EPA DOCKET NO. A-98-49, II-A4-175 

WASTE CHARACTERIZATION INSPECTION 

CONTINUED COMPLIANCE REPORT 

EPA INSPECTION OF THE CENTRAL CHARACTERIZATION PROJECT 

WASTE CHARACTERIZATION PROGRAM 

AT THE IDAHO NATIONAL LABORATORY 

 

May 7–9, 2013 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

July 2013 
i 

TABLE OF CONTENTS 

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

2.0 Purpose of Continued Compliance Inspections .................................................................. 6

3.0 Purpose of This Report ....................................................................................................... 6

4.0 Scope of This Continued Compliance Inspection ............................................................... 6

5.0 Inspection Personnel ........................................................................................................... 7

6.0 Technical Evaluation .......................................................................................................... 7

6.1 Acceptable Knowledge ........................................................................................... 7

6.1.1 Contact-Handled Waste Streams ................................................................ 7

6.1.2 Remote-Handled Waste Streams .............................................................. 12

6.1.3 Acceptable Knowledge Findings and Approval ....................................... 17

6.2 Nondestructive Assay for Contact-Handled Waste .............................................. 17

6.2.1 Technical Evaluation: Waste Assay Gamma Spectrometer...................... 17

6.2.2 Technical Evaluation: Stored Waste Examination Pilot Plant Gamma-Ray 

Spectrometer ......................................................................................................... 19

6.2.3 Technical Evaluation: Super High Efficiency Neutron Counter .............. 22

6.2.4 Nondestructive Assay Findings and Approval ......................................... 23

6.3 Dose-to-Curie for Remote-Handled Waste ........................................................... 23

6.3.1 Dose-to-Curie Findings and Approval ...................................................... 24

6.4 Real-Time Radiography for Remote-Handled Waste ........................................... 25

6.4.1 Real-Time Radiography Approval ............................................................ 27

6.5 Visual Examination ............................................................................................... 27

6.5.1 Visual Examination of Contact-Handled Waste ....................................... 27

6.5.2 Visual Examination of Remote-Handled Waste ....................................... 29

6.5.3 Visual Examination Findings and Approval ............................................. 30

7.0 Findings and Concerns ...................................................................................................... 30

8.0 Conclusions ....................................................................................................................... 30

LIST OF TABLES 

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

Implemented by INL-CCP .............................................................................................................. 3

Table 2. Tiering of Remote-Handled Transuranic Waste Characterization Processes 

Implemented by INL-CCP .............................................................................................................. 4
ii 

ATTACHMENTS 

Attachment A.1 Approval Summary for INL-CCP Contact-Handled Waste Characterization 

Program 

Attachment A.2 Approval Summary for INL-CCP Remote-Handled Waste Characterization 

Program 

Attachment B List of Documents Reviewed for this Inspection 

Attachment C Inspection Personnel 

Attachment D.1 AK Continued Compliance Inspection Checklist: Waste Stream ID-RF-S3114 

Attachment D.2 AK Continued Compliance Inspection Checklist: Waste Stream 

ID-RF-S5300-A 

Attachment D.3 AK Continued Compliance Inspection Checklist: Waste Stream 

ID-SDA-SOIL 

Attachment D.4 AK Continued Compliance Inspection Checklist: Waste Stream ID-ANLES5000 

Attachment D.5 AK Continued Compliance Inspection Checklist: Waste Stream IN-ID-BTO030 

Attachment E.1 NDA Continued Compliance Inspection Checklist: WAGS 

Attachment E.2 NDA Continued Compliance Inspection Checklist: SGRS 

Attachment F.1 Replicate Testing Data for Drum ARP70420 – SGRS 

Attachment F.2 Replicate Testing Data for Drum SRP13045 – SGRS 

Attachment F.3 Replicate Testing Data for Drum ARP70259 – SGRS 

Attachment G Dose-to-Curie Continued Compliance Inspection Checklist 

Attachment H NDE Continued Compliance Inspection Checklist: RTR 

Attachment I.1 NDE Continued Compliance Inspection Checklist: CH VE 

Attachment I.2 NDE Continued Compliance Inspection Checklist: RH VE 

Attachment J EPA Inspection Issue Tracking Form, Issue No. INL-CCP-CC-2013-01C, 

Final 

Attachment K EPA Inspection Issue Tracking Form, Issue No. INL-CCP-CC-2013-02CR, 

Final 
iii 

ACRONYMS AND ABBREVIATIONS 

AGHCF Alpha-Gamma Hot Cell Facility 

AK acceptable knowledge 

AKE Acceptable Knowledge Expert 

AKSR acceptable knowledge summary report 

Am americium 

AMWTP Advanced Mixed Waste Treatment Project 

ANL-E Argonne National Laboratory-East 

ANL-W Argonne National Laboratory-West 

ARP Accelerated Retrieval Project 

ASTM American Society for Testing and Materials 

Ba barium 

BDR batch data report 

BEGe broad energy germanium 

Bkg background count rate 

Br bromine 

χ

2

 chi-squared 

CBFO Carlsbad Field Office 

CCP Central Characterization Program 

CDR contact dose rate 

Ce cerium 

CFR Code of Federal Regulations 

CH contact-handled 

CIS characterization information summary 

cps counts per second 

CRR characterization reconciliation report 

Cs cesium 

CSSF correlation and surrogate summary form 

CTAC Carlsbad Technical Assistance Contractor 

CWI CH2M-WG Idaho, LLC 

DEQ Department of Environmental Quality 
iv 

DOE U.S. Department of Energy 

DPS drum packaging stations 

DQO data quality objective 

DR discrepancy resolution 

DSA digital spectrum analyzer 

DTC dose-to-curie 

DU depleted uranium 

EA Expert Analyst 

EPA U.S. Environmental Protection Agency 

FCF Fuel Conditioning Facility 

FGE fissile gram equivalent 

FWHM full width at half maximum 

FY fiscal year 

HENC High Efficiency Neutron Counter 

HEU highly enriched uranium 

HFEF Hot Fuel Examination Facility 

HWN hazardous waste number 

IDC item description code 

ILTSF Intermediate Level Transuranic Storage Facility 

INEL Idaho National Engineering Laboratory 

INL Idaho National Laboratory 

INTEC Idaho Nuclear Technology and Engineering Center 

ITR independent technical review 

keV kilo electron volt 

kg kilogram 

La lanthanum 

La3Br(Ce) cerium-drifted lanthanum bromide 

LANL Los Alamos National Laboratory 

LLD lower limit of detection 

LLW low level waste 

LOQI list of qualified individuals 
v 

MCS Mobile Characterization Services 

MEL Materials Evaluation Laboratory 

MGA multi-group analysis 

MGA-U multi-group analysis-uranium 

mrem/hr millirem per hour 

mR/hr milliroentgen per hour 

nCi/g nanocuries per gram 

NCR nonconformance report 

NDA nondestructive assay 

NDE nondestructive evaluation 

NRF Naval Reactors Facility 

NTP National TRU Programs 

NWP Nuclear Waste Partnership, LLC 

OJT on-the-job training 

ORIA Office of Radiation and Indoor Air 

PDP Performance Demonstration Program 

Pm promethium 

PM Project Manager 

Pu plutonium 

QAPD quality assurance program document 

QC quality control 

R roentgen 

R/hr roentgen per hour 

RDS radioassay data sheet 

RFP Rocky Flats Plant 

RH remote-handled 

RSD relative standard deviation 

RTR real-time radiography 

RWMC Radioactive Waste Management Complex 

RWMS radioactive waste management system 

σ sigma 
vi 

SCG summary category group 

SDA Subsurface Disposal Area 

SGRS Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer 

SME Subject-Matter Expert 

SPC sludge pan container 

SPM Site Project Manager 

Sr strontium 

SuperHENC Super High Efficiency Neutron Counter 

SWB standard waste box 

SWEPP Stored Waste Examination Pilot Plant 

T1 Tier 1 

T2 Tier 2 

TMU total measurement uncertainty 

TRU transuranic 

TRUCON TRU waste content 

TWMS transuranic waste management system 

U uranium 

uR/hr microRoentgen per hour 

VE visual examination 

VEE Visual Examination Expert 

VEO Visual Examination Operator 

VPM Vendor Project Manager 

VJT VJ Technologies 

WAC waste acceptance criteria 

WAGS Waste Assay Gamma Spectrometer 

WCPIP Waste Characterization Program Implementation Plan 

WDS WIPP Waste Data System 

WG Pu weapons-grade plutonium 

WILD Waste Inventory Location Database 

WIPP Waste Isolation Pilot Plant 

WMC waste matrix code 
vii 

WMP waste material parameter 

WSPF waste stream profile form 
1 

1.0 EXECUTIVE SUMMARY 

This report supports the U.S. Environmental Protection Agency’s (EPA’s) determination that the 

waste characterization program at the U.S. Department of Energy (DOE)-Idaho National 

Laboratory (INL) continues to be in compliance with federal regulations. In accordance with 

Title 40 of the Code of Federal Regulations (40 CFR) 194.24(h), EPA can conduct a continued 

compliance inspection of the EPA-approved transuranic (TRU) waste characterization systems 

used at the TRU waste sites operated by DOE. Since 2005, the Central Characterization Program 

(CCP)1

, a mobile waste characterization systems provider, has operated a waste characterization 

program for contact-handled (CH) and remote-handled (RH) TRU wastes at INL in Idaho Falls, 

Idaho. 

On May 7–9, 2013, EPA conducted a continued compliance inspection of the site’s program to 

characterize CH and RH TRU wastes proposed for disposal at the Waste Isolation Pilot Plant 

(WIPP). During this inspection, EPA evaluated samples of the following waste characterization 

activities: 

• Acceptable knowledge (AK) for CH and RH waste streams. 

• Three nondestructive assay (NDA) systems for characterizing CH TRU wastes: the 

Waste Assay Gamma Spectrometer (WAGS), the Stored Waste Examination Pilot Plant 

Gamma-Ray Spectrometer (SGRS) and the Super High Efficiency Neutron Counter 

(SuperHENC). 

• Dose-to-curie (DTC) for RH TRU waste. 

• Real-time radiography (RTR) for RH TRU waste. 

• Visual Examination (VE) for CH and RH TRU waste. 

Based on the results of this continued compliance inspection, EPA confirms that the INL-CCP 

CH and RH TRU waste characterization programs in the configuration observed during this 

inspection are consistent with the limitations described in the baseline inspection reports (see 

EPA Docket Nos. A-98-49; II-A4-59, dated November 1, 2005, and A-98-49; II-A4-72, dated 

January 12, 2007) and subsequent EPA Tier 1 (T1) approvals. Attachments A.1 and A.2 

summarizes all of EPA’s approvals of the INL-CCP CH and RH TRU waste characterization 

programs. 

Based on this evaluation, there are no substantive changes to the CH or RH T1 designations. 

There substantive changes to the AK Tier (T2) designations: 

1. Notification to EPA upon completion of or revisions to all AK summary reports (AKSRs) 

is a new T2 change applicable to the CH waste characterization program. 

2. Notification to EPA upon completion of or revisions to discrepancy resolution (DR) 

reports and nonconformance reports (NCRs) is a new T2 change applicable to the RH 

waste characterization program. 

 

1

 The Central Characterization Program was formerly known as the Central Characterization Project. 
2 

3. Submission to EPA of a list of AK Experts (AKEs) and Site Project Mangers (SPMs) 

who performed work in these roles for the INL-CCP waste characterization program 

during the previous quarter is a new T2 change applicable to the CH and RH waste 

characterization programs. 

Change Nos. 1 and 2 as listed above are necessary to make the INL-CCP CH and RH tiering 

designations consistent with the requirements at other TRU sites and to reflect current T2 

reporting practices. EPA also revised the tiering tables to ensure completeness and consistency 

with recent EPA T1 approval reports. Tables 1 and 2 show the substantive T2 changes for CH 

and RH in bold text. T1 and T2 changes that were initiated during the CH and RH baseline and 

subsequent T1 approvals remain in effect. The language in Tables 1 and 2 regarding AK 

documentation applies to all INL-CCP waste streams.

In November 2012, DOE, DOE contractor staff and EPA and EPA contractor staff discussed 

DOE’s TRU site cleanup goals through 2016 and ways to improve EPA’s evaluation and 

decision process to support DOE sites’ state-mandated cleanup needs. As a result of this 

discussion, EPA finalized a streamlined evaluation and decision process that includes an EPA 

annual continued compliance inspection at each active, EPA-approved TRU waste site. The 

annual inspections will cover the common elements of waste characterization processes that are 

not expected to significantly vary on a waste stream or T1 basis. Examples of the common 

characterization elements are personnel training, procedures and equipment capabilities. EPA 

will evaluate these elements during T1 change evaluations or in conjunction with the quarterly 

T2 change reports as necessary to ensure that EPA’s waste characterization approvals reflect any 

significant changes made to DOE’s waste characterization program. 

This streamlined approach allows EPA to consider the results of continued compliance 

inspections when setting the scope and evaluating site-specific T1 changes. The results of this 

continued compliance inspection will support EPA’s evaluations of INL-CCP’s T1 change 

requests in the coming year (i.e., May 2013–April 2014). EPA will focus the T1 evaluations on 

those items critical to a specific approval (e.g., waste-stream-specific AK records) and may not 

revisit the elements discussed in this report until the next continued compliance inspection at the 

Agency’s discretion. 

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

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

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

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

(Based on May 3–5, 2005, Baseline Inspection and Subsequent Evaluations, Updated July 2

Process Elements INL-CCP CH Waste Characterization Processes – T1 Changes INL-CCP CH Waste Characterizati

Acceptable Knowledge, including Load Management 

Any new waste category Changes to the accelerated retrieval project targeted wastes from 

what was presented in CCP-AK-INL-001, Revision 7 

Notification to EPA upon completion of o

• AK-NDA memoranda • AK accuracy reports (annually, at a mi• AK-AK and AK-NDA/NDE discrepan

• WSPFs, including updates or additions 

approved waste category 

• New and revised AK summary repor

• The load management status of approv

• Site procedures requiring CBFO appro• Any analysis evaluating effectiveness o

Process 

Submission of a list of active INL-CCP 

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

equipment Extension of or changes to approved calibration range for approved equipment 

Notification to EPA upon substantive mod

• Software for approved equipment • Operating ranges upon CBFO approva• Site procedures requiring CBFO appro

Real-Time Radiography None Notification to EPA upon: 

• Substantive modification** to site proc

• New equipment or substantive physica

equipment 

Visual Examination and Visual Examination Technique 

Changes in the vendor performing visual examination or visual 

examination technique 

Notification to EPA upon substantive mod

requiring CBFO approval 

WIPP Waste Data System 

Changes to WDS algorithms specific to load management requiring 

revisions to the load management provisions of DOE’s CH WAC 

Notification to EPA upon substantive mod

• Site procedures requiring CBFO appro• WDS algorithms corresponding to cha

provisions of the CH WAC 

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

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

are solely related to the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act; or that are editori

address administrative concerns. EPA may request copies of new references that DOE adds during a document revision. 
4 

Table 2. Tiering of Remote-Handled Transuranic Waste Characterization Processes Implemented 

(Based on June 12–16 and August 9 and 26, 2006, Baseline Inspection and Subsequent Tier 1 Evaluations, 

Process Elements INL-CCP RH Waste Characterization Process – T1 Changes INL-CCP RH Waste Characte

Acceptable Knowledge Any new waste stream not approved under the baseline 

Addition of containers to approved waste streams if new or different radionuclide scaling factors are required Substantive modification** to AKSRs and certification confirmation 

test plans (e.g., CCP-AK-INL-500, CCP-AK-INL-502) Load management for any RH waste stream 

Notification to EPA upon availabi

modification** of AKSRs and cer(e.g., CCP‐AK‐INL-500, CCP-AK

Notification to EPA upon availabi

• CCP-TP-005, Attachment 4 th

Source Document Reference L

• The WSPF or WSPF change n

including the CRR, CIS and Su

provided with each requested W

• AK accuracy reports (annually

• Discrepancy resolution repor

• AK documentation as a result 

Program Implementation Plan 

• Correlation or surrogate summ

containers in this waste stream 

based on measured dose rates t

results for assayed containers 

Submission of a list of active INL

Notification to EPA of the intentio

approved waste stream, including containers and volume of waste, thcharacterization, and disposal and documenting that the pedigree of tsame as those covered by the baseapprovals*** Submission of a list of fully charac

population of additional containers 

above*** 

Radiological Characterization, including Dose-to-Curie 

Any new waste stream not approved under the baseline or subsequent T1 evaluations or addition of containers to an approved waste stream that requires changing the established radionuclide scaling factors Use of any alternate radiological characterization procedure other than DTC with established scaling factors as documented in CCP-TP-504 

Use of any alternate gamma detector with the OSPREYTM system 

Notification to EPA upon nonsubs

procedures or radiological technic

CCP‐AK‐INL‐501) requiring CB

Submission of an updated radiologAK-INL-501) documenting that th

processes used for the additional c
5 

Process Elements INL-CCP RH Waste Characterization Process – T1 Changes INL-CCP RH Waste Characte

characterization procedure other than the La3Br(Ce) detector observed 

in July 2010 Application of new (i.e., not EPA-approved) scaling factor development processes for isotopic determination (applies to new RH waste streams and to the addition of containers to an approved waste stream) Substantive modification** to EPA-approved procedures or radiological characterization technical reports (e.g., CCP-TP-504, CCP-AK-INL-501) 

covered by the baseline or subsequSubmission of BDRs or calculatio

by EPA from a list of fully charact

INL-CCP*** 

Visual Examination Visual examination by any new process for SCG S3000, S4000 or 

S5000 waste. Visual examination by review of existing audio/visual recordings for 

SCG S3000 or S4000 waste.

Notification to EPA upon substantprocedures requiring CBFO appro

Submission of BDRs for containerfully characterized containers prov

Real-Time Radiography Any new debris waste stream or waste from SCG S3000 or S4000 

Addition of any new RTR units 

Notification to EPA upon substantprocedures requiring CBFO appro

Submission of BDRs for containerfully characterized containers prov

WIPP Waste Data System None Notification to EPA upon substant

procedures requiring CBFO appro

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

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

changes that are solely related to the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery 

nature or are required to address administrative concerns. EPA may request copies of new references that DOE adds during a do

*** INL-CCP will report this T2 change immediately.
6 

2.0 PURPOSE OF CONTINUED COMPLIANCE INSPECTIONS 

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

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

characterization program (Vol. 69, No. 136, pages 42571–42583, July 16, 2004). The purpose of 

EPA’s baseline inspection is to approve the site’s waste characterization program, based on a 

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. 

Following EPA’s baseline approval, EPA has the authority to conduct continued compliance 

inspections to verify that the site (1) continues to use only the approved waste characterization 

processes to characterize the waste and (2) remains in compliance with all the regulatory 

requirements. EPA is also authorized to evaluate and approve changes, if necessary, to the site’s 

approved waste characterization program by conducting additional inspections under the 

authority of 40 CFR 194.24(h). 

3.0 PURPOSE OF THIS REPORT 

This report documents the basis for EPA’s decision to maintain the approval of the INL-CCP 

waste characterization program for CH and RH TRU wastes. Specifically, this report: 

• Describes the sample of the INL-CCP waste characterization systems evaluated during 

this inspection. 

• Identifies all areas where waste characterization systems have changed relative to what 

was approved during the baseline inspection and other subsequent EPA T1 evaluations 

and assesses the impact, if any, of those changes. 

• Provides objective evidence to support the basis for EPA’s continued approval of all 

waste characterization systems. 

• Describes any tests or demonstrations completed during the course of the inspection and 

their relevance to EPA’s approval decision. 

