DOCKET NO: A-98-49; II-A4-117

WASTE CHARACTERIZATION REPORT

TIER 1 CHANGE:

EVALUATION OF CONTACT-HANDLED TRANSURANIC S4000 SOI LS (ORNL WASTE STREAM OR-NFS-CH-SOIL) AT THE OAK RIDGE NATIO NAL

LABORATORY

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

October 2009i TABLE OF CONTENTS

Section Page

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

................................................... ........................... 1

2.0 Approval Summary for ORNL-CCP CH WC Program.... .................................................. 4

3.0 Purpose of Tier 1 Evaluations ..................

................................................... ........................ 4

4.0 Purpose of This Report.........................

................................................... ............................ 5

5.0 Scope of the Tier 1 Evaluation.................

................................................... ........................ 5

6.0 Performance of the Tier 1 Evaluation ...........

................................................... ................... 5

6.1 Acceptable Knowledge (AK)......................

................................................... ......... 6 6.2 Non Destructive Assay (NDA) .....................

................................................... ..... 22 6.3 Real-Time Radiography (RTR)....................

................................................... ...... 25

7.0 Summary of Results and Conclusions.............

................................................... ............... 28

LIST OF TABLES

Table 1. Revised Tiering of TRU WC Processes Implem ented by ORNL for CH TRU

Wastes (Based on September 2009 Tier 1 Evaluation). ................................................. 3
Table 2. Previous ORNL-CCP CH EPA Approvals ........

................................................... ......... 4
Table 3. T1 Evaluation Participants ................

................................................... .......................... 5
Table 4. Batch Data Reports Examined ...............

................................................... ................... 10
Table 5. Mixed Oxide Fuel Compositions .............

................................................... ................. 18
Table 6. Mass Isotopic Distributions of Mixed Oxide Fuels by NFS Contract ......................... 19
Table 7. Waste Stream OR-NFS-CH-SOIL Radiological Characterization.............................. 19
Table 8. Summary of RTR Operators Performance on Tr aining Drums ................................... 26

ATTACHMENTS

Attachment A: EPA Tier 1 Issue Tracking Form, Iss ue No. ORNL-CCP-CH-RTR-09-001CR,

Final
Attachment B: EPA Tier 1 Issue Tracking Form

, Issue No. ORNL-CCP-CH-NDA-09-002CR,

Final
Attachment C: EPA Inspection Issue Tracking Form , Issue No. ORNL-CCP-CH-NDA-09-

003C, Final1

1.0 EXECUTIVE SUMMARY

This report supports EPA’s approval of retrievably- stored, contact-handled (CH) transuranic (TRU) soils/gravel (S4000) from Soil Waste Stream O R-NFS-CH-SOIL generated at and packaged by the Oak Ridge National Laboratory (ORNL ) for disposal at the Waste Isolation Pilot Plant (WIPP). The Central Characterization P roject (CCP) was responsible for characterizing this waste using the system of contr ols the U.S. Environmental Protection Agency (EPA) evaluated during a baseline inspection conduc ted in August 2008.

In accordance with 40 CFR 194.8(b), the EPA conduct ed a baseline inspection, in August 2008, of the CCP’s CH TRU waste characterization (WC) pro gram at the ORNL in Oak Ridge, Tennessee. As a result of this baseline inspection , EPA approved the ORNL-CCP CH TRU WC program with specific conditions and limitations, a s discussed in the ORNL Baseline Final Inspection Report (see A-98-49; II-A4-103 for detai ls). The August 2008 approval was limited to retrievably-stored debris waste, and any wastes outside of this category (i.e., soils/gravel and solids and newly-generated debris) were identified as a Tier 1 (T1) change.

On May 13, 2009, the Carlsbad Field Office (CBFO) r equested EPA approval as a T1 change to

add ORNL’s CH TRU Soil Waste Stream OR-NFS-CH-SOIL f rom the S4000 summary category group (SCG). Inclusion of S4000 wastes to the base line approval was identified as T1 change in the ORNL baseline inspection report. On August 11- 12, 2009, EPA conducted a T1 evaluation of the requested change by reviewing documents and records for Acceptable Knowledge (AK) and Non-Destructive Assay (NDA) of the subject waste stream in Golden, Colorado. The week before, an EPA inspector evaluated selected audio/v ideo (AV) recordings of Real-Time Radiography (RTR) performed on soil containers.

During the evaluations, EPA identified three concer ns, one in RTR and two in Non-Destructive Assay (NDA). Two of these concerns, one in RTR and one in NDA, required a response. All

three of these concerns are discussed in the text a nd are included as attachments to this report. These concerns did not affect the quality of the wa ste characterization data quantifying the contents of containers of soil waste. ORNL-CCP pro vided responses and they adequately addressed both concerns and no open issues remain r elated to this T1 change. Based on EPA’s evaluation of all aspects of the ORNL-CCP WC progra m relative to Waste Stream OR-NFS-CHSOIL, EPA approves the addition of the SCG S4000 CH TRU soils/gravel SCG at ORNL-CCP.

EPA’s approval of the S4000 soils/gravel SCG to the ORNL-CCP baseline approval required revision of the original T1 and Tier 2 (T2) designa tions (see EPA Docket No. A-98-49, II-A4- 103, Tables 1 and 8). The revisions are in Table 1 below, showing the most current tierings; this tiering table supersedes the table provided in the baseline report. The original table provided references to the specific sections of the baseline inspection report, where each T1 or T2 change was discussed in parentheses, and these have been r emoved from the revised table for clarity.

The CBFO must use tierings in the revised table whe n recertifying the ORNL-CCP program and ORNL-CCP must use the revised table when submitting future changes for EPA approval or concurrence. Changes in the revised table are excl usively in the area of AK. A new T1 change [soil from a burial trench at Nuclear Fuels Service s (NFS)] is included under AK, because EPA2

did not receive the most current AK documents (for example, the AK Summary or AKS, Revision 4, dated May 2009) discussing this waste s tream prior to the August evaluation. All of

the T2 elements listed under AK in the revised Tabl e 1 apply to all approved waste streams and SCGs at ORNL-CCP. There are no changes to the T1 a nd T2 designations assigned to NDA, RTR, Visual Examination (VE), and the WIPP Waste In formation System (WWIS). Consistent with EPA’s authority under 40 CFR 194.24(h), EPA ma y request information, if EPA deems it necessary to ensure continued compliance with EPA r egulations.

This report serves as EPA’s public notification of the results of the proposed T1 change and its evaluation. This information will be provided thro ugh the EPA Web site and by sending e-mails to the WIPPNEWS list, in accordance with 40 CFR 194 .8(b)(3).3Table 1. Revised Tiering of TRU WC Processes Implemented by ORNL for CH TRU Wastes(Based on September 2009 Tier 1 Evaluation)WC Process ElementsORNL-CCP WC T1 ChangesORNL-CCP WC T2 ChangesaAcceptable Knowledge and LoadManagementImplementation of load managementImplementation of AK for wastes other thanretrievably- stored debris and soils/gravel (i.e.,solidsor any type of newly-generated waste)Implementation to include soil from NFS burial trenchin Waste Stream OR-NFS-CH-SOILThe elements listed as T2 changes below apply to all approved ORNLCCP CH TRU waste streams and waste summary categorygroups.Notification to EPA upon completion of AK accuracyreports and, uponcompletion of new versions or updates/substantive changesbof thefollowing:-AK-NDA memoranda-Site AK procedure CCP-TP-005-AK accuracy reports-AK-AK and AK-NDA/NDE Discrepancy Resolution Reports-Attachments 4 and 6 and associated memoranda-WSPFs and AK summaries and related attachments forall newwaste streams, including change notices-“Add Container” memorandaNon Destructive Assay New equipment or physical modifications to approvedequipmentcExtension or changes to approved calibration rangeforapproved equipmentNotification to EPA upon completion of changes to software forapproved equipment, operating range(s), and site procedures that requireCBFO approval.Real-Time Radiography N/A Notification to EPA uponthe following:-Implementation of new RTR equipment or substantivechangescto approved RTR equipment-Completion of changes to site RTR procedures requiring CBFOapprovalsVisual Examination Not approved at this time Not approved at this timeWIPP Waste Information System Implementation of load management Notification to EPA upon completion of changes to WWIS procedure(s)requiring CBFO approvalsaORNL-CCP will report all T2 changes to EPA at theend 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 toES&H, nuclear safety, or RCRA, or that are editorial in nature.cModifications to approved equipment include all changes with the potential to affect NDA data relativeto waste isolation and exclude minor changes, suchas theaddition of safety-related equipment.4

2.0 APPROVAL SUMMARY FOR ORNL-CCP CH WC PROGRAM

EPA provided formal baseline approval of the ORNL-C CP CH WC program in August of 2008. Since then, EPA has approved two T1 changes at ORNL -CCP. These are summarized in

Table 2.

Table 2. Previous ORNL-CCP CH EPA Approvals

Approved Activity EPA Inspection Number (Approval Dates) Docket Number

ORNL-CCP CH Baseline Approval EPA-ORNL-CCP-CH-11.07-8 (August 21, 2008) A-98-49, II-A4-103

T1 Change – DWAS SGS Range and Density Extension EPA-ORNL-CCP-CH-T1-SGS (January 8, 2009) A-98-49, II-A4-108

T1 Change – DWAS IPAN Range Extension EPA-ORNL-CCP-CH-T1-IPAN (January 8, 2009) A-98-49, II-A4-109

3.0 PURPOSE OF TIER 1 EVALUATIONS

Any changes to the WC activities from the date of t he baseline inspection must be reported to, and, if applicable, approved by EPA, according to t he tiering requirements set forth in the ORNL Baseline Final Report cited above.

Under the changes to 40 CFR 194.8 promulgated in th e July 16, 2004, Federal Register notice, EPA must perform a single baseline inspection of a TRU waste generator site’s WC program. The purpose of the baseline inspection is to approv e the site’s WC program, based on the demonstration that the program’s components, with a pplicable conditions and limitations, can adequately characterize TRU wastes and comply with the regulatory requirements imposed on TRU wastes destined for disposal at the WIPP. An E PA inspection team conducts an onsite inspection to verify that the site’s system of cont rols is technically adequate and properly implemented.

