# EPA DOCKET NO. A-98-49, II-A4-189

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT

EPA TIER 1 EVALUATION

OF THE CENTRAL CHARACTERIZATION PROGRAM

CONTACT-HANDLED WASTE CHARACTERIZATION PROGRAM

AT THE OAK RIDGE NATIONAL LABORATORY:

ADDITION OF SUMMARY CATEGORY GROUP S3000 (SOLIDS)

February 4–6, 2014

U.S. Environmental Protection Agency

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

July 2014

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# TABLE OF CONTENTS

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

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

2.0 Purpose of Tier 1 Evaluations .....................

................................................... ..................... 3

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

................................................... ........................ 3

4.0 Scope of This Tier 1 Evaluation ...................

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

5.0 Inspection Personnel ..............................

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

6.0 Technical Evaluation ..............................

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

6.1 Acceptable Knowledge ..............................

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

6.2 Real-Time Radiography .............................

................................................... .......... 7

7.0 Findings and Concerns .............................

................................................... ........................ 8

8.0 Conclusions .......................................

................................................... ............................... 9

LIST OF TABLES

Table 1. Tiering of Contact-Handled Transuranic Wa ste Characterization Processes Implemented by ORNL-CCP ...........................

................................................... ............................ 2

Table 2. Tier 1 Evaluation Participants ...........

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

ATTACHMENTS

Attachment A Approval Summary for ORNL-CCP Contact- Handled Waste Characterization

Program

Attachment B List of Documents Reviewed for This In spection

Attachment C February 2014 Continued Compliance Ins pection Personnel

Attachment D AK Tier 1 Evaluation Checklist: Waste Stream OR-NFS-CH-HOM-A

Attachment E RTR Tier 1 Evaluation Checklist

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# ACRONYMS AND ABBREVIATIONS

AK acceptable knowledge

AKSR acceptable knowledge summary report

Att. Attachment

BDR batch data report

CBFO Carlsbad Field Office

CCP Central Characterization Program

CFR Code of Federal Regulations

CH contact-handled

CIS characterization information summary

CTAC CBFO Technical Assistance Contractor

DOE U.S. Department of Energy

DR discrepancy resolution

DTC dose-to-curie

EA Expert Analyst

EPA U.S. Environmental Protection Agency

FGA flame gas analysis

HLW high-level waste

HWN hazardous waste number

IPAN Integrated Passive Active Neutron

ITR Independent Technical Reviewer

LLW low-level waste

LO Lead Operator

LOQI list of qualified individuals

MCS Mobile Characterization Services

NCR nonconformance report

NDA nondestructive assay

NDE nondestructive examination

NFS Nuclear Fuel Services

NWP Nuclear Waste Partnership, LLC

OJT on-the-job training

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# ORNL Oak Ridge National Laboratory

ORIA Office of Radiation and Indoor Air

Pu plutonium

QA quality assurance

QC quality control

RH remote handled

RTR real-time radiography

SCG summary category group

SD source document

SGS segmented gamma scanner

SME Subject-Matter Expert

SNF spent nuclear fuel

SPM Site Project Manager

STR site technical representative

T1 Tier 1

T2 Tier 2

TRU transuranic

TWPC Transuranic Waste Processing Center

U uranium

VE visual examination

VEE visual examination expert

VJT Vee Jay Technologies

VPN vendor project manager

WAI Wastren Advantage Incorporated

WDS Waste Data System

WIPP Waste Isolation Pilot Plant

WMC waste matrix code

WMP waste material parameter

WSPF waste stream profile form

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# 1.0 EXECUTIVE SUMMARY

This report supports the U.S. Environmental Protect ion Agency’s (EPA’s) approval of a Tier 1 (T1) change to add summary category group (SCG) S30 00 (homogeneous solid) waste to the EPA-approved contact-handled (CH) transuranic (TRU) waste characterization program at the U.S. Department of Energy (DOE) Oak Ridge National Laboratory (ORNL).

In accordance with Title 40 of the Code of Federal Regulations (40 CFR) 194.8(b), EPA conducted a baseline inspection of the Central Char acterization Program (CCP) 1 

# waste characterization program for CH TRU wastes at ORNL in Oak Ridge, Tennessee, in 2007–2008. As a result, EPA approved the ORNL-CCP CH TRU waste characterization program (see EPA Docket No. A-98-49, II-A4-103). From July 2011–Sept ember 2013, DOE suspended waste

characterization activities at ORNL. EPA conducted a continued compliance inspection of ORNL-CCP’s CH and RH TRU waste characterization pro gram in February 2014 and approved

ORNL-CCP to resume CH TRU waste characterization ac tivities in April 2014 2 

# . EPA’s reviews and approvals of ORNL-CCP’s CH waste characterizati on program are listed in Attachment A.

On January 7, 2014, the Carlsbad Field Office (CBFO ) requested EPA approval of a T1 change to include SCG S3000 waste in ORNL’s EPA-approved C H waste characterization program.

EPA conducted this T1 evaluation while onsite at OR NL for the aforementioned continued compliance inspection at ORNL on February 4–6, 2014 . During the continued compliance inspection, EPA verified that the ORNL-CCP nondestr uctive assay (NDA) equipment calibration is sufficiently broad to include homogenous solid w aste. Therefore, EPA limited the scope of the T1 evaluation to acceptable knowledge (AK) and real -time radiography (RTR).

Based on the results of this T1 evaluation, EPA app roves ORNL-CCP to add SCG S3000 CH TRU waste to the waste characterization program. EP A made one change to the CH AK T1 designations to reflect that addition of SCG S3000 waste is no longer a T1 change. This change is reflected in EPA’s tiering table, Table 1, below

.

EPA did not identify any findings or concerns durin g this T1 evaluation.

This report serves as EPA’s public notification of the results of the continued compliance inspection. This information will be provided throu gh the EPA website and by sending emails to the WIPPNEWS list, in accordance with 40 CFR 194.8( b)(3).

1 

# The Central Characterization Program was formerly known as the Central Characterization Project, and

both names are used in the documentation reviewed f or this evaluation.