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

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

Carlsbad Field Office 

Manager, National TRU Program 

P.O. Box 3090 

Carlsbad, NM 88221-3090 

4.0 SCOPE OF THIS CONTINUED COMPLIANCE INSPECTION 

The scope of this continued compliance inspection included the evaluation of selected elements 

of the waste characterization systems in use at INL-CCP to characterize CH and RH TRU wastes 

that were approved during the baseline inspection and subsequent T1 evaluations. Waste 

characterization activities evaluated included AK for CH Waste Streams ID-RF-S3114, ID-RF-
7 

S5300-A and ID-SDA-SOIL and RH Waste Streams ID-ANLE-S5000 and IN-ID-BTO-030; all 

operating NDA systems (WAGS, SGRS and SuperHENC) for CH waste characterization and 

DTC systems for RH waste characterization; and RTR operations for multiple RH summary 

category groups (SCGs) and VE operations for multiple CH and RH SCGs. 

5.0 INSPECTION PERSONNEL 

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

personnel in several disciplines. The personnel contacted represented a sample of the CH and RH 

TRU waste characterization staff. The EPA inspection team and INL-CCP personnel contacted 

are listed in Attachment C, with their affiliations and areas of expertise or function. 

6.0 TECHNICAL EVALUATION 

Sections 6.1 through 6.4 of this report detail the four technical areas assessed during this 

inspection: AK, NDA, DTC and nondestructive examination (NDE), consisting of RTR and VE. 

EPA completed inspection checklists based on responses of INL-CCP waste characterization 

personnel to EPA querries and other documentation (see Attachments D.1–E.2 and G.1–I.2). 

When evaluating future T1 change requests and concurring with quarterly T2 change 

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

6.1 Acceptable Knowledge 

6.1.1 Contact-Handled Waste Streams 

EPA evaluated INL-CCP’s continued compliance with EPA-approved AK procedures for CH 

waste characterization. INL-CCP’s CH AK characterization program is EPA-approved for SCG 

S3000 (homogeneous solids), SCG S4000 (soils) and SCG S5000 (heterogeneous debris) waste. 

EPA selected one waste stream from each approved SCG (ID-RF-S3114, ID-RF-S5300-A and 

ID-SDA-SOIL) to review as representative samples of the INL-CCP CH AK waste 

characterization program. 

EPA has reviewed Waste Stream ID-SDA-SOIL several times (EPA Docket Nos. A-98-49; IIA4-67, A-98-49; II-A4-112 and A-98-49; II-A4-142) and therefore focused this continued 

compliance inspection on changes to the waste stream and associated documentation since the 

last review in October 2010. EPA had not previously reviewed Waste Stream ID-RF-S3114 and 

Waste Stream ID-RF-S5300-A and therefore reviewed their documentation in greater detail. The 

AK checklists used for this inspection are included in Attachments D.1–D.3. 

Technical Evaluation

(1) Central Characterization Program procedures for acceptable knowledge documentation, 

training of Acceptable Knowledge Experts and disposition of nonconformances were 

examined and found to be adequate. 

EPA reviewed several CCP procedures for AK documentation, training of AKEs and disposition 

of nonconformances for technical sufficiency and scope. Specifically, EPA reviewed: 
8 

• CCP-QP-002, Revision 34. 

• CCP-QP-005, Revision 20. 

• CCP-TP-002, Revision 25. 

• CCP-TP-005, Revision 24. 

The procedures adequately reflect the requirements of 40 CFR 194. Procedure implementation is 

evidenced by adequate preparation and maintenance of the required documentation, as reviewed 

below. 

Notification to EPA upon completion of or substantive modification to site procedures requiring 

Carlsbad Field Office (CBFO) approval remains a T2 change (see Table 1). 

(2) The acceptable knowledge characterization process for containers, including acceptable 

knowledge assembly, compilation and verification, was adequately implemented. 

EPA evaluated INL-CCP’s completion of each of the 15 attachments associated with CCP 

procedure CCP-TP-005 (AK documentation) for each of the three sample waste streams. 

EPA identified a few instances when a CCP-TP-005 attachment was completed on the same day 

that a new revision of CCP-TP-005 became effective. The attachments should have been done or 

redone using the new revision. EPA has previously observed CCP’s diligence in revising the 

CCP-TP-005 attachments that happened to be completed on the day that the procedure was 

revised. EPA will continue monitoring use of appropriate attachment revisions to ensure that this 

situation remains a rare and isolated occurrence. 

For both Waste Stream ID-RF-S3114 and Waste Stream ID-RF-S5300-A, the AK information 

lists (CCP-TP-005, Attachment 4) had to be revised during the inspection because discrepancy 

resolutions had been written and added to the AK record but the Attachment 4 had not been 

revised. EPA understands that Attachment 4 is not revised every time a source document is 

added, but EPA expects that the Attachment 4s provided to EPA during an inspection will be 

complete and accurate. EPA will continue to check Attachment 4 completion during future 

inspections. 

(3) Waste traceability was adequately demonstrated. 

EPA randomly selected one container each from Waste Stream ID-RF-3114 and Waste Stream 

ID-RF-S5300-A to assess traceability. These containers are traceable from their Rocky Flats 

Plant (RFP) building of generation through INL-CCP characterization. 

Waste Stream ID-SDA-SOIL is entirely composed of newly-generated waste; therefore, there is 

no direct link between waste generation at the generator site and the drums being characterized 

by INL-CCP. However, through use of the Waste Inventory Location Database (WILD) at INL 

and other historic waste documentation, INL-CCP is able to identify the specific wastes that 

were interred in the pits by quadrant. Each drum is traceable from generation during VE through 

NDA to final emplacement in the WIPP facility. 
9 

(4) The acceptable knowledge summary reports were assessed and found to be adequate. 

EPA evaluated the AKSR for each sample waste stream for inclusion of sufficient information, 

supported by appropriate source documents, to support the following statements: 

• All waste within the waste stream was generated from a single process/activity. 

• All waste within the waste stream is similar in material and physical form. 

• All waste within the waste stream has similar radiological properties. 

• All of the waste in the waste stream is defense in origin.2

• None of the waste in the waste stream is high-level waste.2

• None of the waste in the waste stream is spent nuclear fuel.2

EPA found each AKSR to be adequate. Explanations and source documents supporting each of 

the above statements are included in the checklists in Attachments D.1–D.3 to this report: 

• Waste Stream ID-RF-S3114: Attachment D.1 summarizes the information provided in 

the AKSR CCP-AK-INL-005, Revision 8. 

• Waste Stream ID-RF-S5300-A: Attachment D.2 summarizes the information provided in 

the AKSR CCP-AK-INL-004, Revision 2. 

• Waste Stream ID-SDA-SOIL: Attachment D.3 summarizes the information provided in 

the AKSR CCP-AK-INL-001, Revision 11. 

Notification to EPA upon completion of or revisions to all AKSRs is a new T2 change. This 

requirement was added to make the INL-CCP CH tiering designations consistent with the 

requirements at other sites and to reflect current T2 reporting practices (see Table 1). 

(5) Waste stream profile form preparation and completeness were evaluated and found to be 

adequate. 

EPA reviewed the waste stream profile forms (WSPFs), including the characterization 

information summaries (CISs) and summations of aspects, and related change notices for Waste 

Streams ID-RF-3114, ID-RF-S5300-A and ID-SDA-SOIL and found them to be complete and 

adequate. 

(6) Acceptable knowledge personnel training was assessed and found to be adequate. 

INL-CCP indicated that Scott Smith, Carrie Johnson and Kevin Peters are the only AKEs 

responsible for CH waste in the INL-CCP program. INL-CCP provided completed qualification 

cards and documentation showing familiarity of the AKEs with the current revisions of AK 

procedures. INL-CCP also provided complete SPM qualification cards for Barbara Broomfield, 

Steve Castro, Vince Medina, Carolina Soaterna, Jim Vernon and Roger Whiteaker. Training 

records for the personnel listed above are complete and adequate. EPA will review training 

records for any additional personnel supporting CH waste characterization during a future T1 

evaluation or the next continued compliance inspection. 

 

2As defined by U.S. Code, Title 42, “The Public Health and Welfare,” Chapter 108, “Nuclear Waste Policy

Act of 1982.” 
10 

Jeff Harrison compiled much of the AK for this waste stream, but he is no longer actively 

supporting CH waste characterization at INL-CCP. Therefore, EPA did not review his training 

records as part of this continued compliance evaluation. If Jeff Harrison resumes AK work at 

INL-CCP, submission of his up-to-date training records to EPA will be necessary. Submission to 

EPA of a list of AKEs and SPMs who performed work in these roles for the INL-CCP CH waste 

characterization program in the previous quarter is a new T2 change (see Table 1). 

(7) Nonconformance and discrepancy resolution documentation was assessed and found to 

be adequate. 

EPA has previously evaluated INL-CCP’s ability to produce compliant NCRs several times and 

did not specifically review any NCRs associated with Waste Streams ID-RF-S5300-A or 

ID-SDA-SOIL. EPA found that two sample NCRs associated with Waste Stream ID-RF-S3114 

were adequately prepared. EPA also reviewed randomly selected DR reports associated with 

each sample waste stream and found them to be adequately prepared. 

Notification to EPA upon completion of or substantive modification to AK-AK and AKNDA/NDE discrepancy resolution reports remains a T2 change (see Table 1).

(8) Acceptable knowledge accuracy was assessed and found to be adequate. 

EPA reviewed at least three annual AK accuracy reports for each of the sample waste streams 

and found them to be adequate. 

EPA identified a few inconsistencies in the AK accuracy reports for Waste Stream ID-RF-S3114. 

For example, while the 2011 AK accuracy report noted that out of the whole waste stream two 

containers were inconsistent with AK, the 2012 report indicated that the cumulative AK accuracy 

was 100% (i.e., no containers were inconsistent). During the period between the 2012 accuracy 

assessment and the 2013 accuracy assessment, 18 additional containers were identified as being 

inconsistent with AK, and the two containers identified prior to May 2011 were also accounted 

for. This appears to have been a one-time issue with the 2012 AK accuracy report. EPA will 

continue to review AK accuracy reports for adequacy and completeness. 

In previous evaluation reports (e.g., the 2010 INL-CCP continued compliance report; EPA 

Docket No. A-98-49; II-A4-142), EPA has expressed the position that INL-CCP should consider 

both radionuclide weight percent and activity percent when evaluating AK accuracy. The AK 

accuracy reports reviewed for this inspection (though adequate) do not consider radionuclide 

activity percent. EPA will continue to revisit this issue during future evaluations. 

Notification to EPA upon completion of or substantive modification to AK accuracy reports 

(annually, at a minimum) remains a T2 change (see Table 1). 

(9) Communication between acceptable knowledge and nondestructive assay personnel was 

assessed and found to be adequate. 

EPA reviewed the current AK-NDA memorandum for each sample waste stream, evaluated the 

memoranda for completeness and compared the memoranda with the AKSRs. The AK-NDA 

memoranda for Waste Streams ID-RF-S3114 and ID-RF-S5300-A have not been updated since 
11 

2007 and 2005, respectively. EPA found that the level of detail and precision in the AK portion 

of the AK-NDA memoranda for these waste streams is not up to current standards, but that the 

technical contents of the memoranda are adequate. EPA expects that if the AK-NDA memoranda 

for either of these waste streams require revision in the future, the whole document will be 

reviewed for clarity and accuracy. 

In the report from the previous INL-CCP continued compliance evaluation, EPA stated that, “if 

information regarding the in-growth of [americium-241 (241Am)] is available for a specific group 

of wastes, waste containers or waste stream(s), it should be integrated in the AK-NDA 

memorandum, as appropriate. EPA expects information addressing the in-growth of 241Am to be 

included in the AK record.” The ID-SDA-SOIL AK-NDA memorandum includes footnotes 

explaining that the data are not decay corrected and therefore 241Am values will be higher than 

indicated in the expected radiological distribution. EPA discussed the point about integrating 

241Am in-growth into the AK-NDA memorandum with AK and NDA personnel. The NDA 

personnel explained that, although the expected radiological distribution would be more accurate 

if 241Am and plutonium-241 (241Pu) values were decay corrected, the difference does not impact 

the final assay values. There are two reasons for this: 

(1) In the case of Waste Stream ID-SDA-SOIL and all other waste originating at RFP, the 

default isotopics to be used in the event that NDA measurement does not yield isotopic 

analysis results are based on mass fractions for weapons-grade Pu (WG Pu), highly 

enriched uranium (HEU) and depleted uranium (DU), not based on AK-derived values. 

(2) 241Am is either detected and measured by the NDA equipment or is considered to be not 

present in the subject container. 

EPA determined that the AK-NDA memorandum for Waste Stream ID-SDA-SOIL is adequate. 

EPA will continue to review the AK record to ensure that information addressing 241Am ingrowth is incorporated as appropriate. 

Notification to EPA upon completion of or substantive modification to AK-NDA memoranda 

remains a T2 change (see Table 1). 

(10) Load management was found to be acceptable. 

The WIPP waste acceptance criteria allow payload management such that a payload container 

may include drums that measure less than 100 nanocuries per gram (nCi/g) so long as the 

payload in total is greater than 100 nCi/g. The AKSR for each waste stream selected for payload 

management must include an estimate of the total waste volume and percentage of the waste 

volume that is above and below100 nCi/g. Each container selected for payload management must 

also contain at least one TRU isotope whose activity exceeds the lower limit of detection of the 

radioassay system used to characterize the waste, and each container may only be overpacked 

into a payload container with other containers from the same TRU waste stream. 

CCP-AK-INL-005, Revision 8, says that 34% of the ID-RF-S3114 containers are above 100 

nCi/g and 64% of the containers are below 100 nCi/g TRU alpha. The report also states that each 

payload container will be certified as containing “more than 100 nCi/g of alpha emitting isotopes 

with half-lives greater than 20 years.” INL-CCP performs NDA on each individual drum. If the 
12 

drums contain TRU isotopes but are below nCi/g TRU alpha, they become candidates for load 

management. If the drums do not contain measurable TRU isotopes, they are removed from the 

waste stream. Load management for Waste Stream ID-RF-S3114 is acceptable. Load 

management is not applicable to Waste Streams ID-RF-S5300-A and ID-SDA-SOIL. 

Notification to EPA upon modification to the load management status of approved waste streams 

remains a T2 change (see Table 1). 

(11) Compliance with tiering requirements was evaluated and found to be adequate. 

T2 notification to EPA upon completion of or substantive modification to the waste-streamspecific documents listed below is required on a quarterly basis. EPA compared the revision 

dates of documents provided during this continued compliance inspection with the T2 

notification reports provided to EPA by CBFO. EPA began tracking T2 quarterly reports in the 

fourth quarter of fiscal year 2009 and therefore is unable to verify whether document revisions 

made prior to July 2009 were appropriately included in the T2 notification to EPA. 

EPA found that the AK accuracy reports for Waste Streams ID-RF-S3114 and ID-RF-S5300-A 

were not consistently included in the list of T2 changes provided to EPA. INL-CCP explained 

that they were unaware that the requirement applied to all INL-CCP CH waste streams. EPA 

confirmed that all CH T2 requirements apply to all INL-CCP CH waste streams, unless 

specifically stated otherwise. The tiering changes identified during the INL-CCP CH baseline 

inspection and subsequent T1 inspections remain in effect and are included as Table 1 of this 

document. 

Summary of Acceptable Knowledge for Contact-Handled Waste

EPA did not identify any findings or concerns related to AK for CH wastes as a result of this 

continued compliance inspection. 

Notification to EPA upon completion of or revisions to all AKSRs is a new T2 change. This 

requirement was added to make the INL-CCP CH tiering designations consistent with the 

requirements at other sites and to reflect current T2 reporting practices (see Table 1). Submission 

to EPA of a list of AKEs and SPMs who performed work in these roles for the INL-CCP CH 

waste characterization program during the previous quarter is also a new T2 change (see Table 

1). 

Based on the results of this evaluation and the data examined, EPA determines that INL-CCP 

demonstrated continued AK characterization compliance for CH waste streams. 

6.1.2 Remote-Handled Waste Streams 

EPA evaluated INL-CCP’s continued compliance with EPA-approved AK procedures for RH 

waste characterization. INL-CCP’s RH AK characterization program is EPA-approved for SCG 

S3000 (homogeneous solids) and SCG S5000 (heterogeneous debris) waste. EPA selected one 

waste stream from each approved SCG (IN-ID-BTO-030 for SCG S3000 waste and ID-ANLES5000 for SCG S5000 waste) to review as representative samples of the INL-CCP RH AK waste 

characterization program. 
13 

EPA previously examined Waste Stream ID-ANLE-S5000 several times through review of T1 

requests required to add waste to this RH waste stream. Therefore, the evaluation focused on the 

status of waste stream characterization and documentation since the last T1 approval to add 

drums of high-gamma waste in July 2012 (see EPA Docket No. A-98-49; II-A4-163). EPA had 

not previously reviewed Waste Stream IN-ID-BTO-030 because a T1 change request for the 

waste stream has not been submitted for EPA review. The waste stream is still being 

characterized and many documents are still being prepared and reviewed by the U.S. Navy for 

public release. The U.S. Navy must approve public release of each Waste Stream IN-ID-BTO030 document because the waste originated at the Bettis Laboratory and was generated in 

support of Naval operations. As a result, information available for EPA’s review was limited and 

represents a “snapshot” of the documentation prepared for AK characterization. EPA’s 

inspection of Waste Stream IN-ID-BTO-030 focused on whether the documentation available 

and processes performed at the time of the inspection are adequate. The AK checklists used for 

this inspection are included in Attachments D.4 and D.5. 

Technical Evaluation

(1) Central Characterization Program procedures for acceptable knowledge documentation, 

training of Acceptable Knowledge Experts and disposition of nonconformances were 

examined and found to be adequate. 

EPA reviewed several CCP procedures for AK documentation, training of (AKEs and 

disposition of nonconformances for technical sufficiency and scope. The procedures adequately 

reflect the requirements of 40 CFR 194. Procedure implementation is evidenced by adequate 

preparation and maintenance of the required documentation, as reviewed below. See additional 

discussion in section 6.1.1, Item (1). 

Notification to EPA upon completion of or substantive modification to site procedures requiring 

CBFO approval remains a T2 change (see Table 2). 

(2) The acceptable knowledge characterization process for containers, including acceptable 

knowledge assembly, compilation and verification, was adequately implemented. 

EPA evaluated INL-CCP’s completion of each of the 15 attachments associated with CCP 

procedure CCP-TP-005 (AK documentation) for each of the two sample waste streams. As 

presented in the checklists, required attachments for Waste Stream ID-ANLE-S5000 were 

available, while many for Waste Stream IN-ID-BTO-030 were still in progress. Available 

attachments were prepared using forms from the appropriate revisions of CCP-TP-005. EPA is 

aware that significant revisions are currently being made to CCP-TP-005 and that these revisions 

are expected to significantly change the content of required attachments. EPA expects that the 

revised attachments will retain the information critical to compliance with 40 CFR 194. 

Notification to EPA when Attachment 4 of CCP-TP-005 is generated to reflect the updated 

AKSR source document reference list remains a T2 change (see Table 2). 
14 

(3) Waste traceability was adequately demonstrated. 

EPA examined traceability from the generator through characterization for Waste Stream IDANLE-S5000 drums as part of previous T1 evaluations and therefore did not repeat this exercise. 

EPA examined characterization traceability for two Waste Stream ID-ANLE-S5000 drums as 

part of this continued compliance inspection. Traceability was examined for initial canister, 

subsequent repackaging, final drum identification and characterization. These data show that the 

final drums can be traced to the original source canisters. 

EPA examined traceability of waste containers to evaluate characterization tracking. Waste 

Stream IN-ID-BTO-030 is a four-drum waste stream that originated from Bettis Laboratory. 

Traceability travelers for original drums had not been released by the Navy at the time of the 

inspection, but EPA was able to examine select references and other information to identify the 

original IN-41 cans shipped from Bettis Laboratory to Idaho National Engineering Laboratory 

(INEL),3 the Hot Fuel Examination Facility (HFEF) canisters in which the material was 

emplaced, and the INL repackaged drum (References C207 and U200). 

