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 FOR 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 20460

January 2012
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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 the 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 Characterization............................................................................... 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......................................................................................................................... 43
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ATTACHMENTS

Attachment A: Documents Reviewed During the Baseline Inspection

Attachment B: Inspection Personnel List

Attachment C: EPA Inspection Issue Tracking Form No. SRS-CCP-RH-AK-11-01CR

LIST OF TABLES

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by SRSCCP ................................................................................................................................ 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............................ 27
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ACRONYMS AND INITIALIZATIONS

%RSD percent relative standard deviation

AK acceptable knowledge

AKE Acceptable Knowledge Expert

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 Surrogate 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 Register
iv

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 qualified 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 hour
v

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 visual 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 yttrium
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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 characterized 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-CCP’s RH TRU waste characterization 

program at SRS in Aiken, South Carolina. Baseline Inspection No. EPA-SRS-CCP-RH-08.11-8

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 the 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 proposes 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 streams that have companion1 CH debris 

waste streams

(2) 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 footnote1) CH debris waste 

streams for assigning radionuclide values, 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 waste 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 (mrem/hr), which makes the waste CH or RH, respectively.
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(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 that 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 plutonium (Pu) isotopes plutonium-239 (239Pu), plutonium-240 (240Pu) 

and plutonium-241 (241Pu) to americium-241 (241Am). Further, use of the MCS/ISOCS for 

determining the scaling factor for plutonium-238 (238Pu) or for direct quantification 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 characterized 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 radioactive waste [63 Federal Register (FR) 27354 and 27405, May 18, 

1998]. EPA Baseline Inspection No. EPA-SRS-CCP-RH-08.11-8 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. 42571–42583).
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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-580 or CCP-AK-SRS-582 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 CCP-AK-SRS-580, CCP-AK-SRS-582, 

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, prepared annually at a minimum 

(AK11)

When Add Container Memoranda have been prepared (AK5)

When additional discrepancy resolution reports and nonconformance reports 

have been prepared (AK4)

Radiological Characterization, 

including Dose-to-Curie 

Use of the MCS/ISOCS to provide any information other than the relative 

determinations of 239Pu, 240Pu and 241Pu to 241Am (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 

those 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*** (RC1, 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*** (RTR1)

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 document updates are editorial in nature or are required solely to address administrative concerns.
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2.0 PURPOSE OF INSPECTIONS

On May 18, 1998, EPA certified that the WIPP would comply with the radioactive waste 

disposal regulations in 40 CFR Part 191. In that certification, 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 processes 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 AK2for waste streams proposed for disposal at the 

WIPP and (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 inspection 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 

that 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.3The 

system of controls 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 requirements 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 followup inspections to address issues remaining from the baseline 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 process, 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 Condition 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 

limit 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.‖
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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 compliance4and 

(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 REPORT

This report documents the basis for EPA’s proposed baseline approval and explains the results of 

Baseline Inspection No. EPA-SRS-CCP-RH-08.11-8 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 objective 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 approval

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) changes listed in Table 1 are followed by a reference to the section of this 

report where the technical basis for that 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 changes 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 they 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-CCP personnel. Upon evaluation with or 

without a site inspection, EPA will issue a decision. Only upon receiving EPA written approval 

may SRS-CCP implement T1 changes.

 

4 The potential contents of a single waste 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 selected 

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 the scope of EPA’s inspection.
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EPA will notify the public of the results of its evaluations of T1 and T2 changes established as 

part of the SRS-CCP final approval through the EPA website 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 address:

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 following 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 www.epa.gov/radiation/wipp. 

4.0 SCOPE OF INSPECTION

The scope of Baseline Inspection No. EPA-SRS-CCP-RH-08.11-8 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 inspection 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 activities and associated uncertainties of the 10 WIPP-tracked 

radionuclides [241Am, cesium-137 (137Cs), 238Pu, 239Pu, 240Pu, plutonium-242 (

242Pu), 

strontium-90 (90Sr), uranium-233 (233U), uranium-234 (

234U) and uranium-238 (238U)] 

and other TRU radionuclides 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 reviewing 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 

processes implemented and available as alternatives; and (c) SRS-CCP’s documentation and 

record-keeping procedures. In addition, the EPA evaluation focused on observing equipment 
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operations and waste characterization practices at SRS controlled by site procedures, 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. Objective 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 

evaluation of the waste characterization processes in conjunction with objective evidence, EPA 

determined the technical adequacy of these processes and associated records within the 

inspection’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 inspection, 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 inspections 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 conducted 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 INSPECTION

