EPA DOCKET NO. A-98-49, II-112 

 

WASTE CHARACTERIZATION INSPECTION REPORT 

EPA CONTINUED COMPLIANCE INSPECTION NO. EPA-INL-CCP 09.08-24 OF THE 

CENTRAL CHARACTERIZATION PROJECT WASTE CHARACTERIZATION 

PROGRAM 

AT THE IDAHO NATIONAL LABORATORY 

 

September 16–18, 2008 and October – December 2008 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

February 2009 
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TABLE OF CONTENTS 

Section Page

1.0 Executive Summary............................................................................................................ 3 

2.0 Purpose of Inspections ........................................................................................................ 6 

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

4.0 Scope of Inspection............................................................................................................. 6 

5.0 Inspection-Related Definitions ........................................................................................... 7 

6.0 Personnel............................................................................................................................. 7 

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

6.2 Personnel Contacted................................................................................................ 8 

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

8.0 Technical Waste Characterization Areas ............................................................................ 9 

8.1 Acceptable Knowledge and Load Management of the Subsurface Disposal 

Area (SDA) Waste Streams .................................................................................... 9 

8.2 Nondestructive Assay ........................................................................................... 29 

8.3 Real-Time Radiography........................................................................................ 39 

8.4 Visual Examination Technique (VET) ................................................................. 41 

8.5 Container Management......................................................................................... 42 

9.0 Summary of Results.......................................................................................................... 43 

9.1 Findings and Concerns.......................................................................................... 43 

9.2 Conclusions........................................................................................................... 43 

LIST OF TABLES 

Table 1. Revised Tiering of TRU WC Processes Implemented by INL-CCP............................. 4 

Table 2. EPA Inspection Team Members .................................................................................... 8 

Table 3. Personnel Contacted During Inspection ........................................................................ 8 

Table 4. Most Prevalent Radionuclides by Mass for Three INL-CCP Waste Streams ............. 22 

Table 5. Waste Volumes by Area in CCP-AK-INL-001 ........................................................... 24 

Table 6. Revised Tiering of TRU WC Processes Implemented by INL-CCP........................... 44 
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ATTACHMENTS 

Attachment A.1 Nondestructive Assay (NDA) Checklist, WAGS 

Attachment A.2 Nondestructive Assay (NDA) Checklist, SuperHENC 

Attachment A.3 Real-Time Radiography (RTR) Checklist 

Attachment A.4 Visual Examination Technique (VET) Checklist 

Attachment A.5 Container Management Checklist 

Attachment B.1 Replicate Testing Data for Container 10212486 – WAGS 

Attachment B.2 Replicate Testing Results for Container 10212486 – WAGS 

Attachment B.3 Replicate Testing Data for Container 10215772 – WAGS 

Attachment B.4 Replicate Testing Results for Container 10215772 – WAGS 

Attachment B.5 Replicate Testing Data for Container ARP05744 – WAGS 

Attachment B.6 Replicate Testing Results for Container ARP05744 – WAGS 

Attachment B.7 Replicate Testing Data for Container ARP06447 – WAGS 

Attachment B.8 Replicate Testing Results for Container ARP06447 – WAGS 

Attachment B.9 Replicate Testing Data for Container ARP06723 – WAGS 

Attachment B.10 Replicate Testing Results for Container ARP06723 – WAGS 

Attachment B.11 Replicate Testing Data for Container BN10211041 – SuperHENC 

Attachment B.12 Replicate Testing Results for Container BN10211041 – SuperHENC 

Attachment B.13 Replicate Testing Data for Container BN10239132 – SuperHENC 

Attachment B.14 Replicate Testing Results for Container BN10239132 – SuperHENC
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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 continued compliance Inspection No. EPA-INL-CCP 09.08-24 of the Central 

Characterization Project (CCP) waste characterization (WC) program for contact-handled (CH) 

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

(INL) in Idaho Falls, Idaho. According to the provisions of 40 CFR 194.8(b)(3), as issued in a 

July 16, 2004, Federal Register (FR) notice (69 FR 42571–42583), EPA can conduct a continued 

compliance inspection of the site’s approved WC program to characterize wastes proposed for 

disposal at the Waste Isolation Pilot Plant (WIPP). This on-site inspection occurred at the 

Radioactive Waste Management Complex (RWMC) located on the INL on September 16 

through 18, 2008. The onsite inspection covered all TRU waste characterization processes 

except acceptable knowledge (AK). EPA inspected the AK component separately as part of the 

desk top review between October and December 2008. 

As a result of this continued compliance inspection, EPA confirmed that the INL-CCP CH TRU 

WC program maintains its approval to characterize CH TRU consistent with the conditions and 

limitations that are discussed in the baseline inspection report. As discussed below, EPA is 

adding new Tier 1 and Tier 2 (T1 and T2) items to the original items identified during the 

baseline approval process. During this inspection, the Agency evaluated samples of the 

following WC activities: 

• Acceptable knowledge 

• Two nondestructive assay (NDA) systems, the Waste Assay Gamma Spectrometer 

(WAGS) and the Super High Efficiency Neutron Counter (SuperHENC) for 

characterizing CH TRU wastes 

• Real-time radiography (RTR) for CH retrievably-stored TRU debris waste (S5000) 

• Visual Examination Technique (VET) for newly-generated TRU waste 

• Container Management 

EPA maintains its approval of the INL-CCP CH TRU WC program in the configuration 

observed during this inspection consistent with the limitations described in the baseline 

inspection report (see EPA Docket No.A-98-49; II-A4-59). EPA’s baseline approval and the T1 

and T2 designations are shown in Table 1. This table is not identical to those included in the 

INL-CCP baseline inspection report dated November 2005, particularly with respect to 

presentation of the T2 elements. At that time, T2 elements were presented as two columns— 

general and specific. INL-CCP was the first site to have a baseline approval and the format of 

the approval table has been modified since then. In tiering tables included in more recent 

baseline approval reports, these two T2 columns have been merged into a single T2 column. The 

more recent T2 column entries have been modified to better reflect the 40 CFR 194.24(h) 

requirements that the site provide notification regarding the completion or availability of specific 

T2 elements. Additional T1 and T2 changes to the INL-CCP WC program were indicated as a 

result of this inspection and are included as italicized text in the table below. Also, consistent 
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Table 1. Revised Tiering of TRU WC Processes Implemented by INL-CCP 

Based on May 3–5, 2005, Baseline Inspection and September 16–18, 2008, Continued Compliance Inspection

WC Process Elements INL-CCP WC T1 Changes INL-CCP WC T2 Changesa 

Acceptable Knowledge (AK) and Load Management 

Any new summary category group for TRU waste Changes to WWIS algorithms specific to load management requiring revisions to the load management provisions of DOE’s CH Waste Acceptance Criteria (CH WAC) Changes to the targeted waste(s) from what was 

presented in Revision 6 of the AK Summary CCP-AKINL-001 (AK 2)

Notification to EPA upon completion of the following: 

Waste Stream Profile Forms including updates or additions to waste stream(s) within an approved waste category Changes in load management status of approved waste stream(s) Changes to the WWIS algorithms corresponding to the changes to the load management provisions of the CH WAC Changes to site procedures requiring CBFO approvals

Providing any analysis evaluating effectiveness of the Waste Identification Process 

(AK 1) 

Providing future revisions of CCP-AK-INL-001, Revision 6 (AK2) Providing future Discrepancy Reports related to radiological and physical 

characteristics of the ID-SDA-SOIL, ID-SDA-SLUDGE, and ID-SDA-DEBRIS waste 

streams (AK 6) Providing AK Accuracy Reports for the ID-SDA-SOIL, ID-SDA-SLUDGE, and IDSDA-DEBRIS waste streams (AK 8) 

All forthcoming revisions to AK-NDA memoranda that apply to ID-SDA-SOIL, IDSDA-SLUDGE, and ID-SDA-DEBRIS waste streams (AK 10)

Changes to site procedures requiring CBFO approval

Non Destructive Assay 

(NDA) 

New equipment or substantive changesb to approved 

equipment affecting actual radioassay results (e.g., DQO compliance, TMU) Modificationc to approved calibration range for 

approved equipment and/or equipment 

Changes to software for approved equipment Changes to operating range(s) upon CBFO approv Changes to site procedures requiring CBFO approval 

Real-Time Radiography (RTR) Not Applicable Changes to site procedures requiring CBFO approval Visual Examination (VE) Not Applicable Same as above WIPP Waste Information System (WWIS) Not Applicable Same as above 

a INL-CCP will report all T2 changes to EPA at the end of each fiscal quarter. 

b “Substantive changes” are changes with the potential to impact the site’s WC activities or documentation thereof, excluding changes that are solely related to ES&H, nuclear safety, or 

RCRA, or that are editorial in nature. 
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c “Modifications to approved calibration range for approved equipment and/or equipment” include all changes with the potential to affect NDA data relative to waste isolation and exclude 

minor changes, such as the addition of safety-related equipment.
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with the tables in more recent reports, the specific section of this report where new T1 and T2 

changes are discussed are cited in parentheses. 

2.0 PURPOSE OF INSPECTIONS 

The rule applying to this continued compliance inspection can be found in the FR (69 FR 42571–

42583, July 16, 2004). 

3.0 PURPOSE OF THIS REPORT 

This report documents the basis for EPA’s decision to maintain the approval of the INL WC 

program for CH TRU wastes. Specifically, this report does the following: 

• Describes the sample of the INL WC systems evaluated during this inspection 

• Identifies all areas where WC systems have changed relative to the baseline approval 

configuration and assesses the impact, if any, of those changes 

• Provides objective evidence to support EPA’s continued approval for all INL-CCP WC 

systems 

• Provides objective evidence of outstanding findings or concerns, as applicable 

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

their relevance to EPA’s approval decision 

• Identifies changes to the T1 or T2 designations that were proposed in the original 

baseline approval 

The completed checklists (Attachments A.1 through A.4 to this report) reference the documents 

that the EPA inspection team 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 Area Field Office 

P.O. Box 3090 

Carlsbad, NM 88221 

EPA’s continued approval of the INL-CCP WC program will be conveyed to DOE separately by 

letter. More information is also on EPA’s Web site at 

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

4.0 SCOPE OF INSPECTION 

The scope of EPA Continued Compliance Inspection No. EPA-INL-CCP-09.08-24 was the 

evaluation of the selected elements of the WC systems in use at INL-CCP to characterize TRU 

wastes that were approved during the baseline inspection. The EPA inspection team evaluated 

aspects of these systems with respect to their ability to perform the following functions: 
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• 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 NDA 

systems 

• Assign waste material parameters (WMPs) correctly using RTR and VET for 

CH retrievably-stored and newly-generated wastes, respectively 

• Perform effective waste segregation and container management 

Specifically, these systems consisted of the following components: 

• AK processes that support retrievably-stored S5000 debris wastes 

• Two NDA systems, the WAGS and SuperHENC 

• RTR for retrievably-stored wastes 

• VET for newly-generated wastes 

• Container management 

The evaluation consisted of interviewing personnel, observing equipment operations that follow 

site procedures, and inspecting records related to each of the WC processes within the 

inspection’s scope. An important aspect of this evaluation was the objective evidence 

documenting the effectiveness of the WC processes. Objective evidence typically takes the form 

of batch data reports (BDRs), radioassay data sheets (RDSs), AK accuracy reports and RTR 

tapes. During this inspection, EPA selected samples of each of these items, based on the number 

and variety of items each WC process produced, consistent with standard inspection techniques. 

Based on the evaluation of the WC processes in conjunction with the sample of objective 

evidence, EPA determined the technical adequacy of the WC processes within the inspection’s 

scope. 

5.0 INSPECTION-RELATED DEFINITIONS 

During 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. 

Note that DOE does not need to address concerns not requiring a response prior to program 

approval. However, EPA recommends that when DOE accepts the site’s response to an EPA 

concern, it should inform EPA at the same time that the site implements the corresponding 

corrective action. This process is similar to a T2 change. 

6.0 PERSONNEL 
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6.1 EPA Inspection Team 

Table 2 identifies the members of the EPA WC inspection team. 

Table 2. EPA Inspection Team Members 

Inspection Team Member Position Affiliation

Rajani Joglekar Inspector Team Leader U.S. EPA ORIA

Ed Feltcorn Inspection Team Member U.S. EPA ORIA 

Connie Walker Inspector S. Cohen & Associates 

Dorothy Gill Inspector S. Cohen & Associates 

Patrick Kelly Inspector S. Cohen & Associates 

6.2 Personnel Contacted 

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

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

they are listed in Table 3, along with their affiliations and areas of expertise. 

Table 3. Personnel Contacted During Inspection 

Personnel Affiliation Area of Expertise/Function 

Tom Johnsen CWI STR AK/AKE 

Paula Salas WTS-CCP VE/VEE 

Jeff Poole WTS-CCP VE/VEE 

Abraham Romo WTS-CCP VE/VEE, VPM 

Vince Medina WTS-CCP NDE 

Preston Abbott MCS NDA—WAGS/Operator, SME, ITR

Corey Boland MCS NDA—WAGS/Operator, ITR

Bart Morales MCS NDA—WAGS/EA

David Brasier MCS NDA—WAGS/Operator, ITR 

Stephanie ??? MCS NDA—SuperHENC/EA 

Mary Griffith MCS NDA—SuperHENC/EA 

Shane Boudreau MCS NDA—SuperHENC/Operator 

Ty Bloom MCS NDA—SuperHENC/Lead Operator

Christa Chavez WTS-CCP NDA—WAGS, SuperHENC Technical 

Assistance

Scott Anderson CH2M-WG AK 

Barbara Broomfield INL-CCP AK 

C. A. Stepzinski INL-CCP Program Manager 

David Haar WTS-CCP TRU Program Manager 

Courtland Fesmire CBFO TRU Waste Certification Work Coordinator 
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7.0 PERFORMANCE OF THE INSPECTION 

EPA Continuted Compliance Inspection No. INL-CCP-09.08-24 took place September 16–18, 

2008. EPA reviewed additional documents that were provided after the inspection to complete 

its evaluation of several of the technical areas within the inspection’s scope. The inspection was 

performed for the purpose of determining INL-CCP WC program compliance with 40 CFR 

194.24. The inspection involved the following steps: 

(1) Reviewing the WC processes that were approved under EPA’s baseline inspection 

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

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

(3) Preparing draft checklists specific to each technical area before the inspection 

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

(5) Verifying onsite the technical adequacy or qualifications of WC personnel, procedures, 

processes, and equipment by means of interviews, observation, and demonstrations, and 

recording the results, as appropriate 

(6) Recording all concerns on EPA Inspection Issue Tracking Forms and providing 

completed forms to CBFO and site personnel as they were generated 

(7) Communicating all pertinent information to CBFO and INL-CCP personnel onsite, as 

appropriate 

(8) Pursuing resolution of all identified issues before completion of the inspection by 

discussions with CBFO and INL-CCP personnel 

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

personnel, as appropriate 

(10) Reviewing additional information provided by INL-CCP after the inspection 

8.0 TECHNICAL WASTE CHARACTERIZATION AREAS 

Sections 8.1 through 8.5 of this report detail the five technical areas assessed during this 

inspection—AK; NDA; NDE (non destructive evaluation), consisting of RTR and VET; and 

container management. 

8.1 Acceptable Knowledge and Load Management of the Subsurface Disposal Area 

(SDA) Waste Streams 

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

remained in compliance with 40 CFR 194.8 requirements for CH newly-generated soil, debris, 

and solid waste present in the Subsurface Disposal Area (SDA). Note that INL-CCP is also 

approved for retrievably-stored debris and solid waste originating from Advanced Mixed Waste 

Treament Project( AMWTP), but these categories were not evaluated during EPA’s continued 

compliance inspection, because the focus of INL-CCP’s current characterization activities is 

newly-generated wastes originating from the SDA. 
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8.1.1 Background Information 

The objective of the Accelerated Retrieval Project (ARP) is to perform a targeted retrieval of 

wastes from the SDA that contain higher concentrations of TRU radionuclides, depleted uranium 

(DU) (roaster oxide), and volatile organic compounds. INL-CCP is responsible for 

characterization of specific, targeted wastes buried in the SDA. The targeted wastes consist of: 

• RFETS 741 Series sludge 

• RFETS 743 Series sludge 

• RFETS filters 

• RFETS roaster oxide 

• RFETS graphite 

The majority of wastes in the areas currently being excavated originated at Rocky Flats; the 

remainder originated at other locations, including INEEL facilities and Argonne National 

Laboratory-West (ANL-W)1

. Minor contributions came from several facilities, including those 

that were first received by RFETS and later on shipped to INL. Although all targeted wastes are 

from RFETS, INL-CCP expects that many of the waste containers will be breached and their 

contents might be commingled with wastes from other areas. 

 

At the time of EPA’s initial baseline approval in 2004 and subsequent T1 review, two specific 

areas were being excavated: eastern portions of Pit 4 (ARP-I) and western portions of Pit 6 

(ARP II). Since that time, additional areas are scheduled for excavation and have been added to 

the waste stream descriptions, i.e., wastes from Contract Areas 1A, 2A, 6A, 6B, and 6C of the 

SDA are being retrieved and packaged for disposal. INL-CCP stated that these new areas target 

identical materials as areas previously examined by EPA, although additional materials from 

“other areas” were identified in the Contract Areas that may occur in waste through inadvertent 

commingling. Figure 1, below, presents the location of the current SDA areas described above.

 

1

 ANL-W is now called the Materials and Fuel Complex (MCF). 
11 

Figure 1. Location of ARP I, ARP II, and Contract Areas 1A, 2A, 6A, 6B, and 6C
 

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The ARP-I and ARP-II comprise approximately one acre: the ARP-I area, which is a 1⁄2-acre 

area in the eastern end of Pit 4 that includes a 20-foot buffer on the east and west ends of the 

area; the ARP-II area, which is an additional 1⁄2-acre area encompassing the far eastern portion of 

Pit 4, and the far western end of the adjacent Pit 6. The sub-areas consist of specific areas in Pits

1, 2, and 6 encompassing approximately 1⁄4-acre in total area. This AK Summary Report 

currently addresses: (1) the ARP-I retrieval area, a 1⁄2- acre area within Pit 4; (2) the ARP-II 

retrieval area, an additional 1⁄2-acre adjacent to the ARP-I retrieval area encompassing portions of 

Pit-4 and Pit-6; (3) Contract Area 1A, an approximately 0.08 acre specific sub-area portion of Pit 

1; (4) Contract Area 2A, an approximately 0.07 acre specific sub-area portion of Pit 2; and (5) 

Contract Areas 6A, 6B, and 6C, approximately 0.07, 0.02, and 0.02 acre sub-area portions 

respectively, of Pit 6. These areas contain relatively large amounts of TRU or other contaminated 

materials that will be removed and packaged by the Idaho Cleanup Project (ICP). The retrieval 

area was selected by DOE-ID (Idaho-ID) with agreement from the EPA Region 8 and the Idaho 

Department of Environmental Quality. 

EPA focused the 194.22 inspection on the newly added Contract Area component of the 

previously examined waste streams generated at the SDA to ensure continued compliance with 

the requirements of 40 CFR 194.24, and to verify continued acceptability of the AK process at 

this facility. The three newly-generated waste streams examined were ID-SDA-SLUDGE, IDSDA-DEBRIS, and ID-SDA-SOIL. 

As part of the inspection, EPA reviewed the elements of the AK process listed below: 

• Overall procedural and process technical sufficiency and ability to follow the waste 

selection, retrieval, and characterization processes 

• AK information assembly and compilation 

• Characterization of required waste WMPs and radionuclides 

• Assembly of required information and use of supplemental information 

• AK discrepancy resolution 

• AK summary adequacy 

• AK accuracy 

• Load Management 

• AK-nondestructive assay communication and use of AK by NDA 

AK is used to determine several aspects of TRU wastes at INL-CCP, including, but not limited 

to, the following: 

• Defense waste status 

• WMPs 

• Waste stream designation and composition 

• Radionuclide information 

• Location of targeted wastes in the SDA 
 

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EPA inspectors examined relevant portions of procedures and documents, including the 

following: 

• Attachment 1 - CCP TP 005 Revision 18; Acceptable Knowledge Documentation 

Checklist for INEEL Soil with Minor Amounts of Homogenous Solids and Debris, Waste 

Stream ID-SDA-SOIL, obtained week of May 11, 2008 

• Attachment 1 - CCP TP 005 Revision 18; Acceptable Knowledge Documentation 

Checklist for INEEL Inorganic and Organic Sludge and Roaster Oxide with Minor 

Amounts of Soil and Debris, Waste Stream ID-SDA-SLUDGE, obtained week of May 

11, 2008 

• Attachment 1 - CCP TP 005 Revision 18; Acceptable Knowledge Documentation 

Checklist for Heterogeneous Debris with Minor Amounts of Homogenous Solids and 

Soil, Waste Stream ID-SDA-DEBRIS, obtained week of May 25, 2005 

• Attachment 4 - CCP TP 005 Revision 18; Acceptable Knowledge Source Document 

Reference List for Waste Stream ID-SDA-SOIL, INEEL Soils, obtained week of May 11, 

2008 

• Attachment 4 - CCP TP 005 Revision 18; Acceptable Knowledge Source Document 

Reference List for Waste Stream ID-SDA-DEBRIS, INEEL Debris, January 25, 2008 

• Attachment 4 - CCP TP 005 Revision 18; Acceptable Knowledge Source Document 

Reference List for Waste Stream ID-SDA-PIT4-SLUDGE, INEEL SLUDGE, May 12, 

2008 

• Attachment 6 of CCP TP 005 Revision 18; Waste Form, Waste Material Parameters, 

Prohibited Items, and Packaging for a Described Area at the Idaho National Laboratory 

(CCP-AK-INL-001) for Soils, January 2, 2008, and Related Waste Material Parameter 

Analysis, December 15, 2008 

• Attachment 6 of CCP TP 005 Revision 18; Waste Form, Waste Material Parameters, 

Prohibited Items, and Packaging for a Described Area at the Idaho National Laboratory 

(CCP-AK-INL-001) for Solid Inorganics, January 2, 2008, and Related Waste Material 

Parameter Analysis dated December 15, 2008 

• Attachment 6 of CCP TP 005 Revision 18; Waste Form, Waste Material Parameters, 

Prohibited Items, and Packaging for a Described Area at the Idaho National Laboratory 

(CCP-AK-INL-001 Revision 1) for Debris, January 2, 2008, and Related Waste Material 

Parameter Analysis, December 15, 2008 

• Attachment 7: CCP-TP-005, Revision 17; Acceptable Knowledge Documentation, 

Radionuclides for ID-SDA-Sludge, ID-SDA, soil, ID-SDA-Debris (CCP-AK-INL-001), 

November 11, 2006 

• Attachment 8 - CCP TP 005 Revision 18; List of Waste Containers for CCP-AK-INL001, ID-SDA - SLUDGE, obtained the week of April 8, 2008 

• Attachment 8 - CCP TP 005 Revision 18; List of Waste Containers for CCP-AK-INL001, ID-SDA - DEBRIS, obtained the week of April 8, 2008 
 

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• Attachment 8 - CCP TP 005 Revision 18; List of Waste Containers for CCP-AK-INL001, ID-SDA - SOIL, obtained the week of April 8, 2008 

• Acceptable Knowledge Accuracy Report: Idaho National Laboratory Waste Stream 

Number ID-SDA-SLUDGE, Lots 1-8, May 13, 2008 

• Acceptable Knowledge Accuracy Report: Idaho National Laboratory Waste Stream 

Number ID-SDA-DEBRIS, Lots 1 through 8, May 20, 2008 

• AR Project - Drum Packaging System, TPR-7415, Revision 46; Radioactive Waste 

Management Complex Project No. 23927, Idaho Cleanup Project, July 24, 2008 

• AR Project - Waste Retrieval TPR-7420, Revision 41; Radioactive Waste Management 

Complex Project No. 23927, Idaho Cleanup Project, July 22, 2008 

• CCP-AK-INL-001 NDA Memo (attached to Attachment 7), Evaluation of the 

Radiological Characterization of Waste Streams ID-SDA-SLUDGE, ID-SDA-SOIL, and 

ID-SDA-DEBRIS, September 29, 2006 

• CCP-AK-INL-001, Revision 0; Central Characterization Project Acceptable Knowledge 

Summary Report for Waste Retrieved from Designated Areas within the Subsurface 

Disposal Area at the Idaho National Laboratory, Transuranic Waste Streams 

ID-SDA-DEBRIS, ID-SDA-SLUDGE, ID SDA-SOIL, November 18, 2004 

• CCP-AK-INL-001, Revision 1; Central Characterization Project Acceptable Knowledge 

Summary Report for Waste Retrieved from Designated Areas Within the Subsurface 

Disposal Area at the Idaho National Laboratory, Transuranic Waste Streams 

ID-SDA-DEBRIS, ID-SDA-SLUDGE, ID SDA-SOIL, April 15, 2005 

• CCP-AK-INL-001, Revision 2; Central Characterization Project Acceptable Knowledge 

