DOCKET NO: A

- 98

- 49; II

- A4

- 156

WASTE CHARACTERIZATION INSPECTION REPORT

PROPOSED APPROVAL
EPA BASELINE INSPECTION NO. EPA

- SRS

- CCP

- RH

- 08.11

- 8 OF THE CENTRAL CHARACTERIZATION PROJECT REMOTE

- HANDLED TRANSURANIC WASTE CHARACTERIZATION

PROGRAM F OR THE SAVANNAH RIVER SITE : August 30

– September 1, 2011, and December 6

– 7, 2011

U.S. Environmental Protection Agency Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 2046 0

January 201 2i TABLE OF CONTENTS
Section Page
Acronyms and Initializations

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

................................ ................................ ................................ ............ 1 2.0 Purpose of Inspections

................................ ................................ ................................ ........ 4 3.0 Purpose of This Report

................................ ................................ ................................ ....... 5 4.0 Scope of Inspection

................................ ................................ ................................ ............. 6 5.0 Inspection

- Related Definitions

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

................................ ................................ ................................ ............................. 7 7.0 Performance of th e Inspection

................................ ................................ ............................ 7 7.1 Savannah River Site Background

................................ ................................ ........... 7 7.2 Inspection Process Overview

................................ ................................ .................. 8 8.0 Technical Evaluation

................................ ................................ ................................ .......... 9 8.1 Programmatic Requirements and Acceptable Knowledge

................................ ..... 9 8.2 Radiological Chara cterization

................................ ................................ ............... 25 8.3 Real

- Time Radiography

................................ ................................ ........................ 37 9.0 Response to Comments

................................ ................................ ................................ ..... 41 10.0 Summary of Results

................................ ................................ ................................ .......... 41 10.1 Environmental Protection Agency Findings and Concerns

................................ .. 41 10.2 Conclusions

................................ ................................ ................................ ........... 41 11.0 References

................................ ................................ ................................ ......................... 43ii ATTACHMENTS
Attachment A: Documents Reviewed During the Baseline Inspection Attachment B: Inspection Personnel List Attachment C: EPA Inspection Is sue Tracking Form No. SRS

- CCP

- RH

- AK

- 11

- 01CR

LIST OF TABLES
Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by SRS

CCP

................................ ................................ ................................ ................................ 3 Table 2. Batch Data Reports Examined

................................ ................................ ..................... 10 Table 3. Summary of Traceability Analysis

................................ ................................ ............... 22 Table 4. Objective Evidence of Training for AK Personnel

................................ ...................... 23 Table 5. MCS/ISOCS Replicate Data

................................ ................................ ........................ 31 Table 6. Summary of RH Determinations

................................ ................................ .................. 34 Table 7. Overall Uncertainty of Example Drum SR510588

................................ ...................... 36

LIST OF FIGURES Figure 1. Characterization and Qualification Process

................................ ................................ . 13 Figure 2

. Flow Diagram of the Characterization Process for SR

- RH

- FBL.01

............................ 27iii ACRONYMS AND INITIAL IZATIONS
%RSD percent relative standard deviation A K acceptable knowledge AKE A cceptable K nowledge E xpert AKSR acceptable knowledge summary report Am americium ASME American Society of Mechanical Engineers Ba barium BDR batch data report BGR burial ground record CAR corrective action report CBFO Carlsbad Area Field Office CCP Central Characterization Project CFR Code of Federal Regulations CH contact

- handled Ci curie CIS Characterization Information Summary Cm curium Co cobalt CRR Characterization Reconciliation Report Cs cesium CSSF Correlation and Surrog ate Summary Form CTAC CBFO Technical Assistance Contractor DA destructive assay DL detection limit DOE U.S. Department of Energy DQO data quality objective DR discrepancy resolution DTC dose

- to

- curie EPA U.S. Environmental Protection Agency Eu europium FR Federal Registeriv

FSN File Sequence Number HLW high

- level waste HPGe high

- purity germanium detector hr hour ISOCS In Situ Object Counting System ITR Independent Technical Reviewer LANL Los Alamos National Laboratory LLW low

- level waste LOQI list of qualifie d individuals LWA WIPP Land Withdrawal Act

m meter MCNP5 Monte Carlo N

- Particle Transport Code RSICC Computer Code

Collection, Oak Ridge National Laboratory MCS Mobile Characterization Services MDA minimum detectable activity MGA Multi

- Group Analysis mR/hr milliRoentgen per hour mrem/hr millirem per hour NABC Non Destructive Assay Box Counter nCi nanocurie NCR nonconformance report NDA nondestructive assay Np neptunium NQA Nuclear Quality Assurance NWPA Nuclear Waste Policy Act ORIA Office of Radiation and Indoor Air Pu plutonium PUREX plutonium/uranium extraction QA quality assurance QAO quality assurance objectives QC quality control RC radiological characterization rem/hr rem per hourv

RH remote

- handled RTR real

- time radiography SCG Summary Category Group SF scaling factor SNF spent nuclear fuel SPM Site Project Manager Sr strontium SRNL Savannah River National Laboratories SRS Savannah River Site T1 Tier 1 T2 Tier 2 Th thorium Tl thallium TMU Total Measurement Uncertainty TRU transuranic U uranium VE visua l examination WCPIP Waste Characterization Program Implementation Plan , Revision 2 WDS WIPP Waste Data System WG Pu weapons
- grade plutonium WIPP Waste Isolation Pilot Plant WMC waste matrix code WMP waste material parameter WRM working reference material WSPF Waste Stream Profile Form WTS Washington TRU Solutions Y yttrium1

1.0 EXECUTIVE SUMMARY This report discusses the U.S. Environmental Protection Agency’s (EPA’s) proposed approval of a single remote

- handled (RH) transuranic (TRU) debris waste stream ch aracterized using the waste characterization program implemented by the Central Characterization Project (CCP) at the Savannah River Site (SRS). In accordance with Title 40 of the Code of Federal Regulations ( 40 CFR ), Section 194.8(b), EPA inspected SRS

- CC P’s RH TRU waste characterization program at SRS in Aiken, South Carolina

. Baseline Inspection No. EPA

- S RS

- CCP

- RH

- 0 8 .11

- 8 took place on August 30

– September 1, 2011 , with a follow

- up inspection on December 6

– 7, 2011 , at SRS

. Upon EPA’s final approval, the U .S. Department of Energy ( DOE ) can emplace the SRS

- CCP RH TRU debris waste stream discussed in this report in the Waste Isolation Pilot Plant (WIPP)

. The inspection’s scope included one RH TRU waste stream, SR

- RH

- FBL.01, consisting of debris waste from th e FB

- Line at SRS. The waste was generated by glovebox operations, decontamination, housekeeping, maintenance and construction activities conducted from 1975 through 1984. This inspection evaluated: the use of acceptable knowledge (AK); dose

- to

- curie (DTC) in conjunction with radionuclide

- specific scaling factors derived in part by measurement with the In Situ Object Counting System (ISOCS) and historical assays of containers from the contact

- handled (CH) counterpart waste stream at SRS, SRW027

- FB

- Pre

- 86

- C; and real

- time radiography (RTR) to confirm the physical form and waste material parameters (WMP) of waste drums. EPA propos es to approve the SRS

- CCP waste characterization program implemented to characterize RH debris waste from Waste Stream SR

- RH

- FBL.01 that was evaluated during this baseline inspection and is documented in this report. The proposed approval includes the following: (1) The AK process for RH TRU debris waste stream s that have companion 1 CH debris waste streams (2) The radiological characterizati on of eight drums in Waste Stream SR

- RH

- FBL.01 using DTC and scaling factors generated through use of the ORTEC/ISOCS prior to the baseline inspection and historical assays of companion (see footnote1) CH debris waste streams for assigning radionuclide val ues , according to the limitations discussed in Section 8.2 of this report (3) The radiological characterization process using DTC and scaling factors generated through use of the Mobile Characterization Services ( MCS ) /ISOCS and historical assays of companion ( see footnote1) CH debris waste streams for assigning radionuclide values for RH waste, as documented in CCP

- AK

- SRS

- 581, Revision 1, supported by the calculation packages (or equivalent documentation), and subject to the limitations discussed in Section 8.2 of this report

1 A companion CH waste stream has the same summary category group , same waste stream definition, and same radiological and physical properties as the subject RH wa ste stream. In this case, the only difference between containers in the companion CH waste stream and those in the subject RH waste stream is the waste’s external dose rate ; i.e., less than or greater than 200 millirem per hour ( m r em/hr ), which makes the w aste CH or RH, respectively.2

(4) The RTR process to identify WMPs and the physical form of RH TRU debris waste This proposed baseline approval of SRS

- CCP’s RH TRU waste characterization program, when approved, will allow SRS

- CCP to characterize RH waste from Waste Stream SR

- RH

- FBL.01 in accordance with the conditions and restrictions discussed in this report and summarized in Table 1 below. After EPA finalizes the SRS

- CCP RH waste characterization program approval, additional debris waste stream(s) having a companion (see footnote 1) CH waste stream(s) may be disposed of at the WIPP provided th at an approved radiological scaling factor development process is used

. Use of the MCS/ISOCS is limited to the generation of scaling factors for specific radionuclides, i.e., the ac tivity ratios of plutonium (Pu) isotopes plutonium

- 239 ( 239 Pu ), plutonium

- 240 ( 240 Pu) and plutonium

- 241 ( 241 Pu) to americium

- 241 ( 241 Am). Further, use of the MCS/ISOCS for determining the scaling factor for plutonium

- 238 ( 238 Pu) or for direct quantificati on of any radionuclide is prohibited. A Tier 1 (T1) change approval is necessary when:
The radiological scaling factors development process used for characterizing RH debris waste differs from the process approved; An RH TRU debris waste stream characte rized for WIPP disposal does not have a companion (see footnote 1) CH waste stream; An RH TRU non

- debris waste stream from the solids (S3000) or soils and gravel (S4000) summary category groups is characterized for WIPP disposal; or The ORTEC/ISOCS is used for RH debris waste characterization in the future

. EPA must verify compliance with 40 CFR 194.24 before waste may be emplaced in the WIPP, as specified in Condition 3 of EPA’s certification of the WIPP’s compliance with disposal regulations for TRU rad ioactive waste [63 Federal Register (FR) 27354 and 27405, May 18, 1998]. EPA Baseline Inspection No. EPA

- SRS

- CCP

- RH

- 0 8 .11

- 8 was performed in accordance with the provisions of 40 CFR 194.8(b), as issued in a July 16, 2004, FR notice (Vol. 69, No. 136, pp. 4 2571

– 42583).3 Table 1
. Tiering of RH TRU Waste Characterization Processes Implemented by SRS

- CCP (Based on August 20

– September 1, 2011 , and December 6

– 7, 2011 , Baseline Inspection)
RH Waste Characterization Process Elements SRS
- CCP RH Waste Characterization Process

– T1 Changes SRS
- CCP RH Waste Characterization Process

– T2 Changes *
Acceptable Knowledge Any new RH S3000 or S4000 waste stream Any new RH S5000 waste stream that does not have a companion CH waste stream Substantive modification(s)** to CCP

- AK

- SRS

- 5 8 0 or CCP

- AK

- SRS

- 5 8 2 that have the potential to affect the characterization process (AK2, AK6) Any new RH S5000 waste stream that does have a companion CH waste stream Notification to EPA: Upon completion of revisions to C CP

- AK

- SRS

- 5 8 0, CCP

- AK

- SRS

- 5 8 2, CCP

- TP

- 005, or nonconformance and corrective action procedures that require CBFO approval*** (AK2, AK5, AK6) Upon completion of revisions to any CCP

- TP

- 005 attachments , including when Attachment 4 is generated to reflect the updated AKSR Source Document Reference List (AK5 , AK11 ) When the final or revised WSPF, CIS, CRR and related attachments are available and upon completion of any subsequent revisions to these documents (AK10) When AK accuracy reports are completed, prepare d annually at a minimum (AK11) When Add Container Memoranda have been prepared (AK5) When additional d iscrepancy r esolution r eports and n onconformance r eports have been prepared (AK4) Radiological Characterization, including Dose

- t o
- Curie Use of the MCS/ ISOCS to provide any information other than the relative determinations of 239 Pu, 240 Pu and 241 Pu to 241 Am (RC2) Future use of the ORTEC/ISOCS for any RH TRU waste (RC2) Application of a new scaling factor processes for isotopic determination other than th ose documented in CCP

- AK

- SRS

- 581, Revision 1 (applies to new RH waste streams and to the addition of containers to an approved waste stream) ( RC1 , RC4, RC5) Substantive modification(s)** to CCP

- TP

- 504 or CCP

- AK

- SRS

- 581 that have the potential to affect the characterization process (RC4, RC5) Any new RH waste stream characterized using an approved scaling factor process for isotopic determination Notification to EPA upon completion of revisions to CCP

- AK

- SRS

- 581 or CCP

- TP

- 504 that require CBFO approval*** (R C1, RC5) Notification to EPA when calculation package(s) CCP

- SRS

- 44, or equivalent record(s), are available

Real

- Time Radiography RTR by any new process Notification to EPA upon completion of changes to RTR procedure(s) that require CBFO approval*** (R TR1) Addition of a new SCG to any approved RTR process (RTR2) Notes: * SRS

- CCP will report all T2 changes to EPA every three months. ** Substantive modification refers to a change with the potential to affect SRS

- CCP’s RH waste characterization process ; e .g., the use of an inherently different type of measurement instrument or the use of probes not described in CCP

- TP

- 504 , excluding changes related solely to safety or to address administrative concerns

. *** Notification to EPA is not necessary when documen t updates are editorial in nature or are required solely to address administrative concerns

.4

2.0 PURPOSE OF INSPECTIO NS On May 18, 1998, EPA certified that the WIPP would comply with the radioactive waste disposal regulations in 40 CFR Part 191. In that cert ification, EPA also included Condition 3, which states that ―the Secretary shall not allow shipment of any waste from...any waste generator site other than [Los Alamos National Laboratory (LANL)] for disposal at the WIPP until the Agency has approved the pro cesses for characterizing those waste streams for shipment using the process set forth in §194.8.‖ The approval process described in 40 CFR 194.8 requires DOE to (1) provide EPA with information on AK 2 for waste streams proposed for disposal at the WIPP an d (2) implement a system of controls used to confirm that the total amount of each waste component that will be emplaced in the WIPP will not exceed limits identified in the WIPP Compliance Certification Application. The rule applying to this baseline ins pection can be found in the FR (Vol. 69, No. 136, pp. 42571

– 42583, July 16, 2004). Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, FR notice, EPA must perform a baseline inspection of a TRU waste generator site’s waste characterization program. The purpose of the baseline inspection is to approve the site’s waste characterization 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 on

- site inspection to verify that the site’s system of controls is technically adequate and properly implemented. Specifically, EPA ’s inspection team verifies compliance with 40 CFR 194.24(c)(4), which states the following: Any compliance application shall: . . . Provide information which demonstrates that a system of controls has been and will continue to be implemented to confirm t hat the total amount of each waste component that will be emplaced in the disposal system will not exceed the upper limiting value or fall below the lower limiting value described in the introductory text of paragraph of this section. 3 The system of contro ls shall include, but shall not be limited to: measurement; sampling; chain of custody records; record keeping systems; waste loading schemes used; and other documentation. In other words, the purpose of the baseline inspection is to implement the requir ements of 40 CFR Part 194 by assessing whether DOE sites that characterize TRU waste prior to disposal at the WIPP are capable of characterizing and tracking the waste. EPA may also conduct follow

up inspections to address issues remaining from the baseli ne inspection or to seek further clarification/discussion related to waste characterization processes evaluated during a baseline

2 As of the FR notice of July 16, 2004, EPA has replaced the term process knowledge with acceptable knowledge . Acceptable knowledge refers to any information about the process used to generate waste, material inputs to the proc ess, and the time period during which the wastes were generated, as well as data resulting from the analysis of waste conducted prior to or separate from the waste certification process authorized by an EPA certification decision to show compliance with Co ndition 3 of the certification decision.