7.1 Savannah River Site Background

SRS is located 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 

239Pu, in support of the national defense program. Its main focus has been to develop technical 
8

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 its first 

mission was the production of weapons-grade plutonium (WG Pu)5in 1954. Later FB-Line 

functions were the concentration and purification of Pu and recovering Pu from scrap. The waste 

stream was generated by maintenance and routine housekeeping operations and other activities.

Wastes were not intentionally segregated by process area, and low-level waste (LLW), CH 

waste, and RH TRU waste were generated. CH TRU debris generated by FB-Line operations are 

in Waste Stream SR-W027-FB-Pre86C, and RH TRU debris are in Waste Stream SR-RHFLB.01.

7.2 Inspection Process Overview

EPA conducted Baseline Inspection No. EPA-SRS-CCP-RH-08.11-8 of SRS-CCP’s program to 

characterize RH TRU wastes on two occasions from August through December 2011. This 

inspection had the scope 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 waste 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 logistics

(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 waste 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) Evaluating 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% 239Pu and 6% 240Pu with trace 

amounts of 238Pu, 241Pu and 242Pu.
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 characterization 

RTR

8.1 Programmatic Requirements and Acceptable Knowledge

EPA examined the programmatic requirements and AK process and associated information to 

determine whether SRS-CCP demonstrated compliance with 40 CFR 194.8 requirements for RH 

Waste Stream SR-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-CCP: 

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 reporting, and records retention

AK personnel training

Waste Stream Profile Form (WSPF) and related attachments

Nonconformance and discrepancy resolution documentation

Waste stream definition including radiological and physical characteristics 

Verification that 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 factors
10

AK procedure and implementation, including attachments [AK accuracy, 

Characterization Reconciliation Reports (CRRs), Correlation and Surrogate Summary 

Forms (CSSFs)]

AK summary report (AKSR) and associated source documents

AK data traceability

Attainment of data quality objectives (DQOs) 

Documents and Batch Data Reports 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 SRSRHDTC11002

SR510588 SR4RTR0173 SRSRHDTC11002

SR512002 SR4RTR0173 SRSRHDTC11002

SR501028 SR4RTR0173 SRSRHDTC11002

SR504242 SR4RTR0173 SRSRHDTC11002

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 SR-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 SR-RH-FBL.01

characterization activities.

(1) The scope of CBFO’s baseline inspection request and waste stream designation were 

examined for Waste Stream SR-RH-FBL.01 and found to be adequate (WCPIP, 

Section 3.0, p. 13).

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The purpose of a baseline inspection is to evaluate the adequacy, implementation and 

effectiveness of the technical processes 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 characterize 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 scope 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/activity and (2) similar in material, physical form, and radiological properties. EPA 

examined the containers that were characterized according to the method described in CCP-AKSRS-581, Revision 0, and described in CCP-AK-SRS-580, Revisions 1, 2 and 3, to determine 

whether the waste stream was adequately defined. 

The AKSR (Revision 3) states that the waste stream is currently composed of nine7containers 

that originated at the FB-Line and were generated and packaged between January 1975 and 

December 1984. The 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). The FB-Line functions 

were (1) conversion of dilute Pu solutions from the 221-F Canyon Building into highly purified 

Pu 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 C028). The waste 

stream was generated by maintenance 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, cabinet 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 protective equipment, routine laboratory and job control 

waste, rubber gloves, and metals and floor sweepings. This produced low-level, CH, and RH 

TRU wastes that were not intentionally segregated by process area. CH TRU debris generated by 

FB-Line operations 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-AKSRS-2, Revision 13). Occasional ―months-long‖ campaigns were conducted to produce special 

isotopic blends, including mixtures that were elevated in 240Pu. Scrap recovery campaigns also 

processed 242Pu, 241Am, curium-244 (244Cm) and 240Pu oxide, as well as Lawrence Livermore 

mixed oxide and Hanford oxide scrap. Special recovery accounted for approximately 15% of the 

