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

WASTE CHARACTERIZATION REPORT 

TIER 1 CHANGE: 

EVALUATION OF CONTACT-HANDLED TRANSURANIC S4000 SOILS (ORNL 

WASTE STREAM OR-NFS-CH-SOIL) AT THE OAK RIDGE NATIONAL 

LABORATORY 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

October 2009
i 

TABLE OF CONTENTS 

Section Page

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

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

3.0 Purpose of Tier 1 Evaluations ............................................................................................. 4 

4.0 Purpose of This Report........................................................................................................ 5 

5.0 Scope of the Tier 1 Evaluation............................................................................................ 5 

6.0 Performance of the Tier 1 Evaluation ................................................................................. 5 

6.1 Acceptable Knowledge (AK).................................................................................. 6 

6.2 Non Destructive Assay (NDA) ............................................................................. 22 

6.3 Real-Time Radiography (RTR)............................................................................. 25 

7.0 Summary of Results and Conclusions............................................................................... 28 

LIST OF TABLES 

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

Wastes (Based on September 2009 Tier 1 Evaluation).................................................. 3 

Table 2. Previous ORNL-CCP CH EPA Approvals .................................................................... 4 

Table 3. T1 Evaluation Participants ............................................................................................. 5 

Table 4. Batch Data Reports Examined ..................................................................................... 10 

Table 5. Mixed Oxide Fuel Compositions ................................................................................. 18 

Table 6. Mass Isotopic Distributions of Mixed Oxide Fuels by NFS Contract ......................... 19 

Table 7. Waste Stream OR-NFS-CH-SOIL Radiological Characterization.............................. 19 

Table 8. Summary of RTR Operators Performance on Training Drums ................................... 26 

ATTACHMENTS 

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

Final

Attachment B: EPA Tier 1 Issue Tracking Form, Issue No. ORNL-CCP-CH-NDA-09-002CR, 

Final 

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

003C, Final 
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1.0 EXECUTIVE SUMMARY 

This report supports EPA’s approval of retrievably-stored, contact-handled (CH) transuranic 

(TRU) soils/gravel (S4000) from Soil Waste Stream OR-NFS-CH-SOIL generated at and 

packaged by the Oak Ridge National Laboratory (ORNL) for disposal at the Waste Isolation 

Pilot Plant (WIPP). The Central Characterization Project (CCP) was responsible for 

characterizing this waste using the system of controls the U.S. Environmental Protection Agency 

(EPA) evaluated during a baseline inspection conducted in August 2008. 

In accordance with 40 CFR 194.8(b), the EPA conducted a baseline inspection, in August 2008, 

of the CCP’s CH TRU waste characterization (WC) program at the ORNL in Oak Ridge, 

Tennessee. As a result of this baseline inspection, EPA approved the ORNL-CCP CH TRU WC 

program with specific conditions and limitations, as discussed in the ORNL Baseline Final 

Inspection Report (see A-98-49; II-A4-103 for details). The August 2008 approval was limited 

to retrievably-stored debris waste, and any wastes outside of this category (i.e., soils/gravel and 

solids and newly-generated debris) were identified as a Tier 1 (T1) change. 

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

add ORNL’s CH TRU Soil Waste Stream OR-NFS-CH-SOIL from the S4000 summary category 

group (SCG). Inclusion of S4000 wastes to the baseline approval was identified as T1 change in 

the ORNL baseline inspection report. On August 11-12, 2009, EPA conducted a T1 evaluation 

of the requested change by reviewing documents and records for Acceptable Knowledge (AK) 

and Non-Destructive Assay (NDA) of the subject waste stream in Golden, Colorado. The week 

before, an EPA inspector evaluated selected audio/video (AV) recordings of Real-Time 

Radiography (RTR) performed on soil containers. 

During the evaluations, EPA identified three concerns, one in RTR and two in Non-Destructive 

Assay (NDA). Two of these concerns, one in RTR and one in NDA, required a response. All 

three of these concerns are discussed in the text and are included as attachments to this report. 

These concerns did not affect the quality of the waste characterization data quantifying the 

contents of containers of soil waste. ORNL-CCP provided responses and they adequately 

addressed both concerns and no open issues remain related to this T1 change. Based on EPA’s 

evaluation of all aspects of the ORNL-CCP WC program relative to Waste Stream OR-NFS-CHSOIL, EPA approves the addition of the SCG S4000 CH TRU soils/gravel SCG at ORNL-CCP. 

EPA’s approval of the S4000 soils/gravel SCG to the ORNL-CCP baseline approval required 

revision of the original T1 and Tier 2 (T2) designations (see EPA Docket No. A-98-49, II-A4-

103, Tables 1 and 8). The revisions are in Table 1 below, showing the most current tierings; this 

tiering table supersedes the table provided in the baseline report. The original table provided 

references to the specific sections of the baseline inspection report, where each T1 or T2 change 

was discussed in parentheses, and these have been removed from the revised table for clarity. 

The CBFO must use tierings in the revised table when recertifying the ORNL-CCP program and 

ORNL-CCP must use the revised table when submitting future changes for EPA approval or 

concurrence. Changes in the revised table are exclusively in the area of AK. A new T1 change 

[soil from a burial trench at Nuclear Fuels Services (NFS)] is included under AK, because EPA 
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did not receive the most current AK documents (for example, the AK Summary or AKS, 

Revision 4, dated May 2009) discussing this waste stream prior to the August evaluation. All of 

the T2 elements listed under AK in the revised Table 1 apply to all approved waste streams and 

SCGs at ORNL-CCP. There are no changes to the T1 and T2 designations assigned to NDA, 

RTR, Visual Examination (VE), and the WIPP Waste Information System (WWIS). Consistent 

with EPA’s authority under 40 CFR 194.24(h), EPA may request information, if EPA deems it 

necessary to ensure continued compliance with EPA regulations. 

This report serves as EPA’s public notification of the results of the proposed T1 change and its 

evaluation. This information will be provided through the EPA Web site and by sending e-mails 

to the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3).
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Table 1. Revised Tiering of TRU WC Processes Implemented by ORNL for CH TRU Wastes 

(Based on September 2009 Tier 1 Evaluation) 

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

Acceptable Knowledge and Load Management 

Implementation of load management Implementation of AK for wastes other than retrievably- stored debris and soils/gravel (i.e., solids or any type of newly-generated waste) Implementation to include soil from NFS burial trench in Waste Stream OR-NFS-CH-SOIL 

The elements listed as T2 changes below apply to all approved ORNLCCP CH TRU waste streams and waste summary category groups. 

Notification to EPA upon completion of AK accuracy reports and, upon 

completion of new versions or updates/substantive changesb of the 

following: - AK-NDA memoranda - Site AK procedure CCP-TP-005 - AK accuracy reports - AK-AK and AK-NDA/NDE Discrepancy Resolution Reports - Attachments 4 and 6 and associated memoranda - WSPFs and AK summaries and related attachments for all new 

waste streams, including change notices - “Add Container” memoranda

Non Destructive Assay New equipment or physical modifications to approved 

equipmentc

Extension or changes to approved calibration range for 

approved equipment 

Notification to EPA upon completion of changes to software for 

approved equipment, operating range(s), and site procedures that require CBFO approval. 

Real-Time Radiography N/A Notification to EPA upon the following: - Implementation of new RTR equipment or substantive changesc

to approved RTR equipment - Completion of changes to site RTR procedures requiring CBFO 

approvals 

Visual Examination Not approved at this time Not approved at this time WIPP Waste Information System Implementation of load management Notification to EPA upon completion of changes to WWIS procedure(s) 

requiring CBFO approvals

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

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

ES&H, nuclear safety, or RCRA, or that are editorial in nature. 

c Modifications to approved equipment include all changes with the potential to affect NDA data relative to waste isolation and exclude minor changes, such as the 

addition of safety-related equipment.
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2.0 APPROVAL SUMMARY FOR ORNL-CCP CH WC PROGRAM 

EPA provided formal baseline approval of the ORNL-CCP CH WC program in August of 2008. 

Since then, EPA has approved two T1 changes at ORNL-CCP. These are summarized in 

Table 2. 

Table 2. Previous ORNL-CCP CH EPA Approvals 

Approved Activity EPA Inspection Number 

(Approval Dates) 

 Docket Number 

ORNL-CCP CH Baseline Approval EPA-ORNL-CCP-CH-11.07-8 

(August 21, 2008) A-98-49, II-A4-103 

T1 Change – DWAS SGS Range and Density Extension EPA-ORNL-CCP-CH-T1-SGS 

(January 8, 2009) A-98-49, II-A4-108 

T1 Change – DWAS IPAN Range Extension EPA-ORNL-CCP-CH-T1-IPAN

(January 8, 2009) A-98-49, II-A4-109 

3.0 PURPOSE OF TIER 1 EVALUATIONS 

Any changes to the WC activities from the date of the baseline inspection must be reported to, 

and, if applicable, approved by EPA, according to the tiering requirements set forth in the ORNL 

Baseline Final Report cited above. 

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, Federal Register notice, 

EPA must perform a single baseline inspection of a TRU waste generator site’s WC program. 

The purpose of the baseline inspection is to approve the site’s WC program, based on the 

demonstration that the program’s components, with applicable conditions and limitations, can 

adequately characterize TRU wastes and comply with the regulatory requirements imposed on 

TRU wastes destined for disposal at the WIPP. An EPA inspection team conducts an onsite 

inspection to verify that the site’s system of controls is technically adequate and properly 

implemented. 