3 The introductory text of 40 CFR 194.24(c) states, ―For each waste component identified and assessed pursuant to [40 CFR 194.24(b)], the Department shall specify the limiting value (expressed as an upper or lower l imit of mass, volume, curies, concentration, etc.), and the associated uncertainty (i.e., margin of error) for each limiting value, of the total inventory of such waste proposed for disposal in the disposal system.‖5

inspection. By approving the CCP

- implemented waste characterization systems and processes at SRS

- CCP for RH debris waste, EPA confirms that it has evaluated the capabilities of systems and processes implemented by the site to accomplish two tasks: (1) identification and measurement of waste components, such as Pu, that must be tracked for compliance 4 and (2) confirmation that the waste in any given container has been properly identified as belonging to the group of approved waste streams.
3.0 PURPOSE OF THIS REPO RT This report documents the basis for EPA’s proposed baseline approval and explains the results of Baseline Inspection N o. EPA

- S RS

- CCP

- RH

- 0 8 .11

- 8 in terms of findings or concerns. Specifically, this report does the following:
Describes the SRS

- CCP waste characterization systems proposed for approval Delineates a specific set of RH wastes proposed for approval Provides obje ctive evidence supporting the proposed approval basis for all waste characterization systems Identifies all relevant system limitations and/or conditions for each waste characterization system and/or waste containers that are subject to this proposed appro val Any changes to the waste characterization activities from the date of the baseline inspection must be reported to and, if applicable, approved by EPA, according to Table 1. Please note that most T1 and Tier 2 (T2) change s listed in Table 1 are followed by a reference to the section of this report where the technical basis for th at T1 or T2 designation is presented ; T1 or T2 changes listed in Table 1 without a reference are meant to clarify the scope of the approval

. T1 chang es will require EPA review and approval prior to implementation and will apply to any new waste category groups or equipment types that were not evaluated during the baseline inspection.
SRS

- CCP must report and submit documentation on T1 changes when the y are ready for EPA review. Upon initial review, EPA will inform SRS

- CCP and the Carlsbad Area Field Office ( CBFO ) whether a site inspection is necessary. EPA may request additional information, choose to conduct a desktop review, and/or confer with SRS

- CC P personnel. Upon evaluation with or without a site inspection, EPA wi ll issue a decision. Only upon receiving EPA written approval may SRS

- CCP implement T1 changes.

4 The potential contents of a single was te stream or group of waste streams determine which processes can adequately characterize the waste. For example, if AK suggests that the waste form is heterogeneous, the site should select the matrix

- appropriate radiological characterization technique to obtain adequate radionuclide measurements. Visual Examination (VE) serves to confirm and quantify waste components, such as cellulosics, rubbers, plastics, and metals. Once the nature of the waste has been confirmed, characterization techniques quantify se lected radionuclides in the waste. In some cases, a TRU waste generator site may be able to characterize a range of heterogeneous waste streams or only a few. A site’s stated limits on the applicability of proposed waste characterization processes govern t he scope of EPA’s inspection.6

EPA will notify the public of the results of its evaluations of T1 and T2 changes establi shed as part of the SRS

- CCP final approval through the EPA w ebsite and by sending emails to the WIPPNEWS list. All T1 changes must be submitted for approval before their implementation and will be evaluated by EPA. SRS

- CCP must submit T2 changes that have been implemented four times a year , at the end of each fiscal quarter. The DOE documents that EPA reviewed for this evaluation are cited throughout the report and are listed in Attachment A. Any of these documents can be requested from the following addre ss: Manager, National TRU Program Carlsbad Field Office U.S. Department of Energy P.O. Box 3090 Carlsbad, NM 88221

- 3090 EPA’s final approval decision regarding the SRS

- CCP RH waste characterization program will be conveyed to DOE separately by letter fol lowing EPA’s review of public comments received responding to the proposed approval discussed in this report. In accordance with 40 CFR 194.8(b)(3), this information is also available on EPA’s website at ww w.epa.gov/radiation/wipp

. 4.0 SCOPE OF INSPECTION The scope of Baseline Inspection No. EPA

- S RS

- CCP

- RH

- 0 8 .11

- 8 included the technical adequacy of the waste characterization systems used by SRS

- CCP to characterize RH TRU Waste Stream SR

- RH

- FBL.01 . The EPA in spection team evaluated these systems with respect to their ability to perform the following: Provide adequate documentation regarding the origin and classification of the RH TRU wastes proposed for disposal at WIPP using AK

. Identify and quantify the act ivities and associated uncertainties of the 10 WIPP

- tracked radionuclides [ 241 Am, cesium

- 137 ( 137 Cs), 238 Pu, 239 Pu, 240 Pu, plutonium

- 242 ( 242 Pu ) , strontium

- 90 ( 90 Sr), uranium

- 233 ( 233 U), uranium

- 234 ( 234 U ) and uranium

- 238 ( 238 U ) ] and other TRU radionuclide s using a combination of ISOCS measurements, AK , and DTC with the application of radionuclide

- specific scaling factors

. Assign WMPs correctly for RH retrievably stored debris waste that was repackaged using RTR

. During an inspection, EPA does not approve characterization data; that function is the sole responsibility of the entity being evaluated, in this case, SRS

- CCP. EPA evaluates the site’s waste characterization processes to characterize RH TRU debris waste. The SRS

- CCP evaluation consisted of reviewi ng training records and interviewing waste characterization personnel to assess their understanding of: (a) EPA regulations governing TRU waste characterization activities and EPA’s approval of TRU waste for WIPP disposal ; (b) waste characterization proces ses implemented and available as alternatives; and (c) SRS

- CCP’s documentation and record

- keeping procedures. In addition, the EPA evaluation focused on observing equipment7

operations and waste characterization practices at SRS controlled by site procedure s, and on inspecting records related to each of the waste characterization processes within the inspection’s scope. An important aspect of this evaluation is the objective evidence documenting the effectiveness of the waste characterization processes. Ob jective evidence typically takes the form of batch data reports (BDRs), AK accuracy reports , and RTR records. During this inspection, EPA selected samples of each of these items, based on the number and variety of items each waste characterization process produced, consistent with standard auditing techniques. Based on its evaluati o n of the waste characterization processes in conjunction with objective evidence, EPA determined the technical adequacy of these processes and associated records within the inspe ction’s scope.
DOE’s Remote

- Handled Waste Characterization Program Implementation Plan (WCPIP), DOE WIPP

- 02

- 3124, Revision 2, was effective as of April 21, 2011. EPA requires that all CCP RH TRU waste characterization activities, including the preparation of documentation and the documents themselves, be in conformance with the latest version of the WCPIP

. All mention of the WCPIP in this report refers specifically to DOE WIPP

- 02

- 3124, Revision 2.
5.0 INSPECTION

- RELATED DEFINITIONS During the course of an i nspection, EPA inspectors may encounter items or activities that require further inquiry for their potential to adversely affect waste characterization and/or isolation within the repository. The two main categories relevant to waste characterization inspe ctions are identified below: Finding : A determination that a specific item or activity does not conform to 40 CFR 194.24(c)(4). A finding requires a response from CBFO prior to site approval. Concern : A judgment that a specific item or activity may or may not have a negative effect on compliance and, depending on the magnitude of the issue, may or may not require a response. A concern requiring a response requires a response from CBFO prior to site approval.
6.0 PERSONNEL EPA and its support personnel conduc ted interviews with SRS

- CCP personnel in several disciplines during two site visits to SRS. The members of the EPA inspection team and personnel contacted are listed in Attachment B.
7.0 PERFORMANCE OF THE I NSPECTION
7.1 Savannah River Site Background
SRS is l ocated near Aiken, South Carolina. SRS was constructed during the early 1950s to produce the basic materials used in the fabrication of nuclear weapons, primarily tritium and 239 Pu, in support of the national defense program

. Its main focus has been to dev elop technical8

solutions to support national security and to counter national and international threats. Site activities support national needs in the area of nuclear weapons, nonproliferation and assessments, military technologies and applications, energy and infrastructure assurance, and homeland security.
Waste Generation Activities
Waste Stream SR

- RH

- FBL.01 originated in the FB

- Line between January 1975 and December 1984. The FB

- Line is in the F

- Canyon at SRS and was constructed in 1951

– 1953 , when it s first mission was the production of weapons
- grade plutonium (WG Pu) 5 in 1954. Later FB

- Line functions were the concentration and purification of Pu and recovering Pu from scrap. The waste stream was generated by m aintenance and routine housekeeping opera tions and other activities. Wastes were not intentionally segregated by process area, and l ow
- level waste (LLW) , CH waste, and RH TRU waste w ere generated . CH TRU debris generated by FB

- Line operations are in Waste Stream SR

- W027

- FB

- Pre86C, and RH TRU debr is are in Waste Stream SR

- RH

FLB.01.
7.2 Inspection Process Overview EPA conducted Baseline Inspection No. EPA

- S RS

- CCP

- RH

- 0 8 .11

- 8 of SRS

- CCP’s program to characterize RH TRU wastes on two occasions from August through December 2011 . This inspection had the s cope described in Section 4.0 for the purpose of determining the site’s compliance with 40 CFR 194.24. The inspection was conducted in the following steps: (1) Obtaining and reviewing site procedures, reports, and other technical information related to RH was te characterization activities used to characterize SRS

- CCP Waste Stream SR

- RH

- FBL.01 (2) Preparing technical questions prior to the inspection based on the activities cited in (1) above (3) Interacting with CBFO and SRS

- CCP personnel to arrange inspection logisti cs (4) Evaluating SRS

- CCP’s implementation of waste characterization processes for adequacy and demonstrating compliance with 40 CFR 194.24 requirements (5) Conducting the baseline inspection at SRS to verify the technical adequacy and/or qualifications of RH wast e characterization personnel, procedures, processes and equipment, as documented in SRS

- CCP records (6) Observing the execution of the ISOCS and DTC processes at SRS during two site visits (7) Evaluating the development of radionuclide

- specific scaling factors (8) Eva luating the correlations of containers for the purpose of identifying common attributes (9) Communicating all pertinent information to CBFO and SRS

- CCP personnel

5 Weapons

- grade plutonium is defined as material that is approximately 93% 239 Pu and 6% 240 Pu with trace amounts of 238 Pu, 241 Pu and 242 Pu.9

(10) Conducting entrance, exit and daily briefings for CBFO and SRS

- CCP management personnel (11) Obtaining and reviewing SRS

- CCP documents that were revised and/or created in response to EPA concern after the inspection (12) Issuing the inspection report and proposed approval
8.0 TECHNICAL EVALUATION Sections 8.1 through 8.3 of this report detail the three technical areas assessed during this inspection:
AK Radiological c haracterization RTR
8.1 Programmatic Requirements and Acceptable Knowledge EPA examined the programmatic requirements and AK process and associated information to determine whether S RS

- CCP demonstrate d compliance with 40 CFR 194.8 requirements for RH Waste Stream S R

- RH

- FBL.01

. Waste Characterization Element Description As part of the inspection, EPA reviewed the adequacy of the following aspects of the use of AK for RH waste characterization by SRS

- C CP: Inspection scope and waste stream identification Identification of the WCPIP waste characterization process Certification Plan and other WCPIP documentation WCPIP waste qualification pathway Data management reviews, validation activities, data repor ting , and records retention AK personnel training Waste S tream P rofile F orm (WSPF) and related attachments Nonconformance and d iscrepancy r esolution documentation Waste s tream definition including radiological and physical characteristics Verification tha t the subject waste is of defense origin and is not LLW, high

- level waste (HLW), or spent nuclear fuel (SNF) Role of AK in the characterization methodology, including support of scaling factors10

AK procedure and implementation, including a ttachments [AK a cc uracy, Characterization Reconciliation Reports (CRR s ), Correlation and Surrogate Summary Forms (CSSF s )] AK s ummary r eport (AKSR) and associated source documents AK data traceability Attainment of d ata q uality o bjectives (DQOs)
Documents and Batch Data Re ports Reviewed Source documents, attachments, forms and other data were provided to EPA and were reviewed, as applicable. The list of all documentation examined is in Attachment A. The BDRs examined are listed in Table 2

. Table 2
. Batch Data Reports Examined
Drum No. RTR BDR DTC BDR SR504233 SR4RTR0173 SRSRHDTC1100 2 SR510588 SR4RTR0173 SRSRHDTC1100 2 SR512002 SR4RTR0173 SRSRHDTC1100 2 SR501028 SR4RTR0173 SRSRHDTC1100 2 SR504242 SR4RTR0173 S RSRHDTC1100 2 SR526627 SRSRTR0425 SRSRHDTC11001 SR504196 SRSRTR0425 SRSRHDTC11001 SR513217A SRSRTR0425 SRSRHDTC11001 SR118870 SRSRTR0425 SRSRHDTC11001
Technical Evaluation EPA evaluated the adequacy of AK information specific to Waste Stream S R

- RH

- FBL.01 as described in CCP

- AK

- SRS

- 581, Revision 0, and CCP

- AK

- SRS

- 580, Revisions 1, 2 and 3 . EPA also evaluated WCPIP programmatic requirements related to Waste Stream S R

- RH

- FBL.01 characterization activities. (1) The scope of CBFO’s b aseline inspection request and waste stream de signation were examined for Waste Stream SR

- RH

- FBL.01 and found to be adequate (WCPIP, Section 3.0, p

. 13)

. 6 The purpose of a baseline inspection is to evaluate the adequacy, implementation and effectiveness of the technical pro cesses used to characterize WIPP

- bound TRU waste. EPA inspectors evaluated the scope of the inspection that DOE presented for clarity and focus. DOE is seeking EPA approval of SRS

- CCP’s approach. CCP implemented waste characterization processes to characte rize RH TRU debris (S5000) Waste Stream SR

- RH

- FBL.01, as described in the AKSR and Radiological Characterization Report. EPA reviewed CBFO’s scope and agreed that it is limited to Waste Stream SR

- RH

- FBL.01, as characterized using the approach presented

6 The WCPIP references are examples and are not meant to be an exhaustive list. Many of these requirements are discussed in several places within the WCPIP.11

in CCP

- AK

- SRS

- 581, Revision 0

. The s cope of DOE’s baseline inspection request laid out SRS

- CCP’s RH waste characterization approach in sufficient detail.
The WCPIP defines the waste stream as waste material that is (1) generated from a single process/activit y and (2) similar in material, physical form, and radiological properties. EPA examined the containers that were characterized according to the method described in CCP

- AK

SRS

- 581, Revision 0 , and described in CCP

- AK

- SRS

- 580, Revisions 1, 2 and 3, to determ ine whether the waste stream was adequately defined. The AKSR (Revision 3) states that the waste stream is currently composed of nine 7 containers that originated at the FB

- Line and were generated and packaged between January 1975 and December 1984. Th e F

- Canyon was constructed at SRS in 1951

– 1953 and contains the FB

- Line, which began production of WG Pu in 1954 (References D020 and D035). T he FB

- Line functions were (1) conversion of dilute Pu solutions from the 221

- F Canyon Building into highly purified P u metal and (2) recovery of WG Pu from scrap produced in the FB

- Line and shipped to SRS. Five processing operations took place along the FB

- Line: cation exchange, precipitation filtration, drying, reduction and finishing (References C021, C025, C027 and C0 28). The waste stream was generated by m aintenance and routine housekeeping operations that included sump cleaning, glovebox and equipment (e.g., furnace, hydraulic lift) repair, filter replacement , cabinet window and glove changeout, filter repair, cabine t sweepings, sump cleanouts, cabinet wipedowns, spill/leak cleanups, absorption of liquids, and other activities (References C021, C022, C026, C031, C032, C056, C067, C071, D035 and D037) . Waste generated by these activities included plastics, personnel pr otective equipment, routine laboratory and job control waste, rubber gloves, and metals and floor sweepings. This produced l ow
- level , CH, and RH TRU waste s that were not intentionally segregated by process area. CH TRU debris generated by FB

