# 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 CHARACTERIZA TION

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 Imp lemented 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 fo r 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 Imp lemented 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) Checklis t

Attachment A.4 Visual Examination Technique (VET) C hecklist

Attachment A.5 Container Management Checklist

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

Attachment B.2 Replicate Testing Results for Contai ner 10212486 – WAGS

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

Attachment B.4 Replicate Testing Results for Contai ner 10215772 – WAGS

Attachment B.5 Replicate Testing Data for Containe r ARP05744 – WAGS

Attachment B.6 Replicate Testing Results for Contai ner ARP05744 – WAGS

Attachment B.7 Replicate Testing Data for Containe r ARP06447 – WAGS

Attachment B.8 Replicate Testing Results for Conta iner ARP06447 – WAGS

Attachment B.9 Replicate Testing Data for Containe r ARP06723 – WAGS

Attachment B.10 Replicate Testing Results for Cont ainer ARP06723 – WAGS

Attachment B.11 Replicate Testing Data for Containe r BN10211041 – SuperHENC

Attachment B.12 Replicate Testing Results for Cont ainer BN10211041 – SuperHENC

Attachment B.13 Replicate Testing Data for Containe r BN10239132 – SuperHENC

Attachment B.14 Replicate Testing Results for Conta iner BN10239132 – SuperHENC

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# 1.0 EXECUTIVE SUMMARY

In accordance with 40 CFR 194.8(b), the U.S. Enviro nmental Protection Agency (EPA or the

Agency) conducted continued compliance Inspection N o. EPA-INL-CCP 09.08-24 of the Central

Characterization Project (CCP) waste characterizati on (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 prov isions 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 pro gram 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 al l TRU waste characterization processes

except acceptable knowledge (AK). EPA inspected th e 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 C H TRU consistent with the conditions and

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

adding new Tier 1 and Tier 2 (T1 and T2) items to t he 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 A ssay Gamma Spectrometer

(WAGS) and the Super High Efficiency Neutron Counte r (SuperHENC) for

characterizing CH TRU wastes

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

• Visual Examination Technique (VET) for newly-genera ted 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 tab le is not identical to those included in the

INL-CCP baseline inspection report dated November 2 005, 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 t o have a baseline approval and the format of

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

baseline approval reports, these two T2 columns hav e 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 reg arding the completion or availability of specific

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

result of this inspection and are included as itali cized text in the table below. Also, consistent4Table 1. Revised Tiering of TRU WC Processes Implemented by INL-CCPBased on May 3–5, 2005, Baseline Inspection and September 16–18, 2008, Continued Compliance InspectionWC Process ElementsINL-CCP WC T1 ChangesINL-CCP WC T2 ChangesaAcceptable Knowledge (AK)and Load ManagementAny new summary category group for TRU wasteChanges to WWIS algorithms specific to loadmanagement requiring revisions to the loadmanagement provisions of DOE’s CH WasteAcceptance Criteria (CH WAC)Changes to the targeted waste(s) from what waspresented 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) withinan approved waste categoryChanges in load management status of approved wastestream(s)Changes to the WWIS algorithms corresponding to thechanges to the loadmanagement provisions of the CH WACChanges to site procedures requiring CBFO approvalsProviding any analysis evaluating effectiveness ofthe Waste Identification Process(AK 1)Providing future revisions of CCP-AK-INL-001, Revision 6 (AK2)Providing future Discrepancy Reports related to radiological and physicalcharacteristics of the ID-SDA-SOIL, ID-SDA-SLUDGE,and ID-SDA-DEBRIS wastestreams (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 thatapply to ID-SDA-SOIL, IDSDA-SLUDGE, and ID-SDA-DEBRIS waste streams (AK 10)Changes to site procedures requiring CBFO approvalNon Destructive Assay(NDA)New equipment or substantive changesbto approvedequipment affecting actual radioassay results (e.g.,DQO compliance, TMU)Modificationcto approved calibration range forapproved equipment and/or equipmentChanges to software for approved equipmentChanges to operating range(s) upon CBFO approvChanges to site procedures requiring CBFO approvalReal-Time Radiography(RTR)Not Applicable Changes to site procedures requiringCBFO approvalVisual Examination (VE) Not ApplicableSame as aboveWIPP Waste InformationSystem (WWIS)Not ApplicableSame as aboveaINL-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, orRCRA, or that are editorial in nature.5c “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 excludeminor changes, such as the addition of safety-related equipment.

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# with the tables in more recent reports, the specifi c 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 insp ection 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 repo rt does the following:

• Describes the sample of the INL WC systems evaluate d during this inspection

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

configuration and assesses the impact, if any, of t hose changes

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

systems

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

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

their relevance to EPA’s approval decision

• Identifies changes to the T1 or T2 designations tha t 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 attach ed 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 syste ms in use at INL-CCP to characterize TRU

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

aspects of these systems with respect to their abil ity to perform the following functions:

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# • Identify and quantify the activities of the 10 WIPP -tracked radionuclides ( 241 

# Am, 137 

# Cs,

238 

# Pu, 239 

# Pu, 240 

# Pu, 242 

# Pu, 90 

# Sr, 233 

# U, 234 

# U, and 238 

# U) using a combination of AK and NDA

systems

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

CH retrievably-stored and newly-generated wastes, r espectively

• Perform effective waste segregation and container m anagement

Specifically, these systems consisted of the follow ing 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 ev aluation was the objective evidence

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

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

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

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

Based on the evaluation of the WC processes in conj unction 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 iden tified 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 i ssue, 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 ac cepts 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 inspec tion 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 o nly a sample of the CH TRU WC staff, and

they are listed in Table 3, along with their affiliation s 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 wi thin 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 step s:

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

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

to WC activities at INL-CCP in advance of the inspe ction

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

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

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

processes, and equipment by means of interviews, ob servation, and demonstrations, and

recording the results, as appropriate

(6) Recording all concerns on EPA Inspection Issue Trac king 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-C CP 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 Sub surface Disposal Area

(SDA) Waste Streams

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

remained in compliance with 40 CFR 194.8 requiremen ts 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 wa ste originating from Advanced Mixed Waste

Treament Project( AMWTP), but these categories wer e 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 concentrati ons of TRU radionuclides, depleted uranium

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

characterization of specific, targeted wastes burie d 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 ship ped 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 2 004 and subsequent T1 review, two specific

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

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

the waste stream descriptions, i.e., wastes from Co ntract 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 locatio n of the current SDA areas described above.

1 

# ANL-W is now called the Materials and Fuel Complex (MCF).11Figure 1. Location of ARP I, ARP II, and ContractAreas 1A, 2A, 6A, 6B, and 6C

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# The ARP-I and ARP-II comprise approximately one acr e: 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-acr e 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 to tal 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 th e ARP-I retrieval area encompassing portions of

Pit-4 and Pit-6; (3) Contract Area 1A, an approxima tely 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 relativ ely 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 agreeme nt from the EPA Region 8 and the Idaho

Department of Environmental Quality.

EPA focused the 194.22 inspection on the newly adde d 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 co ntinued acceptability of the AK process at

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

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

• Overall procedural and process technical sufficienc y and ability to follow the waste

selection, retrieval, and characterization processe s

• AK information assembly and compilation

• Characterization of required waste WMPs and radionu clides

• Assembly of required information and use of supplem ental 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 wast es 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 proced ures and documents, including the

following:

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

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

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

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

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

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

11, 2008

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

Checklist for Heterogeneous Debris with Minor Amoun ts of Homogenous Solids and

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

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

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

• Attachment 4 - CCP TP 005 Revision 18; Acceptable K nowledge 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 Are a at the Idaho National Laboratory

(CCP-AK-INL-001) for Soils, January 2, 2008, and Re lated 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 Are a at the Idaho National Laboratory

(CCP-AK-INL-001) for Solid Inorganics, January 2, 2 008, 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 Are a 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 K nowledge Documentation,

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

November 11, 2006

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

• Attachment 8 - CCP TP 005 Revision 18; List of Wast e 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 Wast e Containers for CCP-AK-INL001, ID-SDA - SOIL, obtained the week of April 8, 2 008

• Acceptable Knowledge Accuracy Report: Idaho Nation al Laboratory Waste Stream

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

• Acceptable Knowledge Accuracy Report: Idaho Nation al Laboratory Waste Stream

Number ID-SDA-DEBRIS, Lots 1 through 8, May 20, 200 8

• AR Project - Drum Packaging System, TPR-7415, Revis ion 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, J uly 22, 2008

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

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

ID-SDA-DEBRIS, September 29, 2006

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

Summary Report for Waste Retrieved from Designated Areas within the Subsurface

Disposal Area at the Idaho National Laboratory, Tra nsuranic Waste Streams

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

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

Summary Report for Waste Retrieved from Designated Areas Within the Subsurface

Disposal Area at the Idaho National Laboratory, Tra nsuranic Waste Streams

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

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

Summary Report for Waste Retrieved from Designated Areas Within the Subsurface

Disposal Area at the Idaho National Laboratory, Tra nsuranic Waste Streams

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

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

Summary Report for Waste Retrieved from Designated Areas Within the Subsurface

Disposal Area at the Idaho National Laboratory, Tra nsuranic Waste Streams

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

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

Summary Report for Waste Retrieved from Designated Areas Within the Subsurface

Disposal Area at the Idaho National Laboratory, Tra nsuranic Waste Streams

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

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

Summary Report for Waste Retrieved from Designated Areas Within the Subsurface

Disposal Area at the Idaho National Laboratory, Tra nsuranic Waste Streams

ID-SDA-DEBRIS, ID-SDA-SLUDGE, ID SDA-SOIL, August 3 1, 2007 and February 7,

2008

• CCP-AK-INL-001, Revision 6; Central Characterizatio n 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, Tra nsuranic 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 Tec hnique for Idaho National

Laboratory (INL) Newly-Generated TRU Waste Retrieve d 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 K nowledge Re-Evaluation

Checklist, ID-SDA Sludge, TIC Identification, Octob er 30, 2008

• ID-D002 Discrepancy Report and Resolution Concernin g Prevalent Radionuclides for

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

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

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

September 10, 2008

• ID-P218, Engineering Evaluation/Cost Analysis for A ccelerated 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 Retrie val Project 2, Jeffrey D. Bryan, EDF5447, Revision 1; May 31, 2005

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

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

GDE-318 1, August 21, 2006

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

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

• ID-P249 Excavation Plan for the AR Project (WMF- 16 12) - 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 Retrie val 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 1-4 3, ID-SDA-SLUDGE, undated

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

• RF-C222 Neptunium-Plutonium Content of ZPPR Residue s, undated

• RF-C443 Disposal of Uranium-233 Waste, April 10, 19 74

# 16



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

• Waste Stream Profile Form: Waste Stream Profile Fr om 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 fo rm 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 Fo rm Number ID-SDA-DEBRIS,

Heterogeneous Debris from the Subsurface Disposal A rea, 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 Octob er to December 2008, during which time a

desk-top AK review was performed. The inspection t eam 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 modificatio n through the addition of new Contract

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

compliance inspection are included below, and all T 1 and T2 requirements established in EPA’s

baseline approval are retained. The following obse rvations were made:

(1) Procedural interfacing and implementation were exam ined 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 Sy stem

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

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

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

(INL) Newly-generated TRU Waste Retrieved From Pits

• CCP-TP-005, Revision 18; CCP Acceptable Knowledge D ocumentation

• ID-P249 Excavation Plan for the AR Project (WMF-161 2) - 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 Retrie val Areas

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

• ID-P222 Exhumation Area 1-7 WILD database

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

GDE-318

# 17



# These documents were examined to understand the was te retrieval process, which identifies

“targeted” waste. Targeted wastes are:

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

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

• Heterogeneous debris: filters, primarily high effi ciency 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. Al l 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 t hat were inadvertently mixed during the

retrieval process. That is, soil may become contam inated 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 C CP and ICP representatives, (CH2M-WG

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

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

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 W aste for the Accelerated Retrieval

Project II, Engineering Design File (EDF)-5601

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

Sludge Waste Stream, EDF-5720

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

Guide

• ID-P249: Excavation Plan for the AR Project (WMF-1 612)—Pits 4 and 6 Retrieval Area

(ARP) II

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

CWI personnel first identify targeted wastes, inclu ding 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 T rench (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 ope ration, but is a recipient of the TRU waste

for characterization and disposal. EPA evaluated t his 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 no n-target wastes from the initial

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

Identification Operator (WIO) visually identifies t argeted 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 id entification of target and non-target wastes.

The WIO also identifies WIPP-prohibited waste accor ding 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 t o 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 responsibi lity of CWI under procedure TPR-7415.

The ICP requires periodic evaluations of the effect iveness 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 N CRs issued since 2006, approximately 823

were generated as a result of drums with TRU radioi sotopes 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-C CP 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 t o 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 evaluate d for technical adequacy and/or

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

adequate.

The following AK summaries were examined during the inspection:

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

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

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

Revisions 2, 3, 4, 5, and 6, March 20, 2006, Novemb er 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 con cerning the origin and generation of wastes

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

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

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

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

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

# 19



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

baseline approval evaluation. These two areas incl uded 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 233 

# U

• 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 C ontract Areas 1A, 2A, 6A, 6B, and 6C.

Targeted waste identified in each area is as follow s:

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 additi onal 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 waste s were not summarized in the AK Summary,

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

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

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

includes waste from Atomics International, the Cali fornia Salvage Company, the University of

Washington Radiological Safety Division, and the U. S. Nuclear Corporation (Reference IDP222). INL-CCP explicitly states: “Additional info rmation 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, t he results of the evaluation and inclusion of

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

revision of CCP-AK-INL-001, Revision 6, is a T2 cha nge. (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 ta rget 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 Re vision 6 of the AK Summary, EPA must be

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

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

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

the three streams, and were found to be adequate.

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

originated from Rocky Flats: First and Second Stag e 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 f rom Rocky Flats: Second Stage Sludge

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

Mud; Pond 2B Sludge; and other RFP sludges. Additi onal 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 radiologic al characteristics, prior to inclusion of the

additional Contact Areas:

WG Pu

• 238 

# Pu 0.0105%

• 239 

# Pu 94.06%

• 240 

# Pu 5.72%

• 241 

# Pu 0.173%

• 242 

# Pu 0.043%

DU

• 238 

# U 99.78%

• 236 

# U 0.006%

• 235 

# U 0.215%

• 234 

# U 0.001%

HEU (highly enriched uranium)

• 238 

# U 5.37%

• 236 

# U 0.44%

• 235 

# U 93.17%

• 234 

# U 1.02%

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

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

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

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

prevalent radionuclides are 238 

# U (99.69%) and 235 

# U (0.15%), with 239 

# Pu anticipated to constitute

# 22



# approximately 0.14% of the mass. 2 

# INL-CCP also stated that the most prevalent radio nuclides

by activity would be 241 

# Pu (40.49%) and 241 

# Am (39.59%). Table 5-4 of Revision 6 presents the

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

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

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

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

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

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

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

debris would be the same.

INL-CCP provided the most recent analysis of most p revalent 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 239 

# Pu and 238 

# U, the relative mass of 239 

# Pu 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 revi sit 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, an d forthcoming EPA inspections will watch

for this.

