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

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT 

EPA TIER 1 EVALUATION 

OF THE CENTRAL CHARACTERIZATION PROGRAM 

CONTACT-HANDLED WASTE CHARACTERIZATION PROGRAM 

AT THE OAK RIDGE NATIONAL LABORATORY: 

ADDITION OF SUMMARY CATEGORY GROUP S3000 (SOLIDS) 

February 4–6, 2014 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

July 2014 
i 

TABLE OF CONTENTS 

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

2.0 Purpose of Tier 1 Evaluations ............................................................................................. 3

3.0 Purpose of This Report ....................................................................................................... 3

4.0 Scope of This Tier 1 Evaluation ......................................................................................... 4

5.0 Inspection Personnel ........................................................................................................... 4

6.0 Technical Evaluation .......................................................................................................... 4

6.1 Acceptable Knowledge ........................................................................................... 4

6.2 Real-Time Radiography .......................................................................................... 7

7.0 Findings and Concerns ........................................................................................................ 8

8.0 Conclusions ......................................................................................................................... 9

LIST OF TABLES 

Table 1. Tiering of Contact-Handled Transuranic Waste Characterization Processes 

Implemented by ORNL-CCP .......................................................................................................... 2

Table 2. Tier 1 Evaluation Participants ........................................................................................... 4

ATTACHMENTS 

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

Program 

Attachment B List of Documents Reviewed for This Inspection 

Attachment C February 2014 Continued Compliance Inspection Personnel 

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

Attachment E RTR Tier 1 Evaluation Checklist 
ii 

ACRONYMS AND ABBREVIATIONS 

AK acceptable knowledge 

AKSR acceptable knowledge summary report 

Att. Attachment 

BDR batch data report 

CBFO Carlsbad Field Office 

CCP Central Characterization Program 

CFR Code of Federal Regulations 

CH contact-handled 

CIS characterization information summary 

CTAC CBFO Technical Assistance Contractor 

DOE U.S. Department of Energy 

DR discrepancy resolution 

DTC dose-to-curie 

EA Expert Analyst 

EPA U.S. Environmental Protection Agency 

FGA flame gas analysis 

HLW high-level waste 

HWN hazardous waste number 

IPAN Integrated Passive Active Neutron 

ITR Independent Technical Reviewer 

LLW low-level waste 

LO Lead Operator 

LOQI list of qualified individuals 

MCS Mobile Characterization Services 

NCR nonconformance report 

NDA nondestructive assay 

NDE nondestructive examination 

NFS Nuclear Fuel Services 

NWP Nuclear Waste Partnership, LLC 

OJT on-the-job training 
iii 

ORNL Oak Ridge National Laboratory 

ORIA Office of Radiation and Indoor Air 

Pu plutonium 

QA quality assurance 

QC quality control 

RH remote handled 

RTR real-time radiography 

SCG summary category group 

SD source document 

SGS segmented gamma scanner 

SME Subject-Matter Expert 

SNF spent nuclear fuel 

SPM Site Project Manager 

STR site technical representative 

T1 Tier 1 

T2 Tier 2 

TRU transuranic 

TWPC Transuranic Waste Processing Center 

U uranium 

VE visual examination 

VEE visual examination expert 

VJT Vee Jay Technologies 

VPN vendor project manager 

WAI Wastren Advantage Incorporated 

WDS Waste Data System 

WIPP Waste Isolation Pilot Plant 

WMC waste matrix code 

WMP waste material parameter 

WSPF waste stream profile form 
1 

1.0 EXECUTIVE SUMMARY 

This report supports the U.S. Environmental Protection Agency’s (EPA’s) approval of a Tier 1 

(T1) change to add summary category group (SCG) S3000 (homogeneous solid) waste to the 

EPA-approved contact-handled (CH) transuranic (TRU) waste characterization program at the 

U.S. Department of Energy (DOE) Oak Ridge National Laboratory (ORNL). 

In accordance with Title 40 of the Code of Federal Regulations (40 CFR) 194.8(b), EPA 

conducted a baseline inspection of the Central Characterization Program (CCP)1 waste 

characterization program for CH TRU wastes at ORNL in Oak Ridge, Tennessee, in 2007–2008. 

As a result, EPA approved the ORNL-CCP CH TRU waste characterization program (see EPA 

Docket No. A-98-49, II-A4-103). From July 2011–September 2013, DOE suspended waste 

characterization activities at ORNL. EPA conducted a continued compliance inspection of 

ORNL-CCP’s CH and RH TRU waste characterization program in February 2014 and approved 

ORNL-CCP to resume CH TRU waste characterization activities in April 20142

. EPA’s reviews 

and approvals of ORNL-CCP’s CH waste characterization program are listed in Attachment A. 

On January 7, 2014, the Carlsbad Field Office (CBFO) requested EPA approval of a T1 change 

to include SCG S3000 waste in ORNL’s EPA-approved CH waste characterization program. 

EPA conducted this T1 evaluation while onsite at ORNL for the aforementioned continued 

compliance inspection at ORNL on February 4–6, 2014. During the continued compliance 

inspection, EPA verified that the ORNL-CCP nondestructive assay (NDA) equipment calibration 

is sufficiently broad to include homogenous solid waste. Therefore, EPA limited the scope of the 

T1 evaluation to acceptable knowledge (AK) and real-time radiography (RTR). 

Based on the results of this T1 evaluation, EPA approves ORNL-CCP to add SCG S3000 CH 

TRU waste to the waste characterization program. EPA made one change to the CH AK T1 

designations to reflect that addition of SCG S3000 waste is no longer a T1 change. This change 

is reflected in EPA’s tiering table, Table 1, below. 

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

This report serves as EPA’s public notification of the results of the continued compliance 

inspection. This information will be provided through the EPA website and by sending emails to 

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

 

1

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

both names are used in the documentation reviewed for this evaluation. 