- Line operation s are in Waste Stream SR

- W027

- FB

- Pre86C, and RH TRU debris are in Waste Stream SR

- RH

- FLB.01. Other nuclear material was processed in the FB

- Line in addition to WG Pu (Reference CCP

- AK

SRS

- 2, Revision 13) . O ccasional ―months

- long‖ campaigns were conducted to produce special isotopic blends, including mixtures that were elevated in 240 Pu. Scrap recovery campaigns also processed 242 Pu, 241 Am, curium

- 244 ( 244 Cm) and 240 Pu oxide, as well as Lawrence Livermore mixed oxide and Hanford oxide scrap. Special recove ry accounted for approximately 15% of the FB

- L ine operations in the 1970s and consist ed of various ―special isotopic composition‖ materials

. The FB

- Line occasionally managed resin waste that potentially contained fission products that were not adequately r emoved during early processing activities (References C021, C026, C027, C032, D013, D020, D033 and D037)

. The AKSR and related source documents indicate that Waste Stream SR

- RH

- FBL.01 was generated from the same general processes as the previously approv ed CH Waste Stream SR

- W027

- FB

- Pre86

- C, from which the RH containers were segregated. EPA evaluated the radiological and physical compositions of drummed waste [Item (7)] and found them to be adequately defined for radiological and physical aspects. EPA’s a nalysis showed that the

7 SNL

- CCP was unable to develop scaling factors for one of the nine drums it presented initially; therefore, most documentation pertaining to Waste Stream SR

- RH

- FBL.01 and the rest of this report describe the waste stream as containing eight containers.12

selected drums are traceable to the FB

- Line operations [Item (12)]. Based on this information, EPA determined that the waste stream is adequately defined. (2) The Certification Plan, including a description of the waste characterizatio n process, was examined and found to be complete and technically adequate ( WCPIP , Section 3, pp. 14

– 15). The Certification Plan is presented in CCP

- AK

- SRS

- 582, Revisions 0 and 1. The WCPIP states that the Certification Plan must describe the process for c ertification of the waste stream, including a description of the characterization methods selected (WCPIP, Section 4.1) and AK qualification method(s) (WCPIP, Section 5.0). The WCPIP requires that the Certification Plan include, at a minimum, the following : Description of AK qualification and/or characterization methods selected to meet the DQOs, including the justification for the selection of the methods Description of the q uality a ssurance o bjectives for the selected methods Detailed description of any characterization and testing method not included in the WCPIP; the description of the method must be sufficient to allow for CBFO approval prior to implementation of the method Summary of the program documents to be prepared during the characterization and /or qualification methods selected for the waste stream
EPA reviewed t he Certification Plan to evaluate compliance with these document requirements, as well as the waste characterization requirements consolidated in the WCPIP from 40 CFR Part s 191 (Subpar ts B and C) and 194 and the WIPP Land Withdrawal Act ( LWA ) (Public Law 102

- 579). EPA found that the plan included the necessary components but required revision to clarify statements and make the content technically accurate. Revisions identified by EPA in cluded, but were not limited to: Removal of unnecessary language pertaining to DQOs and AK a ccuracy, if AK is not used to satisfy the DQO Clarification of the confirmatory testing plan contents and approach Clarification of waste stream size and generat ion date
SRS

- CCP revised the Certification Plan to address EPA concerns (CCP

- AK

- SRS

- 582, Revision 1 ). Notification to EPA when formal revisions of the Certification Plan are available is a T2 change. Substantive modification(s) that have the potential to affect the characterization process are a T1 change . (See Table 1

. ) EPA suggests that SRS

- CCP RH AK personnel discuss with EPA any significant contemplated changes with the potential to affect characterization outcome. This will ensure that SRS

- CCP does no t take actions that may jeopardize SRS RH approval.13

(3) The waste qualification pathway was identified and the selected approach and documentation were adequate (WCPIP, Figure 2, p.15 , and Section s 5.0

– 5.4).
40 CFR 194.24(c)(3)

– (5) state s that a system of co ntrols must be implemented to characterize waste components, and that this system must comply with quality assurance (QA) requirements found at 40 CFR 194.22. If AK is used to quantify components, its use must also comply with §194.22, which states that da ta collected prior to implementation of the WIPP

- specific QA program must be qualified by peer review, corroborating data, confirmatory testing, or demonstration that a QA program equivalent to American Society of Mechanical Engineers (ASME) NQA

- 1 requirem ents was in place at the time of characterization. EPA’s characterization requirements in 4 0 CFR 194.24 are presented in Figure 1 , generated by EPA

.

Figure 1
. Characterization and Qualification Process * AK data must be qualified if used to quantify parameters [ § 194.24(c)(3)]

Yes No

Qualification not required Qualify by Peer

Review, Equivalent QA, Confirmatory Testing, or Corroborating Data AK NDA, DA, or

DTC VE or RTR WDS Other, includ ing programmatic controls System of Controls to Characterize Waste [40 CFR 194.24(c)(4)]

Are data obtained under approved QA program?* [§194.24(c)(3), (5)]14

The system of controls used to characterize waste includes: AK for waste stream determination, defense determination, SNF, and HLW; Radiological characterization: radiological composition [nondestructive assay ( NDA)]; RTR: physical composition; WIPP Waste Data System (WDS) (data transfer); and Programmatic controls, including development of the appropriate plans and documents.
SRS

- CCP used the ISOCS system and CH NDA data to develop scaling factors for DTC. B ecause EPA had not previously approved the ISOCS, SRS

- CCP prepared a Test Plan (CCP

- AK

- SRS

- 585, Revision 0) to support this system, discussed in Section 8.2 of this report. EPA examined the qualification approach and approved its use for this SRS RH debris waste stream. The RTR system used by SRS

- CCP was previously approved by EPA, as was the WDS system. The characterization and qualification pathways used by CCP are adequately defined. The Test Plan and Radiological Characterization Report are evaluated in Section 8.2 of this report

. (4) Example n onconformance d ocumentation and d iscrepancy r esolution s were examined and found to be adequate (WCPIP, Section 3.4.2.3, p. 24).
S RS

- CCP provided one example , Nonconformance Report ( NCR) No. NCR

- RHS RS

- 2940

- 11, that segregated ―nonconforming‖ container No. SR504196 because drum

- specific radionuclide scaling factors had not yet been developed (CCP

- AK

- SRS

- 581, Revision 0 ). The NCR was adequately prepared.
SRS

- CCP referenced two discrepancy resolution (DR) documents i n the AKSR: DR001 and DR008 (CCP

- TP

- 005, Revision 23, Attachment 11). DR001 dealt with discrepant dates for the drum culvert limit change from 0.1 curie ( Ci ) per package to 0.5 Ci per drum. DR008 addressed erroneous application of the ignitable and reactiv e hazardous waste numbers based on the presence of calcium. EPA also examined DR documents for the analogous CH Waste Stream SR

- W027

- FB

- Pre86

- C ( References DR3 , DR3, DR6 and DR009). The DRs were adequately prepared. Notification to EPA of the availability of additional DR reports and NCRs is a T2 change. (See Table 1

. ) (5) The Acceptable Knowledge Procedure was examined and found to be adequate and appropriately implemented (WCPIP, Section 4.1, p p . 32

– 33).
CCP

- TP

- 005, Revision 22, integrated WCPIP, Revision 0 d, Appendix A, requirements. CCP

- TP

005, Revision 23, clarified what constitutes a formal record to resolve a CBFO Corrective Action Report (CAR) 11

- 043. Revision 23 was effective June 30, 2011, but Revision 22 was in place at the time the AKSR and prelimi nary supporting work were prepared. EPA accepts the use of CCP

- TP

- 005, Revision 22, as the appropriate revision for preparation of CCP

- TP

- 005 attachments, but future changes to any attachments or documents should be prepared in accordance with the version of CCP

- TP

- 005 in place at the time the changes are made.15

CCP

- TP

- 005, Revision 22, includes 15 attachments and requires development and maintenance of an AK tracking spreadsheet that presents a running compilation of drums within each waste stream. Attach ments 5, 9 and 12 are not relevant to EPA’s inspection. SRS

- CCP prepared Attachments 1, 2, 3, 4, 6, 7, 8, 11, 13, 14 and 15 for Waste Stream SR

- RH

- FBL.01. Attachment 1 was adequate. Adequate examples of Attachments 2 (Reference C018) and 3 were provided. Attachments 6 and 7 are addressed under Item (7) below . Preparation of Attachment 10 was not yet required for this waste stream. Attachment 11 is the DR form and is addressed in Item (4), and Attachment 12 is addressed in Item (6). Attachment 13 is adequa te and AK accuracy (Attachment 14) is addressed under Item (11). Attachments 4, 8 and 15 are discussed below.
Attachment 4 did not include the ―U‖ AK source documents cited in the r adiological c haracterization report. SRS

- CCP prepared a revised source doc ument list (Attachment 4) in accordance with CCP

- TP

- 005, Revision 23, that included these missing references. Also, CCP

- TP

- 005, Revision 23, clarified CCP’s document presentation and retention practices. Only those documents cited in the AKSR are presented in the AKSR reference list. Attachment 4 includes all references in the AKSR reference list as well as other references examined, but only those source documents cited in the AKSR will be placed in CCP Records. References examined and identified by CCP bu t not cited in the AKSR will not be available through CCP Records. Original records that were obtained from sites will be retained at the generator sites. References created by CCP, such as Attachment 3, will be retained as CCP QA records. While it is unde rstood that these changes to CCP

- TP

- 005 are meant to clarify the document presentation and records processes, EPA is concerned that this may encourage sites to present fewer references in the AKSRs, reduce the number of references cited in Attachment 4, an d limit access to cited references. EPA expects CCP to maintain Attachment 4 as a thorough and complete listing of all pertinent documents examined for a waste stream or group of waste streams, including references presented in radiological characterizatio n reports, regardless of whether those references are presented on AKSR reference lists. Regardless of who retains supporting documents, EPA expects CCP to be able to provide a copy of any reference included in Attachment 4 at EPA’s request and to do so in a timely manner, i.e., during the course of an inspection. EPA views the AK process as an important system of controls, and documentation of successful AK source document acquisition and review is a critical aspect of the AK process. CCP implemented a n ew approach to documenting drums within each waste stream. Attachment 8 will now contain all drums identified at the time of AKSR approval but will not be updated as in the past. Instead, SRS

- CCP will generate Add Container Memoranda that document the addi tion and removal of containers from the waste stream and will place them in a single source document in the AK record. Therefore, Attachment 8, associated Add Container Memoranda, and the AK Tracking Spreadsheet together provide the full drum history and c urrent waste stream inventory. SRS

- CCP has not yet prepared an Add Container Memorandum for Waste Stream SR

- RH

- FLB.01, so Attachment 8 and the AK Tracking Spreadsheet adequately document the drum inventory. Attachment 15 is the CSSF. The completed form p repared by SRS

- CCP indicates that all of the characterization information, including program management, process information, waste16

generation, handling and waste management, apply equally to Waste Streams SR

- RH

- FBL.01 and SR

- W027

- FB

- Pre86

- C. The CSSF also states that, although the combined assay data for CH drums were used to develop estimated RH radionuclide weight percentages, the actual percentages for each RH container would be determined by assay. These RH and CH waste streams will be characterized us ing different assay systems, and the AKSR states that the radiological information it presents is ―an estimate of what is to be expected once the radiological characterization method is implemented.‖ See Item (7) for additional information about the radiol ogical characteristics of Waste Stream SR

- RH

- FBL.01. Attachment 15 is adequate. Notification to EPA when the abovementioned attachments are revised and updated is a T2 change. Notification to EPA when Add Container Memoranda have been prepared is a T2 cha nge. Notification to EPA upon completion of revisions to AK procedures (including CCP

- TP

005 and nonconformance and corrective action procedures) is also a T2 change. (See Table 1.) (6) The Acceptable Knowledge Summary Report was examined, along with the refe rence list and associated source documents, and found to be adequate (WCPIP, Section 4.1, p. 31). EPA reviewed the AKSR (CCP

- TP

- 005, Revision 23, Attachment 12) and found it to be deficient in several areas, including:
S upport for radiological character ization I dentification of processes performed in the FB

- Line that affect the radiological characteristics of the waste stream I dentification of the waste stream size and waste generation dates versus waste packaging dates E xplanation of the waste material parameter calculations Description of radiological characteristics and origin of the observed isotopic distribution Presentation of qualification and characterization processes in AKSR, Section 6 Historic waste generation and management information
SRS

- C CP revised the AKSR (Revisions 2 and 3) to address EPA’s concerns. CCP

- AK

- SRS

- 580, Revision 3, adequately addresses EPA’s concerns. Notification to EPA when additional revisions of the AKSR are available is a T2 change. Substantive modification(s) that hav e the potential to affect the characterization process are a T1 change. (See Table 1.) (7) Descriptions of the radiological and physical properties of the waste stream were examined and found to be adequate following revision of the acceptable knowledge summa ry report (WCPIP, Section 3.0, p. 13).
Waste Stream SR

- RH

- FBL.01 consists of debris and includes heterogeneous materials from operations, maintenance and housekeeping. SRS

- CCP assigned Waste Matrix Code ( WMC ) S5400, Heterogeneous Debris, to Waste Stream S R

- RH

- FBL.01 , which differs from the17

WMC S5300 assigned to the companion (see footnote 1) CH waste stream. The AKSR states that the reassignment is based on review of container documentation specific to Waste Stream SR

RH

- FBL.01 that showed a wide r range of material s in RH waste than anticipated, based on CH information. This explanation is reasonable. According to DOE/LLW

- 217 , DOE Waste Treatability Group Guidance (DOE 1995, References M051, M052, M054 and M055), treatability is assigned based on volume per cent, but CCP

- TP

- 005, Attachment 6 (WMP Memorandum), does not include volumetric information

. SRS

- CCP stated that the RTR results provide verification of the assigned WMC, so the information is not presented in the Attachment 6 WMP Memorandum. This explana tion is reasonable.
SRS

- CCP indicated that the WMP estimates in the AKSR were based on the CH waste stream, but EPA questioned this because the data presented in the AKSR (Revision 1) reflect ed the RH

- specific WMPs presented in Attachment 6 and d id not mi rror the CH waste stream physical description

. SRS

- CCP revised the AKSR to clarify that AKSR Table 2 was created from Waste Stream SR

- RH

- FBL.01 RTR data that show the average waste stream composition is as follows:
59.5% i ron
- based m etals and a lloys 0 .6 0% a luminum

- based m etals and alloys <0.1% other metals 5. 67% other inorganic materials 1. 16% cellulosics 8 .7 0% rubber 24.38 % plastics < 0.1% other organic matri ces and inorganic matrices No soils or gravel The stream averages (by weight) 3 4

. 24 % organic waste and 6 5

. 77 % inorganic waste

. The physical composition of the waste stream is adequately defined.
The AKSR states that the FB

- Line produced WG Pu during the time of waste generation (1975

– 1984 ; References C021, C024, C027, C044, C045, C072, D008 and D037) . The standard weapons
- grade isotopic mix associated with the FB

- Line based on mass is:
92

– 94% by weight 239 Pu 5.8

- 6% by weight 240 Pu Less than 1% 238 Pu, 241 Pu, 241 Am (progeny of 241 Pu) and 242 Pu
The AKSR also states that th is distribution was verified by 1982

– 1986 mass spectrometry data (Reference C026)

. Interviews with FB

- Line personnel and site documentation confirm the production of WG Pu from 1971 to 1984 (References C025, C026, C029, C067 and D030)