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

Waste Stream* 235 

# U% By Mass 238 

# U% By Mass 239 

# Pu% By Mass 240 

# Pu% 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 additio n 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 activi ty values for each of the targeted and

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

prevalent radionuclide listings, so that 239 

# Pu (0.36%) and 238 

# U (99.37%) were the most prevalent

by mass instead of 235 

# U and 238 

# U. Revision 3 also indicates that 241 

# Pu (52.59%) and 241 

# Am

(36.21) are still the most prevalent by activity, w ith 239 

# Pu present at approximately 8.9%. This

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

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

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

2 

# Radionuclides vary in their activity per unit mass (specific activity), i.e., 239 

# Pu, 235 

# U, 238 

# U and 241 

# Am have different

amounts of radioactivity per gram. Special Nuclear Materials ( 239 

# Pu, 235 

# U, 241 

# Pu and 241 

# Am) are typically tracked by

mass (in grams), while other radionuclides ( 238 

# U, 137 

# Cs, 90 

# Sr and non-TRU radionuclides) are typically tracked by

activity (in curies). Accordingly, the most preval ent radionuclides for a given waste stream will var y depending on

whether they are tracked by activity in curies or m ass in grams.

# 23



# packaged and known to be TRU waste”, recognizing va riables that could make this analysis

difficult (see Item 6, below).

References ID-P222 and ID-U313 include WILD database informati on 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. Re ference ID-U313 shows that 239 

# Pu, 240 

# Pu and

241 

# Am are present in the highest quantities by activit y in RFETS waste. In addition to the

RFETS waste, Contract Area 1A includes TAN waste co mposed primarily of 137 

# Cs and 90 

# Sr,

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

predominantly of 137 

# Cs; California Service Company, predominantly 137 

# Cs; University of

Washington Radiological Safety Division, predominan tly 137 

# Cs; and, U.S. Nuclear Corporation,

predominantly 60 

# Co, 137 

# Cs and 90 

# Sr. 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 isotopi c distribution of the Contract Area waste is

essentially the same as for the ARPI/ARPII.

This analysis indicates that the new radiological i nformation 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 i mparted by inclusion of these areas, including

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

distribution was assembled assuming potential inclu sion of both targeted and non-targeted

wastes.

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

prohibited items, were assessed to determine whethe r 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 inclu de 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, mo st of the filters were replaced with CWS filter

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

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

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

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

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

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

glass, firebrick, ceramics, sand, and inorganic abs orbents.

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

treatment of aqueous liquids that were solidified t hrough 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. Ro aster Oxide, which is also targeted, consists of

pure DU metal machine turnings converted to an oxid e 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 targete d waste and inclusion of interstitial soils in

the extracted waste. When soil comprises greater t han 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 compa red to assess how inclusion of the

additional Contract Area wastes modified the physic al characteristics of the streams.

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

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

I and ARP II. The total volumes for each of the ar eas 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 (ft 3 

# ) Total Volume

Non-Targeted Waste (ft 3 

# ) Total Waste

Volume (ft 3 

# )

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 ft 3 

# , of which 23% is targeted waste and 77% is

non-targeted waste. In total, the 1A, 2A, 6A, 6B a nd 6C Contract Areas add a total of 91,719 ft 3



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

increased the total volume of wastes, but did not i ncrease 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 wast es in the Contract Area and the ARP I and II

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

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

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

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

additional Contract Areas were appropriately assess ed.

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 signi ficantly 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 r esult 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 Are as. Examples of these changes include but

are not limited to:

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

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

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

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

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

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

Salvage Company, University of Washington Radiologi cal 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 (target ed and non-targeted) waste volume prior

to addition of the Contract Areas was 310,133 ft 3 

# and Contract Areas 1A, 2A, 6A, 6B,

and 6C added another 92,821 ft 3



# .

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

waste areas.

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

• Relative masses and activities of identified radion uclides were slightly modified,

apparently due to the inclusion of more RFP 239 

# Pu-bearing material (see Item 3 above).

• Distribution and predominant radionuclides were mod ified to address Discrepancy

Report D002, changing the most prevalent radionucli de designation and other

specifications (see Item 3, above).

• The November 2005 fire at SDA that resulted from ex cavation of 235 

# U-bearing wastes

was addressed.

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

to radionuclides. EPA expects that future AK Summa ries 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 fou nd to be adequate

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

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

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

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

problem with the methodology for determining the ra dionuclide distribution for waste streams

# 26



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

included radionuclide distributions assuming the pr esence 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 Resolutio n states that the distributions should be made

based on “what is actually retrieved and packaged a nd 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 ar e indistinguishable from the same materials

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

present in 741 sludge, so the most prevalent radion uclides by mass (i.e., 238 

# U and 239 

# Pu) could be

different than predicted; and (4) inadvertent commi ngling 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 pre valent radionuclides” in the waste streams, but

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

would be 238 

# U and 235 

# U.

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 238 

# U and

239 

# Pu, not 238 

# U and 235 

# U, as stated in the Discrepancy Resolution. Note t hat 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 li st for Revision 3. Revision 6 of the AK

Summary retains the designation of 238 

# U and 239 

# Pu as the most prevalent radionuclides by mass.

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

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

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

Discrepancy Reports related to radiological and phy sical 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 sufficien cy 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 stream s. Revisions 0, 1, 2, 3, 4, 5, and 6 of CCPAK-INL-001, Central Characterization Project Accept able Knowledge Summary Report for

Waste Retrieved from Designated Areas Within the Su bsurface Disposal Area at the Idaho

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

SDA-SOIL were dated November 18, 2004, April 15, 20 05, March 20, 2006, November 16,

2006, January 29, 2007, August 31, 2007 and Februar y 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 w ith 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 adequa te.

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

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

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

radionuclides by mass are 238 

# U (73.3%) and 239 

# Pu (23.86%). The Solids AK Accuracy Report

indicated that the most prevalent radionuclides by mass are 238 

# U (99.17%) and 239 

# Pu (0.53%).

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

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

streams. This information supports future reassess ment 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 add ressed in Discrepancy Reports (see item 6,

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

change.)

(9) Load management was assessed and was found to not a pply 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 wer e issued because drums did not contain

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

namely, INL.

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

Memoranda) and was found to be adequate.

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

is included with Attachment 7 of CCP-TP-005 Revisio n 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 sev eral waste streams mixed during retrieval,

and it is not possible to predict a radiological di stribution 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 typ es 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 tec hniques and 234 

# U, which cannot be

measured, will be calculated by scaling it to using measured 235 

# U and/or 238 

# U. Item 8, above,

brings to question whether the radionuclide composi tion 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-ND A memoranda applicable to the IDSDA-SOIL, ID-SDA-SLUDGE, and ID-SDA-DEBRIS waste st reams, 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 determ ination, spent nuclear fuel (SNF),

and high level waste (HLW) was verified.

The AK Summary Report Revisions 3 and 6 were assess ed 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 w hole, were commingled with respect to the

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

available documentation. It should be noted that E PA 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 w aste, the AK Summary, Revision 6, states:

Based on the review of AK documentation, spent nucl ear 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 se gregated to the extent possible if

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

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

wastes generated by this facility were acidic liqui ds that were transferred to the

Tank Farm, and were not buried in the SDA. Waste fr om 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-P00 1, INTEC-U001).

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

fuel elements.

Summary of AK Findings and Concerns

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

examined during the desktop review of data pertaini ng 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, a s presented in the following T2 changes:

• Changing the targeted waste(s) from what was presen ted 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 i s a T2 change.

# 29



# • Providing future Discrepancy Reports related to rad iological and physical characteristics

of the ID-SDA-SOIL, ID-SDA-SLUDGE, and ID-SDA-DEBRI S 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 a pplicable 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 origin al tiering issued with the INL-CCP baseline

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

implementation and notifying and providing EPA info rmation related to the T2 changes on the

schedule established as part of the baseline approv al.

8.2 Nondestructive Assay

Technical Evaluation

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

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

equipment. Accordingly, an evaluation of the desig n and basic operating principles of the INLCCP NDA systems is not addressed in this report. T hese 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 sys tems:

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

and software to perform the required analyses

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

routine measurement controls and anomalies

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

content and matrix and the samples routinely assaye d

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

objective evidence of technical activities

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

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

inspection:

• CCP-TP-010, CCP Waste Assay Gamma Spectrometer (WAG S) and SWEPP GammaRay Spectrometer (SWEPP) Calibration Procedure, Rev ision 3, November 6, 2006

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

Revision 4, October 19, 2006

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

November 16, 2006

# 30



# • CCP-TP-146, CCP SuperHENC Operating Procedure, Revi sion 1, January 4, 2007

• CCP-TP-170, CCP SuperHENC Calibration Procedure, Re vision 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 Verific ation, Revision 0, January 10,

2007

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

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

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

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

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

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

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

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

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

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

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

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

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

Confirmation and Verification Report, Revision 0, A pril 27, 2005

• CCP-INL-WAGS-06-005, Calibration Verification Repor t

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

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

• CCP-INL-WAGS-08-002, WAGS Multi-Curve Efficiency Ca libration 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 Parame ter, April 24, 2008

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

Replacement and Energy Calibration, August 6, 2008

• CCP Standing Order: CCP-SO-INL-08-003, Clarificatio n 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, C alendar Year 2008

# 31



# • SuperHENC BDR INNDAB080001 – SWB No. BN10211039

• SuperHENC BDR INNDAB080002 – SWB Nos. BN10211037, B N10211038 &

BN10215259

• SuperHENC BDR INNDAB080003 – SWB Nos. BN10211045 & BN10215278

• SuperHENC BDR INNDAB080004 – SWB Nos. BN10211043, B N10211044,

BN10215293 & BN10215294

• SuperHENC BDR INNDAB080005 – SWB Nos. BN10211040, B N10211041,

BN10211042 & BN10215279

• WAGS BDR INNDAW060008 – Container Nos. 10041591 & 1 0041595

• WAGS BDR INNDAW080049 – Container No. ARP06138

• WAGS BDR INNDAW080065 – Container Nos. ARP05, ARP06 549 & ARP06631

• INNDAW070159 – Container Nos. 10061521, 10019296, 1 0024527, 10181935,

10020606, 10060904, 10174713, 10003141, 10025362, 1 0007999, 10181845, 10062578,

10020593, 10033052, & 10021339

• CCP-Idaho National Laboratory List of Qualified Ind ividuals (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 rel ative to the configuration that was

approved during the baseline inspection.

The WAGS is located in Building WMF-610, formerly c alled 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 quantit ative assays. It consists of six highresolution broad-energy germanium (BEGe) gamma dete ctors, a drum turntable, shielded

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

not changed. In July 2008, one isotopic detector w as 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 basel ine inspection 3 

# . There were no other design

or hardware changes to the WAGs software relative t o 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 a ttempts to compute isotopic distributions for

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

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

3 

# Cadmium filters attenuate the low-energy (<~ 80 ke V) photons typically associated with higher 241 

# Am

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

# 32



# available, default AK values are used. The WAGS de rives a value for 242 

# Pu by correlation, and

90 

# Sr is determined by application of a scaling factor based on 137 

# Cs. Uraniun-234 is quantified

based on measured values for 235 

# U and 238 

# U. There were no substantive changes to the softwa re

relative to the configuration evaluated during the baseline approval.

(2) System calibration of the WAGS had been performed a nd 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 documente d 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 s ystem’s calibrated range of 59 to 1,408 keV.

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

and the calibration confirmation were different. A ll calibration confirmation and verification

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

configuration evaluated during the baseline approva l.

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

documented, including an extension of the density o perating range.

With respect to activity, CCP-INL-WAGS-001 states t hat 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 Detectio n (LLD), discussed below, at the lower end,

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

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

measured photon emission within the efficiency cali bration 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, document ed in CCP-INL-WAGS-08-002. The purpose

of the extension was to allow the assay of higher d ensity containers, i.e., between 1.62 g/cm 3 

# and

2.1 g/cm 3 

# , based on the known attributes of the roaster oxid es 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 efficie ncy 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/cm 3 

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

1,408 keV, the original efficiency and energy calib rations

• Density from 1.62 g/cm 3 

# to 2.10 g/cm 3 

# 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 approve d at the time of this inspection, there were

no BDRs using the extended range operation availabl e.

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

and were found to be adequate.

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

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

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

were performed for a variety of reasons, e.g., fail ure of the 133 

# Ba transmission source, and two

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

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

documented. Weekly Interfering Matrix checks had b een performed and documented as

required.

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

BDRs that had been generated since the baseline ins pection:

• 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 assaye d on the WAQGS, INL-CCP personnel

provided the following summary:

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

because of low plutonium content or elevated 241 

# Am 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 sam ples, 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 mea sure 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 esta blished, 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 adequat ely 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/cm 3 

# and 1.94 g/cm 3 

# . There were no other changes

to the LLD determination for the WAGS relative to w hat 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 CBF O 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 p art of this inspection was to provide EPA with

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

the determination of the quantity of 10 WIPP-tracke d radionuclides ( 241 

# Am, 137 

# Cs, 238 

# Pu, 239 

# Pu,

240 

# Pu, 242 

# Pu, 90 

# Sr, 233 

# U, 234 

# U, and 238 

# U) and the TRU alpha concentration. This is accomp lished

by reassaying drums that were previously characteri zed 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 l onger periods of time, such as weeks

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

reported values.

As with all statistical evaluations, there are limi tations 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 test s are predicated. Our experience to date

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

application of these statistical protocols. For ex ample:

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

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

different values for some of the calibration algori thm’s terms.

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

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

radionuclides.

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

slightly from the original assay value, but produce s 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 statisti cal protocols and do not indicate true

measurement trends or problems, as discussed below.

• Since some radionuclides are quantified based on th e measurement of another

radionuclide, a Significant or Highly Significant

indicator for one measured entity will be

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

than actually exists. Examples include: values fo r 238 

# Pu and 240 

# Pu, which are derived by

applying an isotopic ratio to a measured 239 

# Pu value; and 137 

# Cs and 90 

# Sr that are

quantified based on a directly measured 241 

# Am value, an inferred 137 

# Cs value, and a

scaling factor for 90 

# Sr, as discussed below.

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

or Highly Significant

results may not, in fact, be representative of tru e 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 reas sayed five times and the results

were compared to the original assay data. Two stat istical tests, a chi-squared (χ 2 

# ) test and a t

test,

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

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

the χ 2 

# test showed that the observed variances in the rep licate measurements are less than or

equal to the reported uncertainties within the stat istical 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 t he 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 fiv e replicate measurements for 241 

# Am, 3.54E-02

pCi/g or the original 241 

# Am value versus 2.53E-02 for the mean of the five r eplicates. This

indicates that the variances in the replicate measu rements for these items were greater than the

reported uncertainties for all values relative to t he limits of the test. The 137 

# Cs and 90 

# Sr values

were also Highly Significant , which is expected based on the manner in which th ese

radionuclides are measured. Because both 241 

# Am and 137 

# Cs have measurable photon emissions at

662 keV, they cannot be distinguished directly. Ho wever, 241 

# Am also has a measurable response

at 722 keV and to quantify 137 

# Cs, the gamma response at 662 keV that is not suppo rted by (i.e., is

disproportionate to) the gamma response at 722 keV is attributed to 137 

# Cs. This is an indirect

technique that is in widespread use for measurement s involving WG Pu and its accompanying

241 

# Am. Additionally, 90 

# Sr is quantified by scaling it to 137 

# Cs. For reasons that are technically

beyond the scope of this report, this approach for quantifying 137 

# Cs may produce false positive

values for 137 

# Cs and 90 

# Sr. This is of interest, because one might expect an anomaly for 241 

# Am to

be reflected in the 137 

# Cs and 90 

# Sr values, which was reported for this container. The true

measurement anomaly for this container is probably associated with 241 

# Am 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 ess entially penalized by the tight grouping of the

replicate assays. However, close examination of th e data shows that while the agreement among

the replicates is good, the Highly Significant flag does not appear to be an artifact. Specifica lly,

# 36



# the original measured value for 241 

# Am 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 mov ement or settling; fluctuations in the

measurement system’s background; temporal factors s uch as radioactive growth or decay; or,

actual changes in the measurement system, the aspec t 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 addition al attention at this time.