2 

# DOE’s suspension of characterization activities at ORNL, the resumption process performed by CCP at ORNL, and EPA’s inspection and continued approval o f the resumed waste characterization activities are discussed in EPA Docket No. A-98-49, II-A4-186.2Table 1. Tiering of Contact-Handled Transuranic Waste Characterization Processes Implemented by ORNL-CCP(Based on November 13–15, 2007, Baseline Inspectionand Subsequent Tier 1 Evaluations, Updated June 2014)Process ElementsORNL-CCP CH Waste Characterization Process – T1 ChangesORNL-CCP CH Waste Characterization Process – T2 Changes*Acceptable Knowledge,including LoadManagementAny new waste category other than retrievably stored debris,soils/gravel and solids (i.e., any type of newly generated waste)Load managementSubmission of a list of active ORNL-CCP CH AKEs andSPMsNotification to EPA upon completion of or substantive modification** to:•AK accuracy reports (annually, at a minimum)•AK-AK and AK-NDA/NDE Discrepancy Resolution Reports•WSPFs and related attachments (e.g., CIS) for all new or modified wastestreams, including change notices•AKSRs (new and updated versions)•CCP-TP-005, Attachments 4, 6, 7 and 8 and/or associated memoranda,including “Add Container” memoranda•Site AK procedures requiring CBFO approvalNondestructive Assay New equipment or substantive physical modifications** to approvedequipmentExtension of or changes to approved calibration range for approvedequipmentSubmission of a list of ORNL-CCP NDA operators, EAsand ITRs thatperformed work during the previous quarterNotification to EPA upon substantive modification**to:•Software for approved equipment•Operating ranges upon CBFO approval•Site NDA procedures requiring CBFO approvalReal-Time Radiography NoneSubmission of a list of ORNL-CCP RTR operators andITRs that performedwork during the previous quarterNotification to EPA upon:•New equipment or substantive physical modifications** to approvedequipment•Substantive modification** to site RTR procedures requiring CBFOapprovalVisual Examination andVisual ExaminationTechniqueAny use of visual examination Submission of a listof ORNL-CCP VE operators, VE Experts and ITRs thatperformed work during the previous quarterWIPP Waste Data System Load managementNotification to EPA upon substantive modification**to site WDSprocedures requiring CBFO approvalNew T1s, T2s and significant modifications to existing T1s or T2s are inboldtext; T1s or T2s that were only revised for styleare not shown in bold.* ORNL-CCP will report all T2 changes to EPA everythree months.** “Substantive modification” refers to a change with the potential to affect ORNL-CCP’s CH waste characterization processes or documentation of them, excluding changesthat are solely related to the environment, safetyand health; nuclear safety; or the Resource Conservation and Recovery Act, or that are editorial in nature or are required toaddress administrative concerns. EPA may request copies of new references that DOE adds during a document revision.

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# 2.0 PURPOSE OF TIER 1 EVALUATIONS

Certain changes to the waste characterization activ ities from the date of the site’s baseline inspection must be reported to and, if applicable, approved by EPA according to the tiering requirements set forth in 40 CFR 194.8 regulations and incorporated into the ORNL-CCP CH baseline final report (see EPA Docket No. A-98-49; II-A4-103).

Under the changes to 40 CFR 194.8 promulgated in th e July 16, 2004, Federal Register notice (Vol. 69, No. 136, pages 42571–42583), EPA must per form a single baseline inspection of a TRU waste generator site’s waste characterization p rogram. The purpose of EPA’s baseline inspection is to approve the site’s waste character ization program, based on the demonstration that the program’s components, with applicable cond itions and limitations, can adequately characterize TRU wastes and comply with the regulat ory requirements imposed on TRU wastes destined for disposal at the Waste Isolation Pilot Plant (WIPP).

Following EPA’s baseline approval, EPA is authorize d to evaluate and approve changes, if necessary, to the site’s approved waste characteriz ation program by conducting additional inspections under the authority of 40 CFR 194.24(h) . In addition, 40 CFR 194(h) allows EPA to conduct continued compliance inspections at sites w ith approved TRU waste characterization programs. EPA performs annual continued compliance inspections of each TRU waste characterization program, covering all elements of the programs, including the common elements of waste characterization processes that are not ex pected to significantly vary on a waste stream or T1 basis. Examples of the common characterizatio n elements are personnel training, procedures and equipment capabilities. EPA will con sider the results of continued compliance inspections when setting the scope and evaluating s ite-specific T1 changes.

Changes requiring EPA notification and approval pri or to implementation (T1) and those requiring post-implementation notification [Tier 2 (T2)] are identified in the site-specific baseline inspection reports and subsequent continue d compliance inspection and T1 evaluation reports. When evaluating proposed T1 changes for ap proval, EPA may conduct a site inspection to observe implementation of the change or can opt to conduct a desktop review of information provided specific to a change. DOE may choose to ch aracterize and dispose of any previously approved TRU waste using processes, procedures or e quipment implemented as T2 changes at risk of subsequent EPA disapproval.

3.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluatio n of a T1 change to add SCG S3000 (homogenous solid) waste to the EPA-approved CH TRU waste characterization program. EPA’s approval decision regarding the addition of SCG S30 00 has been conveyed to DOE separately by

letter. EPA will also announce the decision on its website at www.epa.gov/radiation/wipp, in accordance with 40 CFR 194.8(b)(3).

The DOE documents that EPA reviewed for this evalua tion are cited throughout the report and are listed in Attachment B. Any of these documents can be requested from the following address:

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# Carlsbad Field Office Manager, National TRU Program

P.O. Box 3090 Carlsbad, NM 88221-3090

4.0 SCOPE OF THIS TIER 1 EVALUATION

The scope of this T1 evaluation is the addition of SCG S3000 homogenous solids to ORNLCCP’s EPA-approved CH waste characterization progra m. ORNL-CCP provided documentation

related to Waste Stream OR-NFS-CH-HOM-A to demonstr ate ORNL-CCP’s S3000 waste characterization capabilities. Consistent with the streamlined approach to EPA’s evaluation and decision process described in section 2.0, EPA limi ted the scope of this T1 evaluation to the components of AK specific to the addition of SCG S3 000 CH waste. Sections 6.1 and 6.2 of this report detail the technical elements assessed durin g this evaluation.

5.0 INSPECTION PERSONNEL

EPA and its support personnel conducted interviews with ORNL-CCP waste characterization personnel in AK and RTR. The EPA inspection team an d ORNL-CCP personnel contacted are listed in Table 2. Because the T1 evaluation took p lace during the February 2014 continued compliance inspection, additional DOE, EPA and ORNL -CCP personnel were also present. All personnel present during the continued compliance i nspection are listed in Attachment C, with their affiliations and areas of expertise or functi on.

Table 2. Tier 1 Evaluation Participants

6.0 TECHNICAL EVALUATION

Sections 6.1 and 6.2 of this report detail the tech nical areas assessed during this inspection: AK and RTR. EPA completed inspection checklists for AKand RTR based on responses of ORNLCCP waste characterization personnel to EPA queries and other documentation (see Attachments D and E). When evaluating future T1 change requests and concurring with quarterly T2 change submissions, EPA may use these checklists to supple ment its review.