Summary Report for Waste Retrieved from Designated Areas Within the Subsurface 

Disposal Area at the Idaho National Laboratory, Transuranic Waste Streams 

ID-SDA-DEBRIS, ID-SDA-SLUDGE, ID SDA-SOIL, March 20, 2006 

• CCP-AK-INL-001, Revision 3; Central Characterization Project Acceptable Knowledge 

Summary Report for Waste Retrieved from Designated Areas Within the Subsurface 

Disposal Area at the Idaho National Laboratory, Transuranic Waste Streams 

ID-SDA-DEBRIS, ID-SDA-SLUDGE, ID SDA-SOIL, November 16, 2006 

• CCP-AK-INL-001, Revision 4; Central Characterization Project Acceptable Knowledge 

Summary Report for Waste Retrieved from Designated Areas Within the Subsurface 

Disposal Area at the Idaho National Laboratory, Transuranic Waste Streams 

ID-SDA-DEBRIS, ID-SDA-SLUDGE, ID SDA-SOIL, January 29, 2007 

• CCP-AK-INL-001, Revision 5; Central Characterization Project Acceptable Knowledge 

Summary Report for Waste Retrieved from Designated Areas Within the Subsurface 

Disposal Area at the Idaho National Laboratory, Transuranic Waste Streams 

ID-SDA-DEBRIS, ID-SDA-SLUDGE, ID SDA-SOIL, August 31, 2007 and February 7, 

2008 

• CCP-AK-INL-001, Revision 6; Central Characterization Project Acceptable Knowledge 

Summary Report for Waste Retrieved from Designated Areas Within the Subsurface 
 

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Disposal Area at the Idaho National Laboratory, Transuranic Waste Streams 

ID-SDA-DEBRIS, ID-SDA-SLUDGE, ID SDA-SOIL, February 7, 2008 

• CCP-AK-INL-001 NDA Memo, March 29, 2006 

• CCP-PO-024, Revision 8; CCP-INL Interface Document, July 7, 2008 

• CCP-TP-006, Revision 14; CCP Visual Examination Technique for Idaho National 

Laboratory (INL) Newly-Generated TRU Waste Retrieved From Pits, November 11, 

2008 

• CCP-TP-005, CCP Acceptable Knowledge Documentation, Revision 18; November 16, 

2006 

• CCP-TP-005 Revision 18, Attachment 10; Acceptable Knowledge Re-Evaluation 

Checklist, ID-SDA Sludge, TIC Identification, October 30, 2008 

• ID-D002 Discrepancy Report and Resolution Concerning Prevalent Radionuclides for 

Waste Streams ID-SDA-SLUDGE, ID-SDA-SOIL, and ID-SDA-DEBRIS, April 12, 2006 

• ID-D004, Discrepancy Resolution Concerning the Packaging of Sludge Material in 

Cardboard Ice Cream Carton-Like Containers as Targeted Wastes, Scott Smith, 

September 10, 2008 

• ID-P218, Engineering Evaluation/Cost Analysis for Accelerated Retrieval Project II, 

U.S. DOE, Idaho Operations Office, DOE/NE-ID-11223, Revision 0; March 1, 2005 

• ID-P221, Waste Inventory for the Accelerated Retrieval Project 2, Jeffrey D. Bryan, EDF5447, Revision 1; May 31, 2005 

• ID-P222 Exhumation Area 1-7 WILD Database, August 17, 2006 

• ID-P239 SDA Waste Identification, Segregation/Sorting and Disposition Operator Guide 

GDE-318 1, August 21, 2006 

• ID-P242 Independent Investigation Report of the November 2005 Drum Fire at the Idaho 

National Laboratory Site, RPT-190, March 7, 2006 

• ID-P249 Excavation Plan for the AR Project (WMF- 1612) - Pits 4 and 6 Retrieval Area 

(ARP II) EDF-6974, Revision 0; June 13, 2006 

• ID-U313 Composite Source Term, August 7, 2006 

• ID-U323 Maps of Subsurface Disposal Area and Retrieval Areas, September 19, 2006 

• ID-U354 Maps of Retrieval Area, October 7, 2008 

• INL NCRs (non conformance report) Since 2006, Excel Spreadsheet, undated 

• NDA Isotopic Weight Percent Rollup Through Lot 19, ID-SDA-Debris, undated 

• NDA Isotopic Weight Percent Rollup Through Lots 1-43, ID-SDA-SLUDGE, undated 

• NDA Isotopic Weight Percent Rollup Through Lot 19, ID-SDA-SOIL, undated 

• RF-C222 Neptunium-Plutonium Content of ZPPR Residues, undated 

• RF-C443 Disposal of Uranium-233 Waste, April 10, 1974 
 

16 

• RF-U118 Thorium Use at Rocky Flats, June 2, 1976 

• Waste Stream Profile Form: Waste Stream Profile From Number ID-SDA-SOIL, 

Interstitial Soil from the Subsurface Disposal Area, Waste Stream ID-SDA-SOIL, 

approved June 17, 2008 

• Waste Stream Profile Form: Waste Stream Profile form Number ID-SDA-SLUDGE, 

Homogenous Solids from the Subsurface Disposal Area, Waste Stream ID-SDASLUDGE, September 9, 2007 

• Waste Stream Profile Form: Waste Stream Profile Form Number ID-SDA-DEBRIS, 

Heterogeneous Debris from the Subsurface Disposal Area, Waste Stream ID-SDADEBRIS, February 21, 2007 

The EPA obtained some of this information prior to the September 2008 inspection, but the 

majority of the information was provided from October to December 2008, during which time a 

desk-top AK review was performed. The inspection team evaluated the adequacy of this AK 

information specific to the CH TRU newly-generated debris, soil, and solid waste, with an 

emphasis on the effects of waste stream modification through the addition of new Contract 

Areas. Note that only one new T1 and five new T2 requirements based on this continued 

compliance inspection are included below, and all T1 and T2 requirements established in EPA’s 

baseline approval are retained. The following observations were made: 

(1) Procedural interfacing and implementation were examined and were found to be 

adequate. 

The following documents were reviewed to understand the waste characterization process at the 

ARP with respect to acceptable knowledge: 

• TPR-7415, Revision 46; AR Project Drum Packaging System 

• TPR-7420, Revision 41; AR Project-Waste Retrieval 

• CCP-PO-024, Revision 8; CCP/INL Interface Document 

• CCP-TP-006, Revision 4; Visual Examination Technique for Idaho National Laboratory 

(INL) Newly-generated TRU Waste Retrieved From Pits

• CCP-TP-005, Revision 18; CCP Acceptable Knowledge Documentation 

• ID-P249 Excavation Plan for the AR Project (WMF-1612) - Pits 4 and 6 Retrieval Area 

(ARP II) EDF-6974, Revision 0 

• ID-U313 Composite Source Term 

• ID-U323 Maps of Subsurface Disposal Area and Retrieval Areas 

• ID-P221 Waste Inventory Estimate for the Accelerated Retrieval Project II EDF-5447 

• ID-P222 Exhumation Area 1-7 WILD database 

• ID-P239 SDA Waste Identification, Segregation/Sorting and Disposition Operator Guide 

GDE-318 
 

17 

These documents were examined to understand the waste retrieval process, which identifies 

“targeted” waste. Targeted wastes are: 

• Homogenous wastes: inorganic and organic sludges from RFP Building 774 and roaster 

oxide from RFP including 741-Series, 744-Series and 743-Series 

• Heterogeneous debris: filters, primarily high efficiency particulate air and Chemical 

Warfare Service (HEPA and CWS) filters and graphite from RFP. 

For clarification, the terms targeted and non-targeted are applicable to waste materials as they 

occur within the burial pit. During exhumation, targeted wastes, as identified above, are 

processed for waste characterization by INL-CCP. Non-targeted wastes are staged in the 

exhumation area and returned to the burial pit. All wastes other than those identified as targeted 

are by definition non-targeted. Non-targeted wastes are not (intentionally) characterized for 

WIPP disposal. Note that soils are non-targeted, but there may be containers that hold targeted 

materials that are composed predominantly of soil that were inadvertently mixed during the 

retrieval process. That is, soil may become contaminated with targeted wastes when containers 

of targeted waste fail or break open, either during burial or upon retrieval. 

The retrieval process starts with identification of select areas and exhumation of those areas by 

the Idaho Cleanup Project (ICP). As described by CCP and ICP representatives, (CH2M-WG 

Idaho, LLC) (CWI), extraction of waste from the subsurface is performed following procedures 

presented in TRP-7420, Waste Retrieval. The locations of waste to be extracted are determined 

by programs outside of INL-CCP and are described in documents, some of which were provided 

to EPA for review, including the following: 

• ID-P215: Area Based Approach to Identify Type IV Waste for the Accelerated Retrieval 

Project II, Engineering Design File (EDF)-5601 

• ID-P216: Evaluation of Potential Visual Discriminators for Targeted Rocky Flats plant 

Sludge Waste Stream, EDF-5720 

• ID-P239: SDA Waste Identification, Segregation/Sorting and Disposition Operator 

Guide 

• ID-P249: Excavation Plan for the AR Project (WMF-1612)—Pits 4 and 6 Retrieval Area 

(ARP) II 

• ID-P275: Waste Inventory Estimate for the Accelerated Retrieval Project III, EDF-7884 

CWI personnel first identify targeted wastes, including other information such as the areas that 

these wastes were emplaced and emplacement depth. Wastes are removed (extracted) using a 

staged excavation campaign. The Initial Campaign Trench (ICT) stages non-targeted wastes, 

removes targeted wastes, and collects samples (for non-WIPP programs). The segregation 

process is intended to remove all non-WIPP program material from the waste. INL-CCP is not 

involved in the waste removal aspect of the ICP operation, but is a recipient of the TRU waste 

for characterization and disposal. EPA evaluated this operation to verify that waste received by 

INL-CCP is, in fact, targeted waste subject to EPA’s WIPP disposal regulations. 
 

18 

The Moving Trench Campaign of CWI then transfers non-target wastes from the initial 

campaign back to the pit, and removes targeted wastes for INL-CCP characterization. A Waste 

Identification Operator (WIO) visually identifies targeted wastes. Reference ID-P239 provides 

detailed descriptions of targeted and non-targeted wastes to help the WIO in waste identification 

as materials are excavated. This document includes detailed physical descriptions of waste, 

photographs, and other information to aid in the identification of target and non-target wastes. 

The WIO also identifies WIPP-prohibited waste according to TPR-7420. WIPP-prohibited 

items, including liquids and containers exceeding 4 liters, are managed separately prior to INLCCP accepting targeted waste for VE and subjected to other TRU waste characterization 

processes. Also, roaster oxide waste is excavated cautiously to ensure no “deflagration” (rapid 

oxidation of roaster oxides upon contact with air) occurs. INL-CCP performs visual examination 

of the waste, but waste packaging is the responsibility of CWI under procedure TPR-7415. 

The ICP requires periodic evaluations of the effectiveness of the identification process; EPA 

expects that ICP shares this information with CCP, and makes adjustments to the identification 

process if necessary. Of the approximately 1,810 NCRs issued since 2006, approximately 823 

were generated as a result of drums with TRU radioisotopes that were undetectable or less than 

100 nCi/g. That is, approximately 46% of the NCRs issued were because the waste did not 

contain greater than 100 nCi/g of TRU radioisotopes. Because ICP representatives or contractors 

periodically revisit the segregation process, INL-CCP and ICP can ascertain whether the current 

process is satisfactory, given this rejection rate. Providing any analysis evaluating the 

effectiveness of the Waste Identification Process to reduce the number of NCRs is a T2 change. 

(See Table 1 where this is included as a T2 change.) 

(2) Revision Nos. 2 – 6 of the AK Summary were evaluated for technical adequacy and/or 

logical integration of information through the revision sequence and were found to be 

adequate. 

The following AK summaries were examined during the inspection: 

• CCP-AK-INL-001, Central Characterization Project Acceptable Knowledge Summary 

Report for a Described Area in Pit 4 at the Idaho National Laboratory, Transuranic Waste 

Streams ID-SDA-PIT4-DEBRIS, ID-SDA-PIT4-SLUDE, ID-SDA-PIT4-SOIL, 

Revisions 2, 3, 4, 5, and 6, March 20, 2006, November 16, 2006, January 29, 2007, 

August 31, 2007, and February 7, 2008 

AK-INL-001 Revisions 1 and 2 addressed soil, solids, and debris from Pits 4 and 6 soil. Both 

documents contain a large amount of information concerning the origin and generation of wastes 

within the pits. Documents include roll-up data pertaining to the physical, chemical and 

radiological characteristics of the waste as a whole, although it is difficult to discern the specific

contributions of each generator site. Note that the AK Summary contains not only information 

about the process origin and composition of targeted wastes, but also the composition of other 

wastes that may incidentally be included in the waste stream through commingling. 

 
 

19 

ARP Areas I and II included Pit 4 and portions of Pit 6, both of which were included in EPA’s 

baseline approval evaluation. These two areas included both targeted and non-targeted material 

as follows: 

Targeted Material in ARP I and II: 

• RFP First-Stage Sludge (741-Series) 

• RFP Organic Setups (743-Series) 

• RFP Roaster Oxide 

• RFP Graphite 

• RFP Filters 

Non-Targeted Material in ARP I and II: 

• RFP Second-Stage Sludge (742-Series) 

• RFP Special Setups (744-Series) 

• RFP Evaporator Salt (745-Series) 

• RFP Miscellaneous Sludge 

• RFP Beryllium 1,009 

• RFP Line Generated Waste 

• RFP 233U 

• RFP Combustible Debris 

• RFP Non-Combustible Debris 

• Non-RFP Sludge 

• Non-RFP Combustible Debris 

• Non-RFP Non-Combustible Debris 

• Non-RF Unknown From ARA 

In Revision 3, the stream was expanded to include Contract Areas 1A, 2A, 6A, 6B, and 6C. 

Targeted waste identified in each area is as follows: 

Contract Area 1A: 

• RFP Graphite 

• RFP Filters 

Contract Area 2A: 

• RFP First-Stage Sludge (741-Series) 

• RFP Graphite 

Contract Areas 6A 6B 6C: 

• RFP First-Stage Sludge (741-Series) 

• RFP Organic Setups (743-Series) 

• RFP Roaster Oxide 

• RFP Filters 
 

20 

Non-targeted material potentially within the additional Contract Areas includes, but is not 

limited to, the following: 

Contract Area 1A: 

• RFP Miscellaneous Sludge 

• RFP Beryllium 

• RFP Combustible Debris 

• RFP Non-Combustible Debris 

• Non-RFP Non-Combustible Debris 

Contract Area 2A: 

• RFP Second-Stage Sludge (742-Series) 

• RFP Miscellaneous Sludge 

• RFP Beryllium 

• RFP Combustible Debris 

• RFP Non-Combustible Debris 

• Non-RFP Combustibles 

• Non-RFP Non-Combustibles 

Contract Areas 6A, 6B, 6C: 

• RFP Second-Stage Sludge (742-Series) 

• RFP Special Setups (744-Series) 

• RFP Evaporator Salt (745-Series) 

• RFP Beryllium 

• RFP Line Generated Waste 

• RFP Combustible Debris 

• RFP Non-Combustible Debris 

Data suggest that wastes from other generators are present within the additional Contract Areas, 

but the radiological characteristics of these wastes were not summarized in the AK Summary, 

and are instead included in Reference ID-U313 and ID-P222. Based on the information in these 

references, Contract Areas 1A, 2A, 6A, 6B, and 6C contain predominantly RFETS wastes. In 

addition, Contract Area 1A includes Test Area North (TAN) waste, and Contract Area 2A 

includes waste from Atomics International, the California Salvage Company, the University of 

Washington Radiological Safety Division, and the U.S. Nuclear Corporation (Reference IDP222). INL-CCP explicitly states: “Additional information must be collected and evaluated 

before the waste from these generators is included in the waste streams.” When INL-CCP 

evaluates waste information for these generators, the results of the evaluation and inclusion of 

this waste from small generator sites would be included in the AK Summary. Any forthcoming 

revision of CCP-AK-INL-001, Revision 6, is a T2 change. (See Table 1 where this is included 

as a T2 change).

Based on the available data, the process origin of wastes within the additional Contract Areas has 

been identified, at least in terms of identified target and non-target wastes. It should be noted 

that a large percentage of the waste in each of the additional areas is non-targeted material. If the
 

21 

targeted waste changes from what is presented in Revision 6 of the AK Summary, EPA must be 

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

(3) Radiological characteristics of the SDA waste streams were evaluated, including the 

effect that the additional Contract Areas have on the overall radiological composition of 

the three streams, and were found to be adequate. 

As indicated in the AK Summary, Revision 6, targeted waste streams include waste that 

originated from Rocky Flats: First and Second Stage Sludge (741-Series) from Rocky Flats; 

Organic Setups (744 or 743-Series Sludge); Roaster Oxide; Graphite; and Filters (CWS and 

HEPA). Non-targeted wastes include the following from Rocky Flats: Second Stage Sludge 

(742-Series); Special Setup (744-Series); Evaporator Salts (745-Series); Building 881 Discard 

Mud; Pond 2B Sludge; and other RFP sludges. Additional non-targeted wastes may include 

residuals from any of the mentioned generators that could have waste in the pit area 

(combustibles and non-combustibles), as well as INL sludge and beryllium-contaminated waste. 

INL-CCP references and the AK Summary indicate that targeted wastes have distinct 

radiological signatures primarily related to Rocky Flats, including weapons-grade plutonium 

(WG Pu), depleated uranium (DU) (roaster oxide) and enriched uranium (EU). INL-CCP 

described the following default isotopic radiological characteristics, prior to inclusion of the 

additional Contact Areas: 

WG Pu

•

238Pu 0.0105% 

•

239Pu 94.06% 

•

240Pu 5.72% 

•

241Pu 0.173% 

•

242Pu 0.043% 

DU 

•

238U 99.78% 

•

236U 0.006% 

•

235U 0.215% 

•

234U 0.001% 

HEU (highly enriched uranium)

•

238U 5.37% 

•

236U 0.44% 

•

235U 93.17% 

•

234U 1.02% 

The AK Summary, Revision 6, indicates that the primary data source available for the wastes 

buried in the retrieval area were the “Waste Disposal” forms. The Waste Inventory Location 

Database (WILD) was used by INL-CCP to determine the potential radionuclide listing, as well 

as the most prevalent radionuclides, both by mass and activity. INL-CCP indicated that the most 

prevalent radionuclides are 238U (99.69%) and 235U (0.15%), with 239Pu anticipated to constitute 
 

22 

approximately 0.14% of the mass.2 INL-CCP also stated that the most prevalent radionuclides 

by activity would be 241Pu (40.49%) and 241Am (39.59%). Table 5-4 of Revision 6 presents the 

relative mass and activities of radionuclides in the Retrieval Area, including ARP I/II and the 

new Contract Areas. The values in this table include both targeted and non-targeted wastes, 

because it is possible that non-targeted wastes could inadvertently be included in the waste 

stream (ID-D002). That is, these assumptions included both targeted and non-targeted material, 

because INL-CCP determined that distinguishing targeted and non-targeted material could be 

difficult and “rolling up” (combining) the anticipated radionuclide content of both wastes would 

be more appropriate. It is also assumed that the radiological composition of the soil, sludge, and 

debris would be the same. 

INL-CCP provided the most recent analysis of most prevalent radionuclides by mass in each 

waste stream that is presented in Table 4, below. These data indicate that while the most 

prevalent radionuclides by mass are 239Pu and 238U, the relative mass of 239Pu is much higher in 

debris, causing the most prevalent radionuclide by activity to be different for these waste 

streams. As suggested in D002, INL-CCP should revisit the radionuclide distributions to 

determine whether individual distributions by waste stream are more appropriate, given the most 

recent information. EPA anticipates forthcoming AK Summaries to address this issue. Note that 

the record obtained by EPA indicated there were no AK-NDA discrepancies with respect to 

radionuclide information that required preparation of an AK Re-Evaluation Checklist. It is 

unknown whether such a report is being prepared, and forthcoming EPA inspections will watch 

for this.

Table 4. Most Prevalent Radionuclides by Mass for Three INL-CCP Waste Streams 

Waste Stream* 235U% By Mass 238U% By Mass 239Pu% By Mass 240Pu% By Mass 

ID-SDA-SLUDGE 0.12 99.47 0.34 0.02 

ID-SDA-SOIL 0.16 99.14 0.63 0.04 

ID-SDA-DEBRIS 0.43 86.85 11.90 0.73 

* Total mass will not add to 100% due to the minor presence of other radionuclides.

To assess how the waste stream changed with addition of the Contract Areas, differences 

between Revision 2 (pre-Contract Area) and Revision 3 (post-Contract Area) were evaluated. 

Revision 3 shows slightly different mass and activity values for each of the targeted and 

identified radionuclides relative to Revision 2. Most significantly, Revision 3 changes the most 

prevalent radionuclide listings, so that 239Pu (0.36%) and 238U (99.37%) were the most prevalent 

by mass instead of 235U and 238U. Revision 3 also indicates that 241Pu (52.59%) and 241Am 

(36.21) are still the most prevalent by activity, with 239Pu present at approximately 8.9%. This 

conflicts with information presented in the Discrepancy Resolution (Reference D002, addressed 

in Item 6, below). A key element of this Discrepancy Resolution is that the author stated: “A 

more accurate radionuclide distribution would be based on what is actually retrieved and 

 

2

 Radionuclides vary in their activity per unit mass (specific activity), i.e., 239Pu, 235U, 238U and 241Am have different 

amounts of radioactivity per gram. Special Nuclear Materials (239Pu, 235U, 241Pu and 241Am) are typically tracked by 

mass (in grams), while other radionuclides (238U, 137Cs, 90Sr and non-TRU radionuclides) are typically tracked by 

activity (in curies). Accordingly, the most prevalent radionuclides for a given waste stream will vary depending on 

whether they are tracked by activity in curies or mass in grams. 
 

23 

packaged and known to be TRU waste”, recognizing variables that could make this analysis 

difficult (see Item 6, below). 

References ID-P222 and ID-U313 include WILD database information and rollups for the 

current excavation areas, including the additional Contract Areas. Information in these 

documents indicates that for all areas, RFETS waste is the predominant waste type present in 

burial including the additional Contract Areas. Reference ID-U313 shows that 239Pu, 240Pu and 

241Am are present in the highest quantities by activity in RFETS waste. In addition to the 

RFETS waste, Contract Area 1A includes TAN waste composed primarily of 137Cs and 90Sr, 

while Contract area 2A also includes wastes from several sources: ATI, composed 

predominantly of 137Cs; California Service Company, predominantly 137Cs; University of 

Washington Radiological Safety Division, predominantly 137Cs; and, U.S. Nuclear Corporation, 

predominantly 60Co, 137Cs and 90Sr. This information is not spelled out in the AK Summary, but 

can be derived through source document review. The Contract Area targeted wastes are a subset 

of the overall targeted waste types, so the isotopic distribution of the Contract Area waste is 

essentially the same as for the ARPI/ARPII. 

This analysis indicates that the new radiological information for the additional Contract Areas is 

available in the AK Record, and has been “rolled up” within the ARP I/II data tables. In the 

future, as new areas are added to the SDA retrieval, the AK Summary should include a brief 

description of the potential radiological changes imparted by inclusion of these areas, including 

non-targeted wastes that might be included in the waste stream, since the radiological 

distribution was assembled assuming potential inclusion of both targeted and non-targeted 

wastes. 

(4) Physical characteristics of the waste stream and the additional Contract Areas, including 

prohibited items, were assessed to determine whether the additional waste fit within the 

previously described waste streams. 

The wastes consist of debris (ID-SDA-DEBRIS), solid/sludge (ID-SDA-SLUDGE) and soil (IDSDA-SOIL). The AK Summary (CCP-AK-INL-001 Revision 6) describes the targeted debris 

waste as graphite and filters. Filter wastes include Type II and Type III wastes, with Type II 

consisting of filter paper described as cellulosics, i.e., paper, cardboard, wood, and cloth. Type 

III waste consists of “CWS filters” that were used in building ventilation systems, and HEPA 

filters. CWS filter are composed of a wood frame, cellulose-asbestos medium, and paper 

separators. After the 1957 fire at Rocky Flats, most of the filters were replaced with CWS filter 

types that were fire resistant and contained fiberglass and asbestos. While most filters are 

considered “cellulosic”, the filters from the Building 771 incinerator plenum were composed of a 

cadmium-plated steel frame, fiberglass-asbestos medium, and aluminum separators. As a result, 

filters with a metal frame are assigned the waste material parameter “iron-based metals” because 

like the wood frame filters, the metal frame will comprise the majority of the total filter weight. 

Graphite is a form of carbon, and graphite waste may include other materials such as concrete, 

glass, firebrick, ceramics, sand, and inorganic absorbents. 

