containers, i.e., less than 25% full, 

Y I

IDB
Revision No.: 3 RC-DTC-8 

ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: J

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

Verify that the type of waste (waste matrix) in each container is recorded along with the height of the waste in the container. 

25% to 66% full, 66% to 90% full, more than 90% full). 

Verify that all DTC-related calculations have been subjected to a technical review and that all technical review comments and their resolutions are documented. 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 14.0 

With minor exceptions, all calculation packages contain evidence of a technical review. 

Y E

pdsVS

Verify that the ratio of actual measured dose rate to the calculated dose rate is used to calculate a scaling factor that is applied to the “Standard Mix” or subset thereof, that was used to estimate individual radionuclide activities. 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 11.0; CCP-TP-504, Rev. 3, Section 4.2 

The “Standard Mix” was not used to generate scaling factors for this waste stream. The technical documentation of the scaling factor development supports the use of dose rate measurements. 

Y C

RI

Total Measurement Uncertainty (TMU) Verify that a method for estimating total measurement uncertainty (TMU) has been developed and documented for RH TRU waste stream ID ANLES5000. 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 13.0 

This checklist addresses the aspects of TMU attributable to DTC. The aspects of TMU related to the development and application of radionuclide scaling factors are addressed in Section 8.3. 

Y C

RI

TMU is based upon the propagation of uncertainties present in all aspects of radiological characterization, including DTC. 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 13.0 

TMU includes the contributions of all applicable aspects of the DTC process. 

Y C

R

Verify that the approach for TMU determination incorporates the contributions of all applicable components of DTC, including: 

• Measured sample isotopic activities • Relative uncertainties associated 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 13.0 

TMU includes the contributions of all applicable aspects of the DTC process. 

Y C

RI
Revision No.: 3 RC-DTC-9 

ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-

EPA Inspection No.: EPA-INL-CCP-RH-6.06-8 Inspection Date: J

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

with each measured radionuclide 

• Measurement of the container’s 

dose rate 

• Determination of waste mass • Modeling errors or biases. 

Verify that the TMU approach has been formally submitted to CBFO for review and approval. 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 13.0 

The TMU approach was evaluated by the CTAC Technical Specialist (D. Stuenkel) during this inspection. 

Y I

R
VE-1

ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-06.06-8 Inspection Date: Ju

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evid

RHVE-1 Site procedures identify required training and qualifications for RHVE personnel.

WCPIP, Rev. 0D, Section. 4.1.2.2 CCP-QP002, Rev. 20 

• OJT training for operators, including: 

identification of summary category groups, WMPs, packaging configurations, and residual liquids 

• Formal training elements include: project 

requirements, container identification and labeling, applicable state and federal regulations 

• Site-specific instructions waste 

generating practices and expected packaging configurations 

Y INL-CCP uses Qualification C

personnel. The training procedof the WCPIP for training of RINL-CCP provided documentbeen trained on the AK summprocessed. On some of the revincorrect waste stream numbecorrected this error during the Objective evidence:

1. Qualification cards for VE 

RHVE-2 Operator qualification and requalification requirements are described

WCPIP, Rev. 0D, Section. 4.1.2.2 CCP-QP002, Rev. 20, Section. 4.2.5 

• To become qualified, the RHVE operator 

must pass a comprehensive written test based on training objectives with a minimum score of 80% 

• Demonstrate capability in the presence of 

the site VEE during OJT 

• RHVE operators re-qualified every 2 

years based on continued satisfactory performance 

• Unsatisfactory performance – failed to 

identify prohibited item during OJT of score of less than 80% on exam 

N INL-CCP had only generated 

(BDR) that had been through that the BDR was generated, trequired written examination. below to address this issue: INL-CCP-RH-VE-06-001F, R

(Swami Raman, William Boydtheir OJT training requiremennot take the required written teoperators were not qualified to two dates, but they performed RHINLVE060001 during this initiated CAR-RHINL-0001-0occurrence. However, the cornot include review of the subjquality had not been negativelRHINLVE060001 is the only can use to demonstrate the RH Objective evidence:

1. BDR # RHINLVE60001 
VE-2

ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-06.06-8 Inspection Date: Ju

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evid

RHVE-3 Each site has a designated VE expert (VEE) 

WCPIP, Rev. 0D, Section. 4.1.2.2 CCP-PO001, Rev. 12 

• VEE designation is documented • VEE has knowledge of the RH TRU 

waste being characterized 

• Responsible for overall direction and 

implementation of VE at the facility 

• Certification Plan specifies the 

selection, qualification, and training requirements of VEE 

Y VEE training and designation 

site inspection. Objective evidence:

1. Qualification Card for VE

RHVE-4 CCP-TP509, Rev. 0, 

Section. 4.4 

• Operators review AK Tracking 

Spreadsheet to verify that correct containers examined 

• Rejected containers are placed in a 

shielded container with an INL-CCP Hold Tag attached 

• Provide container processing information 

to SPM/VPM 

Y INL-CCP intends to use two (

data for RH containers. The opaudio/videotapes and complettheir observation of the recordaccess to the AK for the waste site. INL-CCP had only generated (BDR) that had been reviewed EPA did not observe the VE p

Objective evidence:

1. BDR # RHINLVE60001 

RHVE-5 Procedures and technical guidance documents provide complete instructions for performing RHVE. 

WCPIP, Rev. 0D, Sections. 4.1.2, 4.1.2.1, 4.3.3 CCP-TP500, Rev. 1, Section. 4.0, Attachment 

1

Procedures are sufficiently detailed to enable the operator to determine if a waste container meets the criteria of 194.24 with regard to identifying applicable parameters with waste limits 

• All existing VE tapes will be reviewed 

and the VE data will be documented 

• Existing waste container packaging 

records will be qualified by VE or RTR 

N CCP-TP-500 was written base

CCP would be performing actto write a procedure for watchconcern INL-CCP-RH-VE-06Weight for 30-gallon containeaid. Weight of cans given to 2 WMP weights also in 2 decimINL-CCP uses a spreadsheet “version 0.xls, to ensure that th

weight of the container. This s
VE-3

ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-06.06-8 Inspection Date: Ju

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evid

1 • 100% of containers will be subject to VE 

at the time of packaging 

• Waste stream description and WMC 

verified 

• Presence/absence of prohibited items 

because the data will not be us

EPA reviewed the video recorsheets for containers in BDR # presence/absence of prohibiteWMC was confirmed. Howevcomplete inventories of the wgenerated the concern INL-CCto address this issue. INL-CCP provided EPA with about the waste stream being • There are 549 drums in w

videotapes recording the 

• 15 of the drums were loca

be examined by RTR. 

• 36 drums had been looked 

INL-CCP does have some containers, but the PIP do

• None of the 70 drums tha

in flooded vaults. 

• Started video taping the V• INL-CCP is buying a new 

available in July 2006) to in the waste stream. 

ANL-E waste: 48 drums ± 50 hot cells and needs to be packUse spreadsheet to total weighversion 0.xls. Software not codata will not be used for certifINL-CCP-RH-VE-06-003CR, 

to be a consistent protocol for 
VE-4

ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-06.06-8 Inspection Date: Ju

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evid

forms, Attachment 1 of CCP-Tcan 161 in container No. 0076cardboard that were not enteresection of Attachment 1. For No. 00748, cardboard and Kleover 5 times each but were noof Attachment 1. However, fopiece of wood was called out as was a single marking pen. unable to provide the rationale what items were/were not recoreported inventory for waste cResolution: A briefing was properators addressing this issue INL-CCP-RH-VE-06-002CR: 

Remote-Handled Waste Visuainstructions for performing anexamination (VE) event. Howsupport of the RH program doconsists of operators viewing audio/visual recordings. The odocumenting the items and Wrecording. INL-CCP has not gprocedure for this process. 