Traceability for Waste Streams IN-ID-BTO-030 and ID-ANLE-S5000 was adequately 

demonstrated. 

(4) The acceptable knowledge summary reports were assessed and found to be adequate. 

EPA evaluated the AKSR for each sample waste stream as described in section 6.1.1, Item (4). 

EPA found each AKSR to be adequate. Explanations and source documents supporting this 

determination are included in the checklists in Attachments D.4 and D.5 of this report: 

• Waste Stream ID-ANLE-S5000: Attachment D.4 summarizes the information provided in 

the AKSR, CCP-AK-INL-500, Revision 11, which was recently revised to address EPA’s 

comments from the T1 to add high-gamma drums. 

• Waste Stream IN-ID-BTO-030: Attachment D.5 summarizes the information provided in 

the AKSR, CCP-AK-INL-590, Revision 2, which was undergoing revision to address 

changes in radiological data and other information at the time of the continued 

compliance inspection. 

Notification to EPA upon completion of or revisions to all AKSRs, including those for which 

EPA has not yet approved the waste stream [see section 6.1.2, Item (10) below] remains a T2 

change. 

(5) Waste stream profile form preparation and completeness were evaluated and found to be 

adequate. 

EPA evaluated the Waste Stream ID-ANLE-S5000 WSPF and related change notices and addcontainer memoranda. The sum total of these documents presents the progression from initial 

waste stream profile to the current waste stream volume, which has been modified three times by 

 

3

 INL was formerly known as INEL. 
15 

T1 requests. WSPFs include a CIS and summation of aspects, and a characterization 

reconciliation report (CRR). EPA determined that, although the preparation of WSPFs was 

adequate, INL-CCP has not developed a consistent methodology for updating the WSPF, either 

by using add-container memoranda or revising the WSPF. EPA could follow the addition of 

containers to the original WSPF, but it would be better if specific modification criteria were 

established. EPA may examine the criteria for modifying WSPFs in forthcoming continued 

compliance inspections. A WSPF was not available for Waste Stream IN-ID-BTO-030. 

EPA found that WSPF preparation and the associated document trail is adequate. Notification to 

EPA upon completion of or substantive modification to WSPFs remains a T2 change (see Table 

2). 

(6) Acceptable knowledge personnel training was assessed and found to be adequate. 

INL-CCP indicated that Lisa Watson, Scott Smith and David Ams are the primary AKEs 

responsible for RH waste in the INL-CCP program, with Mr. Kevin Peters also trained for INL 

waste and primarily providing oversight and guidance. INL-CCP provided complete 

qualification cards and documentation of familiarity with the current revision of the WCPIP 

(Revision 3) for these three AKEs. Submission to EPA of a list of AKEs and SPMs who 

performed work in these roles for the INL-CCP RH waste characterization program during the 

previous quarter is a new T2 change (see Table 2). 

(7) Nonconformance and discrepancy resolution documentation was assessed and found to 

be adequate. 

EPA previously evaluated INL-CCP’s ability to produce compliant NCRs and DR reports as part 

of the recent T1 review to add drums of high-gamma waste. Therefore, EPA evaluated a small 

sample of NCRs and DR reports specific to Waste Streams ID-ANLE-S5000 and IN-ID-BTO030. 

Notification to EPA upon completion of or modification to DR reports and NCRs is a new T2 

requirement. This requirement was added to make the INL-CCP RH tiering designations 

consistent with the requirements at other sites and to reflect current T2 reporting practices (see 

Table 2). 

(8) Acceptable knowledge accuracy was assessed and found to be adequate. 

Several AK accuracy reports have been prepared for Waste Stream ID-ANLE-S5000, the most 

recent of which addresses AK accuracy for Lots 1–36 (dated April 29, 2013). During the 

continued compliance inspection, INL-CCP revised the AK accuracy report for Lots 1–36 to 

clarify that the scaling factors used in the DTC calculations were developed based on AK and, 

therefore, comparing the DTC results to AK data does not result in a meaningful AK accuracy 

evaluation because it is essentially comparing the AK against itself. EPA will continue to 

monitor AK accuracy reports to ensure that meaningful data comparisons are being made or that 

statements are included in the accuracy report explaining why a meaningful evaluation cannot be 

conducted. AK accuracy reports were not available for Waste Stream IN-ID-BTO-030. 
16 

Notification to EPA upon completion of or substantive modification to AK accuracy reports 

(annually, at a minimum) remains a T2 change (see Table 1). 

(9) Load management was found to be not applicable. 

The WIPP waste acceptance criteria allow payload management such that a payload container 

may include drums that measure less than 100 nCi/g so long as the payload in total is greater 

than 100 nCi/g. Neither Waste Stream ID-ANLE-S5000 nor Waste Stream IN-ID-BTO-030 will 

be load managed. 

Addition of load management to any RH waste stream remains a T1 change (see Table 2). 

(10) Compliance with tiering requirements was evaluated and found to be adequate. 

T2 notification to EPA upon completion of or substantive modification to the waste-streamspecific documents listed in Table 2 is required on a quarterly basis. EPA compared the revision 

dates of documents provided during this continued compliance inspection with the T2 

notification reports provided to EPA by CBFO. 

 Most of the examined documents were appropriately reported. EPA expects to receive a T2 

notification when a new or revised Attachment 4 to CCP-TP-005 has been generated, but EPA 

has not received any such notifications. CCP-TP-005, Attachment 4, for Waste Stream IDANLE-S5000 was last revised November 26, 2012, and EPA should have received T2 

notification in the T2 change report covering changes from the first quarter of fiscal year 2013. 

EPA is clarifying that the tiering requirements in Table 2 apply to the whole RH INL-CCP 

characterization program. The T2 requirement for notification of new or modified AKSRs and 

certification plans applies to all waste streams, regardless of their EPA approval status. This 

means that EPA may receive notification of a new or revised AKSR prior to receiving the T1 

request or conducting the T1 review. 

The tiering changes identified during the INL-CCP RH baseline inspection and subsequent T1 

inspections remain in effect and are included as Table 2 of this document. 

(11) The radiological characterization report and the acceptable knowledge summary report 

were reviewed as a demonstration of acceptable knowledge-radiological characterization 

communication and found to be adequate. 

(12) The certification plans were reviewed and found to have been adequately prepared. 

Summary of Acceptable Knowledge for Remote-Handled Waste

EPA did not identify any findings or concerns related to AK for RH wastes as a result of this 

continued compliance inspection. 

Notification to EPA upon completion of or modification to DR reports and NCRs is a new T2 

change. This requirement was added to make the INL-CCP RH tiering designations consistent 

with the requirements at other sites and to reflect current T2 reporting practices (see Table 2). 

Submission to EPA of a list of AKEs and SPMs who performed work in these roles for the INL-
17 

CCP RH waste characterization program during the previous quarter is also a new T2 change 

(see Table 2). 

Based on the results of this evaluation and the data examined, EPA determines that INL-CCP 

demonstrated continued AK characterization compliance for RH waste streams. 

6.1.3 Acceptable Knowledge Findings and Approval 

Summary of Acceptable Knowledge Findings and Concerns

EPA did not identify any findings or concerns for AK at INL-CCP. 

Acceptable Knowledge Approval

Based on the results of this evaluation and the data examined, EPA determines that INL-CCP 

demonstrated continued AK characterization compliance for CH and RH waste. 

6.2 Nondestructive Assay for Contact-Handled Waste 

EPA approved the WAGS and SGRS NDA systems initially during the CH baseline inspection 

in November 2005 (EPA Docket No. A-98-49; II-A4-59). The SuperHENC was added to the 

INL-CCP approval through a T1 change in February 2007 (EPA Docket No. A-98-49; II-A4-86). 

The systems’ abilities to perform the required analyses was demonstrated during the baseline and 

confirmed by the continued compliance inspections. Accordingly, this inspection focused on the 

following: 

• Confirmation that the design and technical capabilities of the NDA systems’ hardware 

and software had not changed since EPA’s last inspection. 

• Adequacy of the current revisions to the INL-CCP NDA procedures and documents. 

• Operational and maintenance history of the NDA systems since the last EPA inspection. 

• Knowledge, understanding and training status of INL-CCP NDA personnel. 

6.2.1 Technical Evaluation: Waste Assay Gamma Spectrometer 

EPA evaluated INL-CCP’s continued compliance with the EPA-approved waste characterization 

program for CH waste using the WAGS NDA system. The checklist used for this inspection is 

included in Attachment E.1. The following aspects of the WAGS were evaluated during this 

inspection. 

(1) The Waste Assay Gamma Spectrometer nondestructive assay system is the same system 

that was approved previously. 

The WAGS system is located at INL in the facility formerly called the Stored Waste 

Examination Pilot Plant (SWEPP), INL building WMF-610. EPA found that since the last 

inspection, the power supply for detector No. DET3NB was replaced. A calibration verification 

was performed on November 29, 2012, after its installation to confirm that the WAGS 

calibration was unaffected by the replacement. Other than the power supply replacement, there 
18 

have been no substantive hardware or software changes to this system since EPA’s last 

evaluation. 

(2) The design and operational range of the Waste Assay Gamma Spectrometer were 

assessed and were found to be unchanged from the last inspection and were adequate for 

the wastes currently being assayed. 

Between May 1, 2012, and May 6, 2013, the WAGS assayed 1,444 drums that were compiled in 

119 batch data reports (BDRs). EPA inspectors observed the assay of Drum No. SRP14193, 

which was 90% full and had a net weight of 136.2 kilograms (kg). This drum is part of BDR 

INNDAW130062. EPA Inspectors reviewed this BDR and found it to adequately document 

assay of the drum. All daily performance measurements were appropriately recorded and were in 

control. Specifically, background, daily performance check, full width at half maximum 

(FWHM), energy calibration (gain) and barium-133 (133Ba) transmission source checks were 

evaluated, as evidenced in the WAGS daily operational logbook and BDRs. Warning and control 

limits [2 and 3 sigma (σ) limits] for all parameters had been established and documented, as 

appropriate, and background [~40 counts per second (cps), full spectrum], FWHM and gain were 

controlled by boundary limits. 

Decay correction of the 133Ba transmission sources is performed in the software. Due to the short 

half-life of 133Ba (approximately 10 years), the count rate boundary limits of the sources must be 

adjusted throughout the operational life of the sources. Since the last EPA continued compliance 

inspection in 2010, the boundary limits of the transmission sources have been adjusted twice, in 

July 2011 and July 2012. 

EPA observed that WAGS personnel had available and were using the current revisions of the 

WAGS operating procedure. All operational aspects of the WAGS operation were acceptable. 

(3) System calibration and calibration confirmation of the Waste Assay Gamma 

Spectrometer had been performed and documented as required. 

EPA verified that the system’s calibration was unchanged since the last inspection. One 

calibration verification has been performed in the last year; the power supply for detector No. 

DET3NB was replaced. This was documented in NCR-INL-0368-12 and CCP-INL-WAGS-12-

005; all aspects of the calibration verification were technically acceptable and appropriately 

documented. 

(4) Determination and documentation for the total measurement uncertainty for the Waste 

Assay Gamma Spectrometer are adequate. 

The total measurement uncertainty (TMU) of assays performed on the WAGS had been 

documented, as required. The EPA inspection team verified that this document was unchanged 

from EPA’s last inspection. 
19 

(5) The lower limit of detection, including the minimum detectable concentration of the 

Waste Assay Gamma Spectrometer, had been determined and documented, as required. 

CCP-INL-WAGS-001, Revision 1, April 2008, adequately documents the technical basis for the 

system’s lower limit of detection (LLD), including reporting thresholds for specific nonmeasured radionuclides 242Pu and strontium-90 (90Sr). The EPA inspection team verified that this 

document was unchanged from EPA’s last inspection. 

(6) The Waste Assay Gamma Spectrometer had successfully participated in drum cycle 19A 

of the CBFO-sponsored performance demonstration program, as required. 

The WAGS performance demonstration program (PDP) approval post-recalibration expires 

August 18, 2013 and the WAGS is secheduled to participate in the PDP annually. 

(7) Personnel training was assessed and found to be adequate. 

All NDA personnel associated with the calibration, operation and data review and approval of 

the WAGS had current training in the applicable areas, as evidenced by the list of qualified 

individuals (LOQI) dated May 6, 2013, that was provided during the inspection. 

6.2.2 Technical Evaluation: Stored Waste Examination Pilot Plant Gamma-Ray 

Spectrometer 

EPA evaluated INL-CCP’s continued compliance with the EPA-approved waste characterization 

program for CH waste using the SGRS NDA system. The checklist used for this inspection is 

included in Attachment E.2. EPA evaluated the following aspects of the SGRS during this 

inspection: 

(1) The Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer is the same system 

that was approved previously. 

The SGRS system is located at the INL Radioactive Waste Management Complex (RWMC) in 

the facility formerly called the SWEPP, INL building WMF-610. EPA verified that there have 

been no substantive hardware changes other than the detector replacement and subsequent 

recalibration that EPA reviewed and approved as a T1 change in February 2013 (EPA Docket 

No: A-98-49; II-A4-172). 

(2) The design and operational range of the Stored Waste Examination Pilot Plant GammaRay Spectrometer were assessed and were found to be unchanged from the last inspection 

and were adequate for the wastes currently being assayed. 

Between May 1, 2012, and May 6, 2013, the SGRS assayed 1,246 drums (697 production drums 

and 549 information-only drums) that were compiled in 41 BDRs. SGRS operators conveyed to 

EPA reviewers that the SGRS has the capability to assay up to 35 55-gallon drums in a day. EPA 

observed the reassay of Drum No. ARP70259/104328, which had a net weight of 96.2 kg and 

was 70% full. The assay witnessed was the third replicate measurement on the drum that EPA 

selected. This and other replicate assays are discussed further in section 6.2.2, Item (7) below. 

All daily performance measurements were appropriately recorded and were in control: 
20 

specifically, background, daily performance check, FWHM and energy calibration (gain), as 

evidenced in the SGRS daily operational logbook and BDRs. Warning and control limits (2 and 

3 σ limits) for all parameters had been established and documented, as appropriate, and 

background (~40 cps, full spectrum), FWHM and gain were controlled by boundary limits. EPA 

observed that SGRS personnel had available and were using the current revisions of the SGRS 

operating procedure. All operational aspects of the SGRS operation were acceptable. 

(3) System calibration and calibration confirmation of the Stored Waste Examination Pilot 

Plant Gamma-Ray Spectrometer nondestructive assay system had been performed and 

documented as required. 

The EPA inspection team verified that the system’s calibration was unchanged since the 

recalibration approved in February 2013. No calibration verification had been performed since 

the last EPA T1 evaluation, when a gamma detector was replaced. All aspects of the calibration 

verification were technically acceptable and appropriately documented. 

(4) The lower limit of detection, including the minimum detectable concentration of the 

Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer, had been determined 

and documented, as required. 

CCP-INL-SGRS-001, Revision 2, November 14, 2012, section 6.0, adequately documents the 

technical basis for the system’s LLD, including reporting thresholds for specific nonmeasured 

radionuclides uranium-234 (234U), 238Pu, 239Pu, 242Pu and 90Sr. The EPA inspection team verified 

that this document was unchanged from EPA’s last T1 inspection. 

(5) The Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer performance 

demonstration program approval post-recalibration expires August 18, 2013. 

The SGRS participated in Cycle 20B of the CBFO-sponsored PDP for drums in May 2013. INLCCP will provide certification of the SGRS’s PDP status upon completion. The SGRS is 

secheduled to participate in the PDP annually. 

(6) Personnel training was assessed and found to be adequate. 

All NDA personnel associated with the calibration, operation and data review and approval of 

the SGRS had current training in the applicable areas, as evidenced by the LOQI dated May 6, 

2012, that was provided during the inspection. 

(7) EPA replicate testing of the Stored Waste Examination Pilot Plant Gamma-Ray 

Spectrometer unit was performed and evaluated and was found to comply with the 

criteria for the Environmental Protection Agency Replicate Testing Protocol. 

The purpose of the replicate testing performed as part of this inspection is to provide EPA with 

an independent means to verify that the SGRS can provide reproducible results for the 

determination of the quantity of 10 WIPP-tracked radionuclides [241Am, cesium-137 (137Cs), 
21 

238Pu, 239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U and 238U] and the TRU alpha concentration.4

 This is 

accomplished by the SGRS reassaying drums it previously measured to demonstrate the system’s 

ability to do the following: 

• Produce results consistent with the reported TMU by comparing the sample standard 

deviation for a number of replicate measurements taken over several hours or days to the 

reported TMU. 

• Provide reproducible results over longer periods of time, such as weeks or months, by 

comparing the results of the replicate measurements to the original reported values. 

As part of this inspection, EPA requested that INL-CCP reassay three drums that EPA randomly 

selected from a list of drums previously assayed on the SGRS. Drum Nos. ARP70420, 

SRP13045 and ARP70259 were reassayed five times, and the results were compared to the 

original assay data. Two statistical tests, a chi-squared (χ2

) test and a t test, were performed. Data 

and results of the statistical analysis are included in Attachments F.1 through F.3. The χ2

 test, 

which is also known as the goodness-of-fit test or the chi-squared test for independence, is used 

to show how observed data compare with data we would expect to obtain according to a specific 

hypothesis. EPA applied it in this instance to show if the replicate measurements differed from 

the expected original measurement. The t test is a statistical tool that is used to tell if two sets of 

data are statistically different from one another. EPA applied it to the replicate data to see if there 

are statistically significant differences between the original assay values and the average of the 

five replicate measurements. 

For Drum Nos. ARP70420 and SRP13045, the χ2

 test showed that the observed variances in the 

replicate measurements are less than or equal to the reported uncertainties within the statistical 

limits of the test. The t test for Drum Nos. ARP70420 and SRP13045 also showed no statistically 

significant differences between the original assay values and the average of the five replicate 

measurements. 

The t test and χ2 for Drum No. ARP70259 both showed a statistically Highly Significant

difference between the original assay value and the average of the five replicate measurements 

for 238U. This indicates that the variances in the replicate measurements for these items were 

greater than the reported uncertainties for all values relative to the limits of the test and that there 

was a statistically significant difference between the original assay and the average of the 

replicate measurements of 238U. It is important to keep these in mind when evaluating replicate 

data and to realize that Significant or Highly Significant results are not always representative of 

true measurement issues. 

There are several possible reasons for the Highly Significant differences in 238U replicate values 

versus original values: (1) actual changes in the physical configuration of the drum’s contents 

due to movement or settling, (2) fluctuations in the measurement system’s background, (3) 

temporal factors such as radioactive growth or decay, or (4) actual changes in the measurement 

system, the aspect that these tests are designed to query. Although the software identified these 

variances as Highly Significant, this does not necessarily indicate a measurement issue that 

 

4

 Revision 2 of the Environmental Protection Agency Replicate Testing Protocol provides the details of the 

replicate testing assay protocol and data evaluation. 
22 

warrants additional attention at this time. Further inspection of the five replicate measurements 

found that the replicate measurements for 238U had high level of precision. All other 

radionuclides in the replicate and original measurements passed both statistical tests. 

Additionally, replicate measurements of drum Nos. ARP70420 and SRP13045 showed the 

instrument to be functioning properly. This suggests that settling or movement of wastes in the 

drum exposed a “hot spot” in the drum that was previously shielded by waste in the drum. Waste 

shifting is expected when a container is moved and this is not indicative of a problem with the 

instrument. 

6.2.3 Technical Evaluation: Super High Efficiency Neutron Counter 

EPA evaluated INL-CCP’s continued compliance with the EPA-approved waste characterization 

program for CH waste using the SuperHENC NDA system. The SuperHENC is located at INL in 

the facility formerly called the SWEPP, INL building WMF-610, South Bay, and is officially 

designated as NDA SHENC-01. EPA verified that there have been no substantive hardware or 

software changes to this system since the last EPA inspection. 