Solid targeted wastes are RFETS 741-Series Sludge, an inorganic solid matrix derived from 

treatment of aqueous liquids that were solidified through addition of Portland Cement. RFETS 
 

24 

743-Sludge is an organic solid matrix derived from the treatment of oils with a synthetic calcium 

silicate and organic solvents to solidify them. Roaster Oxide, which is also targeted, consists of 

pure DU metal machine turnings converted to an oxide in a chemical roaster that INL-CCP 

classifies as a homogenous solid waste. 

Soils are not targeted wastes, but soil wastes (i.e., Waste Stream ID-SDA-SOIL) will be 

generated through excavation and removal of targeted waste and inclusion of interstitial soils in 

the extracted waste. When soil comprises greater than 50% of the waste in a drum, the waste is 

assigned to the soil waste stream, noting that the soil also includes less than 50% targeted debris 

and/or sludge wastes by volume. 

CCP-AK-INL-001 Revision 2 and Revision 3 were compared to assess how inclusion of the 

additional Contract Area wastes modified the physical characteristics of the streams. 

Comparison of target and non-target information indicates that the Contract Areas 1A, 2A and 

6A, 6B, and 6C wastes, both targeted and non-targeted, are subsets of the broader wastes in ARP 

I and ARP II. The total volumes for each of the areas included in CCP-AK-001, Revision 6, are 

presented in Table 5. 

Table 5. Waste Volumes by Area in CCP-AK-INL-001

Area Total Volume 

Targeted Waste (ft3) 

Total Volume 

Non-Targeted Waste (ft3) 

Total Waste 

Volume (ft3) 

ARP I 29,649 106,149 135,798 

ARP II 41,555 132,780 174,335 

1A 1,152 20,829 21,981 

2A 1103 22,149 21,046 

6A/6B/6C 10,309 38,383 48,692 

Total 83,768 320,290 401,852 

% of Total 20.9% 79.1% 100% 

The total volume of ARP I and ARP II is 310,133 ft3, of which 23% is targeted waste and 77% is 

non-targeted waste. In total, the 1A, 2A, 6A, 6B and 6C Contract Areas add a total of 91,719 ft3

, 

of which 14% is targeted waste and 86% is non-targeted waste. Addition of the Contract Areas 

increased the total volume of wastes, but did not increase the amount of targeted waste by 

percentage. 

The analysis of the information provided by INL-CCP indicates that the intended physical 

characteristics of the debris, solid, and soil wastes in the Contract Area and the ARP I and II 

areas should be comparable for targeted wastes. Data also suggest that there are no major 

anomalous non-targeted materials, but all wastes will be described during INL-CCP’s VE 

wherein the physical composition of waste is described and anomalous items are identified. 

(5) AK information assembly and compilation were evaluated to determine whether the 

additional Contract Areas were appropriately assessed. 

In addition to targeted material, Contract Areas 1A, 2A, 6A, 6B, and 6C contained non-targeted 

material. The location and characteristics of this non-targeted material were evaluated to 

determine whether inadvertent inclusion would significantly impact radiological composition or 
 

25 

physical characteristics, since it is probable that non-targeted wastes will unintentionally end up 

in the waste, particularly in soils. Revision 6 of the AK Summary does not identify the specific 

non-targeted materials added to the grouping as a result of the additional Contract Areas. 

Examination of Revision 2 and Revision 3 indicated that several changes were made, 

presumably, to the addition of the new Contract Areas. Examples of these changes include but 

are not limited to: 

• The date of wastes emplaced to be removed was modified from an initial date of 1964 to 

an initial date of 1959; even though the initial date of excavation in Pit 1 was 1957 and 

Pit 2 was 1959, it is assumed that the Pit 1A wastes were not emplaced in 1957. 

• In addition to the several INL, CMS, and other potential waste contributors (nontargeted) that were discussed in earlier AK documentation, Rockwell Atomics 

International was identified as a non-targeted waste within the SDA that was previously 

unidentified. Also, Contract Area 2A was added which contains material from California 

Salvage Company, University of Washington Radiological Safety Division, and U.S. 

Nuclear Corporation. 

• Excavation areas and waste volumes were modified to include the new Contract Areas 

(see item 4 above). For example, the total (targeted and non-targeted) waste volume prior 

to addition of the Contract Areas was 310,133 ft3 and Contract Areas 1A, 2A, 6A, 6B, 

and 6C added another 92,821 ft3

. 

• Solar evaporation pond wastes were identified as possibly being present in unspecified 

waste areas. 

• Resin hardening agent was recognized in one waste form in 744-Series Sludge. 

• Relative masses and activities of identified radionuclides were slightly modified, 

apparently due to the inclusion of more RFP 239Pu-bearing material (see Item 3 above). 

• Distribution and predominant radionuclides were modified to address Discrepancy 

Report D002, changing the most prevalent radionuclide designation and other 

specifications (see Item 3, above). 

• The November 2005 fire at SDA that resulted from excavation of 235U-bearing wastes 

was addressed. 

It was difficult to ascertain changes to the document based upon new Contract Areas with respect 

to radionuclides. EPA expects that future AK Summaries will clearly indicate how the addition 

of new areas fits within the specified physical and radiological characteristics of the waste 

stream. 

(6) AK discrepancy resolution was evaluated and was found to be adequate 

INL-CCP provided two AK Discrepancies for review, one of which dealt with radiological 

issues. Reference D002 was a discrepancy report prepared to address an AK-AK discrepancy 

between Reference EDF-4591 and the ARP I/II WILD source term database with regard to 

prevalent radionuclides. In short, the analysis concluded that there “may be a fundamental 

problem with the methodology for determining the radionuclide distribution for waste streams 
 

26 

ID-SDA-SLUDGE, SOIL and DEBRIS.” The original distribution presented in Revision 2 

included radionuclide distributions assuming the presence of targeted, non-targeted, and nonRFP non-targeted waste, and also assuming the same distributions applied to debris, soil, and 

sludge. More accurately, the Discrepancy Resolution states that the distributions should be made 

based on “what is actually retrieved and packaged and known to be TRU waste.” However, the 

report also cited four variables that might hinder this approach: (1) the inadvertent inclusion of 

non-targeted material that could affect the “known” distribution; (2) inclusion of graphite and 

HEPA filters that contain only uranium but which are indistinguishable from the same materials 

that contain TRU radionuclides; (3) lower amounts of uranium than predicted by AK could be 

present in 741 sludge, so the most prevalent radionuclides by mass (i.e., 238U and 239Pu) could be 

different than predicted; and (4) inadvertent commingling of roaster oxide (which contains only 

uranium) could affect the isotopic distribution in the repackaged waste. INL-CCP stated that 

these four variables could affect the “two most prevalent radionuclides” in the waste streams, but 

until this is demonstrated based on the Discrepancy Resolution, the most prevalent radionuclides 

would be 238U and 235U. 

Examination of Revisions 3-6 indicate that Revision 3 was changed to include this Discrepancy 

Resolution, but the most prevalent radionuclides by mass in the AK Summary were 238U and 

239Pu, not 238U and 235U, as stated in the Discrepancy Resolution. Note that the Discrepancy 

Resolution was dated April 13, 2006, and Revision 3 was dated November 16, 2006. No other 

discrepancy resolution is cited in the reference list for Revision 3. Revision 6 of the AK 

Summary retains the designation of 238U and 239Pu as the most prevalent radionuclides by mass. 

All future AK reports must include appropriately updated discrepancy resolutions to explain the 

differences between D002 and the AK Summary, which presumably should have reflected the 

same information, unless explained in another Discrepancy Resolution Report. Providing future 

Discrepancy Reports related to radiological and physical characteristics of the ID-SDA-SOIL, 

ID-SDA-SLUDGE, and ID-SDA-DEBRIS waste streams is a Tier 2 change. (See Table 1 where 

this is included as a T2 change.) 

(7) AK Summary adequacy and supplemental data sufficiency were examined and were 

found to be adequate. 

CCP provided seven different versions of the SDA AK Summary for review, each of which 

addressed the soil, debris, and sludge waste streams. Revisions 0, 1, 2, 3, 4, 5, and 6 of CCPAK-INL-001, Central Characterization Project Acceptable Knowledge Summary Report for 

Waste Retrieved from Designated Areas Within the Subsurface Disposal Area at the Idaho 

National Laboratory, Transuranic Waste Streams ID-SDA-DEBRIS, ID-SDA-SLUDGE, ID 

SDA-SOIL were dated November 18, 2004, April 15, 2005, March 20, 2006, November 16, 

2006, January 29, 2007, August 31, 2007 and February 7, 2008, respectively. 

EPA had previously examined Revisions 0, 1, and 2, so emphasis was placed on the differences 

between Revisions 2 and 3, as well as the final AK Summary Revision 6. EPA’s examination of 

data indicates that the AK Summaries are thorough with respect to presentation of information 

typical of AK Summaries. See Items 3, 4, 5, and 8 for additional commentary. 
 

27 

(8) AK Accuracy was assessed and was found to be adequate. 

INL-CCP provided AK Accuracy reports for ID-SDA-DEBRIS Lots 1-8 and ID-SDA-SOLIDS 

Lots 1-8. Neither accuracy report identified any issues with respect to waste material parameters 

or radionuclides. The Debris AK Accuracy Report indicated that the most prevalent 

radionuclides by mass are 238U (73.3%) and 239Pu (23.86%). The Solids AK Accuracy Report 

indicated that the most prevalent radionuclides by mass are 238U (99.17%) and 239Pu (0.53%). 

The significant difference in overall relative Pu-U percentages between debris and soil begs the 

question whether the radiological distribution in the AK Summary can be applied to both waste 

streams. This information supports future reassessment of the radionuclide information for each 

waste stream to determine whether the distributions should be established on a waste stream 

basis. It is expected that this issue would be addressed in Discrepancy Reports (see item 6, 

above). Providing AK Accuracy Reports for the ID-SDA-SOIL, ID-SDA-SLUDGE, and IDSDA-DEBRIS waste streams is a T2 change. (See Table 1 where this is included as a T2 

change.) 

(9) Load management was assessed and was found to not apply at INL-CCP at this time. 

INL-CCP has indicated that load management will not be performed. EPA observed that of the 

1,810 NCRs issued since 2006, approximately 823 were issued because drums did not contain 

TRU isotopes at concentrations above 100 nCi/g. These drums were returned to the host site, 

namely, INL. 

(10) Communication between NDA and AK personnel was evaluated (i.e., AK-NDA 

Memoranda) and was found to be adequate. 

A single AK-NDA memorandum has been issued that applies to all three SDA waste streams and 

is included with Attachment 7 of CCP-TP-005 Revision 18, prepared for each stream. The most 

recent memorandum is dated September 29, 2006, and it states that the soil, sludge, and debris 

waste streams are actually “conglomerations” of several waste streams mixed during retrieval, 

and it is not possible to predict a radiological distribution when the waste streams are expected to 

contain varying amounts of the parent waste streams. Tables 1 and 2 in the AK-NDA 

memorandum present the mass and activity fractions by target waste type. This memorandum 

states that if NDA does not yield isotopic results, default isotopics based on Rocky Flats WG Pu, 

HEU, and DU will be used. These three isotopic types are detailed in Tables 4-6 of the AKNDA memorandum, and they compare directly with the percentages presented in Item 3 above. 

Plutonium-242 will be determined by correlation techniques and 234U, which cannot be 

measured, will be calculated by scaling it to using measured 235U and/or 238U. Item 8, above, 

brings to question whether the radionuclide composition of debris versus sludges requires 

revisiting. Any changes to this composition would require modification(s) to the AK-NDA 

memorandum. All forthcoming revisions to the AK-NDA memoranda applicable to the IDSDA-SOIL, ID-SDA-SLUDGE, and ID-SDA-DEBRIS waste streams, or preparation of new, 

separate memoranda, is a Tier 2 change. (See Table 1 where this is included as a T2 change.) 
 

28 

(11) Continued compliance with respect to defense determination, spent nuclear fuel (SNF), 

and high level waste (HLW) was verified. 

The AK Summary Report Revisions 3 and 6 were assessed with respect to the defense origin of 

these wastes. The additional Contract Areas still targeted RFETS waste, and EPA had 

previously determined that the waste streams as a whole, were commingled with respect to the 

defense waste within. Therefore, the defense arguments posed by INL-CCP are supported by 

available documentation. It should be noted that EPA previously questioned whether specific 

non-defense containers (e.g., CSM, USGS, DRI) could be identified during drum retrieval, and 

thus segregated. EPA contends that the AK Summary Report should provide more detail on the 

amount of non-defense waste that may be in the SDA areas being retrieved. 

With respect to spent nuclear fuel and high level waste, the AK Summary, Revision 6, states: 

Based on the review of AK documentation, spent nuclear fuel (i.e., intact fuel 

elements) may have been buried in Pit 4, but not in the retrieval area. Spent 

nuclear fuel is not a targeted waste and will be segregated to the extent possible if 

encountered during retrieval operations. The Fuel Processing Facility (CPP-601) 

reprocessed highly enriched spent nuclear fuel to recover the uranium. High-level 

wastes generated by this facility were acidic liquids that were transferred to the 

Tank Farm, and were not buried in the SDA. Waste from CPP-601 buried in the 

retrieval area consists of dirt, masonry waste (e.g., concrete, sand, gravel), and 

debris waste (e.g., rags, paper, wood, metal, pump heads), and is not HLW 

(References ID-C105, ID-P091, INTEC-C001, INTEC-P001, INTEC-U001). 

Thus far, it does not appear that any NCRs were issued since 2006, due to the presence of intact 

fuel elements. 

Summary of AK Findings and Concerns

The EPA Inspection Team did not identify any findings or concerns relative to the information 

examined during the desktop review of data pertaining to Waste Streams ID-SDA-DEBRIS, IDSDA-SLUDGE, ID SDA-SOIL. 

Addition of New AK Tiering

EPA’s review identified potential changes or issues that may be examined in the future, and EPA 

will assess these through future document review, as presented in the following T2 changes: 

• Changing the targeted waste(s) from what was presented in Revision 6 of the AK 

Summary CCP-AK-INL-001 is a T1 change. 

• Providing any analysis evaluating effectiveness of the Waste Identification Process is a 

T2 change. 

• Providing forthcoming revisions of CCP-AK-INL-001 is a T2 change. 
 

29 

• Providing future Discrepancy Reports related to radiological and physical characteristics 

of the ID-SDA-SOIL, ID-SDA-SLUDGE, and ID-SDA-DEBRIS waste streams is a T2 

change. 

• Providing AK Accuracy Reports for the ID-SDA-SOIL, ID-SDA-SLUDGE, and IDSDA-DEBRIS waste streams is a T2 change. 

• All forthcoming revisions to the AK-NDA memoranda applicable to the ID-SDA-SOIL, 

ID-SDA-SLUDGE, and ID-SDA-DEBRIS waste streams, are T2 changes. 

These new T1 and T2 changes are added to the original tiering issued with the INL-CCP baseline 

approval. INL-CCP is responsible for seeking EPA approval of the T1 change before its 

implementation and notifying and providing EPA information related to the T2 changes on the 

schedule established as part of the baseline approval. 

8.2 Nondestructive Assay 

Technical Evaluation 

Because this inspection focused on the continued compliance of a site that had an existing 

baseline approval, the emphasis was on the continued operations of a subset of the approved 

equipment. Accordingly, an evaluation of the design and basic operating principles of the INLCCP NDA systems is not addressed in this report. These are addressed in detail in EPA’s 

baseline inspection report (see EPA Docket No.A-98-49; II-A4-59). This reports focuses on the 

following aspects of the WAGS and SuperHENC NDA systems: 

 

• Changes to the design and technical capability of the WAGS and SuperHENC hardware 

and software to perform the required analyses 

• Continued performance of these systems since the baseline approval as evidenced by 

routine measurement controls and anomalies 

• Compatibility between the systems’ operational parameters in terms of nuclear material 

content and matrix and the samples routinely assayed 

• Adequacy of the INL-CCP assay program’s documents and procedures to provide 

objective evidence of technical activities 

The checklists in Attachment A.2 and A.3 and the documents listed below comprise the 

documents that EPA examined in assessing the WAGS and SuperHENC systems during this 

inspection: 

• CCP-TP-010, CCP Waste Assay Gamma Spectrometer (WAGS) and SWEPP GammaRay Spectrometer (SWEPP) Calibration Procedure, Revision 3, November 6, 2006 

• CCP-TP-019, CCP Waste Assay Gamma Spectrometer (WAGS) Operating Procedure, 

Revision 4, October 19, 2006 

• CCP-TP-109, CCP Data Reviewing, Validating and Reporting Procedure, Revision 5, 

November 16, 2006 
 

30 

• CCP-TP-146, CCP SuperHENC Operating Procedure, Revision 1, January 4, 2007 

• CCP-TP-170, CCP SuperHENC Calibration Procedure, Revision 1, January 10, 2007 

• SuperHENC Data Reviewing, Validating, and Reporting Procedure, Revision 4, 

November 1, 2007 

• BII-5221-CVR-001, Calibration and Validation Report SuperHENC Mobile Assay 

System, Revision 0, November 2006 

• CCP-SHENC-07-001, INL SuperHENC Calibration Verification, Revision 0, January 10, 

2007 

• CCP-INL-WAGS-05-001, Weekly Interfering Matrix Results Waste Assay Gamma 

Spectrometer (WAGS) at INL, April 1, 2005 – October 1, 2005 

• CCP-INL-WAGS-06-003, Weekly Interfering Matrix Results Waste Assay Gamma 

Spectrometer (WAGS) at INL, October 1, 2005 – April 1, 2006 

• CCP-INL-WAGS-06-007, Weekly Interfering Matrix Results Waste Assay Gamma 

Spectrometer (WAGS) at INL, April 1, 2006 – October 1, 2006 

• CCP-INL-WAGS-07-001, Weekly Interfering Matrix Results Waste Assay Gamma 

Spectrometer (WAGS) at INL, October 1, 2006 – April 1, 2007 

• CCP-INL-WAGS-07-002, Weekly Interfering Matrix Results Waste Assay Gamma 

Spectrometer (WAGS) at INL, April 1, 2007 – October 1, 2007 

• CCP-INL-WAGS-08-004, Weekly Interfering Matrix Results Waste Assay Gamma 

Spectrometer (WAGS) at INL, October 1, 2007 – April 1, 2008 

• CCP-INL-WAGS-001, Waste Assay Gamma Spectrometer (WAGS) Calibration, 

Confirmation and Verification Report, Revision 0, April 27, 2005 

• CCP-INL-WAGS-06-005, Calibration Verification Report 

• CCP-INL-WAGS-08-001, Recalculation of Measurement Control Limits on the Waste 

Assay Gamma Spectrometer (WAGS) after Daily Performance Check Drum Hard SetDown 

• CCP-INL-WAGS-08-002, WAGS Multi-Curve Efficiency Calibration Extension 

Addendum, Revision 0, April 10, 2008 

• CCP-INL-WAGS-08-003, Recalibration Verification of the WAGS System After a 3-

Sigma Failure of the DPC Pu-239 Transmission Parameter, April 24, 2008 

• CCP-INL-WAGS-08-005, Calibration Verification of the WAGS System After Detector 

Replacement and Energy Calibration, August 6, 2008 

• CCP Standing Order: CCP-SO-INL-08-003, Clarification of Doubles Rate Requirement 

for SuperHENC in CCP-TP-146, March 4, 2008 

• WAGS Operational Logbook 2008, INL-NDA-WAGS-089 

• SHENC Operational Logbook CCP-INL-NDA-SHENC-2003, Calendar Year 2008 
 

31 

• SuperHENC BDR INNDAB080001 – SWB No. BN10211039 

• SuperHENC BDR INNDAB080002 – SWB Nos. BN10211037, BN10211038 & 

BN10215259 

• SuperHENC BDR INNDAB080003 – SWB Nos. BN10211045 & BN10215278 

• SuperHENC BDR INNDAB080004 – SWB Nos. BN10211043, BN10211044, 

BN10215293 & BN10215294 

• SuperHENC BDR INNDAB080005 – SWB Nos. BN10211040, BN10211041, 

BN10211042 & BN10215279 

• WAGS BDR INNDAW060008 – Container Nos. 10041591 & 10041595 

• WAGS BDR INNDAW080049 – Container No. ARP06138 

• WAGS BDR INNDAW080065 – Container Nos. ARP05, ARP06549 & ARP06631 

• INNDAW070159 – Container Nos. 10061521, 10019296, 10024527, 10181935, 

10020606, 10060904, 10174713, 10003141, 10025362, 10007999, 10181845, 10062578, 

10020593, 10033052, & 10021339 

• CCP-Idaho National Laboratory List of Qualified Individuals (LOQI), September 4, 

2008, 9:51:59 AM 

Each of the two systems is discussed below. 

Waste Assay Gamma Spectrometer (WAGS)

(1) The design of the WAGS was assessed for changes relative to the configuration that was 

approved during the baseline inspection. 

The WAGS is located in Building WMF-610, formerly called the SWEPP, at the RWMC at INL, 

in the same location as it was during the baseline inspection. The WAGS is a standard Canberra 

IQ3 gamma system that performs isotopic and quantitative assays. It consists of six highresolution broad-energy germanium (BEGe) gamma detectors, a drum turntable, shielded 

enclosure, and supporting electronics. The specific locations of the six gamma detectors were 

not changed. In July 2008, one isotopic detector was changed and the calibration was verified 

and documented appropriately in CCP-INL-WAGS-08-005. These detectors operate without 

cadmium filters, which was different from the baseline inspection3

. There were no other design 

or hardware changes to the WAGs software relative to the configuration evaluated during the 

baseline approval. 

The system runs NDA 2000 (Version 4.0), Genie 2000 (Version 3.0), MGA and MGA-U. When 

plutonium isotopes are not detected, the software attempts to compute isotopic distributions for 

uranium isotopes using the MGA-U program. The isotopic determination is performed 

simultaneously with the quantitative assay, and, if measurement-based isotopics are not 

 

3

 Cadmium filters attenuate the low-energy (<~ 80 keV) photons typically associated with higher 241Am 

concentrations for the purpose of decreasing system dead-time and improving isotopic determinations. 
 

32 

available, default AK values are used. The WAGS derives a value for 242Pu by correlation, and 

90Sr is determined by application of a scaling factor based on 137Cs. Uraniun-234 is quantified 

based on measured values for 235U and 238U. There were no substantive changes to the software 

relative to the configuration evaluated during the baseline approval. 

(2) System calibration of the WAGS had been performed and confirmed, and documented, as 

required, and were consistent with routine samples with respect to matrix and nuclear 

materials. 

The efficiency calibration of the WAGS is documented in CCP-INL-WAGS-001, “WAGS 

Calibration, Confirmation and Verification Report,” Revision 0, dated April 27, 2005. This 

calibration was performed at INL and produced the system’s calibrated range of 59 to 1,408 keV. 

The calibration was confirmed using WG Pu sources and the sources used for initial calibration 

and the calibration confirmation were different. All calibration confirmation and verification 

tests were within measurement criteria. There were no other changes to WAGS, the 

configuration evaluated during the baseline approval. 

(3) The calibrated range and operational range of the WAGS had been established and 

documented, including an extension of the density operating range. 

With respect to activity, CCP-INL-WAGS-001 states that the WAGS has a calibrated range for 

efficiency of 59 to 1,408 keV. Because this is not a mass calibration in the strict sense, it may 

seem inappropriate to state the calibrated range in terms of mass. The operational range is 

functionally defined as the Lower Limit of Detection (LLD), discussed below, at the lower end, 

and the administrative limit of 200 g per waste container, at the upper end. Theoretically, the 

system’s calibration has no true upper limit in terms of mass. Any assay value based on 

measured photon emission within the efficiency calibration range (59 to 1,408 keV) where all 

operational parameters such as system deadtime and resolution (peak shape) are acceptable is 

valid. The summary table on page 3 of CCP-INL-WAGS-001 presents an operating range of 

0.010 to 200 g of total plutonium. 

In September 2008, INL-CCP requested a T1 change to the WAGS in the form of an extension 

of the multi-curve efficiency calibration, documented in CCP-INL-WAGS-08-002. The purpose 

of the extension was to allow the assay of higher density containers, i.e., between 1.62 g/cm3

 and 

2.1 g/cm3, based on the known attributes of the roaster oxides scheduled for excavation [see AK 

(3), above]. EPA conducted a T1 evaluation of the extension of the WAGS efficiency 

calibration density range using a desktop review of documents provided by INL-CCP and a 

teleconference. EPA approved extending the efficiency calibration density range for the WAGS 

(see Docket No: A-98-49; II-A4-107). Based on the range extension, the WAGS had the 

following operational modes: 

• Density from 0.02 to 1.62 g/cm3

 for materials with Z<15, and an energy range of 59 to 

1,408 keV, the original efficiency and energy calibrations 

• Density from 1.62 g/cm3

 to 2.10 g/cm3 and an energy range of 59 to 1,408 keV, the 

extended efficiency calibration and original energy calibration 
 

33 

Because the T1 change had not been formally approved at the time of this inspection, there were 

no BDRs using the extended range operation available. 