Objective evidence:

BDR # RHINLVE60001 

RHVE-6 CCP-TP500,Section. 

2.4.2 

• Corrective actions are taken when 

necessary 

• When are NCRs necessary? 

Y Glass bottles form part of the 

stream contents. Some bottles contents cannot be seen. Thesrequired. NCRs are listed on the BDR Treviewed to ensure that they a
VE-5

ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-06.06-8 Inspection Date: Ju

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evid

Objective evidence:

1. BDR # RHINLVE60001 

RHVE-7 Site procedure(s) require data generation and project level reviews of Batch Data Reports (BDRs). 

WCPIP Section. 4.1.2.1 CCP-TP500, Rev. 1, ITR: Section. 4.3.5-4.3.8, Attachment 2 SPM: Section. 4.4, Attachment 3 

• ITR review Attachment 2 • SPM review Attachment 3 

Y The generation level and proje

reviewed in the one (1) BDR a

Objective evidence:

1. BDR # RHINLVE60001 

RHVE- 8 CCP-TP500, Rev. 1, 

Section. 5.0 

• Lifetime/QA records – Attachments 1-5, 

Copy of NCRs 

• QA/nonpermanent records – VHS tape or 

DVD (primary and backup) 

Y When INL-CCP reviews an or

responsible for records make 2 

Objective evidence:

1. BDR # RHINLVE60001 

RHVE-9 Quality Assurance Objectives are defined and met. 

WCPIP, Rev. 0D, Section. 4.1.2.3 

QOAs are defined for: Precision – maintained by reconciling any discrepancies between 2 operators (or operator and ITR) with regard to physical form of waste, absence of residual liquid Accuracy – maintained by requiring operators to pass a comprehensive test with a score of 

80% and demonstrated satisfactory

N At the time of the inspection I

that the QAOs for accuracy, recomparability had been met (sRH-VE-06-003CR, Rev.. 1 anRev. 1). Objective evidence:

1. Qualification cards for VE 
VE-6

ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-06.06-8 Inspection Date: Ju

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evid

performance for initial qualification and requalification Representativeness – Contents placed in container will be described on the data forms Completeness – Relevant waste information must be collected and documented on a videotape and/or data form or other unalterable media Comparability – ensured by site meeting training requirements and complying with the minimum standards used to implement VE 

2. BDR # RHINLVE60001 

RHVE-10 VE as a method to qualify AK data 

WCPIP, Rev. 0D, Section. 4.3, 4.3.3 

If VE is used as a qualification method for AK, all of the requirements in Sections 4.3 and 4.3.3 are met: • Quality and reliability of the 

measurement control program under which the data were generated (QC samples included in the VE process) 

• Extent to which the data demonstrate the 

properties of interest (VE process generates data for all items in containers) 

• Qualification of personnel generating 

data (training records for personnel on tapes performing the original VE event) 

• Technical adequacy of the procedures 

used to generate the original data (copies of original procedures) 

N • INL-CCP uses 2 operator

• The VE events (original v

reviewed during the inspeitems identified in the con003CR, Rev. 1) 

• The two operators that ge

RHINLVE60001 were nothe VE data (INL-CCP-R

• The procedure CCP-TP-5

for performing VE by rev(INL-CCP-RH-VE-06-00

RHVE-11 Confirmatory testing plan for use of VE data to qualify AK

WCPIP, Rev. 0D, Section. 433

1. Description of waste stream or waste 

stream lots to which the plan applies 

2. Explicit description of the waste

NA See AK checklist. 
VE-7

ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-RH-06.06-8 Inspection Date: Ju

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evid

of VE data to qualify AK 4.3.3 

CCP-AKINL-502, Rev. 0 

characterization DQOs and QAOs that will be satisfied with the data being qualified 

3. Description of the confirmatory testing 

proposed and the percentage of waste containers that will be tested 

4. Description of how the tested 

subpopulation will be representative of the waste stream or waste stream lot 

5. Quantitative acceptance criteria for 

determining that the AK information in question can be qualified as characterization information 

Information Included in INL-CCP RH VE BDR

Required Testing Batch Content Present Y or N Required Testing Batch Content Present Y or N Required Testing Batc

Table of Contents Y Date of measurement Y Testing batch number Test facility name Y SGC Y Batch report date Container or sample numbers in batch Y Prohibited items Y QC documentation Procedure used Y Testing report sheet for each container Y Copies or reference to NCOperator signature and date Y Data review checklists Y ITR signature and date Signature release by SPM or designee 
 

Attachments B.1 through B.8
 Page 1 of 1

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

B-1 

Inspection No. EPA-INL-CCP-RH 06.06-8 Issue Number: INL-CCP-RH-VE-06-001CR, Rev. 2 

Date: 6-13-06 

Inspector: Dorothy E. Gill 

Attachments? YES NO 

Sample Size: AK NDA Memos 

Population size (if known): Three (3) 

A. Description of Issue: The three VE operators (Swami Raman, William Boyd, and John Hegsted) 

completed their OJT training requirements on February 22, 2006 but did not take the required written test 

until April 10, 2006. These operators were not qualified to perform VE between these two dates, but they 

performed VE on containers in BDR RHINLVE060001 during this time period. INL-CCP initiated CARRHINL-0001-06 in response to this occurrence. However, the corrective action implemented did not 

include review of the subject VE data to ensure that data quality had not been negatively affected. BDR 

RHINLVE060001 is the only completed BDR that INL-CCP can use to demonstrate the RH VE process. 

B. Regulatory Reference: 40 CFR 194.24 (c), 

C. Site requirement(s): CCP-QP-002, Revision 20

D. Discussed with: 

Site Personnel: Larry Porter, Rebecca Walker, Cindi Becker 

 DOE/CTAC Personnel: Wayne Ledford, Porf Martinez 

 Other Personnel: NA 

E. Additional Comments: Before implementing this procedure at other CCP sites, the impact of this 

concern should be evaluated for inadequacies. 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: July 5, 2006 
 Page 1 of 1

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

B-2 

Inspection No. EPA-INL-CCP-RH 06.06-8 Issue Number: INL-CCP-RH-VE-06-002CR 

Date: 06-13-06 

Inspector: Dorothy E. Gill 

Attachments? YES NO 

Sample Size: 1 procedure 

Population size (if known): 1 procedure 

A. Description of Issue: Procedure CCP-TP-500, Remote-Handled Waste Visual Examination, 

Revision 1 contains instructions for performing and documenting a visual examination (VE) event. 

However, the VE performed in support of the RH program does not involve actual VE, but consists of 

operators viewing previously generated VE audio/visual recordings. The operators complete a data form 

documenting the items and WMPs seen in the audio/visual recording. INL-CCP has not generated a 

standard operating procedure for this process. 

B. Regulatory Reference: 40 CFR 194.24 (c) 

C. Site requirement(s): CCP-TP-500, Revision 1 

D. Discussed with: 

 Site Personnel: Larry Porter, Tommy Mojica 

 DOE/CTAC Personnel: Wayne Ledford, Porf Martinez 

 Other Personnel: NA 

E. Additional Comments: Before implementing this procedure at other CCP sites, the impact of this 

concern should be evaluated for inadequacies. 