 

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

authorized to evaluate and approve, if necessary, changes to the site’s approved WC program by 

conducting additional inspections under the authority of 40 CFR 194.24(h). Under 

40 CFR 194.24, EPA has the authority to conduct continued compliance inspections to verify 

that the site continues to use only the approved WC processes to characterize the waste and 

remains in compliance with all the regulatory requirements. Based on the adequacies of the WC 

processes demonstrated during the baseline inspection, including all conditions and limitations, 

EPA specified which subsequent WC program changes or modifications must undergo further 

EPA inspection or approval under 40 CFR 194.24. This was accomplished by assigning a tier 

level to each aspect of the ORNL-CCP’s WC program. T1 activities have more stringent 

reporting requirements and require that DOE notify EPA, and that EPA provide approval prior to 

implementation. The rule under which baseline inspections are conducted can be found in the 

Federal Register (Vol. 69, No. 136, pages 42571–42583 of July 16, 2004).
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4.0 PURPOSE OF THIS REPORT 

This report presents the results of EPA’s evaluation of a T1 change to add CH TRU soils/gravel 

(from Waste Stream OR-NFS-CH-SOIL) from the S4000 SCG to the ORNL-CCP approval. 

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

technical evaluation of these wastes. EPA’s approval decision regarding waste from CH TRU 

Soil Waste Stream OR-NFS-CH-SOIL been conveyed to DOE separately by letter. As discussed 

previously, EPA will also announce the decision on its web site at www.epa.gov/radiation/WIPP, 

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

5.0 SCOPE OF THE TIER 1 EVALUATION 

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

materials were not examined at the ORNL-CCP baseline inspection and were identified as a T1 

change. 

6.0 PERFORMANCE OF THE TIER 1 EVALUATION 

This evaluation included three WC areas; AK, NDA, and RTR. Each of these is addressed in a 

separate section of this report. The NDA and RTR systems had been evaluated previously 

during the baseline inspection and, for NDA, two subsequent T1 evaluations. The evaluations of 

these areas began with confirming that they were essentially unchanged from what EPA had 

inspected and approved previously. Upon determining that was the case, the T1 evaluation for 

NDA and RTR focused on the characterization records these systems produced upon processing 

ORNL-CCP Waste Stream OR-NFS-CH-SOIL. For AK, this evaluation resembled the type of 

evaluation typically performed during a baseline inspection. The T1 evaluation of AK and NDA 

was held in Golden, Colorado, on August 11–12, 2009, and the RTR evaluation of recorded 

audio-visual (AV) tapes and related records occurred the previous week in Albuquerque, New 

Mexico. Personnel who participated in the T1 evaluation are listed in Table 3, along with each 

person’s affiliation and function during the evaluation.

Table 3. T1 Evaluation Participants 

Name Affiliation 

Ed Feltcorn EPA Headquarters, Lead Inspector 

Rajani Joglekar EPA Headquarters, Inspector 

Connie Walker SC&A, AK Technical Evaluator 

Patrick Kelly SC&A, NDA Technical Evaluator 

Dorothy Gill SC&A, RTR Technical Evaluator (Albuquerque) 

Mark Pearcy CCP, Management Support 

Jeff Harrison CCP, AK Expert 

Joe Harvill CCP, NDA Technical Support 

Paul Gomez CTAC/CBFO, Observer 
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6.1 Acceptable Knowledge (AK) 

The EPA inspection team evaluated a single retrievably-stored soil waste stream, identified as 

OR-NFS-CH-SOIL and described in the AK Summary (AKS), Revision 3, dated August 11, 

2008. ORNL-CCP provided this revision of the AKS to EPA prior to the inspection as the most 

recent revision to serve as the basis for this evaluation. Revision 4 of the AKS dated May 2009 

was provided by the AKE at the beginning of the evaluation, and this revision introduced a new 

soil waste stream from a burial trench at NFS. However, EPA did not include the NFS burial 

trench waste stream in its evaluation, and therefore it is not part of this approval. This NFS 

burial trench soil waste stream is subject to a T1 change approval request, as indicated in Table 1 

of this report. 

EPA’s approval of this T1 evaluation included revising the T1 and T2 elements that were 

assigned in the ORNL-CCP baseline inspection final report, as stated previously (see Table 2). 

Accordingly, all of the T2 elements listed under AK in Table 1 of this report apply to all 

approved CH waste streams and SCGs at ORNL-CCP. Individual T2 designations for this T1 

evaluation are not specified in this report, nor are they listed at the end of each of the AK 

sections, as was done in the baseline inspection final report. 

This soil waste stream was generated at the NFS in Erwin, Tennessee, and is composed of soils 

that were excavated from below the NFS Building 234 Wet Chemistry Cell. It includes a few 

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

waste tank. Revision 3 of the AKS states that Waste Stream OR-NFS-CH-SOIL contains 529 

55-gallon drums, the majority of which were originally packaged at NFS from February 1993 to 

October 1994. Some soil from operations in 1993 remained in Building 234 and was not shipped 

to ORNL. This soil was subsequently packaged at NFS in 2001 and shipped to ORNL in 2005. 

EPA evaluated the adequacy of AK information that supported these retrievably-stored CH TRU 

soil/gravel wastes from the S4000 SCG, as described below. 

Documents Reviewed

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

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

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

Services Contact-Handled Transuranic Waste Stored at Oak Ridge National Laboratory. 

Waste Stream: OR-NFS-CH-SOIL, Revision 3, August 11, 2008 

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

Services Contact-Handled Transuranic Waste Stored at Oak Ridge National Laboratory. 

Waste Stream: OR-NFS-CH-SOIL, Revision 4, May 26, 2009 

• CCP-TP-005, CCP Acceptable Knowledge Documentation, Revision 18, with Sample 

Attachments, November, 16, 2006 

• CCP-TP-005, Attachment 1, Acceptable Knowledge Documentation Checklist, Revision 

18, July 13, 2009 
7 

• CCP-TP-005, Attachment 4, Acceptable Knowledge Source Document Reference List 

(Included in the AK Summary Report: CCP-AK-ORNL-001), July 13, 2009 

• CCP-TP-005, Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, 

and Packaging, Revision 18, July 13, 2009 

• CCP-TP-005, Attachment 6, Memorandum from Jeff Harrison, CCP AKE, to Records, 

Waste Material Parameter Analysis for Waste Stream OR-NFS-CH-SOIL, NFS ContactHandled Transuranic Soil Stored at ORNL, June 27, 2008 

• CCP-TP-005, Attachment 7, Radionuclides (Radiological Characterization or NDA 

Memorandum), Revisions 1, 2, and 3 dated January 7, 2008, July 2, 2008; May 26, 2009 

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

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

8, 2009 

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

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

• Draft Waste Stream Profile Form for Waste Stream OR-NFS-CH-SOIL and 

Characterization Information, for audit purposes only, undated and provided August 11, 

2009 

• Qualification Card for Jeff Harrison provided August 11, 2009 and Addendum, Required 

Reading List provided list up to August 12, 2009 

• CCP Internal Surveillance Report for Transmittal and Closure of the WTS Quality 

Assurance Audit 109-06, August 5, 2009 

• Inter-Office Correspondence, from R. P. Kantrowitz to D. K. Ploetz, Acceptable 

Knowledge Accuracy Report for Oak Ridge National Laboratory Waste Stream Number 

OR-NFS-CH-SOIL, prepared for audit purposes only, provided August 11, 2008 

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

August 11, 2008 

• C099, Letter to Harold Johnson, CBFO DOE re: KAPL-NFS Transuranic Waste 

Background Information, May 3, 2005 

• C100, Interview with Richard Booth and Faxed defense and waste information for NFS, 

Erwin, TN TRU waste, February 4, 2005 – NFS Proprietary, Not Approved for Public 

Release

• C122, Building 234 Characterization Results, Memorandum to Heather Little, DCM-03-

18, 44T-99-0436, GPC-99-013; September 30,1999 – NFS Proprietary, Not Approved 

for Public Release 

• C200, Internal Correspondence from J.A. Chapman, RE: On the Use of Rad-Sorb in NFS 

TRU Waste Drums, dated May 26, 1993 

• C210, Record of Communication, Re: NFS TRU Waste Shipped to Oak Ridge National 

Laboratory, September 12, 2007 
8 

• DR002, CCP-TP-005, Attachment 11, Acceptable Knowledge Source Document 

Discrepancy Resolution (EPA Hazardous Waste Number Assignment), Revision 0, 

September 21, 2007 and Revision 1, November 1, 2007

• DR006, CCP-TP-005, Attachment 11, Acceptable Knowledge Source Document 

Discrepancy Resolution (Physical form of NFS-0016 and NFS-0929), November 30, 

2007 

• DR010, CCP-TP-005, Attachment 11, Acceptable Knowledge Source Document 

Discrepancy Resolution (Incorrect Waste Stream Assignment of Soil Waste Containers 

(Physical form of NFS-0016 and NFS-0929), January 12, 2009 

• I053 KAPL-TN Waste Profile for NFS Building 234 Soil, Document 44G-03-1050, 

WST-20, JWP-03-009, September 11, 2003 

• M003, ORNL UNC-2109 and UNC-2822 Forms for NFS TRU Waste and Related 

Paperwork, undated (various dates) 

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

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

• M015, Process Knowledge (PK) Documentation for Building 7920/X-10, R. E. 