(4) Performance checks, instrument repairs, and general operational aspects were evaluated 

and were found to be adequate. 

The current revisions of all applicable operating procedures were available in the WAGS 

instrument trailer and the WAGS logbook contained appropriate entries. There were four 

calibration verifications during CY 2006, none during CY 2007, and two during CY 2008. They 

were performed for a variety of reasons, e.g., failure of the 133Ba transmission source, and two 

calibration verification reports were reviewed in detail, CCP-INL-WAGS-06-005 from 2006 and 

CCP-INL-WAGS-08-003 from 2008. Both were technically acceptable and appropriately 

documented. Weekly Interfering Matrix checks had been performed and documented as 

required. 

INL-CCP personnel provided the following information regarding the 5,639 drums and 718 

BDRs that had been generated since the baseline inspection: 

• 2,148 assays and 245 BDRs in CY 2006 

• 1,467 drums and 210 BDRs in CY 2007 

• 2,024 drums and 276 BDRs in 2008 

Regarding the characteristics of the samples assayed on the WAQGS, INL-CCP personnel 

provided the following summary: 

• For approximately half of the assays MGA cannot produce useable isotopic values 

because of low plutonium content or elevated 241Am content, a situation that will be 

addressed by a new version of MGA 

• ARP wastes contain more uranium than legacy wastes 

• MGA-U is used for less than five percent of the samples, and they are predominantly DU 

• Approximately one to two percent of drums leave TRU space by virtue of being less than 

the LLD, and approximately 5%–10 % of ARP drums measure less than 100 nCi/g 

• Approximately one percent of legacy wastes lacks a measurable TRU signature upon 

assay 

(5) The total measurement uncertainty (TMU) for assays performed on the WAGS had been 

determined and is adequately documented. 

There were no changes to the TMU that had been established, since the baseline inspection for 

the WAGS is documented in CCP-INL-WAGS-002, “Total Measurement Uncertainty for the 

WAGS Spectrometer,” dated April 20, 2005. Evidence of this was observed in the WAGS 

BDRs evaluated during this inspection. 
 

34 

(6) The LLD of the WAGS had been determined and adequately documented for all 

operational modes. 

Typical LLD values for the extended range operation were documented in CCP-INL-WAGS-08-

002, Tables 7a and 7b, at densities of 1.62 g/cm3 and 1.94 g/cm3. There were no other changes 

to the LLD determination for the WAGS relative to what was approved during the baseline 

inspection. 

(7) The WAGS had continued successful participation in the CBFO-sponsored NDA 

Performance Demonstration Program (PDP). 

The WAGS had successfully participated in PDP Cycle 14A in May 2007 and Cycle 15A in June 

2008. INL-CCP personnel provided copies of the CBFO scoring reports for both PDP cycles 

that indicated the matrices and source loadings for the WAGS containers. 

(8) Replicate testing of the WAGS was performed and evaluated. 

The purpose of the replicate testing performed as part of this inspection was to provide EPA with 

an independent means to verify that the WAGS can provide consistent, reproducible results for 

the determination of the quantity of 10 WIPP-tracked radionuclides (241Am, 137Cs, 238Pu, 239Pu, 

240Pu, 242Pu, 90Sr, 233U, 234U, and 238U) and the TRU alpha concentration. This is accomplished 

by reassaying drums that were previously characterized on the same system or instrument in 

order to demonstrate the following: 

• The instrument produces results consistent with the reported TMU by comparing the 

sample standard deviation for a number of replicate measurements taken over several 

hours or days to the reported TMU. 

• The instrument provides reproducible results over longer periods of time, such as weeks 

or months, by comparing the results of the replicate measurement(s) to the original 

reported values. 

As with all statistical evaluations, there are limitations inherent in this protocol. The usefulness 

of the results depends in large part on the degree to which the conditions encountered are 

consistent with the assumptions upon which the tests are predicated. Our experience to date 

indicates that containers chosen at random do not always provide information best suited for the 

application of these statistical protocols. For example: 

• An NDA system may have been recalibrated in the time period between the original 

assay and the reassay performed during an inspection, and the new calibration may have 

different values for some of the calibration algorithm’s terms. 

• The containers chosen at random for replicate analysis may lack sufficient nuclear 

material content to provide useable data for some or all of the WIPP-tracked 

radionuclides. 

• High precision for the five replicate assays may yield an average value that differs 

slightly from the original assay value, but produces results that the statistical analysis 
 

35 

indicates are Significant or Highly Significant. However, these differences may be small 

variations that are more a function of the statistical protocols and do not indicate true 

measurement trends or problems, as discussed below.

• Since some radionuclides are quantified based on the measurement of another 

radionuclide, a Significant or Highly Significant indicator for one measured entity will be 

reflected in the other three, indicating a larger potential measurement trend or problem 

than actually exists. Examples include: values for 238Pu and 240Pu, which are derived by 

applying an isotopic ratio to a measured 239Pu value; and 137Cs and 90Sr that are 

quantified based on a directly measured 241Am value, an inferred 137Cs value, and a 

scaling factor for 90Sr, as discussed below. 

It is important to keep these in mind when evaluating replicate data and to realize that Significant

or Highly Significant results may not, in fact, be representative of true measurement issues, as 

discussed below for Container No. ARP06723. 

As part of this inspection, EPA requested that INL-CCP reassay five drums that EPA randomly 

selected from a list of drums previously assayed on the WAGS. Container Nos. 10212486, 

10215772, ARP05744, ARP06447 and ARP06723 were reassayed five times and the results 

were compared to the original assay data. Two statistical tests, a chi-squared (χ2

) test and a t test, 

were performed. Data and results of the statistical analysis are included in Attachments B.1 

through B.5. For container Nos. 10212486, 10215772, ARP05744, ARP06447 and ARP06723, 

the χ2 test showed that the observed variances in the replicate measurements are less than or 

equal to the reported uncertainties within the statistical limits of the test. For container Nos. 

10212486, 10215772, ARP05744, and ARP06447, the t test showed no statistically significant 

differences between the original assay values and the average of the five replicate measurements. 

The t test for container ARP06723 showed a statistically Highly Significant difference between 

the original assay value and the average of the five replicate measurements for 241Am, 3.54E-02 

pCi/g or the original 241Am value versus 2.53E-02 for the mean of the five replicates. This 

indicates that the variances in the replicate measurements for these items were greater than the 

reported uncertainties for all values relative to the limits of the test. The 137Cs and 90Sr values 

were also Highly Significant, which is expected based on the manner in which these 

radionuclides are measured. Because both 241Am and 137Cs have measurable photon emissions at 

662 keV, they cannot be distinguished directly. However, 241Am also has a measurable response 

at 722 keV and to quantify 137Cs, the gamma response at 662 keV that is not supported by (i.e., is 

disproportionate to) the gamma response at 722 keV is attributed to 137Cs. This is an indirect 

technique that is in widespread use for measurements involving WG Pu and its accompanying 

241Am. Additionally, 90Sr is quantified by scaling it to 137Cs. For reasons that are technically 

beyond the scope of this report, this approach for quantifying 137Cs may produce false positive 

values for 137Cs and 90Sr. This is of interest, because one might expect an anomaly for 241Am to 

be reflected in the 137Cs and 90Sr values, which was reported for this container. The true 

measurement anomaly for this container is probably associated with 241Am and the t test issue 

may be driven by the high degree of precision among the five replicates. These conditions 

represent a limitation of the test where one is essentially penalized by the tight grouping of the 

replicate assays. However, close examination of the data shows that while the agreement among 

the replicates is good, the Highly Significant flag does not appear to be an artifact. Specifically, 
 

36 

the original measured value for 241Am for this container clearly differs from the mean of the five 

replicates. There are several possible reasons for this—actual changes in the physical 

configuration of the container’ contents due to movement or settling; fluctuations in the 

measurement system’s background; temporal factors such as radioactive growth or decay; or, 

actual changes in the measurement system, the aspect that this test is designed to query. 

Although the software identified these variances as Highly Significant, this does not necessarily 

indicate a measurement issue that warrants additional attention at this time. 

Super High Efficiency Neutron Counter (SuperHENC)

(1) The design and operational history of the SuperHENC was assessed relative to the 

configuration that was approved during the baseline inspection. 

The SuperHENC is located in a trailer on site at INL in the RWMC adjacent to the Stored Waste 

Examination Pilot Plant (SWEPP), a building that houses other INL-CCP NDA systems used for 

characterizing TRU wastes. This is in the same location as when it was inspected during the 

baseline inspection. The SuperHENC consists of a passive neutron counter and an integral 

gamma-ray spectrometer, the SuperHENC Gamma Energy Analysis (SGEAS) that uses the 

FRAM isotopic software.4 The combination of neutron and isotopic distribution information 

allows quantification of 238Pu, 239Pu, 240Pu, 241Am, 233U, 235U, 238U, 137Cs and 237Np5. The 

system’s current approval allows the assay of Standard Waste Boxes (SWBs) and 100-gallon 

overpacks containing compacted 55-gallon drums referred to as pucks. Pucks are produced at a 

super-compaction facility operated by AMWTP, which is co-located in the RWMC at INL, and 

are provided to INL-CCP post compaction. The three possible assay configurations for the 

SuperHENC are as follows: 

• SWBs containing four 55-gallon drums of retrievably-stored S3000 sludge waste 

• 100-gallon overpacks containing compacted 55-gallon drums (pucks) of newlygenerated S5000 debris waste 

• SWBs containing two 100-gallon drums, each of which contains compacted 55-gallon 

drums (pucks) of newly-generated S5000 debris waste. 

The materials the system assays fall into two categories: S5000 debris loaded into 55-gallon 

drums and compacted into pucks by AMWTP that are overpacked in 100-gallon drums; or S3000 

sludge (solids) packaged in 55-gallon drums that are not compacted. The current software is 

SHENC1.03, Maestro B32, Version 6.05 and SuperHENC QCX15, version 1.0. 

There were no changes to the SuperHENC’s design relative to what was evaluated during the 

baseline inspection. 

 

4

 FRAM is an initialization for Fixed-Energy Response Function Analysis with Multiple Efficiencies. 

5

 The 242Pu content is determined using BII’s Efficiency Times Attenuation (ETA) calculations in an approach that 

has been evaluated previously on several BII NDA systems at other TRU waste characterization facilities. Each 

waste container’s 234U content is performed by application of scaling factors that are based on observed values for 

235U and 238U. The determination of 90Sr is performed by application of a scaling factor based on 137Cs. 
 

37 

 (2) The passive neutron and gamma calibrations of the SuperHENC were consistent with 

routine samples with respect to matrix and nuclear materials. 

The original calibration of the SuperHENC was performed at RFETS in 2001, and is 

documented in BII-5221-SRF-001, SUPERHENC RFETS Calibration Documentation Package. 

This is the calibration of record for the INL-CCP SuperHENC. This calibration was confirmed 

at INL in 2006, and is documented in BII-5221-CVR-001, Calibration and Validation Report 

SuperHENC Mobile Assay System, Revision 0, November 2006. Calibration confirmation was 

performed with six measurements of an empty SBW over a range of Pu loadings, and all 

acceptance criteria were met for each of the six runs. The system’s stated operational ranges for 

neutron assays are from the Limit of Detection or LLD (discussed below) to 12.658 g 240PuEff, 

equivalent to 203.616 g weapons grade (WG) Pu, as stated in BII-5221-CVR-001. The energy 

versus channel calibration for the hyper pure germanium detector (HPGe) had been performed as 

required. Because the HPGe is used in relative ratio mode only, there is no true gamma 

operational range. INL-CCP NDA personnel confirmed that the SGEAS had not been used to 

obtain quantitative values for any waste container and that it has only provided isotopic 

information which is combined with the passive neutron values. 

Regarding isotopic determinations, INL-CCP NDA personnel provided the following summary 

of how isotopics are determined, based on the observed 240PuEFF fitness factor (FF): 

• For FF < 0.17 – Use AK-based isotopics 

• For FF > 0.4 – Use isotopics from FRAM 

• For FF 0.4 > FF >0.17 – Isotopics determined by the Expert Analyst (EA) 

In general, a mass of 1–5 g of WG Pu produces a FF > 0.17. Use of the FF is discussed in detail 

in BII-5221-CVR-001. The EA reviews one hundred percent of the SuperHENC assays. There 

are two different approved AK-based isotopics that are documented and available for use by 

INL-CPP personnel, one from AMWTP documented in PRT-TRUW-07 (BN-510) and one from 

INL documented in the NDA Memorandum CCP-INL-AK-005 (53114). INL-CCP personnel 

stated that they had assayed four containers with heat source plutonium (HS Pu) so far, and that 

they were able to use measured isotopics for one and AK-based isotopics for the other three. The 

use of steel filters is referenced in several INL-CCP documents, but INL-CP NDA personnel 

stated that steel filters had not been used although they may be used in the future. There were no 

substantive changes to the SuperHENC calibration and operational ranges relative to what was 

evaluated during the baseline inspection and these remain appropriate for the wastes assayed, as 

discussed in (3), below. 

(3) Performance checks, instrument repairs, and general operational aspects were evaluated 

and were found to be adequate. 

The current revisions of all applicable SuperHENC procedures were available in the instrument 

trailer and the SuperHENC logbook contained appropriate entries. There were two calibration 

verifications performed, one following replacement of a Helium 3 tube and one following 

replacement of the Add-A-Source motor. Both were technically acceptable and appropriately 

documented. INL-CCP personnel stated that due to a revision of CCP-TP146 (Revision 4 was 
 

38 

replaced by Revision 5), the SuperHENC was not operational for approximately a one-month 

period, which was verified by SuperHENC log book entries. Weekly Interfering Matrix checks 

had been performed and documented as required. 

Regarding the three assay configurations discussed in (1), above, INL-CCP personnel provided 

the following numbers of containers assayed for each configuration: 

• SWBs containing four 55-gallon drums of retrievably-stored S3000 sludge waste – No 

assays in FY 2007, 14 assays in FY 2008 

• 100-gallon overpacks containing compacted 55-gallon drums (pucks) of newlygenerated S5000 debris waste – 200 assays (38 BDRs) in FY 2007, 555 assays in FY 

2008 

• SWBs containing two 100-gallon drums, each of which contains compacted 55-gallon 

drums (pucks) of newly-generated S5000 debris waste – No assays in FY 2007 or 2008 

INL-CCP personnel confirmed that they had not assayed S4000 wastes on the SuperHENC in 

any configuration and that there were (approximately) 12 100-gallon overpacks that measured 

less than 100 nCi/g during FY 2007. 

(4) The SuperHENC had continued successful participation in the CBFO-sponsored NDA 

PDP. 

The SuperHENC had successfully participated in PDP Cycle B8A in November 2007. The 

anticipated operation of a box counter at DOE’s Savannah River Site (SRS) prompted an 

extension of the assay period for Cycle B9A to October 18, 2008, so results for this cycle were 

not available. INL-CCP personnel provided a copy of the CBFO scoring report for PDP Cycle 

B8A that indicated the matrix and source loadings for the SuperHENC container. 

(5) The TMU of assays performed on the SuperHENC had been determined and 

documented. 

The determination of the TMU for the SuperHENC is documented in BII-5221-CVR-001, 

Section 4.1.1. There were no changes to the TMU determination of the SuperHENC relative to 

what was approved during the baseline inspection. 

(6) The LLD, including the minimum detectable concentration (MDC) of the SuperHENC 

had been determined and documented. 

There were no changes to the derivation and application of LLDs and LLD equivalents to the 

SuperHENC relative to what was approved during the baseline inspection. 

(7) EPA replicate testing of the SuperHENC was performed and evaluated. 

The purpose of the replicate testing performed as part of this inspection is to provide EPA with 

an independent means to verify that the SuperHENC can provide consistent, reproducible results 
 

39 

for the determination of the quantity of 10 WIPP-tracked radionuclides (241Am, 137Cs, 238Pu, 

239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U and 238U) and the TRU alpha concentration. This is normally 

accomplished by requesting that the site reassay drums that were previously characterized on the 

same system or instrument in order to demonstrate the following: 

• The instrument produces results consistent with the reported TMU by comparing the 

sample standard deviation for a number of replicate measurements taken over several 

hours or days to the reported TMU. 

• The instrument provides reproducible results over longer periods of time, such as weeks 

or months, by comparing the results of the replicate measurement(s) to the original 

reported values. 

EPA requested that INL-CCP reassay two waste containers that EPA randomly selected from a 

list of containers previously assayed on the SuperHENC. EPA chose Container Nos. 

BN10139128 and BN10141587. Each of these previously assayed containers was reassayed five 

times on the SuperHENC for this inspection. Two statistical tests, χ2

 test and a t test, were 

performed on the replicate analyses of each container. Analytical data for each assay event and 

results of the statistical analysis are included in Attachments B.6 and B.7.

For both containers, the t test showed no statistically significant differences between the original 

measurement assay values and the average of the five replicate measurements for all 

measurement parameters. The χ2 test for these containers showed that the observed variances in 

the replicate measurements were less than or equal to the reported uncertainties for all values 

within the statistical limits of the test. There are no outstanding issues with either statistical test 

for these containers. 

Summary of NDA Findings and Concerns

The EPA inspection team did not identify any findings or concerns related to the WAGS or 

SuperHENC NDA systems during this inspection. 

Changes to NDA Tiering

There are no changes to NDA T1 and T2 change designations. 

8.3 Real-Time Radiography 

Real-Time Radiography for retrievably-stored (legacy) waste 

The INL-CCP RTR system that was approved for S3000 and S5000 waste during the baseline 

inspection consisted of the following four items, each of which was evaluated as described: 

(1) Training for INL-CCP RTR personnel (Operator/ITR/TS/FQAO, Site Project Manager 

(SPM) and Site Project Quality Assurance Officer (SPQAO)) was assessed and was 

found to be adequate. 
 

40 

Operators at INL-CCP received training for RTR Unit No. 5 in accordance with the procedure 

“Training for Idaho National Laboratory Real-time Radiography – System 5,” on September 14, 

2005 and the first examinations took place on September 21, 2005. Since that date operators 

have been re-qualified every two years as required. EPA reviewed the List of Qualified 

Individuals (LOQI) for RTR personnel and found that only qualified operators were used to 

perform RTR examinations. 

Test drum No. INL-NDE-TEST-34 was used to demonstrate operator capability for examinations 

of drums containing both S3000 and S5000 waste. EPA reviewed the written record and 

audio/visual recordings, for demonstration of capability examinations of two operators dated 

April 24, 2008. EPA determined that the examinations were complete and there were no 

discrepancies between the written and audio/visual records. 

(2) The approved and controlled operating procedures: CCP-TP-102, Revision 6, CCP RTR 

No. 2 Radiography Inspection Operating Procedure, April 15, 2005; and CCP-TP-028, 

Revision 2, CCP Radiographic Test and Training Drum Requirements, February 4, 2005, 

were assessed and found to be adequate. 

CBFO correctly reported a Tier 2 change for procedure CCP-TP-102 in that it had been 

cancelled and procedure CCP-TP-053 was now used to perform RTR examinations at INL-CCP. 

RTR Unit No. 5 is located in Building 610. During the on-site demonstration the RTR operator 

had a copy of the procedure CCP-TP-053 available for guidance. A second operator completed 

the electronic data forms as waste items were identified by the operator performing the 

examination. At the end of the demonstration, both operators reviewed the Waste Material 

Parameters (WMP) for accuracy and completeness and assigned weights to each. 

(3) INL-CCP RTR equipment (CCP Mobile Real Time Radiography Unit No. 2) was 

assessed and was found to be adequate. 

At the time of the baseline inspection, RTR Unit No. 2 was in active use for radiographic 

examinations. In the Tiering Change Report dated March 3, 2006, CBFO informed EPA that 

INL-CCP had added RTR Unit No. 5 and that procedure CCP-TP-102 was revised accordingly. 

Unit No. 5 had previously been in operation at the Nevada Test Site (NTS). Operators at INL 

received training for RTR Unit No. 5, titled “Training for Idaho National Laboratory Real-Time 

Radiography – System 5,” on September 14, 2005, and the first examinations took place on 

September 21, 2005. 

EPA observed the RTR examination of two drums, one S3114 and one S5300, on RTR unit #5. 

Also, EPA reviewed the Image Quality Check for the day of the demonstration, which was 

within the acceptance criterion stated in CCP-TP-053. 

(4) RTR records (Attachments 6 and 7 from procedure CCP-TP-102, Revision 6) and RTR 

BDRs were reviewed and were found to be readily available, complete and adequate. 

BDRs contain, at a minimum, data sheets generated during the examinations and review 

checklists. EPA compared the BDR written records and the audio/visual recordings of four 
 

41 

containers to ensure completeness, clarity, and consistency. No differences between the two 

types of records were found. Training records and Demonstration of Capability audio/visual 

records were reviewed and found to be complete and accurate. Quality Control examinations 

were performed as required; an Independent Observation and Replicate Scan were performed for 

each batch of drums examined. 

Summary of RTR Findings and Concerns

The EPA inspection team did not identify any findings or concerns related to the RTR during this 

inspection. 

Changes to RTR Tiering

There are no changes to RTR T1 and T2 change designations as a result of this inspection. 

8.4 Visual Examination Technique (VET) 

Visual Examination Technique (VET) for newly-generated waste 

The scope of this continuing compliance inspection of INL-CCP covered visual examination of 

newly-generated waste, excavated from the ARP site, ARP 2, Building 1612. Removal of 

targeted waste from ARP1, Building 697, was completed prior to EPA’s inspection. The target 

waste removed is subject to VE and placed in 55-gallon drums for disposal. 

The VET system approved for S3000, S4000, and S5000 waste during the baseline inspection 

consisted of the following three elements, each of which was assessed as described: 

 (1) Training for INL-CCP VE personnel [VEO, Subject Matter Experts (SME), SPM, and 

SPQAO] was assessed and was found to be adequate. 

The EPA reviewed training records and Qualification Cards for one Visual Examination Expert 

(VEE) and eleven Operator/ITRs. All VE personnel had received specific training for the waste 

examined through a training module titled, “Specific Training for Idaho National Laboratory – 

Newly-generated TRU Waste Retrieved from the Pits.” All of the records reviewed were 

complete and demonstrated the INL-CCP continues to use trained personnel to perform visual 

examination of newly-generated ARP waste. Qualified VE operators and VEEs were contained 

in CCP’s LOQI, and only these personnel were performing VE at the time of the on-site visit. 

(2) The approved and controlled INL-CCP RTR operating procedure [CCP-TP-006, 

Revision 4, CCP Visual Examination Technique for Idaho National Laboratory (INL) 

Newly-generated TRU Waste Retrieved from Pits, April 19, 2005] was assessed and was 

found to be adequate. 

Procedure CCP-TP-006, CCP Visual Examination Technique for INL Newly-generated TRU 

Waste Retrieved from Pits, is currently at revision 12 with an effective date of May 1, 2008. 
 

42 

(3) VE records (Attachment 1 from CCP-TP-006) VET BDRs were reviewed and were found 

to be readily available, complete, and adequate. 

The three BDRs that EPA reviewed were complete and recorded the VE data generated and 

required information. These BDRs included containers with S3000, S4000, and S5000 wastes. 

The data forms for each container had been signed by two qualified operator and a qualified 

VEE. The requirements for data review have changed since the baseline inspection. Currently 

only a data generation level review ITR and a project level review, Site Project SPM, are 

required. EPA concluded that VE records, including Attachment 1 from procedure CCP-TP-006, 

BDRs, and data review checklists, continue to be generated by effective implementation of the 

applicable INL-CCP procedures. 

Summary of VET Findings and Concerns

The EPA inspection team did not identify any findings or concerns related to the RTR during this 

inspection. 

Changes to VET Tiering

There are no changes VET T1 and T2 change designations. 

8.5 Container Management 

Container Management was not part of the scope of EPA’s 2005 baseline inspection. However, 

in response to recent events concerning container management, it is EPA’s intention to perform a 

review of these processes at each site when circumstances permit this. 

For characterization activities and shipping, INL-CCP interfaces with AMWTP in that AMWTP 

personnel are responsible for actual movement of containers throughout this process. Personnel 

performing the actual container movement are employed by the host site. The procedures 

implemented at INL-CCP ensure that the location of individual containers can be determined 

throughout the characterization process. These include barcodes, container travelers, WTS, and 

some INL-CCP management tools. Throughout the characterization process, personnel check 

the drum number against the AK tracking sheet to ensure that the drum in question belongs in the 

CCP process. Procedure CCP-TP-068, Container Management at the Idaho National Laboratory 

(INL) and TRU Waste Processing Center (TWPC), is used for container tracking and 

management. It is the responsibility of the CCP VPM to schedule container movements with 

the host site. 

INL-CCP receives drums in Building WMF-610, which contains the RTR and NDA equipment. 