 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: July 5, 2006 
 Page 1 of 1

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

B-3 

Inspection No. EPA-INL-CCP-RH 06.06-8 Issue Number: INL-CCP-RH-VE-06-003F, Rev. 2 

Date: 6-13-06 

Inspector: Dorothy E. Gill 

Attachments? YES NO 

Sample Size: 4 

Population size (if known): <70 

A. Description of Issue: There does not appear to be a consistent protocol for entering items on the VE 

data forms, Attachment 1 of CCP-TP-500. For example, waste can #161 in container No. 00761 contained 

both Kleenex and cardboard that were not entered in the item description section of Attachment 1. For 

waste can # 149 in container No. 00748, cardboard and Kleenex were clearly called out over 5 times each 

but were not entered in the item description of Attachment 1. However, for this same waste can, a single 

piece of wood was called out and entered into Attachment 1, as was a single marking pen. The operators 

interviewed were unable to provide the rationale for the discussions regarding what items were/were not 

recorded on the VE data form. The reported inventory for waste cans is therefore incomplete. 

B. Regulatory Reference: 40 CFR 194.24 (c)

C. Site requirement(s): CCP-TP-500, Revision 1

D. Discussed with: 

 Site Personnel: Larry Porter, Tommy Mojica 

 DOE/CTAC Personnel: Wayne Ledford, Porf Martinez 

 Other Personnel: NA 

E. Additional Comments: Before implementing this procedure at other CCP sites, the impact should be 

evaluated for inadequacies. 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: July 5, 2006 
 Page 1 of 1

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

B-4 

Inspection No. EPA-INL-CCP-RH 06.06-8 Issue Number: INL-CCP-RH-VE-06-003F, Rev. 2 

Date: 6-13-06 

Inspection No. EPA-INL-CCP-RH-06.06-8 Issue Number: INL-CCP-RH-AK-06-005CR, Rev. 1 

Date: 06-15-06 

Inspector: Connie Walker 

Attachments? YES NO 

Sample Size: Waste Stream ID-ANLE-S5000 and all 

other INL RH streams 

Population size (if known): Above waste streams 

Description of Issue: INL-CCP has indicated that AK will be used to determine all DQOs that must be assessed as specified in 

the WCPIP (e.g., Sections 2.2 and 4.2). The WCPIP, Attachment A, requires that for each DQO related to AK, AK personnel 

must identify the DQO and supporting AK information, justify the assignments/conclusions, reference the AK Source Documents 

and applicable pages supporting the assessment, and identify the qualification method in 40 CFR 194.22(b) that will be used to 

qualify the AK. This requirement is not adequately reflected in CCP-INL-AK-500. Revise the AK Summary CCP-INL-AK-500 

to address the above requirement, including revision of Chapter 6, entitled “Qualification of AK Information.” Note that based

on the EPA requirements, the DQOs will require revision to include identification and quantification of the 10 EPA WIPPtracked radionuclides in CCP-INL-CCP-AK-500. This AK Summary must be revised to address the following: 

• The AK Summary implies that some of the containers in the population may have been submerged in a few of the vaults. The 

AK Summary states that none of the population of approximately 70 containers that have videotapes being reviewed as a VE 

exercise were inundated, while others may have been. The discussion should be modified to clearly indicate the total number 

of drums in the stream, number of drums suspected of having been inundated, and how the inundated drums will be handled or 

otherwise managed. 

• Documentation for the waste’s defense determination should be included. 

• The definition of waste stream should be clearly supported. Specifically, the document needs to make a better argument that 

the wastes generated in the cells were never segregated by pin or generator, so there is no way a specific pin/radionuclide 

content can be assigned to waste containers. Therefore, the radiological characteristics of the pins must be assigned as a 

whole to the entire population. This assumption must be supported and justified. 

• The radiological data presented in the AK Summary does not provide a good understanding of the overall isotopic 

distributions being applied to the waste stream based on AK. While CCP-AK-INL-501 presents how each container is 

assessed, the AK Summary CCP-AK-INL-500 should still include a general discussion of the overall anticipated distribution 

on a waste stream basis, particularly since AK is being used to address all DQOs. Page 40 presents information for drums 

from 1990–1995, but more information should be included for the entire waste stream. 

B. Regulatory Reference: WCPIP, Attachment A; 40 CFR 194.24(c)(3), 40 CFR 194.22 

C. Site requirement(s): WCPIP, Attachment A (no site-specific AK procedure prepared). 

D. Discussed with: 

 Site Personnel: Steve Schafer, Kevin Peters, Mark Doherty, Eric D’Amico, Lisa Price 

 DOE/CTAC Personnel: Dick Blauvelt 

 Other Personnel: 

E. Additional Comments: 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: Prior to the next CCP RH inspection 
 Page 1 of 1

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

B-5 

Inspection No. EPA-INL-CCP-RH-06.06-8 Issue Number: INL-CCP-RH-AK-06-006CR, Rev. 1 

Date: 06-15-06 

Inspector: Connie Walker 

Attachments? YES NO 

Sample Size: Waste Stream ID-ANLE-S5000 and all 

other INL RH streams 

Population size (if known): See above waste streams 

A. Description of Issue: INL-CCP representatives stated that AK Qualification will always be the approach used to 

meet DQOs. As such, INL-CCP will always prepare an AK Confirmatory Test Plan (CTP) for each waste stream that presents a 

description of the proposed characterization plan for the waste stream and which will include how characterization will be 

accomplished for each DQO. The CTP CCP-AK-INL-502 must be revised to indicate, for each DQO, that AK qualification is 

the selected DQO determination methodology, and to specify the qualification pathway selected included detailed discussion of 

confirmatory methods used. Also, note that based on EPA requirements, the DQOs will require revision to include identification

and quantification of the EPA 10 radionuclides. Also, the CTP includes the proposed approach for assessing AK Accuracy, 

which is only the verification that waste is RH as identified by AK. The CTP also assumes that CCP-AK-INL-501 has 

established “no significant discrepancies” between AK information and confirmation of modeling/sampling. However, this 

assumes that the LANL Mass spec data are demonstrated applicable, and EPA has not fully assessed CCP-AK-INL-501, which 

presumably includes this information. Furthermore, since AK Qualification and confirmatory testing is used for all radiological 

parameters, it would appear that each radiological DQO should be evaluated with respect to how the confirmatory data collected 

will be assessed as part of AK Accuracy (if this is not possible for some reason, a detailed argument should be included). The

AK Accuracy report should be revised accordingly. 