2

 DOE’s suspension of characterization activities at ORNL, the resumption process performed by CCP at 

ORNL, and EPA’s inspection and continued approval of the resumed waste characterization activities are discussed 

in EPA Docket No. A-98-49, II-A4-186. 
2 

Table 1. Tiering of Contact-Handled Transuranic Waste Characterization Processes Implemented b

(Based on November 13–15, 2007, Baseline Inspection and Subsequent Tier 1 Evaluations, Update

Process Elements ORNL-CCP CH Waste Characterization Process – T1 Changes ORNL-CCP CH Waste Characteriz

Acceptable Knowledge, including Load Management 

Any new waste category other than retrievably stored debris, 

soils/gravel and solids (i.e., any type of newly generated waste) 

Load management 

Submission of a list of active ORNL-CCP Notification to EPA upon completion of o

• AK accuracy reports (annually, at a mi

• AK-AK and AK-NDA/NDE Discrepan

• WSPFs and related attachments (e.g., C

streams, including change notices 

• AKSRs (new and updated versions) 

• CCP-TP-005, Attachments 4, 6, 7 and 

including “Add Container” memorand

• Site AK procedures requiring CBFO a

Nondestructive Assay New equipment or substantive physical modifications** to approved 

equipment

Extension of or changes to approved calibration range for approved equipment 

Submission of a list of ORNL-CCP NDA 

performed work during the previous quartNotification to EPA upon substantive mod

• Software for approved equipment 

• Operating ranges upon CBFO approva• Site NDA procedures requiring CBFO 

Real-Time Radiography None Submission of a list of ORNL-CCP RTR o

work during the previous quarter Notification to EPA upon: 

• New equipment or substantive physica

equipment 

• Substantive modification** to site RTR 

approval 

Visual Examination and Visual Examination Technique 

Any use of visual examination Submission of a list of ORNL-CCP VE op

performed work during the previous quart

WIPP Waste Data System Load management Notification to EPA upon substantive mod

procedures requiring CBFO approval 

New T1s, T2s and significant modifications to existing T1s or T2s are in bold text; T1s or T2s that were only revised for style are not shown in 

* ORNL-CCP will report all T2 changes to EPA every three months. ** “Substantive modification” refers to a change with the potential to affect ORNL-CCP’s CH waste characterization processes or documentat

that are solely related to the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act, or that are editoriaaddress administrative concerns. EPA may request copies of new references that DOE adds during a document revision.
3 

2.0 PURPOSE OF TIER 1 EVALUATIONS 

Certain changes to the waste characterization activities from the date of the site’s baseline 

inspection must be reported to and, if applicable, approved by EPA according to the tiering 

requirements set forth in 40 CFR 194.8 regulations and incorporated into the ORNL-CCP CH 

baseline final report (see EPA Docket No. A-98-49; II-A4-103). 

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

(Vol. 69, No. 136, pages 42571–42583), EPA must perform a single baseline inspection of a 

TRU waste generator site’s waste characterization program. The purpose of EPA’s 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 Waste Isolation Pilot Plant (WIPP). 

Following EPA’s baseline approval, EPA is authorized to evaluate and approve changes, if 

necessary, to the site’s approved waste characterization program by conducting additional 

inspections under the authority of 40 CFR 194.24(h). In addition, 40 CFR 194(h) allows EPA to 

conduct continued compliance inspections at sites with approved TRU waste characterization 

programs. EPA performs annual continued compliance inspections of each TRU waste 

characterization program, covering all elements of the programs, including the common elements 

of waste characterization processes that are not expected to significantly vary on a waste stream 

or T1 basis. Examples of the common characterization elements are personnel training, 

procedures and equipment capabilities. EPA will consider the results of continued compliance 

inspections when setting the scope and evaluating site-specific T1 changes. 

Changes requiring EPA notification and approval prior to implementation (T1) and those 

requiring post-implementation notification [Tier 2 (T2)] are identified in the site-specific 

baseline inspection reports and subsequent continued compliance inspection and T1 evaluation 

reports. When evaluating proposed T1 changes for approval, EPA may conduct a site inspection 

to observe implementation of the change or can opt to conduct a desktop review of information 

provided specific to a change. DOE may choose to characterize and dispose of any previously 

approved TRU waste using processes, procedures or equipment implemented as T2 changes at 

risk of subsequent EPA disapproval. 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of EPA’s evaluation of a T1 change to add SCG S3000 

(homogenous solid) waste to the EPA-approved CH TRU waste characterization program. EPA’s 

approval decision regarding the addition of SCG S3000 has been conveyed to DOE separately by 

letter. EPA will also announce the decision on its website at www.epa.gov/radiation/wipp, in 

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

The DOE documents that EPA reviewed for this evaluation are cited throughout the report and 

are listed in Attachment B. Any of these documents can be requested from the following address: 
4 

Carlsbad Field Office 

Manager, National TRU Program 

P.O. Box 3090 

Carlsbad, NM 88221-3090 

4.0 SCOPE OF THIS TIER 1 EVALUATION 

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

related to Waste Stream OR-NFS-CH-HOM-A to demonstrate ORNL-CCP’s S3000 waste 

characterization capabilities. Consistent with the streamlined approach to EPA’s evaluation and 

decision process described in section 2.0, EPA limited the scope of this T1 evaluation to the 

components of AK specific to the addition of SCG S3000 CH waste. Sections 6.1 and 6.2 of this 

report detail the technical elements assessed during this evaluation. 

5.0 INSPECTION PERSONNEL 

EPA and its support personnel conducted interviews with ORNL-CCP waste characterization 

personnel in AK and RTR. The EPA inspection team and ORNL-CCP personnel contacted are 

listed in Table 2. Because the T1 evaluation took place during the February 2014 continued 

compliance inspection, additional DOE, EPA and ORNL-CCP personnel were also present. All 

personnel present during the continued compliance inspection are listed in Attachment C, with 

their affiliations and areas of expertise or function. 