6.1 Acceptable Knowledge

EPA examined the programmatic requirements and AK p rocess and associated information during the continued compliance inspection in Febru ary 2014. Therefore, EPA limited the scope

Name Affiliation & Function
Rajani Joglekar Lead Inspector, U.S. EPA Ed Feltcorn Inspector, U.S. EPA Kira Darlow Technical Evaluator – Acceptable Knowl edge, SC&A, Inc. Dorothy Gill Technical Evaluator – Nondestructive E xamination, SC&A, Inc. Jeff Harrison AK Expert Beverly Schrock ORNL-CCP CH SPM Fred Oney ORNL-CCP RTR Operator Steve Redmond ORNL-CCP RTR Operator

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# of this AK evaluation to those elements necessary t o assess the technical adequacy of the information supporting the addition of SCG S3000 (h omogenous solid) waste.

Waste Characterization Element Description

EPA limited this T1 evaluation to the technical ele ments listed below.

• Waste stream definition.

• AK procedural implementation.

• AKSR completion.

• Drum traceability from generation through character ization.

• NDA-AK communication.

• Verification that the subject waste is of defense o rigin and is not high-level waste (HLW) or spent nuclear fuel (SNF).

Technical Evaluation

The results of EPA’s technical evaluation are summa rized below. EPA’s evaluation checklist is included as Attachment D to this report. ORNL-CCP p rovided CCP-AK-ORNL-001, Revision 8, to EPA prior to the start of the T1 evaluation and then revised the AK Summary Report (AKSR; CCP-AK-ORNL-001, Revision 9) as a result of the Feb ruary 2014 continued compliance inspection. EPA considers Revision 9 of the AKSR to be the officially-submitted document for

the T1 evaluation and all references to the AKSR in this technical evaluation refer to CCP-AKORNL-001, Revision 9.

(1) EPA evaluated ORNL-CCP’s application of a waste str eam definition for Waste Stream OR-NFS-CH-HOM-A and found it to be adequate.

A CH waste stream is defined as waste being similar in material and physical form that was generated from a single process or activity. ORNL-C CP adequately defined Waste Stream ORNFS-CH-HOM-A, which contains homogenous solids that were created during decommissioning of Buildings 234 and 110 at Nuclear Fuel Services ( NFS) in Erwin, Tennessee.

(2) EPA evaluated ORNL-CCP’s acceptable knowledge proce dural implementation and found it to be adequate.

EPA evaluated ORNL-CCP’s implementation of procedur e CCP-TP-005 by examining each of the completed form attachments to that procedure. O RNL-CCP adequately completed all applicable attachments and utilized forms from the correct revision of the procedure in every example EPA reviewed.

Notification to EPA upon substantive modification t o CCP-TP-005, Attachments 4, 6, 7 and 8 and/or associated memoranda, including “Add Contain er” memoranda remains a T2 change (see Table 1)

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# (3) EPA assessed the acceptable knowledge summary repor t for completeness, including adequate descriptions of the radiological and physi cal characteristeics of the waste, and found it to be adequate.

The AKSR contains all required elements and suffici ent detail describing AK-based information about the radiological and physical characteristics of Waste Stream OR-NFS-CH-HOM-A. ORNL-CCP gathered and cited sufficient AK source do cuments to support all information

contained in the AKSR.

Notification to EPA upon substantive modification t o AKSRs remains a T2 change (see Table 1).

(4) EPA assessed drum traceability and the ability to f ollow the acceptable knowledge process for containers and found it to be adequate.

On February 5, 2014, EPA randomly selected three co ntainers to assess drum traceability: NFS0479A1, NFS0481, NFS0865A. All three containers are included in the Attachment 8-Waste

Containers List and are traceable from NFS to recei pt at ORNL. ORNL repackaged drum Nos. NFS0479A1 and NFS0865A, and both drums are traceabl e through the repackaging process. Drum No. NFS0481 had not yet been characterized by ORNL-CCP. EPA traced drum No. NFS0479A1 through ORNL-CCP RTR characterization; th e container had not yet been through NDA. EPA traced drum No. NFS0865A through the ORNL- CCP RTR and NDA processes to

inclusion in the draft Characterization Information Summary (CIS) for Lot 1. EPA determined

that the containers within Waste Stream OR-NFS-CH-H OM-A are adequately traceable.

(5) EPA examined the defense origin of transuranic wast es and found it to be adequate.

NFS manufactured custom nuclear fuels for various c lients in Buildings 234 and 110, and greater than 90% of the fuel produced in these buildings wa s for defense-related projects or clients (References C099, C100 and M021). EPA finds this de termination to be adequate.

(6) EPA evaluated documentation regarding the status of spent nuclear fuel and high-level waste, and found this waste stream to be in complia nce with the Waste Isolation Pilot

Plant Land Withdrawal Act.

NFS manufactured nuclear fuel from scrap plutonium (Pu) or Pu that had been reprocessed elsewhere. NFS did not work with any SNF and did no t have any reprocessing capabilities on site. Therefore, none of the waste in Waste Stream OR-NFS-CH-HOM-A could be either SNF or HLW (References C099, C145, P273 and U038). EPA fin ds this determination to be adequate.

(7) EPA assessed nondestructive assay–acceptable knowle dge communication and found it to be adequate.

ORNL-CCP included the NDA-AK discussion for Waste S tream OR-NFS-CH-HOM-A in the

same NDA-AK memorandum and Attachment 7-Radionuclid es as the other NFS-origin waste streams described in the AKSR. This is acceptable s ince all of the NFS-origin waste streams were generated during decommissioning of Buildings 234 and 110 at NFS, and therefore the wastes would have similar radiological characterist ics. ORNL-CCP included individual expected-radionuclide tables for each waste stream, but only one set of default isotopics. EPA

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# has previously evaluated the NDA-AK memorandum for the NFS-origin waste streams (most recently during the February 2014 continued complia nce inspection; see EPA Docket No. A-98- 49; II-A4-186), and finds the modifications for inc lusion of Waste Stream OR-NFS-CH-HOM-A to be adequate.

Summary of Acceptable Knowledge Findings and Concer ns

EPA did not identify any findings or concerns durin g this T1 evaluation and there are no open

issues relative to this T1 evaluation.

Changes to Tiering

Based on the results of this T1 evaluation, EPA rev ised the CH AK T1 designations to reflect that addition of SCG S3000 waste is no longer a T1 change. For consistency, all of the T2 elements listed under AK in Table 1 apply to all ap proved ORNL-CCP CH TRU waste streams.

Acceptable Knowledge Approval

Based on this evaluation, EPA approves this T1 chan ge. ORNL-CCP is approved to characterize SCG S3000 CH TRU waste, consistent with the limitat ions specified in this report.

6.2 Real-Time Radiography

(1) EPA examined real-time radiography procedures and f ound them to be adequate.