B. Regulatory Reference: 40 CFR 194.24(c)(3), 40 CFR 194.22, WCPIP 

C. Site requirement(s): CCP-TP-002, Rev. 16 

D. Discussed with: 

 Site Personnel: Steve Schafer, Kevin Peters, Lisa Price, Mark Doherty, Eric d’Amico 

 DOE/CTAC Personnel: Dick Blauvelt 

 Other Personnel: 

E. Additional Comments: None 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: Prior to the next CCP RH inspection 
 Page 1 of 1

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

B-6 

Inspection No. EPA-INL-CCP-RH-06.06-8 Issue Number: INL-CCP-RH-AK-06-007CR, Rev. 1 

Date: 06-15-06 

Inspector: Connie Walker 

Attachments? YES NO 

Sample Size: Waste Stream ID-ANLE-S5000 and all 

other INL RH streams 

Population size (if known): See above waste streams 

A. Description of Issue: INL-CCP representatives have indicated that AK Qualification will be the 

method by which DQOs will always be addressed. Based on this, INL-CCP must examine site documents 

that discuss the characterization methodologies to ensure that each reflect the requirements presented in the 

WCPIP when AK Qualification is used. For example, the WCPIP requires that Certification Plan include 

how the DQOs will be addressed, and EPA indicated that this should include stream information. INL-CCP 

representatives have indicated that the Confirmatory Test Plan (CTP) will be prepared for each stream and 

will include this information. Therefore, INL-CCP should revisit documentation to ensure that this 

commitment is clearly cited in related documents to ensure that the CTP always fulfills this requirement. 

Note that based on EPA requirements, the DQOs will require revision to include identification and 

quantification of the EPA 10 radionuclides. 

B. Regulatory Reference: 40 CFR 194.24(c)(3), 40 CFR 194.22, WCPIP 

C. Site requirement(s): CCP-TP-002, Rev. 16; CCP-AK-INL-500; CCP-AK-INL-502; & CCP-TP-506 

D. Discussed with: 

 Site Personnel: Steve Schafer, Kevin Peters, Lisa Price, Mark Doherty, Eric d’Amico 

 DOE/CTAC Personnel: Dick Blauvelt 

 Other Personnel: 

E. Additional Comments: None 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: Prior to the next CCP RH inspection 
 Page 1 of 1

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

B-7 

Inspection No. EPA-INL-CCP-RH-06.06-8 Issue Number: INL-CCP-RH-AK-06-008CR, Rev. 1 

Date: 06-15-06 

Inspector: Connie Walker 

Attachments? YES NO 

Sample Size: Waste Stream ID-ANLE-S5000 and all 

other INL RH streams 

Population size (if known): See above waste streams 

A. Description of Issue: CCP-AK-INL-501 includes several statements, assumptions, and arguments 

without references to calculations or other information to support the arguments. Without references, it is 

not possible to verify conclusionary statements in the document. In particular, several other documents 

(CCP-AK-INL-500, CCP-AK-INL-502, etc.) state that CCP-AK-INL-501 shows that LANL and INL fuel 

pins had many common elements. The brief discussion on page 33 states that: “On the basis of the 

similarities between the two fuel pin examination programs, the fuel types, the sources of the pre-irradiation 

fuel composition and burnup information, and the identical reactors for a majority of the fuel pins, the 

LANL confirmatory sampling is sufficient to satisfy the qualification required for the INL AK 

information.” However, the document does not cite references or other detailed information to support this 

assertion. The document provides charts and other comparisons between pins and INL pins, but the specific 

INL pin numbers and related data and calculations are not referenced. Table 5-1 presents a summary of 

sponsors associated with ANL-E and LANL pins, but of the top three sponsors for LANL and ANL-E, only 

one was common to both. Additional information that better supports the commonalities between the two 

sites in the text of CCP-AK-INL-501 is necessary. The 28 calculation packages that support ORIGEN2.2 

should be included and/or referenced. The link between the INL and LANL fuel pins should be better 

documented and/or supported. Note that EPA has not concluded their review of input parameters to the 

ORIGEN2.2 code, so no issues associated with input data are provided. 

B. Regulatory Reference: 40 CFR 194.24(c)(3), 40 CFR 194.22, WCPIP 

C. Site requirement(s): WCPIP

D. Discussed with: 

 Site Personnel: Steve Schafer, Kevin Peters, Lisa Price, Mark Doherty, Eric d’Amico 

 DOE/CTAC Personnel: Dick Blauvelt 

 Other Personnel: 

E. Additional Comments: None 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: Prior to the next CCP RH inspection 
 Page 1 of 1

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

B-8 

Inspection No. EPA-INL-CCP-RH-06.06-8 Issue Number: EPA-INL-CCP-RH-06-009C 

Date: 8/29/06

Inspector: Dorothy E. Gill 

Attachments? YES NO 

Sample Size: 1 BDR 

Population size (if known): Three (3) 

Description of Issue: INL-CCP responded to EPA’s Concern Number INL-CCP-RH-VE-06-003CR, 

Revision 1 by providing additional training for VE operators and VEE/SME on June 15, 2006, Visual 

Examination Briefing to Clarify the Recording of Description of Container Contents on VE Data Forms. 

During this inspection, EPA evaluated the implementation of this response. Upon review, EPA verified that 

INL-CCP had provided additional training regarding how to inventory drum contents such that the DQOs 

for completeness and representativeness are met. Since generating the original data package 

(RHINLVE060001), INL-CCP has: tested and qualified VE operators and completed two more data 

packages (RHINLVE060002 and RHINLVE060003). However, EPA review of data package 

RHINLVE060003 indicates that further improvements are necessary. Based on the INL-CCP SPM’s (Larry 

Porter) review of this BDR, he determined that operators were not generating container inventories as 

required by training provided on June 15, 2006. When the ITR reviewed and approved this BDR to verify 

that all QAOs had been met, the ITR did not identify that the QAO for representativeness for all three of the 

containers in the BDR was not met.

B. Regulatory Reference: 40 CFR, Part 194.22, b, (3)

C. Site requirement(s): WCPIP, Revision 1, Section 4.2.3

D. Discussed with: Larry Porter, Irene Quintana 

E. Does this concern adversely affect the isolation of TRU waste? YES NO 

 Does this concern affect TRU waste that the site is approved to characterize? YES NO

F. Additional Comments: EPA may examine additional VE BDRs at a later date. 

G. Site Response Required? YES NO 

 Site Response Due Date: NA
Attachment C 

EPA’s Response to Public Comments 
C-1 

EPA’s Response to Public Comments 

EPA received one set of public comments from DOE’s Carlsbad Area Field Office (CBFO) in 

response to the November 8, 2006, Federal Register notice that proposed EPA’s decision to 

approve various components of the RH TRU waste characterization program implemented by 

CCP at ANL and INL (71 FR 65488, November 8, 2006). 

All comments are reproduced here along with EPA’s response to each comment. Both ANL and 

INL Baseline Inspection Reports have been revised to reflect EPA’s response, where appropriate. 

Comment No. 1: On page 65490 of the Federal Register (FR) Notice in the 3rd column it 

references “EPA INL CCP RH Inspection Report A-98-42, II-A4-69” and the correct reference is 

A-98-49. In addition, on page 65492 of the same notice in the 1st column the reference should be 

to A-98-49, as well, instead of A-98-42. 

Response: The comment applies to the FR notice. We concur with the comment, 

however, the error does not affect the sufficiency of the public’s notice of the proposed 

approval nor does it affect the final approval itself. 

Comment No. 2: EPA is using the Tier I and Tier II change notice process to collect additional 

information regarding a site’s waste characterization program. See Comments 9 and 10 below. 

The Tier change process is designed to notify the EPA of changes or expansions to programs 

subsequent to a Baseline Compliance Decision, not to generate additional information. The 

authority provided to the Agency under 40 CFR Part 194.8(b)(4) is for the expressed purpose of 

reporting changes to the Agency. For requests for additional information, the Agency is 

encouraged to implement the provisions of 40 CFR 194.4(b)(2). 