Drum numbers are checked against the AK Tracking Sheet to ensure that the delivered drums are 

eligible for characterization. INL-CCP also ensures that each retrievably-stored waste drum has 

a minimum of three bar code labels, with the container ID number, e.g., 10174688, on them. 

Newly-generated waste drums from the ARP have both a container ID number, such as 

10174688 and an ARP number, e.g., ARP 10839. For these containers, INL-CCP uses the ARP 

number only. Drum receipt is recorded on a VPM Drum Receipt / Return Journal form which 
 

43 

includes acceptance or rejection of each drum. This form is a management tool and is not a part 

of controlled procedure CCP-TP-068. After the AK Tracking Sheet check, container integrity 

and filter check (Attachment 2, CCP-TP-068) and drum weighing (Attachment 3, CCP-TP-068), 

the drum is ready for characterization. 

A Traveler, Attachment 1 of CCP-TP-068, is attached to each container and characterization 

personnel are responsible for completion of applicable sections after completion of the testing. 

As drums are delivered to each process, the characterization personnel verify that the drum is on 

the AK Tracking Sheet. At the end of characterization, the Traveler is removed from the 

container and maintained as nonpermanent record. 

Drums are stored in Building WMF-628 while waiting for movement through the CCP 

processes. CCP has two tags that may be attached to drums. A blue tag indicates there is 

something not complete for that container and this also indicates that there is an electronic hold 

on the container. Drums that have a Nonconformance Report (NCR) written against them have a 

red tag attached to them. These containers cannot be processed further until the NCR is resolved 

and the NCR tag removed. EPA verified that CCP was able to demonstrate the status and 

location of four containers stored in Building WMF-628 at the time of the inspection. Procedure 

CCP-TP-068 is adequate and effectively implemented to track and move containers from 

AMWTP to CCP and through CCP’s characterization processes. EPA has committed to 

inspecting container movement in the shipping process at some future date. 

9.0 SUMMARY OF RESULTS 

9.1 Findings and Concerns 

There were no concerns or findings relative to INL-CCP during this continued compliance 

inspection. 

9.2 Conclusions 

The EPA inspection team determined that the INL-CCP WC program activities continue to be 

technically adequate. EPA is adding to the original tiering changes one T1 and five T2 changes 

to the AK component of the INL-CCP WC program at this time, as discussed in Section 1 and 

shown in Table 6 below. The scope of the compliance decision is based on EPA’s inspection 

completed September 16–18, 2008, and October–December 2008.
44 

Table 6. Revised Tiering of TRU WC Processes Implemented by INL-CCP 

Based on May 3–5, 2005, Baseline Inspection and September 16–18, 2008, Continued Compliance Inspection

WC Process Elements INL-CCP WC T1 Changes INL-CCP WC T2 Changesa 

Acceptable Knowledge (AK) and Load Management 

Any new summary category group for TRU waste Changes to WWIS algorithms specific to load management requiring revisions to the load management provisions of DOE’s CH Waste Acceptance Criteria (CH WAC) Changes to the targeted waste(s) from what was 

presented in Revision 6 of the AK Summary CCP-AKINL-001 (AK 2)

Notification to EPA upon completion of the following: 

Waste Stream Profile Forms including updates or additions to waste stream(s) within 

an approved waste category Changes in load management status of approved waste stream(s) Changes to the WWIS algorithms corresponding to the changes to the load management provisions of the CH WAC Changes to site procedures requiring CBFO approvals

Providing any analysis evaluating effectiveness of the Waste Identification Process 

(AK 1) 

Providing future revisions of CCP-AK-INL-001, Revision 6 (AK2) Providing future Discrepancy Reports related to radiological and physical 

characteristics of the ID-SDA-SOIL, ID-SDA-SLUDGE, and ID-SDA-DEBRIS waste 

streams (AK 6) Providing AK Accuracy Reports for the ID-SDA-SOIL, ID-SDA-SLUDGE, and IDSDA-DEBRIS waste streams (AK 8) 

All forthcoming revisions to AK-NDA memoranda that apply to ID-SDA-SOIL, IDSDA-SLUDGE, and ID-SDA-DEBRIS waste streams (AK 10)

Non Destructive Assay 

(NDA) 

New equipment or substantive changesb to approved 

equipment affecting actual radioassay results (e.g., DQO compliance, TMU) Modificationc to approved calibration range for 

approved equipment and/or equipment 

Changes to software for approved equipment

Changes to operating range(s) upon CBFO approvalChanges to site procedures requiring CBFO approval 

Real-Time Radiography (RTR) Not Applicable Changes to site procedures requiring CBFO approval Visual Examination (VE) Not Applicable Same as above WIPP Waste Information System (WWIS) Not Applicable Same as above 

a INL-CCP will report all T2 changes to EPA at the end of each fiscal quarter. 

b “Substantive changes” are changes with the potential to impact the site’s WC activities or documentation thereof, excluding changes that are solely related to ES&H, nuclear safety, or 

RCRA, or that are editorial in nature. 

c “Modifications to approved calibration range for approved equipment and/or equipment” include all changes with the potential to affect NDA data relative to waste isolation and exclude 

minor changes, such as the addition of safety-related equipment.
A.1-1 

ATTACHMENT A.1: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGS 

NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGS 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Required Technical Elements Changes Since Baseline? Verification of Activity Objective Evidence 

System Description Confirm the name, location, and number of the INL-CCP WAGS. Ensure that this is the same unit as what was approved during the EPA 

baseline inspection in 2005. 

No changes since baseline inspection. 

EPA personnel verified that the WAGS assay unit is the same as what was observed during the 

baseline inspection. 

Visual inspection of WAGS in SWEPP at INL during inspection. 

Identify any hardware and/or software changes made to the WAGS since the baseline approval. Determine which changes, if any, are significant, where they are documented, and how they affect the WAGS’s baseline approval. 

Yes One isotopic detector was 

replaced in July 2008. 

CCP-INL-WAGS-08-005, Calibration Verification of the WAGS System After Detector Replacement and Energy Calibration, August 6, 2008. 

Describe the system’s operational history since the baseline approval. 

Yes Same as observed previously, 

except for density range extension. 

CCP-INL-WAGS-08-002, WAGS Multi-Curve Efficiency Calibration Extension Addendum, Revisions 0 and 1 

List all applicable calibrations, operational and data reduction/validation procedures, and the current revisions that are in use for the WAGS. 

No changes since baseline inspection. 

All procedures observed in use 

by WAGS personnel were the 

current revisions. 

CCP-TP-010, Revision 3; CCP-TP-019, Revision 4; CCP-TP-109, Revision 5. 

System Performance Identify the following: • Number of waste containers this system 

assayed during the period of performance 

• Number of BDRs assembled 

• Number of BDRs that have been promoted 

through Project Level Review 

Yes 5639 drums and 718 BDRs have 

been generated since the baseline inspection: 

• 2,148 assays and 245 BDRs 

in CY 2006 

• 1,467 drums and 210 BDRs 

in CY 2007 

• 2,024 drums and 276 BDRs 

in 2008 

Interviews with INL-CCP WAGS personnel during this inspection. 
A.1-2 

NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGS 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Required Technical Elements Changes Since Baseline? Verification of Activity Objective Evidence 

General Reporting Requirements The WAGS provides quantitative values and uncertainties for 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 233U, 234U, 238U, 90Sr, and 137Cs. Identify other 

radionuclides that are encountered during routine WAGS assays. 

No changes since baseline inspection. 

The INL-CCP WAGS continues acceptable operation. CCP-INL-WAGS-001, Revision 0, April 27, 2005, and Revision 1, April 2, 2008; WAGS BDRs 

INNDAW060008, INNDAW080049, and INNDAW080065. 

Each container characterized by the WAGS intended for disposal at WIPP must contain TRU waste. 

No changes since baseline inspection. 

The INL-CCP WAGS continues acceptable operation. CCP-INL-WAGS-001, Revision 0, April 27, 2005, and Revision 1, April 2, 2008; WAGS BDRs 

INNDAW060008, INNDAW080049, and INNDAW080065. 

WAGS procedures are appropriate for the waste streams being assayed, and the results provide unbiased values for the cumulative activity of the WIPP radionuclide inventory. 

No changes since baseline inspection. 

The INL-CCP WAGS is appropriate for the waste containers assayed in terms of radionuclide content and matrix. 

CCP-INL-WAGS-001, Revision 0, April 27, 2005, and Revision 1, April 2, 2008; WAGS BDRs INNDAW060008, INNDAW080049, and INNDAW080065. 

Confirm the radionuclides that are derived by the application of scaling factors and/or correlation techniques and the technical adequacy of these techniques. 

No changes since baseline inspection. 

The INL-CCP WAGS continues acceptable operation. CCP-INL-WAGS-001, Revision 0, April 27, 2005, and Revision 1, April 2, 2008; WAGS BDRs 

INNDAW060008, INNDAW080049, and INNDAW080065. 

Acceptable Knowledge (AK)Confirm when NDA personnel use AK-derived isotopic values and identify the formal procedure controlling this function. 

No changes since baseline inspection. 

Isotopics are based on MGA, measurement statistics 

permitting. Only approved 

AK-based isotopics are used. 

CCP-TP-019, Revision 4; CCP-TP-109, Revision 5. 

Evaluate the AK used for the wastes and/or waste streams assayed by the WAGS and ensure that all radionuclides encountered fit under the WAGS’s approved AK. 

No changes since baseline inspection. 

For approximately half of the assays, MGA cannot produce useable isotopic values because of low Pu or elevated 241Am. 

ARP wastes contain more uranium than legacy wastes. MGA-U is used for less than 5% of samples and they are 

predominantly DU. 1%–2% of 

drums measure less than the 

Interviews with INL-CCP WAGS personnel during this inspection; CCP-TP-019, Revision 4. 
A.1-3 

NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGS 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Required Technical Elements Changes Since Baseline? Verification of Activity Objective Evidence 

LLD, 5%–10 % of ARP drums measure less than 100 nCi/g. 1% of legacy wastes lack a measurable TRU signature upon assay. 

Isotopic Determination Identify the radionuclides that are measured directly. 

No changes since baseline inspection. 

238Pu, 240Pu and 242Pu are derived 

by mass ratios to a measured 

239Pu; 241Am and 233U are 

measured directly when sufficient signal is present, otherwise they may be ratioed to the measured 239Pu value; 234U is 

scaled to the measured 238U 

and/or 235U; 90Sr is scaled to 

137Cs. 

CCP-INL-WAGS-001, Revision 0, April 27, 2005, and Revision 1, April 2, 2008; WAGS BDRs INNDAW060008, INNDAW080049, and INNDAW080065. 

Confirm that the method(s) used to derive the isotopic contribution for unmeasured radionuclides are MGA and MGA-U. 

No changes since baseline inspection. 

MGA and MGA-U are integral 

parts of the WAGS operation. 

CCP-TP-019, Revision 4; Interviews with INL-CCP WAGS personnel during this inspection; WAGS BDRs INNDAW060008, INNDAW080049, and INNDAW080065. 

Lower Level of Detection (LLD)Confirm that the LLD for the WAGS has been determined. 

No changes since baseline inspection. 

Interviews with INL-CCP WAGS personnel during inspection. 

CCP-INL-WAGS-001, Revision 0, April 27, 2005, and Revision 1, April 2, 2008; CCP-INL-WAGS-08-002, Revision 0, April 10, 2008. 

Site-specific environmental backgrounds and container-specific interferences must be accounted for in LLD determinations. 

No changes since baseline inspection. 

Interviews with INL-CCP WAGS personnel during inspection. 

CCP-INL-WAGS-001, Revision 0, April 27, 2005, and Revision 1, April 2, 2008; CCP-INL-WAGS-08-002, Revision 0, April 10, 2008. 

Confirm that the WAGS is used to discriminate TRU/Non-TRU wastes and that it has the required sensitivity. 

No changes since baseline inspection. 

Interviews with INL-CCP WAGS personnel during inspection. 

CCP-INL-WAGS-001, Revision 0, April 27, 2005, and Revision 1, April 2, 2008; CCP-INL-WAGS-08-002, Revision 0, April 10, 2008. 
A.1-4 

NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGS 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Required Technical Elements Changes Since Baseline? Verification of Activity Objective Evidence 

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

based on a lack of technical feasibility. 

No changes since baseline inspection. 

INL-CCP states that it is not technically feasible to provide an LLD equivalent for 234U. 

CCP-INL-WAGS-001, Revision 0, April 27, 2005, and Revision 1, April 2, 2008; CCP-INL-WAGS-08-002, Revision 0, April 10, 2008. 

Total Measurement Uncertainty (TMU)Identify any changes in the TMU determination or documentation for the WAGS since the 

baseline approval. 

No changes to TMU since 

EPA baseline inspection. 

Interviews with INL-CCP WAGS personnel during inspection. 

CCP-INL-WAGS-002, Total Measurement Uncertainty for the WAGS System, not numbered, April 20, 2005. 

Evaluate the magnitude of the TMU values observed in the WAGS BDRs that were examined during this inspection. 

No changes to TMU since 

EPA baseline inspection. 

TMU values in BDRs are generally consistent with expectations based on CCP-INLWAGS-002. 

CCP-INL-WAGS-002, Total Measurement Uncertainty for the WAGS System, not numbered, April 20, 2005; BDRs INNDAW060008, INNDAW080049, and INNDAW080065. 

System Calibration Confirm the WAGS’s calibration of record. No changes since 

baseline inspection. 

The gamma energy and efficiency calibrations have been 

performed and documented 

appropriately. 

CCP-INL-WAGS-001, Revision 0, April 27, 2005 and Revision 1, April 2, 2008. 

Confirm the WAGS’s operational range with respect to matrix (density) and activity. 

Yes Initial density range was 

extended in 2008 to 2.10 g/cm3

with a specific limit on 59 keV 

241Am line for densities from 1.62 to 2.10 g/cm3, approved by EPA Docket No: A-98-49; IIA4-107, September 2008. 

CCP-INL-WAGS-08-002, WAGS Multi-Curve Efficiency Calibration Extension Addendum, Revisions 0 and 1. 

Identify the consensus standards that were used for the system calibration or the alternate calibration technique and CBFO approval, if applicable. 

No changes since baseline inspection. 

Consensus standards are ASTM C-1030, ASTM C-1133, ASTM C-1215 and E-181-98 (2003). 

CCP-INL-WAGS-001, Revision 0, April 27, 2005, and Revision 1, April 2, 2008. 
A.1-5 

NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGS 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Required Technical Elements Changes Since Baseline? Verification of Activity Objective Evidence 

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

No changes since baseline inspection; 

however, due to the nature of the standards, different configurations of the same standards may have been used. 

All radionuclide standards and their pedigrees are documented. 

CCP-INL-WAGS-001, Revision 0, April 27, 2005, and Revision 1, April 2, 2008; CCP-INL-WAGS-08-002, WAGS Multi-Curve Efficiency Calibration Extension Addendum, Revisions 0 and 1. 

Calibration Verification and Confirmation Confirm that the WAGS’s calibration had been confirmed. 

Yes Initial calibration is valid, 

additional measurements were made to support the density range extension. 

CCP-INL-WAGS-001, Revision 0, April 27, 2005, and Revision 1, April 2, 2008; CCP-INL-WAGS-08-002, WAGS Multi-Curve Efficiency Calibration Extension Addendum, Revisions 0 and 1. 

Determine if the WAGS has been recalibrated since the calibration of record listed above. 

The WAGS had not been recalibrated since the 

baseline inspection. 

The initial calibration is valid. CCP-INL-WAGS-001, Revision 0, April 27, 2005, 

and Revision 1, April 2, 2008; CCP-INL-WAGS-08-002, WAGS Multi-Curve Efficiency Calibration Extension Addendum, Revisions 0 and 1. 

Determine the number of calibration verifications that have been performed since the 

baseline approval and that all were appropriately 

documented, if applicable. 

Yes Calibration verifications since 

baseline approval by year: 

2006 – 4; 2007 – none; 2008 – 2.

CCP-INL-WAGS-06-005, June 7, 2006; CCP-INLWAGS-08-004, April 1, 2008; CCP-INL-WAGS08-003, April 24, 2008. 

Confirm the pedigree of all radionuclide standards that were used for calibration confirmation and/or verifications. List or reference all standards used. 

No changes since the baseline inspection. 

The radionuclide content and 

pedigree of all standards have been listed. 

CCP-INL-WAGS-001, Revision 0, April 27, 2005, and Revision 1, April 2, 2008; CCP-INL-WAGS-08-002, WAGS Multi-Curve Efficiency Calibration Extension Addendum, Revisions 0 and 1. 

Requirements for accuracy and precision must be met, as specified in DOE/WIPP-02-3122, Appendix A, Table A-3.2 for calibration verifications. 

Yes Criteria for precision and 

accuracy were met for calibration verifications. 

CCP-INL-WAGS-06-005, June 7, 2006; CCP-INLWAGS-08-004, April 1, 2008; CCP-INL-WAGS08-003, April 24, 2008. 
A.1-6 

NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGS 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Required Technical Elements Changes Since Baseline? Verification of Activity Objective Evidence 

Quality Control All WAGS calibration, operation, and data validation activities must be performed by appropriately trained and qualified personnel. 

No changes since EPA baseline inspection. 

All levels of INL-CCP WAGS 

personnel were interviewed. 

CCP-INL LOQI. 

Identify the name, title, and function of all 

personnel performing NDA data validation. 

No changes since EPA baseline inspection. 

All INL-CCP WAGS personnel were identified and appropriately qualified. 

CCP-INL LOQI. 

Confirm the WAGS’s status with respect to the CBFO NDA PDP. 

Yes Successful participation in NDA 

Cycle 14 A in May 2007 for combustibles, metals and sludge; Cycle 15A in June 2008. 

CBFO PDP Approval Letter. 

Background and Performance Checks Confirm that WAGS background measurements have been taken daily. 

No changes since EPA baseline inspection. 

All records evaluated indicate compliant background 

performance. 

WAGS Operational Logbook; WAGS BDRs INNDAW060008, INNDAW080049, and INNDAW080065. 

Assess how often background radiation was 

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

No changes since EPA baseline inspection. 

No instances of problematic backgrounds were observed. 

WAGS BDRs INNDAW060008, INNDAW080049, and INNDAW080065. 

Identify the criteria used to evaluate instrument 

backgrounds and assess the technical adequacy 

of this criterion, i.e., statistical or administrative. 

No changes since EPA baseline inspection. 

Criteria for instrument 

background are provided in the 

WAGS calibration report. 

CCP-INL-WAGS-001, Revision 0, April 27, 2005, and Revision 1, April 2, 2008; CCP-TP-019, Revision 4, Section 4.4; WAGS BDRs INNDAW060008, INNDAW080049, and INNDAW080065. 

Confirm that system performance checks have 

been performed at least once per operational day. 

Confirm that performance checks include efficiency, matrix correction checks, and gamma 

peak position and resolution checks. 

No changes since EPA baseline inspection. 

The WAGS daily performance assays include checks for energy/channel, FWHM, Pu mass, and efficiency (Weekly Interfering Matrix Checks). 

CCP-TP-019, Revision 4, Sections 4.5 and 4.6; WAGS BDRs INNDAW060008, INNDAW080049, and INNDAW080065; Weekly Interfering Matrix Results for three 6-month periods. 
A.1-7 

NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGS 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Required Technical Elements Changes Since Baseline? Verification of Activity Objective Evidence 

Compare the current control limits for all 

performance checks with the limits that were 

established initially. Identify how many data 

points are used for the initial evaluation and at 

what interval(s) new limits are calculated. 

No changes since EPA baseline inspection. 

Initial limits were derived based 

on Student T Test using 6 points. INL-CCP WAGS personnel recalculated when they obtained 100 points, which took approximately 4 months, August 20–December 5, 2007. 

WAGS BDRs INNDAW060008, INNDAW080049, and INNDAW080065; AMWTP Work Order No. 167576, for purpose of updating WAGS QA 

parameters. 

Confirm that all radioactive sources used for 

performance checks have been decay corrected 

as a function of their physical half-life. 

No changes since EPA baseline inspection. 

In NDA 2000, the Source Certificate file is created and updated automatically to 

produce current values for 133Ba, 

152Eu, and 241Am. 

CCP-INL-WAGS-001, Revision 0, April 27, 2005, and Revision 1, April 2, 2008; CCP-INL-WAGS-08-002, WAGS Multi-Curve Efficiency Calibration Extension Addendum, Revisions 0 and 1. 

Data Management All WAGS data must be reviewed and approved 

by qualified personnel. Identify the name, title, 

and function of the individual(s) performing technical review and approval of WAGS BDRs. 

Yes All WAGS BDRs evaluated 

contained evidence of review by appropriately qualified 

personnel. 

INL-CCP LOQI; WAGS BDRs INNDAW060008, INNDAW080049, and INNDAW080065. 

WAGS BDRs must consist of the following elements: • Testing facility name, testing batch number, 

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

• Table of Contents 

• Background and performance check data or 

control charts for the relevant time period 

• Data validation per the QAPD and site 

procedures 

• Separate testing report sheets for each 

container. 

Yes All WAGS BDRs contained the 

required elements. 

WAGS BDRs INNDAW060008, INNDAW080049, and INNDAW080065. 
A.1-8 

NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGS 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Required Technical Elements Changes Since Baseline? Verification of Activity Objective Evidence 

WAGS RDSs must include: • Title “Radioassay Data Sheet” 

• Method/procedure used 

• Date of radioassay 

• Activities and associated TMU for individual 

radionuclides 

• TRU alpha concentration and its associated 

TMU 

• Operator and reviewer signatures 

Yes All WAGS RDSs contained the 

required elements. 

BDR INNDAW060008 – Container Nos. 10041591 and 10041595. BDR INNDAW080049 – Container No. ARP06138. BDR INNDAW080065 – Container Nos. ARP05, ARP06549, and ARP06631. 
A.2-9 

ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, SUPERHENC 

NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, SUPERHENC

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Required Technical Elements Change Since Baseline? Verification of Activity Objective Evidence 

System Description Confirm the name, location, and number of the INL-CCP SuperHENC. Ensure that this is the same unit approved during the EPA baseline inspection in 2005. 

No changes since EPA baseline inspection. 

EPA personnel verified that the SuperHENC assay unit is the same as observed during the baseline inspection. 

Visual inspection of SuperHENC in trailer at SWEPP at INL during inspection. 

Identify any hardware and/or software changes made to the SuperHENC since the baseline approval. Determine which changes, if any, are significant, where they are documented, and how they affect the SuperHENC’s baseline approval. 

Yes Two calibration verifications were performed: an 

H-3 tube was replaced and the Add-a-Source motor was replaced, and both were documented in calibration verifications. CCP-TP-146 was revised;Revision 4 replaced by Revision 5. 

CCP-SHENC-07-001, INL SuperHENC Calibration Verification, Revision 0, January 10, 2007. 

List all applicable calibration, operational and data reduction/validation 

procedures, and the current revisions that 

are in use for the SuperHENC. 

Yes All procedures observed in the SuperHENC trailer 

were the current revisions. 

CCP-TP-170, Revision 2; CCP-TP-146, Revision 5; CCP-TP-148, Revision 4. 

System Performance Identify the following: • Type (size) of waste containers 

assayed by SuperHENC 

• Number of waste containers this 

system assayed during the period of 

performance 

• Number of BDRs assembled 

• Number of BDRs that have been 

promoted through Project Level 

Review 

Yes SWBs containing four 55-gallon drums of S3000

sludge – no assays in FY 2007, 14 assays in FY 2008. 100-gallon overpacks with pucks of S5000 debris – 200 assays in FY 2007, 555 assays in FY 2008. SWBs with two 100-gallon drums, each containing 

pucks of S5000 debris – no assays in FY 2007 or 

2008. Assays of S4000 waste in any configuration – no assays in FY 2007 or 2008. 

Interviews with INL-CCP SuperHENC 

personnel; CCP VPM SWB/100 GALLON 

CONTAINER listing, 19 pages, dated September 16, 2008, 11:47 AM, generated at the request of EPA. 
A.2-10 

NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, SUPERHENC

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Required Technical Elements Change Since Baseline? Verification of Activity Objective Evidence 

General Reporting Requirements Confirm that the SuperHENC provides quantitative values and uncertainties for 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 233U, 234U, 238U, 90Sr, and 137Cs. Identify other 

radionuclides that are encountered during routine assays. 

No change since baseline 

inspection. 

The INL-CCP SuperHENC continues acceptable operation. 

BII-5221-CVR-001, Calibration and Validation Report SuperHENC Mobile Assay System, Revision 0, November 2006; SuperHENC BDRs INNDAB08001 through INNDAB08005. 

Each container characterized by the SuperHENC that is intended for disposal at WIPP must contain TRU waste. 

No change since baseline 

inspection. 

The INL-CCP SuperHENC continues acceptable operation. 

BII-5221-CVR-001, Calibration and Validation Report SuperHENC Mobile Assay System, Revision 0, November 2006; SuperHENC BDRs INNDAB08001 through INNDAB08005. 