The procedures used to generate the data reported i n the batch data reports (BDRs) discussed throughout section 6.2 are well established and hav e been reviewed by EPA inspectors at previous onsite inspections. The procedures continu e to comply with 40 CFR 194.

Notification to EPA upon substantive modification t o site NDE procedures requiring CBFO approval remains a T2 change (see Table 1).

(2) EPA examined real-time radiography characterization records and found them to be adequate.

EPA reviewed the audio/visual and written records for selected containers from BDR Nos. ORRTR6-0437, OR-RTR6-0438, OR-RTR6-0439 and OR-RTR6-0 440 and determined that the records were complete and generated in accordance w ith ORNL-CCP procedures. RTR operators had properly examined each container’s contents and entered characterization data into an electronic data sheet. RTR operators determined tha t the waste matched the waste stream description and verified the waste matrix code (WMC ). ORNL-CCP generated on conformance report (NCR) NCR-ORNL-0873-13 to address one RTR op erator’s misidentification of the WMC and waste stream description. This error was id entified at the Independent Technical Reviewer (ITR) level and the applicable BDRs were c orrected as necessary in accordance with ORNL-CCP procedures and processes. No other prohibi ted items were identified in the

containers from the reviewed BDRs.

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# RTR operators performed an image quality check prio r to each RTR event for the BDRs examined. ORNL-CCP personnel had performed the requ ired quality control examinations, i.e., an independent observation and replicate scan, for the BDRs reviewed.

ORNL-CCP reviewed the data at the data-generation a nd SPM level; the reviews were recorded on the appropriate forms from the applicable ORNL-C CP procedures.

(3) EPA examined real-time radiography training records and found them to be adequate.

EPA reviewed the following written and audio/visual training records for selected RTR operator/ITR personnel:

• Inventory sheets for RTR containers NDE-TEST-11, ND E-TEST-20, NDE-TEST-22, NDE-TRAINING-19, NDE-TRAINING-26, NDE-TRAINING-30, NDE-TRAINING-32.

• Training Container Evaluation Data Sheets for selec ted operators.

• Audio/visual recordings of test examinations for se lected personnel.

• Qualification Cards for selected personnel.

• List of qualified individuals.

The above records demonstrated that RTR personnel w ere trained in accordance with ORNLCCP procedures and that training records were compl ete.

Submission to EPA of a list of all RTR personnel wh o performed work during the previous quarter remains an RTR T2 change (see Table 1). Spe cifically, the list must include all RTR operators and ITRs.

Summary of Real-Time Radiography Findings and Conce rns

EPA did not identify any findings or concerns relat ed to RTR as a result of this T1 evaluation.

Real-Time Radiography Approval

Based on this evaluation, EPA approves this T1 chan ge. ORNL-CCP is approved to characterize SCG S3000 CH TRU waste using RTR, consistent with t he limitations specified in this report.

Based on the results of this T1 evaluation, there a re no revisions to the RTR T1 or T2 designations.

7.0 FINDINGS AND CONCERNS

EPA did not identify any findings or concerns durin g this T1 evaluation.

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# 8.0 CONCLUSIONS

Changes to Tiering

Based on this T1 evaluation, there is one change to the CH AK T1 designations to reflect that addition of SCG S3000 waste is no longer a T1 chang e. This change is reflected in EPA’s tiering table, Table 1, above.

Table 1 shows the substantive T1 change in bold tex t. T1 and T2 changes that were initiated during the CH baseline and subsequent T1 approvals remain in effect. The language in Table 1 regarding AK documentation applies to all ORNL-CCP waste streams.

Approval

EPA concluded that the waste characterization proce sses of AK and RTR used to characterize CH TRU SCG S3000 (homogenous solids) are adequate, as evidenced by the records evaluated. There are no open issues relative to this T1 evalua tion

Based on the results of this evaluation, EPA approv es this T1 change to add SCG S3000 waste to the ORNL-CCP EPA-approved CH TRU waste characteriza tion program, consistent with the limitations specified in this report. ORNL-CCP may continue to characterize previously approved CH TRU waste consistent with the restricti ons specified with the approvals listed in Appendix A to this report.

# A-1



# ATTACHMENT A: APPROVAL SUMMARY FOR ORNL-CCP CONTACT -HANDLED

WASTE CHARACTERIZATION PROGRAM

Approved Activity EPA Inspection Number, Approval Dates EPA 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 – Extension of the Calibration and Densit y Ranges for the SGS NDA System October 8, 2008 A-98-49; II-A4-108

T1 Change – Extension of the Passive Mode Calibration Range for the DWAS/IPANSGS January 8, 2009 A-98-49, II-A4-109

T1 Change – Addition of SCG S4000 October 7, 2009 A -98-49, II-A4-117

Unannounced Continued Compliance Inspection Novembe r 23, 2009 A-98-49, II-A4-121

T1 Change – Addition of the MCS IQ3 NDA System

and Visual Examination March 30, 2010 A-98-49, II-A4-125

T1 Change – Addition of NFS Trench B Soils to Waste

Stream OR-NFS-CH-SOIL March 23, 2011 A-98-49; II-A4-144

Continued Compliance Inspection and T1 Change for Modifications to the IQ3 NDA System June 18, 2014 A-98-49; II-A4-186

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# ATTACHMENT B: LIST OF DOCUMENTS REVIEWED FOR THIS E VALUATION

American Society for Nondestructive Testing, Recomm ended Practices, No. SNT-TC-1A, June

1980 Edition

Audio/visual recordings for selected containers fro m BDR Nos. OR-RTR6-0437, OR-RTR6- 0438, OR-RTR6-0439 and OR-RTR6-0440

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

C100, Interview with Richard Booth and faxed defens e and Waste Information for NFS, February 24, 2005

C145, Memo to Distribution re: Nuclear Fuel Service s, In. (NFS) Background Information, D.W. Turner, February 7, 1992

C203, Letter to Martin Tull from Robert A. Hunt Reg arding a Picture of the Proposed Method to "Lab Pack" Bottles of Immobilized Respirable Fines and Residual Materials, Robert A. Hunt, Ecotek, Inc., March 23, 1993

C206, Numerous Faxes Containing Handwritten Notes ( Oversight Reports) from Paul O. Emerson re: Such Items as Sampling the Top of the U nderground Tank, Pu Crew activities, Equipment Issues, Processing of Gloveboxes and Info rmation on Drums that were Packaged, Paul O. Emerson, January 9, 1991 through August 28, 1992

C209, Internal Correspondence to F.J. Shultz from J .A. Chapman regarding NFS Project Accomplishments for Month of April 1992, J.A. Chapm an, May 4, 1992

C210, Interview re: NFS TRU Waste Shipped to Oak Ri dge National Laboratory. Interviewees: Richard Booth, Richard Moore, Bob Hunt, Scott Tolle r, Marie Moore, J. Harrison and L. Watson, September 12, 2007