Response: By requiring INL-CCP and ANL-CCP to notify EPA of the availability of new 

or additional information generated following the EPA’s baseline inspection and the 

approval decision as part of the Tier 2(T2) change notice process, EPA will remain 

informed of improvements in the approved waste characterization processes (e.g., AK 

and DTC) in a timely manner. Through this process, EPA will verify that CCP has 

updated/substantiated information that was EPA evaluated during the baseline and 

follow-up inspections. 

EPA’s baseline inspection approvals are not contingent on review of any additional 

information. EPA agrees that T2 reports are intended to report changes to approved 

waste characterization programs. Also, T2 change reports are not the appropriate 

mechanism to generate new information that would assist in evaluating continuing 

compliance. As described in EPA’s final modification to 194.8(b) (69 FR 42571, July16, 

2004), EPA uses its authority under §194.24(h), when it is necessary, to generate new or 

additional information to ensure continued compliance with EPA regulations. When 

reporting T2 changes reflecting updates or addition of new information to the material 

inspected during the baseline inspections, EPA expects the RH site to provide a brief 

description of additions/updates to various AK and DTC documents. EPA can then 

decide whether review of this additional information under the authority of §194.24(h) is 
C-2 

warrented for evaluating adequacy and continued compliance with regulatory 

requirements. EPA then will request such information. EPA have made appropriate 

modifications to the INL and ANL final baseline inspection reports to clarify our intent. 

Comment No. 3: DOE is unclear as to the reasoning that the addition of a new piece of RTR 

equipment is considered a Tier I change by EPA for RTR of RH. However, as evidenced, for 

example, by the EPA approval of the INL-CCP CH Baseline, the addition of new RTR 

equipment would be a Tier II change. DOE requests that EPA explain this inconsistency.

Response: EPA identified the use of new RTR equipment for RH waste as a Tier I 

change because we did not evaluate any RTR equipment during the baseline inspection of 

June 2006 at INL. Since EPA has no information of how RTR would be applied to RH 

waste to characterize physical waste contents and the absence of prohibited items in the 

retrievably-stored RH containers, EPA identified RTR equipment and its use for RH 

waste as a T1 change. Under the CH program, EPA identified a new RTR process at an 

approved site as a T2 change because we had evaluated the CH RTR process during 

baseline inspections at all CH sites. 

Comment No. 4: There are a number of inaccuracies in the Inspection Report A-98-49, II-A4-

69 for EPA Baseline Inspection No. EPA-INL-CCP-RH-6.06-8. Some examples follow: 

a. Page 63, Section 8.3 in fifth bullet under Documents Reviewed identifies 19 

containers in VE Batch Data Report (BDR) RHINLVE60001, 17 of which were 

subject to a CCP Non Conformance Report (NCR). Actually, at the time of the 

inspection, 5 of the 19 containers were rejected by an NCR. 

b. Page 8, Section 6.2, Table 3 identifies personnel that were not at the inspection. For 

example, James Mobley (as a VEE), Buddy Fussell (as VE/VET) and Marcus Steade 

(as VE/VET) did not participate in the inspection. 

Response: EPA concurs with the comment. We have revised report text accordingly. 

The revision described in (a), above increases the number of acceptable RH containers to 

19 and not the number of containers stated in the proposed for approval in November 

2006. (For additional discussion, see EPA’s response to Comment Nos. 8 and 12, 

below.)

Comment No. 5: On page 2 of the EPA-INL-CCP-RH-6.06-8 Inspection Report, the EPA limits 

their approval of processes (AK, DTC, and VE) based upon waste streams reviewed during the 

inspection. The CBFO agrees that the EPA has the authority to limit their approvals to specific 

waste streams at a particular site; however, it is important to note that these characterization 

processes do not change between waste streams. 

As written, it is confusing as to which characterization processes are approved. The CBFO 

recommends that the EPA remove any waste stream specific approvals from process approvals 

and add an item 4 specifically detailing which waste streams are approved, as follows: 
C-3 

(4) Waste Stream No. ID-ANLLE-S5000 is approved for shipment. Any waste stream not 

approved under this approval must undergo a T1. 

The removal of waste stream approvals from process approvals should be done throughout the 

text, including Table 1 and Table 14 of Baseline Inspection Report No. 

EPA-INL-CCP-RH-6.06-8. 

Response: Waste characterization processes may change depending on the complexity of 

different waste streams. Therefore, until the RH sites generate and apply detailed 

procedures for the derivation/generation of scaling factors and other critical radiological 

characterization inputs from the analytical data and AK records, EPA must restrict its 

approval to waste streams that have demonstrated compliance during the baseline 

inspection and cannot approve entire waste categories as is typically done under the CH 

program. EPA expects scaling factors will vary by waste stream and the RH sites need a 

consistent way to generate them. Therefore, we believe it is premature for EPA to 

approve the DTC process until the RH sites develop procedure(s) for calculating scaling 

factors. 

EPA did not approve CH TRU Summary Waste Categories at the beginning of the CH 

program. When approving the site-specific CH TRU waste characterization programs 

initially, EPA approval was also limited to specific waste streams. The reason for a 

limited approval was that both characterization activities at the waste generator sites and 

EPA’s inspection process were in their infancy. As knowledge was gained and the sites’ 

CH waste characterization program matured, EPA was able to approve summary waste 

categories. EPA expects that as RH waste characterization programs mature and gains 

confidence in the sites’ ability to implement the RH WCPIP and comply with regulatory 

requirements as additional waste streams are characterized, we may be able to approve 

RH waste by Summary Waste Categories. The experience gained would then justify such 

an approval and could support moving from more restrictive tiering of waste streams to 

broader approvals of RH summary waste categories. 

INL-CCP and ANL-CCP provided EPA several AK documents (CCP-AK-INL-500, CCPAK-INL-501 and CCP-AK-INL-502) that described the results of analyses or activities 

performed at both sites to generate scaling factors, which are critical to the 

characterization of radiological components in the RH waste streams. These documents 

were reports, not controlled procedures, with the exception that a portion of the AK 

process dealing with data assembly/assimilation is included in the RH WCPIP. These 

reports present the results of AK-related characterization activities and do not provide 

the detailed procedures used to obtain the results. The reports contain the results of a 

process used to develop radionuclide concentrations retrospectively. They did not

provide instructions whereby RH site’s WC staff could perform the task in the same 

manner prospectively. The technical calculations and data handling that were performed 

to assess AK in support of the generation of radionuclide scaling factors were complex 

and were appropriately presented to EPA during inspection interviews and in the form of 

approximately 36 calculation packages. The calculation packages contained 

considerable detail and represent the primary documentation of the results of the 
C-4 

activities and processes used to derive the scaling factors. During the inspection and 

follow-up interviews, EPA did not obtain objective evidence documenting a set of 

instructions governing this waste steam-specific concentration development activity 

ensuring that the processes we observed at INL and ANL would be the same. Therefore, 

approving the DTC process beyond the waste streams evaluated during the EPA 

inspection, in the absence of a formal, controlled procedure for developing scaling 

factors would be premature. For this reason, EPA is approving the DTC process for only 

specific waste streams. If an RH site chooses to develop procedure(s) to control the 

generation of scaling factors for additional waste streams and upon EPA review of the 

procedure(s), EPA may, if appropriate, be able to give a broader approval of a DTC 

process that can be applied to a waste category. 