Although the SuperHENC is an approved measurement modality at INL-CCP, it was only used 

for WIPP assays on three days from May 1, 2012, through May 6, 2013. INL-CCP indicated to 

EPA inspectors that they do not anticipate the frequency of use will increase in the near future. 

Despite the lack of use, INL-CCP continues to run weekly checks on the instrument to keep the 

instrument functioning properly. Because the SuperHENC is only being used infrequently, EPA 

elected to abridge its review of the SuperHENC in order to focus on the SGRS and WAGs, 

which have much higher throughput. EPA requested that INL-CCP notify EPA if there is a 

significant increase in the use of the instrument. 

EPA evaluated the following aspects of the SuperHENC during this inspection. 

(1) The design and operational range of the Super High Efficiency Neutron Counter were 

assessed and were found to be unchanged from the last inspection and were adequate for 

the wastes currently being assayed. 

EPA verified that the original operational ranges for all of the system’s previously approved 

assay configurations were unchanged since the last EPA inspection. 

(2) System calibration and calibration confirmation of the Super High Efficiency Neutron 

Counter had been performed and documented as required. 

EPA verified that the system’s original calibrations for all previously approved assay 

configurations were unchanged. No calibration verifications had been performed since the last 

EPA inspection. 

(3) The total measurement uncertainty of assays performed on the Super High Efficiency 

Neutron Counter had been determined and documented, as required. 

EPA verified that the system’s original determinations of TMU for all previously approved assay 

configurations were unchanged since the last EPA inspection. 
23 

(4) The lower limit of detection, including the minimum detectable concentration of the 

Super High Efficiency Neutron Counter, had been determined and documented, as 

required. 

The EPA inspection team verified that the system’s original determinations of LLDs for all 

previously approved assay configurations were unchanged since the last EPA inspection. 

(5) The Super High Efficiency Neutron Counter had successfully participated in drum cycle 

17A (combustibles and metals matrices) and box cycle 9A (combustibles and metals 

matrices) of the Carlsbad Field Office-sponsored performance demonstration program, as 

required. 

The SuperHENC PDP approval expires August 18, 2013. The SuperHENC is secheduled to 

participate in the PDP annually. 

(6) Personnel training was assessed and found to be adequate. 

All NDA personnel associated with the calibration, operation and data review and approval of 

the SuperHENC had current training in the applicable areas, as evidenced by the LOQI dated 

May 6, 2012, that was provided during the inspection. 

6.2.4 Nondestructive Assay Findings and Approval 

Summary of Nondestructive Assay Findings and Concerns

EPA did not identify any findings or concerns for NDA at INL-CCP. 

Nondestructive Assay Approval

There are no changes to the T1 or T2 designations for NDA as a result of this continued 

compliance inspection. Based on the results of this evaluation and the data examined, EPA 

determines that INL-CCP demonstrated continued compliance with the EPA-approved waste 

characterization program for all NDA systems. 

6.3 Dose-to-Curie for Remote-Handled Waste 

EPA approved the DTC technique initially during the RH baseline inspection in June 2007 (EPA 

Docket No. A-98-49; II-A4-72). 

Technical Evaluation

EPA evaluated INL-CCP’s continued compliance with EPA-approved DTC procedures for RH 

waste characterization. The checklist used for this inspection is included in Attachment G. The 

following aspects of DTC were evaluated during this inspection: 
24 

(1) Dose-to-curie and technique, including source checks, was observed and found to be 

adequate. 

EPA observed the DTC technique on May 8, 2013, at Idaho Nuclear Technology and 

Engineering Center (INTEC) in INL Building 659, Room 306, from screens in the operator 

control room, Room 302. The INL-CCP DTC operators were David Pinnock and Brent Dial, 

who were listed on the current LOQI dated May 7, 2013. The INL-CCP DTC/OSPREY operator, 

Mary Carroll, used the gamma software. DTC personnel began by performing the operational 

check on Scale No. 724422, which is due for recalibration on June 21, 2013. This check was not 

witnessed by EPA inspectors but was documented appropriately in the logbook. The operator 

weighed the drums and recorded the weight on the measurement control report (CCP-TP-504, 

Revision 13 Attachment 2) and summarized this activity in the operational logbook. 

DTC personnel performed the source checks for Thermo Scientific Model FH 40 G Dose Rate 

Measuring Unit with FHZ 612 Probe (Instrument No.) attached to Probe No. XC0674, with the 

option of using Probe No. XC0675. The ambient background was measured and 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 logbook. DTC personnel 

consulted “CCP Operator Aid: RH-DM-INL-002, Revision 17, 4-09-12,” 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 also performed a source check for the 

OSPREY LaBr5 Probe No. 13000014 using 137Cs source No. 1181-64 INL 1D; CP-7CS001 

positioned with the appropriate jig. DTC operators took a background dose reading while all 

containers were in a shielded position. 

EPA observed an overhead crane lift Drum No. FC0100B-1 onto the DTC assembly and four 

measurements made at different points on the drum’s circumference, i.e., at 0°, 90°, 180° and 

270°. All measurements were recorded on the container data sheet (CCP-TP-504, Revision 13, 

Attachment 2), a copy of which was provided to EPA. Contact dose rates for this drum exceeded 

200 millirem per hour (mrem/hr) and exceeded three times the measured background of 0.2 

mR/hr, and all measurements and accompanying parameters were acceptable. 

(2) Personnel training was assessed and found to be adequate. 

INL-CCP provided the LOQI dated May 7, 2012, for DTC and OSPREY documenting that all 

DTC personnel were appropriately trained. 

6.3.1 Dose-to-Curie Findings and Approval 

Summary of Dose-to-Curie Findings and Concerns

EPA did not identify any findings or concerns for DTC at INL-CCP. 

 

5

 The OSPREY detector is a cerium-drifted lanthanum bromide crystal [La3Br(Ce)]. 
25 

Radiological Characterization Approval

There are no changes to the T1 or T2 designations for DTC as a result of this continued 

compliance inspection. Based on the results of this evaluation and the data examined, EPA 

determines that INL-CCP demonstrated continued compliance with the EPA-approved waste 

characterization program for DTC. 

6.4 Real-Time Radiography for Remote-Handled Waste 

EPA evaluated INL-CCP’s continued compliance with EPA-approved RTR procedures for RH 

waste and found compliance to be adequate. INL-CCP does not perform RTR for CH waste 

containers. The RTR checklist used for this inspection is included in Attachment H. 

Technical Evaluation 

(1) Real-time radiography examination of a drum was observed and found to be adequate. 

On May 8, 2013, INL-CCP demonstrated the RTR process for Drum No. FCO100B-1 from BDR 

No. INLRHRTR13006, Waste Stream ID-HFEF-S5000-RH. The operator had already performed 

the necessary equipment checks prior to EPA’s arrival. The operator properly examined the 

container’s contents and entered characterization data into the electronic data sheet. The operator 

determined that the waste matched the waste stream description and verified the waste matrix 

code (WMC). No prohibited items were found in the container. After the demonstration, EPA 

reviewed the container data sheets and determined that they had been completed correctly and 

signed by the RTR operator. The operator used procedure CCP-TP-508, Revision 7, to guide the 

examination. 

The EPA inspector determined the procedure continues to be adequate and effective for 

generation of compliant RH RTR data. 

(2) Real-time radiography characterization records were examined and found to be adequate. 

EPA reviewed the audio/visual and written records for selected containers from BDR Nos. 

INLRHRTR13001, INLRHRTR13003 and INLRHRTR13004 and determined that the records 

were complete and generated in accordance with INL-CCP procedures. Operators had properly 

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

sheet. The operator determined that the waste matched the waste stream description and verified 

the WMC. No prohibited items were identified in the containers from the reviewed BDRs. 

An image quality check had been performed prior to each RTR event for the BDRs examined. 

Required quality control examinations, in the form of an independent observation and replicate 

scan, had been performed for the BDRs examined. One NCR was initiated for the independent 

observation, container FCO102B-2, BDR No. INLRHRTR13003. A 30-gallon can had been 

called out on the audio tape but was not written into the waste container inventory. The record 

was corrected in accordance with INL-CCP procedures. 
26 

Data were reviewed at the data generation and SPM level; the reviews were recorded on the 

appropriate forms from CCP-TP-508. 

EPA determined that INL-CCP continues to generate and record compliant RH RTR data in 

accordance with written procedures. 

(3) Real-time radiography training records were examined and found to be adequate. 

EPA reviewed training records for selected operators and identified a concern not requiring a 

response (INL-CCP-CC-2013-01C, reproduced in full in Attachment J) regarding written 

training records of RTR operators. 

RTR and VE personnel qualification records for on-the-job training marked as “Requalification” 

are not required to be signed by the VE Expert (VEE)/Subject-Matter Expert (SME) unless the 

requalification is a result of disqualification of the operator. Seven of the fourteen records 

reviewed had been signed by the VEE/SME attesting that the requalification was a result of 

operator disqualification. Telephonic interview of INL-CCP training records personnel reveal 

that none of the subject operators had actually been disqualified for the dates listed on the 

requalification records. 

EPA requests that INL-CCP consider this concern and evaluate it with an eye towards ensuring 

that training records accurately reflect the continued qualification status of all VE and RTR 

personnel. 

EPA also reviewed container inventories for three training drums, Nos. 17, 21 and 25, and 

generated a concern requiring a response (INL-CCP-CC-2013-02CR, reproduced in full in 

Attachment K) regarding the training containers used to demonstrate continued operator 

performance. 

RTR Training Drum Nos. 17, 21 and 25, assembled on January 10, 2012, August 15, 2012, and 

April 2, 2013, respectively, contained the same waste items. The only exception was that 

Container Nos. 21 and 25 contained a “plastic bag with horsetail” while Drum No.17 did not. A 

cursory review of RTR tapes for Drum Nos. 21 and 25 indicates that waste items in both drums 

are in the same positions and relative orientations. 

Because the contents of the training drums are known, they are the only objective test of an RTR 

operator's competency. EPA requests that INL-CCP consider adding different, varied, 

discretionary waste items and varying their positions in training drums to provide a process 

improvement and enhanced level of operator skills testing. EPA requests that INL-CCP evaluate 

this concern and ensure that RTR training drums constitute a rigorous test of RTR operators’ 

skills. 

EPA wrote a similar concern at INL-CCP on May 9, 2012, while reviewing an RH T1 change to 

add Lot 2 waste to Waste Stream ID-ANLE-S5000 (EPA Docket No. A-98-49; II-A4-163, 

Concern No. INL-CCP-RH-RTR-2012-01C Final). 

CBFO responded to EPA’s concern on May 30, 2013. CBFO believes that the current practice of 

developing RTR training drums meets the minimum requirements but agrees with EPA that 
27 

process improvements should be implemented. As a result, the CCP Cognizant Engineer for 

NDE has directed that all active generator sites reconfigure their RTR training drums to ensure 

that the locations and orientations of items, as well as the liquid volumes and waste-streamspecific items, are varied for each training drum. CCP will also revise procedure CCP-TP-028, 

“CCP Radiographic Test Drum and Training Container Construction,” to include the 

reconfiguration directive identified above. CBFO’s targeted completion dates for these activities 

are June 18, 2013, for reconfiguration of the drums, and June 28, 2013, for revision of the 

procedure. EPA finds CBFO’s response to be acceptable and EPA will confirm implementation 

of the container reconfiguration directive and procedure revision during the next RTR inspection. 

EPA determined that operators were trained in accordance with INL-CCP procedures and that 

training records were readily available for review. EPA reviewed a LOQI and determined that 

the operator performing the demonstrated RTR examination discussed in section 6.4, Item (1) 

above was properly qualified. 

Summary of Real-Time Radiography Findings and Concerns

EPA did not identify any findings related to RTR for RH wastes as a result of this continued 

compliance inspection. 

EPA did identify a concern not requiring a response, INL-CCP-CC-2013-01C (Attachment J), 

and a concern requiring a response, INL-CCP-CC-2013-02CR (Attachment K), both related to 

RTR personnel training as discussed in Item (3) above. There are no open concerns as a result of 

this continued compliance inspection. 

6.4.1 Real-Time Radiography Approval 

Based on the results of this evaluation and the data examined, EPA determines that INL-CCP 

demonstrated continued RTR compliance for RH waste.

6.5 Visual Examination 

EPA evaluated INL-CCP’s continued compliance with EPA-approved VE procedures for CH 

and RH waste characterization. The VE checklists used for this inspection are included in 

Attachments I.1 and I.2. 

6.5.1 Visual Examination of Contact-Handled Waste 

Technical Evaluation 

(1) Visual examination of a contact-handled drum was observed and found to be adequate. 

On May 9, 2013, EPA observed VE of RFP organic sludge waste. The receiving drum for the 

waste was SRP14510 (BDR No. IN-SRP-VE-000175) and the waste stream for the waste was 

ID-RF-S3114. During the onsite demonstration, the actual handling of the waste in the glove box 

was performed by CH2M-WG Idaho, LLC (CWI) personnel with the INL-CCP operators 

performing VE and recording the VE data generated. The VEE was available to the operators at 

the time of data generation. EPA obtained the data sheets generated during the onsite 
28 

demonstration and verified that the VE process was completely and accurately recorded. There 

were no prohibited items identified during the VE demonstration and the area of the glove box 

set aside to segregate prohibited items was visible to EPA during the demonstration. A VE 

operator stated during the onsite demonstration that oil dry is added to the waste if liquids are 

present. 

EPA determined the procedure and process to be adequate and effective for generation of 

compliant CH VE data. EPA reviewed a LOQI and determined that the operators and VEE 

performing the demonstrated VE event were currently qualified. 

(2) Contact-handled visual examination characterization records were examined and found to 

be adequate. 

EPA reviewed BDR Nos. IN-ARP-VE-002792, IN-ARP-VE-002728 and IN-SRP-VE-000120 to 

ensure that VE data were compliantly generated and recorded. The waste in these three BDRs 

was sludge with WMCs of S3114 and S3900 from Waste Streams ID-RF-S3114 and ID-SDASLUDGE. EPA verified that INL-CCP generated and recorded the VE data in accordance with 

INL-CCP procedures. VE personnel recorded the waste material parameter (WMP) of each 

waste item, verified the WMC, and confirmed the absence of prohibited items. Data sheets were 

signed by two operators as required by procedure CCP-TP-500. EPA did not identify any issues 

with regard to generation and recording of RH VE data. 

(3) Contact-handled visual examination training records were examined and found to be 

adequate. 

EPA reviewed training records for selected operators and identified a concern not requiring a 

response, INL-CCP-CC-2013-01C, regarding written training records of VE operators. This 

concern is discussed in section 6.4, Item (3), and reproduced in full in Attachment J of this 

report. 

EPA determined that CH VE operators and VEEs continued to be trained in accordance with 

INL-CCP procedures and that training records continue to be available for review. 

Summary of Visual Examination for Contact-Handled Waste

EPA did not identify any findings related to VE for RH wastes as a result of this continued 

compliance inspection. EPA did identify a concern not requiring a response, INL-CCP-CC-2013-

01C (Attachment J), related to VE personnel training as discussed in section 6.4, Item (3) above. 

Based on the results of this evaluation and the data examined, EPA determines that INL-CCP 

demonstrated continued VE compliance for CH waste. 
29 

6.5.2 Visual Examination of Remote-Handled Waste 

Technical Evaluation 

(1) Visual examination of a remote-handled drum was observed and found to be adequate. 

On May 7, 2013, EPA observed VE of drum No. ANLE3D-3, BDR No. INLRHVE13001. The 

source container for the items subjected to VE during the onsite visit was ANLE 3D, which had 

an unacceptable fissile gram equivalent level. The purpose of the VE activity was to separate the 

three 1-gallon paint cans into separate 30-gallon containers. The three paint cans were designated 

as ANLE3D-1, ANLE3D-2 and ANLE3D-3. INL-CCP VE personnel for this examination 

consisted of two VE operators and one VEE who completed the required data forms while 

overseeing the process. CWI personnel physically manipulated the waste in the glove box. The 

operators verified that no prohibited items were present and that the waste matched the waste 

stream description and WMC. The VE personnel used procedure CCP-TP-500, Revision 11, to 

guide the examination. EPA reviewed the container data sheets generated during the 

demonstration and determined that they had been completed correctly and signed by the VE 

operators. 

EPA determined that the procedure continues to be adequate and effective for generation of 

compliant RH VE data. 

(2) Remote-handled visual examination characterization records were examined and found to 

be adequate. 

EPA reviewed BDR Nos. INLRHVE11002, INLRHVE11003 and INLRHVE12001 and 

determined that characterization records were complete and properly processed. The waste in 

these three BDRs was debris with WMC S5100 from waste stream ID-ERB-S5000. EPA verified 

that VE operators generated and recorded VE data in accordance with INL-CCP procedures. VE 

operators recorded the WMP of each waste item, verified the WMC and confirmed the absence 

of prohibited items. Two VE operators signed the data sheets as required by procedure CCP-TP500. INL-CCP had not generated any NCRs for the containers in these BDRs. 

(3) Remote-handled visual examination training records were examined and found to be 

adequate. 

EPA reviewed training records for selected operators and identified a concern not requiring a 

response, INL-CCP-CC-2013-01C, related to written training records of VE operators. This 

concern is discussed in section 6.4, Item (3), and reproduced in full in Attachment J of this 

report. 

EPA determined that RH VE operators and VEEs continued to be trained in accordance with 

INL-CCP procedures and that training records continue to be available for review. 
30 

Summary of Visual Examination for Remote-Handled Waste

EPA did not identify any findings related to VE for CH wastes as a result of this continued 

compliance inspection. EPA did identify a concern not requiring a response, INL-CCP-CC-2013-

01C (Attachment J), related to VE personnel training as discussed in section 6.4, Item (3) above. 

Based on the results of this evaluation and the data examined, EPA determines that INL-CCP 

demonstrated continued VE compliance for RH waste. 

6.5.3 Visual Examination Findings and Approval 

Summary of Visual Examination Findings and Concerns

EPA did not identify any findings for VE at INL-CCP. EPA did identify a concern not requiring 

a response, INL-CCP-CC-2013-01C (Attachment J), related to VE personnel training as 

discussed in section 6.4, Item (3) above. 

Visual Examination Approval

Based on the results of this evaluation and the data examined, EPA determines that INL-CCP 

demonstrated continued VE compliance. 

7.0 FINDINGS AND CONCERNS 

There were no findings identified during this continued compliance inspection. The EPA 

inspection team identified one concern related to RTR as performed by INL-CCP and one 

concern related to RTR and VE operator qualification records. These concerns are discussed in 

section 6.4, Item (3) above and are provided in Attachments J and K. INL-CCP satisfactorily 

responded to EPA’s concern in writing on June 26, 2013. The concern is closed. There are no 

open concerns as a result of this continued compliance inspection. 

8.0 CONCLUSIONS 

Changes to Tiering

There are no changes to the T1 designations in any waste characterization area as a result of this 

inspection. There substantive changes to the RH and CH AK T2 designations. 

1. Notification to EPA upon completion of or revisions to all AKSRs is a new T2 change 

applicable to the CH waste characterization program. 

2. Notification to EPA upon completion of or revisions to DR reports and NCRs is a new T2 

change applicable to the RH waste characterization program. 

3. Submission to EPA of a list of AKEs and SPMs who performed work in these roles for 

the INL-CCP waste characterization program during the previous quarter is a new T2 

change applicable to both the CH and RH waste characterization programs. 
31 

Change Nos. 1 and 2 as listed above are necessary to make the INL-CCP CH and RH tiering 

designations consistent with the requirements at other TRU sites and to reflect current T2 

reporting practices. EPA also revised the tiering tables to ensure completeness and consistency 

with recent EPA T1 approval reports. Tables 1 and 2 show the substantive T2 changes for CH 

and RH in bold text. T1 and T2 changes that were initiated during the CH and RH baseline and 

subsequent T1 approvals remain in effect. The language in Tables 1 and 2 regarding AK 

documentation applies to all INL-CCP waste streams.