Following EPA’s approval of WC processes evaluated during the baseline inspection, EPA is authorized to evaluate and approve, if necessary, c hanges to the site’s approved WC program by conducting additional inspections under the authori ty of 40 CFR 194.24(h). Under 40 CFR 194.24, EPA has the authority to conduct con tinued compliance inspections to verify that the site continues to use only the approved WC processes to characterize the waste and remains in compliance with all the regulatory requi rements. Based on the adequacies of the WC processes demonstrated during the baseline inspecti on, including all conditions and limitations, EPA specified which subsequent WC program changes o r modifications must undergo further EPA inspection or approval under 40 CFR 194.24. Th is was accomplished by assigning a tier level to each aspect of the ORNL-CCP’s WC program. T1 activities have more stringent reporting requirements and require that DOE notify EPA, and that EPA provide approval prior to implementation. The rule under which baseline insp ections are conducted can be found in the Federal Register

(Vol. 69, No. 136, pages 42571–42583 of July 16, 2 004).5

4.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluatio n of a T1 change to add CH TRU soils/gravel (from Waste Stream OR-NFS-CH-SOIL) from the S4000 S CG to the ORNL-CCP approval. This report documents the basis for EPA’s approval decision, and explains the results of the technical evaluation of these wastes. EPA’s approv al decision regarding waste from CH TRU Soil Waste Stream OR-NFS-CH-SOIL been conveyed to D OE separately by letter. As discussed previously, EPA will also announce the decision on its web site at www.epa.gov/radiation/WIPP

, in accordance with 40 CFR 194.8(b)(3).

5.0 SCOPE OF THE TIER 1 EVALUATION

The scope of the T1 evaluation was the inclusion ofwaste from CH TRU Soil Waste Stream ORNFS-CH-SOIL from ORNL-CCP, which included Waste Stre am OR-NFS-CH-SOIL. These

materials were not examined at the ORNL-CCP baselin e inspection and were identified as a T1 change.

6.0 PERFORMANCE OF THE TIER 1 EVALUATION

This evaluation included three WC areas; AK, NDA, a nd RTR. Each of these is addressed in a separate section of this report. The NDA and RTR s ystems had been evaluated previously during the baseline inspection and, for NDA, two sub sequent T1 evaluations. The evaluations of these areas began with confirming that they were es sentially unchanged from what EPA had inspected and approved previously. Upon determinin g that was the case, the T1 evaluation for

NDA and RTR focused on the characterization records these systems produced upon processing ORNL-CCP Waste Stream OR-NFS-CH-SOIL. For AK, this evaluation resembled the type of evaluation typically performed during a baseline in spection. The T1 evaluation of AK and NDA was held in Golden, Colorado, on August 11–12, 2009 , and the RTR evaluation of recorded audio-visual (AV) tapes and related records occurre d the previous week in Albuquerque, New Mexico. Personnel who participated in the T1 evalu ation are listed in Table 3, along with each person’s affiliation and function during the evalua tion.

Table 3. T1 Evaluation Participants

Name Affiliation

Ed Feltcorn EPA Headquarters, Lead Inspector

Rajani Joglekar EPA Headquarters, Inspector

Connie Walker SC&A, AK Technical Evaluator

Patrick Kelly SC&A, NDA Technical Evaluator

Dorothy Gill SC&A, RTR Technical Evaluator (Albuque rque)

Mark Pearcy CCP, Management Support

Jeff Harrison CCP, AK Expert

Joe Harvill CCP, NDA Technical Support

Paul Gomez CTAC/CBFO, Observer6

6.1 Acceptable Knowledge (AK)

The EPA inspection team evaluated a single retrieva bly-stored soil waste stream, identified as OR-NFS-CH-SOIL and described in the AK Summary (AKS) , Revision 3, dated August 11, 2008. ORNL-CCP provided this revision of the AKS t o EPA prior to the inspection as the most

recent revision to serve as the basis for this eval uation. Revision 4 of the AKS dated May 2009 was provided by the AKE at the beginning of the eva luation, and this revision introduced a new

soil waste stream from a burial trench at NFS. How ever, EPA did not include the NFS burial trench waste stream in its evaluation, and therefor e it is not part of this approval. This NFS burial trench soil waste stream is subject to a T1 change approval request, as indicated in Table 1 of this report.

EPA’s approval of this T1 evaluation included revis ing the T1 and T2 elements that were assigned in the ORNL-CCP baseline inspection final report, as stated previously (see Table 2). Accordingly, all of the T2 elements listed under AK in Table 1 of this report apply to all approved CH waste streams and SCGs at ORNL-CCP. In dividual T2 designations for this T1 evaluation are not specified in this report, nor ar e they listed at the end of each of the AK sections, as was done in the baseline inspection fi nal report.

This soil waste stream was generated at the NFS in E rwin, Tennessee, and is composed of soils that were excavated from below the NFS Building 234 Wet Chemistry Cell. It includes a few

drums of soil that were excavated from an area arou nd the Building 110 laboratory underground

waste tank. Revision 3 of the AKS states that Wast e Stream OR-NFS-CH-SOIL contains 529 55-gallon drums, the majority of which were origina lly packaged at NFS from February 1993 to October 1994. Some soil from operations in 1993 re mained in Building 234 and was not shipped to ORNL. This soil was subsequently packaged at NF S in 2001 and shipped to ORNL in 2005. EPA evaluated the adequacy of AK information that s upported these retrievably-stored CH TRU soil/gravel wastes from the S4000 SCG, as described below.

Documents Reviewed

EPA inspectors examined a variety of documents rela ted to AK, and they are listed below:

• CCP-QP-002, CCP Training and Qualification Plan, Re vision 27, September 30, 2008

• CCP-AK-ORNL-001, CCP Acceptable Knowledge Summary R eport for Nuclear Fuel

Services Contact-Handled Transuranic Waste Stored a t Oak Ridge National Laboratory. Waste Stream: OR-NFS-CH-SOIL, Revision 3, August 1 1, 2008

• CCP-AK-ORNL-001, CCP Acceptable Knowledge Summary R eport for Nuclear Fuel

Services Contact-Handled Transuranic Waste Stored a t Oak Ridge National Laboratory. Waste Stream: OR-NFS-CH-SOIL, Revision 4, May 26, 2009

• CCP-TP-005, CCP Acceptable Knowledge Documentation, Revision 18, with Sample Attachments, November, 16, 2006

• CCP-TP-005, Attachment 1, Acceptable Knowledge Docu mentation Checklist, Revision 18, July 13, 20097

• CCP-TP-005, Attachment 4, Acceptable Knowledge Sour ce Document Reference List (Included in the AK Summary Report: CCP-AK-ORNL-001 ), July 13, 2009

• CCP-TP-005, Attachment 6, Waste Form, Waste Materia l Parameters, Prohibited Items, and Packaging, Revision 18, July 13, 2009

• CCP-TP-005, Attachment 6, Memorandum from Jeff Harr ison, CCP AKE, to Records, Waste Material Parameter Analysis for Waste Stream OR-NFS-CH-SOIL, NFS ContactHandled Transuranic Soil Stored at ORNL, June 27, 2 008

• CCP-TP-005, Attachment 7, Radionuclides (Radiologic al Characterization or NDA Memorandum), Revisions 1, 2, and 3 dated January 7, 2008, July 2, 2008; May 26, 2009

• CCP-TP-005, Attachment 8, Waste Containers List, Re vision 18, June 2, 2009

• CCP-TP-005, Attachment 10, Acceptable Knowledge Re- Evaluation Checklist, January 8, 2009

• ORNL-AK Tracking Spreadsheet, print out August 10, 2009

• CCP-QP-002, CCP Training and Qualification Plan, Re vision 25, May 8, 2007

• Draft Waste Stream Profile Form for Waste Stream OR -NFS-CH-SOIL and Characterization Information, for audit purposes on ly, undated and provided August 11,

2009

• Qualification Card for Jeff Harrison provided Augus t 11, 2009 and Addendum, Required Reading List provided list up to August 12, 2009

• CCP Internal Surveillance Report for Transmittal an d Closure of the WTS Quality Assurance Audit 109-06, August 5, 2009

• Inter-Office Correspondence, from R. P. Kantrowitz to D. K. Ploetz, Acceptable Knowledge Accuracy Report for Oak Ridge National La boratory Waste Stream Number OR-NFS-CH-SOIL, prepared for audit purposes only, p rovided August 11, 2008

• NCRs ORNL-0642, 0644, 0646, 0647, 0648, 0650, 0661, 0664, and 0665 (08), provided August 11, 2008

• C099, Letter to Harold Johnson, CBFO DOE re: KAPL- NFS Transuranic Waste Background Information, May 3, 2005

• C100, Interview with Richard Booth and Faxed defens e and waste information for NFS, Erwin, TN TRU waste, February 4, 2005 – NFS Proprietary, Not Approved for Public

Release

• C122, Building 234 Characterization Results, Memora ndum to Heather Little, DCM-03- 18, 44T-99-0436, GPC-99-013; September 30,1999 – NFS Proprietary, Not Approved

for Public Release

• C200, Internal Correspondence from J.A. Chapman, RE : On the Use of Rad-Sorb in NFS TRU Waste Drums, dated May 26, 1993

• C210, Record of Communication, Re: NFS TRU Waste S hipped to Oak Ridge National Laboratory, September 12, 20078

• DR002, CCP-TP-005, Attachment 11, Acceptable Knowle dge Source Document Discrepancy Resolution (EPA Hazardous Waste Number Assignment), Revision 0, September 21, 2007 and Revision 1, November 1, 2007

• DR006, CCP-TP-005, Attachment 11, Acceptable Knowle dge Source Document Discrepancy Resolution (Physical form of NFS-0016 an d NFS-0929), November 30,

2007

• DR010, CCP-TP-005, Attachment 11, Acceptable Knowle dge Source Document Discrepancy Resolution (Incorrect Waste Stream Assi gnment of Soil Waste Containers (Physical form of NFS-0016 and NFS-0929), January 12 , 2009

• I053 KAPL-TN Waste Profile for NFS Building 234 Soi l, Document 44G-03-1050, WST-20, JWP-03-009, September 11, 2003

• M003, ORNL UNC-2109 and UNC-2822 Forms for NFS TRU W aste and Related Paperwork, undated (various dates)

• M011, Material Safety Data Sheets for Products Used at NFS, undated

• M012, EM Waste Database Query, August 9,2007

• M015, Process Knowledge (PK) Documentation for Buil ding 7920/X-10, R. E. Schreiber, RES-7920-000-002, June 8, 1995

• M052, Logbook for Decommissioning and Volume Reduct ion Facility, December 16, 1990, June 2, 1994