With respect to AK, EPA does not distinguish between parts of the AK process because 

INL-CCP and ANL-CCP use AK for a continuum of characterization activities, from data 

collection through modeling and scaling factor development. The only measurement part 

of the characterization process, i.e., DTC, occurs well after the fundamental AK data 

assessment has been performed. Because the entire AK process is not formalized in a 

procedure or procedures for a summary waste category, and is instead applied to wastestream specific activities, AK is approved for the waste stream evaluated during the 

baseline inspection and discussed in Sections 8.1 and 8.2 of the final INL and ANL 

baseline inspection reports. Both EPA and CCP’s experience to date is limited for RH, 

i.e., essentially one waste stream at two sites, INL and ANL. As additional waste streams 

are brought forward, the need for Tier 1 change designation can be reevaluated and a 

tier adjustment could be made through the process identified in 40 CFR 194.8.

Comment No. 6: Section III.A.(1) of the Federal Register Notice references the June 1, 2006 

version (Revision 2) of CCP-AK-INL-500. Though this revision of the report was reviewed 

during the June inspection, Revision 3 of this report (dated July 7, 2006) addressing comments 

made during this inspection was presented and reviewed during the follow-up inspections in 

August as documented in Inspection Report A-98-49, II-A4-69.

Response: In Section 8.1 of this final baseline inspection report EPA has made 

appropriate changes to reflect Revision 3 that addresses EPA comments on the initial AK 

report made during the baseline inspection. 

Comment No. 7: Section III.A.(1) of the Federal Register Notice, and the associated Inspection 

Report A-98-49, II-A4-69 identifies “...Waste Stream No. ID-ANLE-S5000, Lots 1 through 20, 

as defined in CCP-AK-INL-500, Revision 2, June 1, 2006.” CCP-AK-INL-500 does not define 

these lots. The Central Characterization Project (CCP) acceptable knowledge (AK) process was 

applied to a population of 549 thirty-gallon RH debris drums, which is described in CCP-AKINL-500. Of these drums, approximately 70 had been subjected to visual examination (VE), 

which was recorded on audio/video media during packaging. There is no further distinction 

made in this waste stream inventory. The designation of “lots” has no relevance in the 

characterization and certification process and should be deleted. As described in CCP reference 

C350 prepared for EPA during the inspections, CCP determined, and EPA agreed, that further 

segregation of the waste stream into lots based on the radiological characterization performed by 

ANLE was not appropriate. References to “lots” occur in numerous places in docket EPA-HQ-
C-5 

OAR-2006-0881 and the associated Inspection Report A-98-49, II-A4-69; these references 

should be deleted.

Response: EPA recognizes that historic AK data is presented in “lots” by INL (and 

therefore EPA examined this historic data by the groupings provided by CCP), but EPA 

does not expect CCP to characterize this waste stream by these or any other 

predetermined lots. 

INL-CCP AK supporting references identify INL’s Lot assignment of “lots” and several 

AK documents that are important to the characterization process (e.g., EDF-6946 and 

EDF-6685) discuss the waste stream by INL “lots”. Therefore, portions of the EPA’s 

reports use the same terminology and refer to “lots” because the references examined 

present the information in this fashion. Appropriate changes to the text have been made 

when referring to the term “lots” in the context of historic AK data. 

Comment No. 8: Section III.A.(3) of the Federal Register Notice states: “The VE process used 

for a total of 8 retrievably-stored RH debris waste drums included in three batch data reportsBDR No.’s RHINLVE 6001-3. CCP has terminated the use of VE process for this waste until 

further notice. If CCP decides to use VE in the future, EPA inspection and approval is 

necessary.” This citation is incorrect. CCP used the VE process to characterize a total of 70 

drums of retrievably-stored RH debris waste where the waste contents were recorded on 

audio/video media during waste packaging operations. The approval should apply to the process 

of conducting VE using audio/video media, not to a particular population of drums characterized 

using that process. 

As stated in Section 4.0 on page 7 of both the INL EPA Inspection Report A-98-49, II-A4-69 

and the ANL EPA Inspection Report A-98-49, II-A4-70: “During an inspection, EPA does not 

approve characterization data; that function is the sole responsibility of the site being evaluated 

during the inspection...EPA evaluated the WC processes implemented by the site to characterize 

RH retrievably-stored debris waste.” 40 CFR Part 194.8(b)(2) states, “The Agency will verify the 

compliance of waste characterization programs and processes. . .” Nowhere does the Agency’s 

mandate require or allow for the approval by EPA, on a drum-by-drum basis, waste to be shipped 

to WIPP. Their mandate is to ensure that the waste characterization programs and processes are 

compliant. By approving eight drums (and only eight drums) for shipment to WIPP, the Agency 

is usurping the authority of the Department of Energy (the Certifying Authority for Waste 

Characterization Activities) to approve drums for shipment to WIPP. The process of visual 

examination using audio/video media was extensively demonstrated during the inspection. EPA 

has not indicated any noncompliance with the process but has arbitrarily restricted its use to eight 

drums. 

The reference to the eight containers should be removed and it is recommended that the text read 

as follows: 

The VE process as defined in CCP-AK-INL-502, Central Characterization Project RH 

TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmation Test 

Plan for INL RH Waste Stream ID-ANLE-S5000 and implemented by procedure CCPTP-500 CCP Remote-Handled Waste Visual Examination. 
C-6 

This same comment applies to item 3 on page 2, and any related text, of the associated inspection 

report (A-98-49, II-A4-69) for EPA Baseline Inspection No. EPA-INL-CCP-RH-6.06-8. 

DOE CBFO agrees the language in the VE Tiering designation in Table 2 of the Federal Register 

Notice correctly indicates what was inspected and should be approved regarding the VE process. 

DOE CBFO requests that Table 1 in the FR and the corresponding sections of the two inspection 

reports be made consistent with this language. 

Response: EPA’s proposed approval was based on an evaluation of the VE process (i.e., 

visual examination of waste container contents recorded on audio/visual media), 

interviews with VE personnel, and review of VE personnel training records. EPA 

identified one finding and one concern as a result of this review and concluded that the 

VE process implementation was not inadequate. CCP took steps to correct the EPAnoted inadequacies (e.g., additional training to VE staff and revisions to VE procedure(s) 

used by the VE personnel). EPA limited its proposed approval to only 9 drums because 

CCP had categorized the remaining 61 containers as not suitable for WIPP disposal 

using its own NCR (non compliance reporting) process. Following the inspection, CBFO 

informed EPA that (a) CCP does not plan to use this VE process beyond the 70 

containers (included in 4BDRs that were part of the AK documentation), and (b) the 61 

NCR drums would be reevaluated using real-time radiography (RTR), or another nondestructive examination procedure, in the future. 

Since the baseline inspection, however, DOE informed EPA that all 70 RH waste 

containers from INL were subjected to another VE review using a better monitor. Upon 

the review of the video records for these drums, CCP revised the associated BDRs and 

after using a modified VE process (with a better monitor) CCP concluded that 60 of the 

70 containers are eligible for disposal at WIPP. DOE submitted this new information to 

EPA. 

As stated in the Comment No. 4, Commenter corrected EPA’s understanding of the 

number of containers suitable for the disposal at WIPP saying that 19 and not 9 RH 

waste containers were eligible for WIPP disposal at the time of the proposal. 