Approval

The EPA inspection team determined that the INL-CCP waste characterization program 

activities continue to be technically adequate. EPA is not proposing any changes to the INL-CCP 

waste characterization program at this time. The scope of the compliance decision is based on 

EPA’s inspection completed May 7–9, 2013.

Section 6.4, Item (3) discusses one item related to RTR operator training drums and one item 

related to RTR and VE operator written training records. EPA brought these minor issues to the 

attention of INL-CCP personnel and management during the inspection. There are no open issues 

as a result of this continued compliance inspection. 

In November 2012, DOE, DOE contractor staff and EPA and EPA contractor staff discussed 

DOE’s TRU site cleanup goals through 2016 and ways to improve EPA’s evaluation and 

decision process to support DOE sites’ state-mandated cleanup needs. As a result of this 

discussion, EPA finalized a streamlined evaluation and decision process that includes an EPA 

annual continued compliance inspection at each active, EPA-approved TRU waste site. The 

annual inspections will cover the common elements of waste characterization processes that are 

not expected to significantly vary on a waste stream or T1 basis. Examples of the common 

characterization elements are personnel training, procedures and equipment capabilities. EPA 

will evaluate these elements during T1 change evaluations or in conjunction with the quarterly 

T2 change reports as necessary to ensure that EPA’s waste characterization approvals reflect any 

significant changes made to DOE’s waste characterization program. 

This streamlined approach allows EPA to consider the results of continued compliance 

inspections when setting the scope and evaluating site-specific T1 changes. The results of this 

continued compliance inspection will support EPA’s evaluations of INL-CCP’s T1 change 

requests in the coming year (i.e., May 2013–April 2014). EPA will focus the T1 evaluations on 

those items critical to a specific approval (e.g., waste-stream-specific AK records) and will avoid 

revisiting any of the elements discussed in this report until the next continued compliance 

investigation unless otherwise deemed necessary. 
A-1 

ATTACHMENT A.1: APPROVAL SUMMARY FOR INL-CCP CONTACT-HANDLED 

WASTE CHARACTERIZATION PROGRAM 

Approved Activity EPA Inspection Number, 

Approval Dates EPA Docket Number 

INL-CCP CH Baseline Approval EPA-INL-CCP-05.05-8, 

November 1, 2005 A-98-49, II-A4-59 

T1 Change – Approval of the HENC November 16, 2005 A-98-49; II-A4-60 

T1 Change – Approval of Visual Examination as a 

Quality Control Check for Real-time Radiography November 16, 2005 A-98-49, II-A4-61 

T1 Change – Approval of Pit 4 and Pit 6 (ARP-I and 

ARP-II) Waste (plus Addendum) 

August 3, 2006 

(December 5, 2006) 

A-98-49, II-A4-67 

(A-98-49, II-A4-71) 

T1 Change – Approval of the SuperHENC February 28, 2007 A-98-49, II-A4-86 

Unannounced Continued Compliance Inspection November 26, 2007 A-98-49, II-A4-94 

T1 Change – Approval of Multi-Curve Efficiency 

Calibration for the WAGS October 7, 2008 A-98-49, II-A4-107 

T1 Change – Approval of Visual Examination by 

Review of Waste Packaging Audio/Visual 

Recordings 

March 4, 2009 A-98-49, II-A4-110 

Continued Compliance Inspection March 25, 2009 A-98-49, II-A4-112 

T1 Change – Approval of Recalibration of the HENC September 22, 2009 A-98-49, II-A4-119 

Continued Compliance Inspection March 16, 2011 A-98-49, II-A4-142 

T1 Change – Approval of Supplemental Calibration for 

the WAGS to Allow Filters June 23, 2011 A-98-49, II-A4-150 

Unannounced Inspection – Waste Stream ID-NRD.1 January 4, 2012 A-98-49, II-A4-157 

T1 Change – Approval of Recalibration of the SGRS February 26, 2013 A-98-49, II-A4-172 

 
A-2 

ATTACHMENT A.2: APPROVAL SUMMARY FOR INL-CCP REMOTE-HANDLED 

WASTE CHARACTERIZATION PROGRAM 

Approved Activity EPA Inspection Number, 

Approval Dates EPA Docket Number 

INL-CCP RH Baseline Approval EPA-INL-CCP-RH-6.06-8, 

January 12, 2007 A-98-49; II-A4-72 

T1 Change – Approval of WIPP Waste Information 

System January 17, 2007 A-98-49; II-A4-74 

T1 Change – Approval of Visual Examination January 25, 2007 A-98-49; II-A4-75 

T1 Change – Approval of Real-Time Radiography February 12, 2007 A-98-49; II-A4-80 

T1 Change – Approval of K Cell Wastes January 1, 2008 A-98-49; II-A4-97 

T1 Change – Approval of High-Range Gamma Probe 

for DTC April 11, 2008 A-98-49; II-A4-98 

T1 Change – Approval of Visual Examination 

Technique September 22, 2009 A-98-49; II-A4-118 

T1 Change – Addition of Twelve Containers to Waste 

Stream ID-ANLE-S5000 and Addition of Waste 

Stream ID-HFEF-S5400-RH 

February 1, 2010 A-98-49; II-A4-122 

T1 Change – Approval of Waste Stream 

ID-MFC-S5400-RH June 8, 2010 A-98-49; II-A4-126 

T1 Change – Approval of Waste Stream 

ID-INTEC-S5400-RH August 17, 2010 A-98-49; II-A4-130 

T1 Change – Addition of Lot 1B to Waste Stream 

ID-HFEF-S5400-RH August 23, 2010 A-98-49; II-A4-131 

T1 Change – Approval of Waste Stream 

IN-ID-NRF-153 November 1, 2010 A-98-49; II-A4-135 

T1 Change – Approval of Waste Stream 

ID-RTC-S3000 November 1, 2010 A-98-49; II-A4-137 

Continued Compliance Inspection March 16, 2011 A-98-49; II-A4-142 

T1 Change – Addition of Lot 4A to Waste Stream 

ID-HFEF-S5400-RH March 23, 2011 A-98-49; II-A4-145 

T1 Change – Approval of Waste Stream 

IN-ID-NRF-SPC March 12, 2012 A-98-49; II-A4-159 

T1 Change – Addition of Lot 2 to Waste Stream 

ID-ANLE-S5000 July 25, 2012 A-98-49; II-A4-163 
B-1 

ATTACHMENT B: LIST OF DOCUMENTS REVIEWED FOR THIS INSPECTION 

CH AK

Common to all three CH waste streams: 

AKE WCPIP Acknowledgements, May 7, 2013 

CCP-QP-002, CCP Training and Qualification Plan, Revision 34, January 30, 2013 

CCP-QP-005, CCP TRU Nonconforming Item Reporting and Control, Revision 20, April 26, 

2011 

CCP-TP-002, CCP Reconciliation of DQOs and Reporting Characterization Data, Revision 25, 

February 11, 2013 

CCP-TP-005, CCP Acceptable Knowledge Documentation, Revision 24, November 28, 2011 

Lists of fully characterized containers for Waste Streams ID-RF-S5300-A, ID-RF-S3114 and IDSDA-SOIL, provided April 26, 2013 

Qualification card for Carrie Johnson, June 16, 2011 

Qualification card for Kevin Peters, June 16, 2011 

Qualification card for Scott Smith, June 22, 2011 

ID-RF-S5300-A 

C039, Internal Correspondence from J.K. Paynter to B.C. Barrett, WCP8-20, March 23, 1989 

C501, Record of Communication, Subject: Fibre-Pak Containers, January 28, 2005 

CCP-AK-INL-004, Central Characterization Project Acceptable Knowledge Summary Report 

for Rocky Flats Combustibles and Plastic Stored at the Idaho National Laboratory, Waste 

Stream: ID-RF-S5300-A, Revision 2, November 16, 2006 

CCP-TP-002, Revision 24, CCP Reconciliation of DQOs and Reporting Characterization Data, 

Attachment 2 – CCP Waste Stream Profile Form (Example), ID-RF-S5300-A, Revision 0, April 

18, 2006 

CCP-TP-005, Revision 15, CCP Acceptable Knowledge Documentation, Attachment 7 – 

Radionuclides, ID-RF-S5300-A, May 16, 2005 

CCP-TP-005, Revision 17, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, ID-RF-S5300-A, June 20, 2006 

CCP-TP-005, Revision 18, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, ID-RF-S5300-A, January 

19, 2007 
B-2 

CCP-TP-005, Revision 18, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, ID-RF-S5300-A, March 14, 2007 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, ID-RF-S5300-A, May 9, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, ID-RF-S5300-A, various dates 

CCP-TP-005, various revisions, CCP Acceptable Knowledge Documentation, Attachment 10 – 

Acceptable Knowledge Re-evaluation Checklist, ID-RF-S5300-A, various dates 

CCP-TP-005, various revisions, CCP Acceptable Knowledge Documentation, Attachment 8 – 

Waste Containers List, ID-RF-S5300-A, various dates

CCP-TP-005, various revisions, CCP Acceptable Knowledge Documentation, Attachment 11 – 

Acceptable Knowledge Source Document Discrepancy Resolution –Example Form, ID-RFS5300-A, various dates 

D010, Discrepancy Resolution, Incorrect Waste Matrix Code, Jeff Harrison, Revision 1, 

November 29, 2005 

D011, Acceptable Knowledge Source Document Discrepancy Resolution (Drums Containing 

Tile Material), Jeff Harrison, Revision 0, November 8, 2006 

D020, Discrepancy Resolution, High Calculated Inorganic Volume Percentages, Scott Smith, 

Revision 0, December 19, 2008 

Inter-Office Correspondence from B.J. Broomfield to CCP Records Custodian, Submission of 

Change Notice #2 for Waste Stream Profile Form ID-RF-S5300-A, May 17, 2007 

Inter-Office Correspondence from J.A. Vernon to B.J. Broomfield, Acceptable Knowledge 

Accuracy Report: Idaho National Laboratory Waste Stream Number ID-RF-S5300-A, Lots 1–

134, May 10, 2010 

Inter-Office Correspondence from J.A. Vernon to W.F. Verlanic, Acceptable Knowledge 

Accuracy Report: Idaho National Laboratory Waste Stream Number ID-RF-S5300-A, Rocky 

Flats Environmental Technical Site Combustibles and Plastics Stored at Idaho National 

Laboratory Lot 135, Cumulative for Lots 1 - 135, May 26, 2011 

Inter-Office Correspondence from J.A. Vernon to W.F. Verlanic, Acceptable Knowledge 

Accuracy Report: Idaho National Laboratory Waste Stream Number ID-RF-S5300-A, 

Combustible and Plastic Waste Items Assigned to Item Description Codes (IDC) 330, 336 and 

337, Lot 136, Cumulative for Lots 1 - 136, May 31, 2012 

Inter-Office Correspondence from J.A. Vernon to W.F. Verlanic, Acceptable Knowledge 

Accuracy Report: Idaho National Laboratory Waste Stream Number ID-RF-S5300-A, 

Combustible and Plastic Waste Items Assigned to Item Description Codes (IDC) 330, 336 and 

337, Lot 137, Cumulative for Lots 1 - 137, April 29, 2013 
B-3 

Inter-Office Correspondence from R.P. Kantrowitz to CCP Records Custodian, Submission of 

Change Notice #1 for Waste Stream Profile Form ID-RF-S5300-A, November 15, 2006 

Memorandum from Jeff Harrison to CCP Records, Evaluation of the Radiological 

Characterization of Rocky Flats Combustibles and Plastic Wastes Stored at the Idaho National 

Laboratory, Waste Stream ID-RF-S5300-A, CCP-AK-INL-004 NDA Memo, May 13, 2005 

P001, TRU Waste Compliance Program for WIPP-WAC (U), WO-4500-H, 1989 

P004, Rocky Flats Plant Waste Management Site Plan, December 1987 

P024, Content Code Assessments for INEL Contact-Handled Stored Transuranic Wastes, WMF1-82-021, October 1, 1982 

P052, Backlog Waste Reassessment Baseline Book, Waste Inventory and Documentation Rocky 

Mountain Remediation Services, L.L.C, WF4, WF5, WF6, WF17, WF19, WF47, WF52, 

Revision B, January 4, 1995 

P053, (Tasks 3&4 Final Draft Report) Reconstruction of Historical Rocky Flats Operations and 

Identification of Release Points, August 1992 

P069, Nuclear Materials Control Elements printout, SAN Database Report, 6016-01, June 1, 

1984 

P161, Project Task 5, Draft Report, Estimating Historical Emissions from Rocky Flats, 

Chemrisk, November 1992 

U082, EG&G Rocky Flats Plant Radionuclide and Hazardous Constituent Reportable Quantity 

Determination Guide, 1-10000-RQ, December 15, 1992 

ID-RF-S3114 

C184, Interview Record of Al Morgan by Jeff Harrison, March 19, 1997 

CCP-AK-INL-005, Central Characterization Program Acceptable Knowledge Summary Report 

for Rocky Flats Immobilized Organic Liquids Stored at the Idaho National Laboratory, Waste 

Streams: ID-RF-S3114 and ID-RF-S3150-A, Revision 8, February 28, 2013 

CCP-QP-005, Revision 20, CCP TRU Nonconforming Item Reporting and Control, Attachment 

1 – CCP Nonconformance Report (NCR), NCR-INL-2862-11, Revision 0, origin date June 7, 

2011, closure date January 5, 2012 

CCP-QP-005, Revision 22, CCP TRU Nonconforming Item Reporting and Control, Attachment 

1 – CCP Nonconformance Report (NCR), NCR-INL-1759-12, Revision 0, origin date November 

27, 2012, closure date December 12, 2012 

CCP-TP-002, Revision 15, CCP Reconciliation of DQOs and Reporting Characterization Data, 

CCP Waste Stream Profile Form, ID-RF-S3114, Revision 0, January 24, 2006 

CCP-TP-002, Revision 25, CCP Reconciliation of DQOs and Reporting Characterization Data, 

Attachment 2 – CCP Waste Stream Profile Form, ID-RF-S3114, Revision 1, February 26, 2013 
B-4 

CCP-TP-005, Revision 15, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, ID-RF-S3114, May 17, 2006 

CCP-TP-005, Revision 18, CCP Acceptable Knowledge Documentation, Attachment 7 – 

Radionuclides, ID-RF-S3114, February 19, 2007 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, ID-RF-S3114, February 27, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, ID-RF-S3114, February 27, 2013, 

and May 7, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, ID-RF-S3114, February 21, 

2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, ID-RF-S3114, various dates 

CCP-TP-005, various revisions, CCP Acceptable Knowledge Documentation, Attachment 8 – 

Waste Containers List, ID-RF-S3114, various dates 

CCP-TP-005, various revisions, CCP Acceptable Knowledge Documentation, Attachment 10 – 

Acceptable Knowledge Re-evaluation Checklist, ID-RF-S3114, various dates 

CCP-TP-005, various revisions, CCP Acceptable Knowledge Documentation, Attachment 11 – 

Acceptable Knowledge Source Document Discrepancy Resolution –Example Form, ID-RFS3114, various dates 

D023, Acceptable Knowledge Source Document Discrepancy Resolution (Graphite in Waste), 

Scott Smith, D023, Revision 0, February 5, 2013 

Inter-Office Correspondence from J.A. Vernon to B.J. Broomfield, Acceptable Knowledge 

Accuracy Report: Idaho National Laboratory Waste Stream Number ID-RF-S3114, Lots 1–54, 

May 21, 2010 

Inter-Office Correspondence from J.A. Vernon to W.F. Verlanic, Acceptable Knowledge 

Accuracy Report: Idaho National Laboratory Waste Stream Number ID-RF-S3114, Organic 

Setups, Lots 51 through 59, Cumulative for Lots 1 - 59, May 27, 2011 

Inter-Office Correspondence from J.A. Vernon to W.F. Verlanic, Acceptable Knowledge 

Accuracy Report: Idaho National Laboratory Waste Stream Number ID-RF-S3114, Organic 

Liquids that were Transferred to Building 774, Lots 60 - 81, Cumulative for Lots 1 - 81, May 31, 

2012 

Inter-Office Correspondence from J.A. Vernon to W.F. Verlanic, Acceptable Knowledge 

Accuracy Report: Idaho National Laboratory Waste Stream Number ID-RF-S3114, Organic 

Liquids that were Transferred to Building 774, Lots 82 - 100, Cumulative for Lots 1 - 100, May 

2, 2013 
B-5 

Inter-Office Correspondence from R.P. Kantrowitz to CCP Records Custodian, Submission of 

Change Notice #1 for Waste Stream Profile Form ID-RF-S3114, January 10, 2008 

Memorandum from Scott Smith to CCP Records, Addition of Containers to Waste Stream IDRF-S3114, June 11, 2012 

Memorandum from Scott Smith to CCP Records, Evaluation of the Radiological 

Characterization of Rocky Flats Immobilized Organic Liquid Wastes Stored at the Idaho 

National Laboratory, Waste Stream ID-RF-S3114: Organic Setups and ID-RF-S3150-A: 

Solidified Organics, CCP-AK-INL-005 NDA Memo, Revision 1, February 8, 2007 

P002, Organic and Sludge Immobilization System, RFP-4095, July 27, 1987 

P024, Content Code Assessments for INEL Contact-Handled Stored Transuranic Wastes, WMF1-82-021, October 1, 1982 

P052, Backlog Waste Reassessment Baseline Book, Waste Inventory and Documentation Rocky 

Mountain Remediation Services, L.L.C, WF4, WF5, WF6, WF17, WF19, WF47, WF52, 

Revision B, January 4, 1995 

P053, (Tasks 3&4 Final Draft Report) Reconstruction of Historical Rocky Flats Operations and 

Identification of Release Points, August 1992 

P507, Acceptable Knowledge Document for INEEL Stored Transuranic Waste – Rocky Flats 

Plant Waste, INEL-96/0280, Revision 3, February 28, 2003 

U505, Rocky Flats Prefix History Timeline 

ID-SDA-SOIL

AK Tracking Spreadsheet, ID-SDA-SOIL, provided April 26, 2013 

ANL-W-P003, Estimated Radiological Inventory Sent from the Argonne National LaboratoryWest to the Subsurface Disposal Area from 1952 through 1993, Michael L. Carboneau and 

James A. Vail, INEEL/EXT-02-01385, Revision 1, November 2005 

CCP-TP-005, Revision 18, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, ID-SDA-SOIL, June 19, 

2009 

CCP-TP-005, Revision 21, CCP Acceptable Knowledge Documentation, Attachment 10 – 

Acceptable Knowledge Re-evaluation Checklist, ID-SDA-SOIL, March 17, 2011 

CCP-TP-005, Revision 23, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, ID-SDA-SOIL, November 9, 2011 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, ID-SDA-SOIL, June 5, 2012 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, ID-SDA-SOIL, January 11, 2013 
B-6 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 7 – 

Radionuclides, ID-SDA-SOIL, November 30, 2011 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, ID-SDA-SOIL, various dates 

ID-C109, Record of Communication, Interview with Abraham Romo, re: Accelerated Retrieval 

Project (ARP) Drum Packaging Station (DPS) and Visual Examination (VE) Operations, Scott 

Smith and Jeff Harrison, June 2, 2008 

ID-P118, ORAU Team Dose Reconstruction Project for NIOSH, Idaho National Engineering 

and Environmental Laboratory- Site Description, Norman D. Rohrig, Oak Ridge Associated 

Universities, Dade Moeller & Associates and MJW Corporation, ORAUT-TKBS-0007-2, 

Revision 2, July 29, 2005 

ID-P275, Engineering Design File, Waste Inventory Estimate for the Accelerated Retrieval 