• M075, TWPC Contact-Handled Waste Repackaging Forms, various dates

• M076, Evaluation of Additional Containers for Waste Stream OR-NFS-CH-HET, April 30, 2008

• M128, Evaluation of Additional Containers for Waste Stream OR-NFS-CH-HET, September 5, 2008

• M129, Evaluation of Additional Containers for Waste Stream OR-NFS-CH-HET, September 8, 2008

• M130, Evaluation of Additional Containers for Waste Stream OR-NFS-CH-HET, September 15, 2008

• M132, Evaluation of Additional Containers for Waste Stream OR-NFS-CH-HET, September 24, 2008

• P212, Lattice Experiments with Simulated Burned-Up Fuel for D 2 O Power Reactors, DP1122, February 1968 – NFS Proprietary, Not Approved for Public Release

• P218, Oak Ridge National Laboratory/Nuclear Fuel Ser vices Inc. NFS Waste Parameter Verification Program, October 29, 1992

• P248, Structural Assessment of Building 234, DCM-03 -18, 44T-99-0450, SS-99-002, November, 1999

• P251, Box Breakdown Area Operations, CH-P-OP-003, R evision 7, March 13, 20079

• P254, Contact Handled Waste Repackaging, CH-P-OP-01 3, Revision 6, April 30, 2007

• P255, Contact Handled Waste Acceptance Criteria, T- CH-FW-X-AD-001, Revision 5, October 19, 2006

• P268, ORNL WAC for Contact Handled Transuranic and Mixed Oxide Wastes from Nuclear Fuel Services, Inc., WMRA-WMPC-106, October 16,1992

• P269, ORNL WAC for Contact Handled Transuranic and Mixed Oxide Wastes from Nuclear Fuel Services, Inc., WMRA-WMPC-106, October 16, 2002

• P273, Nuclear Fuel Services, Inc., Waste Certificat ion Plan for Transuranic Waste, 28G91-001, Revision 0, July 1991; DCM-03-05-Revision 0 , July1991 and Revision 1, February 1992

• P283, Plutonium Facilities Decommissioning Project Plan Condition Addendum, SNF124, Chapter 7, Appendix B, Rev.2, April 28, 1989

• P300, Operation of the Decontamination and Volume R eduction Facility, DCM-08,

1990–1992 – NFS Proprietary, Not Approved for Public Release

• P315, We Cell Soil Excavation and Mixing, DCM-61, J uly 5, 1993 – NFS Proprietary, Not Approved for Public Release

• P321, Determination of Plutonium Isotopics for Buil dings 110 and 234, April 28, 1992

• P323, Status of Former Mixed Oxide Fuel and Fabrica tion Facilities at Nuclear Fuel Services’ Erwin, TN Site, 28T-94-003, January 10, 2 004

• P116, EnergX TRU Waste Processing Center Procedure: Absorbing Liquids, CH-I-OP013, Revs 4 and 6, June 27, 2008 and November 17, 20 08

• U016, A Graphical Workbook for Estimating Important Quantities of NFS Radioactive Waste Constituents, March 1, 1992

• U017, The Inter-Comparison of NDA Measurements on C H-TRU Waste Between Nuclear Fuel Services, Inc. and Oak Ridge National La boratory, October 24, 1995

• U043, Final Report- Waste Characterization of Waste Generated from D&D Activity, Buildings 110 and 234 on the NFS Site in Erwin, Tenn essee, January 31, 1992

• U054, Decontamination and Decommissioning of a Plut onium Fabrication Facility. EcoTek, Inc., NFS Plutonium Facilities Decommission ing Project, undated

• U055, Calibration Schemes and measurement Technique s for the Assay of Raschig Rings and Soils, undated

• U058, Oak Ridge National Laboratory/Nuclear Fuel Ser vices Inc., NFS Waste Parameter Verification Program, undated

• PTS Print Outs and Traceability Data (e.g., 2109 fo rms as available) for Drums NFS0104, NFS0282, NFS0324, NFS0585, NFS0812, X10C0506 11541, from References M003, M065, M075, provided August 11, 200910

The containers and Batch Data Reports (BDRs) that E PA examined during this evaluation are

shown in Table 4.

Table 4. Batch Data Reports Examined

Container Number NDE BDR Number NDA BDR Number

NFS0104 OR-RTR6-0074 OR-DWAS-0090

NFS0282 OR-RTR6-0089 OR-DWAS-0104

NFS0324 OR-RTR6-0085 OR-DWAS-0102

NFS0585 OR-RTR6-0098 OR-DWAS-0120

NFS0812 OR-RTR6-0101 OR-DWAS-0126

X10C0506154(L) OR-RTR6-0121 OR-DWAS-0203

AK Evaluation

As stated above, the scope of this evaluation was t o determine inclusion of the retrievably-stored CH TRU S4000 soils/gravel identified as ORNL Waste Stream OR-NFS-CH-SOIL. This waste stream was in CBFO’s T1 change request dated May 20 09.

(1) Data management relative to the S4000 soils/gravel SCG was evaluated and was found to be adequate.

ORNL-CCP uses two primary databases to document AK and characterization information—the Program Tracking System (PTS) and AK Tracking Sprea dsheet. AK Procedure CCP-TP-005 requires development and maintenance of the AK Trac king Spreadsheet that lists containers within each waste stream, as well as container ID, waste stream ID, generation date, vent date/status and changes, and container type. The P TS tracks the characterization status of each container, and the Characterization Tracking System module (CTS) of the PTS tracks nonconformance on a container basis. Additionally, CCP accesses the Oak Ridge Environmental Management (EM) database for information pertaining to individual drums. The ORNLmaintained EM database includes historic AK informa tion, such as the 2109 and 2822 Forms, as well as other information pertinent to individual c ontainers. The database also includes current characterization information. ORNL-CCP personnel s aid while they might use the EM database for information, they are not responsible for inputto or maintenance of this database. ORNLCCP tracks each container’s characterization status , but EnergX is responsible for container movement and storage locations.

As part of overall data management, CCP tracks AK d ocuments within individual AKSs, as well as on CCP-TP-005, Attachment 4, which is a Source D ocument Reference List that includes all references pertinent to all waste streams at ORNL. At other sites, CCP assigns reference numbers on a waste stream basis, so a site may have several “C100” references, where each is specific to a certain stream. At ORNL, CCP decided to assign these reference numbers to a single source document, so the reference number is used only once at the site. This greatly helps the inspection process, as it reduces confusion tha t might stem from several documents having

the same reference number. CCP also indicates that references are sometimes updated, and it is not always clear from the reference lists (referenc e lists in the back of the AK Summaries and11

CCP-TP-005, Attachment 4). EPA recommended that CC P develop a methodology for identifying revision numbers or changes to source d ocuments, to allow clear identification that a

reference has been revised in CCP-TP-005.

(2) AK accuracy was assessed and was found to be adequa te.

A Draft AK Accuracy Report for Lot 1 was provided, which included 15 containers. The document states that of these 15, 7 were found to h ave been incorrectly assigned to this SCG (5 containers were debris and 2 containers were sol ids), and were subsequently reassigned,

which reduced the number of containers in the strea m from 529 to 522. The resulting lot exhibited an accuracy of 41.5%. The AK Accuracy Re port states:

AK identifies U-238 and Pu-239 as the two most prev alent isotopes by weight percent, and 95 percent of the activity over the en tire waste stream is from Am-241, Pu-238, Pu-239, Pu-240, and Pu-241. The pr edominant radionuclides

in most containers in this waste stream will be Pu- 239 and Pu-240. Because of the variability in drum loading, some drums will no t contain the waste stream predominant radionuclides but may contain other rad ionuclides expected in this

waste stream.

The AK Accuracy Report did not indicate an issue wi th regard to 238 U, as AK data indicated that a few containers may contain relatively large quant ities of 238 U by mass, which would dominate the mass-based determination of most prevalent radi onuclides in the AKS. The determination of the two most prevalent radionuclides is required by the DOE-WIPP-02-3122 (WIPP Waste Acceptance Criteria or WAC), although there is no s pecification regarding whether the calculation must be expressed by radionuclide mass or activity. EPA believes that a calculation expressed in terms of activity is more meaningful.

(3) NDA-AK communication was assessed and was found to b e adequate.

AK-NDA communication is formally implemented at all TRU WC sites to ensure appropriate use of AK data. CCP-TP-005 requires the preparatio n of an AK-NDA memorandum, as follows:

Prepare a NDA Memorandum to CCP Records CH waste onl y, evaluating the radionuclide characterization of the waste stream. The NDA Memorandum must include a section for an assessment written with th e NDA EA determining how the AK will be applied during assay. For LANL sealed s ources waste, the NDA

Memorandum must include a section written with the Off-Site Source Recovery (OSR) RCTS. This assessment should include a discu ssion of the limitations of the radiological characterization in the AK documen t and a description of the required assay methods, if any. Any NDA issues for both measured and

calculated radionuclides should be discussed and re solved.

ORNL-CCP provided three versions of the AK-NDA Memo randum (Revisions 1–3), intended to

show the evolution of the NFS waste over time. Rev ision 1 addressed only heterogeneous waste originating at NFS, as well as EPA comments on the version EPA assessed during its October12

2007 baseline inspection. Revision 2 included both soil and the heterogeneous debris. Revision 3 recognized the waste stream change to “H ET-A” (see item 6, AKS).

The AK-NDA memo states that with respect to waste s tream OR-NFS-CH-SOIL, 238 U is the most predominant radionuclide by mass, and 239 Pu is the second most predominant radionuclide by mass based on AK. “However, the two most preval ent radionuclides by mass may turn out to

be Pu-239 and Pu-240 because of the issues with det ecting U-238.” The AK-NDA memo points out that, unlike the debris waste stream, 233 U was reported in NFS waste assay data for 36 soil drums in waste stream OR-NFS-CH-SOIL, including sam ples of soil from several borehole locations throughout the interior and exterior of B uilding 234. The AK-NDA memo states, “One source for this radionuclide is the U-233 purificat ion facility located in Building 234 which was adjacent to the Wet Chemistry Cell. Another source for U-233 is from the removal of the Building 110 underground waste tank.” Another diff erence between the NFS soil and the previously approved debris stream is the presence o f 228 Th, which NFS detected in nearly every

drum in Waste Stream OR-NFS-CH-HET at concentration s of between 5.93E+04 and 2.52E+06 pCi (59.3 nCi and 2520 nCi, respectively). The source of thorium is not identified, and the memo indicates it could be due to spectral interference or natural sources (soil). Note that the plutonium isotopic ratios for the heteroge neous NFS waste, derived through detailed calculation based on input site source Pu and U iso topic ratios, have been retained for the soil

stream. Since the source of contamination for the soil and heterogeneous waste streams is the same, application of the same isotopics appears app ropriate. EPA examined the development of isotopic ratios for the heterogeneous waste stream and found them to be well substantiated, so a second detailed examination of the same isotopic ra tio development was not warranted for the

soil stream.