Super High Efficiency Neutron Counter (SuperHENC)

(1) The design and operational history of the Supe rHENC was assessed relative to the

configuration that was approved during the baseline inspection.

The SuperHENC is located in a trailer on site at IN L in the RWMC adjacent to the Stored Waste

Examination Pilot Plant (SWEPP), a building that ho uses other INL-CCP NDA systems used for

characterizing TRU wastes. This is in the same loc ation as when it was inspected during the

baseline inspection. The SuperHENC consists of a pa ssive 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 distribut ion information

allows quantification of 238 

# Pu, 239 

# Pu, 240 

# Pu, 241 

# Am, 233 

# U, 235 

# U, 238 

# U, 137 

# Cs and 237 

# Np 5 

# . The

system’s current approval allows the assay of Stand ard Waste Boxes (SWBs) and 100-gallon

overpacks containing compacted 55-gallon drums refe rred 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 categ ories: S5000 debris loaded into 55-gallon

drums and compacted into pucks by AMWTP that are ov erpacked in 100-gallon drums; or S3000

sludge (solids) packaged in 55-gallon drums that ar e 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 rel ative to what was evaluated during the

baseline inspection.

4 

# FRAM is an initialization for Fixed-Energy Respons e Function Analysis with Multiple Efficiencies.

5 

# The 242 

# Pu content is determined using BII’s Efficiency Tim es Attenuation (ETA) calculations in an approach th at

has been evaluated previously on several BII NDA sy stems at other TRU waste characterization facilitie s. Each

waste container’s 234 

# U content is performed by application of scaling fa ctors that are based on observed values for

235 

# U and 238 

# U. The determination of 90 

# Sr is performed by application of a scaling factor based on 137 

# Cs.

# 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 perfo rmed 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 S uperHENC. This calibration was confirmed

at INL in 2006, and is documented in BII-5221-CVR-0 01, Calibration and Validation Report

SuperHENC Mobile Assay System, Revision 0, November 2006. Calibration confirmati on was

performed with six measurements of an empty SBW ove r a range of Pu loadings, and all

acceptance criteria were met for each of the six ru ns. The system’s stated operational ranges for

neutron assays are from the Limit of Detection or L LD (discussed below) to 12.658 g 240 

# Pu Eff 

# , equivalent to 203.616 g weapons grade (WG) Pu, as s tated in BII-5221-CVR-001. The energy

versus channel calibration for the hyper pure germa nium detector (HPGe) had been performed as

required. Because the HPGe is used in relative rat io 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 neut ron values.

Regarding isotopic determinations, INL-CCP NDA pers onnel provided the following summary

of how isotopics are determined, based on the obser ved 240 

# Pu EFF 

# 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 th e 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 pe rcent 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 h eat source plutonium (HS Pu) so far, and that

they were able to use measured isotopics for one an d AK-based isotopics for the other three. The

use of steel filters is referenced in several INL-C CP documents, but INL-CP NDA personnel

stated that steel filters had not been used althoug h they may be used in the future. There were no

substantive changes to the SuperHENC calibration an d 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 gen eral operational aspects were evaluated

and were found to be adequate.

The current revisions of all applicable SuperHENC p rocedures were available in the instrument

trailer and the SuperHENC logbook contained appropr iate 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 t echnically 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 oper ational for approximately a one-month

period, which was verified by SuperHENC log book en tries. 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 eac h 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 assay ed S4000 wastes on the SuperHENC in

any configuration and that there were (approximatel y) 12 100-gallon overpacks that measured

less than 100 nCi/g during FY 2007.

(4) The SuperHENC had continued successful particip ation 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 Sav annah River Site (SRS) prompted an

extension of the assay period for Cycle B9A to Octo ber 18, 2008, so results for this cycle were

not available. INL-CCP personnel provided a copy o f the CBFO scoring report for PDP Cycle

B8A that indicated the matrix and source loadings f or 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 d ocumented in BII-5221-CVR-001,

Section 4.1.1. There were no changes to the TMU de termination of the SuperHENC relative to

what was approved during the baseline inspection.

(6) The LLD, including the minimum detectable con centration (MDC) of the SuperHENC

had been determined and documented.

There were no changes to the derivation and applica tion 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 pe rformed and evaluated.

The purpose of the replicate testing performed as p art of this inspection is to provide EPA with

an independent means to verify that the SuperHENC c an provide consistent, reproducible results

# 39



# for the determination of the quantity of 10 WIPP-tr acked radionuclides ( 241 

# Am, 137 

# Cs, 238 

# Pu,

239 

# Pu, 240 

# Pu, 242 

# Pu, 90 

# Sr, 233 

# U, 234 

# U and 238 

# U) and the TRU alpha concentration. This is normal ly

accomplished by requesting that the site reassay dr ums that were previously characterized on the

same system or instrument in order to demonstrate t he 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 l onger periods of time, such as weeks

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

reported values.

EPA requested that INL-CCP reassay two waste contai ners that EPA randomly selected from a

list of containers previously assayed on the SuperH ENC. EPA chose Container Nos.

BN10139128 and BN10141587. Each of these previousl y assayed containers was reassayed five

times on the SuperHENC for this inspection. Two st atistical tests, χ 2 

# test and a t test, were

performed on the replicate analyses of each contain er. 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 differenc es between the original

measurement assay values and the average of the fiv e replicate measurements for all

measurement parameters. The χ 2 

# 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 a re no outstanding issues with either statistical te st

for these containers.

Summary of NDA Findings and Concerns

The EPA inspection team did not identify any findin gs 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 design ations.

8.3 Real-Time Radiography

Real-Time Radiography for retrievably-stored (legac y) waste

The INL-CCP RTR system that was approved for S3000 and S5000 waste during the baseline

inspection consisted of the following four items, e ach of which was evaluated as described:

(1) Training for INL-CCP RTR personnel (Operator/I TR/TS/FQAO, Site Project Manager

(SPM) and Site Project Quality Assurance Officer (S PQAO)) 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 R adiography – System 5,” on September 14,

2005 and the first examinations took place on Septe mber 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 demonstra te operator capability for examinations

of drums containing both S3000 and S5000 waste. EP A reviewed the written record and

audio/visual recordings, for demonstration of capab ility examinations of two operators dated

April 24, 2008. EPA determined that the examinatio ns were complete and there were no

discrepancies between the written and audio/visual records.

(2) The approved and controlled operating procedur es: CCP-TP-102, Revision 6, CCP RTR

No. 2 Radiography Inspection Operating Procedure, A pril 15, 2005; and CCP-TP-028,

Revision 2

, CCP Radiographic Test and Training Drum Requirement s, February 4, 2005,

were assessed and found to be adequate.

CBFO correctly reported a Tier 2 change for procedu re 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 fo r guidance. A second operator completed

the electronic data forms as waste items were ident ified 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 Ra diography 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 M arch 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 “Train ing 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-05 3.

(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 ava ilable, complete and adequate.

BDRs contain, at a minimum, data sheets generated d uring the examinations and review

checklists. EPA compared the BDR written records a nd the audio/visual recordings of four

# 41



# containers to ensure completeness, clarity, and con sistency. 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 Observat ion 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 findin gs or concerns related to the RTR during this

inspection.

Changes to RTR Tiering

There are no changes to RTR T1 and T2 change design ations as a result of this inspection.

8.4 Visual Examination Technique (VET)

Visual Examination Technique (VET) for newly-genera ted 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 complet ed prior to EPA’s inspection. The target

waste removed is subject to VE and placed in 55-gal lon 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, Subje ct 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 h ad received specific training for the waste

examined through a training module titled, “Specifi c 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. Qualifie d VE operators and VEEs were contained

in CCP’s LOQI, and only these personnel were perfor ming VE at the time of the on-site visit.

(2) The approved and controlled INL-CCP RTR operat ing procedure [CCP-TP-006,

Revision 4, CCP Visual Examination Technique for Id aho National Laboratory (INL)

Newly-generated TRU Waste Retrieved from Pits, Apri l 19, 2005] was assessed and was

found to be adequate.

Procedure CCP-TP-006, CCP Visual Examination Techni que 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 containe rs with S3000, S4000, and S5000 wastes.

The data forms for each container had been signed b y 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 proje ct 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 ge nerated by effective implementation of the

applicable INL-CCP procedures.

Summary of VET Findings and Concerns

The EPA inspection team did not identify any findin gs or concerns related to the RTR during this

inspection.

Changes to VET Tiering

There are no changes VET T1 and T2 change designati ons.

8.5 Container Management

Container Management was not part of the scope of E PA’s 2005 baseline inspection. However,

in response to recent events concerning container m anagement, it is EPA’s intention to perform a

review of these processes at each site when circums tances permit this.

For characterization activities and shipping, INL-C CP interfaces with AMWTP in that AMWTP

personnel are responsible for actual movement of co ntainers throughout this process. Personnel

performing the actual container movement are employ ed 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 inc lude barcodes, container travelers, WTS, and

some INL-CCP management tools. Throughout the char acterization process, personnel check

the drum number against the AK tracking sheet to en sure that the drum in question belongs in the

CCP process. Procedure CCP-TP-068, Container Manag ement at the Idaho National Laboratory

(INL) and TRU Waste Processing Center (TWPC), is us ed for container tracking and

management. It is the responsibility of the CCP V PM to schedule container movements with

the host site.

INL-CCP receives drums in Building WMF-610, which c ontains the RTR and NDA equipment.

Drum numbers are checked against the AK Tracking Sh eet to ensure that the delivered drums are

eligible for characterization. INL-CCP also ensure s that each retrievably-stored waste drum has

a minimum of three bar code labels, with the contai ner 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 t hese containers, INL-CCP uses the ARP

number only. Drum receipt is recorded on a VPM Dru m Receipt / Return Journal form which

# 43



# includes acceptance or rejection of each drum. Thi s form is a management tool and is not a part

of controlled procedure CCP-TP-068. After the AK T racking Sheet check, container integrity

and filter check (Attachment 2, CCP-TP-068) and dru m 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 applica ble sections after completion of the testing.

As drums are delivered to each process, the charact erization personnel verify that the drum is on

the AK Tracking Sheet. At the end of characterizat ion, 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 t o 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 pro cesses. EPA has committed to

inspecting container movement in the shipping proce ss 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 origina l tiering changes one T1 and five T2 changes

to the AK component of the INL-CCP WC program at th is time, as discussed in Section 1 and

shown in Table 6 below. The scope of the complianc e decision is based on EPA’s inspection