Project III, Brent N. Burton, EDF-7884, Revision 0, April 11, 2007 

ID-P421, Excavation Plan for the Accelerated Retrieval Project (WMF-1618)- Pit 4 Retrieval 

Area (ARP VI), Idaho Cleanup Project, EDF-9873, Revision 0, December 21, 2010 

ID-U349, Non-Rocky Flats Shipping Records ARP-VI (P04P03), August 26, 1964 to September 

17, 1965, not inclusive 

Inter-Office Correspondence from J.A. Vernon to W.F. Verlanic, Acceptable Knowledge 

Accuracy Report: Idaho National Laboratory Waste Stream Number ID-SDA-SOIL, Interstitial 

Soil from the Subsurface Disposal Area, Lots 38 - 57, Cumulative for Lots 1 - 57, May 26, 2011 

Inter-Office Correspondence from J.A. Vernon to W.F. Verlanic, Acceptable Knowledge 

Accuracy Report: Idaho National Laboratory Waste Stream Number ID-SDA-SOIL, Interstitial 

Soil from the Subsurface Disposal Area, Lots 58 - 73, Cumulative for Lots 1 - 73, June 1, 2012 

Inter-Office Correspondence from J.A. Vernon to W.F. Verlanic, Acceptable Knowledge 

Accuracy Report: Idaho National Laboratory Waste Stream Number ID-SDA-SOIL, Interstitial 

Soil from the Subsurface Disposal Area, Lots 74 - 76, Cumulative for Lots 1 - 76, April 29, 2013 

Inter-Office Correspondence from M.F. Ramirez to CCP Records Custodian, Transmittal of 

Idaho National Laboratory Change Notice for Waste Stream #ID-SDA-SOIL, Revision 1, June 

22, 2011 

Memorandum from Carrie Johnson to CCP Records, Evaluation of the Radiological 

Characterization of Waste Streams ID-SDA-SLUDGE, IDA-SDA-SOIL and ID-SDA-DEBRIS, 

CCP-AK-INL-001 NDA Memo, Revision 7, November 2, 2011 

RF-C416, Record of Communication, Interview with Ed Vejvoda, Waste Management Practices 

at Rocky Flats, K. Peters, J. Harrison and C. Johnson, September 27, 2004 

RF-U1313, Rocky Flats shipping records for ARP-VII (P10P03), Lisa Frost, E. Ryan, et al, July 

30, 1968 to October 30, 1968, not inclusive 
B-7 

RF-U1315, Rocky Flats Shipping Records for ARP-VI (P04P03) in the RWMC SDA, March 7, 

1964 to March 6, 1965, not inclusive 

RH AK

ID-ANLE-S5000 

Add Container Memorandum from Kevin Peters, CCP AKE to Hillari Neeley, CCP SPM, 

Addition of 7 containers to Waste Stream AERHDM [ID-ANLE-S5000], April 27, 2010 

Add Container Memorandum from Kevin Peters, CCP AKE to Hillari Neeley, CCP SPM, 

Addition of 2 Containers to Waste Stream AERHDM [ID-ANLE-S5000], April 28, 2010 

Add Container Memorandum from Kevin Peters, CCP AKE to Hillari Neeley, CCP SPM, 

Addition of 1 Container to Waste Stream AERHDM [ID-ANLE-S5000], April 29, 2010 

Add Container Memorandum from Kevin Peters, CCP AKE to Irene Quintana, CCP SPM, 

Addition of 12 Containers to Waste Stream ID-ANLE-S5000, June 24, 2009 

Add Container Memorandum, from Steve Schafer, CCP AKE to Larry Porter, CCP SPM, From: 

Steve Schafer, CCP AKE, RE: Addition of 56 Containers to Waste Stream ID-ANLE-S5000, 

November 14, 2007 

BDR No. INLRHDTC12012, October 15, 2012 

BDR No. INLRHDTC12013, October 11, 2012 

BDR No. INLRHRTR12014, October 9, 2012 

BDR No. INLRHRTR12015, October 19, 2012 

C001, Fax to Larry Neimark re: Defense versus Non-Defense Waste, January 21, 1997 

C036, Letter to Sheildon Meyers, Deputy Assistant Secretary for Nuclear Waste Management re: 

Disposition of TRU from LWR Program: Documentation of Agreements Reached in August 15, 

1980, Meeting, September 9, 1980 

C066, Record of Communication with Bill Kettman and Dennis Donahue, AGHCF re: AGHCF 

Operations and Waste Packaging, August 7, 2001 

C1002, E-Mail Correspondence, Re: Work Performed in the M Cells of the Bldg. 200 M-Wing, 

March 18, 2008 

C1031, K Peters, Summary of AK Research for 12 Drums Generated in the Building 200 M 

Wing to be Included in Waste Stream ID-ANLE-S5000, July 10, 2009 

C125, Letter to K.M. Tomko; Re: Near Cell Filter Hazardous Evaluation, June 6, 1990 

C332, Memorandum to CCP Central Records: Assessment of Waste Material Parameters 

(WMPs) for Waste Stream ID-ANLE-S5000, January 6, 2006 
B-8 

C347, Evaluation of Combustible versus Noncombustible Waste Drums in Waste Stream IDANLE-S5000, June 29, 2006 

C348, Evaluation of Generator Reported Radionuclides for Waste Stream ID-ANLE-S5000, June 

30, 2006 

C350, Evaluation for Radiological Waste Stream Delineation for Waste Stream ID-ANLES5000, September 1, 2006 

C3660, Memorandum from Scott Smith to CCP Records, Evaluation of 51 ANLE-E High 

Gamma TRU Waste Containers Stored at the MFC Radioactive Scrap and Waste Facility to be 

added to Waste Stream ID-ANLE-S5000, Revision 1 May 2, 2012 

C380, Record of Communication – Interview with Bill Kettman, re: Extension of AGHCF 

Operations in Building 200 K-1 and K-2 Cells and 10-gallon Waste Cans, July 16, 2007 

C381, Results of Document Review Relating to the AK Available for RH TRU Waste 

Containers Generated in the Building 200 K-Cells at ANLE, K Peters, October 23, 2007 

CCP-AK-INL-500, Central Characterization Program Acceptable Knowledge Summary Report 

For Remote-Handled Transuranic Debris Waste from Argonne National Laboratory-East Stored 

at the Idaho National Laboratory, Waste Stream: ID-ANLE-S5000, Revision 11, November 20, 

2012 

CCP-AK-INL-501, Central Characterization Program Remote-Handled Transuranic Radiological 

Characterization Technical Report for Remote-Handled Transuranic Debris Waste from Idaho 

National Laboratory, Revision 6, November 8, 2012 

CCP-AK-INL-502, Central Characterization Project RH TRU Waste Certification Plan for 40 

CFR Part 194 Compliance for INL RH Waste Stream: ID-ANLE-S5000, Revision 6, August 1, 

2012 

CCP-TP-005, Revision 18, CCP Acceptable Knowledge Documentation, Attachment 10 – 

Acceptable Knowledge Re-evaluation Checklist, Waste Stream ID-ANLE-S5000, May 7, 2007 

CCP-TP-005, Revision 23, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, ID-ANLE-S5000, August 

29, 2011 with associated WMP analysis memorandum 

CCP-TP-005, Revision 23, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, Waste Stream ID-ANLE-S5000, November 16, 2006 

CCP-TP-005, Revision 23, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, Waste Stream ID-ANLE-S5000, August 29, 2011 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, ID-ANLE-S5000, November 26, 2012 
B-9 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, ID-ANLE-S500, November 26, 

2012 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, ID-ANLE-S5000, Heterogeneous Debris from AGHCF Operations, April 30 

2012 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, ID-ANLE-S5000, Heterogeneous Debris from AGHCF Operations, August 29, 

2012 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, ID-ANLE-S5000, Lot 32, October 

24, 2012 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, ID-ANLE-S5000, Lot 36, February 

13, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, ID-ANLE-S5000, Lot 36, dated 

February 21, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 14 – CCP 

Acceptable Knowledge Accuracy Report – Example Form, ID-ANLE-S5000, Lots 1-36, April 

29, 2013, Revised May 28, 2013 

DR014, Discrepancy Report for the RCRA Assignment of EPA HWNS to Waste Stream IDANLE-S5000, November 16, 2006 

DR016, Unsealed 1-gallon Waste Can Discrepancy Report, August 14, 2007 

DR017, Discrepancy Involving Free Liquids in Waste, May 7, 2007 

DR018, Discrepancy Resolution Regarding: K Cell Waste Packaging, October 24, 2007 

DR019, Discrepancy Resolution Re: Sealed Waste Cans, September 20, 2007 

DR020, Discrepancy Resolution Re: Aerosol Cans, September 20, 2007 

DR021, Discrepancy Resolution for 3-Gallon Cans, October 23, 2007 

Inter-Office Correspondence from L.M. Nelson to NTP Records Custodian GSA-212, 

Transmittal of Characterization Reconciliation Report, CRR-ID-ANLE-S5000-0036 for Remote 

Handled Lot 36 ID-ANLE-S5000 at the Idaho National Laboratory, February 21, 2013 

Inter-Office Correspondence from L.M. Nelson to NTP Records Custodian GSA-212, 

Transmittal of Characterization Reconciliation Report, CRR-ID-ANLE-S5000-0032, for Remote 

Handled Lot 32, at the Idaho National Laboratory, October 24, 2012 
B-10 

Inter-Office Correspondence from L.M. Nelson to NTP Records Custodian GSA-212, 

Transmittal of Characterization Information Summary for Remote-Handled Lot 32, ID-ANLES5000, at the Idaho National Laboratory, October 24, 2012 

M00l, Smith, Scott, Evaluation of Additional Containers Added to Waste Stream ID-ANLES5000, Evaluation of Drums from Repack of ANL-E High Gamma TRU Waste and Containers 

at INL in Waste Stream ID-ANLE-S5000 and Evaluation of Drums From Repack of ANL-E 

High Gamma TRU Waste Containers at INL in Waste Stream ID-ANLE-S5000, April 22, 2013, 

and April 16, 2012 

P001, AGHCF Operations Manual, IPS-2-00-00, Revision 2, September 10, 1990 

P002, Central Characterization Project Acceptable Knowledge Summary Report for Argonne 

National Laboratory-East Contact-Handled TRU Waste Facility Maintenance and Laboratory 

Operations, CCP-AK-ANLE-001, Revision 11, December 31, 2003 

U001, AGHCF Position Statement Regarding Defense versus Non-Defense TRU Waste, April 7, 

2000 

U013, Waste Stream Fissile Content, March 23, 1990 

U015, Data from Logbooks for RH TRU Drums 798 to 809, 1995 

U017, Data from Logbooks for RH TRU Drums 778 to 797, Book 8, 1994 

U018, Data from Logbooks for RH TRU Drums 748 to 777, Book 7, 1993 

U1003, Argonne Special Material Receipt and Transfer Documentation by A/G Number (A/G 1-

535), 1967-1997 

U343, RTR Quick Scan Data for 6 K-Cell Drums 

U3607, Excel Spreadsheet: Information for 108 MFC RH-TRU Liners 

U3900, Collection of Retrievable Storage Canister Data, Irradiated High-Level Gamma 

Transuranic Scrap Material Forms (SPM-50), Argonne National Laboratory – East, March 6, 

1975, through November 1, 1984 

U3901, Collection of Handwritten Retrievable Storage Canister Data Irradiated High-Level 

Gamma Transuranic Scrap Material Sheets and Associated Paperwork, February 6, 1975, 

through November 18, 1991 

Waste Stream Profile Form, Waste Stream ID-ANLE-S5000, with Characterization Information 

Summary and Summation of Aspects, January 12, 2007 

IN-ID-BTO-030 

AK RH Container Tracking Spreadsheet, provided May 7, 2013 

C127, Letter to Manager Pittsburgh Naval Reactors Office, Re: Shipment of Special Nuclear 

Materials: PZA-CZC-3, November 14, 1987 
B-11 

C206, Letter to S.D. Harkness, Re: Request for Material Description and History of Thirteen 

Sludge Containers, March 17, 1989 

C207, Letter to ANL, Re: Shipping Information, Westinghouse Electric Corporation, BAPL, 

December 12, 1988 

C210, Letter to Manager, Pittsburgh Naval Reactors Office, Re: Advanced Notification: PZACZC-4, January 29, 1988 

CCP-AK-INL-590, Central Characterization Project Acceptable Knowledge Summary Report 

For Bettis Laboratory Remote-Handled Transuranic Waste Stored at Idaho National Laboratory 

Waste Stream IN-ID-BTO-030, Revision 2, April 4, 2012 

CCP-AK-INL-592, Central Characterization Project RH TRU Waste Certification Plan for 40 

CFR Part 194 Compliance for Bettis Laboratory Remote-Handled Transuranic Debris Waste 

Stored at the Idaho National Laboratory, Waste Stream: IN-ID-BTO-030, Revision 1, August 16, 

2012 

CCP-AK-INL-595A, Central Characterization Program Radiological Sampling and Analysis 

Plan For Bettis Laboratory Remote-Handled Transuranic Waste Stored at Idaho National 

Laboratory, Waste Stream IN-ID-BTO-030, Revision 1, February 6, 2013 

CCP-TP-005, Revision 22, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, IN-ID-BTO-030, May 19, 

2011, and related Waste Material Parameter Memorandum dated May 25, 2011 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, IN-ID-BTO-030, January 4, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, IN-ID-BTO-030, January 4, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, IN-ID-BTO-030, May 19, 2012 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 15 – CCP 

TRU Waste Correlation and Surrogate Summary Form, Bettis Laboratorv / Idaho National 

Laboratorv, Waste Stream IN-ID-BTO-030, Waste Used to Correlate: BT-T001, June 13, 2012 

DR005, Attachment 11 Acceptable Knowledge Document Discrepancy Resolution (Hazardous 

Waste Codes), December 11, 2012 

DR006, Attachment 11 Acceptable Knowledge Document Discrepancy Resolution (Containers 

Used for Solidification), December 21, 2010 

P100, the United States Naval Nuclear Propulsion Program, July 21, 1998 

P102, Cultural Resource Assessment: Bettis Atomic Power Laboratory, Allegheny County, 

Pennsylvania, May 2002 
B-12 

P201, Memo to M.J. Holzemer with waste profile attachment Re: TRU Waste Profile Sheet for 

Bettis Content Code 30 Approval, JDW-23-88, April 6, 1988 

U200, ANL-W Radioactive Waste Disposal Request Certification Statement (Summary), AW88-

025, March 8, 2009 

U201, News Release: Bettis Atomic Power Laboratory Celebrates 50th Anniversary, BET-3-U 

U212, Operation Record of Met Cell Equivalent Gram Loss, March 3, 1982, through November 

11, 1986 

U221, Solidification Procedures, April 14, 1987, through July 13, 1987 

U236, COW Logbook #2, Waste Disposal Log, January 1973 through November 1979 

U256, Bettis Experimental Facilities, Bettis Hot Laboratory, November 1978 

U275, Radiological Data from INL-W Shipping Documents (U200), June 18, 2010 

U276, Material Weights and Volume Percentages from P201, June 22, 2010 

U305, Certified Waste Data Base System Transuranic Waste Data Base Input Form, June 10, 

1987 

NDA

BII-5221-CVR-001, Pajarito Scientific Corporation, Calibration and Validation Report: 

SuperHENC Mobile Assay System, March 18, 2009 

CCP-Idaho National Laboratory List of Qualified Individuals, May 7, 2013, 4 pages, prepared at 

request of EPA Inspectors 

CCP-INL-174, Operator Aid: WAGS Pulser Parameter Data, December 21, 2009 

CCP-INL-244, Operator Aid: SGRS Pulser Parameter Data, August 8, 2012 

CCP-INL-251, Operator Aid: SGRS/WAGS Weekly Performance check drum, November 28, 

2012 

CCP-INL-SGRS-001, SGRS Calibration Confirmation and Verification Report, Revision 2, 

November 14, 2012 

CCP-INL-SGRS-12-003, Calibration Verification of the SGRS System after Detector 

Replacement and Energy Calibration, August 8, 2012 

CCP-INL-SGRS-12-005, Measurement Control Limit Update on the SGRS, October 17, 2012 

CCP-INL-WAGS-001, Revision 1, April 2008 

CCP-INL-WAGS-003, WAGS Calibration, Confirmation and Verification Report, Revision 0, 

May 18, 2011 
B-13 

CCP-INL-WAGS-12-003, Measurement Control Limit Update for 356 keV count rate on the 

WAGS, July 19, 2012 

CCP-INL-WAGS-12-005, Calibration Verification of the WAGS System after replacement of 

DSA 1000 power supply for DET3NB, December 3, 2012 

CCP-SHENC-12-002, INL SuperHENC Calibration Verification, Revision 0, September 12, 

2012 

CCP-SHENC-12-004, Investigation of INL SuperHENC PDP Cycle B12A Bias Criteria Failure 

for the Combustibles Matrix, Revision 0, November 28, 2012 

CCP-TP-010, WAGS and SGRS Calibration Procedure, Revision 4, March 2011 

CCP-TP-019, WAGS Operating Procedure, Revision 6, April 2013 

CCP-TP-109, CCP Data Reviewing, Validating and Reporting Procedure, Revision 9, February 

2013 

CCP-TP-115, SGRS Operating Procedure, Revision 5, April 2013 

CCP-TP-146, CCP SuperHENC Operating Procedure, Revision 8, March 2013 

CCP-TP-148, CCP SuperHENC Data Reviewing, Validating and Reporting Procedure, Revision 

8, January 2013 

CCP-TP-170, CCP SuperHENC Calibartion Procedure, Revision 2, March 2007 

SGRS BDR Nos. INNDAS130001 and INNDAS120034 

SGRS Operational Logbook, May 7, 2013, corresponding to day of EPA inspection and 

sampling of entries

SuperHENC BDR No. INNDAB12005 

SuperHENC Operational Logbook, May 7, 2013, corresponding to day of EPA inspection and 

sampling of entries

Summary of Containers Assayed on SGRS, WAGS and HENC, May 1, 2012 to May 6, 2013, 

prepared for inspection 

WAGS BDR Nos. INNDAW120076 and INNDAW130036 

WAGS Operational Logbook, May 7, 2013, corresponding to day of EPA inspection and 

sampling of entries

DTC

CCP-TP-504, CCP DTC Survey Procedure for RH TRU Waste, Revision 13, September 17, 

2012 
B-14 

DTC Operational Logbook, May 8, 2013, corresponding to day of EPA inspection and sampling 

of entries

NIST Report of Calibration for detector XY022481, October 25, 2002 

RH-DM-INL-002, Operator Aid, Posted in Control Room of DTC, CCP, Revision 17, April 8, 

2013 

RH-DM-INL-003, Operator Aid Posted in Control Room of DTC, CCP, Revision 2, November 

29, 2012 

Source Calibration Certificates and Source Capsule Descriptions of DTC Sources, March 29, 

2007 

NDE

Audio/visual recordings for selected containers from RH RTR BDR Nos. INLRHRTR13001, 

INLRHRTR13003 and INLRHRTR13004 

CCP AK training attendance sheets for VE and RTR operators 

CCP Transuranic Waste Certification Plan, CCP-PO-002, Revision 26, July 14, 2011 

CCP Transuranic Waste Characterization Quality Assurance Project Plan, CCP-PO-001, 

Revision 21, May 31, 2013 

CCP Training and Qualification Plan, CCP-QP-002, Revision 26, January 30, 2013

CCP TRU Nonconforming Item Reporting and Control, CCP-QP-005, Revision 22, September 

27, 2012 

CCP Project Level Data Validation and Verification, CCP-TP-001, Revision 20, September 27, 

2012 

CCP Visual Examination Technique for Idaho National Laboratory (INL) Newly Generated 

TRU Waste Retrieved from Pits, CCP-TP-006, Revision 17, November 1, 2012 

CCP Radiographic Test Drum and Training Container Construction, CCP-TP-028, Revision 7, 