Table 2. Tier 1 Evaluation Participants 

6.0 TECHNICAL EVALUATION 

Sections 6.1 and 6.2 of this report detail the technical areas assessed during this inspection: AK 

and RTR. EPA completed inspection checklists for AK and RTR based on responses of ORNLCCP waste characterization personnel to EPA queries and other documentation (see Attachments 

D and E). When evaluating future T1 change requests and concurring with quarterly T2 change 

submissions, EPA may use these checklists to supplement its review. 

6.1 Acceptable Knowledge 

EPA examined the programmatic requirements and AK process and associated information 

during the continued compliance inspection in February 2014. Therefore, EPA limited the scope 

Name Affiliation & Function 

Rajani Joglekar Lead Inspector, U.S. EPA 

Ed Feltcorn Inspector, U.S. EPA 

Kira Darlow Technical Evaluator – Acceptable Knowledge, SC&A, Inc. 

Dorothy Gill Technical Evaluator – Nondestructive Examination, SC&A, Inc. 

Jeff Harrison AK Expert 

Beverly Schrock ORNL-CCP CH SPM 

Fred Oney ORNL-CCP RTR Operator 

Steve Redmond ORNL-CCP RTR Operator 
5 

of this AK evaluation to those elements necessary to assess the technical adequacy of the 

information supporting the addition of SCG S3000 (homogenous solid) waste. 

Waste Characterization Element Description 

EPA limited this T1 evaluation to the technical elements listed below. 

• Waste stream definition. 

• AK procedural implementation. 

• AKSR completion. 

• Drum traceability from generation through characterization. 

• NDA-AK communication. 

• Verification that the subject waste is of defense origin and is not high-level waste (HLW) 

or spent nuclear fuel (SNF). 

Technical Evaluation 

The results of EPA’s technical evaluation are summarized below. EPA’s evaluation checklist is 

included as Attachment D to this report. ORNL-CCP provided CCP-AK-ORNL-001, Revision 8, 

to EPA prior to the start of the T1 evaluation and then revised the AK Summary Report (AKSR; 

CCP-AK-ORNL-001, Revision 9) as a result of the February 2014 continued compliance 

inspection. EPA considers Revision 9 of the AKSR to be the officially-submitted document for 

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

(1) EPA evaluated ORNL-CCP’s application of a waste stream definition for Waste Stream 

OR-NFS-CH-HOM-A and found it to be adequate. 

A CH waste stream is defined as waste being similar in material and physical form that was 

generated from a single process or activity. ORNL-CCP adequately defined Waste Stream ORNFS-CH-HOM-A, which contains homogenous solids that were created during decommissioning 

of Buildings 234 and 110 at Nuclear Fuel Services (NFS) in Erwin, Tennessee. 

(2) EPA evaluated ORNL-CCP’s acceptable knowledge procedural implementation and 

found it to be adequate. 

EPA evaluated ORNL-CCP’s implementation of procedure CCP-TP-005 by examining each of 

the completed form attachments to that procedure. ORNL-CCP adequately completed all 

applicable attachments and utilized forms from the correct revision of the procedure in every 

example EPA reviewed. 

Notification to EPA upon substantive modification to CCP-TP-005, Attachments 4, 6, 7 and 8 

and/or associated memoranda, including “Add Container” memoranda remains a T2 change (see 

Table 1) 
6 

(3) EPA assessed the acceptable knowledge summary report for completeness, including 

adequate descriptions of the radiological and physical characteristeics of the waste, and 

found it to be adequate. 

The AKSR contains all required elements and sufficient detail describing AK-based information 

about the radiological and physical characteristics of Waste Stream OR-NFS-CH-HOM-A. 

ORNL-CCP gathered and cited sufficient AK source documents to support all information 

contained in the AKSR. 

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

(4) EPA assessed drum traceability and the ability to follow the acceptable knowledge 

process for containers and found it to be adequate.

On February 5, 2014, EPA randomly selected three containers to assess drum traceability: 

NFS0479A1, NFS0481, NFS0865A. All three containers are included in the Attachment 8-Waste 

Containers List and are traceable from NFS to receipt at ORNL. ORNL repackaged drum Nos. 

NFS0479A1 and NFS0865A, and both drums are traceable through the repackaging process. 

Drum No. NFS0481 had not yet been characterized by ORNL-CCP. EPA traced drum No. 

NFS0479A1 through ORNL-CCP RTR characterization; the container had not yet been through 

NDA. EPA traced drum No. NFS0865A through the ORNL-CCP RTR and NDA processes to 

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

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

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

NFS manufactured custom nuclear fuels for various clients in Buildings 234 and 110, and greater 

than 90% of the fuel produced in these buildings was for defense-related projects or clients 

(References C099, C100 and M021). EPA finds this determination to be adequate. 

(6) EPA evaluated documentation regarding the status of spent nuclear fuel and high-level 

waste, and found this waste stream to be in compliance with the Waste Isolation Pilot 

Plant Land Withdrawal Act. 

NFS manufactured nuclear fuel from scrap plutonium (Pu) or Pu that had been reprocessed 

elsewhere. NFS did not work with any SNF and did not have any reprocessing capabilities on 

site. Therefore, none of the waste in Waste Stream OR-NFS-CH-HOM-A could be either SNF or 

HLW (References C099, C145, P273 and U038). EPA finds this determination to be adequate. 

(7) EPA assessed nondestructive assay–acceptable knowledge communication and found it 

to be adequate. 

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

same NDA-AK memorandum and Attachment 7-Radionuclides as the other NFS-origin waste 

streams described in the AKSR. This is acceptable since all of the NFS-origin waste streams 

were generated during decommissioning of Buildings 234 and 110 at NFS, and therefore the 

wastes would have similar radiological characteristics. ORNL-CCP included individual 

expected-radionuclide tables for each waste stream, but only one set of default isotopics. EPA 
7 

has previously evaluated the NDA-AK memorandum for the NFS-origin waste streams (most 

recently during the February 2014 continued compliance inspection; see EPA Docket No. A-98-

49; II-A4-186), and finds the modifications for inclusion of Waste Stream OR-NFS-CH-HOM-A 

to be adequate. 