. SRS

- CCP used the NDA results from 6 , 884 drums fr om associated CH Waste Stream SR

- W027

- FB

- Pre86

- C to develop an overall isotopic distribution that was applied to RH Waste Stream SR

RH

- SRS

- 581. Th e distribution by weight, shown in Table 5 of the AKSR, is reproduced below:

238 Pu (0.04%) 234 U (0.03%) 23 9 Pu (85.33%) 235 U (0.20%)18 240 Pu (6.64%) 238 U (5.31%) 241 Pu (0.24%) 232 Th (1.41%) 242 Pu (0.07%) 237 Np (0.14%) 241 Am (0.46%) 208 Tl (0.07%) 233 U (0.01%) 244 Cm (0.06%) The AKSR Table 5 distribution is not representative of WG Pu. EPA asked SRS

- CCP to explain this apparent discrepancy in light of statements in the AKSR that indicated only WG Pu was managed in the FB

- Line during RH waste generation. EPA pointed out that the SR

- W027

- FB

Pre86

- C AKSR identifies several month s
- long scrap recover y cam paigns that were performed in the FB

- Line and that contribute d radionu c lides other than WG Pu to the process lines. For example, the Recovery U nit in the FB

- Line processed materials ranging from 2% to 20% 240 Pu ; before 1980, the process material may have c ontained up to 20% 240 Pu

. A ―High Pu Isotope‖ campaign was performed as well, as was at least one campaign that dealt with higher quantities of 241 Am ( CCP

- AK

- SRS

- 2, Revision 13; References C21, C24, C27 and DR3 ). E PA identified other campaigns performed in the FB

- Line between 1972 and 1979 that processed material other than WG Pu including 242 Pu, 241 Am and 244 Cm (CCP

- AK

- SRS

- 2, Revision 13).
SRS

- CCP revised the AKSR to address these campaigns and explain the isotopic distribution presented in AKSR Table 5. Additionally, EPA obtained the original spreadsheets used to generate AKSR Table 5 and was able to reproduce the values presented in AKSR Table 5 and in CCP

- TP

- 005, Attachment 7. EPA concluded that the AKSR, as revised, adequately represents the physical and potential radiological composition of the RH waste stream

. (8) The waste stream information was examined and indicates that the waste stream does not con tain spent nuclear fuel or high

- level waste (WCPIP, Section 2.2.7, p. 12). The LWA prohibits the dis posal at WIPP of SNF and HLW as defined by the Nuclear Waste Policy Act (NWPA). The NWPA and DOE M435.1

- 1 8 state that SNF is ―fuel that has been withdrawn from a nuclear reactor following irradiation, the constituent elements of which have not been separat ed by reprocessing...

. [However ,] test specimens of fissionable material irradiated for research and development only, and not production of power or plutonium, may be classified as waste, and managed in accordance with the requirements of this Order when it is technically infeasible, cost prohibitive, or would increase worker exposure to separate the remaining test specimens from other contaminated material.‖ The NWPA defines HLW a s ―the highly radioactive material resulting from the reprocessing of spent nu clear fuel, including liquid waste produced directly in reprocessing and any solid material derived from such liquid waste that contains fission products in sufficient concentrations, and other highly radioactive material that the commission, consistent wi th existing law, determines by rule requires permanent isolation.‖
The AKSR states that Waste S tream SR

- RH

- FBL.01 consists of debris generated during Pu separation and purification processes for weapons manufacturing. The Pu was recovered from Pu

- nitrate solutions from various sources, including scrap delivered to SRS from other DOE

8 DOE M435.1

- 1 is DOE’s Radioactive Waste Management Manual.19

facilities and SNF rods. Two distinct operations are associated with the recovery of Pu from SNF: the plutonium/uranium extraction (PUREX) process and production of WG Pu from the resulting Pu

- nitrate solution. Waste produced during the PUREX stage is HLW and contains nearly all of the fission products that were in the SNF (References D016 and D035). PUREX process waste is not included in Waste Stream SR

- RH

- FBL.01. Waste produce d during the Pu

- production stage is the subject of this review and is not HLW; it was not produced directly from reprocessing the SNF and it does not contain high concentrations of fission products.
The F

- Canyon as a whole did manage SNF and generate HLW while processing SNF to recover Pu. Waste Stream SR

- RH

- FBL.01 contains FB

- Line debris from operations and maintenance associated with processing and purifying WG Pu metal. Fragments of SNF are not present in the debris, so the waste stream does not contain SNF. Nearly all of the fission products were removed from the Pu

- nitrate solution before it entered the FB

- Line, and Pu

- production wastes were never managed as HLW; therefore, Waste Stream SR

- RH

- FBL.01 does not contain HLW (References D016 and D035). The PUREX process wastes are not included in Waste Stream SR

- RH

- FBL.01. (9) The waste stream information was examined and indicates that the waste stream has defense pedigree (WCPIP, Section 2.2.7, p. 12).
TRU waste must be defense

- related in order to qualify fo r disposal at WIPP. The scope of this inspection is limited to the debris waste produced during Pu

- production operations and maintenance activities in the FB

- Line

. The FB

- Line mission since 1954 was to produce WG Pu for use in atomic weapons manufacturing (Reference D020). Defense nuclear materials production is one of the activities listed in the NWPA and, therefore, waste produced by activities in the FB

- Line are defense

- related in origin. As discussed in Item (7), the FB

- Line periodically participated in special recovery campaigns and may have produced non

- WG Pu. Some of these campaigns were for other defense

- related research and development activities. According to DOE, when any defense

- related and nondefense

- related wastes are comingled and cannot be se parated, these materials can be classified as defense waste. Therefore, Waste Stream SR

- RH

- FBL.01 has a defense pedigree (References D013, D016, D029, D035 and D054 ) (10) The Waste Stream Profile Form and attached Characterization Reconciliation Reports were e xamined and found to be adequate (WCPIP, Section 3.4.2.1, p. 22).
SRS

- CCP provided EPA with t he draft WSPF, CRR, and Characterization Information Summary (CIS) on July 26, 2011. The WCPIP explicitly lists the required contents of the WSPF and the CRR

. The WCPIP does not require the CIS; however, SRS

- CCP has elected to combine the once
- separate EPA and New Mexico Environmental Department WSPFs. Therefore, a CIS must be prepared and may be used in conjunction with the WSPF to meet all of the EPA requirements as documented in WCPIP. A Summation of Aspects accompanies the CIS; SRS

- CCP provided it to EPA on August 30, 2011. EPA examined the draft documents and found that some revisions were necessary. The draft WSPF initially provided to EPA had been adapted f rom a WSPF for a different waste stream and required revision to correct all of the site and waste stream references. The WSPF also did not20

list the BDRs supporting waste stream characterization (as required by the WCPIP), instead referencing the CIS. The draft CIS, however, did not include the DTC BDRs. SRS

- CCP revised the CIS to include the DTC BDRs. The WSPF, CIS and CRR are draft documents and , therefore , do not include the Site Project Manager ( SPM ) signature and date. T he revised draft WSPF and CIS an d the draft CRR are complete and adequate. Notification to EPA of the availability of the final WSPF, CIS, CRR and any revisions to these documents and their attachments (e.g., Summation of Aspects) are T2 changes . (See Table 1 .) (11) The AK a ccuracy r eport and Correlation and Surrogate Summary Form w ere examined and found to be adequate (WCPIP, Section 4.1, p. 30 , and Section 3.2.2, p p
. 17

– 19). EPA examined the draft AK accuracy report and found that it initially di d not adequately address the following WCPIP requirements: AK accuracy will be determined by assessing the percentage of waste containers that require reassignment to a new Summary Category Group or new waste stream based on the reevaluation of AK or on o btaining testing, sampling and/or analysis data. It will also identify the percentage of containers for which there are significant discrepancies in radionuclide information between the AK record and measured values. Therefore, EPA expects that the AK ac curacy evaluation will include, among other evaluations, a comparison of the measured radionuclides and those expected based on AK. The AK accuracy report for Lot 1 of Waste Stream SR

- RH

- FBL.01 did not initially include an evaluation of the radionuclide di stribution. EPA discussed this with SRS

- CCP representatives, who revised the accuracy report to indicate that all eight containers are consistent with the anticipated radionuclide composition. A few other clarification revisions were also necessary to br ing the AK accuracy report into full compliance with the WCPIP. As discussed for the Certification Plan in Item (2) above , AK accuracy does not evaluate whether the specific DQOs were met, and discussion of AK accuracy in terms of the DQOs gives the impres sion that AK is used to meet all of the DQOs. Also, the AK accuracy report needed revision to clarify that not all of the AK was qualified. EPA discussed these issues with SRS

- CCP representatives, who revised the AK accuracy report to remove reference to t he DQOs and to clarify that not all of the information in CCP

- AK

- SRS

- 502 was used to qualify AK.
SRS

- CCP provided a revised draft AK accuracy report that reflects those changes and is adequate. Notification to EPA when AK accuracy reports are completed, p repared annually at a minimum, is a T2 change . (See Table 1 .)
Waste Stream SR

- RH

- FBL.01 consists of RH containers that were originally classified as CH Waste Stream SR

- WO27

- FB

- Pre86

- C. Assay data from this CH wast e stream were used to estimate the radionuclide distribution in the AKSR. Therefore, a CSSF was required. EPA reviewed the CSSF and found it to be adequate. Notification to EPA of revision to the CSSF21

(CCP

- TP

- 005, Attachment 15) or preparation of an additi onal CSSF is a T2 change. (See Table 1 .) (12) Drum data are adequately traceable and are in the AK r ecord (WCPIP, Sections 3.4.4.1, p. 20; 3.4.2.2, p. 23; and 4.1, pp. 29

– 34).
As discussed in Item (1), Waste Stream SR

- RH

- FBL.01 was produced and packaged during normal FB

- Line operation and maintenance activities from 1975 to 1984. The drums were then stored at the Radioactive Waste Burial Grounds. SRS personnel were required to complete the Radioactive Waste Burial Grou nd records (BGRs) for each drum. The BGRs included such information as the assigned unique File Sequence Number (FSN), the generating facility, waste volume, isotopic quantity, and a brief description (References P009 and P010). The BGRs are the earliest r ecord of the drums in Waste Stream SR

- RH

- FBL.01. They clearly indicate that the drums originated in the FB

- Line but do not provide any further information about the specific activities that produced each waste container.
EPA reviewed the records and deter mined that the drums proposed for emplacement in the WIPP facility as Waste Stream SR

- RH

- FBL.01 are traceable from the FB

- Line to the burial ground and more recently through SRS prescreening and SRS

- CCP characterization. Table 3 presents a summary of the t raceability information reviewed. The drums continued to be referenced by their FSNs throughout repackaging and characterization. All information summarized in Table 3, except for the two NCRs, is in the AK record as Reference M052. (13) Acceptable k nowledge t raining was examined and found to be adequate (WCPIP, Section 4.1, p. 32). The WCPIP requires that characterization personnel responsible for compiling AK, characterizing RH TRU waste streams using the AK process, and assessing the AK characterization sh all be qualified and trained to:
The WCPIP The characterization program nonconformance and corrective action process Site

- specific training relative to the site’s waste streams (e.g., current AKSRs) Determining the radiological contents of individual cont ainers Through interviews and discussions, EPA was able to conclude that the SRS

- CCP AK Experts (AKEs) are current with respect to the training requirements listed above. Table 4 lists the objective evidence that EPA reviewed documenting that the AKEs ass ociated with Waste Stream SR

- RH

- FBL.01 are adequately trained to the elements listed above.22 Table 3
. Summary of Traceability Analysis Drum No. BGR Date Drum Timelines SR510588 4/10/80 Vented and p urged 1/21/04 RTR q uick

s creen 6/ 19/04

– prohibited items found Repackaged

7/9/08 CCP RTR

4/27/11 (BDR SR4RTR0173)
SR504233 11/13/75 RTR q uick s creen 11/1/03 and 6/28/08 Vented and

p urged 11/3/03 Vented and

c losed 7/2/08 CCP RTR

4/27/11 (BDR SR4RTR0173) SR526627 12/11/84 RTR q uick s creen 5/23/04 and 4/9/06 Repackaged

11/9/06 CH VE 11/9/06;

NCR

- SRS

- 1137

- 06 for wrong WMC

– resolution to u se a s i s CH r adioassay,

isotope list, MGA analysis 3/2/07 Headspace g as

d rum s ample 3/8/07 6/8/09 NCR

SRS

- 0533

- 09 for s urface d ose r ate 9 > 200 mrem/h r

– r eject reassign as RH CCP RTR

4/26/11 (BDR SRSRTR0425)

SR118870 3/13/80 RTR q uick s creen 5/31/06

– prohibited items found Transferred to

F

- Canyon 10/10/06 Repackaged

10/28/06 Repackaged

7/1/08 and split into 3 drums: 118870 (only RH drum), 118870A, 11 8870B 118870B

Repackaged 1/9/10 and split into 2 drums : 118870B, 118870C (both CH) CCP RTR 4/26/11 (BDR SRSRTR0425)

9 In this report the term dose rate is expressed in mrem/hr or mR/hr, which, while technically incorrect, are commonly used by DOE and CCP TRU generators. These terms are used throughout this report for convenience.23 Table 4
. Objective Evidence of Training for AK Personnel

Name WCPIP Nonconformance and Corrective Action Process (CCP

- QP

- 005) Site

- Specific

Training Determining

Radiological Contents of Containers Current

Revision of CCP

- TP

- 005

Mark Doherty Qual Card Qual Card CCP Document Control Screenshot Briefing R2 3 : Briefing and Att

. 5, 6 , 7, 8, 15 Jason Montoya Qual Card Qua l Card Email Statement Briefing R2 3 : Briefing and Att

. 1, 4 Steve Schafer Qual Card Qual Card Email Statement Briefing R2 3 : Briefing
(14) Data q uality o bjectives were evaluated and found to be adequately met (WCPIP, Section 3.4.2, p. 22).
The WCPIP identifi es the following DQO s that must be addressed: Defense Waste, HLW and SNF Determination (Regulatory Basis: LWA) : This is required to ensure that the waste stream was generated by atomic energy defense activities, is not HLW, and is not SNF. These are addre ssed in CCP

- AK

- SRS

- 580, Revision 2, and CCP

- AK

- SRS

- 582, Revision 1 , as discussed in Items (9) and (8) above. Radioactive Properties (Regulatory Basis: LWA, EPA Certification of the WIPP) :
TRU Waste Determination: Waste must contain more than 100 nanocuri es (nCi) of TRU isotopes per gram of waste

. RH Waste Determination: Surface dose rate must be equal to or greater than 200 mrem/hr and less than 1, 000 rem/hr. Activity Determination: The total waste inventory can be no more than 5.1 million Ci of RH TRU; activity limit per canister is 23 Ci per liter; and all radionuclides important to release calculations must be tracked

. These three DQOs are addressed in CCP

- AK

- S RS

- 5 81 , Revision 1 , as discussed in Section 8.2 below. Physical Properties (Regulatory Bas is: EPA Certification of the WIPP) : Liquids: The absence of liquids in excess of 1% must be confirmed

. Physical Form: The physical form of the waste to delineate the waste stream as required by the final certification rule must be determined

. These two D QOs concerning the waste’s physical form and the presence of liquids are discussed in Items (7) and (12) above and documented in RTR BDRs SR4RTR0173 and SRSRTR0425.24

EPA determined that the documents cited above supported that all DQOs were achieved.
Summ ary of Acceptable Knowledge Findings and Concerns
The EPA evaluation team did not identify any AK

- related findings or concern s. T here are no open issues related to AK resulting from this inspection. Tier 1 Acceptable Knowledge Changes The following AK c hanges are T1 changes: Any new RH S3000 or S4000 waste stream Any new RH S5000 waste stream that does not have a companion (see footnote 1) CH waste stream Substantive modification(s) to CCP