Schreiber, RES-7920-000-002, June 8, 1995 

• M052, Logbook for Decommissioning and Volume Reduction Facility, December 16, 

1990, June 2, 1994 

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

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

30, 2008 

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

September 5, 2008 

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

September 8, 2008 

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

September 15, 2008 

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

September 24, 2008 

• P212, Lattice Experiments with Simulated Burned-Up Fuel for D2O Power Reactors, DP1122, February 1968 – NFS Proprietary, Not Approved for Public Release

• P218, Oak Ridge National Laboratory/Nuclear Fuel Services Inc. NFS Waste Parameter 

Verification Program, October 29, 1992 

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

November, 1999 

• P251, Box Breakdown Area Operations, CH-P-OP-003, Revision 7, March 13, 2007 
9 

• P254, Contact Handled Waste Repackaging, CH-P-OP-013, Revision 6, April 30, 2007 

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

October 19, 2006 

• P268, ORNL WAC for Contact Handled Transuranic and Mixed Oxide Wastes from 

Nuclear Fuel Services, Inc., WMRA-WMPC-106, October 16,1992 

• P269, ORNL WAC for Contact Handled Transuranic and Mixed Oxide Wastes from 

Nuclear Fuel Services, Inc., WMRA-WMPC-106, October 16, 2002 

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

February 1992 

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

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

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

• P315, We Cell Soil Excavation and Mixing, DCM-61, July 5, 1993 – NFS Proprietary, 

Not Approved for Public Release 

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

• P323, Status of Former Mixed Oxide Fuel and Fabrication Facilities at Nuclear Fuel 

Services’ Erwin, TN Site, 28T-94-003, January 10, 2004 

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

• U016, A Graphical Workbook for Estimating Important Quantities of NFS Radioactive 

Waste Constituents, March 1, 1992 

• U017, The Inter-Comparison of NDA Measurements on CH-TRU Waste Between 

Nuclear Fuel Services, Inc. and Oak Ridge National Laboratory, October 24, 1995 

• U043, Final Report- Waste Characterization of Waste Generated from D&D Activity, 

Buildings 110 and 234 on the NFS Site in Erwin, Tennessee, January 31, 1992

• U054, Decontamination and Decommissioning of a Plutonium Fabrication Facility. 

EcoTek, Inc., NFS Plutonium Facilities Decommissioning Project, undated

• U055, Calibration Schemes and measurement Techniques for the Assay of Raschig Rings 

and Soils, undated

• U058, Oak Ridge National Laboratory/Nuclear Fuel Services Inc., NFS Waste Parameter 

Verification Program, undated

• PTS Print Outs and Traceability Data (e.g., 2109 forms as available) for Drums 

NFS0104, NFS0282, NFS0324, NFS0585, NFS0812, X10C050611541, from References 

M003, M065, M075, provided August 11, 2009 
10 

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

shown in Table 4. 

Table 4. Batch Data Reports Examined 

Container Number NDE BDR Number NDA BDR Number 

NFS0104 OR-RTR6-0074 OR-DWAS-0090 

NFS0282 OR-RTR6-0089 OR-DWAS-0104 

NFS0324 OR-RTR6-0085 OR-DWAS-0102 

NFS0585 OR-RTR6-0098 OR-DWAS-0120 

NFS0812 OR-RTR6-0101 OR-DWAS-0126 

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

AK Evaluation

As stated above, the scope of this evaluation was to determine inclusion of the retrievably-stored 

CH TRU S4000 soils/gravel identified as ORNL Waste Stream OR-NFS-CH-SOIL. This waste 

stream was in CBFO’s T1 change request dated May 2009. 

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

to be adequate. 

ORNL-CCP uses two primary databases to document AK and characterization information—the 

Program Tracking System (PTS) and AK Tracking Spreadsheet. AK Procedure CCP-TP-005 

requires development and maintenance of the AK Tracking Spreadsheet that lists containers 

within each waste stream, as well as container ID, waste stream ID, generation date, vent 

date/status and changes, and container type. The PTS tracks the characterization status of each 

container, and the Characterization Tracking System module (CTS) of the PTS tracks 

nonconformance on a container basis. Additionally, CCP accesses the Oak Ridge Environmental 

Management (EM) database for information pertaining to individual drums. The ORNLmaintained EM database includes historic AK information, such as the 2109 and 2822 Forms, as 

well as other information pertinent to individual containers. The database also includes current 

characterization information. ORNL-CCP personnel said while they might use the EM database 

for information, they are not responsible for input to or maintenance of this database. ORNLCCP tracks each container’s characterization status, but EnergX is responsible for container 

movement and storage locations. 

 

As part of overall data management, CCP tracks AK documents within individual AKSs, as well 

as on CCP-TP-005, Attachment 4, which is a Source Document Reference List that includes all 

references pertinent to all waste streams at ORNL. At other sites, CCP assigns reference 

numbers on a waste stream basis, so a site may have several “C100” references, where each is 

specific to a certain stream. At ORNL, CCP decided to assign these reference numbers to a 

single source document, so the reference number is used only once at the site. This greatly helps 

the inspection process, as it reduces confusion that might stem from several documents having 

the same reference number. CCP also indicates that references are sometimes updated, and it is 

not always clear from the reference lists (reference lists in the back of the AK Summaries and 
11 

CCP-TP-005, Attachment 4). EPA recommended that CCP develop a methodology for 

identifying revision numbers or changes to source documents, to allow clear identification that a 

reference has been revised in CCP-TP-005. 

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

A Draft AK Accuracy Report for Lot 1 was provided, which included 15 containers. The 

document states that of these 15, 7 were found to have been incorrectly assigned to this SCG 

(5 containers were debris and 2 containers were solids), and were subsequently reassigned, 

which reduced the number of containers in the stream from 529 to 522. The resulting lot 

exhibited an accuracy of 41.5%. The AK Accuracy Report states: 

AK identifies U-238 and Pu-239 as the two most prevalent isotopes by weight 

percent, and 95 percent of the activity over the entire waste stream is from 

Am-241, Pu-238, Pu-239, Pu-240, and Pu-241. The predominant radionuclides 

in most containers in this waste stream will be Pu-239 and Pu-240. Because of 

the variability in drum loading, some drums will not contain the waste stream 

predominant radionuclides but may contain other radionuclides expected in this 

waste stream. 

The AK Accuracy Report did not indicate an issue with regard to 238U, as AK data indicated that 

a few containers may contain relatively large quantities of 238U by mass, which would dominate 

the mass-based determination of most prevalent radionuclides in the AKS. The determination of 

the two most prevalent radionuclides is required by the DOE-WIPP-02-3122 (WIPP Waste 

Acceptance Criteria or WAC), although there is no specification regarding whether the 

calculation must be expressed by radionuclide mass or activity. EPA believes that a calculation 

expressed in terms of activity is more meaningful. 

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

AK-NDA communication is formally implemented at all TRU WC sites to ensure appropriate 

use of AK data. CCP-TP-005 requires the preparation of an AK-NDA memorandum, as follows: 

Prepare a NDA Memorandum to CCP Records CH waste only, evaluating the 

radionuclide characterization of the waste stream. The NDA Memorandum must 

include a section for an assessment written with the NDA EA determining how the 

AK will be applied during assay. For LANL sealed sources waste, the NDA 

Memorandum must include a section written with the Off-Site Source Recovery 

(OSR) RCTS. This assessment should include a discussion of the limitations of 

the radiological characterization in the AK document and a description of the 

required assay methods, if any. Any NDA issues for both measured and 

calculated radionuclides should be discussed and resolved. 

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

show the evolution of the NFS waste over time. Revision 1 addressed only heterogeneous waste 

originating at NFS, as well as EPA comments on the version EPA assessed during its October 
12 

2007 baseline inspection. Revision 2 included both soil and the heterogeneous debris. 

Revision 3 recognized the waste stream change to “HET-A” (see item 6, AKS). 

The AK-NDA memo states that with respect to waste stream OR-NFS-CH-SOIL, 238U is the 

most predominant radionuclide by mass, and 239Pu is the second most predominant radionuclide 

by mass based on AK. “However, the two most prevalent radionuclides by mass may turn out to 

be Pu-239 and Pu-240 because of the issues with detecting U-238.” The AK-NDA memo points 

out that, unlike the debris waste stream, 233U was reported in NFS waste assay data for 36 soil 

drums in waste stream OR-NFS-CH-SOIL, including samples of soil from several borehole 

locations throughout the interior and exterior of Building 234. The AK-NDA memo states, “One 

source for this radionuclide is the U-233 purification facility located in Building 234 which was 

adjacent to the Wet Chemistry Cell. Another source for U-233 is from the removal of the 

Building 110 underground waste tank.” Another difference between the NFS soil and the 

previously approved debris stream is the presence of 228Th, which NFS detected in nearly every 

drum in Waste Stream OR-NFS-CH-HET at concentrations of between 5.93E+04 and 

2.52E+06 pCi (59.3 nCi and 2520 nCi, respectively). The source of thorium is not identified, 

and the memo indicates it could be due to spectral interference or natural sources (soil). Note 

that the plutonium isotopic ratios for the heterogeneous NFS waste, derived through detailed 

calculation based on input site source Pu and U isotopic ratios, have been retained for the soil 

stream. Since the source of contamination for the soil and heterogeneous waste streams is the 

same, application of the same isotopics appears appropriate. EPA examined the development of 

isotopic ratios for the heterogeneous waste stream and found them to be well substantiated, so a 

second detailed examination of the same isotopic ratio development was not warranted for the 

soil stream. 

(4) Load management was examined and was found to not apply for CH TRU wastes at 

ORNL-CCP, as was determined during the baseline inspection. 

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

performed at the site. 

(5) The AK Summary for Waste Stream OR-NFS-CH-SOIL, as presented in CCP-AKORNL-001, Revision 3, was assessed and was found to be adequate. NFS burial tranch 

waste added in Revision 4 of CCP-AK-ORNL-001 is expressly not included in this 

evaluation as explained below. 

The AK Summary for Waste Stream OR-NFS-CH-SOIL is included in CCP-AK-ORNL-001, 

Revision 3, dated August 11, 2008. This was presented to EPA as current and most 

representative of this document, and EPA used this version as the basis for this evaluation. The 

AKS includes information that is general and also specific to heterogeneous debris stream ORNFS-CH-HET generated at NFS, with detailed discussions about the soil and debris waste 

streams. This approach is satisfactory. 