FB-Line operations in the 1970s and consisted of various ―special isotopic composition‖ 

materials. The FB-Line occasionally managed resin waste that potentially contained fission 

products that were not adequately removed 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 approved 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 analysis 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 characterization 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 certification 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 quality assurance objectives 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 the Certification Plan to evaluate compliance with these document requirements, 

as well as the waste characterization requirements consolidated in the WCPIP from 40 CFR Parts

191 (Subparts 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 included, but 

were not limited to:

Removal of unnecessary language pertaining to DQOs and AK accuracy, if AK is not 

used to satisfy the DQO 

Clarification of the confirmatory testing plan contents and approach

Clarification of waste stream size and generation 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 not 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 Sections 5.0–5.4).

40 CFR 194.24(c)(3)–(5) states that a system of controls 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 data 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 requirements was in place at the time of characterization. EPA’s 

characterization requirements in 40 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, including 

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. 

Because 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 nonconformance documentation and discrepancy resolutions were examined 

and found to be adequate (WCPIP, Section 3.4.2.3, p. 24).

SRS-CCP provided one example, Nonconformance Report (NCR) No. NCR-RHSRS-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 in 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 reactive 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, pp. 32–33).

CCP-TP-005, Revision 22, integrated WCPIP, Revision 0d, Appendix A, requirements. CCP-TP005, 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 preliminary 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. Attachments 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 adequate 

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 radiological 

characterization report. SRS-CCP prepared a revised source document 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 but 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 

understood 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, and 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 characterization 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 new 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 addition 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 current 

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 prepared by SRS-CCP indicates that all of the 

characterization information, including program management, process information, waste 
16

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 using 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 radiological 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 

change. Notification to EPA upon completion of revisions to AK procedures (including CCP-TP005 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 reference 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: 

Support for radiological characterization

Identification of processes performed in the FB-Line that affect the radiological 

characteristics of the waste stream

Identification of the waste stream size and waste generation dates versus waste packaging 

dates 

Explanation 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-CCP 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 have 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 

summary 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 SR-RH-FBL.01, which differs from the 
17

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 SRRH-FBL.01 that showed a wider range of materials 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 percent, 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 explanation 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) reflected the 

RH-specific WMPs presented in Attachment 6 and did not mirror 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% iron-based metals and alloys

0.60% aluminum-based metals and alloys

<0.1% other metals

5.67% other inorganic materials

1.16% cellulosics

8.70% rubber

24.38% plastics

<0.1% other organic matrices and inorganic matrices

No soils or gravel

The stream averages (by weight) 34.24% organic waste and 65.77% 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 239Pu 

5.8-6% by weight 240Pu

Less than 1% 238Pu, 241Pu, 241Am (progeny of 241Pu) and 242Pu

The AKSR also states that this 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 from associated CH Waste Stream SR-W027-

FB-Pre86-C to develop an overall isotopic distribution that was applied to RH Waste Stream SRRH-SRS-581. The distribution by weight, shown in Table 5 of the AKSR, is reproduced below:

238Pu (0.04%) 234U (0.03%) 

239

Pu (85.33%) 235U (0.20%)
18

240Pu (6.64%) 238U (5.31%) 

241Pu (0.24%) 232Th (1.41%) 

242Pu (0.07%) 237Np (0.14%) 

241Am (0.46%) 208Tl (0.07%) 

233U (0.01%) 244Cm (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-FBPre86-C AKSR identifies several months-long scrap recovery campaigns that were performed in 

the FB-Line and that contributed radionuclides other than WG Pu to the process lines. For 

example, the Recovery Unit in the FB-Line processed materials ranging from 2% to 20% 240Pu; 

before 1980, the process material may have contained up to 20% 240Pu. A ―High Pu Isotope‖ 

campaign was performed as well, as was at least one campaign that dealt with higher quantities 

of 241Am (CCP-AK-SRS-2, Revision 13; References C21, C24, C27 and DR3). EPA identified 

other campaigns performed in the FB-Line between 1972 and 1979 that processed material other 

than WG Pu including 242Pu, 241Am and 244Cm (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 

contain spent nuclear fuel or high-level waste (WCPIP, Section 2.2.7, p. 12).