- AK

- SRS

- 580 or CCP

- AK

- SRS

- 582 that have the potential to affect the characterization process Tier 2 Acceptable Knowledge Changes The following AK changes are T2 changes: Any new RH S5000 waste stream that does have a companion (see footnote 1) CH waste stream
Notification to EPA is required :

o Upon completion of r evisions to CCP

- AK

- SRS

- 580, CCP

- AK

- SRS

- 582, CCP

- TP

005, or nonconformance and corrective action procedures that require CBFO approval

o Upon completion of revisions to any CCP

- TP

- 005 attachments, including when Attachment 4 is generated to reflect the update d AKSR Source Document Reference List

o When the final or revised WSPF, CIS, CRR and related attachments are available and upon completion of any subsequent revisions to these documents

o When AK accuracy reports are completed, prepared annually at a minimum

o When Add Container Memoranda have been prepared

o When additional discrepancy resolution reports and nonconformance reports have been prepared Proposed Baseline Acceptable Knowledge Approval Based on this inspection, EPA proposes to approve the AK process evaluated during this baseline inspection. The approval is limited to RH TRU debris waste streams that have25

companion (see footnote 1) CH debris waste streams. After EPA finalizes the SRS

- CCP RH waste characterization approval, a ny additional RH waste res ulting from characterization of the associated CH waste stream may be added to Waste Stream SR

- RH

- FBL.01 provided specific conditions are met , as discussed in Section1.0 above. Also , additional waste streams , beyond the waste stream that EPA evaluated as p art of the baseline inspection , may be disposed of at the WIPP provided that they are debris waste streams and have a companion (see footnote 1) CH waste stream. W hen SRS

- CCP characterizes for disposal any new RH TRU debris waste stream that does not have a companion (see footnote 1) CH waste stream or any RH TRU waste from the other two SCGs (solids and soils and gravel), EPA approval as a T1 change is necessary.
8.2 Radiological Characterization Waste Characterization Element Description
EPA evaluated t he radiological characterization of SRS

- CCP RH Waste Stream SR

- RH

- FBL.01 in terms of its technical adequacy, as supported by the program’s documents, procedures and controls, and the knowledge and understanding of the personnel involved in the RH waste charac terization program. During this RH inspection, the EPA inspection team evaluated the following elements of the SRS

- CCP radiological characterization program:
ISOCS and DTC measurements made at SRS in June and August 2011, respectively Development of DTC correlations for 55

- gallon drums based on MCNP5 modeling of the drum’s gamma dose rate using a one
- Ci source of 241 Am, assumed to be the main contributor to the dose Derivation of radionuclide scaling factors using isotopic ratios found through ISOCS assay s and isotopic distributions from historical assays of W aste S tream SR

- W027

- FB

Pre86

- C Representativeness and technical adequacy of the analytical data used to support the scaling factors
Each of these is discussed in the sections that follow.
Documents Reviewed
All SRS

- CCP RH radiological characterization documents that EPA reviewed to support this inspecti on are listed in Attachment A.
Technical Evaluation The EPA inspection team evaluated the following aspects: (1) The overall radiological characteriz ation process and its documentation were evaluated and found to be adequate.26

The radiological characterization process for Waste Stream SR

- RH

- FBL.01 differs from the RH characterization that EPA has observed at other CCP sites. Typically, the RH character ization process has included the collection and laboratory analysis of representative waste samples to determine the waste’s radionuclide composition (isotopics). Isotopic information forms the basis of radionuclide

- specific scaling factors, i.e., technica lly supported relationships between specific radionuclides and an easily measured gamma

- emitting radionuclide, typically 137 Cs. Application of the DTC process requires scaling factors to determine the radionuclide contents of each waste container.
The SR S

- CCP RH radiological characterization program incorporated five main aspects: Historical information (AK) for CH Waste Stream SR

- W027

- FB

- Pre86

- C , as summarized in CCP

- AK

- SRS

- 580 and associated source documents Development of scaling factors for 239 Pu, 24 0 Pu and 241 Pu 10 to 241 Am based on ISOCS measurements Development of scaling factors for 238 Pu , 233 U, 234 U, 238 U, 137 Cs and 90 Sr based on past assays of the RH waste stream’s CH counterpart, Waste Stream SR

- W027

- FB

- Pre86

- C MCNP5 modeling to determine the a mount of 241 Am in each drum Direct exposure rate measurements (DTC) of each waste drum The EPA inspection team prepared a flow diagram to accurately reflect this process, shown in Figure 2 . EPA determined that the radiological characterization process fo r Waste Stream SR

- RH

- FBL.01 was technically adequate and appropriately documented. Any new RH waste stream not approved to date or the addition of containers to Waste Stream SR

- RH

- FBL.01 that requires changing the established process of radiological charac terization from what is documented in CCP

- AK

- SRS

- 581, Revision 1, is a T1 change. (See Table 1 .) Any change to CCP

- AK

- SRS

- 581 that requires CBFO approval is a T2 change. (See Table 1 .)

10 EPA does not usually evaluate 241 Pu because it is neither a TRU radionuclide nor a WIPP

- tracked radionuclide. However, 241 Pu accumulates over the time period of i nterest to this inspection, due to its 14.4

- year half life, and it is the progenitor of 241 Am, which is the denominator of the scaling factor for all radionuclides.27

Figure 2
. Flow Diagram of the Characterization Process for SR
- RH
- FBL.01

Yes

Yes No No Select 12 drums from CH Waste Stream SR

- W027

- FB

- Pre86

- C. Each drum should have > 1 Ci Am

- 241 and be within the operating range of the ISOCS (SRS

- RH

585 & SRS Submittal #061611)

Select an additional drum for each failed drum

Failure to prove concept for Pu
- 238: Pu

- 238 cannot be characterized based on ISOCS data Model dose rate u sing MCNP5 at 1 m from the mid

- height elevation of a drum containing a 1

- Ci Am

- 241 source uniformly distributed. This is done for each drum using its calculated waste density (SRS

- RH

- 43 & SRS

- RH

- 44)

Determine Am

- 241 content of each drum 

### Proof of Concept Execute DTC

No

Container

- specific values for 10 WIPP

- tracked radionuclides, Pu

- 241 and U

- 235 (BRD Nos. SRSRHDTC11001 & SRSRHDTC11002) 

### 1

3

Measure the isotopics for each RH drum on the ISOCS to determine the ratio of Pu

- 239, Pu

- 240 and Pu

- 241 (SRS Su bmittal #061711)



### 4 Assumptions/Definitions

Scaling factor= (Activity of Radionuclide X)

. (Activity of Am

- 241) RH Waste Stream SR

- RH

- FBL.01 has an isotopic distribution equivalent to CH Waste Stream SR

- W027

- FB

- Pre86

- C All NDA measurements have been collected on WIPP

- approved NDA equipment and are valid, i.e., meet appropriate performance criteria and are of drums containing > 1 Ci Am

- 241 All ISOCS measurements are acceptable, i.e., meet the performance criteria and are sig nificantly above the system’s DL to allow their use. Use AK data to derive Am

- 241 based scaling factor for Pu

- 242 and Pu

- 239 from their average ratio in the subset of SR

- W027

- FB

- Pre86

- C drums that contain more than 1 Ci of Am

- 241 (SRS

RH

- 41) Sr

- 90 is no t measured. It is reported in 1:1 ratio with Cs

- 137. This ratio was carried through as the Sr

- 90/Cs

- 137 scaling factor (SRS

- RH

- 41)

U

- 234 is not measured. It is reported in 46.2:1 ratio with U

- 235. This ratio was applied to the U

- 235 MDA values to derive an upper estimate (SRS

- RH

- 41) 

### 2

Proof of Concept: ISOCS can be used to develop Am

- 241 scaling factors for Pu

- 239, Pu

- 240 and Pu

- 241 Are 90% of comparisons within a factor of 2? (Post

- Confirmation Test Memorandum) Are all values greater than 1.5 ti mes the system’s MDA? Are criteria for ISOCS met? Assay selected 12 CH drums on approved CH NDA instrument Assay selected 12 CH drums on ISOCS (CCP

- TP

- 139) Take 1 m dose rate reading at 0  ̊ , 90  ̊ , 180  ̊ and 270  ̊ for each drum in waste stream (BRD Nos. SRS RHDTC11001 & SRSRHDTC11002)

Average 4 readings to develop the average dose rate for each drum

Use scaling factors to determine the amount of Cs

- 137, Sr

- 90, U

- 233, U

- 234, U

- 235, U

- 238 and Pu

- 238 in each container Multiply the ratios of Pu

- 239, Pu

- 240 and Pu

- 241 to Am

- 241 by the Am

- 241 activity for each container Use AK data from CH stream to determine the average ratio of Cs

- 137, U

- 233, U

- 235, U

- 238 , and Pu

- 238 to Am

- 241 (SRS

- RH

- 41) 

### Develop Scaling Factors for RH Drums

Calculations & Results28

(2) Use of the In Situ Object Counting System to derive isotopic ratios (scaling factors ) was found to be correctly implemented and appropriatel y documented.
I n S itu O bject C ounting S ystem Description An ISOCS is a portable assembly consisting of a gamma detector, a cryostat, and supporting electronics. These components are installed on a moveable cart, which can be positioned in proximity to t he item being measured

— in this case, an RH waste drum. The ISOCS software contains predetermined geometries that can be applied to a variety of sizes and shapes in the field without moving the item. These aspects provide two important advantages for using the ISOCS in the field. First, the source

- to

- detector distance for a specific item is determined in the field based on the item’s external dose rate, allowing the user to optimize the measurement efficiency. When measuring a number of items, a user can ge t close to a low

- dose

- rate waste container and far from a high

- dose

- rate container with minimum adjustments, addressing potentially problematic issues like excessive dead time associated with RH TRU drums. Second, the predetermined geometries allow a user to essentially derive an efficiency calibration for each item in the field by matching field conditions with an established geometry without repositioning or manipulating the item. Because the system’s use is not tied to a specific waste configuration, th e ISOCS has considerable flexibility; i.e., the same unit could measure a 5

- gallon pail, a 30

- gallon drum, or a 55

- gallon drum with minor adjustments in the field. Limitations include background interferences from other radionuclide

- bearing items in the ar ea as well as typical measurement control issues.
I n S itu O bject C ounting S ystem Background An ISOCS instrument has never been used to assay WIPP

- bound RH TRU waste drums. Like other NDA instruments in CH programs, the ORTEC/ISOCS is not a direct charact erization method; it is used exclusively for obtaining the relative ratios of 239 Pu, 240 Pu and 241 Pu to 241 Am. To demonstrate the ISOCS capabilities, SRS

- CCP developed Test Plan CCP

- AK

- SRS

- 585, Revision 0, in which the results of drums that were assayed on an EPA

- approved NDA system would be compared to ISOCS results for the same radionuclides. Specifically, 12 drums from CH Waste Stream SR

- W027

- FB

- Pre86

- C that each contained at least one Ci of 241 Am and had been assayed on the Box Segmented Gamma System or the Segmented Gamma System 11 were assayed on the ORTEC/ISOCS. The ISOCS results were compared with the CH NDA values, and reasonable agreement between the measurements confirmed the ability of the ORTEC/ISOCS to obtain relative ratios of 238 Pu, 239 Pu, 240 P u and 241 Pu to 241 Am (i.e., develop scaling factors for these radionuclides). There was no ISOCS unit available for EPA to inspect during the August 2011 visit. EPA returned to SRS in December 2011 to inspect two different ISOCS units at SRS

- CCP, both loc ated in the E Area, Building 643

- 43E, adjacent to the Non Destructive Assay Box Counter

11 The Box Segmented Gamma System is the gamma component of the NABC . EPA had previously app roved both the box segmented and segmented systems for assaying CH TRU wastes at SRS.29

(NABC), in an area shielded by 55

- gallon drums of water. EPA observed the set up and execution of both ISOCS units, referred to as the ORTEC/ISOCS and the MCS /ISOCS, an d evaluated both units and their supporting documentation as described separately below. Tim Carlton operated both ISOCS units; the ORTEC/ISOCS was operated under the direction of Ray Dewberry, a Savannah River National Laboratory ( SRNL ) employee.
ORTEC/ In Situ Object Counting System
The ORTEC/ISOCS unit uses an older coaxial germanium detector with Canberra ISOCS software. It was used to develop scaling factors for all eight drums of Waste Stream SR

- RH

FBL.01 . SRS

- CCP stated that this is the only time t he ORTEC/ISOCS will be used in the WIPP program, and, accordingly, EPA’s evaluation of this instrument was retrospective (i.e., to assess it in terms of its ability to support only the data for the eight drums in Waste Stream SR

- RH

FBL.01 and not its futur e use )

. SRS

- CCP initially intended to use ORTEC/ISOC to develop scaling factors of 238 Pu, 239 Pu, 240 Pu and 241 Pu to 241 Am. Therefore, SRS

- CCP compared the ratios (scaling factors) obtained from the ORTEC/ISOCS with the previously preformed NDA assays. The scaling factor comparisons were deemed acceptable if 90% were within a factor of two, as established by SRS

- CCP and documented in CCP

- AK

- SRS

- 585, Revision 0. The scaling factor comparisons for 239 Pu, 240 Pu and 241 Pu were acceptable, and the scaling factor s for these radionuclides to 241 Am can be determined from ISOCS measurements. Only half of the 238 Pu ratios were acceptable, and 238 Pu did not meet the test criterion. Accordingly, the test failed to establish the ISOCS as a valid means of calculating the 238 Pu scaling factor. Therefore, the 238 Pu scaling factor for these eight RH drums must be established from the isotopic distributions of SR

- W027

- FB

- Pre86

- C, as discussed in Item (3) below

. EPA observed the unit’s operation and determined that it was tech nically adequate to collect data to support the development of radionuclide scaling factors for 239 Pu, 240 Pu and 241 Pu. The instrument had been calibrated prior to use in 2005, as documented in WSRC

- TR

- 2005

- 00431, Revision 0. Before collecting data for the se eight RH drums, SRS

- CCP conducted performance checks and backgrounds, evaluated them against established operational criteria, and recorded them in the ISOCS logbook. The system was operated in accordance with SRNL Procedure ADS

- 2460, although SRS

- CCP P rocedure CCP

- TP

- 139, Revision 3, was revised before the December 2011 inspection to include a provision for the ORTEC/ISOCS. All appropriate measurement controls were performed and documented in the ISOCS log book. Replicate testing was not performed for t he ORTEC/ISOCS unit. ISOCS values were documented in two batch reports, 12 MCS ISOCS Report, ISOCS DTC

- RH Waste Drums, SRS Submittal #061611 and MCS ISOCS Report, ISOCS DTC

- RH Waste Drums, SRS Submittal #061711

. T he ORTEC /ISOCS is not approved for assaying any additional containers, and future use of this instrument to characterize any RH TRU wastes is a T1 change . (See Table 1.)