Summary of Acceptable Knowledge Findings and Concerns 

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

issues relative to this T1 evaluation. 

Changes to Tiering 

Based on the results of this T1 evaluation, EPA revised the CH AK T1 designations to reflect 

that addition of SCG S3000 waste is no longer a T1 change. For consistency, all of the T2 

elements listed under AK in Table 1 apply to all approved ORNL-CCP CH TRU waste streams. 

Acceptable Knowledge Approval 

Based on this evaluation, EPA approves this T1 change. ORNL-CCP is approved to characterize 

SCG S3000 CH TRU waste, consistent with the limitations specified in this report. 

6.2 Real-Time Radiography 

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

The procedures used to generate the data reported in the batch data reports (BDRs) discussed 

throughout section 6.2 are well established and have been reviewed by EPA inspectors at 

previous onsite inspections. The procedures continue to comply with 40 CFR 194. 

Notification to EPA upon substantive modification to site NDE procedures requiring CBFO 

approval remains a T2 change (see Table 1). 

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

adequate. 

EPA reviewed the audio/visual and written records for selected containers from BDR Nos. ORRTR6-0437, OR-RTR6-0438, OR-RTR6-0439 and OR-RTR6-0440 and determined that the 

records were complete and generated in accordance with ORNL-CCP procedures. RTR operators 

had properly examined each container’s contents and entered characterization data into an 

electronic data sheet. RTR operators determined that the waste matched the waste stream 

description and verified the waste matrix code (WMC). ORNL-CCP generated on conformance 

report (NCR) NCR-ORNL-0873-13 to address one RTR operator’s misidentification of the 

WMC and waste stream description. This error was identified at the Independent Technical 

Reviewer (ITR) level and the applicable BDRs were corrected as necessary in accordance with 

ORNL-CCP procedures and processes. No other prohibited items were identified in the 

containers from the reviewed BDRs. 
8 

RTR operators performed an image quality check prior to each RTR event for the BDRs 

examined. ORNL-CCP personnel had performed the required quality control examinations, i.e., 

an independent observation and replicate scan, for the BDRs reviewed. 

ORNL-CCP reviewed the data at the data-generation and SPM level; the reviews were recorded 

on the appropriate forms from the applicable ORNL-CCP procedures. 

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

EPA reviewed the following written and audio/visual training records for selected RTR 

operator/ITR personnel: 

• Inventory sheets for RTR containers NDE-TEST-11, NDE-TEST-20, NDE-TEST-22, 

NDE-TRAINING-19, NDE-TRAINING-26, NDE-TRAINING-30, NDE-TRAINING-32. 

• Training Container Evaluation Data Sheets for selected operators. 

• Audio/visual recordings of test examinations for selected personnel. 

• Qualification Cards for selected personnel. 

• List of qualified individuals. 

The above records demonstrated that RTR personnel were trained in accordance with ORNLCCP procedures and that training records were complete. 

Submission to EPA of a list of all RTR personnel who performed work during the previous 

quarter remains an RTR T2 change (see Table 1). Specifically, the list must include all RTR 

operators and ITRs. 

Summary of Real-Time Radiography Findings and Concerns 

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

Real-Time Radiography Approval

Based on this evaluation, EPA approves this T1 change. ORNL-CCP is approved to characterize 

SCG S3000 CH TRU waste using RTR, consistent with the limitations specified in this report. 

Based on the results of this T1 evaluation, there are no revisions to the RTR T1 or T2 

designations. 

7.0 FINDINGS AND CONCERNS 

EPA did not identify any findings or concerns during this T1 evaluation. 
9 

8.0 CONCLUSIONS 

Changes to Tiering 

Based on this T1 evaluation, there is one change to the CH AK T1 designations to reflect that 

addition of SCG S3000 waste is no longer a T1 change. This change is reflected in EPA’s tiering 

table, Table 1, above. 

Table 1 shows the substantive T1 change in bold text. T1 and T2 changes that were initiated 

during the CH baseline and subsequent T1 approvals remain in effect. The language in Table 1 

regarding AK documentation applies to all ORNL-CCP waste streams. 

Approval 

EPA concluded that the waste characterization processes of AK and RTR used to characterize 

CH TRU SCG S3000 (homogenous solids) are adequate, as evidenced by the records evaluated. 

There are no open issues relative to this T1 evaluation 

Based on the results of this evaluation, EPA approves this T1 change to add SCG S3000 waste to 

the ORNL-CCP EPA-approved CH TRU waste characterization program, consistent with the 

limitations specified in this report. ORNL-CCP may continue to characterize previously 

approved CH TRU waste consistent with the restrictions specified with the approvals listed in 

Appendix A to this report. 
A-1 

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

WASTE CHARACTERIZATION PROGRAM 

Approved Activity EPA Inspection Number, 

Approval Dates EPA Docket Number 

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

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

T1 Change – Extension of the Calibration and Density 

Ranges for the SGS NDA System October 8, 2008 A-98-49; II-A4-108 

T1 Change – Extension of the Passive Mode 

Calibration Range for the DWAS/IPANSGS January 8, 2009 A-98-49, II-A4-109 

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

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

T1 Change – Addition of the MCS IQ3 NDA System 

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

T1 Change – Addition of NFS Trench B Soils to Waste

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

Continued Compliance Inspection and T1 Change for 

Modifications to the IQ3 NDA System June 18, 2014 A-98-49; II-A4-186 
B-1 

ATTACHMENT B: LIST OF DOCUMENTS REVIEWED FOR THIS EVALUATION 

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

1980 Edition 

Audio/visual recordings for selected containers from BDR Nos. OR-RTR6-0437, OR-RTR6-

0438, OR-RTR6-0439 and OR-RTR6-0440 

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

Information, May 3, 2005 

C100, Interview with Richard Booth and faxed defense and Waste Information for NFS, 

February 24, 2005 

C145, Memo to Distribution re: Nuclear Fuel Services, In. (NFS) Background Information, D.W. 