completed September 16–18, 2008, and October–Decemb er 2008.44Table 6. Revised Tiering of TRU WC Processes Implemented by INL-CCPBased on May 3–5, 2005, Baseline Inspection and September 16–18, 2008, Continued Compliance InspectionWC Process ElementsINL-CCP WC T1 ChangesINL-CCP WC T2 ChangesaAcceptable Knowledge (AK)and Load ManagementAny new summary category group for TRU wasteChanges to WWIS algorithms specific to loadmanagement requiring revisions to the loadmanagement provisions of DOE’s CH WasteAcceptance Criteria (CH WAC)Changes to the targeted waste(s) from what waspresented in Revision 6 of the AK Summary CCP-AKINL-001 (AK 2)Notification to EPA upon completion of the following:Waste StreamProfile Forms including updates or additions to waste stream(s) withinan approved waste categoryChanges in load management status of approved wastestream(s)Changes to the WWIS algorithms corresponding to thechanges to the loadmanagement provisions of the CH WACChanges to site procedures requiring CBFO approvalsProviding any analysis evaluating effectiveness ofthe Waste Identification Process(AK 1)Providing future revisions of CCP-AK-INL-001, Revision 6 (AK2)Providing future Discrepancy Reports related to radiological and physicalcharacteristics of the ID-SDA-SOIL, ID-SDA-SLUDGE,and ID-SDA-DEBRIS wastestreams (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 thatapply to ID-SDA-SOIL, IDSDA-SLUDGE, and ID-SDA-DEBRIS waste streams (AK 10)Non Destructive Assay(NDA)New equipment or substantive changesbto approvedequipment affecting actual radioassay results (e.g.,DQO compliance, TMU)Modificationcto approved calibration range forapproved equipment and/or equipmentChanges to software for approved equipmentChanges to operating range(s) upon CBFO approvalChanges to site procedures requiring CBFO approvalReal-Time Radiography(RTR)Not Applicable Changes to site procedures requiringCBFO approvalVisual Examination (VE) Not ApplicableSame as aboveWIPP Waste InformationSystem (WWIS)Not ApplicableSame as aboveaINL-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, orRCRA, 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 excludeminor changes, such as the addition of safety-related equipment.A.1-1ATTACHMENT A.1: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGSNONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGSEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Required Technical ElementsChanges Since Baseline?Verification of ActivityObjective EvidenceSystem DescriptionConfirm the name, location, and number of theINL-CCP WAGS. Ensure that this is the sameunit as what was approved during the EPAbaseline inspection in 2005.No changes sincebaseline inspection.EPA personnel verified that theWAGS assay unit is the same aswhat was observed during thebaseline inspection.Visual inspection of WAGS in SWEPP at INLduring inspection.Identify any hardware and/or software changesmade to the WAGS since the baseline approval.Determine which changes, if any, are significant,where they are documented, and how they affectthe WAGS’s baseline approval.Yes One isotopic detector wasreplaced in July 2008.CCP-INL-WAGS-08-005, Calibration Verificationof the WAGS System After Detector Replacementand Energy Calibration, August 6, 2008.Describe the system’s operational history sincethe baseline approval.Yes Same as observed previously,except for density rangeextension.CCP-INL-WAGS-08-002, WAGS Multi-CurveEfficiency Calibration Extension Addendum,Revisions 0 and 1List all applicable calibrations, operational anddata reduction/validation procedures, and thecurrent revisions that are in use for the WAGS.No changes sincebaseline inspection.All procedures observed in useby WAGS personnel were thecurrent revisions.CCP-TP-010, Revision 3; CCP-TP-019, Revision 4;CCP-TP-109, Revision 5.System PerformanceIdentify the following:•Number of waste containers this systemassayed during the period of performance•Number of BDRs assembled•Number of BDRs that have been promotedthrough Project Level ReviewYes5639 drums and 718 BDRs havebeen generated since thebaseline inspection:•2,148 assays and 245 BDRsin CY 2006•1,467 drums and 210 BDRsin CY 2007•2,024 drums and 276 BDRsin 2008Interviews with INL-CCP WAGS personnel duringthis inspection.A.1-2NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGSEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Required Technical ElementsChanges Since Baseline?Verification of ActivityObjective EvidenceGeneral Reporting RequirementsThe WAGS provides quantitative values anduncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr, and137Cs. Identify otherradionuclides that are encountered during routineWAGS assays.No changes sincebaseline inspection.The INL-CCP WAGS continuesacceptable operation.CCP-INL-WAGS-001, Revision 0, April 27, 2005,and Revision 1, April 2, 2008; WAGS BDRsINNDAW060008, INNDAW080049, andINNDAW080065.Each container characterized by the WAGSintended for disposal at WIPP must contain TRUwaste.No changes sincebaseline inspection.The INL-CCP WAGS continuesacceptable operation.CCP-INL-WAGS-001, Revision 0, April 27, 2005,and Revision 1, April 2, 2008; WAGS BDRsINNDAW060008, INNDAW080049, andINNDAW080065.WAGS procedures are appropriate for the wastestreams being assayed, and the results provideunbiased values for the cumulative activity of theWIPP radionuclide inventory.No changes sincebaseline inspection.The INL-CCP WAGS isappropriate for the wastecontainers assayed in terms ofradionuclide content and matrix.CCP-INL-WAGS-001, Revision 0, April 27, 2005,and Revision 1, April 2, 2008; WAGS BDRsINNDAW060008, INNDAW080049, andINNDAW080065.Confirm the radionuclides that are derived by theapplication of scaling factors and/or correlationtechniques and the technical adequacy of thesetechniques.No changes sincebaseline inspection.The INL-CCP WAGS continuesacceptable operation.CCP-INL-WAGS-001, Revision 0, April 27, 2005,and Revision 1, April 2, 2008; WAGS BDRsINNDAW060008, INNDAW080049, andINNDAW080065.Acceptable Knowledge (AK)Confirm when NDA personnel use AK-derivedisotopic values and identify the formal procedurecontrolling this function.No changes sincebaseline inspection.Isotopics are based on MGA,measurement statisticspermitting. Only approvedAK-based isotopics are used.CCP-TP-019, Revision 4; CCP-TP-109, Revision 5.Evaluate the AK used for the wastes and/orwaste streams assayed by the WAGS and ensurethat all radionuclides encountered fit under theWAGS’s approved AK.No changes sincebaseline inspection.For approximately half of theassays, MGA cannot produceuseable isotopic values becauseof low Pu or elevated241Am.ARP wastes contain moreuranium than legacy wastes.MGA-U is used for less than 5%of samples and they arepredominantly DU. 1%–2% ofdrums measure less than theInterviews with INL-CCP WAGS personnel duringthis inspection; CCP-TP-019, Revision 4.A.1-3NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGSEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Required Technical ElementsChanges Since Baseline?Verification of ActivityObjective EvidenceLLD, 5%–10 % of ARP drumsmeasure less than 100 nCi/g.1% of legacy wastes lack ameasurable TRU signature uponassay.Isotopic DeterminationIdentify the radionuclides that are measureddirectly.No changes sincebaseline inspection.238Pu,240Pu and242Pu are derivedby mass ratios to a measured239Pu;241Am and233U aremeasured directly whensufficient signal is present,otherwise they may be ratioed tothe measured239Pu value;234U isscaled to the measured238Uand/or235U;90Sr is scaled to137Cs.CCP-INL-WAGS-001, Revision 0, April 27, 2005,and Revision 1, April 2, 2008; WAGS BDRsINNDAW060008, INNDAW080049, andINNDAW080065.Confirm that the method(s) used to derive theisotopic contribution for unmeasuredradionuclides are MGA and MGA-U.No changes sincebaseline inspection.MGA and MGA-U are integralparts of the WAGS operation.CCP-TP-019, Revision 4; Interviews with INL-CCPWAGS personnel during this inspection; WAGSBDRs INNDAW060008, INNDAW080049, andINNDAW080065.Lower Level of Detection (LLD)Confirm that the LLD for the WAGS has beendetermined.No changes sincebaseline inspection.Interviews with INL-CCPWAGS personnel duringinspection.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 andcontainer-specific interferences must beaccounted for in LLD determinations.No changes sincebaseline inspection.Interviews with INL-CCPWAGS personnel duringinspection.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 discriminateTRU/Non-TRU wastes and that it has therequired sensitivity.No changes sincebaseline inspection.Interviews with INL-CCPWAGS personnel duringinspection.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.1-4NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGSEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Required Technical ElementsChanges Since Baseline?Verification of ActivityObjective EvidenceIdentify any/all instances where an LLD valuefor anon-measuredradionuclide is not providedbased on a lack of technical feasibility.No changes sincebaseline inspection.INL-CCP states that it is nottechnically feasible to provide anLLD equivalent for234U.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 determinationor documentation for the WAGS since thebaseline approval.No changes to TMU sinceEPA baseline inspection.Interviews with INL-CCPWAGS personnel duringinspection.CCP-INL-WAGS-002, Total MeasurementUncertainty for the WAGS System, not numbered,April 20, 2005.Evaluate the magnitude of the TMU valuesobserved in the WAGS BDRs that wereexamined during this inspection.No changes to TMU sinceEPA baseline inspection.TMU values in BDRs aregenerally consistent withexpectations based on CCP-INLWAGS-002.CCP-INL-WAGS-002, Total MeasurementUncertainty for the WAGS System, not numbered,April 20, 2005; BDRs INNDAW060008,INNDAW080049, and INNDAW080065.System CalibrationConfirm the WAGS’s calibration of record. No changes sincebaseline inspection.The gamma energy andefficiency calibrations have beenperformed and documentedappropriately.CCP-INL-WAGS-001, Revision 0, April 27, 2005and Revision 1, April 2, 2008.Confirm the WAGS’s operational range withrespect to matrix (density) and activity.Yes Initial density range wasextended in 2008 to 2.10 g/cm3with a specific limit on 59 keV241Am line for densities from1.62 to 2.10 g/cm3, approved byEPADocket No: A-98-49; IIA4-107, September 2008.CCP-INL-WAGS-08-002, WAGS Multi-CurveEfficiency Calibration Extension Addendum,Revisions 0 and 1.Identify the consensus standards that were usedfor the system calibration or the alternatecalibration technique and CBFO approval, ifapplicable.No changes sincebaseline inspection.Consensus standards are ASTMC-1030, ASTM C-1133, ASTMC-1215 and E-181-98 (2003).CCP-INL-WAGS-001, Revision 0, April 27, 2005,and Revision 1, April 2, 2008.A.1-5NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGSEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Required Technical ElementsChanges Since Baseline?Verification of ActivityObjective EvidenceList the standards used for calibration and verifythe pedigree of each standard.No changes sincebaseline inspection;however, due to thenature of the standards,different configurationsof the same standardsmay have been used.All radionuclide standards andtheir 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 CalibrationExtension Addendum, Revisions 0 and 1.Calibration Verification and ConfirmationConfirm that the WAGS’s calibration had beenconfirmed.Yes Initial calibration is valid,additional measurements weremade to support the densityrange 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 CalibrationExtension Addendum, Revisions 0 and 1.Determine if the WAGS has been recalibratedsince the calibration of record listed above.The WAGS had not beenrecalibrated since thebaseline 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 CalibrationExtension Addendum, Revisions 0 and 1.Determine the number of calibrationverifications that have been performed since thebaseline approval and that all were appropriatelydocumented, if applicable.Yes Calibration verifications sincebaseline 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 radionuclidestandards that were used for calibrationconfirmation and/or verifications. List orreference all standards used.No changes since thebaseline inspection.The radionuclide content andpedigree of all standards havebeen 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 CalibrationExtension Addendum, Revisions 0 and 1.Requirements for accuracy and precision must bemet, as specified in DOE/WIPP-02-3122,Appendix A, Table A-3.2 for calibrationverifications.Yes Criteria for precision andaccuracy were met forcalibration verifications.CCP-INL-WAGS-06-005, June 7, 2006; CCP-INLWAGS-08-004, April 1, 2008; CCP-INL-WAGS08-003, April 24, 2008.A.1-6NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGSEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Required Technical ElementsChanges Since Baseline?Verification of ActivityObjective EvidenceQuality ControlAll WAGS calibration, operation, and datavalidation activities must be performed byappropriately trained and qualified personnel.No changes since EPAbaseline inspection.All levels of INL-CCP WAGSpersonnel were interviewed.CCP-INL LOQI.Identify the name, title, and function of allpersonnel performing NDA data validation.No changes since EPAbaseline inspection.All INL-CCP WAGS personnelwere identified and appropriatelyqualified.CCP-INL LOQI.Confirm the WAGS’s status with respect to theCBFO NDA PDP.Yes Successful participation in NDACycle 14 A in May 2007 forcombustibles, metals and sludge;Cycle 15A in June 2008.CBFO PDP Approval Letter.Background and Performance ChecksConfirm that WAGS background measurementshave been taken daily.No changes since EPAbaseline inspection.All records evaluated indicatecompliant backgroundperformance.WAGS Operational Logbook; WAGS BDRsINNDAW060008, INNDAW080049, andINNDAW080065.Assess how often background radiation wasproblematic to the extent that measurementpersonnel had to make adjustments.No changes since EPAbaseline inspection.No instances of problematicbackgrounds were observed.WAGS BDRs INNDAW060008, INNDAW080049,and INNDAW080065.Identify the criteria used to evaluate instrumentbackgrounds and assess the technical adequacyof this criterion, i.e., statistical or administrative.No changes since EPAbaseline inspection.Criteria for instrumentbackground are provided in theWAGS 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 BDRsINNDAW060008, INNDAW080049, andINNDAW080065.Confirm that system performance checks havebeen performed at least once per operational day.Confirm that performance checks includeefficiency, matrix correction checks, and gammapeak position and resolution checks.No changes since EPAbaseline inspection.The WAGS daily performanceassays include checks forenergy/channel, FWHM, Pumass, and efficiency (WeeklyInterfering Matrix Checks).CCP-TP-019, Revision 4, Sections 4.5 and 4.6;WAGS BDRs INNDAW060008, INNDAW080049,and INNDAW080065; Weekly Interfering MatrixResults for three 6-month periods.A.1-7NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGSEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Required Technical ElementsChanges Since Baseline?Verification of ActivityObjective EvidenceCompare the current control limits for allperformance checks with the limits that wereestablished initially. Identify how many datapoints are used for the initial evaluation and atwhat interval(s) new limits are calculated.No changes since EPAbaseline inspection.Initial limits were derived basedon Student T Test using 6 points.INL-CCP WAGS personnelrecalculated when they obtained100 points, which tookapproximately 4 months, August20–December 5, 2007.WAGS BDRs INNDAW060008, INNDAW080049,and INNDAW080065; AMWTP Work Order No.167576, for purpose of updating WAGS QAparameters.Confirm that all radioactive sources used forperformance checks have been decay correctedas a function of their physical half-life.No changes since EPAbaseline inspection.In NDA 2000, the SourceCertificate file is created andupdated automatically toproduce current values for133Ba,152Eu, and241Am.CCP-INL-WAGS-001, Revision 0, April 27, 2005,and Revision 1, April 2, 2008; CCP-INL-WAGS-08-002, WAGS Multi-Curve Efficiency CalibrationExtension Addendum, Revisions 0 and 1.Data ManagementAll WAGS data must be reviewed and approvedby qualified personnel. Identify the name, title,and function of the