(4) Load management was examined and was found to not a pply for CH TRU wastes at ORNL-CCP, as was determined during the baseline ins pection.

During this evaluation, the ORNL-CCP AKE indicated that load management will not be performed at the site.

(5) The AK Summary for Waste Stream OR-NFS-CH-SOIL, as presented in CCP-AKORNL-001, Revision 3, was assessed and was found to be adequate. NFS burial tranch waste added in Revision 4 of CCP-AK-ORNL-001 is exp ressly not included in this evaluation as explained below.

The AK Summary for Waste Stream OR-NFS-CH-SOIL is i ncluded in CCP-AK-ORNL-001, Revision 3, dated August 11, 2008. This was presen ted to EPA as current and most representative of this document, and EPA used this version as the basis for this evaluation. The AKS includes information that is general and also s pecific to heterogeneous debris stream ORNFS-CH-HET generated at NFS, with detailed discussio ns about the soil and debris waste streams. This approach is satisfactory.

The AKS indicates that the soil waste stream is com posed of soil generated through decontamination and decommissioning (D&D) of Buildi ng 234 and the waste tank associated with the Building 110 Laboratory. D&D occurred in 1993–1994, and the majority of these13

drums were shipped to ORNL. Some of the soil was n ot drummed until 2001, and was shipped

to ORNL in 2005. ORNL-CCP indicated that there wer e:

....five high-density polyethylene High Integrity Con tainers [HICs] (packaged in five B25 boxes) containing soil from the same excav ation activity that were packaged at NFS in 2005. This soil will be evaluat ed for possible inclusion in this waste stream after the waste is repackaged into 55- gallon drums at the TWPC (Reference M003). The soil in these containers rep resents approximately 13.4 m 3
of waste. Another B25 box (X10C0506154) containing soil and debris has been repackaged at the TWPC. This repackaging activity produced 25 drums of debris and 5 drums containing mostly soil (Reference M075) . These five drums will also be evaluated for possible inclusion in this waste s tream at a later date.

During this evaluation, EPA was provided a more rec ent AKS, Revision 4, dated May 26, 2009. Revision 4 was prepared primarily because ORNL-CCP identified admixed soil in heterogeneous containers that contained tetrachloroethylene (TCE) , a single hazardous constituent specific to the soil waste. While the heterogeneous debris was not reassigned to a different SCG, because it was still greater than 50% soil, the soil admix in this waste stream imparted a new chemical characteristic to the heterogeneous waste stream. Rather than modify the waste stream summary,

ORNL-CCP elected to discontinue the “HET” stream an d create a new HET-A” stream that was identical to the original HET stream, with the exce ption of the inclusion of lesser quantities of soil that contained TCE. ORNL-CCP representatives indicated that the original “HET” stream did not contain the soil admix, so it was appropria te to create the second waste stream. The radionuclide composition of the waste stream was no t modified, although the physical composition was changed to include a small portion of admixed soil. In addition to the “HETA” designation, CCP-TP-005, Revision 4 included a r evision to the soil waste stream to include the 5 HICs (packaged in five B25 boxes) and the X10 C0506154 Box, as well as waste soil from

an NFS burial trench.

EPA was not provided the revised AKS until the Augu st 2009 evaluation in Golden, CO. Upon examination, EPA found that the original HICs were generated at the same time as the remaining soil drums, but were not included in the waste stre am initially, because ORNL anticipated that the HICs would contain low-level waste (LLW). Howe ver, recent ORNL-CCP assays indicated that at least some of the repackaged soil would be TRU waste, meaning that Box X10C0506154 may ultimately be included in this waste stream. E PA was not provided this information prior to the inspection, nor was sufficient information prov ided during the August evaluation regarding the trench soil to approve its inclusion in Waste S tream OR-NFS-CH-SOIL. Accordingly,

addition of soil from the NFS burial trench soil to Waste Stream OR-NFS-CH-SOIL is a T1 change. (See Table 1, where this is included as a T 1 change).

(6) The definitions of the Waste Stream and Waste Strea m Profile Form (WSPF) were evaluated and were found to be adequate.

The WIPP Waste Analysis Plan (WAP) and WAC define a waste stream as: “waste material generated from a single process or from an activity which is similar in material, physical form,

and hazardous constituents.” Waste Stream OR-NFS-C H-SOIL consists of soil with RADSORB14

admix and a RADPAD at the top of each drum. ORNL-C CP has characterized the waste stream as RCRA-hazardous waste under 40 CFR Part 261, Subp art C, based on the presence of organic

constituents.

Waste Stream OR-NFS-CH-SOIL was generated during de commissioning of Building 234 and the removal of the Building 110 laboratory undergro und waste tank. This waste tank was a 55-gallon drum buried underground. Production oper ations stopped in 1973 within Building 234, and decommissioning was initiated in the early 1990s. The majority of the soil was generated from excavating under the Building 234 We t Chemistry Cell that performed nitric acid dissolution and mixing of Pu and depleted uranium ( DU) or low-enriched uranium (LEU). The floor of the Building 234 wet cell was breached alo ng a wall and sump, providing a transport pathway for material from the cell to the underling soil column. Soil was excavated to about 6 feet below grade, and excavated soils were placed on a conveyor and transferred from the Wet Chemistry Cell where they were blended in a mixer w ith added RADSORB (10 lb/drum). Soil was then placed in a drum and a RADPAD was placed o n top of the drummed soil. ORNL-CCP

states that:

The purpose of soil mixing was to break up and homo genize the clay, add RADSORB absorbent powder to the soil to prevent the formation of liquid, and to blend soils with plutonium contamination that would otherwise exceed 128 grams Pu-239 fissile gram equivalent (FGE) in compliance with ORNL Waste Acceptance Criteria.

In addition to Building 234, soil associated with c leaning up Building 110 Wet Chemistry and Spectographic Laboratories underground was also tra nsported to and mixed in the same facility. When queried, ORNL-CCP representatives indicated th at there was no information to suggest that Building 110 soils were drummed separately, an d data examined indicated that this soil was mixed with Building 234 soils. ORNL-CCP indicated that there was no way to distinguish between drums containing soil from only Building 23 4 or Building 110, as both areas were processed using the same equipment and were mixed d uring the drumming packaging.

EPA reviewed the methodology and supporting AK docu mentation that ORNL-CCP used to define the waste stream in terms of physical form; radiological characteristics; chemical usage and potential hazardous materials; ignitable, corro sive, and reactive contents; Polychlorinated biphenyls (PCBs); pyrophoric constituents; toxicity for organic compounds; and prohibited items, as well as the ability of the site to segreg ate them from the waste stream. EPA found that waste stream OR-NFS-CH-SOIL as presented in CCP-AK- 500, Revision 3, was appropriately

defined.

CCP uses the “add container” memoranda to document the addition of drums to a given waste

stream. Since Revision 4 includes more containers than considered by EPA through review of Revision 3, these memoranda are necessary to unders tand why containers were added. In the future, when ORNL-CCP/CBFO submits a T1 change requ est for soils from NFS burial trench,

the “add container” memoranda and revised AK-NDA mem oranda need to be made available to EPA as part of the request, along with other releva nt documents.

(7) The use of Quick or Fast Scan was examined and foun d to be adequate.15

The ORNL-CCP AKE indicated that ORNL-CCP performs a fast scan of containers using internal process and procedures to screen container s for the presence of prohibited items, WAC requirements, and other elements, including non-WIP P-related requirements. The data are used to release containers to CCP, who performs one-hund red percent RTR on containers. Although these results are not currently in the AK record, E PA believes that this information should be integrated to ensure availability of potentially im portant data on containers as they are processed. EPA also believes that ORNL-CCP should reference Qu ick or Fast Scan records and make them available as part of the AK Record. This is important, because these are either charact erization actions that must be used to calculate AK accuracy, or they are AK documents that must be

included in the record and considered for documenti ng AK-AK discrepancy resolution. EPA may examine AK accuracy calculations and Fast/QuickScan results to see whether the ORNLCCP considers Quick/Fast Scan results in AK-AK disc repancy resolutions or accuracy

calculations.

(8) Staff training was examined and was found to be ade quate.

Qualification and training of CCP personnel is impl emented through CCP-QP-002, CCP Training and Qualification Plan . Training records for the CCP AKE, Jeff Harrison, were examined, including the AK Qualification Card and A ddendum, as well as a list of required reading that had been accomplished up to August 10, 2008. Mr. Harrison had performed required reading pertinent to applicable portions o f the WIPP WAP and WAC, State and Federal hazardous waste regulations associated with solid a nd hazardous waste characteristics, and sitespecific WC procedures for confirming AK and genera ting data for radiological and physical contents of the TRU waste. However, this training was based on old versions of the WAP and WAC, and records did not indicate that the AKE had been retrained with respect to recent

versions of the WAP and WAP.

Furthermore, CCP in general, does not incorporate r esults of DOE’s Performance Assessment which became the basis for EPA WIPP regulations (i. e., Compliance Certification Requirements) specifically into CCP’s TRU WC personnel training p rogram. EPA has repeatedly requested that the program be modified to incorporate these requir ements, particularly since the second Recertification Application (which EPA is currently reviewing) could directly affect characterization requirements. EPA discussed this with CCP Lead during the inspection and they agreed that the training program could be impr oved with regard to EPA requirements. EPA committed to provide CCP with materials that could be used in such a training program.

(9) Drum traceability and the ability to follow the AK WC process for specific containers

and waste streams were assessed and were found to b e adequate.

EPA selected six containers for which BDRs and hist oric traceability data were provided: NFS0104, NFS0282, NFS0324, NFS0585, NFS0812, and X10C 0506154(L) (the last was a repackaged drum from a larger box). Historical dat a provided for the drummed waste included the 2822/2109 Forms, NFS NDA data sheets, TRU Waste Package Data, various checklists for ORNL drum receipt, NFS shipment information and num ber, drum-specific procurement quality16

surveillance plans(s), waste certification checklis t, and WEAF 1 data entry/analysis. In addition to these documents specific to the individual drums , ORNL-CCP also provided other historic information including, but not limited to, WEAF Was te Acceptance Reports, Storage of Disposal of Radioactive Waste Tracking Update forms, and dat a log sheets for packaging TRU waste.