July 13, 2012

CCP Remote-Handled Waste Visual Examination, CCP-TP-500, Revision 11, April 21, 2011 

CCP RH Standard Real-Time Radiography Inspection Procedure, CCP-TP-508, Revision 7, 

April 21, 2011 

CH VE BDR Nos. IN-ARP-VE-002728, IN-ARP-VE-002729, IN-SRP-VE-000120 and IN-SRPVE-000175 

Completed data sheets for container FCO100B-1 

Lists of Qualified Individuals, various dates between June 2011 and April 2013 
B-15 

Nonconformance Report No. NCR-RHINL-0430-13

Qualification records for selected VEEs and VE and RTR operators 

RH RTR BDR Nos. INLRHRTR13001, INLRHRTR13003 and INLRHRTR13004 and 

INLRHRTR13006 

RH VE BDR Nos. INLRHVE11002, INLRHVE11003 and INLRHVE12001 

RTR Measurement Control Report, dated May 8, 2013 

Training drum inventories, container Nos. 17, 21 and 25

VEE appointment letters dated between 2007 and 2011
C-1 

ATTACHMENT C: INSPECTION PERSONNEL 

Personnel Affiliation Area of Expertise/Function Entrance Meeting Interviewed 

Ed Feltcorn U.S. EPA ORIA Inspector-Team Leader  Rajani Joglekar U.S. EPA ORIA Inspector  Connie Walker SC&A, Inc. AK Inspector  Dorothy Gill SC&A, Inc. RTR/VE Inspector  Kira Darlow SC&A, Inc. AK Inspector  Patrick Kelly SC&A, Inc. NDA/DTC Inspector  Rose Gogliotti SC&A, Inc. NDA/DTC Inspector  Ben Roberts DOE  Bill Verlanic CCP/NWP PM  Bret Palmer CWI VE Operator Bruce LaRue DEQ INL OP Environmental Scientist  Chris Davis CWI VE, DTC Operator Chris Heavit DOE Cody Remsburg Site Operations Manager Crary Davis CCP/MCS NDA Lead  David Ams CCP/NWP LANL AK  Doug Pruitt DOE Ed Gulbransen CCP NTP Certification Manager  Greg Smith CCP/NWP VPM Irene Joo CCP/NWP RH Project Manager   Jeff Poole CCP CH, RH VEE Jeri Miles CCP/NWP VPM   Jim Vernon CCP/NWP SPM  Kevin J. Peters CCP AK   Keith Farmer NFM Larry Hutsek CWI WM Operations Director Larry Klingler CCP/NWP QA  Lisa Frost CWI CH Support Lisa Watson CCP/NWP LANL AKE   Marcus A. Pinzel DOE/CBFO  Mark Doherty CTAC/NTP Observer  Mary Carrol NDA Operator Preston Abbott CCP/MCS NDA Lead  
C-2 

Rajir N. Bhau CWI/INL TRU Waste Program  

Roger Vawter CTAC/CBFO Observer  Scott Smith CCP AKE   Sharron Cummins NDA Operator Tammy Hobbes CWI WM Thomas L. Clements, Jr CWI/INL TRU Waste Program   Tom Johnsen CWI CH TRU STR Tyson Christensen CCP/VJT RTR Lead  
D-1 

ATTACHMENT D.1: AK CONTINUED COMPLIANCE INSPECTION CHECKLIST: WASTE STRE

EPA Inspection No.: INL-CC-2013 Waste Stream: ID-RF-S3114 Insp

Technical Elements Objective Evidence/Comments 

AK-1: Do AK, training and nonconformance procedures adequately reflect the requirements of 40 CFR 194 and have they been adequately implemented? 

Yes. Examples of adequate implementation: CCP-QP-002, Revision 34, training and qualification plan: report body Item (6) CCP-QP-005, Revision 20, nonconforming item report: checklist Item (AK-6)-NCRs CCP-TP-002, Revision 25, WSPF package development: checklist Item (AK-5) CCP-TP-005, AK documentation: checklist Items (AK-2), (AK-4), (AK-6)-DRs, (AK-7

AK-2: Is the AK characterization process, including AK assembly, compilation and verification adequate? 

Yes. Completed CCP-TP-005 attachments provide objective evidence of AK assembly, 

a. Attachment 1, Revision 24, Acceptable Knowledge Documentation Checklist: comp

b. Attachment 2, Record of Communication: not used. All interviews took place prior 

005; therefore, those communications are appropriately not documented on CCP-TP

c. Attachment 3s, various revisions, Acceptable Knowledge Source Document Summa

source documents. Most are Revision 24. 

d. Attachment 4, Revision 24, Acceptable Knowledge Information List: revised during 

were written since the last AK update. 

e. Attachment 5, Hazardous Constituents: outside EPA’s purview; not reviewed. 

f. Attachment 6, Revision 24, Waste Form, Waste Material Parameters, Prohibited Ite

It and the associated WMP analysis memorandum support estimates in AKSR and d(AK-4b). 

g. Attachment 7, Revision 18, Radionuclides: complete. Supports estimates given in A

checklist Item (AK-4c). See also discussion in checklist Item (AK-8). 

h. Attachment 8, Revisions 15–23, Waste Containers List: updated periodically as was

storage. Each revision of Attachment 8 is comprehensive for the whole waste stream 

accompanying container lists include only those containers added since the last Atta

revision of Attachment 8, additional containers were added to the waste stream thro

memorandum (dated 6/11/2012) that describes the evaluation of the additional conta

i. Attachment 9, Waste Characterization Data Cross-Reference: reference tool, not a f

j. Attachment 10, various revisions, Acceptable Knowledge Re-evaluation Checklist: 

3/28/2006–2/20/2013. DRs and revisions to AKSR were completed as indicated in A

k. Attachment 11, various revisions, Acceptable Knowledge Source Document Discrep

as appropriate [see checklist Item (AK-6)]. The associated Attachment 3s for the old

created until fall 2012. Attachment 3s for the DR reports created in 2013 were creatreports, but Attachment 4 was not updated to reflect the 2013 DR reports until durin

l. Attachment 12, Example Form and Content Guide for AK Summary Reports: refere

completion; see review of completed AKSR in checklist Item (AK-4). 

m. Attachment 13, Revision 24, CCP Waste Stream Characterization Checklist: compl

Waste Stream Characterization Checklists were also completed for Lots 1–74; howecompleted as forms out of CCP-TP-005. 

n. Attachment 14, Revisions 18, 22 and 24, CCP Acceptable Knowledge Accuracy Re

checklist Item (AK-7). 
D-2 

EPA Inspection No.: INL-CC-2013 Waste Stream: ID-RF-S3114 Insp

Technical Elements Objective Evidence/Comments 

o. Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form: not ap

AK-3: Are waste containers traceable from retrieval through CCP’s EPA-approved characterization 

process? 

Yes. Tracked Container 10082578. AMWTP retrieves container, uses RWMS and TWM

for each retrieved container, and sends historical drum numbers, IDC, and original closu

confirmation of waste stream inclusion. This container added in Attachment 8 memoran

Drum No. IDRF074311957; IDC 003; initial closure date 7/5/1973. “RF0743” indicates (References P024, P052 and U505). RTR BDR: INRTR5110074, 6/27/2011 (Reference containers); NDA BDR: INNDAW110114, 6/28/2011 (Reference list of fully character

AK-4: Does the AK summary report include sufficient information, supported by appropriate source documents, to support the statements below? a. All waste within the waste stream was 

generated from a single process/activity. 

b. All waste within the waste stream is similar in 

material and physical form. 

c. All waste within the waste stream has similar 

radiological properties. 

d. All of the waste in the waste stream is defense 

in origin. 

e. None of the waste in the waste stream is highlevel waste. 

f. None of the waste in the waste stream is spent 

nuclear fuel. 

Yes. CCP-AK-INL-005, Revision 8, contains all required items. 

a. ID-RF-S3114 was produced by organic liquids immobilization process at RFP Grea

(References P024 and P052). Organic liquid waste was transferred by pipeline or in 

buildings at RFP and processed through an extruder with a synthetic calcium silicat

(References P002, P024 and P053). Grease Plant shut down in 1985 and was replac

OASIS waste is not included in ID-RF-S3114 (Reference P507). 

b. ID-RF-S3114 is composed of organic setups: IDC 003.

c. Primary TRU organic liquid generating activities: Pu production (WG Pu and HEU)

parts (site-return Pu with higher 241Am decay product, HEU and tritium). Wastes co

be found in this waste stream (References C184, P052 and P053). 

d. RFP mission was to produce Pu targets for nuclear weapons and to recover Pu from 

(Reference P053). 

e. RFP did not reprocess spent nuclear fuel (Reference P053). 

f. RFP did not handle irradiated fuel elements (Reference P053). 

AK-5: Are the waste stream profile form and related attachments complete and adequate/accurate? Related attachments include: a. Characterization information summary 

b. Summation of aspects 

Yes. WSPF, Revision 0: dated 1/24/2006. WSPF is complete; package includes complecomplete summation of aspects based on the current-at-the-time AKSR (CCP-AK-INL-

Change Notice 1: submitted 1/10/2008 to update generation dates and expected WMPs. WSPF, Revision 1, dated 2/26/2013 to add a new hazardous waste code. Revised WSPF 

complete CIS for Lot 87 containers and complete summation of aspects based on the cu

AK-INL-005, Revision 7). 

AK-6: Are nonconformances and discrepancy resolutions documented appropriately? 

Yes. NCR-INL-2862-11: RTR found unexpected packaging configuration; AK reevalua

NCR-INL-1759-12: VE BDR incorrectly identified WMP for “absorbent mixed with w

D023 written because VE identified graphite in the waste; AK review determined graph

not contain hazardous constituents; drums remain primarily inorganic sludge so drums r

INL-CCP revised the AKSR to include information about graphite. 
D-3 

EPA Inspection No.: INL-CC-2013 Waste Stream: ID-RF-S3114 Insp

Technical Elements Objective Evidence/Comments 

AK-7: Is the AK accuracy report technically adequate? Has it been updated annually? 

Yes. Most recent AK accuracy report completed 5/2/2013: assessed AK accuracy for Lo

cumulative AK accuracy for Lots 1–100. Accuracy report includes a memorandum sumanalysis, lists correlating containers in Lots 82–100 to their BDRs, and CCP-TP-005, R

listing containers from Lots 1–100 that have been evaluated for reassignment. AK accu

INL-CCP completed two AK reevaluation checklists during the reporting period: one ad

waste items in the AKSR; the other updated the hazardous waste numbers to include D0

accuracy for the waste stream as a whole changed from 99.9% to 99.5% during the repoEPA also reviewed AK accuracy reports prepared 5/21/2010, 5/27/2011 and 5/31/2012. inconsistencies in the past reports (e.g., 2 containers inconsistent with AK in 2011, 0 co

plus the 2 existing inconsistent containers in 2013). This appears to be a one-time issue 

report. 

AK-8: Is AK-NDA communication adequately documented? 

Yes. AK-NDA communication documented in CCP-TP-005, Revision 18, Attachment 7

attached NDA memorandum dated 2/8/2007. As stated in checklist Item (AK-4c) above

with high 241Am decay product, HEU and DU. NDA memorandum, Revision 1, only lis

primary radiological contaminants. The NDA memorandum presents relative weight pe

radionuclides in ID-RF-S3114. Memorandum identifies the predominant radionuclides 

weight percent) as 238U (largest expected from DU), 239Pu (largest expected from WG P

expected from WG Pu), 235U (largest expected from HEU), and then 241Am. Estimating 

an ideal way to document the expected radionuclides. 

AK-9: Has notification of applicable T2 changes been 

provided to EPA as required in the INL-CCP CH 

tiering table? 

Yes. EPA tracking began with 4th quarter FY 2009. T2 change notification required for: 

a. AK-NDA memoranda – No revisions post-EPA tracking. 

b. AK accuracy reports (annually, at a minimum) – Produced annually as required; how

notification in 2011. SPM was unaware that this requirement applied to all waste str

c. AK-AK and AK-NDA/NDE DR reports – D018 was revised and D022–D025 writte

received two notifications of D018 in the FY 2011 3rd quarter report and infers that 

and D022. Notification of D023, D024 provided with FY 2013 2nd quarter report as 

is expected with the FY 2013 3rd quarter report. 

d. WSPFs, including updates or additions to waste streams within an approved waste c

notification to EPA in FY 2013 2nd quarter report as expected. 

e. The load management status of approved waste streams – Status has not changed. 
D-4 

ATTACHMENT D.2: AK CONTINUED COMPLIANCE INSPECTION CHECKLIST: WASTE STREA

EPA Inspection No.: INL-CC-2013 Waste Stream: ID-RF-S5300-A Insp

Technical Elements Objective Evidence/Comments 

AK-1: Do AK, training and nonconformance procedures adequately reflect the requirements of 40 CFR 194 and have they been adequately implemented? 

Yes. See Attachment D.1, checklist Item (AK-1). 

AK-2: Is the AK characterization process, including AK assembly, compilation and verification adequate? 

Yes. Completed CCP-TP-005 attachments provide objective evidence of AK assembly, 

a. Attachment 1, Revision 18, Acceptable Knowledge Documentation Checklist: comp

b. Attachment 2, Revision 14, Record of Communication: Completed when appropriat

took place prior to implementation of CCP-TP-005; therefore those communicationdocumented on CCP-TP-005, Attachment 2. 

c. Attachment 3s, various revisions, Acceptable Knowledge Source Document Summa

source documents. Most are Revision 15 from initial AK compilation. The AK sourU082 is dated 6/30/2011 and was completed using Revision 22 of the form. CCP-TPapproved on 6/30/2011, so the summary should have been done or redone using the 

d. Attachment 4, Revision 24, Acceptable Knowledge Information List: revised during 

written since the last AK update. 

e. Attachment 5, Hazardous Constituents: outside EPA’s purview; not reviewed. 

f. Attachment 6, Revision 18, Waste Form, Waste Material Parameters, Prohibited Ite

It and the associated WMP analysis memorandum support estimates in AKSR and d(AK-4b). 

g. Attachment 7, Revision 15, Radionuclides: complete. Supports estimates given in A

checklist Item (AK-4c). See also discussion in checklist Item (AK-8). 

h. Attachment 8, Revisions 15–18, Waste Containers List: Updated periodically as wa

in storage. Each revision of Attachment 8 is comprehensive for the whole waste stre

the accompanying container lists include only those containers added since the last 

8 dated 6/5/2006 was completed using Revision 16 of the form. CCP-TP-005, Revis

6/5/2006, so the Attachment 8 should have been done or redone using the Revision 

i. Attachment 9, Waste Characterization Data Cross-Reference: reference tool, not a f

j. Attachment 10, Revisions 15, 17 and 18, Acceptable Knowledge Re-evaluation Che

dated 5/16/2007–2/11/2008. DRs and revisions to AKSR were completed as indicat

k. Attachment 11, Revisions 15 and 18, Acceptable Knowledge Source Document Dis

completed as appropriate [see checklist Item (AK-6)]. The associated Attachment 3

time, but Attachment 4 was not updated to reflect the most recent DRs until during t

l. Attachment 12, Example Form and Content Guide for AK Summary Reports: refere

completion; see review of completed AKSR in checklist Item (AK-4). 

m. Attachment 13, Revision 24, CCP Waste Stream Characterization Checklist: compl

Waste Stream Characterization Checklists were also completed for Lots 1–135; how

completed as forms out of CCP-TP-005. 

n. Attachment 14, Revisions 18, 22 and 24, CCP Acceptable Knowledge Accuracy Re
D-5 

EPA Inspection No.: INL-CC-2013 Waste Stream: ID-RF-S5300-A Insp

Technical Elements Objective Evidence/Comments 

checklist Item (AK-7). 

o. Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form: not ap

AK-3: Are waste containers traceable from retrieval through CCP’s EPA-approved characterization 

process? 

Yes. Tracked Container 10102536. AMWTP retrieves container, uses RWMS and TWM

for each retrieved container, and sends historical drum numbers, IDC, and original closu

confirmation of waste stream inclusion. This container added in Attachment 8 memoran

Drum No. IDRF000216988; IDC 330; initial closure date 3/4/1974. “RF0002” indicates 771-Pu recovery facility (Reference P052). RTR BDR: INRTR5120005, 8/9/2012 (Ref

characterized containers); NDA BDR: INNDAW120056, 8/16/2012 (Reference list of f

AK-4: Does the AK summary report include sufficient information, supported by appropriate source documents, to support the statements below? a. All waste within the waste stream was 

generated from a single process/activity. 

b. All waste within the waste stream is similar in 

material and physical form. 

c. All waste within the waste stream has similar 

radiological properties. 

d. All of the waste in the waste stream is defense 

in origin. 

e. None of the waste in the waste stream is highlevel waste. 

f. None of the waste in the waste stream is spent 

nuclear fuel. 

Yes. CCP-AK-INL-004, Revision 2, contains all required items. 

a. ID-RF-S5300-A was produced by activities in most RFP buildings and each retrieve

original building. EPA questioned inclusion of all of the waste from distinct generat

stream. INL-CCP explained that all the RFP activities were components within the 

Pu processing included Pu production, Pu recovery, and all the supporting activitiesthere is historical precedent for shipping RFP waste by IDC instead of by building (

b. ID-RF-S5300-A is composed of combustibles and plastic debris waste: IDC 330, dr

combustibles; IDC 337, plastics. RFP managed all three types of waste on a single WCombustible Waste (References P001, P024 and P052).

c. Primary radionuclides expected in the waste stream are WG Pu and 241Am from Pu 

recovery and purification. These activities are also expected to have produced waste 

DU. These processes were carried out over all of RFP; the waste from all RFP build

similar radiological properties (References C039, P053, P069 and P161). 

d. RFP mission was to produce Pu targets for nuclear weapons and to recover Pu from 

(Reference P053). 

e. RFP did not reprocess spent nuclear fuel (Reference P053). 

f. RFP did not handle irradiated fuel elements (Reference P053). 

AK-5: Are the waste stream profile form and related attachments complete and adequate/accurate? Related attachments include: a. Characterization information summary 

b. Summation of aspects 

Yes. WSPF, Revision 0: dated 4/18/2006. WSPF is complete; package includes complecomplete summation of aspects based on the current-at-the-time AKSR (CCP-AK-INL-

Change Notice 1: submitted 11/15/2006 to update generation dates and expected WMPChange Notice 2: submitted 5/17/2007 to update the expected radionuclides. 

AK-6: Are nonconformances and discrepancy resolutions documented appropriately? 

Yes. EPA did not specifically review any NCRs associated with Waste Stream ID-RF-S

D011 written to resolve recurring issue of drums being identified by VE and RTR to cotiles (WMP: other inorganic materials). INL-CCP determined that while each tile-contacombustible or plastic material, the drums would not cause the waste stream as a whole combustible or plastic material. Therefore the drums remain in Waste Stream ID-RF-S5

the AKSR to include information about asbestos tiles. 
D-6 

EPA Inspection No.: INL-CC-2013 Waste Stream: ID-RF-S5300-A Insp

Technical Elements Objective Evidence/Comments 

AK-7: Is the AK accuracy report technically adequate? Has it been updated annually? 

Yes. Most recent AK accuracy report completed 4/29/2013: assessed AK accuracy for L

AK accuracy for Lots 1–137. Accuracy report includes a memorandum summarizing A

correlating containers in Lot 137 to their BDRs, and CCP-TP-005, Revision 24, Attachmfrom Lots 1–137 that have been evaluated for reassignment. AK accuracy for Lot 137 ithe waste stream as a whole is 99.7%. EPA also reviewed AK accuracy reports prepared 5/10/2010, 5/26/2011 and 5/31/2012. 

AK-8: Is AK-NDA communication adequately documented? 