individual(s) performingtechnical review and approval of WAGS BDRs.Yes All WAGS BDRs evaluatedcontained evidence of review byappropriately qualifiedpersonnel.INL-CCP LOQI; WAGS BDRs INNDAW060008,INNDAW080049, and INNDAW080065.WAGS BDRs must consist of the followingelements:•Testing facility name, testing batch number,container numbers, and signature of the SiteProject Officer (SPO) or designee(s)•Table of Contents•Background and performance check data orcontrol charts for the relevant time period•Data validation per the QAPD and siteprocedures•Separate testing report sheets for eachcontainer.Yes All WAGS BDRs contained therequired elements.WAGS BDRs INNDAW060008, INNDAW080049,and INNDAW080065.A.1-8NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, WAGSEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Required Technical ElementsChanges Since Baseline?Verification of ActivityObjective EvidenceWAGS RDSs must include:•Title “Radioassay Data Sheet”•Method/procedure used•Date of radioassay•Activities and associated TMU for individualradionuclides•TRU alpha concentration and its associatedTMU•Operator and reviewer signaturesYes All WAGS RDSs contained therequired elements.BDR INNDAW060008 – Container Nos. 10041591and 10041595.BDR INNDAW080049 – Container No. ARP06138.BDR INNDAW080065 – Container Nos. ARP05,ARP06549, and ARP06631.A.2-9ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, SUPERHENCNONDESTRUCTIVE ASSAY (NDA) CHECKLIST, SUPERHENCEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Required Technical ElementsChange Since Baseline?Verification of ActivityObjective EvidenceSystem DescriptionConfirm the name, location, and numberof the INL-CCP SuperHENC. Ensurethat this is the same unit approved duringthe EPA baseline inspection in 2005.No changes since EPAbaseline inspection.EPA personnel verified that the SuperHENC assayunit is the same as observed during the baselineinspection.Visual inspection of SuperHENC in trailer atSWEPP at INL during inspection.Identify any hardware and/or softwarechanges made to the SuperHENC sincethe baseline approval. Determine whichchanges, if any, are significant, wherethey are documented, and how theyaffect the SuperHENC’s baselineapproval.Yes Two calibration verifications were performed:anH-3 tube was replaced and the Add-a-Source motorwas replaced, and both were documented incalibration verifications. CCP-TP-146 was revised;Revision 4 replaced by Revision 5.CCP-SHENC-07-001, INL SuperHENCCalibration Verification, Revision 0,January 10, 2007.List all applicable calibration,operational and data reduction/validationprocedures, and the current revisions thatare in use for the SuperHENC.Yes All procedures observed in the SuperHENC trailerwere the current revisions.CCP-TP-170, Revision 2; CCP-TP-146,Revision 5; CCP-TP-148, Revision 4.System PerformanceIdentify the following:•Type (size) of waste containersassayed by SuperHENC•Number of waste containers thissystem assayed during the period ofperformance•Number of BDRs assembled•Number of BDRs that have beenpromoted through Project LevelReviewYes SWBs containing four 55-gallon drums of S3000sludge – no assays in FY 2007, 14 assays in FY2008.100-gallon overpacks with pucks of S5000 debris –200 assays in FY 2007, 555 assays in FY 2008.SWBs with two 100-gallon drums, each containingpucks of S5000 debris – no assays in FY 2007 or2008.Assays of S4000 waste in any configuration – noassays in FY 2007 or 2008.Interviews with INL-CCP SuperHENCpersonnel; CCP VPM SWB/100 GALLONCONTAINER listing, 19 pages, datedSeptember 16, 2008, 11:47 AM, generated atthe request of EPA.A.2-10NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, SUPERHENCEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Required Technical ElementsChange Since Baseline?Verification of ActivityObjective EvidenceGeneral Reporting RequirementsConfirm that the SuperHENC providesquantitative values and uncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr, and137Cs. Identify otherradionuclides that are encountered duringroutine assays.No change since baselineinspection.The INL-CCP SuperHENC continues acceptableoperation.BII-5221-CVR-001,Calibration andValidation Report SuperHENC Mobile AssaySystem, Revision 0, November 2006;SuperHENC BDRs INNDAB08001 throughINNDAB08005.Each container characterized by theSuperHENC that is intended for disposalat WIPP must contain TRU waste.No change since baselineinspection.The INL-CCP SuperHENC continues acceptableoperation.BII-5221-CVR-001,Calibration andValidation Report SuperHENC Mobile AssaySystem, Revision 0, November 2006;SuperHENC BDRs INNDAB08001 throughINNDAB08005.SuperHENC procedures are appropriatefor the waste streams being assayed andthe results provide unbiased values forthe cumulative activity of the WIPPradionuclide inventory.No change since baselineinspection.The INL-CCP SuperHENC continues acceptableoperation.BII-5221-CVR-001,Calibration andValidation Report SuperHENC Mobile AssaySystem, Revision 0, November 2006;SuperHENC BDRs INNDAB08001 throughINNDAB08005.Confirm the radionuclides that arederived by the application of scalingfactors and/or correlation techniques andthe technical adequacy of thesetechniques.No change since baselineinspection.The INL-CCP SuperHENC continues acceptableoperation.BII-5221-CVR-001,Calibration andValidation Report SuperHENC Mobile AssaySystem, Revision 0, November 2006;SuperHENC BDRs INNDAB08001 throughINNDAB08005.Acceptable Knowledge (AK)Confirm when NDA personnel use AKderived isotopic values and identify theformal procedure controlling thisfunction.No change since baselineinspection.Specific criteria have been established for theapplication of AL-based isotopics and they areimplemented by the EA for all (100%) SuperHENCassays.BII-5221-CVR-001, Appendix V, page 71(iii); function of the240PuEFFFitness Factor(FF):•FF < 0.17 – AK-based isotopics•FF > 0.4 – FRAM isotopics•FF 0.4 > FF >0.17 – Isotopicsdetermined by EAA.2-11NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, SUPERHENCEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Required Technical ElementsChange Since Baseline?Verification of ActivityObjective EvidenceEvaluate the AK used for the wastesand/or waste streams assayed by theSuperHENC and ensure that allradionuclides encountered fit under theSuperHENC’s approved AK.No change since baselineinspectionTwo different AK isotopics: RPT-TRUW-07 (BN510) for AMWTP wastes; CCP-AK-INL-005 NDAMemo for INL-CCP wastes.CCP-TP-148, Revision 4; SuperHENC BDRsINNDAB08001 through INNDAB08005.Isotopic DeterminationIdentify the radionuclides that aremeasured directly and their specificradiation type of each (gamma or passiveneutron).No change since baselineinspection.All radionuclides are identified by the gamma and/orneutron emission of each.BII-5221-CVR-001,Calibration andValidation Report SuperHENC Mobile AssaySystem, Revision 0, November 2006.Lower Level of Detection (LLD)Confirm that the LLD for theSuperHENC has been determined forpassive neutron and gamma modes.No change since baselineinspection.Interviews with INL-CCP SuperHENC personnelduring inspection.BII-5221-CVR-001,Calibration andValidation Report SuperHENC Mobile AssaySystem, Revision 0, November 2006.Site-specific environmental backgroundsand container-specific interferences mustbe accounted for in LLD determinations.No change since baselineinspection.Interviews with INL-CCP SuperHENC personnelduring inspection.BII-5221-CVR-001,Calibration andValidation Report SuperHENC Mobile AssaySystem, Revision 0, November 2006;SuperHENC BDRs INNDAB08001 throughINNDAB08005.Confirm if the SuperHENC is used todiscriminate TRU/Non-TRU wastes atthe 100 nCi/g criterion and that it has therequired sensitivity.No change since baselineinspection.There were approximately twelve 100-gal drumswhere the assay values were <100 nCi/gram.Interviews with INL-CCP SuperHENCpersonnel during inspection.Identify any/all instances where an LLDequivalent is derived. Identify if an LLDvalue for anon-measuredradionuclide isnot provided, based on a lack oftechnical feasibility.No changes to LLD sinceEPA baseline inspection.LLD equivalentsfor241Am,238Pu,239Pu,240Pu,241Pu,and242Pu are determined by rationing them to theLLD for the240PuEffbased on their mass fractions.LLD equivalentfor234U derived by scaling to235Uand238U, and90Sr to137Cs.BII-5221-CVR-001,Calibration andValidation Report SuperHENC Mobile AssaySystem, Revision 0, November 2006.A.2-12NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, SUPERHENCEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Required Technical ElementsChange Since Baseline?Verification of ActivityObjective EvidenceTotal Measurement Uncertainty (TMU)Identify any changes in the TMUdetermination or documentation for theSuperHENC since the baseline approval.No changes to TMU sinceEPA baseline inspection.Interviews with INL-CCP SuperHENC personnelduring inspection.BII-5221-CVR-001,Calibration andValidation Report SuperHENC Mobile AssaySystem, Revision 0, November 2006,Section 4.11Evaluate the magnitude of the TMUvalues observed in the SuperHENCBDRs that were examined during thisinspection.TMU values in BDRs are generally consistent withexpectations based on CVR.SuperHENC BDRs INNDAB08001 throughINNDAB08005.System CalibrationConfirm the SuperHENC’s calibration ofrecord.No changes since EPAbaseline inspection.The SuperHENC was calibrated at RFETS before itsinitial use at INL-CCP and the calibration of recordhas been documented. Calibrations include passiveneutron for240PuEffand gamma for relative ratiomode (isotopics) operation only.BII-5221-SRF-001, SuperHENC RFETSCalibration Documentation Package; BII5221-CVR-001,Calibration and ValidationReport SuperHENC Mobile Assay System,Revision 0, November 2006.Confirm the SuperHENC’s operationalrange with respect to matrix (density)and activity.No changes since EPAbaseline inspection.The range of applicability of the SuperHENC’scalibration has been specified and documented.BII-5221-CVR-00112, CCP-TP-146, andCCP-TP-170 state the range as 12.658 g240PuEffor 203.8 g Pu total.Primary standards must be obtained fromsuppliers maintaining a nationallyaccredited measurement program.Identify the nationally accreditedmeasurement program.No changes toradionuclide standardssince EPA baselineinspection.Interviews with INL-CCP SuperHENC personnelduring inspection.BII-5221-CVR-001,Calibration andValidation Report SuperHENC Mobile AssaySystem, Revision 0, November 2006.Calibration Verification and ConfirmationConfirm the SuperHENC’s gamma andpassive neutron calibrationconfirmations.No changes since EPAbaseline inspection.Both gamma and neutron calibrations had beenappropriately confirmed and documented.BII-5221-CVR-001,Calibration andValidation Report SuperHENC Mobile AssaySystem, Revision 0, November 2006.Determine if the SuperHENC has beenrecalibrated since the calibration ofrecord listed above.The SuperHENC has notbeen recalibrated sinceEPA baseline inspection.Not Applicable Not ApplicableA.2-13NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, SUPERHENCEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Required Technical ElementsChange Since Baseline?Verification of ActivityObjective EvidenceDetermine the number of calibrationverifications that have been performedsince the baseline approval and that allwere appropriately documented, ifapplicable.Yes Two calibration verifications were performed:an H3 tube was replaced and the Add-a-Source motor wasreplaced, and both were documented in calibrationverifications.CCP-SHENC-07-001, INL SuperHENCCalibration Verification, Revision 0,January 10, 2007.Confirm the pedigree of all radionuclidestandards that were used for calibrationconfirmation and/or verifications. List orreference all standards used.No changes since EPAbaseline inspection.Interviews with INL-CCP SuperHENC personnelduring inspection.BII-5221-CVR-001,Calibration andValidation Report SuperHENC Mobile AssaySystem, Revision 0, November 2006.Requirements for accuracy and precisionmust be met, as specified in DOE/WIPP02-3122, Appendix A, Table A-3.2 forcalibration verifications.Yes Accuracy and precision criteria were met for bothcalibration verifications.CCP-SHENC-07-001, INL SuperHENCCalibration Verification, Revision 0, January10, 2007.Quality ControlAll SuperHENC calibration, operation,and data validation activities must beperformed by appropriately trained andqualified personnel.No changes since EPAbaseline inspection.All levels of INL-CCP SuperHENC personnel wereinterviewed.INL-CCP LOQI.Identify the name, title, and function ofall personnel performing NDA datavalidation.Yes All levels of INL-CCP SuperHENC personnel wereinterviewed.INL-CCP LOQI.Confirm the SuperHENC’s status withrespect to the CBFO NDA PDP.Yes Successful participation in Cycle B7A, November2007. Cycle B8A will be reported by November 18,2008.CBFO PDP Scoring Letter.Background and Performance ChecksConfirm that SuperHENC backgroundmeasurements have been taken daily.No changes since EPAbaseline inspection.All records evaluated indicate compliant backgroundperformance.SuperHENC operational logbook;SuperHENC BDRs INNDAB08001 throughINNDAB08005.Assess how often background radiationwas problematic to the extent thatmeasurement personnel had to makeadjustments.No changes since EPAbaseline inspection.No instances of problematic backgrounds wereobserved.Interviews with INL-CCP SuperHENCpersonnel.A.2-14NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, SUPERHENCEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Required Technical ElementsChange Since Baseline?Verification of ActivityObjective EvidenceIdentify the criteria used to evaluateinstrument backgrounds and assess thetechnical adequacy of this criterion.No changes since EPAbaseline inspection.Gamma limit is 125.98170 cps; neutron limit is 3times the mean of the calibration baseline.BII-5221-CVR-001, Section 4.7, andAppendix II, pages 9 and 54; CCP-TP-146,Revision 5.Compare the current background controllimit with the limit established initially.No changes since EPAbaseline inspection.Initial control limits are still in effect. BII-5221-CVR-001, Section 4.7, andAppendix II, page 54; CCP-TP-146,Revision 5.Confirm that system performance checkshave been performed at least once peroperational day. Confirm thatperformance checks include gamma andneutron efficiency, matrix correctionchecks, and gamma peak position andresolution checks.No changes since EPAbaseline inspectionDaily checks include gamma background, calibrationand FWHM; neutron checks include singles rate,empty SWB, and240PuEFFmass.BII-5221-CVR-001, Section 4.7 andAppendix II; SHENC operational logbook;SuperHENC BDRs INNDAB08001 throughINNDAB08005.Compare the current control limits for allperformance checks with the limits thatwere established initially. Identify howmany data points are used for the initialevaluation and at what interval(s) newlimits are calculated.No changes since EPAbaseline inspectionNine data points were used for the initial evaluation;limits are evaluated after accumulatingapproximately 30 data points.BII-5221-CVR-001,Calibration andValidation Report SuperHENC Mobile AssaySystem, Revision 0, November 2006.Confirm that all radioactive sources usedfor performance checks have been decaycorrected as a function of their physicalhalf-life.No changes since EPAbaseline inspectionInterviews with INL-CCP SuperHENC personnelduring inspection.BII-5221-CVR-001, Section 4.7 andAppendix II, pages 9 and 54; CCP-TP-146,Revision 5.Data ManagementAll SuperHENC data must be reviewedand approved by qualified personnel.Identify the name, title, and function ofthe individual(s) performing technicalreview and approval of SuperHENCBDRs.Yes All SuperHENC BDRs evaluated contained evidenceof review by appropriately qualified personnel.CCP-INL LOQI; SuperHENC BDRsINNDAB08001 through INNDAB08005.A.2-15NONDESTRUCTIVE ASSAY (NDA) CHECKLIST, SUPERHENCEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Required Technical ElementsChange Since Baseline?Verification of ActivityObjective EvidenceSuperHENC BDRs must consist of thefollowing elements:•Testing facility name, testing batchnumber, container numbers, andsignature of the Site Project Officer(SPO) or designee(s)•Table of Contents•Background and performance checkdata or control charts for the relevanttime period•Data validation per the QAPD andsite procedures•Separate testing report sheets for eachcontainerYes All SuperHENC BDRs contained the requiredelements.SuperHENC BDRs INNDAB08001 throughINNDAB08005.SuperHENC RDSs must include:•Title “Radioassay Data Sheet”•Method/procedure used•Date of radioassay•Activities and associated TMU forindividual radionuclides•TRU alpha concentration and itsassociated TMU•Operator and reviewer signaturesYes All SuperHENC RDSs contained the requiredelements.BDR INNDAB080001 – SWB No.BN10211039.BDR INNDAB080002 – SWB Nos.BN10211037, BN10211038, andBN10215259.