These data are contained in references M003 and M06 5. With respect to the repackaged drums, ORNL-CCP provided information for drums packaged fr om two larger boxes; X10C0506154(L) that was repackaged from Box X10C056150, and X10C05 6150(A) that was repackaged from Box X10C056150. ORNL-CCP provided the BDR for 6154 (L), as well as the 2109 Forms, Radioisotope Continuation Sheet, and Radwaste Packa ge Certification Record and other information for both boxes. The EnergX Contact-Han dled Waste Repackaging Data Forms were provided for each repackaged drum. ORNL-CCP demons trated that abundant information was available for the selected containers and adequatel y demonstrated traceability.

(10) Limitations and exclusions associated with the AK r ecord were assessed and were found to be adequate.

Every AK Source Document has an associated Attachme nt 3 – Record of Communication that includes an area to list or identify AK data limita tions. Each of the examples provided either

listed a limitation or stated that there were no li mitations.

(11) AK-AK and Measurement-AK discrepancy resolutions an d NCRs were examined and were found to be adequate.

ORNL-CCP prepared two AK-AK discrepancy resolutions , DR006 and DR010, pertinent to this waste stream. DR006 addressed the misassignment of a drum with respect to its SCG and the potential misidentification of a drum that may cont ain compacted waste. A report entitled, "ORNL TRU Waste Historical Survey," indicated that container No. NFS-0929 contained waste grouted in 2 liter bottles, which indicated SCG S30 00, homogeneous waste. Review of the WEAF RTR indicated that the drum contained predomin antly debris waste, which would reassign the drum to SCG S5000. Drum NFS-0116 was d escribed in historical paperwork as containing raschig rings, but a logbook implied tha t a compacted puck was placed atop the rings.

Examination of WEAF RTR showed there to be a crushe d bucket atop the raschig rings, but it was unclear whether the bucket was machine-compacte d, so the drum was retained in the HET stream pending future RTR results.

DR010 addressed the misidentification of seven drum s by AK. DR010 states that AK identified 7 drums as S4000 soil, but RTR determined that 5 of the drums (NFS0821, NFS0839, NFS0840, NFS0927, and X10C0506047) were predominantly S5000 d ebris waste and 2 of the drums (NFS0816 and NFS0817) were predominantly S3000 absor bent. This misidentification was captured on CCP-TP-005 Attachment 10, the Acceptabl e Knowledge Re-Evaluation Checklist, which documents assignment and disposition of these containers.

ONRL-CCP also provided several Non Conformance Repo rts (NCRs) pertaining to the soil waste stream. Many of the NCRs were issued because RTR found prohibited quantities of liquids in the containers. For example, NCRs were prepared when a drum was assigned to a

1 WEAF is the Waste Assay and Examination Facility a t ORNL.17

different SCG as in NCR-ORNL-0664-08 and NCR-ORNL-0 665-08, both of which address reassignment of waste from a soil to debris SCG bas ed on RTR. These changes are within the “L” trend group and EPA may examine “L” trends in t he future to determine whether assigning L trend codes would require a tier assignment.

(12) Defense origin of waste was verified.

The WAC requires generator sites to use AK to deter mine if the TRU waste streams to be disposed at WIPP meet the definition of TRU “defens e” waste. TRU waste is eligible for disposal at WIPP if it has been generated in whole or in part by one of the atomic energy defense activities listed in Section 10101(3) of the Nuclear Waste Policy Act of 1982. According to the site, the basis for the “defense” nature of waste s tream OR-NFS-CH-SOIL is that Building 234 performed mixed oxide (MOX) fuel fabrication and 233 U purification under subcontracts to two government contracts administered by the U.S. Atomi c Energy Commission (AEC) and two smaller commercial contracts. The two larger contr acts were national defense-rated orders, which were designated DO-E2 certified for national defense use under Defense Material System, Regulation 1. The defense and commercial activitie s utilized the same process equipment, so the source of contamination is indistinguishable. Ther efore, ORNL-CCP contends that the TRU wastes from decommissioning are linked primarily to defense nuclear material production. This

is the same rationale used for ORNL Waste Stream OR -NFS-CH-HET, which was previously approved by EPA.

(13) AK information pertaining to radiological character istics of waste was examined and was found to be adequate.

AK data presented in the Waste Stream CCP-AK-ORNL-0 01 AKS, Revision 3, and the AKNDA memo, as well as various supporting documents, w ere examined to understand the radiological characteristics of Waste Stream OR-NFS- CH-SOIL. Essentially, ORNL-CCP indicated that the isotopic distributions for Pu an d U used for OR-NFS-CH-HET wastes were applicable to soils, because Waste Stream OR-NFS-CH -SOIL was created when the same liquid waste that contaminated heterogeneous debris leaked through the Wet Cell in Building 234 to the underlying soil column. However, ORNL-CCP also sta ted that additional radionuclides, such as

Natural Thorium and 233 U, were present exclusively in soil and not in debr is. EPA assessed the similarities and differences with respect to the so il’s radiological characteristics.

CCP-AK-ORNL-001 states that waste within the stream was generated through D&D of Building 234 and removal of underlying soils. Buil ding 234 was used for production and other activities related to MOX fuels, and a portion of t he building was used as a 233 U purification process facility. The portion of the building that was used for 233 U was decommissioned in 1983,

and while the OR-NDF-CH-HET waste stream did not co ntain debris contaminated with 233 U, soil underlying the building was not removed when t he 233 U purification area was decommissioned. Therefore, soil underlying Buildin g 234 was expected to contain 233 U, which was verified by NFS assay. ORNL-CCP stated:

U-233 was reported in NFS waste assay data for 36 s oil drums (0.1 grams U-233 is the largest mass reported in a single soil drum) (References M003, M012). U-233 was also identified in samples of soil from s everal borehole locations18

throughout the interior and exterior of Building 23 4 (References C122, I053). One source for this radionuclide is the U-233 purif ication facility located in Building 234 (References C122, C210, I053, P248, P2 83). Another source for U-233 is from the removal of the Building 110 under ground waste tank since the Building 110 laboratory also handled U-233 (Referen ces C210, U055).

As discussed in items (5) and (6) above, inclusion of Building 110 soil in Waste Stream ORNFS-CH-SOIL is supported by the available informatio n.

ORNL-CCP stated that some of the soil that was prev iously identified as LLW remained in Building 234 and was not shipped to ORNL with the d rums generated during the initial D&D events. This soil was packaged in 2001 and assayed on the NFS VAGAS 2 system, and contained measurable natural thorium, i.e., 228 Th and 232 Th (References M003, M012), that was not identified in debris. ORNL-CCP states that the pre sence of 228 Th and 232 Th may be “due to spectral interference from background radiation. U nlike debris waste, soils are more likely to

contain natural thorium. This is consistent with al pha spectroscopy results for soil from the Building 234 Wet Chemistry Cell area (Reference I05 3).” EPA examined many of the cited

references and verified that thorium has been ident ified in NFS soil. However, ORNL-CCP did not provide any references explaining the origin of the thorium or 233 U, sometimes calling upon potential contaminant migration from offsite source s as a contributing factor to the chemical or radiological make-up of soils. EPA indicated that since more D&D waste and soils are being approved, ORNL-CCP must ensure that all arguments c oncerning natural, background, or offsite sources of radionuclides are fully referenced and s upported. For example, if a chemical or radiological component is thought to have migrated to the soil, the contaminant migration pathways and specific source terms should be identi fied. ORNL-CCP should consider radionuclide partitioning that may take place in th e soil column, as this may affect the actual presence or absence of radionuclides within the soi l. It cannot always be assumed that the

radionuclides within a release would be retained in the same distribution in the soil column, due to differences in radionuclide mobility. EPA discu ssed this with ORNL-CCP representatives and they stated that in the future, they will evaluate waste streams in this regard, as appropriate.

Although 233 U and thorium were apparently unique to soil, the P u and U isotopic distributions were common to both the soil and debris originating from Building 234 D&D, because the source of Pu and U (other than 233 U) present in both streams had a common origin. Bu ilding 234 managed and performed MOX fuel-related activities f rom four different contracts. ORNL-CCP indicates that the radiological composition shown i n Table 5 is applicable to both the OR-NFSCH-HET and OR-NFS-CH-SOIL waste streams:

Table 5. Mixed Oxide Fuel Compositions

Contract Pu Percent U Percent Pu (kg) U (kg) Total (kg) SEFOR 20 80 746 2,984 3,730 Consumers 2.27 97.9 47 2,027 2,070.48 SRS 0.31 99.7 16 5,064 5,079.37

Halden 0.5 99.5 3 117 120

Total - - 812 10,192 11,000

2 VAGAS is the Versatile Automated Gamma Assay Syste m NDA system used at NFS.19

These data show that uranium dominates the mass of radiological material within each material. Fuels generated for the various sites/contracts had specified isotopic distributions, as presented in Table 6, and are applicable to both the SOIL and HE T waste streams.

The AK Summary states that TRU soil waste was assay ed multiple times on different systems, including the VAGAS at NFS and the APNEA 3 at the ORNL WEAF. ORNL-CCP representatives indicated that the NFS data were in cluded in the EM database, and the EM database was used to develop the general isotopic r anges expected for various radionuclides, as presented in Table 6-4 of CCP-AK-ORNL-001, which is reproduced here as Table 7.

Table 6. Mass Isotopic Distributions of Mixed Oxide Fuels by NFS Contract

Radionuclide SEFOR Consumers SRS Halden

238 Pu 0.01 0.04 0.01 0.43 -- -- 0.01 0.29

239 Pu 18.13 90.63 1.73 76.24 0.29 90.94 2.00 79.89

240 Pu 1.67 8.33 0.37 16.34 0.02 7.99 0.36 14.51

241 Pu 0.10 0.48 0.07 2.91 0.003 0.99 0.06 2.24

242 Pu 0.01 0.05 0.03 1.1 0.0002 0.08 0.02 0.83

241 Am 0.09 0.47 0.06 2.86 -- -- 0.06 2.20

Total 20.0 100 2.27 100 0.31 100 2.5 100

234 U 0.12 0.15 0.58 0.59 0.001 0.001 3.90 4.00

235 U 0.28 0.35 2.36 2.41 0.30 0.30 4.88 5.01

238 U 79.60 99.50 94.96 97.00 99.40 99.69 88.73 91.01

Total 80.0 100 97.9 100 99.7 100 97.5 100
NOTE: For each of these materials, the first colu mn represents the overall mass fractions of the MOX fuel, and the second column provides the mass fract ions of the fuel’s plutonium and uranium constituen ts separately.