Turner, February 7, 1992 

C203, Letter to Martin Tull from Robert A. Hunt Regarding a Picture of the Proposed Method to 

"Lab Pack" Bottles of Immobilized Respirable Fines and Residual Materials, Robert A. Hunt, 

Ecotek, Inc., March 23, 1993 

C206, Numerous Faxes Containing Handwritten Notes (Oversight Reports) from Paul O. 

Emerson re: Such Items as Sampling the Top of the Underground Tank, Pu Crew activities, 

Equipment Issues, Processing of Gloveboxes and Information on Drums that were Packaged, 

Paul O. Emerson, January 9, 1991 through August 28, 1992 

C209, Internal Correspondence to F.J. Shultz from J.A. Chapman regarding NFS Project 

Accomplishments for Month of April 1992, J.A. Chapman, May 4, 1992 

C210, Interview re: NFS TRU Waste Shipped to Oak Ridge National Laboratory. Interviewees: 

Richard Booth, Richard Moore, Bob Hunt, Scott Toller, Marie Moore, J. Harrison and L. 

Watson, September 12, 2007 

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

CCP-AK-ORNL-001, Central Characterization Program Acceptable Knowledge Summary 

Report for Nuclear Fuel Services Contact-Handled Transuranic Waste Stored at Oak Ridge 

National Laboratory, Revision 8, December 12, 2013, and Revision 9, February 6, 2014 

CCP-QP-005, Revision 23, CCP TRU Nonconforming Item Reporting and Control, Attachment 

1 – CCP Nonconformance Report (NCR), NCR-ORNL-0873-13, Revision 0, origin date 

December 11, 2013, interim hold date December 12, 2013 

CCP-TP-005, Revision 20, CCP Acceptable Knowledge Documentation, Attachment 7 – 

Radionuclides, OR-NFS-CH-HOM-A, Jeff Harrison, November 16, 2010 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, OR-NFS-CH-HOM-A, Jeff Harrison, January 

7, 2014 
B-2 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, OR-NFS-CH-HOM-A, Travis 

Smith, January 6, 2014 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, OR-NFS-CH-HOM-A, Jeff 

Harrison, December 5, 2013 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, OR-NFS-CH-HOM-A, Jeff Harrison, December 5, 2013 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, Lot 1, OR-NFS-CH-HOM-A, 

unsigned draft dated January 8, 2014, provided February 5, 2014 

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

DR031, Discrepancy Resolution re: OR-NFS-CH-HOM-A EPA Hazardous Waste Number 

Assignment, Jeff Harrison, January 10, 2011 

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

LOQI for RTR operators dated 1/21/14 

M003, ORNL UCN-2109 and UCN-2822 Forms for NFS TRU Waste and Related Paperwork for 

Waste Stored at ORNL, August 26, 1993 

M007, Internal Correspondence and the Environmental Assessment for the Receipt and Storage 

at ORNL of Transuranic Waste, Mixed Transuranic Waste, and Mixed Oxide Waste from 

Nuclear Fuels and the Environmental Assessment for Disposition of Transuranic Waste, L.T. 

Cusick, LTR# ER-NEP A/92-015, November 9, 1992 

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

M021, Defense Determination Approval for ORNL/NFS-HD-001, Heterogeneous Debris- NFS, 

Betty Humphrey, ORNL-HD-001-IF, May 13, 2005 

M075, TWPC Contact Handled Waste Repackaging Data Forms for NFS Waste (Container 

Paperwork), ORNL, various dates 

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

2010 

M202, Review of WEAF RTR Videos for NFS Immobilized Liquids and Fines, Rick Schultz, 

October 11, 2010 through October 13, 2010 

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

P1116, EnergX TRU Waste Processing Center Procedure: Absorbing Liquids, EnergX, CH-IOP-013, Revision 4, June 27, 2008, and Revision 6, November 17, 2008 
B-3 

P1371, Procedure for Removal and Decontamination of Utility and Process Lines and Systems, 

NFS, DCM-11, Revision 2, October 15, 1992 

P212, Lattice Experiments with Simulated Burned Up Fuel for D20 Power Reactors, N.P. 

Baumann et al., February 1968 

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

Verification Program, Martin Marietta Energy Systems, October 29, 1992 

P251, Box Breakdown Area Operations, CH-UET-OP-003 and CH-P-OP-003, Revisions 4, 7, 9, 

12, 15, 18 and 20, March 13, 2007, through July 16, 2013 

P252, Glove Box Operations, CH-UET-OP-004 and CH-P-OP-004, Revisions 5, 8, 10, 14, 17, 

18 and 20, March 13, 2007, through June 20, 2013 

P253, Drum Bag In/Bag Out and Glove Ports, CH-REF-OP-001 and CH-P-OP-011, Revisions 1-

1, 10, 12, 13, 14, 16 and 18, May 2, 2007, through February 11, 2013 

P254, Contact Handled Waste Repackaging, CH-REF-OP-013 and CH-P-OP-013, Revisions 0, 

1, 2, 3, 4, 5,6, 7, 8, 9, 12, 13 and 14, April 30, 2007, through August 27, 2013 

P273, NFS, Inc. Waste Certification Plan for Transuranic Waste, no date 

P274, Segregation and Immobilization of Particulate Fines, NFS Decommissioning Department, 

DCM-58, Revisions 0 and 1, July 1991, November 1992 and February 1992 

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

August 16, 1991 

P321, Determination of Plutonium lsotopics for Building 110 and 234, John T. Caldwell, April 

28, 1992 

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

Qualification Cards for selected RTR personnel 

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

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

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

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

Training Container Evaluation Data Sheets for various RTR operators 

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

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

Constituents, J.A. Chapman, March 1992 
B-4 

U017, The lntercomparison of NDA Measurements on CH-TRU Waste Between Nuclear Fuel 

Services, Inc. and Oak Ridge National Laboratory, J.A. Chapman, et a., October 24, 1995 

U038, ORNL TRU Waste Historical Survey; Volumes 1,2 and 3- Origins and Characteristics of 

Remote-Handled Transuranic Wastes (Trabalka report) Plus Appendices, J.R. Trabalka, A.J. 