In the proposed approval EPA designated the reuse of the VE process (since then being 

retired) as a T1 change. EPA considers the use of a better monitor as a change in key VE 

equipment. Therefore, EPA must consider this new information as a T1 change. Since 

CCP used a modified VE process and the additional, (new) data generated from this 

action was provided during the public comment period on EPA’s proposed approval, 

EPA must consider this as a T1 change and complete a review accordingly. Therefore, 

as part of the T1 change review and approval process an EPA inspector will complete a 

review of the modified VE process. CBFO will be notified of EPA’s decision, regarding 

the VE of additional drums in the waste stream. EPA’s T1 decision will also be posted on 

the EPA website at www.epa.gov/radiation/wipp.

Comment No. 9: Table 1 of the Federal Register Notice, INL-CCP RH WC process-T2 changes 

and the associated Inspection Report A-98-49, II-A4-69 identifies “...AK accuracy report for Lot 
C-7 

16 (or the appropriate Lot) wherein individual drum data assessed by INL (e.g., P030) will be 

compared against DTC-derived values...” As described in Comment 7 above, INL-CCP 

determined that the “lot” approach was not appropriate for the reasons described in reference 

C350 and addressed on page 20 in Inspection Report A-98-49, II-A4-69: 

“These documents show that detailed analyses of AK data assembled for each drum can 

be performed to determine, in some detail, the estimated radiological content of each lot, 

recognizing that the process to develop an accurate and complete picture requires 

analysis well beyond that performed by the generator site, ANL-E (see item (1) above, 

and reference C350). This activity is also an alternative approach to characterizing 

waste based on the AK record that does not use DTC in the manner currently proposed 

by INL-CCP but instead uses various calculations and modeling efforts to determine 

values for the individual waste drums. INL-CCP has indicated, and EPA agrees, that this 

approach is time consuming (e.g., two years for 10 drums alone), and various 

assumptions and questions may still remain that could bring considerable uncertainty to 

this approach (see reference C350). This alternative approach has not been used at INLCCP; therefore, EPA did not evaluate it in depth.” 

In Inspection Report A-98-49, II-A4-69, EPA requests that INL-CCP compare AK and DTC 

results for ten containers (lot 16) for the purpose of determining AK accuracy as a T2 change; 

however, since INL-CCP has chosen to radiologically characterize the waste stream as a whole, 

the level of accuracy can not be determined by comparing the DTC results to those previously 

calculated for a small subset of containers within the stream. If any of the containers are 

determined to be non-transuranic (TRU) waste using the dose-to-curie (DTC) methodology, they 

will be reported as an AK inaccuracy. There is neither a plan nor a requirement currently in 

place to prepare a separate AK Accuracy Report for the ten drums cited. This requirement for a 

T2 change notification should be deleted from the applicable tables and the text of Docket 

EPA-HQ-OAR-2006-0881 and Inspection Report A-98-49, II-A4-69. 

Response: EPA’s intent behind the comparison requirement was to better understand the 

relationship between the results of the proposed characterization approach and data for 

a small number of waste containers reviewed during the baseline inspection. The 

comment objects to the comparison of a small set of AK data to results that were obtained 

through DTC because INL-CCP proposes to characterize the stream “as a whole”, and 

the small subset may not match the stream as characterized to that point. EPA 

understands this concern and also understands that there may be variability in the 

characterization data at any point in time. EPA has changed the T2 change to require 

the site to notify EPA when this data set is available. Under its authority of §194.24(h), 

EPA may request these data from INL-CCP in order to perform comparison as a 

verification of how the data sets compare. EPA believes that a comparison may provide 

additional insight regarding AK accuracy and help to better understand the variability of 

the characterization data, not to find a means to criticize INL-CCP’s characterization 

approach for this waste stream that this report approves. EPA has made the appropriate 

clarifications to the INL and ANL final baseline inspection reports to reflect this 

explanation. 
C-8 

Note that the DTC process evaluated by EPA during the baseline inspection had been 

proposed for approval and is being approved now and the comparison discussed here 

does not affect this approval. 

Comment No. 10: Table 1 of the Federal Register Notice, INL-CCP RH WC process-T2 

changes and Table 1 on page 3 of the associated Inspection Report A-98-49, II-A4-69 identifies 

“...Completed Correlation or Surrogate Summary Form of RH containers identified in this waste 

stream identified as CH based upon measured dose rates that present NDA results for assayed 

containers, including isotopic ratios...” As described in the AK procedure of the WCPIP, a 

Correlation and Surrogate Form is prepared to document when contact-handled (CH) data are 

used to meet a required DQO for an RH waste stream. This form would not be completed unless 

the resulting CH assay data is specifically used to meet one of the RH DQOs. The comparison 

of isotopic ratios derived from modeling and mass spectrometry for the waste stream as a whole 

to any isotopic ratios measured via NDA for one or more individual containers is likely to be 

inconclusive. This is because variations in the isotopic ratios between containers is expected and 

may be difficult to quantify. This requirement for a T2 change notification should be deleted 

from cited tables and the text of the Inspection Report A-98-49, II-A4-69. 

Response: The Correlation or Summary (CSS) Form, if prepared, can easily address any 

discrepancies between an RH waste stream and its CH counterpart. The CSS could also 

add valuable information because it would provide actual assay measurement data. 

Accordingly, EPA requires that the site provide notification, as a T2 change notice, when 

the CSS Form is available for a RH waste stream. 

As stated in the previous responses to Comment Nos. 2 and 9 above, T1 and T2 reports 

are intended to report changes to approved waste characterization programs. As 

described in the final modification to 40 CFR 194.8(b) (69 FR 42581, July 14, 2004), 

EPA uses its authority under 194.24(h), when necessary, to evaluate new or additional 

information to ensure continued compliance with regulatory requirements. Under 

§194.24(h) authority, EPA may ask for the CSS Form for an RH waste stream in question 

and may also require a listing of all RH containers that are ultimately identified as CH 

and the measurement (i.e., NDA) data for those containers not presented on a CSS. EPA 

has made the appropriate clarifications to the INL and ANL final baseline inspection 

reports in accordance with this response. 

 

EPA understands that the comparison of isotopic ratios derived from modeling and mass 

spectrometry for the waste stream as a whole to any isotopic ratios measured via NDA 

for one or more individual containers may be inconclusive. EPA also understands the 

potential for variations in the isotopic ratios between containers. We do not necessarily 

consider that such variations would be problematic. 

Comment No. 11: On page 16 of the inspection report, in the paragraph under Table 4, it states 

that NDA will not be used “because of workers’ health concerns.” This entire sentence should 

be deleted. The DTC technique is an approved technique that is being implemented at this site 

and there is no reason for addressing why another technique is not being used. 
C-9 

Response: We concur, the final report the text has been revised to remove reference to 

the worker’s health concerns. 

Comment No. 12: Clarify that implementation of VE following this baseline approval is a T1 

change (Table 1 of the Federal Register Notice). This should apply to VE, not to VE using 

audio/video media: 

a. Under VE T1 changes, the use of the VE process and data, in a manner consistent with 

that applied to the subject waste stream, should not require an EPA T1 approval as noted 

above. 

Response: When characterizing RH waste, INL CCP performed a visual examination of 

audio/video media depicting contents of RH waste containers. EPA has renamed the 

waste characterization process as “VE of audio/video media” in the Tiering tables in the 

Executive Summary and Conclusion sections of the report. 