The AKS indicates that the soil waste stream is composed of soil generated through 

decontamination and decommissioning (D&D) of Building 234 and the waste tank associated 

with the Building 110 Laboratory. D&D occurred in 1993–1994, and the majority of these 
13 

drums were shipped to ORNL. Some of the soil was not drummed until 2001, and was shipped 

to ORNL in 2005. ORNL-CCP indicated that there were: 

....five high-density polyethylene High Integrity Containers [HICs] (packaged in 

five B25 boxes) containing soil from the same excavation activity that were 

packaged at NFS in 2005. This soil will be evaluated for possible inclusion in this 

waste stream after the waste is repackaged into 55-gallon drums at the TWPC 

(Reference M003). The soil in these containers represents approximately 13.4 m3

of waste. Another B25 box (X10C0506154) containing soil and debris has been 

repackaged at the TWPC. This repackaging activity produced 25 drums of debris 

and 5 drums containing mostly soil (Reference M075). These five drums will also 

be evaluated for possible inclusion in this waste stream at a later date. 

During this evaluation, EPA was provided a more recent AKS, Revision 4, dated May 26, 2009. 

Revision 4 was prepared primarily because ORNL-CCP identified admixed soil in heterogeneous 

containers that contained tetrachloroethylene (TCE), a single hazardous constituent specific to 

the soil waste. While the heterogeneous debris was not reassigned to a different SCG, because it 

was still greater than 50% soil, the soil admix in this waste stream imparted a new chemical 

characteristic to the heterogeneous waste stream. Rather than modify the waste stream summary, 

ORNL-CCP elected to discontinue the “HET” stream and create a new HET-A” stream that was 

identical to the original HET stream, with the exception of the inclusion of lesser quantities of 

soil that contained TCE. ORNL-CCP representatives indicated that the original “HET” stream 

did not contain the soil admix, so it was appropriate to create the second waste stream. The 

radionuclide composition of the waste stream was not modified, although the physical 

composition was changed to include a small portion of admixed soil. In addition to the “HETA” designation, CCP-TP-005, Revision 4 included a revision to the soil waste stream to include 

the 5 HICs (packaged in five B25 boxes) and the X10C0506154 Box, as well as waste soil from 

an NFS burial trench. 

EPA was not provided the revised AKS until the August 2009 evaluation in Golden, CO. Upon 

examination, EPA found that the original HICs were generated at the same time as the remaining 

soil drums, but were not included in the waste stream initially, because ORNL anticipated that 

the HICs would contain low-level waste (LLW). However, recent ORNL-CCP assays indicated 

that at least some of the repackaged soil would be TRU waste, meaning that Box X10C0506154 

may ultimately be included in this waste stream. EPA was not provided this information prior to 

the inspection, nor was sufficient information provided during the August evaluation regarding 

the trench soil to approve its inclusion in Waste Stream OR-NFS-CH-SOIL. Accordingly, 

addition of soil from the NFS burial trench soil to Waste Stream OR-NFS-CH-SOIL is a T1 

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

(6) The definitions of the Waste Stream and Waste Stream Profile Form (WSPF) were 

evaluated and were found to be adequate. 

The WIPP Waste Analysis Plan (WAP) and WAC define a waste stream as: “waste material 

generated from a single process or from an activity which is similar in material, physical form, 

and hazardous constituents.” Waste Stream OR-NFS-CH-SOIL consists of soil with RADSORB 
14 

admix and a RADPAD at the top of each drum. ORNL-CCP has characterized the waste stream 

as RCRA-hazardous waste under 40 CFR Part 261, Subpart C, based on the presence of organic 

constituents. 

Waste Stream OR-NFS-CH-SOIL was generated during decommissioning of Building 234 and 

the removal of the Building 110 laboratory underground waste tank. This waste tank was a 

55-gallon drum buried underground. Production operations stopped in 1973 within Building 

234, and decommissioning was initiated in the early 1990s. The majority of the soil was 

generated from excavating under the Building 234 Wet Chemistry Cell that performed nitric acid 

dissolution and mixing of Pu and depleted uranium (DU) or low-enriched uranium (LEU). The 

floor of the Building 234 wet cell was breached along a wall and sump, providing a transport 

pathway for material from the cell to the underling soil column. Soil was excavated to about 

6 feet below grade, and excavated soils were placed on a conveyor and transferred from the Wet 

Chemistry Cell where they were blended in a mixer with added RADSORB (10 lb/drum). Soil 

was then placed in a drum and a RADPAD was placed on top of the drummed soil. ORNL-CCP 

states that: 

The purpose of soil mixing was to break up and homogenize the clay, add 

RADSORB absorbent powder to the soil to prevent the formation of liquid, and to 

blend soils with plutonium contamination that would otherwise exceed 128 grams 

Pu-239 fissile gram equivalent (FGE) in compliance with ORNL Waste 

Acceptance Criteria. 

In addition to Building 234, soil associated with cleaning up Building 110 Wet Chemistry and 

Spectographic Laboratories underground was also transported to and mixed in the same facility. 

When queried, ORNL-CCP representatives indicated that there was no information to suggest 

that Building 110 soils were drummed separately, and data examined indicated that this soil was 

mixed with Building 234 soils. ORNL-CCP indicated that there was no way to distinguish 

between drums containing soil from only Building 234 or Building 110, as both areas were 

processed using the same equipment and were mixed during the drumming packaging. 

EPA reviewed the methodology and supporting AK documentation that ORNL-CCP used to 

define the waste stream in terms of physical form; radiological characteristics; chemical usage 

and potential hazardous materials; ignitable, corrosive, and reactive contents; Polychlorinated 

biphenyls (PCBs); pyrophoric constituents; toxicity for organic compounds; and prohibited 

items, as well as the ability of the site to segregate them from the waste stream. EPA found that 

waste stream OR-NFS-CH-SOIL as presented in CCP-AK-500, Revision 3, was appropriately 

defined. 

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

stream. Since Revision 4 includes more containers than considered by EPA through review of 

Revision 3, these memoranda are necessary to understand why containers were added. In the 

future, when ORNL-CCP/CBFO submits a T1 change request for soils from NFS burial trench, 

the “add container” memoranda and revised AK-NDA memoranda need to be made available to 

EPA as part of the request, along with other relevant documents. 

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

The ORNL-CCP AKE indicated that ORNL-CCP performs a fast scan of containers using 

internal process and procedures to screen containers for the presence of prohibited items, WAC 

requirements, and other elements, including non-WIPP-related requirements. The data are used 

to release containers to CCP, who performs one-hundred percent RTR on containers. Although 

these results are not currently in the AK record, EPA believes that this information should be 

integrated to ensure availability of potentially important data on containers as they are processed. 

EPA also believes that ORNL-CCP should reference Quick or Fast Scan records and make them 

available as part of the AK Record. This is important, because these are either characterization 

actions that must be used to calculate AK accuracy, or they are AK documents that must be 

included in the record and considered for documenting AK-AK discrepancy resolution. EPA 

may examine AK accuracy calculations and Fast/Quick Scan results to see whether the ORNLCCP considers Quick/Fast Scan results in AK-AK discrepancy resolutions or accuracy 

calculations. 

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

Qualification and training of CCP personnel is implemented through CCP-QP-002, CCP 

Training and Qualification Plan. Training records for the CCP AKE, Jeff Harrison, were 

examined, including the AK Qualification Card and Addendum, as well as a list of required 

reading that had been accomplished up to August 10, 2008. Mr. Harrison had performed 

required reading pertinent to applicable portions of the WIPP WAP and WAC, State and Federal 

hazardous waste regulations associated with solid and hazardous waste characteristics, and sitespecific WC procedures for confirming AK and generating data for radiological and physical 

contents of the TRU waste. However, this training was based on old versions of the WAP and 

WAC, and records did not indicate that the AKE had been retrained with respect to recent 

versions of the WAP and WAP. 

Furthermore, CCP in general, does not incorporate results of DOE’s Performance Assessment 

which became the basis for EPA WIPP regulations (i.e., Compliance Certification Requirements) 

specifically into CCP’s TRU WC personnel training program. EPA has repeatedly requested that 

the program be modified to incorporate these requirements, particularly since the second 

Recertification Application (which EPA is currently reviewing) could directly affect 

characterization requirements. EPA discussed this with CCP Lead during the inspection and 

they agreed that the training program could be improved with regard to EPA requirements. EPA 

committed to provide CCP with materials that could be used in such a training program. 

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

and waste streams were assessed and were found to be adequate. 

EPA selected six containers for which BDRs and historic traceability data were provided: 

NFS0104, NFS0282, NFS0324, NFS0585, NFS0812, and X10C0506154(L) (the last was a 

repackaged drum from a larger box). Historical data provided for the drummed waste included 

the 2822/2109 Forms, NFS NDA data sheets, TRU Waste Package Data, various checklists for 

ORNL drum receipt, NFS shipment information and number, drum-specific procurement quality 
16 

surveillance plans(s), waste certification checklist, and WEAF1 data entry/analysis. In addition 

to these documents specific to the individual drums, ORNL-CCP also provided other historic 

information including, but not limited to, WEAF Waste Acceptance Reports, Storage of Disposal 

of Radioactive Waste Tracking Update forms, and data log sheets for packaging TRU waste. 