The LWA prohibits the disposal 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 separated 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 as ―the 

highly radioactive material resulting from the reprocessing of spent nuclear 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 with existing law, determines by rule requires permanent 

isolation.‖

The AKSR states that Waste Stream 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 produced 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 for 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 separated, 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 examined and found to be adequate (WCPIP, Section 3.4.2.1, p. 22).

SRS-CCP provided EPA with the 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 from a WSPF for a different waste stream and

required revision to correct all of the site and waste stream references. The WSPF also did not 
20

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. The revised draft WSPF and 

CIS and 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 accuracy report and Correlation and Surrogate Summary Form were examined 

and found to be adequate (WCPIP, Section 4.1, p. 30, and Section 3.2.2, pp. 17–19).

EPA examined the draft AK accuracy report and found that it initially did 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 obtaining 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 accuracy 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 distribution. 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 bring 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 impression 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 the 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, prepared 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 waste 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 CSSF 
21

(CCP-TP-005, Attachment 15) or preparation of an additional CSSF is a T2 change. (See Table 

1.)

(12) Drum data are adequately traceable and are in the AK record (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 Ground 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 record 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 determined 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 traceability 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 knowledge training 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 shall 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 containers

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 associated 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 

purged 1/21/04

RTR quick 

screen 6/19/04 –

prohibited items 

found

Repackaged 

7/9/08

CCP RTR 

4/27/11 (BDR 

SR4RTR0173)

SR504233 11/13/75 RTR quick 

screen 11/1/03 

and 6/28/08

Vented and 

purged 11/3/03

Vented and 

closed 7/2/08

CCP RTR 

4/27/11 (BDR 

SR4RTR0173)

SR526627 12/11/84 RTR quick 

screen 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 use 

as is

CH radioassay, 

isotope list, 

MGA analysis 

3/2/07

Headspace gas 

drum sample 

3/8/07

6/8/09 NCRSRS-0533-09 for 

surface dose rate9

> 200 mrem/hr –

reject reassign as 

RH

CCP RTR 

4/26/11 (BDR 

SRSRTR0425)

SR118870 3/13/80 RTR quick 

screen 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, 

118870B

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

R23: Briefing 

and Att. 5, 6, 

7, 8, 15

Jason Montoya Qual Card Qual Card Email 

Statement Briefing R23: Briefing and Att. 1, 4

Steve Schafer Qual Card Qual Card Email 

Statement Briefing R23: Briefing

(14) Data quality objectives were evaluated and found to be adequately met (WCPIP, 

Section 3.4.2, p. 22).

The WCPIP identifies the following DQOs 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 addressed 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 nanocuries (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-SRS-581, Revision 1, as discussed in Section 8.2 

below.

Physical Properties (Regulatory Basis: 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 DQOs 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.

Summary of Acceptable Knowledge Findings and Concerns

The EPA evaluation team did not identify any AK-related findings or concerns. There are no 

open issues related to AK resulting from this inspection.

Tier 1 Acceptable Knowledge Changes

The following AK changes 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 revisions to CCP-AK-SRS-580, CCP-AK-SRS-582, CCP-TP005, 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 updated 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 have 
25

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

waste characterization approval, any additional RH waste resulting 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 part 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. When 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 the 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 

characterization 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 241Am, assumed to be the main 

contributor to the dose

Derivation of radionuclide scaling factors using isotopic ratios found through ISOCS 

assays and isotopic distributions from historical assays of Waste Stream SR-W027-FBPre86-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 

inspection are listed in Attachment A.

Technical Evaluation

The EPA inspection team evaluated the following aspects:

(1) The overall radiological characterization 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 characterization 

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., technically supported relationships between specific 

radionuclides and an easily measured gamma-emitting radionuclide, typically 137Cs. Application 

of the DTC process requires scaling factors to determine the radionuclide contents of each waste 

container. 