Mattus and S.N. Storch, BJC/OR-395-V/1,2,3, Draft, September 2001 

U054, Decontamination and Decommissioning of a Plutonium Fabrication Facility Michael 

West, Robert Hunt and Donald Paine, not dated 

Waste Material Parameter Analysis Memorandum, Jeff Harrison, November 1, 2010 
C-1 

ATTACHMENT C: FEBRUARY 2014 CONTINUED COMPLIANCE INSPECTION PERSO

Personnel Affiliation Area of Expertise/Function Entrance Meeting Interviewed 

Rajani Joglekar U.S. EPA ORIA Inspector–Team Leader  Ed Feltcorn U.S. EPA ORIA Inspector  Dorothy Gill SC&A, Inc. RTR/VE Inspector  Connie Walker SC&A, Inc. AK Inspector  Kira Darlow SC&A, Inc. AK Inspector  Patrick Kelly SC&A, Inc. NDA/DTC Inspector  Andrew Stallings ORNL-CCP VPM  Anthony Harley ORNL-CCP VE Operator/ITR, VEE, SME/OJT Expert   Berry Pace CBFO/CTAC QA Observer  Beverly Schrock CCP CH SPM   Chuck Wallace ORNL-CCP VE Operator/ITR Daniel Crosby MCS/CCP DTC Operator David Queen DOE EMOR Project Manager David W. Moody NWP/CCP RH SPM   Derek Matheny ORNL-CCP VE Operator/ITR Derek Ott NWP/CCP RH Radiological Engineer   Fred Oney CCP/VJT RTR/LO   Irene Joo NWP/CCP RH Manager   J.R. Stroble DOE/CBFO Observer Jeff Harrison ORNL-CCP AKE   Jeremy Robinson NFT/CCP FGA Jose R. Franco DOE/CBFO Observer Kenneth Lickliter CBFO/CTAC Observer  Kevin J. Peters ORNL-CCP AKE  LaTravia Harmon CCP QA QA (NWP)  Lisa Watson ORNL-CCP AKE   Marcus A. Pinzel DOE/CBFO RH Program Manager Maria Steade MCS/CCP NDA IQ3 Operator Mark Doherty CBFO/CTAC Observer  
C-2 

Michael Sensibaugh CCP Operations Manager   

Neil Dickes NWP/CCP NDA Support  R.C. McKay WAI General Manager Ronald Whitson MCS/CCP NDA/DTC   Ronnie Lee NWP/CCP Waste Characterization Manager  Scott Kranker WAI STR  Sean Stanfield MCS NDA IQ3 Steve Redmond ORNL-CCP RTR Tammy Reynolds NWP/CCP CCP Program Manager/Observer Tom Morgan CBFO/NTP CCP Manager   
D-1 

ATTACHMENT D: AK TIER 1 EVALUATION CHECKLIST: WASTE STREAM OR-NFS-C

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-NFS-CH-HOM-A Inspection 

Technical Elements Objective Evidence 

CCP-TP-005 Implementation AK-1: Confirm that Attachment 1, Acceptable Knowledge Documentation Checklist, is complete. 

Revision 26; Dated 1/7/2014; Signed by Jeff Harrison Att. 1 includ

that any AKto the HOM

apply to speSD is found useful, it is nfrom Att. 1. AKSR must vice versa. 

AK-2: Confirm that Attachment 2, Record of Communication, is completed as necessary. 

C210 None. 

AK-3: Confirm that an Attachment 3, Acceptable Knowledge Source Document Summary, is complete for every source document. 

See reference list in Attachment B All reviewed 

associated A

AK-4: Confirm that Attachment 4, Acceptable Knowledge Source Document Information List, is complete and up to date. 

Revision 26; Dated 1/6/2014; Signed by Travis Smith Att. 4 includ

ever thoughwaste streamapply or not automaticallEvery SD ci4, but not vi

AK-5: Confirm that Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, and Packaging, is complete and up to date. 

Revision 26, Dated 12/5/2013, Signed by Jeff Harrison. 

WMP analysis memorandum, Dated 11/1/2010, Signed by Jeff Harrison 

Calculated bpaperwork aTable 7-1 in 

AK-6: Confirm that Attachment 7, Radionuclides, is complete and up to date and that AK-NDA communication is appropriately documented. 

Revision 20, Dated 11/16/2010, Signed by Jeff Harrison. 

NDA memorandum, Dated 11/15/2010, Signed by Jeff Harrison (AKE), Robert Ceo (NDA SME), Joe Wachter (MCS Technical Director) and Joe Harvill (CCP Project Office) 

HOM-A waother NFS wappropriate discussion to memorandu
D-2 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-NFS-CH-HOM-A Inspection 

AK-7: Confirm that Attachment 8, Waste Containers List, is complete and up to date. 

Revision 26, Dated 12/5/2013, Signed by Jeff Harrison Att. 8 is reco

waste streamfrom Att. 8 iwaste streamotherwise exdo not add dcontainer nucontainers a

AK-8: Confirm that Attachment 10, Acceptable Knowledge Re-evaluation Checklist, is completed as necessary. 

None AKEs confir

A waste stre

AK-9: Confirm that Attachment 11, Acceptable Knowledge Source Document Discrepancy Resolution, is completed as necessary. 

DR030 and DR031 AKEs confir

waste stream documents cA to HOM-A documents eHWN shoulwaste. 