CCP-AK-ORNL-001 NDA Memorandum, Jeff Harrison, Nove mber 15, 2010

CCP-AK-ORNL-001, Central Characterization Program A cceptable Knowledge Summary Report for Nuclear Fuel Services Contact-Handled Tr ansuranic Waste Stored at Oak Ridge National Laboratory, Revision 8, December 12, 2013, and Revision 9, February 6, 2014

CCP-QP-005, Revision 23, CCP TRU Nonconforming Item Reporting and Control, Attachment 1 – CCP Nonconformance Report (NCR), NCR-ORNL-0873- 13, Revision 0, origin date December 11, 2013, interim hold date December 12, 2 013

CCP-TP-005, Revision 20, CCP Acceptable Knowledge D ocumentation, Attachment 7 – Radionuclides, OR-NFS-CH-HOM-A, Jeff Harrison, Nove mber 16, 2010

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 1 – Acceptable Knowledge Documentation Checklist, OR-NF S-CH-HOM-A, Jeff Harrison, January
7, 2014

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# CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 4 – Acceptable Knowledge Source Document Information Li st, OR-NFS-CH-HOM-A, Travis Smith, January 6, 2014

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 6 – Waste Form, Waste Material Parameters, Prohibited Items, and Packaging, OR-NFS-CH-HOM-A, Jeff Harrison, December 5, 2013

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste Containers List, OR-NFS-CH-HOM-A, Jeff Harrison, De cember 5, 2013

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP Waste Stream Characterization Checklist – Example F orm, Lot 1, OR-NFS-CH-HOM-A, unsigned draft dated January 8, 2014, provided Febr uary 5, 2014

DR030, Discrepancy Resolution re: Drum NFS0929, J. Harrison, January 10, 2011

DR031, Discrepancy Resolution re: OR-NFS-CH-HOM-A E PA Hazardous Waste Number Assignment, Jeff Harrison, January 10, 2011

Inventory sheets for RTR container Nos. NDE-TEST-11 , NDE-TEST-20, NDE-TEST-22, NDETRAINING-19, NDE-TRAINING-26, NDE-TRAINING-30 and N DE-TRAINING-32

LOQI for RTR operators dated 1/21/14

M003, ORNL UCN-2109 and UCN-2822 Forms for NFS TRU Waste and Related Paperwork for Waste Stored at ORNL, August 26, 1993

M007, Internal Correspondence and the Environmental Assessment for the Receipt and Storage at ORNL of Transuranic Waste, Mixed Transuranic Was te, and Mixed Oxide Waste from

Nuclear Fuels and the Environmental Assessment for Disposition of Transuranic Waste, L.T. Cusick, LTR# ER-NEP A/92-015, November 9, 1992

M012, EM Query- Container Information; Waste Descri ption; Isotopes, ORNL, August 9, 2007

M021, Defense Determination Approval for ORNL/NFS-H D-001, Heterogeneous Debris- NFS, Betty Humphrey, ORNL-HD-001-IF, May 13, 2005

M075, TWPC Contact Handled Waste Repackaging Data F orms for NFS Waste (Container Paperwork), ORNL, various dates

M198, eMWaste Query from ORNL Dated August 30, 2010 , ORNL, DR-10-004417, August 30,

2010

M202, Review of WEAF RTR Videos for NFS Immobilized Liquids and Fines, Rick Schultz, October 11, 2010 through October 13, 2010

NDA BDR No. OR-IQ3-0224, December 27, 2013

P1116, EnergX TRU Waste Processing Center Procedure : Absorbing Liquids, EnergX, CH-IOP-013, Revision 4, June 27, 2008, and Revision 6, November 17, 2008

# B-3



# P1371, Procedure for Removal and Decontamination of Utility and Process Lines and Systems, NFS, DCM-11, Revision 2, October 15, 1992

P212, Lattice Experiments with Simulated Burned Up Fuel for D20 Power Reactors, N.P. Baumann et al., February 1968

P218, Oak Ridge National Laboratory/ Nuclear Fuel S ervice, Inc. NFS Waste Parameter Verification Program, Martin Marietta Energy System s, October 29, 1992

P251, Box Breakdown Area Operations, CH-UET-OP-003 and CH-P-OP-003, Revisions 4, 7, 9, 12, 15, 18 and 20, March 13, 2007, through July 16, 2013

P252, Glove Box Operations, CH-UET-OP-004 and CH-P- OP-004, Revisions 5, 8, 10, 14, 17, 18 and 20, March 13, 2007, through June 20, 2013

P253, Drum Bag In/Bag Out and Glove Ports, CH-REF-O P-001 and CH-P-OP-011, Revisions 1- 1, 10, 12, 13, 14, 16 and 18, May 2, 2007, through February 11, 2013

P254, Contact Handled Waste Repackaging, CH-REF-OP- 013 and CH-P-OP-013, Revisions 0, 1, 2, 3, 4, 5,6, 7, 8, 9, 12, 13 and 14, April 30, 2007, through August 27, 2013

P273, NFS, Inc. Waste Certification Plan for Transu ranic Waste, no date

P274, Segregation and Immobilization of Particulate Fines, NFS Decommissioning Department, DCM-58, Revisions 0 and 1, July 1991, November 1992 and February 1992

P319, Preparation of Gloveboxes for Decontamination in the DVRF, DCM-05, Revision 2, August 16, 1991

P321, Determination of Plutonium lsotopics for Buil ding 110 and 234, John T. Caldwell, April
28, 1992

Prohibited Item Training Module, Revision 7, August 23, 2010, and Revision 8, March 29, 2011

Qualification Cards for selected RTR personnel

RTR BDR No. OR-RTR6-0437, December 10, 2013

RTR BDR No. OR-RTR6-0438, December 12, 2013

RTR BDR No. OR-RTR6-0439, December 17, 2013

RTR BDR No. OR-RTR6-0440, December 17, 2013

Training Container Evaluation Data Sheets for vario us RTR operators

Training roster for CCP-AK-ORNL-001, Revisions 7 an d 8

U016, A Graphical Workbook for Estimating Important Quantities of NFS Radioactive Waste Constituents, J.A. Chapman, March 1992

# B-4



# U017, The lntercomparison of NDA Measurements on CH -TRU Waste Between Nuclear Fuel Services, Inc. and Oak Ridge National Laboratory, J .A. Chapman, et a., October 24, 1995

U038, ORNL TRU Waste Historical Survey; Volumes 1,2 and 3- Origins and Characteristics of Remote-Handled Transuranic Wastes (Trabalka report) Plus Appendices, J.R. Trabalka, A.J. Mattus and S.N. Storch, BJC/OR-395-V/1,2,3, Draft, September 2001