These data are contained in references M003 and M065. With respect to the repackaged drums, 

ORNL-CCP provided information for drums packaged from two larger boxes; X10C0506154(L) 

that was repackaged from Box X10C056150, and X10C056150(A) that was repackaged from 

Box X10C056150. ORNL-CCP provided the BDR for 6154(L), as well as the 2109 Forms, 

Radioisotope Continuation Sheet, and Radwaste Package Certification Record and other 

information for both boxes. The EnergX Contact-Handled Waste Repackaging Data Forms were 

provided for each repackaged drum. ORNL-CCP demonstrated that abundant information was 

available for the selected containers and adequately demonstrated traceability. 

(10)Limitations and exclusions associated with the AK record were assessed and were found 

to be adequate. 

Every AK Source Document has an associated Attachment 3 – Record of Communication that 

includes an area to list or identify AK data limitations. Each of the examples provided either 

listed a limitation or stated that there were no limitations. 

(11)AK-AK and Measurement-AK discrepancy resolutions and NCRs were examined and 

were found to be adequate. 

ORNL-CCP prepared two AK-AK discrepancy resolutions, DR006 and DR010, pertinent to this 

waste stream. DR006 addressed the misassignment of a drum with respect to its SCG and the 

potential misidentification of a drum that may contain compacted waste. A report entitled, 

"ORNL TRU Waste Historical Survey," indicated that container No. NFS-0929 contained waste 

grouted in 2 liter bottles, which indicated SCG S3000, homogeneous waste. Review of the 

WEAF RTR indicated that the drum contained predominantly debris waste, which would 

reassign the drum to SCG S5000. Drum NFS-0116 was described in historical paperwork as 

containing raschig rings, but a logbook implied that a compacted puck was placed atop the rings. 

Examination of WEAF RTR showed there to be a crushed bucket atop the raschig rings, but it 

was unclear whether the bucket was machine-compacted, so the drum was retained in the HET 

stream pending future RTR results. 

DR010 addressed the misidentification of seven drums by AK. DR010 states that AK identified 

7 drums as S4000 soil, but RTR determined that 5 of the drums (NFS0821, NFS0839, NFS0840, 

NFS0927, and X10C0506047) were predominantly S5000 debris waste and 2 of the drums 

(NFS0816 and NFS0817) were predominantly S3000 absorbent. This misidentification was 

captured on CCP-TP-005 Attachment 10, the Acceptable Knowledge Re-Evaluation Checklist, 

which documents assignment and disposition of these containers. 

ONRL-CCP also provided several Non Conformance Reports (NCRs) pertaining to the soil 

waste stream. Many of the NCRs were issued because RTR found prohibited quantities of 

liquids in the containers. For example, NCRs were prepared when a drum was assigned to a 

 

1

 WEAF is the Waste Assay and Examination Facility at ORNL. 
17 

different SCG as in NCR-ORNL-0664-08 and NCR-ORNL-0665-08, both of which address 

reassignment of waste from a soil to debris SCG based on RTR. These changes are within the 

“L” trend group and EPA may examine “L” trends in the future to determine whether assigning 

L trend codes would require a tier assignment. 

(12) Defense origin of waste was verified. 

The WAC requires generator sites to use AK to determine if the TRU waste streams to be 

disposed at WIPP meet the definition of TRU “defense” waste. TRU waste is eligible for 

disposal at WIPP if it has been generated in whole or in part by one of the atomic energy defense 

activities listed in Section 10101(3) of the Nuclear Waste Policy Act of 1982. According to the 

site, the basis for the “defense” nature of waste stream OR-NFS-CH-SOIL is that Building 234 

performed mixed oxide (MOX) fuel fabrication and 233U purification under subcontracts to two 

government contracts administered by the U.S. Atomic Energy Commission (AEC) and two 

smaller commercial contracts. The two larger contracts were national defense-rated orders, 

which were designated DO-E2 certified for national defense use under Defense Material System, 

Regulation 1. The defense and commercial activities utilized the same process equipment, so the 

source of contamination is indistinguishable. Therefore, ORNL-CCP contends that the TRU 

wastes from decommissioning are linked primarily to defense nuclear material production. This 

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

approved by EPA. 

(13)AK information pertaining to radiological characteristics of waste was examined and 

was found to be adequate. 

AK data presented in the Waste Stream CCP-AK-ORNL-001 AKS, Revision 3, and the AKNDA memo, as well as various supporting documents, were examined to understand the 

radiological characteristics of Waste Stream OR-NFS-CH-SOIL. Essentially, ORNL-CCP 

indicated that the isotopic distributions for Pu and U used for OR-NFS-CH-HET wastes were 

applicable to soils, because Waste Stream OR-NFS-CH-SOIL was created when the same liquid 

waste that contaminated heterogeneous debris leaked through the Wet Cell in Building 234 to the 

underlying soil column. However, ORNL-CCP also stated that additional radionuclides, such as 

Natural Thorium and 233U, were present exclusively in soil and not in debris. EPA assessed the 

similarities and differences with respect to the soil’s radiological characteristics. 

CCP-AK-ORNL-001 states that waste within the stream was generated through D&D of 

Building 234 and removal of underlying soils. Building 234 was used for production and other 

activities related to MOX fuels, and a portion of the building was used as a 233U purification 

process facility. The portion of the building that was used for 233U was decommissioned in 1983, 

and while the OR-NDF-CH-HET waste stream did not contain debris contaminated with 233U, 

soil underlying the building was not removed when the 233U purification area was 

decommissioned. Therefore, soil underlying Building 234 was expected to contain 233U, which 

was verified by NFS assay. ORNL-CCP stated: 

U-233 was reported in NFS waste assay data for 36 soil drums (0.1 grams U-233 

is the largest mass reported in a single soil drum) (References M003, M012). 

U-233 was also identified in samples of soil from several borehole locations 
18 

throughout the interior and exterior of Building 234 (References C122, I053). 

One source for this radionuclide is the U-233 purification facility located in 

Building 234 (References C122, C210, I053, P248, P283). Another source for 

U-233 is from the removal of the Building 110 underground waste tank since the 

Building 110 laboratory also handled U-233 (References C210, U055). 

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

ORNL-CCP stated that some of the soil that was previously identified as LLW remained in 

Building 234 and was not shipped to ORNL with the drums generated during the initial D&D 

events. This soil was packaged in 2001 and assayed on the NFS VAGAS2

 system, and contained 

measurable natural thorium, i.e., 228Th and 232Th (References M003, M012), that was not 

identified in debris. ORNL-CCP states that the presence of 228Th and 232Th may be “due to 

spectral interference from background radiation. Unlike debris waste, soils are more likely to 

contain natural thorium. This is consistent with alpha spectroscopy results for soil from the 

Building 234 Wet Chemistry Cell area (Reference I053).” EPA examined many of the cited 

references and verified that thorium has been identified in NFS soil. However, ORNL-CCP did 

not provide any references explaining the origin of the thorium or 233U, sometimes calling upon 

potential contaminant migration from offsite sources as a contributing factor to the chemical or 

radiological make-up of soils. EPA indicated that since more D&D waste and soils are being 

approved, ORNL-CCP must ensure that all arguments concerning natural, background, or offsite 

sources of radionuclides are fully referenced and supported. For example, if a chemical or 

radiological component is thought to have migrated to the soil, the contaminant migration 

pathways and specific source terms should be identified. ORNL-CCP should consider 

radionuclide partitioning that may take place in the soil column, as this may affect the actual 

presence or absence of radionuclides within the soil. It cannot always be assumed that the 

radionuclides within a release would be retained in the same distribution in the soil column, due 

to differences in radionuclide mobility. EPA discussed this with ORNL-CCP representatives and 

they stated that in the future, they will evaluate waste streams in this regard, as appropriate. 

Although 233U and thorium were apparently unique to soil, the Pu and U isotopic distributions 

were common to both the soil and debris originating from Building 234 D&D, because the 

source of Pu and U (other than 233U) present in both streams had a common origin. Building 234 

managed and performed MOX fuel-related activities from four different contracts. ORNL-CCP 

indicates that the radiological composition shown in Table 5 is applicable to both the OR-NFSCH-HET and OR-NFS-CH-SOIL waste streams: 

Table 5. Mixed Oxide Fuel Compositions 

Contract Pu Percent U Percent Pu (kg) U (kg) Total (kg) 

SEFOR 20 80 746 2,984 3,730 

Consumers 2.27 97.9 47 2,027 2,070.48 

SRS 0.31 99.7 16 5,064 5,079.37 

Halden 0.5 99.5 3 117 120 

Total - - 812 10,192 11,000 

 

2

 VAGAS is the Versatile Automated Gamma Assay System NDA system used at NFS. 
19 

These data show that uranium dominates the mass of radiological material within each material. 

Fuels generated for the various sites/contracts had specified isotopic distributions, as presented in 

Table 6, and are applicable to both the SOIL and HET waste streams. 

The AK Summary states that TRU soil waste was assayed multiple times on different systems, 

including the VAGAS at NFS and the APNEA3

 at the ORNL WEAF. ORNL-CCP 

representatives indicated that the NFS data were included in the EM database, and the EM 

database was used to develop the general isotopic ranges expected for various radionuclides, as 

presented in Table 6-4 of CCP-AK-ORNL-001, which is reproduced here as Table 7. 

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

Radionuclide SEFOR Consumers SRS Halden 

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

239Pu 18.13 90.63 1.73 76.24 0.29 90.94 2.00 79.89 

240Pu 1.67 8.33 0.37 16.34 0.02 7.99 0.36 14.51 

241Pu 0.10 0.48 0.07 2.91 0.003 0.99 0.06 2.24 

242Pu 0.01 0.05 0.03 1.1 0.0002 0.08 0.02 0.83 

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

Total 20.0 100 2.27 100 0.31 100 2.5 100 

 

234U 0.12 0.15 0.58 0.59 0.001 0.001 3.90 4.00 

235U 0.28 0.35 2.36 2.41 0.30 0.30 4.88 5.01 

238U 79.60 99.50 94.96 97.00 99.40 99.69 88.73 91.01 

Total 80.0 100 97.9 100 99.7 100 97.5 100 

 NOTE: For each of these materials, the first column represents the overall mass fractions of the MOX

fuel, and the second column provides the mass fractions of the fuel’s plutonium and uranium constituents 

separately. 