AK-10: Confirm that Attachment 13, CCP Waste Stream Characterization Checklist, is completed foreach characterization lot. 

Revision 26, Draft for Lot 1, Dated 1/8/2014, Not signed, Provided 

2/5/2014 

Att. 13 is coAtt. 13 also implementat005 impactiNDA reportare not incluthese radionWIPP-trackecontribute to hazard for pdoes not nee

AK-11: Confirm that Attachment 14, CCP Acceptable Knowledge Accuracy Report, is completed annually and verify that the AK accuracy report memorandum is technically adequate. 

None AKEs and S

have not assrestart. 

AK-12: Confirm that Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form, is completed as necessary. 

N/A N/A 

AK-13: Confirm that the AKSR is complete and accurately describes the subject waste. 

CCP-AK-ORNL-001, Revision 9 AKSR inclu

componentsand AKCH-
D-3 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-NFS-CH-HOM-A Inspection 

Waste Stream Definition and Waste Identification AK-14: Verify that all waste within the waste stream was generated from a single process/activity and that the generating process/activity is adequately described. 

CCP-AK-ORNL-001, Revision 9 C210, M007, M075, P218, P251, P252, P253, P254, P274, P319, P1116, P1371, U038, U054 

Waste generimmobilizatand other hicollected duBuildings 23at TWPC. 

AK-15: Verify that all waste within the waste stream is similar in material and physical form and that the expected physical perameters are adequately described. 

CCP-AK-ORNL-001, Revision 9 Attachment 6 and memorandum C203, C206, C209, C210, M003, M202, P218, P274 

WMPs estimdisposal papinformationRTR data. 

AK-16: Verify that the expected radiological characteristics are adequately described. 

CCP-AK-ORNL-001, Revision 9 Attachment 7 and memorandum C099, C100, M003, M012, M198, P212, P218, P321, U016, U017, U038, U054 

238U and 239P

prevalent by may result in 

prevalent dumeasuring 2

AK-17: Verify that waste containers are traceable from retrieval through CCP’s EPA-approved characterization process. 

NFS0479A1: Att. 8; M003; M075; M202; OR-RTR6-0437, 

12/10/2013 NFS0481: Att. 8; M003; M202; not yet ORNL-CCP-characterized NFS0865A: Att. 8; M003; M075; M202; OR-RTR6-0437, 12/10/2013; OR-IQ3-0224 assay 12/4/2013; Draft characterization checklist Lot 1, 1/8/2014 

Drums are trORNL-CCP 

Land Withdrawal Act Requirements AK-18: Verify that all of the waste in the waste stream is defense in origin. 

CCP-AK-ORNL-001, Revision 9 C099, C100, M021 

Over 90% owas for defe

AK-19: Verify that none of the waste in the waste stream is high-level waste. 

CCP-AK-ORNL-001, Revision 9 C099, C145, P273, U038 

AKSR is adreprocess SN

AK-20: Verify that none of the waste in the waste stream is spent nuclear fuel. 

CCP-AK-ORNL-001, Revision 9 C099, C145, P273, U038 

AKSR is adwere scrap Preprocessing SNF. 
E-1 

ATTACHMENT E: RTR TIER 1 EVALUATION CHECKLIST 

Establishment of Required 

Technical Elements in Procedures Execution of Procedures Objective Evidence/C

RTR-1: Site procedures identify required training and qualifications for RTR personnel CCP-TP-028, Revision 8 CCP-QP-002, Revision 35 

RTR operators receive training on the waste matrix parameters and typical packaging configurations expected in each waste stream. To become qualified, the RTR operator must pass a comprehensive written test based on training objectives with a minimum score of 80% Unsatisfactory performance – failed to identify prohibited item during OJT of score of less than 80% on exam Demonstrate capability (At initial qualification, requalification, and semiannually, successfully examine a training container). 

At initial qualification, and subsequent requalification, successfully examine a test drum. 

RHVE operators re-qualified every 2 years based on continued satisfactory performance 

The original inventories for demonstratiNDE-TEST-22 and NDE-TRAINING-3these were identified and corrected by CObjective evidence: 

1. Inventory sheets for RTR container N

TEST-20, NDE-TEST-22, NDE-TRTRAINING-26, NDE-TRAINING-3

2. Training Container Evaluation Data 

operators 

3. Qualification Cards for selected RTR 4. Training roster for CCP-AK-ORNL-

5. LOQI RTR operators dated 1/21/14 6. Revisions 1 and 2 of Prohibited Item

operators

7. American Society for Nondestructiv

Practices, No. SNT-TC-1A, June 19

RTR-2: Site procedures provide complete instructions for operators to perform the RTR examination and completion of the associated documentation CCP-TP-053, Revision 14 

RTR operator adequately explained the process followed for examining a drum and entering data into data forms (whether hard copy or electronic data entry is used). 

EPA did not identify any issues associat

recording of CH S3000 RTR data. Objective evidence: 

1. BDR Nos. OR-RTR6-0437, OR-RTR

and OR-RTR6-0440 

2. Audio/visual recordings for selected 

CH BDRs 

3. Training roster for CCP-AK-ORNL-

RTR-3: The RTR procedures require an image quality check to be performed CCP-TP-053, Revision 14, section 4.3, Attachment 1 

Operator adequately explained how the acceptability of an image is determined Image quality check is performed once per day (RTR Measurement Control Report) Performance of the image quality check is documented and recorded

The result of the image quality test was Att. 1.Objective evidence: 

1. BDR Nos. OR-RTR6-0437, OR-RTR

and OR-RTR6-0440

2. Audio/visual recordings for selected 

CH BDRs 
E-2 

Establishment of Required 

Technical Elements in Procedures Execution of Procedures Objective Evidence/C

RTR-4: The procedure allows the operator to adjust the RTR to accommodate the physical properties of the waste and waste containers likely to be encountered at the site CCP-TP-053, Revision 14 