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.3-1ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTREAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Establishment of RequiredTechnical Elements inProceduresLocationExecution of ProceduresObjective Evidence/CommentsRTR-1: Site procedures identifyrequired training andqualifications for RTRpersonnel.CCP-TP-028, Rev. 3CCP-QP-002,Rev. 26Operator training was consistent withapplicable procedures.Operator certification is current.OJT was documented for each operator.Operators are re-qualified every two years.RTR operators passed a training drum testthat includes items common to the wastestreams examined at the site (biannually).RTR operators receive training on thewaste matrix parameters and typicalpackaging configurations expected in eachwaste stream.At the time of the baseline inspection, RTR Unit No.2 was usedby CCP for radiographic examinations. EPA was informed byCBFO in the Tiering Change Report dated March 3, 2006, thatCCP had added RTR Unit No. 5 at INL and procedure CCP-TP102 was revised accordingly. This unit had previously been inoperation at the NTS. CBFO reported in a subsequent T2change report that procedure CCP-TP-102 had been cancelledand procedure CCP-TP-053 would be used for performing RTRexaminations. RTR Unit No. 5 is located in Building 610.Operators at INL received training for RTR Unit No.5, titledTraining for Idaho National Laboratory Real-time Radiography– System 5, on September 14, 2005, and the first examinationstook place on September 21, 2005. Since that date,operatorshave been re-qualified every 2 years, as required.Test container INL-NDE-TEST-34 was used for operatordemonstration of capability examinations, and it contains bothS3000 and S5000 waste. EPA reviewed the written record andaudio/visual recordings, dated April 24, 2008, fordemonstrationof capability examinations of two operators. EPA determinedthat the examinations were complete and there werenodiscrepancies between the written and audio/visualrecords.Objective evidence:1Nondestructive Examination Real-time RadiographyOperator/ITR Qualification Cards for two operators2Current List of Qualified Individuals (LOQI) for RTR3Demonstration of Capability DVD and hard copy dataformsfor two operators4CCP-AK-INL-005, Revision 2A.3-2REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Establishment of RequiredTechnical Elements inProceduresLocationExecution of ProceduresObjective Evidence/CommentsRTR-2: Site procedure(s)provide complete instructionsfor operators to perform theRTR examination andcompletion of the associateddocumentation.CCP-TP-053, Rev. 6,Sect. 4.0RTR operator adequately explained theprocess followed for examining acontainer and entering data into data forms(whether hard copy or electronic dataentry is used).Procedure CCP-TP-053 is used for performance of RTRexaminations. Table 3 of the procedure is a WasteItem Weightstable, providing weights for frequently encountereditems. EPAobserved the RTR examination of container Nos. 10233789(S3114) and 10163250 (S5300) during the on-site inspection. Asecond RTR operator completed electronic data formsas wasteitems were identified by the operator performing theexamination. At the end of the demonstration, bothoperatorsreviewed the WMPs for accuracy and completeness andassignedweights to each. The procedure was determined to be completeand adequately implemented.Procedure CCP-TP-119 is used for powering up, loading, andunloading containersObjective evidence:1BDRs 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 checkto be performed.CCP-TP-053, Rev. 6,Sect. 4.3.4,Attachment 1Operator adequately explained how theacceptability of an image is determinedImage quality test (IQT) check isperformed once per dayLDA acceptability test performed atbeginning of each shiftPerformance of the image quality check isdocumented and recordedThe EPA observed two RTR events during the on-sitevisit, butthe IQT had already been performed for that day. However,EPA was able to review the DVD recording of this test anddetermined it was performed and recorded in accordance withprocedure requirements. This process was observedforcontainer Nos. 10233789 (S3114) and 10163250 (S5300).INL-CCP does not have an LDA.Objective evidence:1BDRs S5300 and S3114, INRTR5080061 (June 4, 2008),INRTR5080078 (July 23, 2008), and INRTR5080081(September 10, 2008).2DVD recording of IQT performed on September 16, 2008A.3-3REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Establishment of RequiredTechnical Elements inProceduresLocationExecution of ProceduresObjective Evidence/CommentsRTR-4: The procedure allowsthe operator to adjust the RTR toaccommodate the physicalproperties of the waste andwaste containers likely to beencountered at the site.CCP-TP-053, Rev. 6,Sect. 4.4.2Operator could identify applicable policiesand procedures governing the operation ofRTR equipment.The RTR system could be adjusted.High-density material was examined withthe X-ray device set on the maximumvoltage and low-density material at alower voltage.Operator adequately explained what isdone if an image is unacceptable (e.g., thewaste is solidified or the container is leadlined).Through interview of RTR operators, EPA determinedthat theywere properly trained and performed RTR examinations inaccordance with procedure CCP-TP-053. During theexaminations observed by EPA, the operator scannedthecontainer from side to side and from top to bottom,identifyingwaste items as they were encountered. The voltagesettings wereadjusted, so that items of varying density could beidentified.The operator was able to explain what process is followed if aprohibited item was found in a container.Objective evidence:1BDRs 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 1RTR tape is high quality, the sound trackis audible, and the required information iscontained on the audible portion of thetape.The RTR tape is consistent with the datapackage for the same container.The audio/visual recordings made are on DVD ratherthan VHStapes. EPA compared the written record (BDR) and theaudio/visual recordings of four containers to ensurecompleteness, clarity, and consistency. No differences betweenthe two records were found, and EPA determined thattheexaminations and records generated were complete and correct.Objective evidence:1BDRs S5300 and S3114, INRTR5080061 (June 4, 2008),INRTR5080078 (July 23, 2008), and INRTR5080081(September 10, 2008).2DVD recordings of VE events for container Nos. 10220098,10230860, 10233749, and 10219863RTR-6: There is a procedure fordetermining whether the wastematches the waste streamdescription and Waste MatrixCode, and for determiningCCP-TP-053, Rev. 6,Sect. 4.4.3,Attachment 2The procedure is adequately implemented.Operators verify that the waste matchesthe waste stream description.The WMC is verified. If not, correctiveDuring the demonstration, the operator had a copy of procedureCCP-TP-053 open at the work station and used it toguide theRTR examination. At the conclusion of the examination, theoperators assigned WMP weights for the items identified in thecontainer. Procedure CCP-TP-053 does contain a table ofA.3-4REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Establishment of RequiredTechnical Elements inProceduresLocationExecution of ProceduresObjective Evidence/CommentsWaste Material Parameters andweights.action is taken.WMP weights are estimated by compilingan inventory of waste items andresidual/packaging materials.Does the RTR operator use a standardweight lookup table to provide an estimateof WMP weights? If so, has the tablebeen updated to reflect additionalinformation gained through previousRTR/VE exams or updated AKinformation?standard weights for items, but this is rarely usedby theoperators to assign WMP weights.The operator verified that the waste items found inthe containermatched WMC and physical description of waste stream. Theoperator used the waste stream descriptions locatedin CCP-AKINL-005 to make these determinations.Objective evidence:1BDRs S5300 and S3114, INRTR5080061 (June 4, 2008),INRTR5080078 (July 23, 2008), and INRTR5080081(September 10, 2008).2CCP-AK-INL-005RTR-7: The RTR procedureprovides instructions foridentifying prohibited items andfor processing containerscontaining prohibited items.CCP-TP-053, Rev. 6,Sect. 4.3.4,Note, Table 1Operator could name prohibited items.Operator adequately explained how thepresence of free liquids is determined.Operator’s explanation of required actionsif prohibited items were encountered wasconsistent with procedure.Corrective actions are taken whennecessary.Procedure CCP-TP-053 includes a list of prohibiteditems (Table1). NCR-INL-0642-08 was written because a prohibited itemwas found in container No.10217951. The NCR was processedas required.Objective evidence:1BDRs S5300 and S3114, INRTR5080061 (June 4, 2008),INRTR5080078 (July 23, 2008), and INRTR5080081(September 10, 2008).2NCRs NCR-INL-0652-07, NCR-INL-0637-08, NC-INL0655-08, NCR-INL-0643-08, and NCR-INL-0642-08RTR-8: RTR procedures includethe required QC examinations,evaluation accuracy, andreproducibility of the RTRprocess.CCP-TP-053, Rev. 6,Sects. 4.5 and 4.6An independent replicate scan isperformed on one waste container per dayor on one container per testing batch(whichever is less frequent).A qualified RTR Operator performs anindependent observation of one scan otherthan the replicate. An independent RTROperator is any qualified RTR operatorThe required quality control examinations were performed asrequired.In BDR INRTR5080061, the replicate scan was performed oncontainer No. 10218573 and a second RTR operator performedan independent observation on container No. 10215819.In BDR INRTR5080078, the replicate scan was performed oncontainer No. 10223052 and a second RTR operator performedA.3-5REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Establishment of RequiredTechnical Elements inProceduresLocationExecution of ProceduresObjective Evidence/Commentsexcept the one who performed the initialRTR.an independent observation on container No. 10219826.In BDR INRTR5080081, the replicate scan was performed oncontainer 10232567 and a second RTR operator performed anindependent observation on container No. 10233749.Objective evidence:1BDRs S5300 and S3114, INRTR5080061 (June 4, 2008),INRTR5080078 (July 23, 2008), and INRTR5080081(September 10, 2008).2CCP LOQIRTR-9: Procedure(s) containstandardized forms for recordingRTR data.CCP-TP-053, Rev. 6,Sect 4.3.4,Attachment 2RTR operator adequately explained theprocess followed for examining acontainer and entering data into data forms(whether hard copy or electronic dataentry is used).The RTR operator performs direct dataentry into an electronic form using acomputer while he/she is still in the RTRbooth.The electronic data file undergoes thesame QC checks used for hand-writtendata entries.EPA reviewed the written (BDR) records for container Nos.10220098 (S3114), 10230860 (S5300), 10233749 (S3114), and10219863 (S5300). During the demonstration RTR examination,the operator called out the waste items identifiedas the containerwas scanned and a second operator entered these data into theelectronic forms (CCP Radiography Data Sheet, Attachment 2,CCP-TP-053). The data sheet for each container isincluded inthe BDR. BDRs are subject to both data generationlevel byIndependent Technical Review (ITR) and project level review bythe Site Project Manager (SPM).Objective evidence:1BDRs S5300 and S3114, INRTR5080061 (June 4, 2008),INRTR5080078 (July 23, 2008), and INRTR5080081(September 10, 2008).RTR-10: Site procedures requirereview of BDRs at the datageneration and project level.CCP-TP-053, Rev. 6,Sect. 4.10 (ITR)Data generation level reviews areperformed and documented by the ITR.Project level reviews are performed anddocumented by the SPM.BDRs INRTR5080061 and INRTR5080078 had completed ITRand SPM checklists attached. BDR INRTR5080081 didnothave an SPM checklist, because the BDR was only generatedSeptember 10, 2008, and had not been through the SPM review.All checklists were completed and signed as required.A.3-6REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH InspectionInspection Date: September, 16–18, 2008Establishment of RequiredTechnical Elements inProceduresLocationExecution of ProceduresObjective Evidence/CommentsObjective evidence:1BDRs S5300 and S3114, INRTR5080061 (June 4, 2008),INRTR5080078 (July 23, 2008), and INRTR5080081(September 10, 2008).A.3-7Information included in BDRRequired Testing Batch ContentPresentY or NRequired Testing Batch ContentPresentY or NRequired Testing Batch ContentPresentY or NBatch date Y Verification that waste matches wastestream description Y Container gross weight YReport date Y Estimated weights for WMPs Y Reference to or copies of any NCRs YWaste container number Y Layers of confinement Y Operator signature and test date YWaste matrix code Y Indication of vented rigid liners Y Data generation checklist YVideotape reference Y Description of container contents Y Project level checklist YDescription of liners Y Indication of sealed containers >4L YQC documentation Y Amount of free liquidYA.4-1ATTACHMENT A.4: VISUAL EXAMINATION TECHNIQUE (VET) CHECKLISTVISUAL EXAMINATION TECHNIQUE (VET) CHECKLISTEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH VETInspection Date: September 16–18, 2008Establishment of RequiredTechnical Elements inProceduresLocationExecution of ProceduresObjective Evidence/CommentVE-1:Site procedures identifyrequired training andqualifications for VE personnel.CCP-QP-002,Rev. 26Visual Examination Expert (VEE) has beenappointed.VE personnel’s training was consistent withapplicable procedures.VE personnel’s certification is current.VE personnel are re-qualified every 2 years.VE personnel received training on specificwaste generating processes, typical packagingconfigurations, and the WMPs that areexpected to be found in each WMCVE is performed for newly-generated or repackaged waste from theARPs. VE for ARP1 is performed in Building WMF 697and VE forARP2 is performed in Building WMF 1612.Two trained operators perform the VE, and a VEE ispresent toprovide assistance, if needed. The EPA reviewed training records for1 Operator/ITR/TS/FQAO (VEE) and 11 Operators/ITRs.All VEpersonnel received specific training for the wasteexamined through atraining module titled,Specific Training for Idaho NationalLaboratory – Newly-generated TRU Waste Retrieved from the Pits.Objective evidence:1Training records and Qualification Cards for 1 VEEand 11Operators/ITRs2CCP LOQIVE-2:Procedures and technicalguidance documents providecomplete instructions forperforming VE.CCP-TP-006,Rev. 12,Sect. 4.0Audio/visual recording of VE event includesdate, container ID number, waste items,WMPs, and operators (if applicable).Two trained operators perform VE and datacollection/recording.Procedures are sufficiently detailed to enablethe operator to determine if a waste containermeets the criteria of 40 CFR 194.24 withregard to identifying applicable parameterswith waste limits.Two trained and qualified operators perform VE, butan audio/visualrecording is not made. Both operators are requiredto sign the datasheets recording the waste items identified duringthe VE event.There are 11 Drum Packaging Stations (DPSs) available for VE ofwaste from ARP1 and APR2. At the time of the inspection, one DPSwas not in use. The DPSs are gloveboxes and are operated by CWIpersonnel, but all VE operators and VEEs are CCP personnel.The EPA inspectors observed VE of waste in the DPSduring theon-site visit. Because of radiological concerns, the EPA was onlyable to observe from the radiation barrier. However, EPA was ableto see operators sorting waste and the VE data being recorded.The EPA reviewed three BDRs, which included VE forS3000,S4000, and S5000 waste. The data sheets for the containerscontained in each BDR were properly completed and had beenA.4-2VISUAL EXAMINATION TECHNIQUE (VET) CHECKLISTEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH VETInspection Date: September 16–18, 2008Establishment of RequiredTechnical Elements inProceduresLocationExecution of ProceduresObjective Evidence/Commentsubjected to generation and project level reviews.Objective evidence:1BDRs 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)2Training records for VEO/ITR/TS/FQAO, VEE, and VEO/ITR3CCP LOQIVE-3: CCP-TP-006,Rev. 12,Sects. 