Table 7. Waste Stream OR-NFS-CH-SOIL Radiological Characterization

Radionuclide Total

Radionuclide

Wt% 1 Radionuclide Wt%

Range for Individual

Containers 2 Total

Radionuclide

Ci% 3 Radionuclide Ci%

Range for Individual

Containers 4 Suspected To

Be Present (Yes/No)

WIPP-Tracked Radionuclides

Am-241 0.12% 0.00%

- 2.86% 7 4.79% 3.02%

- 18.38% Yes 6

Pu-238 Trace 5 0.00%

- 0.43% 7 1.23% 0.00%

- 10.90% Yes

Pu-239 19.17% 0.59%

- 90.94% 7 13.63% 5.10%

- 52.93% Yes

Pu-240 2.31% 0.06%

- 16.34% 7 6.02% 0.60%

- 38.20% Yes

Pu-242 0.01% 0.00%

- 1.17% 7 Trace 0.00%

- Trace Yes

U-233 Trace 0.00%

- 0.18% Trace 0.00%

- 0.25% Yes

U-234 3.84% 0.00%

- 5.00% 0.27% 0.00%

- 1.06% Yes

U-238 73.42% 0.00%

- 99.69% 7 Trace 0.00%

- 0.03% Yes

Cs-137 Trace 0.00%

- Trace Trace 0.00%

- Trace Yes

Sr-90 Trace 0.00%

- Trace Trace 0.00%

- Trace Yes

3 APNEA stands for Active Passive Neutron Examinatio n Assay NDA system used at WEAF.20

Table 7. Waste Stream OR-NFS-CH-SOIL Radiological Characterization

Radionuclide Total

Radionuclide

Wt% 1 Radionuclide Wt%

Range for Individual

Containers 2 Total

Radionuclide

Ci% 3 Radionuclide Ci%

Range for Individual

Containers 4 Suspected To

Be Present (Yes/No)

Additional Radionuclides

Pu-241 0.06% 0.00%

- 2.91% 7 74.05% 23.56%

- 86.96% Yes

Tc-99 Trace 0.00%

- 0.15% Trace 0.00%

- 0.07% Yes

Th-228 Trace 0.00%

- Trace Trace 0.00%

- Trace Yes

Th-232 0.16% 0.00%

- 22.23% Trace 0.00%

- Trace Yes

U-232 Trace 0.00%

- Trace Trace 0.00%

- Trace Yes

U-235 0.90% 0.28%

- 5.01% 7 Trace 0.00%

- Trace Yes

1 This listing indicates the total weight percent of each radionuclide over the entire Waste Stream.

2 This listing is the weight percent range of each ra dionuclide on a container-by-container basis. Some containers with “0” listed as the lower range, will not contai n the specified radionuclide.

3 This listing indicates the total activity (curie) p ercent of each radionuclide over the entire Waste S tream.

4 This listing is the curie percent range of each rad ionuclide on a container-by-container basis.

5 “Trace” indicates <0.01 weight percent for that ra dionuclide.

6241 Am may be present in slightly larger percentages du e to the further decay of 241 Pu.

7 These weight percent ranges were expanded based on plutonium and uranium isotopic distribution data.

Predominant radionuclides by mass are anticipated t o be 238 U and 239 Pu based on AK data. As determined for the HET waste stream, ORNL-CCP indic ates there are significant uncertainties.

Data in Table 6 indicate that the waste stream is a nticipated to consist primarily of a mixture of U and Pu, with the predominant radionuclides by act ivity being 239 Pu, 240 Pu, 241 Pu, and 241 Am associated with measuring 238 U, and the ORNL-CCP measurement system is not sensi tive enough to detect 238 U, except when it is present in substantial quantit ies. Therefore, while previous systems identified 238 U as a predominant radionuclide by mass, measuremen ts by ONRL-CCP may not identify 238 U, so the predominant radionuclides by mass detecte d by ORNL-CCP may ultimately be 239 Pu and 240 Pu. This lack of instrument sensitivity may result in under-reporting of 238 U.

ORNL-CCP representatives stated that default isotop ics were calculated based on the amount of MOX fuel processed and other characteristics for ea ch material (see the AK-NDA memo for additional details). The isotopics for soil and d ebris are the same, and the decay-corrected

default mass fractions are as follows:

Plutonium% Uncertainty

238 Pu 0.044% 0.0044%

239 Pu 90.837% 9.0837%

240 Pu 8.893% 0.8893%

241 Pu 0.104% 0.0104%

242 Pu 0.122% 0.0122%

241 Am 1.115% 0.1115%

EPA examined the default isotopic calculations when evaluating the HET waste stream and determined that the calculation approach used by OR NL-CCP is reasonable, based on available21

data. Extension of these default isotopics to the soil waste stream is also reasonable, based on

available data.

(14) Identification of Waste Material Parameters (WMPs) and prohibited items were assessed and found to be adequate.

ORNL-CCP addresses WMP calculations in Attachment 6 of CCP-TP-005 and through a June 27, 2008, memorandum in which they state that Waste Stream OR-NFS-CH-SOIL is composed of soil, rock, and gravel mixed with RADSORB, with each drum containing about 10 pounds of adsorbent. A RADPAD (absorbent) pad was placed on top of the soil in each drum prior to drum

closure. ORNL-CCP examined the records for over 50 0 containers and determined that they consisted almost entirely of soils and gravels (84. 9–98.3%), and the remaining material was primarily absorbent (1.5–13.6%). Minor amounts of plastic may be present (less than 1.5%). Examination of the individual drum summaries provid ed with the July 27, 2008, memorandum generally confirmed these ranges, noting that indiv idual drums may exhibit significant weight variations, due to the amount of soil within the dr um.

With regard to prohibited items, ORNL-CCP states th at, “Prohibited items have not been identified in this waste stream.” However, EPA not es that some NCRs have been issued due to the presence of prohibited amounts of liquid that w ere identified via RTR, and ORNL-CCP identified at least one such drum. Accordingly, OR NL-CCP’s statement may require revision to more accurately describe these conditions. ORNL-CC P acknowledged that liquid may have

formed in some drums:

...[due to the] physical nature of this waste and the fact that man y of these drums have been in storage at ORNL for nearly 15 years, i t is possible that liquid may have formed in some drums. Certified RTR and/or VE are performed by CCP to ensure the waste does not contain prohibited items in accordance with the WIPPWAC and WIPP-WAP.

EPA agrees that ongoing characterization, including RTR and repackaging, as necessary, will be used to detect and mitigate the presence of liquids , as evidenced by the issuance of NCRs.

Summary of AK Findings and Concerns

The EPA inspection team did not identify any findin gs or concerns related to AK during this inspection. EPA did make several recommendations t hat are included in the text of each AK item, above, for CCP to consider, as these will be evaluated in future EPA evaluations. There are no open AK issues relative to this T1 evaluatio n.

Tiering Changes

Based on the results of this T1 evaluation, EPA has revised the T1 and T2 designations assigned to AK during the ORNL-CCP baseline approval, as ref lected in Table 1 of this report. There is one new AK T1 change and slight modifications to th e AK T2 elements. All of the T2 elements22

listed under AK in Table 1 apply to all approved CH TRU waste streams and SCGs at ORNLCCP.

6.2 Non Destructive Assay (NDA)

Documents Reviewed

As part of this evaluation, EPA inspectors examined a variety of documents related to NDA, and they are listed below:

• CCP-DWAS/IPAN/SGS-08-001, DWAS IPAN Calibration Vali dation and Confirmation for Extended Passive Mode Operating Range, June 200 8, Revision 0, June 30, 2008

• CCP-DWAS/IPAN/SGS-08-001, DWAS IPAN Calibration Vali dation and Confirmation for Extended Passive Mode Operating Range, June 200 8, Revision 0, June 30, 2008

• CCP-AK-ORNL-001, NDA Memo for Waste Stream OR-NFS-C H-SOIL, July10, 2008

• Draft Waste Stream Profile Form: OR-NFS-CH-SOIL

• MV-SGS0101-CAL-001, Segmented Gamma Scanner-01 (SGS -01-01) Calibration, Confirmation and Verification Report, Revision 0, N ovember 6, 2007 and Revision 1, December 19, 2007

• WASTE CHARACTERIZATION INSPECTION REPORT, FINAL APPROVA L; EPA

BASELINE INSPECTION NO. EPA-ORNL-CCP-CH-11.07-8 OF THE CENTRAL

CHARACTERIZATION PROJECT WASTE CHARACTERIZATION PROG RAM AT THE OAK RIDGE NATIONAL LABORATORY; November 13–15, 2 007

• Calibration Verification Report for the DWAS from F ebruary 11, 2009

• Six DWAS NDA Batch Data Reports: OR-DWAS-0120; OR-D WAS-0126; OR-DWAS0102; OR-DWAS-0104; OR-DWAS-0900; and OR-DWAS-0203

• CCP-TP-168, CCP Drum Waste Assay System Imaging Pas sive/Active Neutron/Segmented Gamma Scanner Data Generation Leve l Validation, Revision 0, October 18, 2007

• CCP-TP-166, CCP Drum Waste Assay System Imaging Pas sive/Active Neutron Operations, Revision 2

• CCP-TP-167, CCP Drum Waste Assay System Imaging Pas sive/Active Neutron Calibration, Revision

NDA Evaluation

(1) The design and operational range of the DWAS were a ssessed and found to have not changed from what EPA had approved previously.

The Drum Waste Assay System Imaging Passive Active Neutron/Segmented Gamma Scanner (DWAS IPAN/SGS) is a multimode NDA system housed in Building 7880-I of the TWPC and23

operated by ORNL-CCP for gamma and neutron-based as says of CH retrievably-stored TRU wastes in 55-gallon drums. The SGS and IPAN compone nts of the DWAS determine the isotopic distribution of 238 Pu, 239 Pu, 240 Pu, 241 Pu, 242 Pu, 241 Am, 235 U, 237 Np, and other radionuclides using Genie 2000 and NDA 2000 software ; and values for 239 Pu effective mass ( 239 Pu EFF ) and 240 Pu effective mass ( 240 Pu EFF ), respectively, operating in both active and passi ve modes. Matrix corrections for the IPAN are expresse d in moderator (MOD index) and/or absorber/moderator (ABSMOD index) for passive and a ctive modes, respectively. Values for other WIPP-tracked radionuclides are qua ntified based on measured values from the SGS, i.e., gamma-based isotopic distribution, or kn own or established relationships (AK-based isotopics) in conjunction with the measured neutron -based quantity. In some cases, radionuclides are quantified by the SGS, and three specific radionuclides are quantified by computational or correlation techniques, i.e., 242 Pu, 137 Cs and 234 U. These aspects of the SGS and IPAN were unchanged from what EPA had inspected and approved previously, and are appropriate for assaying S4000 wastes from ORNL Was te Stream OR-NFS-CH-SOIL.