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

Radionuclide

Total 

Radionuclide 

Wt%1

Radionuclide Wt% 

Range for Individual 

Containers 2

Total 

Radionuclide 

Ci% 3

Radionuclide Ci% 

Range for Individual 

Containers 4

Suspected To 

Be Present 

(Yes/No) 

WIPP-Tracked Radionuclides 

Am-241 0.12% 0.00% - 2.86% 7 4.79% 3.02% - 18.38% Yes 6

Pu-238 Trace 5 0.00% - 0.43% 7 1.23% 0.00% - 10.90% Yes 

Pu-239 19.17% 0.59% - 90.94% 7 13.63% 5.10% - 52.93% Yes 

Pu-240 2.31% 0.06% - 16.34% 7 6.02% 0.60% - 38.20% Yes 

Pu-242 0.01% 0.00% - 1.17% 7 Trace 0.00% - Trace Yes 

U-233 Trace 0.00% - 0.18% Trace 0.00% - 0.25% Yes 

U-234 3.84% 0.00% - 5.00% 0.27% 0.00% - 1.06% Yes 

U-238 73.42% 0.00% - 99.69% 7 Trace 0.00% - 0.03% Yes 

Cs-137 Trace 0.00% - Trace Trace 0.00% - Trace Yes 

Sr-90 Trace 0.00% - Trace Trace 0.00% - Trace Yes 

 

3

 APNEA stands for Active Passive Neutron Examination Assay NDA system used at WEAF. 
20 

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

Radionuclide

Total 

Radionuclide 

Wt%1

Radionuclide Wt% 

Range for Individual 

Containers 2

Total 

Radionuclide 

Ci% 3

Radionuclide Ci% 

Range for Individual 

Containers 4

Suspected To 

Be Present 

(Yes/No) 

Additional Radionuclides 

Pu-241 0.06% 0.00% - 2.91% 7 74.05% 23.56% - 86.96% Yes 

Tc-99 Trace 0.00% - 0.15% Trace 0.00% - 0.07% Yes 

Th-228 Trace 0.00% - Trace Trace 0.00% - Trace Yes 

Th-232 0.16% 0.00% - 22.23% Trace 0.00% - Trace Yes 

U-232 Trace 0.00% - Trace Trace 0.00% - Trace Yes 

U-235 0.90% 0.28% - 5.01% 7 Trace 0.00% - Trace Yes 

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

2This listing is the weight percent range of each radionuclide on a container-by-container basis. Some containers 

with “0” listed as the lower range, will not contain the specified radionuclide. 

3This listing indicates the total activity (curie) percent of each radionuclide over the entire Waste Stream. 

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

5

 “Trace” indicates <0.01 weight percent for that radionuclide. 

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

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

Predominant radionuclides by mass are anticipated to be 238U and 239Pu based on AK data. As 

determined for the HET waste stream, ORNL-CCP indicates there are significant uncertainties. 

Data in Table 6 indicate that the waste stream is anticipated to consist primarily of a mixture of 

U and Pu, with the predominant radionuclides by activity being 239Pu, 240Pu, 241Pu, and 241Am 

associated with measuring 238U, and the ORNL-CCP measurement system is not sensitive 

enough to detect 238U, except when it is present in substantial quantities. Therefore, while 

previous systems identified 238U as a predominant radionuclide by mass, measurements by 

ONRL-CCP may not identify 238U, so the predominant radionuclides by mass detected by 

ORNL-CCP may ultimately be 239Pu and 240Pu. This lack of instrument sensitivity may result in 

under-reporting of 238U. 

 

ORNL-CCP representatives stated that default isotopics were calculated based on the amount of 

MOX fuel processed and other characteristics for each material (see the AK-NDA memo for 

additional details). The isotopics for soil and debris are the same, and the decay-corrected 

default mass fractions are as follows: 

Plutonium% Uncertainty 

238Pu 0.044% 0.0044% 

239 Pu 90.837% 9.0837% 

240Pu 8.893% 0.8893% 

241Pu 0.104% 0.0104% 

242Pu 0.122% 0.0122% 

241Am 1.115% 0.1115% 

EPA examined the default isotopic calculations when evaluating the HET waste stream and 

determined that the calculation approach used by ORNL-CCP is reasonable, based on available 
21 

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

available data. 

(14)Identification of Waste Material Parameters (WMPs) and prohibited items were assessed 

and found to be adequate.

ORNL-CCP addresses WMP calculations in Attachment 6 of CCP-TP-005 and through a June 

27, 2008, memorandum in which they state that Waste Stream OR-NFS-CH-SOIL is composed 

of soil, rock, and gravel mixed with RADSORB, with each drum containing about 10 pounds of 

adsorbent. A RADPAD (absorbent) pad was placed on top of the soil in each drum prior to drum 

closure. ORNL-CCP examined the records for over 500 containers and determined that they 

consisted almost entirely of soils and gravels (84.9–98.3%), and the remaining material was 

primarily absorbent (1.5–13.6%). Minor amounts of plastic may be present (less than 1.5%). 

Examination of the individual drum summaries provided with the July 27, 2008, memorandum 

generally confirmed these ranges, noting that individual drums may exhibit significant weight 

variations, due to the amount of soil within the drum. 

With regard to prohibited items, ORNL-CCP states that, “Prohibited items have not been 

identified in this waste stream.” However, EPA notes that some NCRs have been issued due to 

the presence of prohibited amounts of liquid that were identified via RTR, and ORNL-CCP 

identified at least one such drum. Accordingly, ORNL-CCP’s statement may require revision to 

more accurately describe these conditions. ORNL-CCP acknowledged that liquid may have 

formed in some drums: 

...[due to the] physical nature of this waste and the fact that many of these drums 

have been in storage at ORNL for nearly 15 years, it is possible that liquid may 

have formed in some drums. Certified RTR and/or VE are performed by CCP to 

ensure the waste does not contain prohibited items in accordance with the WIPPWAC and WIPP-WAP. 

EPA agrees that ongoing characterization, including RTR and repackaging, as necessary, will be 

used to detect and mitigate the presence of liquids, as evidenced by the issuance of NCRs. 

Summary of AK Findings and Concerns

The EPA inspection team did not identify any findings or concerns related to AK during this 

inspection. EPA did make several recommendations that are included in the text of each AK 

item, above, for CCP to consider, as these will be evaluated in future EPA evaluations. There 

are no open AK issues relative to this T1 evaluation. 

Tiering Changes

Based on the results of this T1 evaluation, EPA has revised the T1 and T2 designations assigned 

to AK during the ORNL-CCP baseline approval, as reflected in Table 1 of this report. There is 

one new AK T1 change and slight modifications to the AK T2 elements. All of the T2 elements 
22 

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

6.2 Non Destructive Assay (NDA) 

Documents Reviewed

As part of this evaluation, EPA inspectors examined a variety of documents related to NDA, and 

they are listed below: 

• CCP-DWAS/IPAN/SGS-08-001, DWAS IPAN Calibration Validation and Confirmation 

for Extended Passive Mode Operating Range, June 2008, Revision 0, June 30, 2008 

• CCP-DWAS/IPAN/SGS-08-001, DWAS IPAN Calibration Validation and Confirmation 

for Extended Passive Mode Operating Range, June 2008, Revision 0, June 30, 2008 

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

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

• MV-SGS0101-CAL-001, Segmented Gamma Scanner-01 (SGS-01-01) Calibration, 

Confirmation and Verification Report, Revision 0, November 6, 2007 and Revision 1, 

December 19, 2007 

• WASTE CHARACTERIZATION INSPECTION REPORT, FINAL APPROVAL; EPA 

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

CHARACTERIZATION PROJECT WASTE CHARACTERIZATION PROGRAM AT 

THE OAK RIDGE NATIONAL LABORATORY; November 13–15, 2007 

• Calibration Verification Report for the DWAS from February 11, 2009 

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

• CCP-TP-168, CCP Drum Waste Assay System Imaging Passive/Active 

Neutron/Segmented Gamma Scanner Data Generation Level Validation, Revision 0, 

October 18, 2007 

• CCP-TP-166, CCP Drum Waste Assay System Imaging Passive/Active Neutron 

Operations, Revision 2 

• CCP-TP-167, CCP Drum Waste Assay System Imaging Passive/Active Neutron 

Calibration, Revision 

NDA Evaluation

(1) The design and operational range of the DWAS were assessed and found to have not 

changed from what EPA had approved previously. 

The Drum Waste Assay System Imaging Passive Active Neutron/Segmented Gamma Scanner 

(DWAS IPAN/SGS) is a multimode NDA system housed in Building 7880-I of the TWPC and 
23 

operated by ORNL-CCP for gamma and neutron-based assays of CH retrievably-stored TRU 

wastes in 55-gallon drums. The SGS and IPAN components of the DWAS determine the 

isotopic distribution of 238Pu, 239Pu, 240Pu, 241Pu, 242Pu, 241Am, 235U, 237Np, and other 

radionuclides using Genie 2000 and NDA 2000 software; and values for 239Pu effective mass 

(

239PuEFF) and 240Pu effective mass (240PuEFF), respectively, operating in both active and passive 

modes. Matrix corrections for the IPAN are expressed in moderator (MOD index) and/or 

absorber/moderator (ABSMOD index) for passive and active modes, respectively. 