Operator could identify applicable policies and procedures governing the operation of RTR equipment The RTR system could be adjusted High-density material was examined with the Xray device set on the maximum voltage and low density material at a lower voltage Operator adequately explained what is done if an image is unacceptable (e.g., the waste is solidified or the container is lead-lined) 

For containers NFS0788A (BDR No. ONFS0806A (BDR No. OR-RTR6-0439)

WMC and that the waste matched the wHowever, drum No. NFS0788A containNo. NFS0806A contained scrap lead; th

waste not matching the waste stream de

ITR identified these errors. ORNL-CCP 0873-13 to address this issue and correcObjective evidence: 

1. BDR Nos. OR-RTR6-0437, OR-RTR

and OR-RTR6-0440

2. Audio/visual recordings for selected 

CH BDRs 

3. CCP-TP-053, CCP Standard Real-Ti

Inspection Procedure, Revision 14, 0

4. Qualification Cards and training reco

RTR operator 

5. Training Container Evaluation Data 

operators 

6. NCR NCR-ORNL-0873-13 

7. Training roster for CCP-AK-ORNL-

8. CCP-QP-005, CCP TRU Nonconfor

Control, Revision 23, 06/25/2013 

RTR-5: Data records are of sufficiently high quality for complete review CCP-TP-053, Revision 14 

RTR tape is high quality, the sound track is audible, and the required information is contained on the audible portion of the tape The RTR tape is consistent with the data package for the same drum. 

EPA compared audio/visual recordings selected containers to verify that the datObjective evidence: 

1. BDR Nos. OR-RTR6-0437, OR-RTR

and OR-RTR6-0440

2. Audio/visual recordings for selected 

CH BDRs 
E-3 

Establishment of Required 

Technical Elements in Procedures Execution of Procedures Objective Evidence/C

RTR-6: There is a procedure for determining whether the waste matches the waste stream description and Waste Matrix Code, and for determining Waste Material Parameters and weights CCP-TP-053, Revision 14, Tables 2 & 3, Attachment 2 

The procedure is adequately implemented Operators verify that the waste matches the waste stream description Waste Matrix Code is verified. If not, corrective action is taken WMP weights are estimated by compiling an inventory of waste items and residual/packaging materials Does the RTR operator use a standard weight lookup table to provide an estimate of WMP weights? If so, has the table been updated to reflect additional information gained through previous RTR/VE exams or updated AK information? 

The audio/visual and written records, redemonstrated that the waste in each conand waste stream description. The operaprohibited items and estimated WMP wprocedure CCP-TP-053 (see RTR-4 of tCCP-TP-053 provides standardized weiitems to assist the operator when assigniObjective evidence: 

1. BDR Nos. OR-RTR6-0437, OR-RTR

and OR-RTR6-0440

2. Audio/visual recordings for selected 

CH BDRs 

3. NCR NCR-ORNL-0873-13 

RTR-7: The RTR procedure provides instructions for identifying prohibited items and for processing drums containing prohibited items CCP-TP-053, Revision 14, Table 1 

Operator could name prohibited items Operator adequately explained how the presence of prohibited liquids is determined Operator’s explanation of required actions if prohibited items were encountered was consistent with procedure 

See RTR-4 of this checklist. The subjec

accordance with CCP procedures. No otidentified during the examinations. 

Objective evidence: 

1. BDR Nos. OR-RTR6-0437, OR-RTR

and OR-RTR6-0440

2. Audio/visual recordings for selected 

CH BDRs 

3. Prohibited Item training module, Rev

8/23/10 and 3/29/11 respectively. 

4. NCR NCR-ORNL-0873-13

RTR-8: RTR procedures include the required QC examinations, evaluation accuracy and reproducibility of the RTR process CCP-TP-053, Revision 14, sections 4.5 & 4.6 

An independent replicate scan is performed on one waste container per day or on one container per testing batch (whichever is less frequent) An independent observation of one scan (not the replicate) is performed, by a qualified RTR operator (anyone but the initial RTR operator) 

In BDR No. OR-RTR6-0437, the indepe

performed on container No. NFS0479Acontainer No. NFS0414I; in BDR No. Oindependent observation was performed 

NFS0508A and the replicate scan on co

second qualified operator performed the as required by procedure CCP-TP-053. Objective evidence: 1. BDR Nos. OR-RTR6-0437, OR-RTR

and OR-RTR6-0440

2. Audio/visual recordings for selected 

CH BDRs 
E-4 

Establishment of Required 

Technical Elements in Procedures Execution of Procedures Objective Evidence/C

RTR-9: Procedures contain standardized forms for recording RTR data CCP-TP-053, Revision 14, Attachment 2 

RTR operator adequately explained the process followed for examining a drum and entering data into data forms (whether hard copy or electronic data entry is used). Direct data entry into an electronic form is done by the RTR operator using a computer while the operator is still in the RTR booth. The electronic data file undergoes the same QC checks used for hand-written data entries 

The operator had identified waste items electronic data form, CCP-TP-053, Att. 

absence of prohibited items and estimat

accordance with procedure CCP-TP-053

provides standardized weights for commthe operator when assigning estimated w

been reviewed at the data generation and Objective evidence: 1. BDR Nos. OR-RTR6-0437, OR-RTR

and OR-RTR6-0440

2. Audio/visual recordings for selected 

CH BDRs 

RTR-10: Site procedures require review of Batch Data Reports (BDRs) at the data generation and project level CCP-TP-053, Revision 14, section 4.10 CCP-TP-001, Revision 21, Attachment 2 

Data generation level reviews are performed and documented (ITR) Project level reviews are performed and documented (SPM) 

All of the BDRs reviewed had been revi

and project level. The ITR and SPM doc

required on CCP-TP-053, Att. 3, and CCsigned and dated the reviews. Objective evidence: 

1. BDR Nos. OR-RTR6-0437, OR-RTR

and OR-RTR6-0440