SuperHENC procedures are appropriate for the waste streams being assayed and the results provide unbiased values for the cumulative activity of the WIPP radionuclide inventory. 

No change since baseline 

inspection. 

The INL-CCP SuperHENC continues acceptable operation. 

BII-5221-CVR-001, Calibration and Validation Report SuperHENC Mobile Assay System, Revision 0, November 2006; SuperHENC BDRs INNDAB08001 through INNDAB08005. 

Confirm the radionuclides that are derived by the application of scaling factors and/or correlation techniques and the technical adequacy of these techniques. 

No change since baseline 

inspection. 

The INL-CCP SuperHENC continues acceptable operation. 

BII-5221-CVR-001, Calibration and Validation Report SuperHENC Mobile Assay System, Revision 0, November 2006; SuperHENC BDRs INNDAB08001 through INNDAB08005. 

Acceptable Knowledge (AK) Confirm when NDA personnel use AKderived isotopic values and identify the formal procedure controlling this function. 

No change since baseline 

inspection. 

Specific criteria have been established for the application of AL-based isotopics and they are implemented by the EA for all (100%) SuperHENC assays. 

BII-5221-CVR-001, Appendix V, page 71 (iii); function of the 240PuEFF Fitness Factor 

(FF): • FF < 0.17 – AK-based isotopics • FF > 0.4 – FRAM isotopics 

• FF 0.4 > FF >0.17 – Isotopics 

determined by EA 
A.2-11 

NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, SUPERHENC

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Required Technical Elements Change Since Baseline? Verification of Activity Objective Evidence 

Evaluate the AK used for the wastes and/or waste streams assayed by the SuperHENC and ensure that all radionuclides encountered fit under the SuperHENC’s approved AK. 

No change since baseline 

inspection 

Two different AK isotopics: RPT-TRUW-07 (BN 510) for AMWTP wastes; CCP-AK-INL-005 NDA Memo for INL-CCP wastes. 

CCP-TP-148, Revision 4; SuperHENC BDRs INNDAB08001 through INNDAB08005. 

Isotopic Determination Identify the radionuclides that are measured directly and their specific radiation type of each (gamma or passive neutron). 

No change since baseline 

inspection. 

All radionuclides are identified by the gamma and/or neutron emission of each. 

BII-5221-CVR-001, Calibration and Validation Report SuperHENC Mobile Assay System, Revision 0, November 2006. 

Lower Level of Detection (LLD) Confirm that the LLD for the SuperHENC has been determined for 

passive neutron and gamma modes. 

No change since baseline 

inspection. 

Interviews with INL-CCP SuperHENC personnel during inspection. 

BII-5221-CVR-001, Calibration and Validation Report SuperHENC Mobile Assay System, Revision 0, November 2006. 

Site-specific environmental backgrounds and container-specific interferences must 

be accounted for in LLD determinations. 

No change since baseline 

inspection. 

Interviews with INL-CCP SuperHENC personnel during inspection. 

BII-5221-CVR-001, Calibration and Validation Report SuperHENC Mobile Assay System, Revision 0, November 2006; SuperHENC BDRs INNDAB08001 through INNDAB08005. 

Confirm if the SuperHENC is used to discriminate TRU/Non-TRU wastes at the 100 nCi/g criterion and that it has the required sensitivity. 

No change since baseline 

inspection. 

There were approximately twelve 100-gal drums where the assay values were <100 nCi/gram. 

Interviews with INL-CCP SuperHENC 

personnel during inspection. 

Identify any/all instances where an LLD equivalent is derived. Identify if an LLD value for a non-measured radionuclide is 

not provided, based on a lack of technical feasibility. 

No changes to LLD since 

EPA baseline inspection. 

LLD equivalents for 241Am, 238Pu, 239Pu, 240Pu, 241Pu, 

and 242Pu are determined by rationing them to the 

LLD for the 240PuEff based on their mass fractions. 

LLD equivalent for 234U derived by scaling to 235U 

and 238U, and 90Sr to 137Cs. 

BII-5221-CVR-001, Calibration and Validation Report SuperHENC Mobile Assay System, Revision 0, November 2006. 
A.2-12 

NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, SUPERHENC

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Required Technical Elements Change Since Baseline? Verification of Activity Objective Evidence 

Total Measurement Uncertainty (TMU)Identify any changes in the TMU determination or documentation for the SuperHENC since the baseline approval. 

No changes to TMU since 

EPA baseline inspection. 

Interviews with INL-CCP SuperHENC personnel during inspection. 

BII-5221-CVR-001, Calibration and Validation Report SuperHENC Mobile Assay System, Revision 0, November 2006, Section 4.11 

Evaluate the magnitude of the TMU values observed in the SuperHENC BDRs that were examined during this inspection. 

 TMU values in BDRs are generally consistent with 

expectations based on CVR. 

SuperHENC BDRs INNDAB08001 through INNDAB08005. 

System Calibration Confirm the SuperHENC’s calibration of record. 

No changes since EPA baseline inspection. 

The SuperHENC was calibrated at RFETS before its initial use at INL-CCP and the calibration of record has been documented. Calibrations include passive neutron for 240PuEff and gamma for relative ratio 

mode (isotopics) operation only. 

BII-5221-SRF-001, SuperHENC RFETS Calibration Documentation Package; BII5221-CVR-001, Calibration and Validation 

Report SuperHENC Mobile Assay System, 

Revision 0, November 2006. 

Confirm the SuperHENC’s operational range with respect to matrix (density) and activity. 

No changes since EPA baseline inspection. 

The range of applicability of the SuperHENC’s calibration has been specified and documented. 

BII-5221-CVR-00112, CCP-TP-146, and CCP-TP-170 state the range as 12.658 g 

240PuEff or 203.8 g Pu total. 

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

No changes to 

radionuclide standards since EPA baseline inspection. 

Interviews with INL-CCP SuperHENC personnel during inspection. 

BII-5221-CVR-001, Calibration and Validation Report SuperHENC Mobile Assay System, Revision 0, November 2006. 

Calibration Verification and Confirmation Confirm the SuperHENC’s gamma and 

passive neutron calibration 

confirmations. 

No changes since EPA baseline inspection. 

Both gamma and neutron calibrations had been appropriately confirmed and documented. 

BII-5221-CVR-001, Calibration and Validation Report SuperHENC Mobile Assay System, Revision 0, November 2006. 

Determine if the SuperHENC has been recalibrated since the calibration of record listed above. 

The SuperHENC has not 

been recalibrated since 

EPA baseline inspection. 

Not Applicable Not Applicable 
A.2-13 

NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, SUPERHENC

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Required Technical Elements Change Since Baseline? Verification of Activity Objective Evidence 

Determine the number of calibration verifications that have been performed since the baseline approval and that all were appropriately documented, if applicable. 

Yes Two calibration verifications were performed: an H3 tube was replaced and the Add-a-Source motor was 

replaced, and both were documented in calibration verifications. 

CCP-SHENC-07-001, INL SuperHENC Calibration Verification, Revision 0, January 10, 2007. 

Confirm the pedigree of all radionuclide standards that were used for calibration confirmation and/or verifications. List or reference all standards used. 

No changes since EPA baseline inspection. 

Interviews with INL-CCP SuperHENC personnel during inspection. 

BII-5221-CVR-001, Calibration and Validation Report SuperHENC Mobile Assay System, Revision 0, November 2006. 

Requirements for accuracy and precision must be met, as specified in DOE/WIPP02-3122, Appendix A, Table A-3.2 for calibration verifications. 

Yes Accuracy and precision criteria were met for both 

calibration verifications. 

CCP-SHENC-07-001, INL SuperHENC Calibration Verification, Revision 0, January 10, 2007. 

Quality Control All SuperHENC calibration, operation, and data validation activities must be 

performed by appropriately trained and 

qualified personnel. 

No changes since EPA baseline inspection. 

All levels of INL-CCP SuperHENC personnel were interviewed. 

INL-CCP LOQI. 

Identify the name, title, and function of all personnel performing NDA data validation. 

Yes All levels of INL-CCP SuperHENC personnel were 

interviewed. 

INL-CCP LOQI. 

Confirm the SuperHENC’s status with respect to the CBFO NDA PDP. 

Yes Successful participation in Cycle B7A, November

2007. Cycle B8A will be reported by November 18, 2008. 

CBFO PDP Scoring Letter. 

Background and Performance Checks Confirm that SuperHENC background measurements have been taken daily. 

No changes since EPA baseline inspection. 

All records evaluated indicate compliant background

performance. 

SuperHENC operational logbook; SuperHENC BDRs INNDAB08001 through INNDAB08005. 

Assess how often background radiation was problematic to the extent that measurement personnel had to make adjustments. 

No changes since EPA baseline inspection. 

No instances of problematic backgrounds were 

observed. 

Interviews with INL-CCP SuperHENC 

personnel. 
A.2-14 

NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, SUPERHENC

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Required Technical Elements Change Since Baseline? Verification of Activity Objective Evidence 

Identify the criteria used to evaluate instrument backgrounds and assess the technical adequacy of this criterion. 

No changes since EPA baseline inspection. 

Gamma limit is 125.98170 cps; neutron limit is 3 times the mean of the calibration baseline. 

BII-5221-CVR-001, Section 4.7, and Appendix II, pages 9 and 54; CCP-TP-146, Revision 5. 

Compare the current background control limit with the limit established initially. 

No changes since EPA baseline inspection. 

Initial control limits are still in effect. BII-5221-CVR-001, Section 4.7, and 

Appendix II, page 54; CCP-TP-146, Revision 5. 

Confirm that system performance checks have been performed at least once per operational day. Confirm that 

performance checks include gamma and 

neutron efficiency, matrix correction checks, and gamma peak position and resolution checks. 

No changes since EPA baseline inspection 

Daily checks include gamma background, calibration and FWHM; neutron checks include singles rate, empty SWB, and 240PuEFF mass. 

BII-5221-CVR-001, Section 4.7 and Appendix II; SHENC operational logbook; SuperHENC BDRs INNDAB08001 through INNDAB08005. 

Compare the current control limits for all 

performance checks with the limits that 

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

No changes since EPA baseline inspection 

Nine data points were used for the initial evaluation; 

limits are evaluated after accumulating approximately 30 data points. 

BII-5221-CVR-001, Calibration and Validation Report SuperHENC Mobile Assay System, Revision 0, November 2006. 

Confirm that all radioactive sources used for performance checks have been decay corrected as a function of their physical half-life. 

No changes since EPA baseline inspection 

Interviews with INL-CCP SuperHENC personnel during inspection. 

BII-5221-CVR-001, Section 4.7 and Appendix II, pages 9 and 54; CCP-TP-146, Revision 5. 

Data Management All SuperHENC data must be reviewed and approved by qualified personnel. Identify the name, title, and function of the individual(s) performing technical review and approval of SuperHENC BDRs. 

Yes All SuperHENC BDRs evaluated contained evidence

of review by appropriately qualified personnel. 

CCP-INL LOQI; SuperHENC BDRs INNDAB08001 through INNDAB08005. 
A.2-15 

NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, SUPERHENC

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Required Technical Elements Change Since Baseline? Verification of Activity Objective Evidence 

SuperHENC BDRs must consist of the following elements: • Testing facility name, testing batch 

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

• Table of Contents 

• Background and performance check 

data or control charts for the relevant time period 

• Data validation per the QAPD and 

site procedures 

• Separate testing report sheets for each 

container 

Yes All SuperHENC BDRs contained the required 

elements. 

SuperHENC BDRs INNDAB08001 through INNDAB08005. 

SuperHENC RDSs must include: • Title “Radioassay Data Sheet” 

• Method/procedure used 

• Date of radioassay 

• Activities and associated TMU for 

individual radionuclides 

• TRU alpha concentration and its 

associated TMU 

• Operator and reviewer signatures 

Yes All SuperHENC RDSs contained the required 

elements. 

BDR INNDAB080001 – SWB No. BN10211039. BDR INNDAB080002 – SWB Nos. BN10211037, BN10211038, and BN10215259. BDR INNDAB080003 – SWB Nos. BN10211045, and BN10215278. BDR INNDAB080004 – SWB Nos. BN10211043, BN10211044, BN10215293, and BN10215294. BDR INNDAB080005 – SWB Nos. BN10211040, BN10211041, BN10211042, and BN10215279. 
A.3-1 

ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Establishment of Required 

Technical Elements in 

Procedures 

Location Execution of Procedures Objective Evidence/Comments 

RTR-1: Site procedures identify required training and qualifications for RTR 

personnel. 

CCP-TP-028, Rev. 3 CCP-QP-002, Rev. 26 

Operator training was consistent with applicable procedures. Operator certification is current. OJT was documented for each operator. Operators are re-qualified every two years. RTR operators passed a training drum test that includes items common to the waste streams examined at the site (biannually). RTR operators receive training on the waste matrix parameters and typical 

packaging configurations expected in each 

waste stream. 

At the time of the baseline inspection, RTR Unit No.2 was used 

by CCP for radiographic examinations. EPA was informed by 

CBFO in the Tiering Change Report dated March 3, 2006, that CCP had added RTR Unit No. 5 at INL and procedure CCP-TP102 was revised accordingly. This unit had previously been in operation at the NTS. CBFO reported in a subsequent T2 change report that procedure CCP-TP-102 had been cancelled and procedure CCP-TP-053 would be used for performing RTR examinations. RTR Unit No. 5 is located in Building 610. Operators at INL received training for RTR Unit No.5, titled Training for Idaho National Laboratory Real-time Radiography – System 5, on September 14, 2005, and the first examinations

took place on September 21, 2005. Since that date, operators have been re-qualified every 2 years, as required. Test container INL-NDE-TEST-34 was used for operator demonstration of capability examinations, and it contains both S3000 and S5000 waste. EPA reviewed the written record and 

audio/visual recordings, dated April 24, 2008, for demonstration 

of capability examinations of two operators. EPA determined that the examinations were complete and there were no discrepancies between the written and audio/visual records. Objective evidence:

1 Nondestructive Examination Real-time Radiography 

Operator/ITR Qualification Cards for two operators 

2 Current List of Qualified Individuals (LOQI) for RTR 

3 Demonstration of Capability DVD and hard copy data forms 

for two operators 

4 CCP-AK-INL-005, Revision 2 
A.3-2 

REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Establishment of Required 

Technical Elements in 

Procedures 

Location Execution of Procedures Objective Evidence/Comments 

RTR-2: Site procedure(s) 

provide complete instructions 

for operators to perform the RTR examination and completion of the associated documentation. 

CCP-TP-053, Rev. 6, Sect. 4.0 

RTR operator adequately explained the 

process followed for examining a 

container and entering data into data forms (whether hard copy or electronic data entry is used). 

Procedure CCP-TP-053 is used for performance of RTRexaminations. Table 3 of the procedure is a Waste Item Weights table, providing weights for frequently encountered items. EPA observed the RTR examination of container Nos. 10233789 (S3114) and 10163250 (S5300) during the on-site inspection. A second RTR operator completed electronic data forms as waste 

items were identified by the operator performing the 

examination. At the end of the demonstration, both operators reviewed the WMPs for accuracy and completeness and assigned weights to each. The procedure was determined to be complete and adequately implemented. Procedure CCP-TP-119 is used for powering up, loading, and 

unloading containers Objective evidence:

1 BDRs S5300 and S3114, INRTR5080061 (June 4, 2008), 

INRTR5080078 (July 23, 2008), and INRTR5080081 (September 10, 2008). 

RTR-3: The RTR procedure(s) require an image quality check to be performed. 

CCP-TP-053, Rev. 6, Sect. 4.3.4, Attachment 1 

Operator adequately explained how the acceptability of an image is determined Image quality test (IQT) check is 

performed once per day 

LDA acceptability test performed at 

beginning of each shift 

Performance of the image quality check is documented and recorded 

The EPA observed two RTR events during the on-site visit, but the IQT had already been performed for that day. However, EPA was able to review the DVD recording of this test and 

determined it was performed and recorded in accordance with 

procedure requirements. This process was observed for 

container Nos. 10233789 (S3114) and 10163250 (S5300). INL-CCP does not have an LDA. Objective evidence:

1 BDRs S5300 and S3114, INRTR5080061 (June 4, 2008), 

INRTR5080078 (July 23, 2008), and INRTR5080081 (September 10, 2008). 

2 DVD recording of IQT performed on September 16, 2008 
A.3-3 

REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Establishment of Required 

Technical Elements in 

Procedures 

Location Execution of Procedures Objective Evidence/Comments 

RTR-4: The procedure allows the operator to adjust the RTR to accommodate the physical 

properties of the waste and 

waste containers likely to be encountered at the site. 

CCP-TP-053, Rev. 6, Sect. 4.4.2 

Operator could identify applicable policies and procedures governing the operation of RTR equipment. The RTR system could be adjusted. High-density material was examined with the X-ray device set on the maximum voltage and low-density material at a lower voltage. Operator adequately explained what is done if an image is unacceptable (e.g., the waste is solidified or the container is leadlined). 

Through interview of RTR operators, EPA determined that they were properly trained and performed RTR examinations in accordance with procedure CCP-TP-053. During the examinations observed by EPA, the operator scanned the 

container from side to side and from top to bottom, identifying 

waste items as they were encountered. The voltage settings were adjusted, so that items of varying density could be identified. The operator was able to explain what process is followed if a 

prohibited item was found in a container. 

Objective evidence:

1 BDRs S5300 and S3114, INRTR5080061 (June 4, 2008), 

INRTR5080078 (July 23, 2008), and INRTR5080081 (September 10, 2008). 

RTR-5: CCP-TP-053, Rev. 6, 

Sect. 4.3.4, Attachment 1 

RTR tape is high quality, the sound track is audible, and the required information is contained on the audible portion of the tape. The RTR tape is consistent with the data 

package for the same container. 

The audio/visual recordings made are on DVD rather than VHS 

tapes. EPA compared the written record (BDR) and the audio/visual recordings of four containers to ensure 

completeness, clarity, and consistency. No differences between the two records were found, and EPA determined that the examinations and records generated were complete and correct. 

Objective evidence:

1 BDRs S5300 and S3114, INRTR5080061 (June 4, 2008), 

INRTR5080078 (July 23, 2008), and INRTR5080081 (September 10, 2008). 

2 DVD recordings of VE events for container Nos. 10220098, 

10230860, 10233749, and 10219863 

RTR-6: There is a procedure for determining whether the waste matches the waste stream description and Waste Matrix Code, and for determining 

CCP-TP-053, Rev. 6, Sect. 4.4.3, Attachment 2 

The procedure is adequately implemented. Operators verify that the waste matches the waste stream description. The WMC is verified. If not, corrective 

During the demonstration, the operator had a copy of procedure CCP-TP-053 open at the work station and used it to guide the RTR examination. At the conclusion of the examination, the 

operators assigned WMP weights for the items identified in the 

container. Procedure CCP-TP-053 does contain a table of 
A.3-4 

REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Establishment of Required 

Technical Elements in 

Procedures 

Location Execution of Procedures Objective Evidence/Comments 

Waste Material Parameters and weights. 

action is taken. WMP weights are estimated by compiling an inventory of waste items and residual/packaging materials. Does the RTR operator use a standard weight lookup table to provide an estimate of WMP weights? If so, has the table 

been updated to reflect additional 

information gained through previous RTR/VE exams or updated AK information? 

standard weights for items, but this is rarely used by the operators to assign WMP weights. The operator verified that the waste items found in the container 

matched WMC and physical description of waste stream. The operator used the waste stream descriptions located in CCP-AKINL-005 to make these determinations. Objective evidence:

1 BDRs S5300 and S3114, INRTR5080061 (June 4, 2008), 

INRTR5080078 (July 23, 2008), and INRTR5080081 (September 10, 2008). 

2 CCP-AK-INL-005 

RTR-7: The RTR procedure 

provides instructions for 

identifying prohibited items and for processing containers containing prohibited items. 

CCP-TP-053, Rev. 6, Sect. 4.3.4, 

Note, Table 1 

Operator could name prohibited items. Operator adequately explained how the 

presence of free liquids is determined. 

Operator’s explanation of required actions if prohibited items were encountered was consistent with procedure. Corrective actions are taken when necessary. 

Procedure CCP-TP-053 includes a list of prohibited items (Table 1). NCR-INL-0642-08 was written because a prohibited item was found in container No.10217951. The NCR was processed as required. Objective evidence:

1 BDRs S5300 and S3114, INRTR5080061 (June 4, 2008), 

INRTR5080078 (July 23, 2008), and INRTR5080081 (September 10, 2008). 

2 NCRs NCR-INL-0652-07, NCR-INL-0637-08, NC-INL0655-08, NCR-INL-0643-08, and NCR-INL-0642-08 

RTR-8: RTR procedures include the required QC examinations, evaluation accuracy, and reproducibility of the RTR 

process. 

CCP-TP-053, Rev. 6, Sects. 4.5 and 4.6 

An independent replicate scan is 

performed on one waste container per day 

or on one container per testing batch (whichever is less frequent). A qualified RTR Operator performs an independent observation of one scan other than the replicate. An independent RTR Operator is any qualified RTR operator 

The required quality control examinations were performed as required. In BDR INRTR5080061, the replicate scan was performed on container No. 10218573 and a second RTR operator performed an independent observation on container No. 10215819. In BDR INRTR5080078, the replicate scan was performed on container No. 10223052 and a second RTR operator performed 
A.3-5 

REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Establishment of Required 

Technical Elements in 

Procedures 

Location Execution of Procedures Objective Evidence/Comments 

except the one who performed the initial RTR. 

an independent observation on container No. 10219826. In BDR INRTR5080081, the replicate scan was performed on container 10232567 and a second RTR operator performed an independent observation on container No. 10233749. Objective evidence:

1 BDRs S5300 and S3114, INRTR5080061 (June 4, 2008), 

INRTR5080078 (July 23, 2008), and INRTR5080081 (September 10, 2008). 

2 CCP LOQI 

RTR-9: Procedure(s) contain standardized forms for recording RTR data. 

CCP-TP-053, Rev. 6, Sect 4.3.4, Attachment 2 

RTR operator adequately explained the 

process followed for examining a 

container and entering data into data forms (whether hard copy or electronic data entry is used). The RTR operator performs direct data entry into an electronic form using a computer while he/she is still in the RTR 

booth. 

The electronic data file undergoes the same QC checks used for hand-written data entries. 

EPA reviewed the written (BDR) records for container Nos. 10220098 (S3114), 10230860 (S5300), 10233749 (S3114), and 10219863 (S5300). During the demonstration RTR examination, the operator called out the waste items identified as the container was scanned and a second operator entered these data into the 

electronic forms (CCP Radiography Data Sheet, Attachment 2, 

CCP-TP-053). The data sheet for each container is included in the BDR. BDRs are subject to both data generation level by Independent Technical Review (ITR) and project level review by 

the Site Project Manager (SPM). Objective evidence:

1 BDRs S5300 and S3114, INRTR5080061 (June 4, 2008), 

INRTR5080078 (July 23, 2008), and INRTR5080081 (September 10, 2008). 

RTR-10: Site procedures require review of BDRs at the data generation and project level. 

CCP-TP-053, Rev. 6, Sect. 4.10 (ITR) 

Data generation level reviews are 

performed and documented by the ITR. 

Project level reviews are performed and documented by the SPM. 

BDRs INRTR5080061 and INRTR5080078 had completed ITR 

and SPM checklists attached. BDR INRTR5080081 did not 

have an SPM checklist, because the BDR was only generated September 10, 2008, and had not been through the SPM review. 

All checklists were completed and signed as required. 
A.3-6 

REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH Inspection Inspection Date: September, 16–18, 2008

Establishment of Required 

Technical Elements in 

Procedures 

Location Execution of Procedures Objective Evidence/Comments 

Objective evidence:1 BDRs S5300 and S3114, INRTR5080061 (June 4, 2008), 

INRTR5080078 (July 23, 2008), and INRTR5080081 (September 10, 2008). 
A.3-7 

Information included in BDR 

Required Testing Batch Content Present Y or N Required Testing Batch Content Present Y or N Required Testing Batch Content Present Y or N 

Batch date Y Verification that waste matches waste stream description Y Container gross weight Y Report date Y Estimated weights for WMPs Y Reference to or copies of any NCRs Y Waste container number Y Layers of confinement Y Operator signature and test date Y Waste matrix code Y Indication of vented rigid liners Y Data generation checklist Y Videotape reference Y Description of container contents Y Project level checklist Y Description of liners Y Indication of sealed containers >4L Y QC documentation Y Amount of free liquid Y 
A.4-1 

ATTACHMENT A.4: VISUAL EXAMINATION TECHNIQUE (VET) CHECKLIST 

VISUAL EXAMINATION TECHNIQUE (VET) CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH VET Inspection Date: September 16–18, 2008

Establishment of Required 

Technical Elements in 

Procedures 

Location Execution of Procedures Objective Evidence/Comment 

VE-1: Site procedures identify 

required training and qualifications for VE personnel. 