(2) The applicability of the DWAS calibration to S4000 soils/gravel wastes for the SGS and IPAN components was found to be acceptable.

The DWAS SGS matrix calibration was initially perfo rmed in 1996, and subsequently updated with several additional data to support a matrix de nsity range of 0.0 to 0.72 g/cm 3 for the SGS. This was subsequently extended to 1.72 g/cm 3 via a T1 change evaluation, along with a new upper limit of 220.4 grams total Pu. For the IPAN, EPA’s initial approval for passive neutron was 2.050 g 240 Pu EFF . This was subsequently extended to 72.5133 g 240 Pu EFF via a separate T1 change evaluation, with no changes to the MOD or AB SMOD ranges. The current SGS and IPAN limits adequately cover the density (matrix) an d activity ranges for the S4000 soils/gravel

wastes in Waste Stream OR-NFS-CH-SOIL.

(3) Demonstration of the ability to quantify the WIPP-t racked radionuclides and assign isotopic distributions pertinent to CH TRU wastes f or the density and activity ranges for

the S4000 soils in ORNL Waste Stream OR-NFS-CH-SOIL was evaluated and found to have not changed from what EPA had approved previou sly.

Six DWAS BDRs were evaluated with respect to ORNL-C CP’s ability to adequately document required NDA elements and to provide technical supp ort for NDA reported values. The BDRs were reviewed with respect to containing the follow ing elements:

• Testing facility name, testing batch number, contai ner numbers, and signature of the Site Project Officer (SPO)

• Table of Contents

• Background and performance check data or control ch arts for the relevant time period

• Data validation, as required in CCP-TP-168, CCP Dru m Waste Assay System Imaging Passive/Active Neutron/Segmented Gamma Scanner Data Generation Level Validation

• Separate testing report sheets for each container ( Radioassay Data Sheets or RDS)24

Within each DWAS BDR, the RDSs were evaluated with respect to containing the following

elements:

• Title “Radioassay Data Sheet”

• Method/procedure used

• Date of radioassay

• Activities and associated total measurement uncerta inty (TMU) for individual radionuclides expressed in appropriate units

• TRU alpha concentration expressed in appropriate un its

• Operator signature

• Reviewer signature(s)

Technical review of the DWAS BDRs and RDSs indicate d two issues with respect to the execution and documentation of the neutron componen t of the DWAS daily performance checks. These were discussed with ORNL-CCP personnel and re sulted in EPA issuing two formal concerns; EPA T1 Evaluation Issue Nos. ORNL-CCP-CH- NDA-09-002CR and ORNL-CCPCH-NDA-09-003C, as shown in Attachments B and C to t his report, respectively. Both concerns

are discussed below.

EPA T1 Evaluation Issue No. ORNL-CCP-CH-NDA-09-002C R: Common practice for ORNL NDA control charts is to record only successfu l performance checks and to omit any measurement failures, i.e., values outside of the 3 Sigma Control Limits. Each such failure requires resolution, i.e., calibration verification and a subsequent successful performance check, which overrides the failure, resulting in only the successful performance check value being entered on the control chart. This only occurs at ORNL-CCP. This does not affect the technical quality of the DWAS NDA data evaluated during this T1 evaluation; its effect is limited to the record that documents performance of the DWAS.

Concern Resolution: This concern required a response; however, acceptan ce of the DWAS

BDRs for ORNL Waste Stream OR-NFS-CH-SOIL was not co ntingent upon resolution of this issue. Nonetheless, ORNL-CCP did provide a written response, in which the DWAS data generation level validation procedures (CCP-TP-166 and CCP-TP-168) were revised to remove the requirement for control charts and replace them with performance data sheets that will be included in the DWAS BDRs. EPA accepts this resolu tion.

Status of Concern: This concern is closed.

EPA T1 Evaluation Issue No. ORNL-CCP-CH-NDA-09-003C : ORNL BDR No. ORDWAS-0203 contains a control chart for 240 Pu EFF for the time period of February 1, 2009, to March 3, 2009. The control chart shows three point s that exceed the 3 Sigma Control Limits on February 2, 11, and 19; however, all points were, i n fact, in control. This apparent discrepancy occurs because the 2 and 3 Sigma Warning and Contro l Limits change every week as a result of decay-correcting the 252 Cf source, which has a half-life of 2.6 years. A v alue that is in control at25

the time it was performed may be outside of warning or control limits that were generated at a later time, due to changes in the limits as a funct ion of decay-correcting the 252 Cf source. When

the older value is shown on a control chart with th e newer limits, it appears to be out of control when, in fact, it was not. This is not a technical issue, in that all performance checks that we observed were in control at the time they were perf ormed.

Concern Resolution: This concern did not require a response.

Status of Concern: This concern is closed.

(4) Total Measurement Uncertainty (TMU) of the DWAS for the S4000 soils/gravel in

ORNL Waste Stream OR-NFS-CH-SOIL was evaluated and was found to have not changed from what EPA had approved previously.

(5) The lower limit of detection (LLD) of the DWAS for the S4000 soils/gravel in ORNL

Waste Stream OR-NFS-CH-SOIL IPAN was evaluated and was found to not have changed from what EPA had approved previously.

Summary of NDA Findings and Concerns

EPA did not identify any findings relative to this T1 evaluation. EPA did identify the two concerns discussed above, and they are included in Attachments B and C to this report. Concern

No. ORNL-CH-NDA-09-002CR required a response, which ORN L-CCP provided and which EPA evaluated and found adequately addressed the co ncern. Concern No. ORNL-CH-NDA-09-

002CR is closed and Concern No. ORNL-CH-NDA-09-003C does not require a response. Th ere are no open issues related to NDA for this T1 evalu ation.

Tiering Changes

Based on the results of this T1 evaluation, there a re no changes to the T1 and T2 designations assigned to NDA during the ORNL-CCP baseline approv al.

6.3 Real-Time Radiography (RTR)

RTR Evaluation

(1) The RTR operating procedure was reviewed and was fo und to be adequate.

RTR operations are performed as directed in CCP Pro cedure CCP-TP-053, Revision 6, CCP Standard Real-Time Radiography (RTR) Inspection Pro cedure. This is a well-established procedure containing adequate instructions and dire ctions to generate and process RTR data. EPA did not identify any concerns with this procedu re.

(2) Training for RTR personnel was evaluated and was fo und to be adequate.26

EPA reviewed training Qualification Cards for five RTR operators and Demonstration of Capability records for three RTR operators. The Qu alification Cards for all operators were complete and EPA did not identify any concerns asso ciated with these records.

ORNL-CCP provided EPA with inventories for Training Drum Nos. ORNL-NDE-TEST-007, ORNL-NDE-TEST-008, ORNL-NDE-TEST-009, ORNL-NDE-TEST-0 10, and ORNL-NDETEST-011. All training drums were constructed to c hallenge and demonstrate operators’ ability to identify items typically found in S5000 (debris) and S4000 (soil) waste. Each training drum included at least five non-WAP-required items, and Training Drum No. ORNL-NDE-TEST-007

contained nine such items. EPA reviewed both the w ritten and A/V records for one RTR operator’s Capability Demonstration and written rec ords for two RTR operators on Training

Drum No. ORNL-NDE-TEST-007. From review of these re cords, EPA identified items that were missed by all operators. EPA summarized the r esults in Table 8:

Table 8. Summary of RTR Operators Performance on Tr aining Drums

Training Drum No. ORNL-NDETEST-007 Contents, June 18, 2008 Operator SE

Written Record Operator SB

Written Record Operator LS

Written and A/V Record

Soil OK OK OK Horse tail bag of Tyvek coveralls Missed in horsetail bag Missed in horsetail bag Missed in horsetail bag

Cardboard OK OK OK Horsetail bag of Raschig rings Missed in horsetail bag Missed in horsetail bag Missed in horsetail bag Horsetail bag with rubber hose and paint brush Found hose and paint brush, but missed them in a horsetail bag Found brush and “tygon” tubing. Missed that these were in horsetail bag Missed hose and in horsetail bag Orally identified a paint brush,

but did not record on data sheet
Plastic labware Missed (glass labware identified) Missed (glass labware identified) Missed (glass labware identified)
Rubber hose OK “tygon tubing” OK Horsetail bag with paper Found horsetail bag, but missed paper in bag Found horsetail bag, but missed paper in bag Found horsetail bag, but missed paper in bag
Electrical cord OK OK OK

All operators failed to identify some items, and op erator LS identified the paintbrush orally, but

did not include it in the written record. Furtherm ore, the Subject Matter Expert (SME) neither recognized nor recorded these errors as required by CCP-QP-002, Training and Qualification

Plan , Revision 26, Attachment 3, CCP Capability Demonstration Data Sheet for Contact

Handled Waste . This was discussed with ORNL-CCP RTR personnel, and EPA generated Inspection Issue No. ORNL-CCP-CH-RTR-09-001CR, whic h required a response. It is included in Attachment A to this report and is discussed bel ow:

EPA T1 Evaluation Issue No. ORNL-CCP-CH-RTR-09-001C R : Review of recordings of Demonstrations of Capability examinations performed on Test Drum ORNL-NDE-TEST-007 on June 19, 2008, showed that operators missed some of the non-WAP items included, as summarized in Table 8. Furthermore, the SME, who c hecked the Demonstration of Capability recordings, did not identify these errors. This is a repeat concern, the original being written during the ORNL CH baseline inspection.

Concern Resolution: This concern required a response; however, acceptan ce of RTR for the S4000 soils/gravel SCG was not contingent upon reso lution of this issue. Nonetheless, ORNLCCP did provide a written response, in which they a greed with EPA’s concern. CCP committed27

to provide appropriate training to all RTR and Vend or Project Manager (VPM) qualified personnel to emphasize the importance of identifyin g all items in the RTR training drums. This response adequately addressed EPA’s concern and thi s issue is closed.

Status of Concern: This concern is closed.