The SRS-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 239Pu, 240Pu and 241Pu10 to 241Am based on ISOCS 

measurements 

Development of scaling factors for 238Pu, 

233U, 234U, 238U, 137Cs and 90Sr based on past 

assays of the RH waste stream’s CH counterpart, Waste Stream SR-W027-FB-Pre86-C

MCNP5 modeling to determine the amount of 241Am 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 for 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 characterization 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 241Pu because it is neither a TRU radionuclide nor a WIPP-tracked 

radionuclide. However, 241Pu accumulates over the time period of interest to this inspection, due to its 14.4-year half 

life, and it is the progenitor of 241Am, 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-RH585 & 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 using 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 Submittal #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 

significantly 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 (SRSRH-41)

Sr-90 is not 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 times 

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. SRSRHDTC11001 & 

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 & Results
28

(2) Use of the In Situ Object Counting System to derive isotopic ratios (scaling factors) was

found to be correctly implemented and appropriately documented.

In Situ Object Counting System 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 the 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 get 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, the 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 area 

as well as typical measurement control issues.

In Situ Object Counting System 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 characterization 

method; it is used exclusively for obtaining the relative ratios of 239Pu, 240Pu and 241Pu to 241Am. 

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 241Am and had 

been assayed on the Box Segmented Gamma System or the Segmented Gamma System11were 

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 238Pu, 239Pu, 240Pu and 241Pu to 241Am (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 

located 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 

approved 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, and 

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-RHFBL.01. SRS-CCP stated that this is the only time the 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-RHFBL.01 and not its future use). SRS-CCP initially intended to use ORTEC/ISOC to develop 

scaling factors of 238Pu, 239Pu, 240Pu and 241Pu to 241Am. 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 239Pu, 240Pu and 241Pu were acceptable, and the scaling factors 

for these radionuclides to 241Am can be determined from ISOCS measurements. Only half of the 

238Pu ratios were acceptable, and 238Pu did not meet the test criterion. Accordingly, the test failed 

to establish the ISOCS as a valid means of calculating the 238Pu scaling factor. Therefore, the 

238Pu 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 technically adequate to collect data 

to support the development of radionuclide scaling factors for 239Pu, 240Pu and 241Pu. The 

instrument had been calibrated prior to use in 2005, as documented in WSRC-TR-2005-00431, 

Revision 0. Before collecting data for these 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 Procedure 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 the 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.

The 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/In Situ Object Counting System

The MCS/ISOCS uses a high-purity germanium (HPGe) detector with Canberra’s 

ISOCS/LabSOCS software 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 239Pu, 240Pu and 241Pu. The 

instrument 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 Calibration 

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 the 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/ISOCS 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 239Pu, 240Pu 

and 241Pu to 241Am observed during this baseline inspection is a T1 change. (See Table 1.)

Replicate Testing - MCS/In Situ Object Counting System

To obtain objective evidence on the precision of the MCS/ISOCS, EPA required SRS-CCP to 

perform replicate measurements. Due to the 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 239Pu, 240Pu, 241Pu and 241Am without changing the measurement configuration in 

any way between measurements. 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 other. 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 

application 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 standard in a 55-gallon 

drum that is traceable to the national standards base. The item had to contain sufficient quantities 

of 239Pu, 240Pu, 241Pu and 241Am to provide statistically significant values for these radionuclides 

 

13 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, 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 238Pu) to 241Am, the parameter of interest was the ratio of radionuclide X to 241Am, 

where X is 239Pu, 

240Pu or 241Pu. 

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 any modifications to the 

system’s geometry. These measurements were used to derive three ratios: 239Pu/241Am, 

240Pu/241Am, and 241Pu/241Am. The ratios were used to calculate the percent relative standard 

deviation (%RSD) according to the equation below:

Where:

s = measured standard deviation of the ratio Ci X/Ci14 241Am from each respective ISOCS device

n = number of replicates

μ = known standard deviation of the ratio Ci X/Ci 241Am 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 reference 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 acceptance 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 239Pu/241Am 240Pu/241Am 241Pu/241Am

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 products was found to be 

technically adequate and correctly documented.