12 The titles of these reports indicate that they document operation of the MCS/ISOCS, which is not the case; they document operation of the ORTEC/ISOCS.30

MCS/I n S itu O bject C ounting S ystem The MCS/ISOCS uses a high

- purity germanium (HPGe) detector with Canberra’s ISOCS/LabSOCS soft ware packages and is mounted on a cart like the ORTEC/ISOCS. EPA observed the unit’s operation and determined that it was technically adequate to collect data to support the development of radionuclide scaling factors for 239 Pu, 240 Pu and 241 Pu. The instru ment had been calibrated prior to use at Canberra Industries in 2010, as documented in ISOCS /LabSOCS Detector Calibration Report, ACK#67328, Detector Model BE5025, S/N 4480

. The calibration was verified at SRS in November 2011, as documented in ISOCS Calib ration Verification Detector #4480 . Operation of the MCS/ISOCS is controlled by SRS

- CCP Procedure CCP

- TP

- 139, Revision 4. Measurements on the MCS/ISOCS were not used as the measurement of record for any waste drums in this waste stream as of the date of th e December 2011 site visit, and EPA did not evaluate any BDRs or batch reports of MCS/ISOCS data. If future drums are discovered to be RH during the processing of CH Waste Stream SR

- W027

- FB

- Pre86

- C, EPA expects that these containers will be characterized using the MCS/ISOCS. No measurements of record have been performed to date on the MCS/ISOCS; therefore, if the first measurements of record are for Waste Stream SR

- RH

- FBL.01, EPA expects that batch reports or other documentation showing the first MCS/ISOC S measurements of record and the results of any performance testing done to support those measurements be provided when available

. Use of the MCS/ISOCS to provide any information other than the relative determinations of 239 Pu, 240 Pu and 241 Pu to 241 Am obs erved during this baseline inspection is a T1 change. (See Table 1.) Replicate Testing
- MCS/I n S itu O bject C ounting S ystem
T o obtain objective evidence on the precision of the MCS/ISOCS, EPA required SRS

- CCP to perform replicate measurements. Due to th e nature of the ISOCS equipment and the end use of the data it generates, EPA specified that SRS

- CCP assay a standard drum with measurable quantities of 239 Pu, 240 Pu, 241 Pu and 241 Am without changing the measurement configuration in any way between measure ments. This technique is designed to assess only the reproducibility (precision) of the ISOCS itself. 13 Precision is a quality associated with a set of measurements and refers to the way in which repeated measurements of the same quantity conform to each o ther. Precision is determined by the dispersion of the measurements around their central value. An instrument is precise if the set of measurements it generates for the same conditions is very reproducible. Because it was not possible to reproduce exactly the same conditions each time the ISOCS was set up and used, precision was defined in this context as the degree of agreement among a group of measurements of the same source for a particular application of the ISOCS unit . Specifically, a particular applic ation of the ISOCS unit was defined as once an ISOCS unit was set up at SRS and deemed ready to take valid measurements of RH waste containers, as specified by SRS

- CCP procedures. The ISOCS then measured an item of known value, i.e., a radionuclide standar d in a 55

- gallon drum that is traceable to the national standards base. The item had to contain sufficient quantities of 239 Pu, 240 Pu, 241 Pu and 241 Am to provide statistically significant values for these radionuclides

13 Inter o ffice Cor respondence from R. Gogliotti and P. Kelly to Ed Feltcorn , RE: Replicate Testing Protocol for System at SRS

- CCP Using a Standard Drum, November 18, 2011

.31

when the operators followed the same procedure as was used to assay the eight drums in RH Waste Stream SR

- RH

- FBL.01. Because an ISOCS was used to establish the ratio of Pu isotopes (excluding 238 Pu) to 241 Am, the parameter of interest was the ratio of radionuclide X to 241 Am , where X is 239 Pu , 240 Pu or 241 Pu. The MCS/ISOCS unit and the standard drum were set up in the same manner as the original eight RH drums in RH Waste Stream SR

- RH

- FBL.01. Six measurements were taken. Each measurement was of the same source in the same location without an y modifications to the system’s geometry. These measurements were used to derive three ratios: 239 Pu/ 241 Am, 240 Pu/ 241 Am, and 241 Pu/ 241 Am. The ratios were used to calculate the percent relative standard deviation (%RSD) according to the equation below:

W here:
s = measured standard deviation of the ratio Ci X /Ci 14 241 Am from each respective ISOCS device
n = number of replicates μ = known standard deviation of the ratio Ci X /Ci 241 Am from the standard drum Χ 2 0.05, n - 1 = critical value of the upper 5% tail of the one

- sided chi squared distribution with n - 1

degrees of freedom
On December 5

- 6, 2011, SRS

- CCP used the MCS/ISOCS to perform six replicate assays of a 55

- gallon drum containing 203.68 g Total Pu. The single drum contained 12 discrete WG Pu working re ference material (WRM) standards of varying gram values, all of which had been fabricated by LANL and were traceable to the national standards base. On December 6, 2011, EPA observed the operation of the MCS/ISOCS in the same configuration as was used for the replicate analyses, and SRS

- CCP supplied the replicate data to EPA on December 7, 2011. EPA evaluated the precision of the replicate data using the %RSD equation above, as summarized in Table 5. The replicate testing of the MCS/ISOCS met EPA’s acceptan ce criterion for precision of <14% (for six replicates) and provided sufficient objective evidence to support use of the ISOCS for the determination of radionuclide scaling factors.
Table 5
. MCS/ISOCS Replicate Data Run Number 239 P u/ 241 Am 240 Pu/ 241 Am 241 Pu/ 241 Am 1 7.28 1.31 13.2 2 7.56 1.41 13.9 3 7.66 1.44 13.9 4 7.56 1.40 13.8 5 7.69 1.54 13.9 6 7.81 1.48 14.3 Average Ratio 7.59 1.43 13.83 Standard Deviation 0.180 0.078 0.356 True Value 12.92 3.08 46.06 %RSD 1.39% 2.53% 0.77%

14 Activity can be expressed in Ci or radionuclide

- specific disintegrations.32

(3) Use of nondestructive assay data from CH Waste Stream SR

- W027

- FB

- Pre86

- C to develop scaling factors for uranium isotopes and fission prod ucts was found to be technically adequate and correctly documented.
SRS Waste Stream SR

- W027

- FB

- Pre86

- C is the CH equivalent of RH W aste Stream SR

- RH

FBL.01 , and all eight 55

- gallon drums in SR

- RH

- FBL.01 were originally generated and managed as part of the CH waste stream. They fell out of the waste stream when drum contact dose readings met or exceeded the contac t dose rate limits of 200 milliRoentgen per hour (mR/hr). As such, these drums are assumed to have the same ratios of radionuclides as the CH drums but in larger concentrations. This assumption is the basis for using historical CH assays to derive the rati os of 233 U, 234 U, 238 U, 137 Cs and 90 Sr to 241 Am. Approximately 6,900 CH assay records from SR

- W027

- FB

- Pre86

- C were available at the time of inspection. Of these assays, a subset of 251 assay records were selected , whic h are the only containers in SR

- W027

- F B

- Pre86

- C that contained over one Ci of 241 Am. This subset was used because it is assumed that they would most accurately reflect the distribution of radionuclides in the eight drums in the SR

- RH

FBL.01 waste stream. In this subset , the total quantity of e ach radionuclide was summed to represent the total quantity of that radio nuclide in the subset. When an assay did not have detectable levels of a radionuclide, the average minimum detectable activity ( MDA ) f or that radionuclide was applied to that sample. MDAs do not represent a sample’s true radionuclide concentration; however, their use allows an upper estimate of a drum ’ s content so as to not underestimate true averages because of the measurement system’s limitations. Only a handful of assays measured 23 4 U. To accurately estimate its average quantity, the average MDA of 235 U was applied at a ratio of 46.2 to 1 when no reported values existed. The total was divided by the number of assays ( 251 ), to develop the average quantity of each radio nuclide in the s ubset. The NDA system does not directly measure 90 Sr ; its contribution is inferred by assuming a 1

- to

- 1 ratio with 137 Cs. These values were then corrected for decay and 241 Am in

- growth to the reference date of March 9, 2007, which is the weighted average o f CH assays done between March 8, 2002, and December 11, 2008. The ratios of the average values of the uranium isotopes and fission products to the average 241 Am were then determined. These values served as the scaling factors for the respective radionucli des. (4) Computer modeling to develop the dose

- to

- curie correlation was evaluated and was found to be adequate.
SRS

- CCP used the MCNP5 computer code to develop DTC correlation for a 55

- gallon drum filled with debris waste and its external dose rate at one me ter . This was based on the assumption that a one
- Ci source of 241 Am was uniformly distributed within the drum and that the only significant gamma emitter in the drum was 241 Am. S pecifically, the contributions of e uropium

- 154 ( 154 Eu), cobalt

- 60 ( 60 Co) or ot her gamma emitters in the drum were negligible. This provided the container

- specific correlation of measured dose rate and 241 Am content to drum density. Two drums, Nos. SR512002 and SR526627, did not have poly

- liners, which was taken into account in MCNP5 modeling. Each drum’s MCNP5 results are documented in DTC Values and Gamma Sensitivity Studies , Calculation Package SRS

- RH

- 43. The use of any alternate scaling factor determination methods other than those documented in CCP

- AK

- SRS

- 581, Revision 1, is a T1 change. (See Table 1 .)33

(5) Execution and documentation of the dose

- to

- curie technique was assessed and found to be adequate. EPA observed the DTC technique on August 30, 2011, in the DTC alcove located in Area E, Pad 4, for Drum No . SR 526627. 15 The DTC process for the actual drums in the waste stream was perform e d on April 26 and 27, 2011, as documented in DTC BDR Nos. SRSRHDTC11001 and SRSRHDTC11002

. The SRS

- CCP DTC operators were Tim Carlton, Ron Whitson and Todd She pley, all three of whom were listed i n the current RH p rogram SRS list of qualified individuals ( LOQI ) dated August 16, 2011 . The next CCP trai nings for the three DTC operators ar e due in April 2013, May 2012 and April 2013

. The DTC personnel began by per forming the operational check on WEIGHTRONIX Scale No. 26738, which was last calibrated on August 15, 2011, and is due for recalibration in August 2012. SRS personnel weighed the drum , and CCP operators recorded the weight. The weights were recorded on the Measurement Control Report (CCP

- TP

- 50 4, Attachment 1) and summarized in the operational log book. DTC personnel performed the source checks for the Thermo Scientific Model FH 40 G Dose Rate Measuring Unit with FHZ 612 Probe (Serial No. 921) attached to P robe No. XC0677. This instrument is different from the unit FHZ612 (Serial No. 831) attached to Probe No. XC0673, which was used for the DTC measurements that were performed on SR

- RH

- FBL.01. This is because the calibration of the initial probe was due betw een the measurement and the witnessing of the process demonstration. SRS

- CCP replaced the instrument instead of recalibrating the detector. The daily source checks were preformed with a 60 Co sealed source with an activity of 1.1 Ci on the reference date M ay 1, 1996. The ambient background was measured , source checks were performed for the high and low ranges , and all measurements were recorded on the Measurement Control Report and summarized in the operational log book ; EPA inspectors received a copy of th e log book entry page. DTC personnel consulted CCP Operator Aid: OA

- SRS

- 0153, Revision 2, 8

- 30

- 11 , which listed tolerances for the t est d rum w eights, s cale e rror, o perational r anges for the Geiger Mueller Probes and acceptance criteria for the source check s. DTC operators took a background reading while all containers were in a shielded position. SRS

- CCP provided a copy of the Measurement Control Report to EPA ; it included all pertinent information. Measurements were made in four locations on the drum’s cir cumference (0 , 90 , 180 and 270 ) , and all measurements were recorded on the Container Data Sheet (CCP

- TP

- 504, Revision 11, Attachment 2), a copy of which was provided to EPA. Contact dose rates for each of the three drums exceeded 200 mrem/hr, which was inferred by multiplying the one

- meter readings by 18 to correct for the difference in measurement distances. All contact dose rate readings greatly exceeded three times t he measured background of 0.2 mR /hr. The measurements and all accompanying parameters were acceptable, and cop ies of the Measurement Control Report and the Container Data Sheet for all drums are contained in DTC BDR Nos. SRSRHDTC11001 and SRSRHDTC11002

.

15 Container No. SR526627 i s not part of SR

- RH

- FBL.01 and technically is not within the scope of this inspection. However, EPA observed the DTC process as a demonstration of the execution of Procedure CCP

- 504.34

The use of any alternate radiological characterization procedure other than DTC (CCP

- T P

- 504) with scaling factors established by the procedures documented in CCP

- AK

- SRS

- 581, Revision 1, or substantive modification thereof, is a T1 change. (See Table 1 .) Any change to CCP

- TP

- 504 that requires CBFO ap proval is a T2 change. (See Table 1 .) (6) Radionuclide documentation in dose

- to

- curie batch data reports was assessed and found to be adequate.
The DTC results for all containers were documented in two BDRs, SRSRHDTC 11001 and SRSRHDTC11002. The EPA inspection team verified that both BDRs included the following: SPM Checklist, Attachment 8 BDR Cover Sheet, Attachment 4 BDR Table of Contents, Attachment 5 BDR Narrative Summary, Attachment 6 Independent Technical Review er ( ITR ) Review Checklist, Attachment 7 Measurement Control Report with all parameters acceptable Container Data Sheets Concentrations and corresponding uncertainties for all WIPP

- tracked radionuclides Waste Container DTC Conversion Records with all requir ed parameters, Attachment 3 Evidence of signatures by the ITR on Attachment 7 and an SPM on Attachment 8 Type of waste in each container ( organic and inorganic ) i n Attachment 3 TRU determination for all containers i n Attachment 3 Correct revision of CCP

- T P

- 504 (i.e., Revision 11 ) The BDRs were technically adequate. (7) Remote

- handled determinations were evaluated and found to be adequate. Contact dose rates were measured by SRS personnel, and SRS

- CCP provided the dose rate survey sheets for all eight drums . EPA reviewed these SRS records that indicated each container in the waste stream was RH, i.e., had a contact dose rate in excess of 200 mrem/hr. The contact dose rate readings for all eight containers represent the values at a distance of 5 centimeters , which is adequate for our purposes. The values are shown in Table 6, below.

Table 6
. Summary of RH Determinations

Drum Number Contact Dose

Rate (mrem/hr) Measurement Date SR510588 225 6/26/2008 SR512002 360 12/19/2009 SR5010 28 502 7/19/2008 SR504233 1210 12/19/2009 SR504242 200 8/13/2009 SR513217A 210 12/12/2008 SR526627 200 12/14/2009 SR118870 360 12/14/200935

(8) TRU determinations were evaluated and were found to be adequate.
DTC BDRs SRSRHDTC11001 and SRSRHDTC11002 cont ained activity and mass values with the associated uncertainties for the 10 WIPP

- tracked radionuclides plus other radionuclides, as appropriate. In all cases , the TRU alpha concentration exceeded 100 n Ci per g ram
. (9) The technical basis and documentation of T otal M easurement U ncertainty were evaluated and found to be adequate. The development of Total Measurement Uncertainty (TMU) for Waste Stream SR

- RH

- FBL.01 is based on the propagation of uncertainties present in the determination of the waste stream’s ra diological constituents. These aspects are assumed to be independent, which allows them to be added in quadrature

. 16 The TMU determination included contributions of the following:

241 Am DTC correlation

— MicroShield® Version 5 code, MicroShield® modeling, an d waste density uncertainties
241 Am activity measurement

— dose rate measurement uncertainty and uncertainty due to the contribution of other gamma

- emitting radionuclides Scaling factor uncertainty

— ISOCS modeling uncertainties, waste density uncertainties, s caling factor uncertainty in CH data A general treatment of TMU for SR

- RH

- FBL.01 is presented in CCP

- AK

- SRS

- 581, Revision 1, Section 6, and the detailed treatment of TMU is provided in Uncertainty Analysis for SR

- RH

FBL.01 , Calculation Package SRS

- RH

- 42 , Revision 1 (Reference U002). The overall uncertainties are consistent with what EPA has observed for RH determinations at other RH TRU generator sites. TMU varies slightly from drum to drum because scaling factors are developed on an individual drum basis. An example of the overall uncertainty for drum No. SR510588 from SR

- RH

- FBL.01 is provided in Table 7 below.