Following the June 2006 baseline inspection, DOE provided additional information 

regarding drums that had been cited in INL-CCP non-conformance reports. Because this 

information identified a modified procedure for VE of this waste stream, EPA is 

evaluating this additional VE information as a T1 change. (For additional discussion, 

see Response to Comment No. 8, above.) Upon completion of the T1 evaluation, EPA 

may issue an approval of the modified VE process and data applying to the waste stream 

as a whole and not restricted to the 8 containers as proposed. As noted in the Response 

to Comment No. 4, above, the EPA proposed approval incorrectly states the number of 

containers as 9. The correct number of approved containers for the proposed approval 

should have been 19. EPA has been informed by CCP that it will no longer use the VE 

of audio/visual media process for characterizing RH containers at INL. If CCP again 

uses this process for visually examining audio/video media records for RH waste 

containers at INL, its implementation will be subject to theT1 change procedures 

requiring EPA notification and approval prior to implementation. 

Comment No. 13: Table 2 of the Federal Register Notice, ANL-CCP RH WC process-T2 

changes and Table 1 on page 3 of the associated Inspection Report A-98-49, II-A4-70 identifies 

“...Comparison of AK versus DTC-derived radiological data to support the use of waste streamspecific instead of drum-specific radiological data and the completed DTC results for all 

containers in this waste stream...” As discussed on page 20 in Inspection Report A-98-49, IIA4-70, the following language was added to the AK Report:

The stated purpose of the method employed by Argonne to estimate the radiological 

composition in individual waste containers was to address site accountability 

requirements and to comply with the maximum allowable fissile content of RH TRU 

drums. While the Argonne reported radiological content of containers in this waste 

stream was used to support the CCP waste stream delineation, RH, and TRU 

determinations, the Argonne methodology did not produce results adequate for the 

purposes of WIPP certification. For this reason, it is not appropriate to compare the 

Argonne estimates to the results of the CCP radiological characterization activities in AK 

accuracy evaluations. 
C-10 

For this reason, the level of accuracy can not be determined by comparing the DTC results to 

those previously estimated by ANLE and this stipulation should be deleted from the cited Tables 

and the text of the Inspection Report A-98-49, II-A4-70. 

Response: EPA concurs with the comment. The report including the Tables is modified 

accordingly. 

Comment No. 14: Table 1 of the Federal Register Notice, INL-CCP RH WC process-T1 and 

Table 2 of the Federal Register Notice, ANL-CCP RH WC process-T1 changes are identified for 

the addition of containers to the existing waste streams. Addition of containers to the existing 

waste streams should not be considered a change unless the addition of the containers changes 

the characteristics of the waste stream, which would require a change to the certification plan 

(CCP-AK-INL-502 for INL and CCP-AK-ANL-502 for ANL). As stated in Section 4.0 on page 

7 of both the INL EPA Inspection Report A-98-49, II-A4-69 and the ANL EPA Inspection 

Report A-98-49, II-A4-70: “During an inspection, EPA does not approve characterization data; 

that function is the sole responsibility of the site being evaluated during the inspection...EPA 

evaluated the WC processes implemented by the site to characterize RH retrievably-stored debris 

waste.” Therefore, EPA is only approving the waste characterization processes implemented, 

such as the process used to assign waste containers to a waste stream, and not the assignment of 

individual, specific containers to a waste stream. As defined in the inspection reports (page 2, 6th

paragraph) “Any changes to the WC activities from the date of the baseline inspection must be 

reported to and if applicable, approved by EPA.” EPA tier changes therefore, should only 

address changes to WC and not routine modifications performed in accordance with the WC. 

This same comment applies to the corresponding tables, and any related text, in the associated 

inspection reports (A-98-49, II-A4-69 and A-98-49, II-A4-70) for EPA Baseline Inspection No.’s 

EPA-INL-CCP-RH-6.06-8 and EPA-ANL-CCP-RH-9.06-8. 

Response: EPA inspected and approved the full AK process (including scaling factor 

development, etc.) through interviews and evaluations that were applicable to a small 

sample size. It is quite possible that “new” containers would require a different approach 

to scaling factor development following a process that EPA has not inspected or 

examined. Therefore, addition of containers to the waste stream requires EPA 

notification to ensure that CCP has implemented a process that is well documented. If 

CCP seeks a broader approval in the future whereby containers could be added without 

review, CCP could present to EPA for approval a documented process for AK data 

analysis beyond that in the WCPIP. This will need to include all other AK data 

manipulation (e.g., scaling factor development) up to application of the DTC 

measurement. Until that time, EPA believes it is prudent to limit the approval to the 

waste stream evaluated during the baseline inspection, noting that our T1 review of waste 

stream expansion could be accomplished in a timely manner. 

Comment No. 15: Under AK T2 changes, the term “waste stream data package” does not 

appear in the Remote-Handled Transuranic Waste Characterization Program Implementation 

Plan (WCPIP). CBFO assumes that EPA is referring to the primary AK documents referenced 

including the waste stream profile form (WSPF), the characterization reconciliation report 

(CRR), and the AK Summary Report.
C-11 

Response: EPA agrees that the term “waste stream data package” is broad, and 

CBFO’s assumption is correct. EPA is referring to the AK documents including the 

WSPF and CRR. If a Characterization Information Summary is prepared and includes 

information pertinent to EPA compliance, EPA must be notified of its availability using 

the T2 change notice process. EPA may request that this information be provided, 

consistent with 194.24(h). EPA has made the appropriate clarifications to the INL and 

ANL final baseline inspection reports. 

Comment No. 16: Delete the wording: “or the use of the high range probe as described in 

CCP-TP-504”, from footnote *** to Table 1 and Table 2 of the Federal Register and the 

corresponding tables in the inspection reports. Use of the high range probe is authorized in 

CCP-TP-504. Its operation is no different from the low- and mid-range probes that were 

demonstrated at the two inspections. 

Response: EPA agrees that the use of all three probes is authorized under CCP-TP-504, 

as discussed below. The operations observed at INL and ANL did not involve the use of 

the high range probe and EPA would be interested in such an application, not because of 

the probe itself, but because its use would require a significantly different DTC operation 

from what was observed during the inspections. 

As stated in the INL-CCP Report: 

• There are three ion chamber probes available for use with the RO-7 Ion Chamber: 

RO-7LD with a full-scale range of 1,999 mR/hr and a resolution of 1 mR/hr (Low 

Range); RO-7BM, with a full-scale range of 199,900 mR/hr and a resolution of 

100 mR/hr (Medium Range); and, RO-7BH with a full-scale range of 

199,900,000 mR/hr and a resolution of 10,000 mR/hr (High Range). The calibrations 

are essentially probe-specific, allowing the probes to be interchanged between ion 

chamber bodies. 

• The Low Range Probe No. 802038 and the Medium Range Probe No. 801254 were in 

calibration at the time of the inspection. The High Range probe was not observed in 

use, INL-CCP personnel stated that it had been neither calibrated nor source 

checked. INL-CCP personnel stated that there was no intention of using this probe in 

the foreseeable future. 

CCP-TP-504 states that, prior to use, the high range probe requires a source check with 

a source of greater than or equal to 500,000 mR and less than or equal to 12,000,000 

mR, i.e., a source with an external gamma exposure rate of between 500 and 12,000 R/hr 

(Roentgens per hour). The logistical aspects of such an operation would be considerably 

different from the operation observed during the inspections, and EPA wants to know 

about this in advance and have the opportunity to evaluate it prior to or during its 

application.