SRS Waste Stream SR-W027-FB-Pre86-C is the CH equivalent of RH Waste Stream SR-RHFBL.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 contact 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 ratios of 233U, 234U, 238U, 137Cs and 90Sr to 241Am. 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, which are the only containers in SR-W027-FB-Pre86-

C that contained over one Ci of 241Am. 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-RHFBL.01 waste stream. In this subset, the total quantity of each radionuclide was summed to 

represent the total quantity of that radionuclide in the subset. When an assay did not have 

detectable levels of a radionuclide, the average minimum detectable activity (MDA) for 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 234U. To accurately estimate its average quantity, the average MDA of 235U 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 radionuclide in the subset. The 

NDA system does not directly measure 90Sr; its contribution is inferred by assuming a 1-to-1 

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

reference date of March 9, 2007, which is the weighted average of 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 241Am were then determined. These values served as the 

scaling factors for the respective radionuclides.

(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 meter. This was based on the assumption 

that a one-Ci source of 241Am was uniformly distributed within the drum and that the only 

significant gamma emitter in the drum was 241Am. Specifically, the contributions of 

europium-154 (154Eu), cobalt-60 (60Co) or other gamma emitters in the drum were negligible. 

This provided the container-specific correlation of measured dose rate and 241Am 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. SR526627.15 The DTC process for the actual drums in the waste stream was 

performed 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 

Shepley, all three of whom were listed in the current RH program SRS list of qualified 

individuals (LOQI) dated August 16, 2011. The next CCP trainings for the three DTC operators 

are due in April 2013, May 2012 and April 2013.

The DTC personnel began by performing 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-504, 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 Probe 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 between 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 60Co sealed source with an activity of 1.1 Ci on 

the reference date May 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 

the log book entry page. DTC personnel consulted CCP Operator Aid: OA-SRS-0153, Revision 

2, 8-30-11, which listed tolerances for the test drum weights, scale error, operational ranges for 

the Geiger Mueller Probes and acceptance criteria for the source checks. 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 circumference (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 the measured background of 0.2 mR/hr. The measurements and all 

accompanying parameters were acceptable, and copies 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 is 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-TP-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 approval 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, SRSRHDTC11001 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 Reviewer (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 required 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) in Attachment 3

TRU determination for all containers in Attachment 3 

Correct revision of CCP-TP-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

SR501028 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 12/14/2009
35

(8) TRU determinations were evaluated and were found to be adequate.

DTC BDRs SRSRHDTC11001 and SRSRHDTC11002 contained 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 nCi per gram.

(9) The technical basis and documentation of Total Measurement Uncertainty 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 

radiological 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:

241Am DTC correlation—MicroShield® Version 5 code, MicroShield® modeling, and 

waste density uncertainties

241Am 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, 

scaling 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-RHFBL.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 one 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 239Pu is derived by taking the square root of (25.0%)2plus (10%)2

plus (26.2%)2plus (5.4%)2plus (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 

Uncertainty

Uncertainty 

of ISOCS 

SF

Uncertainty 

in SF 

Derived 

from CH 

Data

Uncertainty 

in Waste 

Density

Uncertainty 

in Waste 

Distribution

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 inspection.

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 239Pu, 240Pu and 241Pu to 241Am

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 waste 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 new RH waste stream characterized using an approved scaling factor process for 

isotopic determination
37

Notification to EPA upon completion of revisions to CCP-AK-SRS-581 or CCP-TP504 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 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 Section8.2 of this report. EPA 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 used 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 239Pu, 

240Pu and 241Pu to 241Am. 

SRS-CCP may not measure 238Pu in this manner and must instead quantify 238Pu 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 radionuclides. The sole purpose of the MCS/ISCOS will be to develop 

ratios (scaling factors) for 239Pu, 

240Pu and 241Pu to 241Am. The ORTEC/ISOCS is not approved 

for use beyond the eight containers that were the subject of this proposed baseline approval.

8.3 Real-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 

prohibited 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 WMC 
38

Presence or absence of prohibited items 

Demonstration of capability testing for operators on the RTR system using specifically 

placed items

Documents, Batch Data Reports 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 Attachment 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 SRSRTR0425

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 qualification cards

Qualification cards and training records for three 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 procedural technical adequacy and implementation were considered and were 

found to be acceptable.

The RTR procedure, documented in CCP-TP-053, Revision 11, Standard Real-Time 

Radiography (RTR) Inspection Procedure, contained specific information on performing 

nonintrusive 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 results. 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 completion of changes to RTR procedure(s) that 

require CBFO approval is a T2 change. (see Table 1).
39

(2) Characterization of waste material parameters 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 BDRs reviewed had acceptable lines-pair tests recorded 

for the days that RTR took place.