4.1.5and 4.2, andAttachment 1,Table 4If an automated data entry system is used,data entry VE personnel could navigatethrough the various screens.A calibrated scale is used to weigh WMPs.VE personnel have access to standardizedcharts or tables to aid in the consistentestimation or assignment of weights, wastematerial 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 signthe data sheets.WMP weights are determined by weighing either the organic orinorganic part of waste, and the other part is determined bydifference between the full and empty container weights. ProcedureCCP-TP-006 provides historical weights for commonlyencountereditems 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 scalecheck records and confirmed that the scales used were withintolerance and their calibration dates. EPA also verified that thetorque wrench used to close containers at the end of the VE eventwas still within its calibration period.Either the excavator operator or VE personnel identify any prohibiteditems encountered during VE.Objective evidence:1BDRs 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.4-3VISUAL EXAMINATION TECHNIQUE (VET) CHECKLISTEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH VETInspection Date: September 16–18, 2008Establishment of RequiredTechnical Elements inProceduresLocationExecution of ProceduresObjective Evidence/CommentVE-4:There is a procedure forhandling instances when the VEExpert is unable to see throughthe inner plastic bags/packages/containers of waste.CCP-TP-006,Rev. 12,Sects. 3.1 and4.3.14,Table 4The VEE has decision-making criteria forassessing the need to open the bags/packagesin order to identify all of their contents.If the bags are not opened, a brief writtendescription of the contents of the bags isprepared, with estimates of the amount ofeach waste type in the bags.Reference tables are updated as site gainsinformation from VE.The waste, being subject to VE at the time of the inspection, wasuncontainerized when it was retrieved from the ARP.The VEE waspresent in the DPS area and was available for questions or resolvingproblems with the VE operators.Objective evidence:1BDRs 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 procedurerequires verification of WMCand WMP weights.Procedure provides instructionsfor processing of containers withprohibited items.CCP-TP-006,Rev. 12,Sect. 4.3.14,Attachment 1WMPs are identified, weighed and recordedon a data sheet; all discernible waste items,residual materials, and packaging arerecorded.A VE data form is used to documentverification of the physical form of the wasteand the WMC.WMP weights are determined by weighing either the organic orinorganic part of waste and the other part is determined by thedifferences between the full and empty container weights. ProcedureCCP-TP-006 provides historical weights for commonlyencountereditems in Table 4.The data forms completed during VE events requiresthe operators toverify the physical form of the waste and WMC.The EPA reviewed data packages to verify data entry, WMP weightassignments, and verification of the physical formof the waste andWMC.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 projectlevel reviews.Objective evidence:1BDRs 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.4-4VISUAL EXAMINATION TECHNIQUE (VET) CHECKLISTEPA Inspection No.: EPA-INL-CCP-09.08-24, INL/CCPContinuing Compliance CH VETInspection Date: September 16–18, 2008Establishment of RequiredTechnical Elements inProceduresLocationExecution of ProceduresObjective Evidence/CommentVE-6:CCP-TP-006,Rev. 12,Sect. 4.8.3,Attachment 1,Table 1Absence/presence of prohibited items.Operators explained required actions ifprohibited items were encountered.Corrective action is taken when necessary.Prohibited items are removed by the excavator operator prior towaste being delivered to the DPS or by the VE operators. Allprohibited items remain in the ARP awaiting site disposition.There were no NCRs for the containers in the BDRs reviewed byEPA.Objective evidence:1BDRs 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)2NCR-INL-0652-07 and NCR-INL00637-08VE-7: CCP-TP-006,Rev. 12,Attachments 1and 5The gross weight of the waste container(container plus contents) is recorded on theVE data form.Volume utilization of the container isdocumented.Containers are weighed outside of the DPS area on acalibrated scale.Gross and net weights for each container are recorded onAttachment 1, as well as the percent utilization ofthe container.Objective evidence:1BDRs 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) requiredata generation and project levelreviews of BDRs.CCP-TP-006,Rev. 12,Attachment 2ITR review is performed and documented.Project level review is performed as required(SPM).All of the BDRs reviewed had been reviewed at the data generationlevel (ITR) and IN-ARP-VE-000868 had both project level (SPM)and ITR checklists present. All of the checklistswere completed andsigned as required.Objective evidence:1BDRs 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.4-5Information Included in BDRRequired Testing Batch ContentPresentY or NRequired Testing Batch ContentPresentY or NRequired Testing Batch ContentPresentY or NBatch dateY Description of liners Y Verification of waste matrix code YReport dateY Layers of confinement Y Reference to or copies ofany NCRs YWaste container number Y Indication of vented rigidliners Y VEE decisions YWaste matrix codeY Description of container contents Y Operator signature and test date YImplementing procedure name or number Y Indicationof sealed containers >4L Y VEE signature and test date YVideotape referenceY Amount of free liquid Y Completed ITR checklist YQC documentationY Container gross weight Y Completed SPM checklistYVerification that waste matches waste stream description Y Waste material parameter weights YA.5-1ATTACHMENT A.5: CONTAINER MANAGEMENT CHECKLISTCCP-TP-068, CONTAINER MANAGEMENT AT THE INL AND TWCPEPA Inspection No.: EPA-INL-CCP-09.08-24, CCP/INLContinuing ComplianceInspection Date: September 16–18, 2008Establishment of RequiredTechnical Elements in ProceduresLocationExecution of ProceduresObjective Evidence/CommentsCM-1: Personnel training andqualification.CCP-TP-068,Rev. 5,Sect. 2.2.1;CCP-QP-002,Rev. 26Are personnel performing this proceduretrained and qualified in accordance withCCP-QP-002?Personnel who move containers for CCP are employeesofCWI and are trained in their procedures.Characterization personnel who implement parts of procedureCCP-TP-068 are trained and qualified in accordancewith CCPrequirements.Objective evidence:1Training records and qualification cards for RTR personnel2Training records and qualification cards for VE personnelCM-2: Retrievably-stored waste. CCP-TP-068,Rev. 5,Sects. 2.3.2–2.3.4 and 3.1,andAttachment 2Do containers subject to an NCR have a CCPHold Tag attached?Are Hold-tagged containers physicallysegregated?Does each container processed have acompleted Attachment 2, ContainerInspection Report?Are only containers that are safe to handle(Attachment 4, Structural Inspection Report)processed through the characterizationactivities?CCP employs two types of tags:Blue tag indicates that there is something missingfor thecontainer. This is not an NCR tag, but it resultsin anelectronic hold on the container. Red tags are NCRtags andthese containers cannot be processed further untilthe NCR isresolved. As containers are delivered to CCP in BuildingWMF-610, they are checked for integrity (Attachment2).This is performed while the containers are still onthetransportation truck, and containers that fail thistest arereturned to the host site without being removed from the truck.Container numbers are checked with the AK Trackingsheet toensure that only containers eligible for characterization areremoved from the transportation truck. If any containers arenot on the tracking sheet, they are returned to thehost site.Objective evidence:1Red CCP NCR tags2Blue CCP hold tags3AK Tracking sheet for CCP/INLA.5-2CCP-TP-068, CONTAINER MANAGEMENT AT THE INL AND TWCPEPA Inspection No.: EPA-INL-CCP-09.08-24, CCP/INLContinuing ComplianceInspection Date: September 16–18, 2008Establishment of RequiredTechnical Elements in ProceduresLocationExecution of ProceduresObjective Evidence/CommentsCM-3CCP-TP-068,Rev. 5,Sects. 2.3.6and 2.3.9Is the temperature of retrievably-storedcontainers monitored as necessary prior todelivery for characterization?Is there a CCP Container Traveler(Attachment 1) attached to each container tobe characterized?The VPM determines if the environmental temperaturewouldhave adversely impacted containers stored in Building WMF628. NDE operators are required to record the containertemperature on the Traveler prior to RTR examination.All of the containers inspected had a Traveler attached asrequired.CM-4: Retrievably-stored wastecontainer acceptance performed bycontainer management personnel.CCP-TP-068,Rev. 5,Sect. 4.1Verify that container is on the AK TrackingSpreadsheet.Perform container filter inspection.Verify at least 3 bar code labels on eachcontainer are evenly spaced around thecontainer.Verify container’s radiological label/tag.Complete Attachment 2, ContainerInspection Report.Verification that a container is on the AK trackingsheet isperformed prior to container acceptance from AMWTPandprior to performance of each characterization technique.The presence of the requisite number of barcode labels, aradiological tag, and a container integrity check are allrecorded on Attachment 2, Container Inspection Report.Containers failing one or more of these checks maybereturned to the host site.CM-5: Traveler. CCP-TP-068,Rev. 5,Sect. 4.2Is there a Traveler (Attachment 1) on eachcontainer to be characterized?All of the containers inspected had a Traveler attached asrequired.CM-6: Container weighing. CCP-TP-068,Rev. 5,Sect. 4.3Newly-generated Waste (4.3.1):Are the VE data sheet and Attachment 1completed as required?Retrievably-stored Waste (4.3.2):Is scale calibration verified with a knownweight?Is verification documented on Attachment 3?Are Attachments 1 and 3 completed withcontainer information?The VE data sheet must be attached to a container prior toNDA, and the NDA operator is required to verify that eitherVE or RTR data sheets are attached to the Traveler.A scale check is performed and recorded as required. The netand gross container weights are used in RTR to determinewaste weight and hence WMP weights.A.5-3CCP-TP-068, CONTAINER MANAGEMENT AT THE INL AND TWCPEPA Inspection No.: EPA-INL-CCP-09.08-24, CCP/INLContinuing ComplianceInspection Date: September 16–18, 2008Establishment of RequiredTechnical Elements in ProceduresLocationExecution of ProceduresObjective Evidence/CommentsCM-7: Container movement. CCP-TP-068,Rev. 5,Sect. 4.4-4.8These sections deal with the characterizationtechniques, but do not provide anyinformation on how containers are moved toeach location.NACM-8: Characterization completion.CCP-TP-068,Rev. 5,Sect. 4.9Container Management Personnel arerequired to remove Traveler andcharacterization data sheets and forwardthem to the VPM. No information on howthe containers are moved or tracked or whathappens to them after the completion ofcharacterization.EPA has committed to inspection of container movement andtracking after characterization has been completed(shipping).This will be performed at some future date.B-1ATTACHMENT B.1: REPLICATE TESTING DATA FOR CONTAINER 10212486 – WAGSInstrument: WAGSContainer: 10212486Original Measurement Replicate #1 Replicate #2Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238Pu 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-01239Pu 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-01240Pu 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-01242Pu 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-01241Am 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-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 1.95E+01 4.64E+00 2.38E-012.48E+01 5.42E+00 2.19E-01 2.62E+01 5.98E+00 2.28E-01Replicate #3 Replicate #4 Replicate #5Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238Pu 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-01239Pu 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-01240Pu 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-01242Pu 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-01241Am 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-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 2.46E+01 5.65E+00 2.30E-012.14E+01 4.69E+00 2.19E-01 2.08E+01 4.63E+00 2.23E-01B-2ATTACHMENT B.2: REPLICATE TESTING RESULTS FOR CONTAINER 10212486 – WAGSInstrument: WAGSContainer: 10212486Original MeasurementQuantity of InterestReportedValueAbsoluteUncertaintySampleMeanSampleStandardDeviationRelativeStandardDeviationx2Pr(x<|c2|)233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A238Pu Activity (Ci) 4.34E-05 2.13E-05 5.30E-05 5.57E-06 1.05E-01 2.73E-01 9.91E-01239Pu Activity (Ci) 1.52E-03 4.68E-04 1.85E-03 1.95E-04 1.05E-01 6.93E-01 9.52E-01240Pu Activity (Ci) 3.37E-04 1.08E-04 4.11E-04 4.32E-05 1.05E-01 6.41E-01 9.58E-01242Pu Activity (Ci) 4.38E-08 2.61E-08 5.35E-08 5.62E-09 1.05E-01 1.85E-01 9.96E-01241Am Activity (Ci) 1.30E-04 3.29E-05 1.31E-04 1.14E-06 8.68E-03 4.80E-03 1.00E+0090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/ATRU Alpha Conc. (nCi/g) 1.95E+01 4.64E+00 2.36E+012.34E+00 9.93E-02 1.02E+00 9.07E-01Quantity of Interest t Pr(x<|t|)x2Testt Test233U Activity (Ci)N/A N/A N/A Not Applicable234U Activity (Ci) N/A N/A N/A Not Applicable238U Activity (Ci) N/A N/A N/A Not Applicable238Pu Activity (Ci) -1.57E+00 1.92E-01 Not SignificantNot Significant239Pu Activity (Ci) -1.55E+00 1.97E-01 Not SignificantNot Significant240Pu Activity (Ci) -1.57E+00 1.91E-01 Not SignificantNot Significant242Pu Activity (Ci) -1.57E+00 1.92E-01 Not SignificantNot Significant241Am Activity (Ci) -1.12E+00 3.25E-01 Not SignificantNot Significant90Sr Activity (Ci) N/A N/A N/A Not Applicable137Cs Activity (Ci) N/A N/A N/A Not ApplicableTRU Alpha Conc. (nCi/g) -1.58E+00 1.88E-01 Not Significant Not SignificantB-3ATTACHMENT B.3: REPLICATE TESTING DATA FOR CONTAINER 10215772 – WAGSInstrument: WAGSContainer: 10215772Original Measurement Replicate #1 Replicate #2Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00234U Activity (Ci) 3.68E-07 2.37E-07 6.44E-01 3.60E-072.32E-07 6.44E-01 3.12E-07 2.01E-07 6.44E-01238U Activity (Ci) 1.97E-06 9.65E-07 4.90E-01 1.93E-068.82E-07 4.57E-01 1.67E-06 7.97E-07 4.77E-01238Pu 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+02239Pu 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-01240Pu 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-01242Pu 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-01241Am 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-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 7.31E+01 2.43E+01 3.32E-017.22E+01 2.27E+01 3.14E-01 7.64E+01 2.48E+01 3.25E-01Replicate #3 Replicate #4 Replicate #5Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00234U Activity (Ci) 2.66E-07 1.72E-07 6.47E-01 2.61E-071.68E-07 6.44E-01 3.40E-07 2.19E-07 6.44E-01238U Activity (Ci) 1.43E-06 7.02E-07 4.91E-01 1.40E-066.73E-07 4.81E-01 1.82E-06 8.44E-07 4.64E-01238Pu 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-01239Pu 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-01240Pu 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-01242Pu 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-01241Am 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-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 8.03E+01 2.70E+01 3.36E-016.98E+01 2.31E+01 3.31E-01 8.32E+01 2.58E+01 3.10E-01B-4ATTACHMENT B.4: REPLICATE TESTING RESULTS FOR CONTAINER 10215772 – WAGSInstrument: WAGSContainer: 10215772Original MeasurementQuantity of InterestReportedValueAbsoluteUncertaintySampleMeanSampleStandardDeviationRelativeStandardDeviationx2Pr(x<|c2|)233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A234U Activity (Ci) 3.68E-07 2.37E-07 3.08E-07 4.39E-081.43E-01 1.37E-01 9.98E-01238U Activity (Ci) 1.97E-06 9.65E-07 1.65E-06 2.34E-071.42E-01 2.35E-01 9.94E-01238Pu Activity (Ci) 2.70E-04 4.35E-04 4.96E-04 5.66E-04 1.14E+00 6.78E+00 