16 Adding in quadrature is a standard statistical technique that allows on e to combine the square root of the sum of each contributor to uncertainty squared, resulting in a lower value than what would be obtained if the values were simply added. For example, the TMU for 239 Pu is derived by taking the square root of ( 25.0 %) 2 plus ( 10%) 2 plus (26.2%) 2 plus (5.4%) 2 plus (28.1%) 2
, which equals 47.21%, which is less than the value obtained by simply adding the values ( i.e., less than 94.7 %, as shown in Table 7 ).36 Table 7
. Overall Uncertainty of Example Drum SR510588

Radionuclide Uncertainty

in Dose Rate Measurement MCNP5

Code Uncer tainty Uncertainty

of ISOCS SF Uncertainty

in SF D erived from CH D ata Uncertainty

in W aste D ensity Uncertainty

in W aste D istribution TMU

U

- 233 25.0% 10% NA 52.0% 4.6% 21.9% 62.7% U

- 234 25.0% 10% NA 77.3% 4.6% 21.9% 84.9% U

- 235 25.0% 10% NA 73.3% 4.6% 21 .9% 81.2% U

- 238 25.0% 10% NA 64.7% 4.6% 21.9% 73.6 % Pu

- 238 25.0% 10% NA 90.4% 4.6% 21.9% 96.9% Pu

- 239 25.0% 10% 26.2% NA 5.4% 28.1% 47.2% Pu

- 240 25.0% 10% 28.2% NA 3.0% 25.2% 46.5% Pu

- 241 25.0% 10% 27.7% NA 3.4% 25.0% 46.1% Pu

- 242 25.0% 10% NA 234.0 % 4.6% 21.9% 236.7% Am

- 241 25.0% 10% 0% NA 4.6% 21.9% 35.0% Sr

- 90 25.0% 10% NA 366.7% 4.6% 21.9% 368.4% Cs

- 137 25.0% 10% NA 366.7% 4.6% 21.9% 368.4% Y

- 90 25.0% 10% NA 366.7% 4.6% 21.9% 368.4% Ba

- 137m 25.0% 10% NA 366.7% 4.6% 21.9% 368.4% Summary of Radiological Characterization Findings and Concerns The EPA inspection team did not identify any findings or concerns related to radiological characterization. There are no open issues related to radiological characterization resulting from this inspecti on. Tier 1 Radiological Characterization Changes The following radiological characterization changes are T1 changes: Use of the MCS/ISOCS to provide any information other than the relative determinations of 239 Pu, 240 Pu and 241 Pu to 241 Am Any future use of the ORTEC/ISOCS for any RH TRU waste Application of new scaling factor processes for isotopic determination other than those documented in CCP

- AK

- SRS

- 581, Revision 1 (applies to new RH waste streams and to the addition of containers to an approved wast e stream) Substantive modification(s) to CCP

- TP

- 504 or CCP

- AK

- SRS

- 581 that have the potential to affect the characterization process Tier 2 Radiological Characterization Changes The following radiological characterization changes are T2 changes:

Any ne w RH waste stream characterized using an approved scaling factor process for isotopic determination37 Notification to EPA upon completion of revisions to CCP

- AK

- SRS

- 581 or CCP

- TP

504 that require CBFO approval Notification to EPA when calculation package(s) CCP

- SRS

- 44, or equivalent record(s), are available Proposed Radiological Characterization Baseline Approval Based on this inspection, EPA proposes to approve the radiological characterization of eight drums in Waste Stream SR

- RH

- FBL.01 using DTC and scal ing factors generated through use of the ORTEC/ISOCS prior to the baseline inspection and historical assays of companion (see footnote 1) CH debris waste streams for assigning radionuclide values according to the limitations in Section8.2 of this report. E PA also proposes to approve the radiological characterization process using DTC and scaling factors generated through use of the MCS/ ISOCS and historical assays of companion (see footnote 1) CH debris waste streams for assigning radionuclide values for RH waste , as documented in CCP

- AK

- SRS

- 581, Revision 1, and supported by the calculation packages (or equivalent documentation) referenced in this report , and subject to the limitations in Section 8.2 of this report

. This is the first time that an ISOCS was u sed for characterization of WIPP

- bound RH TRU waste. Under this proposed approval, use of the MCS/ISOCS is limited to the generation of specific radionuclide ratios, i.e., the activity of Pu isotopes 239 Pu , 240 Pu and 241 Pu to 241 Am. SRS

- CCP may not measure 238 Pu in this manner and must instead quantify 238 Pu based on appropriate AK (including necessary AK qualification) or another EPA

- approved characterization technique. Under this proposed approval, the MCS/ISOCS may not be used to directly quantify any ra dionuclides. The sole purpose of the MCS/ISCOS will be to develop ratios (scaling factors) for 239 Pu , 240 Pu and 241 Pu to 241 Am. The ORTEC/ISOCS is not approved for use beyond the eight containers that were the subject of this proposed baseline approval.
8.3 R eal

- Time Radiography Waste Characterization Element Description As part of the inspection of the RTR activities, the EPA inspection team focused on overall procedural technical adequacy and implementation, as well as the identification of WMPs and prohib ited items, in reviewing the following RTR elements: Documentation of RTR activities through use of an approved procedure Proper execution of RTR activities Management oversight and independent review of RTR activities Training of RTR personnel
The RTR facility uses radiography to help determine the following aspects of TRU waste characterization: Types and amounts of WMPs Confirmation of the WMC38

Presence or absence of prohibited items Demonstration of capability testing for operators on the RTR syste m using specifically placed items Documents, B atch D ata R eport s and Objective Evidence Reviewed
SRS

- CCP provided source documents, attachments, forms and other data to EPA, which reviewed them as applicable. The list of all documentation examined is in A ttachment A to this report. The following is a complete list of all objective evidence the EPA team evaluated during the inspection:
Written and audio/visual recording of RTR events for selected drums contained in Batch Data Report Nos. SR4RTR0173 and SR SRTR0425 Written and audio/visual recordings of training container NDE

- Training

- 11 for selected RTR operators Completed and signed Training Container Evaluation Data Sheet RTR Operator/ITR q ualification cards Qualification card s and training records for th ree RTR operators/ITRs LOQI for the SRS RH RTR program, dated April 25, 2011
Technical Evaluation During the baseline inspection, the EPA inspection team evaluated the technical elements of the RTR process that are summarized as follows: (1) Overall procedu ral technical adequacy and implementation were considered and were found to be acceptable. The RTR procedure, documented in CCP

- TP

- 053, Revision 11, Sta ndard Real

- Time Radiography (RTR) Inspection Procedure , contained specific information on performing no nintrusive radiography, including operational setup and checkout, identification of prohibited items, assignment of WMPs and estimation of weights and volumes, confirmation of WMCs, input of data, issuance of NCRs, and technical review of radiography resul ts. This procedure was written specifically for RTR of CH waste but was used to characterize the RH waste contained in the BDRs listed above. EPA determined that all pertinent WCPIP requirements had been met using this procedure. Notification to EPA upon c ompletion of changes to RTR procedure(s) that require CBFO approval is a T2 change. (see Table 1).39

(2) Characterization of waste material parameter s and prohibited items was assessed and was found to be acceptable.
Procedure CCP

- TP

- 053, Revision 11, requires that radiography audio/visual recording equipment verification be performed at the beginning of every shift in which drums are subject to examination. EPA inspectors confirmed adherence to verification requirements through review of written BDRs and audio /video tapes. At the beginning of a shift, and before examining any waste containers, the operator runs a scan on the lines

- pair resolution test gauge to determine that images are clearly visible. The two BDR s reviewed had acceptable lines

- pair tests recor ded for the days that RTR took place. For each container undergoing examination, the operator makes an audio/vid eo recording of the RTR event. B efore begi nning the radiography process, the operator notes the drum number and the date and time on the audio/ video recording

. The examination of the drum begins at the top of the drum , where the operator identifies the seal and vent. The drum rotates through 360 degrees so that all objects inside a dr um are visible from all sides. The operator can zoom both in an d out and increase or decrease the scan energy in order to compensate for varying densities i n the material being examined. During examination, the operator also ―rocks‖ the drum to determine the presence of free liquids. The waste stream being processed was SR

- RH

- FBL

- 01, which is a debris (S5000) waste stream. There is a standardized weight table (Table 3) in CCP

- TP

- 053, Revision 11 , that provides weights for com monly encountered waste items. WMP weight estimates are made and recorded on the data sheet. As part of the inspection , the EPA team reviewed RTR data, both audio/visual and written, for containers SR504233, SR512002, SR118870 and SR526627. The first two containers are from BDR No. SR4RTR0173 , and the last two are from BDR No. SRSRTR0425

. EPA de termined that the quality control ( QC ) samples , i ndependent o bservation , and r eplicate s can performed w ere appropriate and that information on the audio/visual recording matched the written RTR record (BDR). Addition of a new SCG to the approved RTR proces s is a T 2 change. ( S ee Table 1

. ) (3) EPA ascertained that documentation of radiography procedures was adequate. Radiography procedures are well defined and the documents are controlled. During the inspection, the EPA team reviewed the adequacy and implementa tion of all r adiography

- related procedures. QC examinations were performe d as required by the procedure. In B atch SRSRTR0425, an independent observation was performed on container SR526627 and a replicate scan was performed on container SR513217A; in B atch SR4RTR0173, an independent observation was performed on container SR512002 and a replicate scan was performed on container SR504233. There were no nonconformances reported for these two batche s. The BDRs the EPA examined had been reviewed at the data

- gene ration level ( by the ITR) and project level ( by the SPM) as required.40

( 4 ) Training of radiography personnel was performed in accordance with CCP procedures. The EPA team reviewed documentation of the training container examinations for selected radiograp hy personnel. The inspectors viewed the audio/visual recording for the latest training drum for an RTR ITR and RTR operator during the inspection. Training records reviewed indicate that only personnel trained in accordance with CCP procedures were operati ng the RTR equipment. Summary of Real
- Time Radiography Findings and Concerns The EPA team did not identify any findings and or concerns during the inspection.
Tier 1 Real
- Time Radiography Changes The following RTR change is a T1 change: RTR by any ne w process
Tier 2 Real
- Time Radiography Changes The following RTR changes are T2 changes: Changes made to RTR procedure(s) that require CBFO approval Addition of a new SCG to any approved RTR process Every three months from the date of EPA approval, S RS

- CCP will provide information concerning T2 changes. If new RTR equipment is in use, EPA inspection may be necessary. EPA will evaluate changes and communicate with SRS

- CCP regarding whether the changes raise any concerns and require SRS

- CCP response, or whether SRS

- CCP can continue to implement the changes. Proposed Real
- Time Radiography Baseline Approval The baseline conditions that the EPA inspection team evaluated during this inspection consisted of RTR of RH TRU S5000 debris wastes to identify WMPs and the physical form using the following: Trained personnel, RTR operator/ITR and subject matter expert Approved and controlled operating procedures CCP

- TP

- 053, Revision 11; CCP

- QP

- 002, Revision 31; and CCP

- TP

- 028, Revision 6 RTR records and supporting data, CCP

- TP

- 053 and CCP

- TP

- 001 review checklists, operator training records and BDRs Based on this inspection, EPA proposes to approve SNL

- CCP to perform RTR of RH TRU waste according to procedure CCP

- TP

- 053.41

9.0 RESPONSE TO COMMENTS
This section is reserv ed for responses to public comments on the proposed approval

. 10.0 SUMMARY OF RESULTS
10.1 Environmental Protection Agency Findings and Concerns EPA did not identify any findings or concerns during this inspection related to the processes SRS

- CCP implemented to characterize RH TRU debris Waste Stream SR

- RH

- FBL.01 . No issues resulting from this baseline inspection remain open at this time.
10.2 Conclusions This proposed approval is based on EPA’s baseline inspection conducted at SRS in September and December of 2011

. EPA evaluated SRS

- CCP’s RH waste characterization program for eight drums of d ebris W aste Stream SR

- RH

- FBL.01and determined it to be technically adequate. The proposed approval includes the following: The AK process for RH

- TRU debris waste stream s th at have companion (see footnote 1) CH debris waste streams The radiological characterization of eight drums in Waste Stream SR

- RH

- FBL.01 using DTC and scaling factors generated through use of the ORTEC/ISOCS prior to the baseline inspection and historical assays of companion (see footnote 1) CH debris waste streams for assigning radionuclide values according to the limitations in Section 8.2 of this report The radiological characterization process using DTC and scaling factor s generated through use of the M CS/ ISOCS and historical assays of companion (see footnote 1) CH debris waste streams for assigning radionuclide values for RH waste , as documented in CCP

- AK

- SRS

- 581, Revision 1, supported by the calculation packages (or equivalent documentation) reference d in this report , and subject to the limitations in Section 8.2 of this report The RTR process to identify WMPs and the physical form of RH TRU debris waste This proposed baseline approval of SRS

- CCP’s RH TRU waste characterization program, when approved, will allow SRS

- CCP to characterize RH waste from Waste Stream SR

- RH

- FBL.01 in accordance with the conditions and restrictions discussed in this report and summarized in Table 1. After EPA finalizes the SRS

- CCP RH waste characterization program approval, a dditional debris waste stream(s) having a companion (see footnote 1) CH waste stream(s) may be disposed of at the WIPP provided th at an approved radiological scaling factor development process is used

. Use of the MCS/ISOCS is limited to the generation of scaling factors for specific radionuclides, i.e., the activity ratios of Pu isotopes 239 Pu , 240 Pu and 241 Pu to 241 Am. Further, use of the42

MCS/ISOCS for determining the scaling factor for 238 Pu or for direct quantification of any radionuclide is prohibite d. A T1 change approval is necessary when:
The radiological scaling factors development process used for characterizing RH debris waste differs from the process approved; An RH TRU debris waste stream characterized for WIPP disposal does not have a comp anion (see footnote 1) CH waste stream; An RH TRU non

- debris waste stream from the solids (S3000) or soils and gravel (S4000) summary category groups is characterized for WIPP disposal; or The ORTEC/ISOCS is used for RH debris waste characterization in the future

.43

11.0 REFERENCES U.S. Environmental Protection Agency, ―Criteria for the Certification and Recertification of the Waste Isolation Pilot Plant’s Compliance with the Disposal Regulations: Certification Decision; Final Rule,‖ Federal Register , Vol. 63 , No. 95, May 18, 1998, pp. 27354, 27405. U.S. Code of Federal Regulations, Title 40 , Protection of Environment , Part 191, ―Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High

- Level and Transuranic Radioact ive Wastes.‖ U.S. Code of Federal Regulations, Title 40 , Protection of Environment , Part 194, ―Criteria for the Certification and Re

- Certification of the Waste Isolation Pilot Plant’s Compliance with the 40 CFR Part 191 Disposal Regulations.‖ U.S. Depart ment of Energy, Office of Environmental Management, ―Radioactive Waste Management Manual,‖ DOE M435.1

- 1, July 9, 1991, Change 1: June 19, 2001. U.S. Department of Energy, Carlsbad Field Office, ―Remote Handled TRU Waste Characterization Program Implementa tion Plan,‖ DOE/WIPP

- 02

- 3214, Revision 0D, Carlsbad, New Mexico, October 30, 2003. U.S. Department of Energy, Carlsbad Field Office, ―Remote Handled TRU Waste Characterization Program Implementation Plan,‖ DOE/WIPP

- 02

- 3214, Revision 2, Carlsbad, New Mexic o, April 21, 2011. U.S. Department of Energy, Title 40 CFR Part 191, Compliance Certification Application for the Waste Isolation Pilot Plant, DOE/CAO 1996

- 2184, Carlsbad, New Mexico, 1996. U.S. Department of Energy, Title 40 CFR Part 191, SUBPART D AND C, Compliance Recertification Application 2004, DOE/WIPP/2004

- 3231. U.S. Department of Energy, ― DOE Waste Treatability Group Guidance , ‖ DOE/LLW

- 217 , INEL

- Lockheed Idaho Technologies, Idaho Falls, Idaho, 1995 U.S. Department of Energy, ―Remote

- Handled Tra nsuranic Waste Authorized Methods for Payload Control (RH

- TRAMPAC),‖ Carlsbad, New Mexico.A

- 1 ATTACHMENT A: DOCUME NTS REVIEWED CCP Calculation Package: SRS RH TRU Radiological Characterization, J. Vance, SRS