For each container undergoing examination, the operator makes an audio/video recording of the 

RTR event. Before beginning 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 drum are visible from all sides. The operator can zoom both in and out 

and increase or decrease the scan energy in order to compensate for varying densities in 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 commonly 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 determined 

that the quality control (QC) samples, independent observation, and replicate scan performed 

were appropriate and that information on the audio/visual recording matched the written RTR 

record (BDR). Addition of a new SCG to the approved RTR process is a T2 change. (See 

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 implementation of all radiography-related 

procedures. QC examinations were performed as required by the procedure. In Batch 

SRSRTR0425, an independent observation was performed on container SR526627 and a 

replicate scan was performed on container SR513217A; in Batch 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 batches. The BDRs 

the EPA examined had been reviewed at the data-generation 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 

radiography 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 operating 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 new 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, SRS-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 reserved 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 debris Waste 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 streams that 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 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, supported by the calculation packages (or equivalent 

documentation) referenced 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, additional 

debris waste stream(s) having a companion (see footnote 1) CH waste stream(s) may be disposed 

of at the WIPP provided that 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 239Pu, 

240Pu and 241Pu to 241Am. Further, use of the 
42

MCS/ISOCS for determining the scaling factor for 238Pu or for direct quantification of any 

radionuclide is prohibited. 

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 

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.
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 Radioactive 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. Department 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 Implementation 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 Mexico, 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 Transuranic Waste Authorized Methods for 

Payload Control (RH-TRAMPAC),‖ Carlsbad, New Mexico.
A-1

ATTACHMENT A: DOCUMENTS REVIEWED 

CCP Calculation Package: SRS RH TRU Radiological Characterization, J. Vance, SRS-RH-41, 

Revision 0, August 4, 2011

CCP Calculation 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, September 14, 2011

CCP Calculation Package: DTC Values and Gamma Sensitivity Studies, J. Holderness, SRS-RH43, 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-RH44, Revision 1, October 25, 2011

Calibration Verification Report for the ISOCS Detector # 4480 at the Savannah River Site, 

B. Gillespie, Revision 0, November 9, 2011

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-580, Central Characterization Project Acceptable Knowledge Summary Report 

for Savannah 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-581, Central Characterization Project Remote-Handled Transuranic Radiological 

Characterization 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 Certification 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 Savannah 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, April 26, 2011

CCP-QP-008, Revision 19, CCP Records Management, August 02, 2011
A-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 Parameters, 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 Checklist, 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 11, 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 July 21, 

2011, and November 29, 2011

Characterization Reconciliation Report for Waste Stream SR-RH-FBL.01, Draft for Audit 

Purposes, Provided July 21, 2011

DTC BDR Nos. SRSRHDTC11001, August 17, 2011, and SRSRHDTC11002, August 18, 2011

Interoffice 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 for 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, 2011
A-3

ISOCS/LabSOCS Detector Characterization Report, Canberra Industries, Inc., August 10, 2010

List of Qualified Individuals (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, June 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-RHSRS-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 cards 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 – Interview 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, 2002
A-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 John 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 Engineer, 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 International 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 1988
A-5

D029, Savannah River Site Solid Waste Management 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 Plant: 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 Limit 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 Resolution, 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, 

March 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 Support Revised WMP Calculation, Various Authors, 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-RH41, Revision 0, August 4, 2011, Revision 1, September 13, 2011
A-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 from Other Radionuclides, 

J. Holderness, SRS-RH-46, Revision 0, September 14, 2011
B-1

ATTACHMENT B: PERSONNEL CONTACTED DURING INSPECTION

Personnel Name Affiliation Area of Expertise, Function Aug Dec

Ed Feltcorn U.S. EPA ORIA Inspection Team Leader  

Connie 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 Mobasheran* SC&A Inspection Team, Radiological Characterization 

Jim Holderness CCP Consultant Radiological Characterization 

Derek Ott CCP Radiological Characterization 

Marcus A. Pinzel DOE/CBFO RH Waste Manager, RC 

David A. McCoy CCP DTC Operator, 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 CCP ISOCS Lead Operator 

* Performed evaluations via desk-top review.

†Contacted by phone