CCP-QP-002, Rev. 26 

Visual Examination Expert (VEE) has been appointed. VE personnel’s training was consistent with applicable procedures. VE personnel’s certification is current. VE personnel are re-qualified every 2 years. VE personnel received training on specific waste generating processes, typical packaging configurations, and the WMPs that are expected to be found in each WMC 

VE is performed for newly-generated or repackaged waste from the 

ARPs. VE for ARP1 is performed in Building WMF 697 and VE for 

ARP2 is performed in Building WMF 1612. Two trained operators perform the VE, and a VEE is present to 

provide assistance, if needed. The EPA reviewed training records for 1 Operator/ITR/TS/FQAO (VEE) and 11 Operators/ITRs. All VE 

personnel received specific training for the waste examined through a 

training module titled, Specific Training for Idaho National 

Laboratory – Newly-generated TRU Waste Retrieved from the Pits. 

Objective evidence:1 Training records and Qualification Cards for 1 VEE and 11 

Operators/ITRs 

2 CCP LOQI 

VE-2: Procedures and technical 

guidance documents provide complete instructions for 

performing VE. 

CCP-TP-006, Rev. 12, Sect. 4.0 

Audio/visual recording of VE event includes date, container ID number, waste items, WMPs, and operators (if applicable). Two trained operators perform VE and data collection/recording. Procedures are sufficiently detailed to enable the operator to determine if a waste container meets the criteria of 40 CFR 194.24 with regard to identifying applicable parameters with waste limits. 

Two trained and qualified operators perform VE, but an audio/visual recording is not made. Both operators are required to sign the data 

sheets recording the waste items identified during the VE event. There are 11 Drum Packaging Stations (DPSs) available for VE of waste from ARP1 and APR2. At the time of the inspection, one DPS 

was not in use. The DPSs are gloveboxes and are operated by CWI 

personnel, but all VE operators and VEEs are CCP personnel. 

The EPA inspectors observed VE of waste in the DPS during the on-site visit. Because of radiological concerns, the EPA was only 

able to observe from the radiation barrier. However, EPA was able to see operators sorting waste and the VE data being recorded. The EPA reviewed three BDRs, which included VE for S3000, S4000, and S5000 waste. The data sheets for the containers contained in each BDR were properly completed and had been 
A.4-2 

VISUAL EXAMINATION TECHNIQUE (VET) CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH VET Inspection Date: September 16–18, 2008

Establishment of Required 

Technical Elements in 

Procedures 

Location Execution of Procedures Objective Evidence/Comment 

subjected to generation and project level reviews. Objective evidence:

1 BDRs S3900, S4200, and S5400: IN-ARP-VE-000929 (May 29, 

2008), IN-ARP-VE-000964 (June 17, 2008), and IN-ARP-VE000868 (April 24, 2008) 

2 Training records for VEO/ITR/TS/FQAO, VEE, and VEO/ITR 3 CCP LOQI 

VE-3: CCP-TP-006, 

Rev. 12, Sects. 4.1.5 and 4.2, and Attachment 1, Table 4 

If an automated data entry system is used, data entry VE personnel could navigate through the various screens. A calibrated scale is used to weigh WMPs. VE personnel have access to standardized charts or tables to aid in the consistent estimation or assignment of weights, waste material parameters, and waste matrix codes. 

The VE data generated are entered on the appropriate form (Attachment 1, CCP-TP-006) and operators and the VEE must sign the data sheets. WMP weights are determined by weighing either the organic or inorganic part of waste, and the other part is determined by 

difference between the full and empty container weights. Procedure 

CCP-TP-006 provides historical weights for commonly encountered items in Table 4. A calibration check is performed on scale Nos. 724386 and 722311, and each DPS scale at the start of each day. EPA inspected the scale check records and confirmed that the scales used were within tolerance and their calibration dates. EPA also verified that the 

torque wrench used to close containers at the end of the VE event 

was still within its calibration period. Either the excavator operator or VE personnel identify any prohibited items encountered during VE. Objective evidence:

1 BDRs S3900, S4200, and S5400: IN-ARP-VE-000929 (May 29, 

2008), IN-ARP-VE-000964 (June 17, 2008), and IN-ARP-VE000868 (April 24, 2008) 
A.4-3 

VISUAL EXAMINATION TECHNIQUE (VET) CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH VET Inspection Date: September 16–18, 2008

Establishment of Required 

Technical Elements in 

Procedures 

Location Execution of Procedures Objective Evidence/Comment 

VE-4: There is a procedure for 

handling instances when the VE Expert is unable to see through the inner plastic bags/packages/ containers of waste. 

CCP-TP-006, Rev. 12, Sects. 3.1 and 4.3.14, Table 4 

The VEE has decision-making criteria for assessing the need to open the bags/packages in order to identify all of their contents. If the bags are not opened, a brief written description of the contents of the bags is 

prepared, with estimates of the amount of 

each waste type in the bags. Reference tables are updated as site gains information from VE. 

The waste, being subject to VE at the time of the inspection, was 

uncontainerized when it was retrieved from the ARP. The VEE was 

present in the DPS area and was available for questions or resolving 

problems with the VE operators. 

Objective evidence:

1 BDRs S3900, S4200, and S5400: IN-ARP-VE-000929 (May 29, 

2008), IN-ARP-VE-000964 (June 17, 2008), and IN-ARP-VE000868 (April 24, 2008) 

VE-5: The VE procedure 

requires verification of WMC and WMP weights. Procedure provides instructions for processing of containers with 

prohibited items. 

CCP-TP-006, Rev. 12, Sect. 4.3.14, Attachment 1 

WMPs are identified, weighed and recorded on a data sheet; all discernible waste items, residual materials, and packaging are recorded. A VE data form is used to document verification of the physical form of the waste and the WMC. 

WMP weights are determined by weighing either the organic or 

inorganic part of waste and the other part is determined by the 

differences between the full and empty container weights. Procedure 

CCP-TP-006 provides historical weights for commonly encountered items in Table 4. The data forms completed during VE events requires the operators to verify the physical form of the waste and WMC. The EPA reviewed data packages to verify data entry, WMP weight 

assignments, and verification of the physical form of the waste and 

WMC. The BDRs reviewed contained containers containing S3000, S4000, and S5000 waste. All data forms reviewed were correct, complete, and had been subject to data generation and project level reviews. Objective evidence:

1 BDRs S3900, S4200, and S5400: IN-ARP-VE-000929 (May 29, 

2008), IN-ARP-VE-000964 (June 17, 2008), and IN-ARP-VE000868 (April 24, 2008) 
A.4-4 

VISUAL EXAMINATION TECHNIQUE (VET) CHECKLIST 

EPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCP Continuing Compliance CH VET Inspection Date: September 16–18, 2008

Establishment of Required 

Technical Elements in 

Procedures 

Location Execution of Procedures Objective Evidence/Comment 

VE-6: CCP-TP-006, 

Rev. 12, Sect. 4.8.3, Attachment 1, Table 1 

Absence/presence of prohibited items. Operators explained required actions if 

prohibited items were encountered. 

Corrective action is taken when necessary. 

Prohibited items are removed by the excavator operator prior to waste being delivered to the DPS or by the VE operators. All 

prohibited items remain in the ARP awaiting site disposition. 

There were no NCRs for the containers in the BDRs reviewed by 

EPA. Objective evidence:

1 BDRs S3900, S4200, and S5400: IN-ARP-VE-000929 (May 29, 

2008), IN-ARP-VE-000964 (June 17, 2008), and IN-ARP-VE000868 (April 24, 2008) 

2 NCR-INL-0652-07 and NCR-INL00637-08 

VE-7: CCP-TP-006, 

Rev. 12, Attachments 1 and 5 

The gross weight of the waste container (container plus contents) is recorded on the VE data form. Volume utilization of the container is documented. 

Containers are weighed outside of the DPS area on a calibrated scale. Gross and net weights for each container are recorded on Attachment 1, as well as the percent utilization of the container. 

Objective evidence:

1 BDRs S3900, S4200, and S5400: IN-ARP-VE-000929 (May 29, 

2008), IN-ARP-VE-000964 (June 17, 2008), and IN-ARP-VE000868 (April 24, 2008) 

VE-8: Site procedure(s) require data generation and project level reviews of BDRs. 

CCP-TP-006, Rev. 12, Attachment 2 

ITR review is performed and documented. Project level review is performed as required (SPM). 

All of the BDRs reviewed had been reviewed at the data generation 

level (ITR) and IN-ARP-VE-000868 had both project level (SPM) 

and ITR checklists present. All of the checklists were completed and 

signed as required. Objective evidence:

1 BDRs S3900, S4200, and S5400: IN-ARP-VE-000929 (May 29, 

2008), IN-ARP-VE-000964 (June 17, 2008), and IN-ARP-VE000868 (April 24, 2008) 
A.4-5 

Information Included in BDR

Required Testing Batch Content Present Y or N Required Testing Batch Content Present Y or N Required Testing Batch Content Present Y or N 

Batch date Y Description of liners Y Verification of waste matrix code Y Report date Y Layers of confinement Y Reference to or copies of any NCRs Y Waste container number Y Indication of vented rigid liners Y VEE decisions Y Waste matrix code Y Description of container contents Y Operator signature and test date Y Implementing procedure name or number Y Indication of sealed containers >4L Y VEE signature and test date Y Videotape reference Y Amount of free liquid Y Completed ITR checklist YQC documentation Y Container gross weight Y Completed SPM checklist Y Verification that waste matches waste stream description Y Waste material parameter weights Y 
A.5-1 

ATTACHMENT A.5: CONTAINER MANAGEMENT CHECKLIST 

CCP-TP-068, CONTAINER MANAGEMENT AT THE INL AND TWCP 

EPA Inspection No.: EPA-INL-CCP-09.08-24, CCP/INL Continuing Compliance Inspection Date: September 16–18, 2008

Establishment of Required 

Technical Elements in Procedures Location Execution of Procedures Objective Evidence/Comments 

CM-1: Personnel training and qualification. 

CCP-TP-068, Rev. 5, Sect. 2.2.1; CCP-QP-002, Rev. 26 

Are personnel performing this procedure trained and qualified in accordance with CCP-QP-002? 

Personnel who move containers for CCP are employees of CWI and are trained in their procedures. Characterization personnel who implement parts of procedure 

CCP-TP-068 are trained and qualified in accordance with CCP 

requirements. Objective evidence:

1 Training records and qualification cards for RTR personnel 

2 Training records and qualification cards for VE personnel 

CM-2: Retrievably-stored waste. CCP-TP-068, 

Rev. 5, Sects. 2.3.2–2.3.4 and 3.1, and Attachment 2 

Do containers subject to an NCR have a CCP Hold Tag attached? Are Hold-tagged containers physically segregated? Does each container processed have a completed Attachment 2, Container Inspection Report? Are only containers that are safe to handle (Attachment 4, Structural Inspection Report) 

processed through the characterization 

activities? 

CCP employs two types of tags: Blue tag indicates that there is something missing for the 

container. This is not an NCR tag, but it results in an electronic hold on the container. Red tags are NCR tags and these containers cannot be processed further until the NCR is resolved. As containers are delivered to CCP in Building WMF-610, they are checked for integrity (Attachment 2). This is performed while the containers are still on the transportation truck, and containers that fail this test are 

returned to the host site without being removed from the truck. 

Container numbers are checked with the AK Tracking sheet to 

ensure that only containers eligible for characterization are 

removed from the transportation truck. If any containers are not on the tracking sheet, they are returned to the host site. Objective evidence:

1 Red CCP NCR tags 

2 Blue CCP hold tags 

3 AK Tracking sheet for CCP/INL 
A.5-2 

CCP-TP-068, CONTAINER MANAGEMENT AT THE INL AND TWCP 

EPA Inspection No.: EPA-INL-CCP-09.08-24, CCP/INL Continuing Compliance Inspection Date: September 16–18, 2008

Establishment of Required 

Technical Elements in Procedures Location Execution of Procedures Objective Evidence/Comments 

CM-3 CCP-TP-068, 

Rev. 5, Sects. 2.3.6 and 2.3.9 

Is the temperature of retrievably-stored containers monitored as necessary prior to delivery for characterization? Is there a CCP Container Traveler (Attachment 1) attached to each container to 

be characterized? 

The VPM determines if the environmental temperature would have adversely impacted containers stored in Building WMF628. NDE operators are required to record the container temperature on the Traveler prior to RTR examination. All of the containers inspected had a Traveler attached as required. 

CM-4: Retrievably-stored waste container acceptance performed by container management personnel. 

CCP-TP-068, Rev. 5, Sect. 4.1 

Verify that container is on the AK Tracking Spreadsheet. Perform container filter inspection. Verify at least 3 bar code labels on each container are evenly spaced around the container. Verify container’s radiological label/tag. Complete Attachment 2, Container Inspection Report. 

Verification that a container is on the AK tracking sheet is 

performed prior to container acceptance from AMWTP and 

prior to performance of each characterization technique. 

The presence of the requisite number of barcode labels, a radiological tag, and a container integrity check are all recorded on Attachment 2, Container Inspection Report. Containers failing one or more of these checks may be returned to the host site. 

CM-5: Traveler. CCP-TP-068, 

Rev. 5, Sect. 4.2 

Is there a Traveler (Attachment 1) on each container to be characterized? 

All of the containers inspected had a Traveler attached as 

required. 

CM-6: Container weighing. CCP-TP-068, 

Rev. 5, Sect. 4.3 

Newly-generated Waste (4.3.1):

Are the VE data sheet and Attachment 1 completed as required? Retrievably-stored Waste (4.3.2):

Is scale calibration verified with a known weight? Is verification documented on Attachment 3? Are Attachments 1 and 3 completed with container information? 

The VE data sheet must be attached to a container prior to 

NDA, and the NDA operator is required to verify that either 

VE or RTR data sheets are attached to the Traveler.

A scale check is performed and recorded as required. The net and gross container weights are used in RTR to determine 

waste weight and hence WMP weights. 
A.5-3 

CCP-TP-068, CONTAINER MANAGEMENT AT THE INL AND TWCP 

EPA Inspection No.: EPA-INL-CCP-09.08-24, CCP/INL Continuing Compliance Inspection Date: September 16–18, 2008

Establishment of Required 

Technical Elements in Procedures Location Execution of Procedures Objective Evidence/Comments 

CM-7: Container movement. CCP-TP-068, 

Rev. 5, Sect. 4.4-4.8 

These sections deal with the characterization techniques, but do not provide any information on how containers are moved to each location. 

NA 

CM-8: Characterization completion. CCP-TP-068, 

Rev. 5, Sect. 4.9 

Container Management Personnel are required to remove Traveler and characterization data sheets and forward them to the VPM. No information on how the containers are moved or tracked or what happens to them after the completion of characterization. 

EPA has committed to inspection of container movement and tracking after characterization has been completed (shipping). This will be performed at some future date. 
B-1 

ATTACHMENT B.1: REPLICATE TESTING DATA FOR CONTAINER 10212486 – WAGS 

Instrument: WAGS Container: 10212486 

Original Measurement Replicate #1 Replicate #2 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238Pu Activity (Ci) 4.34E-05 2.13E-05 4.91E-01 5.59E-05 2.64E-05 4.72E-01 5.92E-05 2.84E-05 4.80E-01 239Pu Activity (Ci) 1.52E-03 4.68E-04 3.08E-01 1.95E-03 5.48E-04 2.81E-01 2.07E-03 6.05E-04 2.92E-01 240Pu Activity (Ci) 3.37E-04 1.08E-04 3.20E-01 4.34E-04 1.27E-04 2.93E-01 4.60E-04 1.40E-04 3.04E-01 242Pu Activity (Ci) 4.38E-08 2.61E-08 5.96E-01 5.64E-08 3.29E-08 5.83E-01 5.98E-08 3.52E-08 5.89E-01 241Am Activity (Ci) 1.30E-04 3.29E-05 2.53E-01 1.30E-04 3.31E-05 2.55E-01 1.32E-04 3.35E-05 2.54E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 1.95E+01 4.64E+00 2.38E-01 2.48E+01 5.42E+00 2.19E-01 2.62E+01 5.98E+00 2.28E-01 

Replicate #3 Replicate #4 Replicate #5 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238Pu Activity (Ci) 5.55E-05 2.67E-05 4.81E-01 4.79E-05 2.27E-05 4.74E-01 4.63E-05 2.21E-05 4.77E-01 239Pu Activity (Ci) 1.94E-03 5.71E-04 2.94E-01 1.67E-03 4.73E-04 2.83E-01 1.62E-03 4.67E-04 2.88E-01 240Pu Activity (Ci) 4.31E-04 1.32E-04 3.06E-01 3.72E-04 1.10E-04 2.96E-01 3.60E-04 1.08E-04 3.00E-01 242Pu Activity (Ci) 5.60E-08 3.31E-08 5.91E-01 4.83E-08 2.82E-08 5.84E-01 4.68E-08 2.75E-08 5.88E-01 241Am Activity (Ci) 1.31E-04 3.33E-05 2.54E-01 1.33E-04 3.37E-05 2.53E-01 1.31E-04 3.33E-05 2.54E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 2.46E+01 5.65E+00 2.30E-01 2.14E+01 4.69E+00 2.19E-01 2.08E+01 4.63E+00 2.23E-01 
B-2 

ATTACHMENT B.2: REPLICATE TESTING RESULTS FOR CONTAINER 10212486 – WAGS 

Instrument: WAGS Container: 10212486 

Original Measurement 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation x 2 Pr(x <|c2|) 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 238Pu Activity (Ci) 4.34E-05 2.13E-05 5.30E-05 5.57E-06 1.05E-01 2.73E-01 9.91E-01 239Pu Activity (Ci) 1.52E-03 4.68E-04 1.85E-03 1.95E-04 1.05E-01 6.93E-01 9.52E-01 240Pu Activity (Ci) 3.37E-04 1.08E-04 4.11E-04 4.32E-05 1.05E-01 6.41E-01 9.58E-01 242Pu Activity (Ci) 4.38E-08 2.61E-08 5.35E-08 5.62E-09 1.05E-01 1.85E-01 9.96E-01 241Am Activity (Ci) 1.30E-04 3.29E-05 1.31E-04 1.14E-06 8.68E-03 4.80E-03 1.00E+00 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A TRU Alpha Conc. (nCi/g) 1.95E+01 4.64E+00 2.36E+01 2.34E+00 9.93E-02 1.02E+00 9.07E-01 

Quantity of Interest t Pr(x <|t|) x 2 Test t Test

233U Activity (Ci) N/A N/A N/A Not Applicable 

234U Activity (Ci) N/A N/A N/A Not Applicable 238U Activity (Ci) N/A N/A N/A Not Applicable 238Pu Activity (Ci) -1.57E+00 1.92E-01 Not Significant Not Significant 239Pu Activity (Ci) -1.55E+00 1.97E-01 Not Significant Not Significant 240Pu Activity (Ci) -1.57E+00 1.91E-01 Not Significant Not Significant 242Pu Activity (Ci) -1.57E+00 1.92E-01 Not Significant Not Significant 241Am Activity (Ci) -1.12E+00 3.25E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A N/A Not Applicable 137Cs Activity (Ci) N/A N/A N/A Not Applicable TRU Alpha Conc. (nCi/g) -1.58E+00 1.88E-01 Not Significant Not Significant 
B-3 

ATTACHMENT B.3: REPLICATE TESTING DATA FOR CONTAINER 10215772 – WAGS 

Instrument: WAGS Container: 10215772 

Original Measurement Replicate #1 Replicate #2 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 3.68E-07 2.37E-07 6.44E-01 3.60E-07 2.32E-07 6.44E-01 3.12E-07 2.01E-07 6.44E-01 238U Activity (Ci) 1.97E-06 9.65E-07 4.90E-01 1.93E-06 8.82E-07 4.57E-01 1.67E-06 7.97E-07 4.77E-01 238Pu Activity (Ci) 2.70E-04 4.35E-04 1.61E+00 5.71E-04 3.97E-04 6.95E-01 3.35E-06 3.98E-04 1.19E+02 239Pu Activity (Ci) 1.17E-02 4.83E-03 4.13E-01 1.08E-02 4.48E-03 4.15E-01 1.18E-02 4.87E-03 4.13E-01 240Pu Activity (Ci) 2.06E-03 9.40E-04 4.56E-01 2.45E-03 1.06E-03 4.33E-01 2.88E-03 1.27E-03 4.41E-01 242Pu Activity (Ci) 1.51E-07 7.61E-08 5.04E-01 1.73E-07 8.13E-08 4.70E-01 2.15E-07 1.03E-07 4.79E-01 241Am Activity (Ci) 8.89E-04 3.67E-04 4.13E-01 8.98E-04 3.71E-04 4.13E-01 9.07E-04 3.74E-04 4.12E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 7.31E+01 2.43E+01 3.32E-01 7.22E+01 2.27E+01 3.14E-01 7.64E+01 2.48E+01 3.25E-01 

Replicate #3 Replicate #4 Replicate #5 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 2.66E-07 1.72E-07 6.47E-01 2.61E-07 1.68E-07 6.44E-01 3.40E-07 2.19E-07 6.44E-01 238U Activity (Ci) 1.43E-06 7.02E-07 4.91E-01 1.40E-06 6.73E-07 4.81E-01 1.82E-06 8.44E-07 4.64E-01 238Pu Activity (Ci) 4.41E-04 4.73E-04 1.07E+00 5.32E-05 5.57E-04 1.05E+01 1.41E-03 8.83E-04 6.26E-01 239Pu Activity (Ci) 1.30E-02 5.39E-03 4.15E-01 1.10E-02 4.52E-03 4.11E-01 1.23E-02 5.06E-03 4.11E-01 240Pu Activity (Ci) 2.05E-03 9.41E-04 4.59E-01 2.34E-03 1.15E-03 4.91E-01 2.40E-03 1.13E-03 4.71E-01 242Pu Activity (Ci) 1.36E-07 6.95E-08 5.11E-01 1.86E-07 9.73E-08 5.23E-01 2.09E-07 1.04E-07 4.98E-01 241Am Activity (Ci) 9.11E-04 3.76E-04 4.13E-01 8.97E-04 3.70E-04 4.12E-01 8.99E-04 3.71E-04 4.13E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 8.03E+01 2.70E+01 3.36E-01 6.98E+01 2.31E+01 3.31E-01 8.32E+01 2.58E+01 3.10E-01 
B-4 

ATTACHMENT B.4: REPLICATE TESTING RESULTS FOR CONTAINER 10215772 – WAGS 

Instrument: WAGS Container: 10215772 

Original Measurement 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation 

x

 2 Pr(x <|c2|) 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 234U Activity (Ci) 3.68E-07 2.37E-07 3.08E-07 4.39E-08 1.43E-01 1.37E-01 9.98E-01 238U Activity (Ci) 1.97E-06 9.65E-07 1.65E-06 2.34E-07 1.42E-01 2.35E-01 9.94E-01 238Pu Activity (Ci) 2.70E-04 4.35E-04 4.96E-04 5.66E-04 1.14E+00 6.78E+00 1.48E-01 239Pu Activity (Ci) 1.17E-02 4.83E-03 1.18E-02 9.12E-04 7.74E-02 1.43E-01 9.98E-01 240Pu Activity (Ci) 2.06E-03 9.40E-04 2.42E-03 2.98E-04 1.23E-01 4.03E-01 9.82E-01 242Pu Activity (Ci) 1.51E-07 7.61E-08 1.84E-07 3.17E-08 1.72E-01 6.93E-01 9.52E-01 241Am Activity (Ci) 8.89E-04 3.67E-04 9.02E-04 6.23E-06 6.90E-03 1.15E-03 1.00E+00 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A TRU Alpha Conc. (nCi/g) 7.31E+01 2.43E+01 7.64E+01 5.54E+00 7.25E-02 2.08E-01 9.95E-01 

Quantity of Interest t Pr(x <|t|) x 2 Test t Test

233U Activity (Ci) N/A N/A N/A Not Applicable 

234U Activity (Ci) 1.25E+00 2.79E-01 Not Significant Not Significant 238U Activity (Ci) 1.25E+00 2.80E-01 Not Significant Not Significant 238Pu Activity (Ci) -3.64E-01 7.34E-01 Not Significant Not Significant 239Pu Activity (Ci) -8.01E-02 9.40E-01 Not Significant Not Significant 240Pu Activity (Ci) -1.11E+00 3.28E-01 Not Significant Not Significant 242Pu Activity (Ci) -9.45E-01 3.98E-01 Not Significant Not Significant 241Am Activity (Ci) -1.96E+00 1.21E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A N/A Not Applicable 137Cs Activity (Ci) N/A N/A N/A Not Applicable TRU Alpha Conc. (nCi/g) -5.41E-01 6.17E-01 Not Significant Not Significant 
B-5 