U054, Decontamination and Decommissioning of a Plut onium Fabrication Facility Michael West, Robert Hunt and Donald Paine, not dated

Waste Material Parameter Analysis Memorandum, Jeff Harrison, November 1, 2010C-1ATTACHMENT C: FEBRUARY 2014 CONTINUED COMPLIANCE INSPECTION PERSONNELPersonnelAffiliationArea of Expertise/FunctionEntranceMeetingInterviewedExitMeetingRajani Joglekar U.S. EPA ORIAInspector–Team LeaderEd Feltcorn U.S. EPA ORIA InspectorDorothy Gill SC&A, Inc. RTR/VE InspectorConnie Walker SC&A, Inc. AK InspectorKira Darlow SC&A, Inc. AK InspectorPatrick Kelly SC&A, Inc. NDA/DTC InspectorAndrew Stallings ORNL-CCP VPMAnthony Harley ORNL-CCPVE Operator/ITR, VEE,SME/OJT ExpertBerry Pace CBFO/CTAC QA ObserverBeverly Schrock CCP CH SPMChuck Wallace ORNL-CCP VE Operator/ITRDaniel Crosby MCS/CCP DTC OperatorDavid Queen DOE EMOR Project ManagerDavid W. Moody NWP/CCP RH SPMDerek Matheny ORNL-CCP VE Operator/ITRDerek Ott NWP/CCP RH Radiological EngineerFred Oney CCP/VJT RTR/LOIrene Joo NWP/CCP RH ManagerJ.R. Stroble DOE/CBFO ObserverJeff Harrison ORNL-CCP AKEJeremy Robinson NFT/CCP FGAJose R. Franco DOE/CBFO ObserverKenneth Lickliter CBFO/CTAC ObserverKevin J. Peters ORNL-CCP AKELaTravia Harmon CCP QA QA (NWP)Lisa Watson ORNL-CCP AKEMarcus A. Pinzel DOE/CBFO RH Program ManagerMaria Steade MCS/CCP NDA IQ3 OperatorMark Doherty CBFO/CTAC ObserverC-2Michael Sensibaugh CCP Operations ManagerNeil Dickes NWP/CCP NDA SupportR.C. McKay WAI General ManagerRonald Whitson MCS/CCP NDA/DTCRonnie Lee NWP/CCPWaste CharacterizationManagerScott Kranker WAI STRSean Stanfield MCS NDA IQ3Steve Redmond ORNL-CCPRTRTammy Reynolds NWP/CCPCCP ProgramManager/ObserverTom Morgan CBFO/NTP CCP ManagerD-1ATTACHMENT D: AK TIER 1 EVALUATION CHECKLIST: WASTESTREAM OR-NFS-CH-HOM-AEPA Inspection No.: ORNL-CC-2014 Waste Stream:OR-NFS-CH-HOM-AInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsCCP-TP-005 ImplementationAK-1:Confirm that Attachment 1, AcceptableKnowledge Documentation Checklist, is complete.Revision 26; Dated 1/7/2014; Signed by Jeff Harrison Att. 1 includes source document (SD)that any AKE ever thoughtmightapplyto the HOM-A waste stream andmightapply to specific AK requirements. If anSD is found to not apply or not beuseful, it is not automatically removedfrom Att. 1. Everything cited in theAKSR must be listed in Att. 1, but notvice versa.AK-2:Confirm that Attachment 2, Record ofCommunication, is completed as necessary.C210None.AK-3:Confirm that an Attachment 3, AcceptableKnowledge Source Document Summary, is completefor every source document.See reference list in Attachment B All reviewed source documents have anassociated Att. 3 summary.AK-4:Confirm that Attachment 4, AcceptableKnowledge Source Document Information List, iscomplete and up to date.Revision 26; Dated 1/6/2014; Signed by Travis SmithAtt. 4 includes every SD that any AKEever thoughtmightapply to the HOM-Awaste stream. If an SD is found to notapply or not be useful, it is notautomatically removed from Att. 4.Every SD cited in AKSR must be in Att.4, but not vice versa.AK-5:Confirm that Attachment 6, Waste Form,Waste Material Parameters, Prohibited Items, andPackaging, is complete and up to date.Revision 26, Dated 12/5/2013, Signed by Jeff Harrison.WMP analysis memorandum, Dated 11/1/2010, Signed byJeffHarrisonCalculated based on NFS containerpaperwork and historical RTR. SupportsTable 7-1 in AKSR, Revision 9.AK-6:Confirm that Attachment 7, Radionuclides, iscomplete and up to date and that AK-NDAcommunication is appropriately documented.Revision 20, Dated 11/16/2010, Signed by Jeff Harrison.NDA memorandum, Dated 11/15/2010, Signed by Jeff Harrison(AKE), Robert Ceo (NDA SME), Joe Wachter (MCS TechnicalDirector) and Joe Harvill (CCP Project Office)HOM-A waste is similar in origin toother NFS waste streams; therefore it isappropriate to add the HOM-Adiscussion to the same NDAmemorandum.D-2EPA Inspection No.: ORNL-CC-2014 Waste Stream:OR-NFS-CH-HOM-AInspection Date: February 4–6, 2014AK-7:Confirm that Attachment 8, Waste ContainersList, is complete and up to date.Revision 26, Dated 12/5/2013, Signed by Jeff Harrison Att. 8 is record of what was added to thewaste stream; containers only removedfrom Att. 8 if added to a different CCPwaste stream. If fall out for LLW orotherwise excluded, stay in Att. 8; alsodo not add daughter or repackagedcontainer numbers to Att. 8. No newcontainers added since restart.AK-8:Confirm that Attachment 10, AcceptableKnowledge Re-evaluation Checklist, is completed asnecessary.NoneAKEs confirmed no Att. 10s for HOMA waste stream since restart.AK-9:Confirm that Attachment 11, AcceptableKnowledge Source Document DiscrepancyResolution, is completed as necessary.DR030 and DR031AKEs confirmed no DRs for HOM-Awaste stream since restart. DR030documents containers moved from HETA to HOM-A waste streams. DR031documents evaluation of whether EPAHWN should be applied to HOM-Awaste.AK-10:Confirm that Attachment 13, CCP WasteStream Characterization Checklist, is completed foreach characterization lot.Revision 26, Draft for Lot 1, Dated 1/8/2014, Not signed, Provided2/5/2014Att. 13 is complete for two containers.Att. 13 also includes example ofimplementation of revisions to CCP-TP005 impacting AK-NDA comparison:NDA reported certain radionuclides thatare not included in the AKSR; becausethese radionuclides are not any of the 10WIPP-tracked and they do notcontribute to 95% of the radioactivehazard for payload container, AKSRdoes not need revision.AK-11:Confirm that Attachment 14, CCPAcceptable Knowledge Accuracy Report, iscompleted annually and verify that the AK accuracyreport memorandum is technically adequate.NoneAKEs and SPM confirmed that theyhave not assessed AK accuracy sincerestart.AK-12:Confirm that Attachment 15, CCP TRUWaste Correlation and Surrogate Summary Form, iscompleted as necessary.N/AN/AAK-13:Confirm that the AKSR is complete andaccurately describes the subject waste.CCP-AK-ORNL-001, Revision 9 AKSR includes all requiredcomponents. See AKCH-17–AKCH-19and AKCH-21–AKCH-23.D-3EPA Inspection No.: ORNL-CC-2014 Waste Stream:OR-NFS-CH-HOM-AInspection Date: February 4–6, 2014Waste Stream Definition and Waste