- RH

- 41, Revision 0, August 4, 2011
CCP Calculati on Package: Determination of Scaling Factors for SRS

- 580 Drums, J. Holderness, SRS

- RH

- 41, Revision 1, September 13, 2011 CCP Calculation Package: Uncertainty Analysis for SR

- RH

- FBL.01, J. Holderness, SRS

- RH

- 42, Revision 0, July 31, 2011, and Revision 1, Se ptember 14, 2011 CCP Calculation Package: DTC Values and Gamma Sensitivity Studies, J. Holderness, SRS

- RH

43, Revision 0, July 30, 2011 CCP Calculation Package: DTC and Related Calculations for SR

- RH0FBL.01, J. Holderness, SRS

- RH

- 44, Revision 0, August 3, 2011 CCP Calculation Package: SRS RH TRU Radiological Characterization, J. Holderness, SRS

- RH

44, Revision 1, October 25, 2011 Calibration Verification Report for the ISOCS Detector # 4480 at the Savannah River Site, B. Gillespie, Revision 0, November 9, 2 011
CCP

- AK

- SRS

- 2, Central Characterization Project Acceptable Knowledge Summary Report for Savannah River Site SR

- W027

- FB

- Pre86

- C, Revision 13, September 16, 2010
CCP

- AK

- SRS

- 58 0 , Central Characterization Project Acceptable Knowledge Summary Report for Sava nnah River Site Remote

- Handled Transuranic Waste, Waste Stream: SR

- RH

- FBL.01, Revision 1 , June 22, 2011, Revision 2, August 26, 2011, and Revision 3, October 4, 2011
CCP

- AK

- SRS

- 58 1 , Central Characterization Project Remote

- Handled Transuranic Radiological C haracterization Technical Report for Savannah River Site Remote

- Handled Transuranic Debris Waste, Waste Stream: SR

- RH

- FBL.01, Revision 0, August 11, 2011, and Revision 1, November 1, 2011
CCP

- AK

- SRS

- 582, Central Characterization Project RH TRU Waste Certif ication Plan for 40 CFR Part 194 Compliance for SRS Waste Stream: SR

- RH

- FBL.01, Revision 0, July 6, 2011 , and Revision 1, November 9, 2011
CCP

- AK

- SRS

- 585, Central Characterization Project Acceptable Knowledge Radionuclide Distribution Test Program for Sava nnah River Site Remote

- Handled FB LINE DEBRIS WASTE, Waste Stream: SR

- RH

- FBL.01, Revision 0, June 2, 2011
CCP

- QP

- 002 , Revision 31 , CCP Training and Qualification Plan , April 21, 2011
CCP

- QP

- 005, Revision 20 , TRU Nonconforming Item Reporting and Control , Ap ril 26, 2011
CCP

- QP

- 008 , Revision 19, CCP Records Management , August 02, 2011A

- 2

CCP

- TP

- 002 , Attachment 2, CCP Waste Stream Profile Form, Waste Stream SR

- RH

- FBL.01 , Draft for Audit Purposes, Provided July 21, 2011, and August 31, 2011
CCP

- TP

- 005, Attachment 1 , Acceptable Knowledge Documentation Checklist, June 16, 2011, and August 31, 2011
CCP

- TP

- 005 , Attachment 4, Acceptable Knowledge Source Document Reference List, June 16, 2011, and August 31, 2011,
CCP

- TP

- 005, Attachment 6 , Waste Form, Waste Material Param eters, Prohibited Items, and Packaging , May 24, 2011, and September 6, 2011
CCP

- TP

- 005, Attachment 7, Radionuclides, May 24, 2011
CCP

- TP

- 005, Attachment 8 , Waste Containers, June 14, 2011
CCP

- TP

- 005, Attachment 13, CCP Waste Stream Characterization Checkli st, Draft, Provided July 21, 2011
CCP

- TP

- 005, Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form, May 24, 2011
CCP

- TP

- 028 , Revision 6, CCP Radiographic Test Drum and Training Container Construction , December 29, 2010
CCP

- TP

- 053, Revision 1 1, CCP Standard Real

- Time Radiography (RTR) Inspection Procedure , July 20, 2011
CCP

- TP

- 139, Revision 3, CCP In Situ Object Counting System Nondestructive Assay Operating Procedure , May 4, 2011
CCP

- TP

- 508, Revision 7, CCP Standard Real

- Time Radiography (RTR ) Inspection Procedure , April 21, 2011 Characterization Information Summary, Waste Stream SR

- RH

- FBL.01 , Draft, Provided Ju ly 2 1 , 2011 , and November 29, 2011 Characterization Reconciliation Report for Waste Stream SR

- RH

- FBL.01, Draft for Audit Purposes, P ro vided July 21, 2011
DTC BDR Nos. SRSRHDTC11001, August 17, 2011, and SRSRHDTC11002, August 18, 2011
Inter o ffice Correspondence, from Irene Quintana to CCP Records Custodian , Acceptable Knowledge Accuracy Report : Savannah River Site Waste Stream Number SNL

- HCF

- S5400

- RH, Lot 1, Draft f

or Audit Purposes Only, July 18, 2011 Interoffice Correspondence from R. Gogliotti and P. Kelly to Ed Feltcorn, RE: Replicate Testing Protocol for System at SRS

- CCP Using a Standard Drum, November 18, 2011A

- 3

ISOCS/LabSOCS Detector Characterization Report, Canberra Industries, Inc., August 10, 2010
List of Q ualified I ndividuals (LOQI) Savannah River Site, April 25, 2011, August 16, 2011, and December 1, 2011 MCS ISOCS Report ISOCS DTC

– CH Waste Drums, SRS Submittal Nos. #061611, Ju ne 16, 17, and 30, 2011, and #061711, June 17, 20, and 21, 2011 Memorandum from J. Vance to Irene Quintana, Analysis of ISOCS Confirmation Test Results for SRS Debris RH TRU Waste Stream, September 13, 2011
NCRs: NCR

- RHS RS

- 2940

- 11, NCR

- SRS

- 0533

- 09 , and NCR

- SRS

- 1137

- 06
OA

- SRS

- 0153, Revision 2, CCP DTC Operator Aid, August 30, 2011
Post

- Confirmation Testing Memorandum: Analysis of ISOCS Confirmation Test Results for SRS Debris RH TRU Waste Stream, J. Vance, July 29, 2011 QC Limits for the MCS ISOCS System at the Savannah River Site, Bruce Gillespie, November 18, 2011 Qualification cards and training records for M. Doherty, J. Montoya and S. Schafer, provided August 31, 2011 Qualification card s and training records for RTR and DTC operators/ITRs
SRNL Procedure ADS

- 2460, Revision 0, Gamma Assays Using ORTEC’s Isotopic Program, February 16, 2011
RTR BDR Nos. SR4RTR0173 and SRSRTR0425 VSDS Standard Map RSLS Surveys: SWIN

- M

- 20090813

- 26, SWIN

- M

- 20081212

- 4, SWIN

- M

- 20080626

- 5, SWIN

- M

- 20080719

- 2, SWIN

- M

- 20091214

- 9, and SWIN

- M

- 20091219

- 1
WSRC

- TR

- 2005

- 00431, Revision 0, Nondestructive Assay Efficiency Calibration of HPGe Detectors for the ORTEC ―Isotopic‖ Method, SNRL, Raymond Sigg, Vito Casella and Raymond Dewberry, September 2005
C018 , Record of Communication

– Intervie w with M.P. Rodriquez, FB

- Line Engineer, W.G. Estill, January 10, 2002
C021 , Record of Communication

– Interview with Chip Harris, J. Whitworth, S. Fevig, G. Lunsford, January 10, 2002
C022 , Record of Communication

– Interview of Jeff Overcash by Stephanie Fevig and David Guerin, Stephanie Fevig and David Guerin, January 11, 2002
C024 , Interview with Joe Stapf, Process Engineer and MC&A Shipping Supervisor at FB

- Line, 1978

– 1982, W.G. Estill, January 14, 2002A

- 4

C025, Record of Communication

– Interview with Ed Moore, J. Whitworth, S. Fevig, G. Lunsford, January 10, 2002 C026, Record of Communication for Interview with Les Sonnenberg, Former FB

- Line Mechanical Engineer, J. Whitworth and S. Fevig, January 10, 2002 C027, Record of Communication for Interview with A. Gibbs, SRS Solid Waste Management, J. Whitworth and S. Fevig, January 15, 2002 C028, Record of Communication

– Interview of Charley Williams, J. Whitworth and S. Fevig, January 15, 2002 C029, Record of Communication for Interview with D. Rogers, Former FB

- Line Operator and Supervisor, J. Whitworth and S. Fevig, January 15, 2002
C031 , Record of Communication

– Interview with Richard Runnels, Process Engineer at FB

- Line 1986

- 87, W.G. Estill, January 16, 2002
C032 , Record of Communication

– Interview with J ohn Crim, J. Whitworth and S. Fevig, January 17, 2002
C044 , Letter from O.M. Morris to M.G. O’Rear, ―TRU Waste Data Update Request , ‖ O.M. Morris, March 6, 1985 C045, Letter from C.M. Morris to C.G. Halsted, TRU Waste Annual Call for Data , ‖ C.M. Morris, May 17 , 1984
C056 , Record of Communication: Interview with Supervisor Harry Smiley regarding FB

- Line Waste from 1970

– 86, W. Estill, January 28, 2002
C067 , Record of Communication for Written Response to Interview Questions from R. Burns, Former FB

- Line Engine er, J. Whitworth and S. Fevig, January 15, 2002
C071 , Record of Communication

– Interview of FB

- Line Personnel, J. Harrison, J. Whitworth, January 16, 2001 C072, Memo from N. Dienes to Distribution List re: Specifications for Plutonium Shipped to the Rocky Flats Plant, Albuquerque Operations Office, March 22, 1985
D008 , Savannah River TRU Waste Inventory Workoff Plan, SRS, DPSP

- 86

- 1, July 15 , 1986
D013 , Safety Analysis

– 200 Area Savannah River Plant Burial Ground Operations, Science Applications Internatio nal Corporation, DPSTSA

- 200

- 10, SUPP

- 8, October 1988
D016 , History of Du Pont at the Savannah River Plant, William P. Bebbington, 1990
D020 , 200

- Area Safety Analysis, SAIC, SRS, DPSTSA

- 200

- 10, Supp

- 9, April 1988A

- 5

D029 , Savannah River Site Solid Waste Manage ment Facility Safety Analysis Report, Westinghouse Savanna River Company, Aiken, SC, WSRC

- SA

- 22, Revision 2 draft, November 25, 1998 D030, Savannah River Site Transuranic Waste Program, J.A. Blankenhorn, Solid Waste Management Operations, SWE

- SWE

- 96

- 0195, Revision 0, May 15, 1997
D033 , The FB

- Line Facility

– A Training Aid Document, DPST

- 86

- 449, September 1986 D035, The Purex Process, J.B. Starks, Separation Technology Department, DPSU 77

- 11

- 1, January 1977
D037 , Systems Analysis

– 200 Area Savannah River P lant: JB

- Line Operations, D.H. Stoddard and R.V. Slates, DPSTSY

- 200

- 10, May 1978
D054 , Works Technical Report for January, February 1977, DPSPs 77

- 1

- 1, 77

- 1

- 2, Savannah River Plant, January 1977, February 1977
DR001 , Discrepancy Resolution: Drum/Culvert Li mit Change, D. Guerin, October 19, 2002
DR3 , Discrepancy Resolution: Radionuclides, J. Whitworth, October 16, 2002
DR6 , Discrepancy Resolution: Physical Form, Julia Whitworth, October 19, 2002
DR008 , Acceptable Knowledge Source Document Discrepancy Resolut ion, Calcium Reactivity, J. Harrison, July 18, 2006 DR009, Discrepancy Resolution for Discrepant Drum in SR

- W027

- FB

- Pre86

- C Waste Stream, Lisa Price

- Watson, January 24, 2008
M051 , Calculation of WMPs for SRS RH Waste Stream SR

- RH

- FBL

- 01, Mark Doherty, Marc h 25, 2009 M052, RH Container Data, 1975 to 2008
M054 , Memo to File from Mark Doherty re: Revision of the Calculation of WMPs for SRS RH Waste Stream SR

- RH

- FBL.01, Mark Doherty, May 24, 2011 M055, CCP RTR Data to S upport R evised WMP Calculation, Various Au thors, April 2011
P009 , Packing TRU Waste and Sealing in 55

- Gallon Drums, DPSOL 241

- FH

- 40, Revision 1, July 1977 P010, Savannah River Plant Radiation and Contamination Control/Management of Solid Radioactive Waste, E.I. Du Pont de Nemours and Co, DPSOP 40, Various Revisions, 1976

- 1977 U001, CCP Calculation Package: SRS

- 580 Scaling Factor Development, Jene Vance, SRS

- RH

41, Revision 0, August 4, 2011 , Revision 1, September 13, 2011A

- 6

U002, CCP Calculation Package: SRS

- 580 Uncertainty Analysis, J. Vance, SRS

- RH

- 42, Revision 0, August 4, 2011 , Revision 1, September 14, 2011 U003, CCP Calculation Package: SRS

- 580 DTC Derivation for Am

- 241, J. Vance, SRS

- RH

- 43, Revision 0, August 4, 2011 U004, CCP Calculation Package: DTC and Related Calculations for SR

- RH

- FBL.01, J. Vance, SRS

- RH

- 44, Revision 0, August 8, 2011 , Revision 1, October 25, 2011 U005, CCP Calculation Package: SRS

- 580 Reporting Requirements Evaluation , J. Vance, SRS

- RH

- 45, Revision 0, August 14, 2011 U007, CCP Calculation Package: Dose Rate Contribution f rom Other Radionuclides, J. Holderness, SRS

- RH

- 46, Revision 0, September 14, 2011B

- 1

ATTACHMENT B: PERSON NEL CONTACTED DURING INSPECTION

Personnel Name Affiliation Area of Expertise, Function Aug Dec Ed Feltcorn U.S. EPA ORIA Inspection Team Leader   C onnie Walker * SC&A Inspection Team, AK  Kira Darlow SC&A Inspection Team, AK  Dorothy Gill * SC&A Inspection Team, VE  Rose Gogliotti SC&A Inspection Team, Radiological Characterization   Patrick Kelly SC&A Inspection Team, RC, AK   Amir Moba sheran* SC&A Inspection Team, Radiological Characterization  Jim Holderness CCP Consultant Radiological Characterization  Derek Ott CCP Radiological Characterization  Marcus A. Pinz e l DOE/CBFO RH Waste Manager, RC  David A. McCoy CCP DTC Operat or , RC  Paul Gomez CBFO/CTAC Observer  Todd Shepley MCS/CCP DTC Operator   Ronald Whitson MCS DTC Operator  Mark Doherty CCP

- TechSpecs AK Expert  Kevin Peters WTS/CCP AK Expert  Joe Harvill CCP /WTS DTC/NDA   Buddy Fussel CCP V. Project Manager  Steve Mise WTS Quality Engineer  Steve Schafer CCP

- TechSpecs SRS

- CCP AK Expert  Court Fesmire DOE Observer  Irene Quintana WTS

- CCP RH Site Project Manager   Jene Vance * † WTS

- CCP Radiological Characterization  Lee Fox SRNS STR  Joe Stepzinski CCP VPM  Ronald D. Reeves WTS/CCP NDA  Tom Morgan NTP/DOE CBFO Observer  Pat Tilman WTS/CCP VPM  Tom Cochran DOE/FR Observer  Ray Dewberry SRNL Radiological Characterization  Bruce Gillespie Canberra NDA  Tim Carlton C CP ISOCS Lead Operator  * Performed evaluations via desk

- top review. † Contacted by phone