ATTACHMENT B.5: REPLICATE TESTING DATA FOR CONTAINER ARP05744 – WAGS 

Instrument: WAGS Container: ARP05744 

Original Measurement Replicate #1 Replicate #2 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238Pu Activity (Ci) 1.96E-03 9.94E-04 5.07E-01 2.00E-03 1.01E-03 5.05E-01 2.24E-03 1.13E-03 5.04E-01 239Pu Activity (Ci) 6.84E-02 2.29E-02 3.35E-01 6.99E-02 2.32E-02 3.32E-01 7.82E-02 2.60E-02 3.32E-01 240Pu Activity (Ci) 1.52E-02 5.24E-03 3.45E-01 1.55E-02 5.32E-03 3.43E-01 1.74E-02 5.95E-03 3.42E-01 242Pu Activity (Ci) 1.97E-06 1.21E-06 6.14E-01 2.02E-06 1.23E-06 6.09E-01 2.26E-06 1.38E-06 6.11E-01 241Am Activity (Ci) 2.63E-01 8.76E-02 3.33E-01 2.69E-01 8.91E-02 3.31E-01 2.46E-01 8.17E-02 3.32E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 3.11E+03 8.09E+02 2.60E-01 3.18E+03 8.23E+02 2.59E-01 3.07E+03 7.66E+02 2.50E-01 

Replicate #3 Replicate #4 Replicate #5 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238Pu Activity (Ci) 1.63E-03 8.21E-04 5.04E-01 2.09E-03 1.06E-03 5.07E-01 1.92E-03 9.74E-04 5.07E-01 239Pu Activity (Ci) 5.69E-02 1.89E-02 3.32E-01 7.31E-02 2.43E-02 3.32E-01 6.72E-02 2.25E-02 3.35E-01 240Pu Activity (Ci) 1.26E-02 4.32E-03 3.43E-01 1.62E-02 5.56E-03 3.43E-01 1.49E-02 5.15E-03 3.46E-01 242Pu Activity (Ci) 1.64E-06 1.00E-06 6.10E-01 2.11E-06 1.29E-06 6.11E-01 1.94E-06 1.19E-06 6.13E-01 241Am Activity (Ci) 2.62E-01 8.68E-02 3.31E-01 2.64E-01 8.74E-02 3.31E-01 2.66E-01 8.82E-02 3.32E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 2.97E+03 7.94E+02 2.67E-01 3.17E+03 8.12E+02 2.56E-01 3.13E+03 8.14E+02 2.60E-01 
B-6 

ATTACHMENT B.6: REPLICATE TESTING RESULTS FOR CONTAINER ARP05744 – WAGS 

Instrument: WAGS Container: ARP05744 

Original Measurement 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation 

x

 2 Pr(x <|c2|) 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 238Pu Activity (Ci) 1.96E-03 9.94E-04 1.98E-03 2.27E-04 1.15E-01 2.09E-01 9.95E-01 239Pu Activity (Ci) 6.84E-02 2.29E-02 6.91E-02 7.94E-03 1.15E-01 4.80E-01 9.75E-01 240Pu Activity (Ci) 1.52E-02 5.24E-03 1.53E-02 1.78E-03 1.16E-01 4.62E-01 9.77E-01 242Pu Activity (Ci) 1.97E-06 1.21E-06 1.99E-06 2.31E-07 1.16E-01 1.46E-01 9.97E-01 241Am Activity (Ci) 2.63E-01 8.76E-02 2.61E-01 8.99E-03 3.44E-02 4.21E-02 1.00E+00 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A TRU Alpha Conc. (nCi/g) 3.11E+03 8.09E+02 3.10E+03 8.65E+01 2.79E-02 4.58E-02 1.00E+00 

Quantity of Interest t Pr(x <|t|) x 2 Test t Test

233U Activity (Ci) N/A N/A N/A Not Applicable 234U Activity (Ci) N/A N/A N/A Not Applicable 238U Activity (Ci) N/A N/A N/A Not Applicable 238Pu Activity (Ci) -6.43E-02 9.52E-01 Not Significant Not Significant 239Pu Activity (Ci) -7.59E-02 9.43E-01 Not Significant Not Significant 240Pu Activity (Ci) -6.15E-02 9.54E-01 Not Significant Not Significant 242Pu Activity (Ci) -9.49E-02 9.29E-01 Not Significant Not Significant 241Am Activity (Ci) 1.62E-01 8.79E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A N/A Not Applicable 137Cs Activity (Ci) N/A N/A N/A Not Applicable TRU Alpha Conc. (nCi/g) 6.33E-02 9.53E-01 Not Significant Not Significant 
B-7 

ATTACHMENT B.7: REPLICATE TESTING DATA FOR CONTAINER ARP06447 – WAGS 

Instrument: WAGS Container: ARP06447 

Original Measurement Replicate #1 Replicate #2 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238Pu Activity (Ci) 1.38E-04 8.03E-05 5.82E-01 1.52E-04 8.48E-05 5.58E-01 1.44E-04 8.01E-05 5.56E-01 239Pu Activity (Ci) 4.81E-03 2.12E-03 4.41E-01 5.33E-03 2.16E-03 4.05E-01 5.04E-03 2.04E-03 4.05E-01 240Pu Activity (Ci) 1.07E-03 4.79E-04 4.48E-01 1.18E-03 4.91E-04 4.16E-01 1.12E-03 4.63E-04 4.13E-01 242Pu Activity (Ci) 1.39E-07 9.36E-08 6.73E-01 1.54E-07 1.00E-07 6.49E-01 1.45E-07 9.49E-08 6.55E-01 241Am Activity (Ci) 5.67E-02 2.20E-02 3.88E-01 4.82E-02 1.87E-02 3.88E-01 4.43E-02 1.72E-02 3.88E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 4.10E+02 1.44E+02 3.51E-01 3.58E+02 1.23E+02 3.44E-01 3.31E+02 1.13E+02 3.41E-01 

Replicate #3 Replicate #4 Replicate #5 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238Pu Activity (Ci) 1.57E-04 8.70E-05 5.54E-01 1.44E-04 7.95E-05 5.52E-01 1.54E-04 8.59E-05 5.58E-01 239Pu Activity (Ci) 5.50E-03 2.21E-03 4.02E-01 5.05E-03 2.00E-03 3.96E-01 5.39E-03 2.19E-03 4.06E-01 240Pu Activity (Ci) 1.22E-03 5.01E-04 4.11E-01 1.12E-03 4.55E-04 4.06E-01 1.20E-03 4.97E-04 4.14E-01 242Pu Activity (Ci) 1.59E-07 1.03E-07 6.48E-01 1.46E-07 9.44E-08 6.47E-01 1.56E-07 1.02E-07 6.54E-01 241Am Activity (Ci) 5.19E-02 2.01E-02 3.87E-01 5.06E-02 1.96E-02 3.87E-01 5.35E-02 2.07E-02 3.87E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 3.84E+02 1.32E+02 3.44E-01 3.72E+02 1.29E+02 3.47E-01 3.94E+02 1.36E+02 3.45E-01 
B-8 

ATTACHMENT B.8: REPLICATE TESTING RESULTS FOR CONTAINER ARP06447 – WAGS 

Instrument: WAGS Container: ARP06447 

Original Measurement 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation 

x

 2 Pr(x <| x 2|) 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 238Pu Activity (Ci) 1.38E-04 8.03E-05 1.50E-04 5.93E-06 3.95E-02 2.18E-02 1.00E+00 239Pu Activity (Ci) 4.81E-03 2.12E-03 5.26E-03 2.07E-04 3.94E-02 3.83E-02 1.00E+00 240Pu Activity (Ci) 1.07E-03 4.79E-04 1.17E-03 4.60E-05 3.94E-02 3.70E-02 1.00E+00 242Pu Activity (Ci) 1.39E-07 9.36E-08 1.52E-07 6.20E-09 4.08E-02 1.76E-02 1.00E+00 241Am Activity (Ci) 5.67E-02 2.20E-02 4.97E-02 3.59E-03 7.22E-02 1.06E-01 9.99E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A TRU Alpha Conc. (nCi/g) 4.10E+02 1.44E+02 3.68E+02 2.46E+01 6.68E-02 1.17E-01 9.98E-01 

Quantity of Interest t Pr(x <|t|) x 2 Test t Test

233U Activity (Ci) N/A N/A N/A Not Applicable 234U Activity (Ci) N/A N/A N/A Not Applicable 238U Activity (Ci) N/A N/A N/A Not Applicable 238Pu Activity (Ci) -1.88E+00 1.34E-01 Not Significant Not Significant 239Pu Activity (Ci) -1.99E+00 1.17E-01 Not Significant Not Significant 240Pu Activity (Ci) -1.94E+00 1.24E-01 Not Significant Not Significant 242Pu Activity (Ci) -1.91E+00 1.28E-01 Not Significant Not Significant 241Am Activity (Ci) 1.78E+00 1.50E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A N/A Not Applicable 137Cs Activity (Ci) N/A N/A N/A Not Applicable TRU Alpha Conc. (nCi/g) 1.57E+00 1.92E-01 Not Significant Not Significant 
B-9 

ATTACHMENT B.9: REPLICATE TESTING DATA FOR CONTAINER ARP06723 – WAGS 

Instrument: WAGS Container: ARP06723 

Original Measurement Replicate #1 Replicate #2 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 5.70E-06 3.28E-06 5.75E-01 5.13E-06 2.95E-06 5.75E-01 6.14E-06 3.53E-06 5.75E-01 238U Activity (Ci) 2.27E-05 6.62E-06 2.92E-01 2.31E-05 6.67E-06 2.89E-01 2.10E-05 6.11E-06 2.91E-01 238Pu Activity (Ci) 8.76E-04 8.72E-04 9.95E-01 3.25E-03 1.19E-03 3.66E-01 3.36E-03 1.25E-03 3.72E-01 239Pu Activity (Ci) 1.21E-01 3.46E-02 2.86E-01 1.18E-01 3.36E-02 2.85E-01 1.20E-01 3.43E-02 2.86E-01 240Pu Activity (Ci) 2.68E-02 7.70E-03 2.87E-01 2.52E-02 7.25E-03 2.88E-01 2.66E-02 7.64E-03 2.87E-01 242Pu Activity (Ci) 2.21E-06 6.77E-07 3.06E-01 2.13E-06 6.50E-07 3.05E-01 2.26E-06 6.91E-07 3.06E-01 241Am Activity (Ci) 3.45E-02 1.06E-02 3.07E-01 2.56E-02 7.31E-03 2.86E-01 2.50E-02 7.15E-03 2.86E-01 90Sr Activity (Ci) 6.24E-07 1.80E-07 2.89E-01 7.85E-07 2.25E-07 2.87E-01 7.59E-07 2.18E-07 2.87E-01 137Cs Activity (Ci) 5.67E-07 1.64E-07 2.89E-01 7.13E-07 2.04E-07 2.86E-01 6.90E-07 1.98E-07 2.87E-01 TRU Alpha Conc. (nCi/g) 2.22E+03 4.48E+02 2.02E-01 2.08E+03 4.25E+02 2.04E-01 2.12E+03 4.34E+02 2.05E-01 

Replicate #3 Replicate #4 Replicate #5 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 7.24E-06 4.16E-06 5.75E-01 5.79E-06 3.33E-06 5.75E-01 5.62E-06 3.23E-06 5.75E-01 238U Activity (Ci) 2.20E-05 6.37E-06 2.90E-01 1.97E-05 5.74E-06 2.91E-01 2.37E-05 6.86E-06 2.90E-01 238Pu Activity (Ci) 3.83E-03 1.34E-03 3.50E-01 5.07E-03 1.64E-03 3.24E-01 3.59E-03 1.28E-03 3.57E-01 239Pu Activity (Ci) 1.21E-01 3.44E-02 2.84E-01 1.16E-01 3.31E-02 2.85E-01 1.19E-01 3.40E-02 2.86E-01 240Pu Activity (Ci) 2.75E-02 7.90E-03 2.87E-01 2.66E-02 7.65E-03 2.88E-01 2.68E-02 7.69E-03 2.87E-01 242Pu Activity (Ci) 2.34E-06 7.15E-07 3.06E-01 2.24E-06 6.85E-07 3.06E-01 2.25E-06 6.89E-07 3.06E-01 241Am Activity (Ci) 2.54E-02 7.24E-03 2.85E-01 2.52E-02 7.19E-03 2.85E-01 2.53E-02 7.21E-03 2.85E-01 90Sr Activity (Ci) 7.83E-07 2.25E-07 2.87E-01 7.47E-07 2.14E-07 2.87E-01 7.82E-07 2.24E-07 2.86E-01 137Cs Activity (Ci) 7.12E-07 2.04E-07 2.87E-01 6.79E-07 1.95E-07 2.87E-01 7.11E-07 2.04E-07 2.87E-01 TRU Alpha Conc. (nCi/g) 2.15E+03 4.37E+02 2.03E-01 2.09E+03 4.21E+02 2.01E-01 2.12E+03 4.31E+02 2.03E-01 
B-10 

ATTACHMENT B.10: REPLICATE TESTING RESULTS FOR CONTAINER ARP06723 – WAGS 

Instrument: WAGS Container: ARP06723 

Original Measurement 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation 

x

 2 Pr(x <| x 2|) 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 234U Activity (Ci) 5.70E-06 3.28E-06 5.98E-06 7.91E-07 1.32E-01 2.33E-01 9.94E-01 238U Activity (Ci) 2.27E-05 6.62E-06 2.19E-05 1.61E-06 7.34E-02 2.36E-01 9.94E-01 238Pu Activity (Ci) 8.76E-04 8.72E-04 3.82E-03 7.33E-04 1.92E-01 2.83E+00 5.87E-01 239Pu Activity (Ci) 1.21E-01 3.46E-02 1.19E-01 1.92E-03 1.62E-02 1.24E-02 1.00E+00 240Pu Activity (Ci) 2.68E-02 7.70E-03 2.65E-02 8.35E-04 3.15E-02 4.71E-02 1.00E+00 242Pu Activity (Ci) 2.21E-06 6.77E-07 2.24E-06 7.50E-08 3.34E-02 4.91E-02 1.00E+00 241Am Activity (Ci) 3.45E-02 1.06E-02 2.53E-02 2.24E-04 8.84E-03 1.78E-03 1.00E+00 90Sr Activity (Ci) 6.24E-07 1.80E-07 7.71E-07 1.72E-08 2.23E-02 3.64E-02 1.00E+00 137Cs Activity (Ci) 5.67E-07 1.64E-07 7.01E-07 1.56E-08 2.22E-02 3.61E-02 1.00E+00 TRU Alpha Conc. (nCi/g) 2.22E+03 4.48E+02 2.11E+03 2.77E+01 1.31E-02 1.53E-02 1.00E+00 

Quantity of Interest t Pr(x <|t|) x 2 Test t Test

233U Activity (Ci) N/A N/A N/A Not Applicable 234U Activity (Ci) -3.28E-01 7.59E-01 Not Significant Not Significant 238U Activity (Ci) 4.54E-01 6.73E-01 Not Significant Not Significant 238Pu Activity (Ci) -3.66E+00 2.15E-02 Not Significant Significant 239Pu Activity (Ci) 1.04E+00 3.55E-01 Not Significant Not Significant 240Pu Activity (Ci) 2.84E-01 7.90E-01 Not Significant Not Significant 242Pu Activity (Ci) -4.14E-01 7.00E-01 Not Significant Not Significant 241Am Activity (Ci) 3.76E+01 3.00E-06 Not Significant Highly Significant 90Sr Activity (Ci) -7.82E+00 1.44E-03 Not Significant Highly Significant 137Cs Activity (Ci) -7.86E+00 1.42E-03 Not Significant Highly Significant TRU Alpha Conc. (nCi/g) 3.55E+00 2.37E-02 Not Significant Significant 
B-11 

ATTACHMENT B.11: REPLICATE TESTING DATA FOR CONTAINER BN10211041 – SUPERHENC 

Instrument: Idaho SuperHENC Container: BN10211041 

Original Measurement Replicate #1 Replicate #2 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 1.33E-05 5.54E-06 4.16E-01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238Pu Activity (Ci) 4.59E-03 2.15E-03 4.68E-01 3.75E-03 1.71E-03 4.57E-01 3.87E-03 1.76E-03 4.54E-01 239Pu Activity (Ci) 1.49E-01 3.88E-02 2.60E-01 1.22E-01 2.94E-02 2.41E-01 1.26E-01 2.96E-02 2.34E-01 240Pu Activity (Ci) 3.32E-02 8.19E-03 2.46E-01 2.71E-02 6.15E-03 2.27E-01 2.80E-02 6.15E-03 2.19E-01 242Pu Activity (Ci) 4.31E-06 2.45E-06 5.68E-01 3.52E-06 1.97E-06 5.60E-01 3.64E-06 2.03E-06 5.57E-01 241Am Activity (Ci) 4.09E-02 1.29E-02 3.16E-01 1.51E-02 4.05E-03 2.68E-01 2.43E-02 6.06E-03 2.50E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 2.74E+02 7.20E+01 2.62E-01 2.02E+02 4.89E+01 2.42E-01 2.19E+02 5.16E+01 2.35E-01 

Replicate #3 Replicate #4 Replicate #5 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 1.45E-05 5.30E-06 3.67E-01 0.00E+00 N/A 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 4.03E-03 1.84E-03 4.57E-01 0.00E+00 N/A 0.00E+00 239Pu Activity (Ci) 1.46E-01 5.02E-02 3.45E-01 1.31E-01 3.16E-02 2.41E-01 1.43E-01 4.90E-02 3.42E-01 240Pu Activity (Ci) 2.88E-02 6.48E-03 2.26E-01 2.92E-02 6.60E-03 2.26E-01 3.04E-02 6.72E-03 2.21E-01 242Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 3.78E-06 2.12E-06 5.60E-01 0.00E+00 N/A 0.00E+00 241Am Activity (Ci) 3.13E-02 1.12E-02 3.57E-01 2.85E-02 7.85E-03 2.76E-01 2.66E-02 9.50E-03 3.57E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 2.47E+02 8.59E+01 3.47E-01 2.32E+02 5.62E+01 2.42E-01 2.41E+02 8.29E+01 3.44E-01 
B-12 

ATTACHMENT B.12: REPLICATE TESTING RESULTS FOR CONTAINER BN10211041 – SUPERHENC 

Instrument: Idaho SuperHENC Container: BN10211041 

Original Measurement Quantity of Interest 

Reported 

Value 

Absolute 

Uncertainty

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation x 2 Pr(x <|2|) 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 234U Activity (Ci) 1.33E-05 5.54E-06 2.89E-06 6.47E-06 2.24E+00 5.45E+00 2.44E-01 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 238Pu Activity (Ci) 4.59E-03 2.15E-03 2.33E-03 2.13E-03 9.14E-01 3.94E+00 4.15E-01 239Pu Activity (Ci) 1.49E-01 3.88E-02 1.34E-01 1.04E-02 7.81E-02 2.89E-01 9.91E-01 240Pu Activity (Ci) 3.32E-02 8.19E-03 2.87E-02 1.21E-03 4.22E-02 8.76E-02 9.99E-01 242Pu Activity (Ci) 4.31E-06 2.45E-06 2.19E-06 2.00E-06 9.14E-01 2.67E+00 6.15E-01 241Am Activity (Ci) 4.09E-02 1.29E-02 2.52E-02 6.19E-03 2.46E-01 9.18E-01 9.22E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A TRU Alpha Conc. (nCi/g) 2.74E+02 7.20E+01 2.28E+02 1.81E+01 7.92E-02 2.52E-01 9.93E-01 Quantity of Interest t Pr(x <|t|) x 2 Test t Test233U Activity (Ci) N/A N/A N/A Not Applicable 234U Activity (Ci) 1.47E+00 2.15E-01 Not Significant Not Significant 238U Activity (Ci) N/A N/A N/A Not Applicable 238Pu Activity (Ci) 9.69E-01 3.87E-01 Not Significant Not Significant 239Pu Activity (Ci) 1.38E+00 2.38E-01 Not Significant Not Significant 240Pu Activity (Ci) 3.42E+00 2.67E-02 Not Significant Significant 242Pu Activity (Ci) 9.69E-01 3.87E-01 Not Significant Not Significant 241Am Activity (Ci) 2.32E+00 8.07E-02 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A N/A Not Applicable 137Cs Activity (Ci) N/A N/A N/A Not Applicable TRU Alpha Conc. (nCi/g) 2.33E+00 8.01E-02 Not Significant Not Significant 
B-13 

ATTACHMENT B.13: REPLICATE TESTING DATA FOR CONTAINER BN10239132 – SUPERHENC 

Instrument: Idaho SuperHENC Container: BN10239132 

Original Measurement Replicate #1 Replicate #2 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238Pu Activity (Ci) 2.23E-02 9.00E-03 4.03E-01 2.18E-02 8.80E-03 4.04E-01 2.12E-02 8.53E-03 4.02E-01 239Pu Activity (Ci) 7.27E-01 7.86E-02 1.08E-01 7.09E-01 7.92E-02 1.12E-01 6.90E-01 7.19E-02 1.04E-01 240Pu Activity (Ci) 1.62E-01 1.13E-02 6.97E-02 1.58E-01 1.19E-02 7.53E-02 1.54E-01 9.74E-03 6.34E-02 242Pu Activity (Ci) 2.10E-05 1.08E-05 5.15E-01 2.04E-05 1.06E-05 5.17E-01 1.99E-05 1.03E-05 5.16E-01 241Am Activity (Ci) 1.19E-01 2.08E-02 1.75E-01 1.18E-01 1.75E-02 1.48E-01 9.98E-02 1.73E-02 1.73E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 2.82E+03 3.11E+02 1.10E-01 2.76E+03 3.13E+02 1.13E-01 2.64E+03 2.81E+02 1.06E-01 

Replicate #3 Replicate #4 Replicate #5 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238Pu Activity (Ci) 2.09E-02 8.49E-03 4.05E-01 2.34E-02 9.43E-03 4.03E-01 2.37E-02 9.49E-03 4.01E-01 239Pu Activity (Ci) 6.82E-01 7.88E-02 1.15E-01 7.62E-01 8.16E-02 1.07E-01 7.71E-01 7.68E-02 9.97E-02 240Pu Activity (Ci) 1.52E-01 1.22E-02 8.06E-02 1.69E-01 1.16E-02 6.83E-02 1.71E-01 9.55E-03 5.57E-02 242Pu Activity (Ci) 1.97E-05 1.02E-05 5.18E-01 2.20E-05 1.13E-05 5.16E-01 2.22E-05 1.15E-05 5.15E-01 241Am Activity (Ci) 1.36E-01 2.15E-02 1.59E-01 1.23E-01 1.76E-02 1.43E-01 1.37E-01 1.95E-02 1.42E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 2.71E+03 3.19E+02 1.17E-01 2.95E+03 3.21E+02 1.09E-01 3.02E+03 3.07E+02 1.02E-01 
B-14 

ATTACHMENT B.14: REPLICATE TESTING RESULTS FOR CONTAINER BN10239132 – SUPERHENC 

Instrument: Idaho SuperHENC Container: BN10239132 

Original Measurement 

Quantity of Interest Reported 

Value 

Absolute 

Uncertainty

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation 

x

2 Pr(x <| x 2|) 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A238Pu Activity (Ci) 2.23E-02 9.00E-03 2.22E-02 1.26E-03 5.66E-02 7.79E-02 9.99E-01239Pu Activity (Ci) 7.27E-01 7.86E-02 7.23E-01 4.09E-02 5.66E-02 1.08E+00 8.97E-01240Pu Activity (Ci) 1.62E-01 1.13E-02 1.61E-01 9.10E-03 5.66E-02 2.60E+00 6.26E-01242Pu Activity (Ci) 2.10E-05 1.08E-05 2.09E-05 1.18E-06 5.66E-02 4.77E-02 1.00E+00241Am Activity (Ci) 1.19E-01 2.08E-02 1.23E-01 1.52E-02 1.24E-01 2.14E+00 7.11E-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/A137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A N/ATRU Alpha Conc. (nCi/g) 2.82E+03 3.11E+02 2.82E+03 1.61E+02 5.73E-02 1.07E+00 8.98E-01

Quantity of Interest t Pr(x <|t|) x 2 Test t Test

233U Activity (Ci) N/A N/A N/A Not Applicable 234U Activity (Ci) N/A N/A N/A Not Applicable 238U Activity (Ci) N/A N/A N/A Not Applicable 238Pu Activity (Ci) 8.88E-02 9.33E-01 Not Significant Not Significant 239Pu Activity (Ci) 9.53E-02 9.29E-01 Not Significant Not Significant 240Pu Activity (Ci) 9.53E-02 9.29E-01 Not Significant Not Significant 242Pu Activity (Ci) 9.55E-02 9.29E-01 Not Significant Not Significant 241Am Activity (Ci) -2.10E-01 8.44E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A N/A Not Applicable 137Cs Activity (Ci) N/A N/A N/A Not Applicable TRU Alpha Conc. (nCi/g) 2.86E-02 9.79E-01 Not Significant Not Significant