IdentificationAK-14:Verify that all waste within the waste streamwas generated from a single process/activity and thatthe generating process/activity is adequatelydescribed.CCP-AK-ORNL-001, Revision 9C210, M007, M075, P218, P251, P252, P253, P254, P274, P319,P1116, P1371, U038, U054Waste generated from: (1)immobilization of fines, sweeps, liquids,and other high-activity residualscollected during decommissioning ofBuildings 234 and 110; (2) repackagingat TWPC.AK-15:Verify that all waste within the waste streamis similar in material and physical form and that theexpected physical perameters are adequatelydescribed.CCP-AK-ORNL-001, Revision 9Attachment 6 and memorandumC203, C206, C209, C210, M003, M202, P218, P274WMPs estimated from NFS containerdisposal paperwork, procedures, productinformation, and a review of historicalRTR data.AK-16:Verify that the expected radiologicalcharacteristics are adequately described.CCP-AK-ORNL-001, Revision 9Attachment 7 and memorandumC099, C100, M003, M012, M198, P212, P218, P321, U016, U017,U038, U054238U and239Pu are predicted mostprevalent by mass but measurementsmay result in239Pu and240Pu being mostprevalent due to expected issuesmeasuring238U.AK-17:Verify that waste containers are traceablefrom retrieval through CCP’s EPA-approvedcharacterization process.NFS0479A1: Att. 8; M003; M075; M202; OR-RTR6-0437,12/10/2013NFS0481: Att. 8; M003; M202; not yet ORNL-CCP-characterizedNFS0865A: Att. 8; M003; M075; M202; OR-RTR6-0437,12/10/2013; OR-IQ3-0224 assay 12/4/2013; Draft characterizationchecklist Lot 1, 1/8/2014Drums are traceable from NFS throughORNL-CCP characterization.Land Withdrawal Act RequirementsAK-18:Verify that all of the waste in the wastestream is defense in origin.CCP-AK-ORNL-001, Revision 9C099, C100, M021Over 90% of the NFS fuel productionwas for defense-related projects/clients.AK-19:Verify that none of the waste in the wastestream is high-level waste.CCP-AK-ORNL-001, Revision 9C099, C145, P273, U038AKSR is adequate: NFS did notreprocess SNF or handle HLW.AK-20:Verify that none of the waste in the wastestream is spent nuclear fuel.CCP-AK-ORNL-001, Revision 9C099, C145, P273, U038AKSR is adequate: inputs to processwere scrap Pu or Pu recovered duringreprocessing at other facilities, and notSNF.E-1ATTACHMENT E: RTR TIER 1 EVALUATION CHECKLISTEstablishment of RequiredTechnical Elements in ProceduresExecution of ProceduresObjective Evidence/CommentsRTR-1: Site procedures identifyrequired training and qualifications forRTR personnelCCP-TP-028, Revision 8CCP-QP-002, Revision 35RTR operators receive training on the waste matrixparameters and typical packaging configurationsexpected in each waste stream.To become qualified, the RTR operator must pass acomprehensive written test based on trainingobjectives with a minimum score of 80%Unsatisfactory performance – failed to identifyprohibited item during OJT of score of less than80% on examDemonstrate capability (At initial qualification,requalification, and semiannually, successfullyexamine atrainingcontainer).At initial qualification, and subsequent requalification, successfully examine atestdrum.RHVE operators re-qualified every 2 years basedon continued satisfactory performanceThe original inventories for demonstration of capability containersNDE-TEST-22 and NDE-TRAINING-30 contained errors, butthese were identified and corrected by CCP personnel.Objective evidence:1.Inventory sheets for RTR container Nos. NDE-TEST-11, NDETEST-20, NDE-TEST-22, NDE-TRAINING-19, NDETRAINING-26, NDE-TRAINING-30, NDE-TRAINING-322.Training Container Evaluation Data Sheets for various RTRoperators3.Qualification Cards for selected RTR personnel4.Training roster for CCP-AK-ORNL-001, Revisions 7 and 85.LOQI RTR operators dated 1/21/146.Revisions 1 and 2 of Prohibited Items training forRTRoperators7.American Society for Nondestructive Testing, RecommendedPractices, No. SNT-TC-1A, June 1980 EditionRTR-2: Site procedures providecomplete instructions for operators toperform the RTR examination andcompletion of the associateddocumentationCCP-TP-053, Revision 14RTR operator adequately explained the processfollowed for examining a drum and entering datainto data forms (whether hard copy or electronicdata entry is used).EPA did not identify any issues associated with thegeneration andrecording of CH S3000 RTR data.Objective evidence:1.BDR Nos. OR-RTR6-0437, OR-RTR6-0438, OR-RTR6-0439and OR-RTR6-04402.Audio/visual recordings for selected containers from the aboveCH BDRs3.Training roster for CCP-AK-ORNL-001, Revisions 7 and 8RTR-3: The RTR procedures require animage quality check to be performedCCP-TP-053, Revision 14, section 4.3,Attachment 1Operator adequately explained how theacceptability of an image is determinedImage quality check is performed once per day(RTR Measurement Control Report)Performance of the image quality check isdocumented and recordedThe result of the image quality test was recorded on CCP-TP-053,Att. 1.Objective evidence:1.BDR Nos. OR-RTR6-0437, OR-RTR6-0438, OR-RTR6-0439and OR-RTR6-04402.Audio/visual recordings for selected containers from the aboveCH BDRsE-2Establishment of RequiredTechnical Elements in ProceduresExecution of ProceduresObjective Evidence/CommentsRTR-4: The procedure allows theoperator to adjust the RTR toaccommodate the physical properties ofthe waste and waste containers likely tobe encountered at the siteCCP-TP-053, Revision 14Operator could identify applicable policies andprocedures governing the operation of RTRequipmentThe RTR system could be adjustedHigh-density material was examined with the Xray device set on the maximum voltage and lowdensity material at a lower voltageOperator adequately explained what is done if animage is unacceptable (e.g., the waste is solidifiedor the container is lead-lined)For containers NFS0788A (BDR No. OR-RTR6-0438) andNFS0806A (BDR No. OR-RTR6-0439), the operator verified theWMC and that the waste matched the waste stream description.However, drum No. NFS0788A contained a AA battery and drumNo. NFS0806A contained scrap lead; these items resulted in thewaste not matching the waste stream description orthe WMC. TheITR identified these