Values for other WIPP-tracked radionuclides are quantified based on measured values from the 

SGS, i.e., gamma-based isotopic distribution, or known or established relationships (AK-based 

isotopics) in conjunction with the measured neutron-based quantity. In some cases, 

radionuclides are quantified by the SGS, and three specific radionuclides are quantified by 

computational or correlation techniques, i.e., 242Pu, 137Cs and 234U. These aspects of the SGS 

and IPAN were unchanged from what EPA had inspected and approved previously, and are 

appropriate for assaying S4000 wastes from ORNL Waste Stream OR-NFS-CH-SOIL. 

(2) The applicability of the DWAS calibration to S4000 soils/gravel wastes for the SGS and 

IPAN components was found to be acceptable. 

The DWAS SGS matrix calibration was initially performed in 1996, and subsequently updated 

with several additional data to support a matrix density range of 0.0 to 0.72 g/cm3

 for the SGS. 

This was subsequently extended to 1.72 g/cm3

 via a T1 change evaluation, along with a new 

upper limit of 220.4 grams total Pu. For the IPAN, EPA’s initial approval for passive neutron 

was 2.050 g 240PuEFF. This was subsequently extended to 72.5133 g 240PuEFF via a separate T1 

change evaluation, with no changes to the MOD or ABSMOD ranges. The current SGS and 

IPAN limits adequately cover the density (matrix) and activity ranges for the S4000 soils/gravel 

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

 

(3) Demonstration of the ability to quantify the WIPP-tracked radionuclides and assign 

isotopic distributions pertinent to CH TRU wastes for the density and activity ranges for 

the S4000 soils in ORNL Waste Stream OR-NFS-CH-SOIL was evaluated and found to 

have not changed from what EPA had approved previously. 

Six DWAS BDRs were evaluated with respect to ORNL-CCP’s ability to adequately document 

required NDA elements and to provide technical support for NDA reported values. The BDRs 

were reviewed with respect to containing the following elements: 

• Testing facility name, testing batch number, container numbers, and signature of the Site 

Project Officer (SPO) 

• Table of Contents 

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

• Data validation, as required in CCP-TP-168, CCP Drum Waste Assay System Imaging 

Passive/Active Neutron/Segmented Gamma Scanner Data Generation Level Validation 

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

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

elements: 

• Title “Radioassay Data Sheet” 

• Method/procedure used 

• Date of radioassay 

• Activities and associated total measurement uncertainty (TMU) for individual 

radionuclides expressed in appropriate units 

• TRU alpha concentration expressed in appropriate units 

• Operator signature 

• Reviewer signature(s) 

Technical review of the DWAS BDRs and RDSs indicated two issues with respect to the 

execution and documentation of the neutron component of the DWAS daily performance checks. 

These were discussed with ORNL-CCP personnel and resulted in EPA issuing two formal 

concerns; EPA T1 Evaluation Issue Nos. ORNL-CCP-CH-NDA-09-002CR and ORNL-CCPCH-NDA-09-003C, as shown in Attachments B and C to this report, respectively. Both concerns 

are discussed below. 

EPA T1 Evaluation Issue No. ORNL-CCP-CH-NDA-09-002CR: Common practice for 

ORNL NDA control charts is to record only successful performance checks and to omit any 

measurement failures, i.e., values outside of the 3 Sigma Control Limits. Each such failure 

requires resolution, i.e., calibration verification and a subsequent successful performance check, 

which overrides the failure, resulting in only the successful performance check value being 

entered on the control chart. This only occurs at ORNL-CCP. This does not affect the technical 

quality of the DWAS NDA data evaluated during this T1 evaluation; its effect is limited to the 

record that documents performance of the DWAS. 

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

BDRs for ORNL Waste Stream OR-NFS-CH-SOIL was not contingent upon resolution of this 

issue. Nonetheless, ORNL-CCP did provide a written response, in which the DWAS data 

generation level validation procedures (CCP-TP-166 and CCP-TP-168) were revised to remove 

the requirement for control charts and replace them with performance data sheets that will be 

included in the DWAS BDRs. EPA accepts this resolution. 

Status of Concern: This concern is closed. 

EPA T1 Evaluation Issue No. ORNL-CCP-CH-NDA-09-003C: ORNL BDR No. ORDWAS-0203 contains a control chart for 240PuEFF for the time period of February 1, 2009, to 

March 3, 2009. The control chart shows three points that exceed the 3 Sigma Control Limits on 

February 2, 11, and 19; however, all points were, in fact, in control. This apparent discrepancy 

occurs because the 2 and 3 Sigma Warning and Control Limits change every week as a result of 

decay-correcting the 252Cf source, which has a half-life of 2.6 years. A value that is in control at 
25 

the time it was performed may be outside of warning or control limits that were generated at a 

later time, due to changes in the limits as a function of decay-correcting the 252Cf source. When 

the older value is shown on a control chart with the newer limits, it appears to be out of control 

when, in fact, it was not. This is not a technical issue, in that all performance checks that we 

observed were in control at the time they were performed. 

Concern Resolution: This concern did not require a response. 

Status of Concern: This concern is closed. 

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

ORNL Waste Stream OR-NFS-CH-SOIL was evaluated and was found to have not 

changed from what EPA had approved previously. 

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

Waste Stream OR-NFS-CH-SOIL IPAN was evaluated and was found to not have 

changed from what EPA had approved previously. 

Summary of NDA Findings and Concerns

EPA did not identify any findings relative to this T1 evaluation. EPA did identify the two 

concerns discussed above, and they are included in Attachments B and C to this report. Concern 

No. ORNL-CH-NDA-09-002CR required a response, which ORNL-CCP provided and which 

EPA evaluated and found adequately addressed the concern. Concern No. ORNL-CH-NDA-09-

002CR is closed and Concern No. ORNL-CH-NDA-09-003C does not require a response. There 

are no open issues related to NDA for this T1 evaluation. 

Tiering Changes

Based on the results of this T1 evaluation, there are no changes to the T1 and T2 designations 

assigned to NDA during the ORNL-CCP baseline approval. 

6.3 Real-Time Radiography (RTR) 

RTR Evaluation

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

RTR operations are performed as directed in CCP Procedure CCP-TP-053, Revision 6, CCP 

Standard Real-Time Radiography (RTR) Inspection Procedure. This is a well-established 

procedure containing adequate instructions and directions to generate and process RTR data. 

EPA did not identify any concerns with this procedure. 

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

EPA reviewed training Qualification Cards for five RTR operators and Demonstration of 

Capability records for three RTR operators. The Qualification Cards for all operators were 

complete and EPA did not identify any concerns associated with these records. 

ORNL-CCP provided EPA with inventories for Training Drum Nos. ORNL-NDE-TEST-007, 

ORNL-NDE-TEST-008, ORNL-NDE-TEST-009, ORNL-NDE-TEST-010, and ORNL-NDETEST-011. All training drums were constructed to challenge and demonstrate operators’ ability 

to identify items typically found in S5000 (debris) and S4000 (soil) waste. Each training drum 

included at least five non-WAP-required items, and Training Drum No. ORNL-NDE-TEST-007 

contained nine such items. EPA reviewed both the written and A/V records for one RTR 

operator’s Capability Demonstration and written records for two RTR operators on Training 

Drum No. ORNL-NDE-TEST-007. From review of these records, EPA identified items that 

were missed by all operators. EPA summarized the results in Table 8: 

Table 8. Summary of RTR Operators Performance on Training Drums 

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

Written Record 

Operator SB 

Written Record 

Operator LS 

Written and A/V Record 

Soil OK OK OK 

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

Cardboard OK OK OK 

Horsetail bag of Raschig rings Missed in horsetail bag Missed in horsetail bag Missed in horsetail bag

Horsetail bag with rubber hose and 

paint brush 

Found hose and paint 

brush, but missed them 

in a horsetail bag

Found brush and “tygon” 

tubing. Missed that these 

were in horsetail bag 

Missed hose and in horsetail bag 

Orally identified a paint brush, 

but did not record on data sheet

Plastic labware Missed (glass labware 

identified)

Missed (glass labware 

identified)

Missed (glass labware 

identified)

Rubber hose OK “tygon tubing” OK 

Horsetail bag with paper Found horsetail bag, but 

missed paper in bag

Found horsetail bag, but 

missed paper in bag

Found horsetail bag, but missed 

paper in bag

Electrical cord OK OK OK 

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

did not include it in the written record. Furthermore, the Subject Matter Expert (SME) neither 

recognized nor recorded these errors as required by CCP-QP-002, Training and Qualification 

Plan, Revision 26, Attachment 3, CCP Capability Demonstration Data Sheet for ContactHandled Waste. This was discussed with ORNL-CCP RTR personnel, and EPA generated 

Inspection Issue No. ORNL-CCP-CH-RTR-09-001CR, which required a response. It is included 

in Attachment A to this report and is discussed below: 

EPA T1 Evaluation Issue No. ORNL-CCP-CH-RTR-09-001CR: Review of recordings of 

Demonstrations of Capability examinations performed on Test Drum ORNL-NDE-TEST-007 on 

June 19, 2008, showed that operators missed some of the non-WAP items included, as 

summarized in Table 8. Furthermore, the SME, who checked the Demonstration of Capability 

recordings, did not identify these errors. This is a repeat concern, the original being written 

during the ORNL CH baseline inspection. 

Concern Resolution: This concern required a response; however, acceptance of RTR for the 

S4000 soils/gravel SCG was not contingent upon resolution of this issue. Nonetheless, ORNLCCP did provide a written response, in which they agreed with EPA’s concern. CCP committed 
27 

to provide appropriate training to all RTR and Vendor Project Manager (VPM) qualified 

personnel to emphasize the importance of identifying all items in the RTR training drums. This 

response adequately addressed EPA’s concern and this issue is closed. 