For the sake of completeness, the original concern from ORNL CH Baseline Inspection No. EPA-ORNL-CCP-CH-11.07-8 is provided below and is in cluded in the Additional Comments

section of concern ORNL-CCP-CH-RTR-09-001C in Attac hment A.

EPA Inspection Issue No. ORNL-CCP-CH-RTR-09-004C : In the capability demonstration training containers, the EPA inspector noted that w hile all the required items (prohibited items) were identified correctly by all RTR operators, som e additional items (cellulosics and plastics) were not identified. All cellulosics and plastics in the training drum need to be identified and their identification documented. To complete the t raining process, it is critical that the operator receives feedback regarding missed items. More det ailed documentation of the feedback given is needed when the results of the training drum are re viewed.

EPA reviewed the written records for the remaining four Training Drums and found that all items were correctly identified, but all operators failed to recognize that certain items were contained in plastic bags. It should be noted that the non-WAP items in these drums were significantly different to those in Training Drum N o. ORNL-NDE-TEST-007.

(3) Written and audio/visual records for containers wer e reviewed and were found to be adequate.

EPA reviewed selected BDRs for containers from Wast e Stream OR-NFS-CH-Soil to verify the consistency and completeness of the records. EPA r eviewed the records for Container Nos. NFS0123, NFS0585, and NFS0489 from BDR OR-RTR6-0098. The RTR Measurement Control Report (MCR) was reviewed and found to be within th e stipulated acceptance criteria. NonConformance Report (NCR) NCR-ORNL-06550-08 was writ ten for container NFS0489, because of the presence of 300 mL of non-residual liquid. The required Quality Control (QC) was performed with the Independent Observation performe d on Container No. NFS0123 and Replicate Scan on Container No. NFS0585. The BDR h ad been reviewed at both the data generation and project level, as required. For BDR OR-RTR6-0121, EPA verified the acceptability of the MCR, performance of the requir ed Independent Observation (performed on debris Container No. X10C0501806) and Replicate Sca n, and the completeness of the data generation and project level review checklists.

NCR-ORNL-0651-08 was written for Container No. NFS09 27 from RTR BDR OR0RTR6-0101, because the waste did not match the waste descripti on. ORNL-CCP correctly rejected this drum and requested the AKE to perform an AK re-evaluatio n. EPA also reviewed the records for

Container No. NFS0812 from this BDR. EPA also revi ewed records for Container Nos. NFS0141 and NFS0849 from BDR OR-RTR6-0074, and Conta iner No. NFS0487 from BDR

OR-RTR6-0089.28

Summary of RTR Findings and Concerns

EPA did not identify any findings associated with t he processes used or recording of data for RTR examinations performed on containers from ORNL Waste Stream OR-NFS-CH-SOIL. EPA did identify one concern that required a respon se, No. ORNL-CCP-CH-RTR-09-001CR,

that is discussed above and is included at Attachme nt A to this report. ORNL-CCP provided a written response to this concern, which EPA evaluat ed and found it adequately addressed the

concern. Concern No. ORNL-CH-RTR-09-001CR is closed and there are no ope n issues related

to RTR for this T1 evaluation.

Tiering Changes

Based on the results of this T1 evaluation, there a re no changes to the T1 and T2 designations assigned to RTR during the ORNL-CCP baseline approv al.

7.0 SUMMARY OF RESULTS AND CONCLUSIONS

Conclusion

EPA concluded that the WC processes of AK, NDA, andRTR used to characterize retrievablystored CH TRU Soil Waste Stream OR-NFS-CH-SOIL from the S4000 SCG soils/gravel. There were three concerns, two of which required a respon se, and ORNL-CCP adequately addressed both concerns. There are no open issues relative t o this T1 evaluation.

Approval

The T1 change that was evaluated consisted of the W C techniques of AK, NDA, and RTR as evidenced by the records ORNL-CCP generated in char acterizing the CH TRU Waste Stream OR-NFS-CH-SOIL in the S4000 soils/gravel SCG. Based on the results of this evaluation, EPA approves this T1 change. ORNL-CCP is approved to c haracterize CH TRU Soil Waste Stream OR-NFS-CH-SOIL consistent with the limitations speci fied in this report.

Tiering Changes

Based on the results of this T1 evaluation, EPA has revised the T1 and T2 designations assigned to AK during the ORNL-CCP baseline approval, as ref lected in Table 1 of this report. There is one new AK T1 change and slight modifications to th e AK T2 elements. All of the T2 elements listed under AK in Table 1 apply to all approved CH TRU waste streams and SCGs at ORNLCCP. Consistent with EPA’s authority under 40 CFR 194.24(h), EPA may request this information if EPA deems it necessary to ensure con tinued compliance with EPA regulations. There are no changes to the T1 and T2 designations assigned to NDA or RTR during the ORNLCCP baseline approval as a result of this T1 evalua tion.A-1 ATTACHMENT A: EPA TIER 1 ISSUE TRACKING FORM, ISSUE NO. ORNL-CCP-CH-RTR-09-001CR, FINAL

T1 Evaluation No. ORNL-NFS-CH-SOIL Issue Number: ORNL-CCP-CH-RTR-09-001CR, Final

Date: August 12, 2009

Inspector: Dorothy Gill

Attachments? YES NO Sample Size: 1 Test Drum, 3 Operators Population size (if known): 1 Test Drum, 3 Operators

Description of Issue: Review of recordings of Demonstrations of Capabili ty examinations performed on Test Drum No. ORNLNDE-TEST-007 performed on June 19, 2008, showed tha t operators missed some of the non-WAP required ite ms that were in the drum. The SME, who checked the Demonstration of Ca pability recordings, did not identify these errors. This is a repeat concern; the original one was written during ORNL baseline i nspection EPA-ORNL-CCP-CH-11.07-8, provided in “Add itional Comments”

below.

Training Drum No. ORNL-NDETEST-007 Contents, June 18, 2008 Operator SE

Written Record Operator SB

Written Record Operator LS

Written and A/V Record

Soil OK OK OK Horse tail bag of Tyvek coveralls Missed in horseta il bag Missed in horsetail bag Missed in horsetail bag

Cardboard OK OK OK Horsetail bag of Raschig rings Missed in horsetail bag Missed in horsetail bag Missed in horsetail bag Horsetail bag with rubber hose and paint brush Found hose and paint brush,

but missed them in a horsetail bag Found brush and “tygon” tubing. Missed that these were in horsetail bag Missed hose and in horsetail bag Orally identified a paint brush, but did

not record on data sheet Plastic labware Missed (glass labware identified) Missed (glass labware identified) Missed (glass labware identified)

Rubber hose OK “tygon tubing” OK Horsetail bag with paper Found horsetail bag, but missed paper in bag Found horsetail bag, but missed paper in bag Found horsetail bag, but missed paper in bag

Electrical cord OK OK OK

B. Regulatory Reference: 40 CFR 194.24(b)

C. Site requirement(s): Not applicable

D. Discussed with: Mark Pearcy

E. Additional Comments: The following Concern was generated during ORNL CH baseline inspection EPA-ORNL-CCP-CH11.07-8 conducted November 13-15, 2007:

ORNL-CCP-CH-RTR-004C: In the capability demonstration training containers , the EPA inspector noted that while all the required items (prohibited items) were identified c orrectly by all RTR operators, some additional item s (cellulosics and plastics) were not identified. All cellulosics and plastics i n the training drum need to be identified and their identification documented. To complete the training process, it is critical that the operator receives feedback regarding missed ite ms. More detailed documentation of the feedback given is needed when the results of the training drum are reviewed.

While this concern requires a response, it does not affect the pending approval of this Tier 1 change.

F. Site Response Information: Site Response Required? YES NO Site Response Due Date: August 27, 2009B-1 ATTACHMENT B: EPA TIER 1 ISSUE TRACKING FORM

, ISSUE NO. ORNL-CCP-CH-NDA-09-002CR, FINAL

T1 Evaluation No. ORNL-NFS-CH-SOIL Issue Number: ORNL-CCP-CH-NDA-09-002CR. Final

Date: August 12, 2009

Inspector: P. Kelly

Attachments? YES NO Sample Size: Six ORNL DWAS BDRs Population size (if known): All ORNL NDA BDRs

Description of Issue: Common practice for ORNL NDA control charts is to record only successful performance checks and to omit any measurement failures, i.e., values outside of the 3 Sigma Control Limits. Each such failure requires resolution, i.e., calibration verification and a subsequent successfu l performance check, which overrides the failure, r esulting in only the successful performance check value being entered on the control chart. This only occurs at ORNL-CCP.

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): CCP-TP-168, Revision 2

D. Discussed With: Joe Harvill, Mark Pearcy, Jeff Harrison, and Paul Gomez

E. Additional Comments: This does not affect the technical quality of the D WAS NDA data evaluated during this T1

evaluation. It does affect the record that documen ts performance of the DWAS and, accordingly, acceptance of the DWAS BDRs for NFS soils is not contingent upon resolutio n of this issue.

F. Site Response Information: Site Response Required? NO YES Site Response Due Date: August 27, 2009C-1 ATTACHMENT C: EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. ORNL-CCP-CH-NDA-09-003C, FINAL

T1 Evaluation No. ORNL-NFS-CH-SOIL Issue Number: ORNL-CCP-CH-NDA-09-003C, Final

Date: August 12, 2009

Inspector: P. Kelly

Attachments? YES NO Sample Size: 2 DWAS BDRs Population size (if known): 42 Soil NDA BDRs

Description of Issue: ORNL BDR No. OR-DWAS-0203 contains a control char t for 240 Pu EFF for the time period of February 1, 2009 to March 3, 2009. The control chart shows thr ee points that exceed the 3 Sigma Control Limits on February 2, 11 and 19; however, all points were in control. This apparent discrepancy occurs because the 2 and 3 Sigma Warni ng and Control Limits change every week as a result of decay-correcting t he 252 Cf source which has a half-life of 2.6 years. A va lue that is in control at the time it was performed may be outside of warning or control limits that were generated at a later t ime due to changes in the limits as a function of decay-correcting the 252 Cf source. When the older value is shown on a cont rol chart with the newer limits it appears to be out of control when it was not. T his is not a technical issue in that all performanc e checks that we observed were in control at the time they were performed.

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): CCP-TP-166, Revision 2

D. Discussed With: Joe Harvill, Mark Pearcy, Jeff Harrison, and Paul Gomez

E. Additional Comments: None

F. Site Response Information:

Site Response Required? NO YES Site Response Due Date: Not Applicable