errors. ORNL-CCP generated NCR-ORNL0873-13 to address this issue and corrected the BDRs.Objective evidence:1.BDR Nos. OR-RTR6-0437, OR-RTR6-0438, OR-RTR6-0439and OR-RTR6-04402.Audio/visual recordings for selected containers from the aboveCH BDRs3.CCP-TP-053, CCP Standard Real-Time Radiography (RTR)Inspection Procedure, Revision 14, 09/25/20134.Qualification Cards and training records for the demonstrationRTR operator5.Training Container Evaluation Data Sheets for various RTRoperators6.NCR NCR-ORNL-0873-137.Training roster for CCP-AK-ORNL-001 Revisions 7 and88.CCP-QP-005, CCP TRU Nonconforming Item Reporting andControl, Revision 23, 06/25/2013RTR-5: Data records are of sufficientlyhigh quality for complete reviewCCP-TP-053, Revision 14RTR tape is high quality, the sound track isaudible, and the required information is containedon the audible portion of the tapeThe RTR tape is consistent with the data packagefor the same drum.EPA compared audio/visual recordings to the writtenrecord forselected containers to verify that the data recorded were the same.Objective evidence:1.BDR Nos. OR-RTR6-0437, OR-RTR6-0438, OR-RTR6-0439and OR-RTR6-04402.Audio/visual recordings for selected containers from the aboveCH BDRsE-3Establishment of RequiredTechnical Elements in ProceduresExecution of ProceduresObjective Evidence/CommentsRTR-6: There is a procedure fordetermining whether the waste matchesthe waste stream description and WasteMatrix Code, and for determiningWaste Material Parameters and weightsCCP-TP-053, Revision 14, Tables 2 &3, Attachment 2The procedure is adequately implementedOperators verify that the waste matches the wastestream descriptionWaste Matrix Code is verified. If not, correctiveaction is takenWMP weights are estimated by compiling aninventory of waste items and residual/packagingmaterialsDoes the RTR operator use a standard weightlookup table to provide an estimate of WMPweights? If so, has the table been updated toreflect additional information gained throughprevious RTR/VE exams or updated AKinformation?The audio/visual and written records, reviewed by EPA,demonstrated that the waste in each container matched the WMCand waste stream description. The operator verifiedthe absence ofprohibited items and estimated WMP weights in accordance withprocedure CCP-TP-053 (see RTR-4 of this checklist).Table 3 ofCCP-TP-053 provides standardized weights for commonwasteitems to assist the operator when assigning estimated weights.Objective evidence:1.BDR Nos. OR-RTR6-0437, OR-RTR6-0438, OR-RTR6-0439and OR-RTR6-04402.Audio/visual recordings for selected containers from the aboveCH BDRs3.NCR NCR-ORNL-0873-13RTR-7: The RTR procedure providesinstructions for identifying prohibiteditems and for processing drumscontaining prohibited itemsCCP-TP-053, Revision 14, Table 1Operator could name prohibited itemsOperator adequately explained how the presence ofprohibited liquids is determinedOperator’s explanation of required actions ifprohibited items were encountered was consistentwith procedureSee RTR-4 of this checklist. The subject BDRs werecorrected inaccordance with CCP procedures. No other prohibiteditems wereidentified during the examinations.Objective evidence:1.BDR Nos. OR-RTR6-0437, OR-RTR6-0438, OR-RTR6-0439and OR-RTR6-04402.Audio/visual recordings for selected containers from the aboveCH BDRs3.Prohibited Item training module, Revisions 7 and 8,dated8/23/10 and 3/29/11 respectively.4.NCR NCR-ORNL-0873-13RTR-8: RTR procedures include therequired QC examinations, evaluationaccuracy and reproducibility of theRTR processCCP-TP-053, Revision 14, sections 4.5& 4.6An independent replicate scan is performed on onewaste container per day or on one container pertesting batch (whichever is less frequent)An independent observation of one scan (not thereplicate) is performed, by a qualified RTRoperator (anyone but the initial RTR operator)In BDR No. OR-RTR6-0437, the independent observation wasperformed on container No. NFS0479A1 and the replicate scan oncontainer No. NFS0414I; in BDR No. OR-RTR6-0439, theindependent observation was performed on containerNo.NFS0508A and the replicate scan on container No. NFS075A. Asecond qualified operator performed the independentobservationas required by procedure CCP-TP-053.Objective evidence:1.BDR Nos. OR-RTR6-0437, OR-RTR6-0438, OR-RTR6-0439and OR-RTR6-04402.Audio/visual recordings for selected containers from the aboveCH BDRsE-4Establishment of RequiredTechnical Elements in ProceduresExecution of ProceduresObjective Evidence/CommentsRTR-9: Procedures containstandardized forms for recording RTRdataCCP-TP-053, Revision 14, Attachment2RTR operator adequately explained the processfollowed for examining a drum and entering datainto data forms (whether hard copy or electronicdata entry is used).Direct data entry into an electronic form is done bythe RTR operator using a computer while theoperator is still in the RTR booth.The electronic data file undergoes the same QCchecks used for hand-written data entriesThe operator had identified waste items and enteredthem into theelectronic data form, CCP-TP-053, Att. 2. The operator verified theabsence of prohibited items and estimated WMP weights inaccordance with procedure CCP-TP-053. CCP-TP-053, Table 3,provides standardized weights for common waste items to assistthe operator when assigning estimated weights. Dataforms hadbeen reviewed at the data generation and project level.Objective evidence:1.BDR Nos. OR-RTR6-0437, OR-RTR6-0438, OR-RTR6-0439and OR-RTR6-04402.Audio/visual recordings for selected containers from the aboveCH BDRsRTR-10: Site procedures require reviewof Batch Data Reports (BDRs) at thedata generation and project levelCCP-TP-053, Revision 14, section 4.10CCP-TP-001, Revision 21, Attachment2Data generation level reviews are performed anddocumented (ITR)Project level reviews are performed anddocumented (SPM)All of the BDRs reviewed had been reviewed at the data generationand project level. The ITR and SPM documented the reviews asrequired on CCP-TP-053, Att. 3, and CCP-TP-001, Att. 2, andsigned and dated the reviews.Objective evidence:1.BDR Nos. OR-RTR6-0437, OR-RTR6-0438, OR-RTR6-0439and OR-RTR6-0440