Status of Concern: This concern is closed. 

For the sake of completeness, the original concern from ORNL CH Baseline Inspection No. 

EPA-ORNL-CCP-CH-11.07-8 is provided below and is included in the Additional Comments

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

EPA Inspection Issue No. ORNL-CCP-CH-RTR-09-004C: In the capability demonstration 

training containers, the EPA inspector noted that while all the required items (prohibited items) 

were identified correctly by all RTR operators, some additional items (cellulosics and plastics) 

were not identified. All cellulosics and plastics in the training drum need to be identified and 

their identification documented. To complete the training process, it is critical that the operator 

receives feedback regarding missed items. More detailed documentation of the feedback given is 

needed when the results of the training drum are reviewed. 

EPA reviewed the written records for the remaining four Training Drums and found that all 

items were correctly identified, but all operators failed to recognize that certain items were 

contained in plastic bags. It should be noted that the non-WAP items in these drums were 

significantly different to those in Training Drum No. ORNL-NDE-TEST-007. 

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

adequate. 

EPA reviewed selected BDRs for containers from Waste Stream OR-NFS-CH-Soil to verify the 

consistency and completeness of the records. EPA reviewed the records for Container Nos. 

NFS0123, NFS0585, and NFS0489 from BDR OR-RTR6-0098. The RTR Measurement Control 

Report (MCR) was reviewed and found to be within the stipulated acceptance criteria. NonConformance Report (NCR) NCR-ORNL-06550-08 was written for container NFS0489, because 

of the presence of 300 mL of non-residual liquid. The required Quality Control (QC) was 

performed with the Independent Observation performed on Container No. NFS0123 and 

Replicate Scan on Container No. NFS0585. The BDR had been reviewed at both the data 

generation and project level, as required. For BDR OR-RTR6-0121, EPA verified the 

acceptability of the MCR, performance of the required Independent Observation (performed on 

debris Container No. X10C0501806) and Replicate Scan, and the completeness of the data 

generation and project level review checklists. 

NCR-ORNL-0651-08 was written for Container No. NFS0927 from RTR BDR OR0RTR6-0101, 

because the waste did not match the waste description. ORNL-CCP correctly rejected this drum 

and requested the AKE to perform an AK re-evaluation. EPA also reviewed the records for 

Container No. NFS0812 from this BDR. EPA also reviewed records for Container Nos. 

NFS0141 and NFS0849 from BDR OR-RTR6-0074, and Container No. NFS0487 from BDR 

OR-RTR6-0089. 
28 

Summary of RTR Findings and Concerns

EPA did not identify any findings associated with the processes used or recording of data for 

RTR examinations performed on containers from ORNL Waste Stream OR-NFS-CH-SOIL. 

EPA did identify one concern that required a response, No. ORNL-CCP-CH-RTR-09-001CR, 

that is discussed above and is included at Attachment A to this report. ORNL-CCP provided a 

written response to this concern, which EPA evaluated and found it adequately addressed the 

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

to RTR for this T1 evaluation. 

Tiering Changes

Based on the results of this T1 evaluation, there are no changes to the T1 and T2 designations 

assigned to RTR during the ORNL-CCP baseline approval. 

7.0 SUMMARY OF RESULTS AND CONCLUSIONS 

Conclusion

EPA concluded that the WC processes of AK, NDA, and RTR used to characterize retrievablystored CH TRU Soil Waste Stream OR-NFS-CH-SOIL from the S4000 SCG soils/gravel. There 

were three concerns, two of which required a response, and ORNL-CCP adequately addressed 

both concerns. There are no open issues relative to this T1 evaluation. 

Approval

The T1 change that was evaluated consisted of the WC techniques of AK, NDA, and RTR as 

evidenced by the records ORNL-CCP generated in characterizing the CH TRU Waste Stream 

OR-NFS-CH-SOIL in the S4000 soils/gravel SCG. Based on the results of this evaluation, EPA 

approves this T1 change. ORNL-CCP is approved to characterize CH TRU Soil Waste Stream 

OR-NFS-CH-SOIL consistent with the limitations specified in this report. 

Tiering Changes

Based on the results of this T1 evaluation, EPA has revised the T1 and T2 designations assigned 

to AK during the ORNL-CCP baseline approval, as reflected in Table 1 of this report. There is 

one new AK T1 change and slight modifications to the AK T2 elements. All of the T2 elements 

listed under AK in Table 1 apply to all approved CH TRU waste streams and SCGs at ORNLCCP. Consistent with EPA’s authority under 40 CFR 194.24(h), EPA may request this 

information if EPA deems it necessary to ensure continued compliance with EPA regulations. 

There are no changes to the T1 and T2 designations assigned to NDA or RTR during the ORNLCCP baseline approval as a result of this T1 evaluation.
A-1 

ATTACHMENT A: EPA TIER 1 ISSUE TRACKING FORM, 

ISSUE NO. ORNL-CCP-CH-RTR-09-001CR, FINAL 

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

Date: August 12, 2009 

Inspector: Dorothy Gill 

Attachments? YES NO 

Sample Size: 1 Test Drum, 3 Operators 

Population size (if known): 1 Test Drum, 3 Operators 

Description of Issue: Review of recordings of Demonstrations of Capability examinations performed on Test Drum No. ORNLNDE-TEST-007 performed on June 19, 2008, showed that operators missed some of the non-WAP required items that were in the 

drum. The SME, who checked the Demonstration of Capability recordings, did not identify these errors. This is a repeat concern; 

the original one was written during ORNL baseline inspection EPA-ORNL-CCP-CH-11.07-8, provided in “Additional Comments” 

below. 

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

Written Record 

Operator SB 

Written Record 

Operator LS 

Written and A/V Record 

Soil OK OK OK 

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

Cardboard OK OK OK 

Horsetail bag of Raschig rings Missed in horsetail bag Missed in horsetail bag Missed in horsetail bag

Horsetail bag with rubber hose and 

paint brush 

Found hose and paint brush, 

but missed them in a 

horsetail bag 

Found brush and “tygon” 

tubing. Missed that these 

were in horsetail bag 

Missed hose and in horsetail bag 

Orally identified a paint brush, but did 

not record on data sheet 

Plastic labware Missed (glass labware 

identified) 

Missed (glass labware 

identified) 

Missed (glass labware identified) 

Rubber hose OK “tygon tubing” OK 

Horsetail bag with paper Found horsetail bag, but 

missed paper in bag 

Found horsetail bag, but 

missed paper in bag 

Found horsetail bag, but missed paper 

in bag 

Electrical cord OK OK OK 

B. Regulatory Reference: 40 CFR 194.24(b) 

C. Site requirement(s): Not applicable 

D. Discussed with: Mark Pearcy 

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

ORNL-CCP-CH-RTR-004C: In the capability demonstration training containers, the EPA inspector noted that while all the 

required items (prohibited items) were identified correctly by all RTR operators, some additional items (cellulosics and plastics) 

were not identified. All cellulosics and plastics in the training drum need to be identified and their identification documented. To 

complete the training process, it is critical that the operator receives feedback regarding missed items. More detailed 

documentation of the feedback given is needed when the results of the training drum are reviewed. 

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

F. Site Response Information:

 Site Response Required? YES NO 

 Site Response Due Date: August 27, 2009 
B-1 

ATTACHMENT B: EPA TIER 1 ISSUE TRACKING FORM,

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

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

Date: August 12, 2009 

Inspector: P. Kelly 

Attachments? YES NO 

Sample Size: Six ORNL DWAS BDRs 

Population size (if known): All ORNL NDA BDRs 

Description of Issue: Common practice for ORNL NDA control charts is to record only successful performance checks and to 

omit any measurement failures, i.e., values outside of the 3 Sigma Control Limits. Each such failure requires resolution, i.e., 

calibration verification and a subsequent successful performance check, which overrides the failure, resulting in only the 

successful performance check value being entered on the control chart. This only occurs at ORNL-CCP. 

B. Regulatory Reference: 40 CFR 194.24(c)

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

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

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

evaluation. It does affect the record that documents performance of the DWAS and, accordingly, acceptance of the DWAS 

BDRs for NFS soils is not contingent upon resolution of this issue.

F. Site Response Information:

 Site Response Required? NO YES 

 Site Response Due Date: August 27, 2009 
C-1 

ATTACHMENT C: EPA INSPECTION ISSUE TRACKING FORM, 

ISSUE NO. ORNL-CCP-CH-NDA-09-003C, FINAL 

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

Date: August 12, 2009 

Inspector: P. Kelly 

Attachments? YES NO 

Sample Size: 2 DWAS BDRs 

Population size (if known): 42 Soil NDA BDRs 

Description of Issue: ORNL BDR No. OR-DWAS-0203 contains a control chart for 240PuEFF for the time period of February 1, 

2009 to March 3, 2009. The control chart shows three points that exceed the 3 Sigma Control Limits on February 2, 11 and 19; 

however, all points were in control. This apparent discrepancy occurs because the 2 and 3 Sigma Warning and Control Limits 

change every week as a result of decay-correcting the 252Cf source which has a half-life of 2.6 years. A value that is in control at 

the time it was performed may be outside of warning or control limits that were generated at a later time due to changes in the 

limits as a function of decay-correcting the 252Cf source. When the older value is shown on a control chart with the newer limits 

it appears to be out of control when it was not. This is not a technical issue in that all performance checks that we observed were 

in control at the time they were performed. 

B. Regulatory Reference: 40 CFR 194.24(c)

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

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

E. Additional Comments: None 

F. Site Response Information: 

 Site Response Required? NO YES 

 Site Response Due Date: Not Applicable