1.48E-01239Pu Activity (Ci) 1.17E-02 4.83E-03 1.18E-02 9.12E-04 7.74E-02 1.43E-01 9.98E-01240Pu Activity (Ci) 2.06E-03 9.40E-04 2.42E-03 2.98E-04 1.23E-01 4.03E-01 9.82E-01242Pu Activity (Ci) 1.51E-07 7.61E-08 1.84E-07 3.17E-08 1.72E-01 6.93E-01 9.52E-01241Am Activity (Ci) 8.89E-04 3.67E-04 9.02E-04 6.23E-06 6.90E-03 1.15E-03 1.00E+0090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/ATRU Alpha Conc. (nCi/g) 7.31E+01 2.43E+01 7.64E+015.54E+00 7.25E-02 2.08E-01 9.95E-01Quantity of Interestt Pr(x<|t|)x2Testt Test233U Activity (Ci)N/A N/A N/A Not Applicable234U Activity (Ci) 1.25E+00 2.79E-01 Not Significant Not Significant238U Activity (Ci) 1.25E+00 2.80E-01 Not Significant Not Significant238Pu Activity (Ci) -3.64E-01 7.34E-01 Not SignificantNot Significant239Pu Activity (Ci) -8.01E-02 9.40E-01 Not SignificantNot Significant240Pu Activity (Ci) -1.11E+00 3.28E-01 Not SignificantNot Significant242Pu Activity (Ci) -9.45E-01 3.98E-01 Not SignificantNot Significant241Am Activity (Ci) -1.96E+00 1.21E-01 Not SignificantNot Significant90Sr Activity (Ci) N/A N/A N/A Not Applicable137Cs Activity (Ci) N/A N/A N/A Not ApplicableTRU Alpha Conc. (nCi/g) -5.41E-01 6.17E-01 Not Significant Not SignificantB-5ATTACHMENT B.5: REPLICATE TESTING DATA FOR CONTAINER ARP05744 – WAGSInstrument: WAGSContainer: ARP05744Original Measurement Replicate #1 Replicate #2Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238Pu 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-01239Pu 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-01240Pu 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-01242Pu 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-01241Am 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-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 3.11E+03 8.09E+02 2.60E-013.18E+03 8.23E+02 2.59E-01 3.07E+03 7.66E+02 2.50E-01Replicate #3 Replicate #4 Replicate #5Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238Pu 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-01239Pu 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-01240Pu 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-01242Pu 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-01241Am 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-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 2.97E+03 7.94E+02 2.67E-013.17E+03 8.12E+02 2.56E-01 3.13E+03 8.14E+02 2.60E-01B-6ATTACHMENT B.6: REPLICATE TESTING RESULTS FOR CONTAINER ARP05744 – WAGSInstrument: WAGSContainer: ARP05744Original MeasurementQuantity of InterestReportedValueAbsoluteUncertaintySampleMeanSampleStandardDeviationRelativeStandardDeviationx2Pr(x<|c2|)233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A238Pu Activity (Ci) 1.96E-03 9.94E-04 1.98E-03 2.27E-04 1.15E-01 2.09E-01 9.95E-01239Pu Activity (Ci) 6.84E-02 2.29E-02 6.91E-02 7.94E-03 1.15E-01 4.80E-01 9.75E-01240Pu Activity (Ci) 1.52E-02 5.24E-03 1.53E-02 1.78E-03 1.16E-01 4.62E-01 9.77E-01242Pu Activity (Ci) 1.97E-06 1.21E-06 1.99E-06 2.31E-07 1.16E-01 1.46E-01 9.97E-01241Am Activity (Ci) 2.63E-01 8.76E-02 2.61E-01 8.99E-03 3.44E-02 4.21E-02 1.00E+0090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/ATRU Alpha Conc. (nCi/g) 3.11E+03 8.09E+02 3.10E+038.65E+01 2.79E-02 4.58E-02 1.00E+00Quantity of Interest t Pr(x<|t|)x2Testt Test233U Activity (Ci) N/A N/A N/A Not Applicable234U Activity (Ci) N/A N/A N/A Not Applicable238U Activity (Ci) N/A N/A N/A Not Applicable238Pu Activity (Ci) -6.43E-02 9.52E-01 Not SignificantNot Significant239Pu Activity (Ci) -7.59E-02 9.43E-01 Not SignificantNot Significant240Pu Activity (Ci) -6.15E-02 9.54E-01 Not SignificantNot Significant242Pu Activity (Ci) -9.49E-02 9.29E-01 Not SignificantNot Significant241Am Activity (Ci) 1.62E-01 8.79E-01 Not SignificantNot Significant90Sr Activity (Ci) N/A N/A N/A Not Applicable137Cs Activity (Ci) N/A N/A N/A Not ApplicableTRU Alpha Conc. (nCi/g) 6.33E-02 9.53E-01 Not Significant Not SignificantB-7ATTACHMENT B.7: REPLICATE TESTING DATA FOR CONTAINER ARP06447 – WAGSInstrument: WAGSContainer: ARP06447Original Measurement Replicate #1 Replicate #2Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238Pu 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-01239Pu 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-01240Pu 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-01242Pu 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-01241Am 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-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 4.10E+02 1.44E+02 3.51E-013.58E+02 1.23E+02 3.44E-01 3.31E+02 1.13E+02 3.41E-01Replicate #3 Replicate #4 Replicate #5Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238Pu 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-01239Pu 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-01240Pu 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-01242Pu 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-01241Am 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-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 3.84E+02 1.32E+02 3.44E-013.72E+02 1.29E+02 3.47E-01 3.94E+02 1.36E+02 3.45E-01B-8ATTACHMENT B.8: REPLICATE TESTING RESULTS FOR CONTAINER ARP06447 – WAGSInstrument: WAGSContainer: ARP06447Original MeasurementQuantity of InterestReportedValueAbsoluteUncertaintySampleMeanSampleStandardDeviationRelativeStandardDeviationx2Pr(x<|x2|)233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A238Pu Activity (Ci) 1.38E-04 8.03E-05 1.50E-04 5.93E-06 3.95E-02 2.18E-02 1.00E+00239Pu Activity (Ci) 4.81E-03 2.12E-03 5.26E-03 2.07E-04 3.94E-02 3.83E-02 1.00E+00240Pu Activity (Ci) 1.07E-03 4.79E-04 1.17E-03 4.60E-05 3.94E-02 3.70E-02 1.00E+00242Pu Activity (Ci) 1.39E-07 9.36E-08 1.52E-07 6.20E-09 4.08E-02 1.76E-02 1.00E+00241Am Activity (Ci) 5.67E-02 2.20E-02 4.97E-02 3.59E-03 7.22E-02 1.06E-01 9.99E-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/ATRU Alpha Conc. (nCi/g) 4.10E+02 1.44E+02 3.68E+022.46E+01 6.68E-02 1.17E-01 9.98E-01Quantity of Interest t Pr(x<|t|)x2Testt Test233U Activity (Ci) N/A N/A N/A Not Applicable234U Activity (Ci) N/A N/A N/A Not Applicable238U Activity (Ci) N/A N/A N/A Not Applicable238Pu Activity (Ci) -1.88E+00 1.34E-01 Not SignificantNot Significant239Pu Activity (Ci) -1.99E+00 1.17E-01 Not SignificantNot Significant240Pu Activity (Ci) -1.94E+00 1.24E-01 Not SignificantNot Significant242Pu Activity (Ci) -1.91E+00 1.28E-01 Not SignificantNot Significant241Am Activity (Ci) 1.78E+00 1.50E-01 Not SignificantNot Significant90Sr Activity (Ci) N/A N/A N/A Not Applicable137Cs Activity (Ci) N/A N/A N/A Not ApplicableTRU Alpha Conc. (nCi/g) 1.57E+00 1.92E-01 Not Significant Not SignificantB-9ATTACHMENT B.9: REPLICATE TESTING DATA FOR CONTAINER ARP06723 – WAGSInstrument: WAGSContainer: ARP06723Original Measurement Replicate #1 Replicate #2Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00234U Activity (Ci) 5.70E-06 3.28E-06 5.75E-01 5.13E-062.95E-06 5.75E-01 6.14E-06 3.53E-06 5.75E-01238U Activity (Ci) 2.27E-05 6.62E-06 2.92E-01 2.31E-056.67E-06 2.89E-01 2.10E-05 6.11E-06 2.91E-01238Pu 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-01239Pu 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-01240Pu 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-01242Pu 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-01241Am 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-0190Sr 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-01137Cs 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-01TRU Alpha Conc. (nCi/g) 2.22E+03 4.48E+02 2.02E-012.08E+03 4.25E+02 2.04E-01 2.12E+03 4.34E+02 2.05E-01Replicate #3 Replicate #4 Replicate #5Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00234U Activity (Ci) 7.24E-06 4.16E-06 5.75E-01 5.79E-063.33E-06 5.75E-01 5.62E-06 3.23E-06 5.75E-01238U Activity (Ci) 2.20E-05 6.37E-06 2.90E-01 1.97E-055.74E-06 2.91E-01 2.37E-05 6.86E-06 2.90E-01238Pu 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-01239Pu 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-01240Pu 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-01242Pu 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-01241Am 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-0190Sr 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-01137Cs 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-01TRU Alpha Conc. (nCi/g) 2.15E+03 4.37E+02 2.03E-012.09E+03 4.21E+02 2.01E-01 2.12E+03 4.31E+02 2.03E-01B-10ATTACHMENT B.10: REPLICATE TESTING RESULTS FOR CONTAINER ARP06723 – WAGSInstrument: WAGSContainer: ARP06723Original MeasurementQuantity of InterestReportedValueAbsoluteUncertaintySampleMeanSampleStandardDeviationRelativeStandardDeviationx2Pr(x<|x2|)233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A234U Activity (Ci) 5.70E-06 3.28E-06 5.98E-06 7.91E-071.32E-01 2.33E-01 9.94E-01238U Activity (Ci) 2.27E-05 6.62E-06 2.19E-05 1.61E-067.34E-02 2.36E-01 9.94E-01238Pu Activity (Ci) 8.76E-04 8.72E-04 3.82E-03 7.33E-04 1.92E-01 2.83E+00 5.87E-01239Pu Activity (Ci) 1.21E-01 3.46E-02 1.19E-01 1.92E-03 1.62E-02 1.24E-02 1.00E+00240Pu Activity (Ci) 2.68E-02 7.70E-03 2.65E-02 8.35E-04 3.15E-02 4.71E-02 1.00E+00242Pu Activity (Ci) 2.21E-06 6.77E-07 2.24E-06 7.50E-08 3.34E-02 4.91E-02 1.00E+00241Am Activity (Ci) 3.45E-02 1.06E-02 2.53E-02 2.24E-04 8.84E-03 1.78E-03 1.00E+0090Sr Activity (Ci) 6.24E-07 1.80E-07 7.71E-07 1.72E-08 2.23E-02 3.64E-02 1.00E+00137Cs Activity (Ci) 5.67E-07 1.64E-07 7.01E-07 1.56E-08 2.22E-02 3.61E-02 1.00E+00TRU Alpha Conc. (nCi/g) 2.22E+03 4.48E+02 2.11E+032.77E+01 1.31E-02 1.53E-02 1.00E+00Quantity of Interestt Pr(x<|t|)x2Testt Test233U Activity (Ci) N/A N/A N/A Not Applicable234U Activity (Ci) -3.28E-01 7.59E-01 Not SignificantNot Significant238U Activity (Ci) 4.54E-01 6.73E-01 Not Significant Not Significant238Pu Activity (Ci) -3.66E+00 2.15E-02 Not SignificantSignificant239Pu Activity (Ci) 1.04E+00 3.55E-01 Not SignificantNot Significant240Pu Activity (Ci) 2.84E-01 7.90E-01 Not SignificantNot Significant242Pu Activity (Ci) -4.14E-01 7.00E-01 Not SignificantNot Significant241Am Activity (Ci) 3.76E+01 3.00E-06 Not SignificantHighly Significant90Sr Activity (Ci) -7.82E+00 1.44E-03 Not SignificantHighly Significant137Cs Activity (Ci) -7.86E+00 1.42E-03 Not SignificantHighly SignificantTRU Alpha Conc. (nCi/g) 3.55E+00 2.37E-02 Not Significant SignificantB-11ATTACHMENT B.11: REPLICATE TESTING DATA FOR CONTAINER BN10211041 – SUPERHENCInstrument: Idaho SuperHENCContainer: BN10211041Original Measurement Replicate #1 Replicate #2Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00234U Activity (Ci) 1.33E-05 5.54E-06 4.16E-01 0.00E+00N/A 0.00E+00 0.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238Pu 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-01239Pu 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-01240Pu 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-01242Pu 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-01241Am 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-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 2.74E+02 7.20E+01 2.62E-012.02E+02 4.89E+01 2.42E-01 2.19E+02 5.16E+01 2.35E-01Replicate #3 Replicate #4 Replicate #5Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00234U 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+00238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238Pu 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+00239Pu 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-01240Pu 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-01242Pu 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+00241Am 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-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 2.47E+02 8.59E+01 3.47E-012.32E+02 5.62E+01 2.42E-01 2.41E+02 8.29E+01 3.44E-01B-12ATTACHMENT B.12: REPLICATE TESTING RESULTS FOR CONTAINER BN10211041 – SUPERHENCInstrument: Idaho SuperHENCContainer: BN10211041Original MeasurementQuantity of InterestReportedValueAbsoluteUncertaintySampleMeanSampleStandardDeviationRelativeStandardDeviationx2Pr(x<|2|)233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A234U Activity (Ci) 1.33E-05 5.54E-06 2.89E-06 6.47E-062.24E+00 5.45E+00 2.44E-01238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A238Pu Activity (Ci) 4.59E-03 2.15E-03 2.33E-03 2.13E-03 9.14E-01 3.94E+00 4.15E-01239Pu Activity (Ci) 1.49E-01 3.88E-02 1.34E-01 1.04E-02 7.81E-02 2.89E-01 9.91E-01240Pu Activity (Ci) 3.32E-02 8.19E-03 2.87E-02 1.21E-03 4.22E-02 8.76E-02 9.99E-01242Pu Activity (Ci) 4.31E-06 2.45E-06 2.19E-06 2.00E-06 9.14E-01 2.67E+00 6.15E-01241Am Activity (Ci) 4.09E-02 1.29E-02 2.52E-02 6.19E-03 2.46E-01 9.18E-01 9.22E-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/A137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/AN/A N/ATRU Alpha Conc. (nCi/g) 2.74E+02 7.20E+01 2.28E+021.81E+01 7.92E-02 2.52E-01 9.93E-01Quantity of Interestt Pr(x<|t|)x2Testt Test233U Activity (Ci) N/A N/A N/A Not Applicable234U Activity (Ci) 1.47E+00 2.15E-01 Not Significant Not Significant238U Activity (Ci) N/A N/A N/A Not Applicable238Pu Activity (Ci) 9.69E-01 3.87E-01 Not SignificantNot Significant239Pu Activity (Ci) 1.38E+00 2.38E-01 Not SignificantNot Significant240Pu Activity (Ci) 3.42E+00 2.67E-02 Not SignificantSignificant242Pu Activity (Ci) 9.69E-01 3.87E-01 Not SignificantNot Significant241Am Activity (Ci) 2.32E+00 8.07E-02 Not SignificantNot Significant90Sr Activity (Ci) N/A N/A N/A Not Applicable137Cs Activity (Ci) N/A N/A N/A Not ApplicableTRU Alpha Conc. (nCi/g) 2.33E+00 8.01E-02 Not Significant Not SignificantB-13ATTACHMENT B.13: REPLICATE TESTING DATA FOR CONTAINER BN10239132 – SUPERHENCInstrument: Idaho SuperHENCContainer: BN10239132Original Measurement Replicate #1 Replicate #2Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238Pu 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-01239Pu 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-01240Pu 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-02242Pu 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-01241Am 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-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 2.82E+03 3.11E+02 1.10E-012.76E+03 3.13E+02 1.13E-01 2.64E+03 2.81E+02 1.06E-01Replicate #3 Replicate #4 Replicate #5Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00238Pu 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-01239Pu 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-02240Pu 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-02242Pu 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-01241Am 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-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A0.00E+00 0.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 2.71E+03 3.19E+02 1.17E-012.95E+03 3.21E+02 1.09E-01 3.02E+03 3.07E+02 1.02E-01B-14ATTACHMENT B.14: REPLICATE TESTING RESULTS FOR CONTAINER BN10239132 – SUPERHENCInstrument: Idaho SuperHENCContainer: BN10239132Original MeasurementQuantity of InterestReportedValueAbsoluteUncertaintySampleMeanSampleStandardDeviationRelativeStandardDeviationx2Pr(x<|x2|)233U Activity (Ci)0.00E+00 N/A0.00E+00 0.00E+00 N/AN/A N/A234U Activity (Ci)0.00E+00 N/A0.00E+00 0.00E+00 N/AN/A N/A238U Activity (Ci)0.00E+00 N/A0.00E+00 0.00E+00 N/AN/A N/A238Pu Activity (Ci)2.23E-02 9.00E-032.22E-02 1.26E-03 5.66E-027.79E-02 9.99E-01239Pu Activity (Ci)7.27E-01 7.86E-027.23E-01 4.09E-02 5.66E-021.08E+00 8.97E-01240Pu Activity (Ci)1.62E-01 1.13E-021.61E-01 9.10E-03 5.66E-022.60E+00 6.26E-01242Pu Activity (Ci)2.10E-05 1.08E-052.09E-05 1.18E-06 5.66E-024.77E-02 1.00E+00241Am Activity (Ci)1.19E-01 2.08E-021.23E-01 1.52E-02 1.24E-012.14E+00 7.11E-0190Sr Activity (Ci)0.00E+00 N/A0.00E+00 0.00E+00 N/AN/A N/A137Cs Activity (Ci)0.00E+00 N/A0.00E+00 0.00E+00 N/AN/A N/ATRU Alpha Conc. (nCi/g)2.82E+03 3.11E+022.82E+03 1.61E+02 5.73E-021.07E+00 8.98E-01Quantity of Interest t Pr(x<|t|)x2Testt Test233U Activity (Ci) N/A N/A N/A Not Applicable234U Activity (Ci) N/A N/A N/A Not Applicable238U Activity (Ci) N/A N/A N/A Not Applicable238Pu Activity (Ci) 8.88E-02 9.33E-01 Not SignificantNot Significant239Pu Activity (Ci) 9.53E-02 9.29E-01 Not SignificantNot Significant240Pu Activity (Ci) 9.53E-02 9.29E-01 Not SignificantNot Significant242Pu Activity (Ci) 9.55E-02 9.29E-01 Not SignificantNot Significant241Am Activity (Ci) -2.10E-01 8.44E-01 Not SignificantNot Significant90Sr Activity (Ci) N/A N/A N/A Not Applicable137Cs Activity (Ci) N/A N/A N/A Not ApplicableTRU Alpha Conc. (nCi/g) 2.86E-02 9.79E-01 Not Significant Not Significant