Yes. AK-NDA communication documented in CCP-TP-005, Revision 15, Attachment 7

attached NDA memorandum dated 5/13/2005. As stated in checklist Item (AK-4c) abov

241Am as one of the primary radionuclides in the waste stream. The NDA memorandum 241Am as one of the primary expected radionuclides, instead only explicitly mentioning 

Memo Addendum 1 presents the relative weight percent calculations for radionuclides iaddendum identifies the predominant radionuclides (starting with the highest weight pe

from DU), 239Pu (largest expected from WG Pu), 235U (largest expected from HEU), 240P

from WG Pu), and then 241Am. Estimating by weight percent only is not an ideal way to 

radionuclides. 

AK-9: Has notification of applicable T2 changes been 

provided to EPA as required in the INL-CCP CH 

tiering table? 

Yes. EPA tracking began with 4th quarter FY 2009. T2 change notification required for: 

a. AK-NDA memoranda – Document never revised. 

b. AK accuracy reports (annually, at a minimum) – Produced annually as required; how

notification in 2011. SPM was unaware that this requirement applied to all waste str

c. AK-AK and AK-NDA/NDE DR reports – The most recent DR was written in Nove

tracking T2 notifications. 

d. WSPFs, including updates or additions to waste streams within an approved waste c

never been revised and both change notices were submitted prior to EPA’s T2 track

e. The load management status of approved waste streams – Status has not changed. 
D-7 

ATTACHMENT D.3: AK CONTINUED COMPLIANCE INSPECTION CHECKLIST: WASTE STRE

EPA Inspection No.: INL-CC-2013 Waste Stream: ID-SDA-SOIL Insp

Technical Elements Objective Evidence/Comments 

AK-1: Do AK, training and nonconformance procedures adequately reflect the requirements of 40 CFR 194 and have they been adequately implemented? 

Yes. See Attachment D.1, checklist Item (AK-1). 

AK-2: Is the AK characterization process, including AK assembly, compilation and verification adequate? 

Yes. Completed CCP-TP-005 attachments provide objective evidence of AK assembly, 

a. Attachment 1, Revision 24, Acceptable Knowledge Documentation Checklist: comp

b. Attachment 2, Revisions 13 and 18, Record of Communication: Completed when ap

RF-C416) 

c. Attachment 3s, various revisions, Acceptable Knowledge Source Document Summa

source documents. Most are Revisions 13–24. 

d. Attachment 4, Revision 24, Acceptable Knowledge Information List: last revised 1/

e. Attachment 5, Hazardous Constituents: outside EPA’s purview; not reviewed. 

f. Attachment 6, Revision 18, Waste Form, Waste Material Parameters, Prohibited Ite

Not updated since last EPA review. It and the associated WMP analysis memorandu

and discussed in checklist Item (AK-4b). 

g. Attachment 7, Revision 24, Radionuclides: complete. Supports estimates in AKSR 

(AK-4c). See also discussion in checklist Item (AK-8). 

h. Attachment 8, Revision 23, Waste Containers List: last updated 11/9/2011. Each rev

comprehensive for the whole waste stream as identified to date, but the accompanyi

those containers added since the last Attachment 8. Containers assigned to ID-SDA

to the AK tracking spreadsheet after VE; therefore, Attachment 8 is usually only uprevised. 

i. Attachment 9, Waste Characterization Data Cross-Reference: reference tool, not a f

j. Attachment 10, Revision 21, Acceptable Knowledge Re-evaluation Checklist: last c

considers EPA HWNs. This is the only AK reevaluation completed since EPA’s las

k. Attachment 11, Acceptable Knowledge Source Document Discrepancy Resolution: 

of this waste stream. 

l. Attachment 12, Example Form and Content Guide for AK Summary Reports: refere

completion; see review of completed AKSR in checklist Item (AK-4). 

m. Attachment 13, Revision 24, CCP Waste Stream Characterization Checklist: compl

Waste Stream Characterization Checklists were also completed for Lots 1–69; howecompleted as forms out of CCP-TP-005. 

n. Attachment 14, Revisions 22 and 24, CCP Acceptable Knowledge Accuracy Report

checklist Item (AK-7). 

o. Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form: not ap

AK-3: Are waste containers traceable from retrieval 

Yes. Targeted waste is identified through query of WILD and engineering design files c

(References ID-P421, ID-P426). Containers are created during VE process, then added 

then characterized by NDA. Lists of containers correlating drum numbers to VE and ND
D-8 

EPA Inspection No.: INL-CC-2013 Waste Stream: ID-SDA-SOIL Insp

Technical Elements Objective Evidence/Comments 

through CCP’s EPA-approved characterization 

process? 

emplacement dates as applicable are readily available (References list of fully character

tracking spreadsheet). 

AK-4: Does the AK summary report include sufficient information, supported by appropriate source documents, to support the statements below? a. All waste within the waste stream was 

generated from a single process/activity. 

b. All waste within the waste stream is similar in 

material and physical form. 

c. All waste within the waste stream has similar 

radiological properties. 

d. All of the waste in the waste stream is defense 

in origin. 

e. None of the waste in the waste stream is highlevel waste. 

f. None of the waste in the waste stream is spent 

nuclear fuel. 

Yes. CCP-AK-INL-001, Revision 11, was updated appropriately to include ARP-VI an

a. Targeted waste in ARP-VI and -VII remains RFP-generated waste from the same pr

pits contained within ARP-VI, and -VII received waste from RFP during the same t

approved waste (March 1964–November 1968, compared to May 1964–September wastes have the same origin (References ID-U349, ID-P421, RF-U1313 and RF-U1

accordingly. One new RFP generator building identified on waste disposal forms (B

AKSR (Reference RF-U1313). 

b. ID-SDA-SOIL drums contain less than 50%, by volume, targeted debris or sludge w

interstitial soil from the SDA. Targeted waste in ARP-I–ARP-VII remains limited to Series), RFP Second-Stage Sludge (742-Series), RFP Organic Setups (743-Series), Graphite, and RFP Filters. Expected volumes of each waste type in ARP-VI and -V

ID-P275, RF-U1313 and RF-U1315). Did not result in changes to WMP estimates fWMP estimates for ID-SDA-SOIL are based entirely on existing VE records. WMP 

necessary; however, the AKE indicated that the population on which the current estlarge that the estimates will likely not need further revision. 

c. INL-CCP calculates the expected radionuclides based on AK data (Reference ID-U

these calculations every time additional ARP phases are added, historically adding orevision, as evidenced by comparing Tables 5-2, 5-3 and 5-4 in AKSR, Revisions 9 

that the most prevalent radionuclides by mass are 238U (99.63%), with 235U and 239P

prevalent by mass in almost equal concentrations. 241Pu and 241Am are the most prev

activity. 

d. As previously evaluated, all SDA targeted waste is from RFP, which produced Pu ta

to recover Pu from retired nuclear weapons. EPA also previously determined that tanon-targeted wastes are commingled in the pits due to lack of container integrity. Th

ARP-VI and -VII. 

e. As previously evaluated, ID-SDA-SOIL does not contain spent nuclear fuel because 

buried in Pit 4, it would be segregated and not packaged with the WIPP-bound wast

-VII did not change this situation. 

f. While high-level waste was produced at some of the small waste-contributing gener

W), it was sent to a different facility and not buried in the retrieval area (References 

AK-5: Are the waste stream profile form and related attachments complete and adequate/accurate? Related attachments include: a. Characterization information summary 

b. Summation of aspects 

Yes. WSPF, Revision 1, plus CIS and summation of aspects reviewed during last EPA iChange Notice 1: submitted 6/22/2011 to update the waste volume and generating facil
D-9 

EPA Inspection No.: INL-CC-2013 Waste Stream: ID-SDA-SOIL Insp

Technical Elements Objective Evidence/Comments 

AK-6: Are nonconformances and discrepancy resolutions documented appropriately? 

Yes. EPA has previously evaluated INL-CCP’s ability to produce compliant NCRs seve

specifically review any NCRs associated with ID-SDA-SOIL. INL-CCP has not written inspection. 

AK-7: Is the AK accuracy report technically adequate? Has it been updated annually? 

Yes. Most recent AK accuracy report completed 4/29/2013: assessed AK accuracy for L

cumulative AK accuracy for Lots 1–76. Accuracy report includes a memorandum summ

lists correlating the containers in Lots 74–76 to their BDRs, and CCP-TP-005, Revision 

that no containers from Lots 1–76 have been evaluated for reassignment. AK accuracy 

EPA also reviewed AK accuracy reports prepared 5/26/2011 and 6/1/2012. 

AK-8: Is AK-NDA communication adequately documented? 

Yes. AK-NDA communication documented in CCP-TP-005, Revision 24, Attachment 7

attached NDA memorandum dated 11/2/2011. As stated in checklist Item (AK-4c) abovexpected radionuclides each time an ARP phase is added based on information in WILDidentified in the NDA memorandum are the same as discussed in checklist Item (4c) abwaste is from RFP, the NDA memorandum also states that if NDA does not yield valid isotopics based on RFP WG Pu, HEU and DU will be used. 

AK-9: Has notification of applicable T2 changes been 

provided to EPA as required in the INL-CCP CH 

tiering table? 

Yes. EPA tracking began with 4th quarter FY 2009. T2 change notification required for: 

a. AK-NDA memoranda – EPA received notification of availability of Revision 7 of t

1st quarter report as expected. 

b. AK accuracy reports (annually, at a minimum) – EPA has received notification of a

reports annually in the 3rd quarter report. EPA expects this will continue and that EP

the 2013 AK accuracy report (provided to EPA during the inspection) in the FY 201

c. AK-AK and AK-NDA/NDE DR Reports – None post-EPA tracking. 

d. WSPFs, including updates or additions to waste streams within an approved waste c

notification of the availability of the change notice in the FY11 3rd quarter report as 

e. The load management status of approved waste streams – Status has not changed. 
D-10 

ATTACHMENT D.4: AK CONTINUED COMPLIANCE INSPECTION CHECKLIST: WASTE STREA

EPA Inspection No.: INL-CC-2013 Waste Stream: ID-ANLE-S5000 Insp

Technical Elements Objective Evidence/Comments 

AK-1: Do AK, training and nonconformance procedures adequately reflect the requirements of 40 CFR 194 and have they been adequately implemented? 

Yes. See Attachment D.1, checklist Item (AK-1). 

AK-2: Is the AK characterization process, including AK assembly, compilation and verification adequate? 

Yes. Completed CCP-TP-005 attachments provide objective evidence of AK assembly, 

a. Attachment 1, Revision 24, Acceptable Knowledge Documentation Checklist: comp

b. Attachment 2, Record of Communication: Interviews performed post-implementatio

documented on CCP-TP-005, Attachment 2 (References C006, C121, C144, C148 a

c. Attachment 3s, various revisions, Acceptable Knowledge Source Document Summa

source documents. Most are Revision 24. 

d. Attachment 4, Revision 24, Acceptable Knowledge Information List: complete. 

e. Attachment 5, Hazardous Constituents: outside EPA’s purview; not reviewed. 

f. Attachment 6, Revision 23, Waste Form, Waste Material Parameters, Prohibited Item

It and the associated WMP analysis memorandum support estimates in AKSR and d(AK-4). 

g. Attachment 7, Revision 18, Radionuclides: Not completed for RH waste. See checkl

radiological information. 

h. Attachment 8, Revision 24, Waste Containers List: updated periodically as waste co

storage. See checklist Item (AK-5) for additional information about the WSPF, Atta

memorandum process, as they are interrelated in the case of this waste stream. Latesdated 4/30/2012. 

i. Attachment 9, Waste Characterization Data Cross-Reference: reference tool, not a fo

j. Attachment 10, Revision 18, Acceptable Knowledge Re-evaluation Checklist, exam

DR017. 

k. Attachment 11, various revisions, Acceptable Knowledge Source Document Discrep

appropriate [see checklist Item (AK-6)]. Associated Attachment 3s for the older DR 

fall 2012, in response to a programmatic overhaul performed in response to correctiv

CTAC/CBFO QA audit results. 

l. Attachment 12, Example Form and Content Guide for AK Summary Reports: refere

completion; see review of completed AKSR in checklist Item (AK-4). 

m. Attachment 13, Revision 24, CCP Waste Stream Characterization Checklist: exampl

n. Attachment 14, Revision 24, CCP Acceptable Knowledge Accuracy Report: comple

Item (AK-7). 

o. Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form: not app
D-11 

EPA Inspection No.: INL-CC-2013 Waste Stream: ID-ANLE-S5000 Insp

Technical Elements Objective Evidence/Comments 

AK-3: Are waste containers traceable from retrieval through CCP’s EPA-approved characterization 

process? 

Yes. Traceability to original container packaging was established during multiple T1 re

evaluated to determine traceability from original HFEF canister through DTC and found 

Drum HFEF Canister Repackage Date RTR BDR DTC BDR 

ANLE7E ANLE7 7/23/12 INLRHRTR12014 INLRHDTC1201

ANLE12A ANLE12 8/8/12 INLRHRTR12015 INLRHDTC1201

AK-4: Does the AK summary report include sufficient information, supported by appropriate source documents, to support the statements below? a. All waste within the waste stream was 

generated from a single process/activity. 

b. All waste within the waste stream is similar in 

material and physical form. 

c. All waste within the waste stream has similar 

radiological properties. 

d. All of the waste in the waste stream is defense 

in origin. 

e. None of the waste in the waste stream is highlevel waste. 

f. None of the waste in the waste stream is spent 

nuclear fuel. 

Yes. CCP-AK-INL-500, Revision 11, was reviewed extensively for the selected items a

approval (EPA Docket No. A-98-49, II-A4-163). The AKSR continues to contain all rea. ID-ANLE-S5000 was generated in the ANLE AGHCF M-Wing hot cell facility. Th

complex in which metallurgical research and fuel material evaluation and testing are 

generated primarily from activities associated with analysis of post-irradiated nuclea

breeder and light-water reactors (References C066, C350, C380, C1031, DR018, U0

b. ID-ANLE-S5000 is composed primarily of organic (22%) and inorganic (78%) deb

material such as paper, wood items, boxes, various plastics (e.g., tygon tubing), rubbitems such as test tubes, and various metals including carbon and stainless steel from 

assigned to WMC S5400, heterogeneous debris (References C332, C347, C1031, U

c. ID-ANLE-S5000 was generated during processing of irradiated and unirradiated fue

programs. The predominant WIPP radionuclides by weight percent are 239Pu and 240

radionuclides overall by weight are 235U and 239Pu. The predominant WIPP radionuc

137Cs and 90Sr, and the predominant overall radionuclides by curie percent are 137Cs 

component of the waste stream is composed predominantly of 238U and 235U by mas

and 144Ce by curie percent (References C348, C3660, U3607, U3900 and U3901). 

d. The ANLE mission included defense and non-defense activities. As a result of wast

Wing and the AGHCF, segregation of defense and non-defense waste was not feasibANLE-S5000 is a commingled defense waste stream generated in part by atomic en(References C001, C036, C125, C381, C1031, P001, P002, U001, U013 and U1003

e. ID-ANLE-S5000 waste was not generated through separation or reprocessing of con

fuel and is not considered high-level waste. 

f. ID-ANLE-S5000 consists of debris generated from the preparation of irradiated test 

specimens or portions of specimens. Because the material includes test specimens, D

material as spent nuclear fuel. 

AK-5: Are the waste stream profile form and related attachments complete and adequate/accurate? Related attachments include: a. Characterization information summary 

b. Summation of aspects 

c. Characterization Reconciliation Report 

d.WSPF change notices e. Attachment 8 revisions and add container 

Yes. WSPF, Revision 0: dated 1/12/2007 and included the CIS and summation of aspec36 was provided, dated 2/13/2013 (latest CRR developed). EPA has evaluated CRR prereviews, so previous CRRs were not requested. Change Notice #1: dated 7/6/2007 to add TRUCON code ID 321 to support containers 

New CIS and CRR are prepared on a lot basis as characterization proceeds; 36 CIS/CRR 

ID-ANLE-S5000. INL-CCP does not update the WSPF as the waste stream volume changes, although CC

significant changes in waste volume may prompt revision of the WSPF. EPA examined 

8 revisions and add-container memoranda to understand how the waste stream has grow

issuance in 2007, there have been three Attachment 8 revisions and eight add-container 
D-12 

EPA Inspection No.: INL-CC-2013 Waste Stream: ID-ANLE-S5000 Insp

Technical Elements Objective Evidence/Comments 

memoranda C3660 and M001). 

AK-6: Are nonconformances and discrepancy resolutions documented appropriately? 

Yes. EPA examined NCR and DR report preparation during several T1 reviews specific 

selected one example NCR, RHINL-0427-13, that was prepared for Drum No. ANLE34

high-gamma drum that received an NCR due to fissile-gram equivalent requirements. Aseveral DR reports specific to this waste stream, none of which were recently prepared. 

DR021, was prepared to address document and characterization discrepancies with resp

waste containers (References NCR RHINL-0427-13, DR014, DR016, DR017, DR018, 

AK-7: Is the AK accuracy report technically adequate? Has it been updated annually? 

Yes. Most recent AK accuracy report completed 4/29/2013: assessed AK accuracy for Lmust identify the percentage of containers for which there are significant discrepancies 

between the AK record and measured values. INL-CCP stating in the AK accuracy repo

discrepancies between the AK information used in the modeling and the qualification osampling). The scaling factors developed for ID-ANLE-S5000 were based on AK, whic

amenable to AK accuracy evaluations by comparing measurements against AK because 

AK against itself. INL-CCP revised the AK accuracy report to state, “The scaling factor

data. Comparing the dose-to-curie results to AK data does not result in a meaningful AK that AK use in the aforementioned scaling factor development was previously approved 

98-49; II-A4-163). With this revision, the AK accuracy report for ID-ANLE-S5000, Lo

The report is updated annually and EPA has examined AK accuracy report preparation 

AK-8: Do the radiological characterization report and AKSR agree on fundamental AK information as a demonstration of AK-radiological characterization communication? 

Yes. AK-radiological characterization communication was thoroughly evaluated during 

ANLE-S5000 adding the 48 high-gamma drums. AKSR, Revision 11, included radiologthe high-gamma drums to ensure that the information presented in the radiological char

radiological characterization unique to the high-gamma drums was identified by AK peto waste characterization has changed since that review. 

AK-9: Has notification of applicable T2 changes been 

provided to EPA as required in the INL-CCP CH 

tiering table? 

Yes. EPA tracking began with 4th quarter FY 2009. T2 change notification required for: 

a. WSPF and related attachments – No WSPF changes since EPA tracking began. CRR 

shipping lots but only required to be submitted when WSPF updated. 

b. Modification of CCP-AK-INL-500 – Revision 11 completed 11/20/2012; notificatio

1st quarter report as expected. 

c. CCP-AK-INL-502 – Revision 6 completed 8/1/2012; notification provided to EPA 

expected. 

d. AK Accuracy – completed 4/29/2013; EPA expects to receive notification in the FY 

e. Attachment 4 – revised 11/26/2012; Notification not provided to EPA. 

f. CSSF – CSSF is not applicable. 

g. Add container memoranda or similar list, when adding to a previously approved pop

Not required; add-container memoranda were issued to explain addition of containe

population or to add containers via approved T1s. Have not yet added containers to 

the baseline population or approved T1s, although multiple add container memorandhave been prepared to explain drum number changes due to repackaging. 
D-13 

EPA Inspection No.: INL-CC-2013 Waste Stream: ID-ANLE-S5000 Insp

Technical Elements Objective Evidence/Comments 

AK-10 Is the certification plan adequately prepared? 

Yes. The certification plan for ID-ANLE-S5000 was reviewed by EPA during the T1 rehigh-gamma drums (EPA Docket No. A-98-49; II-A4-163) and INL-CCP prepared CCPwhich adequately addressed EPA’s T1 comments.
D-14 

ATTACHMENT D.5: AK CONTINUED COMPLIANCE INSPECTION CHECKLIST: WASTE STREA

EPA Inspection No.: INL-CC-2013 Waste Stream: IN-ID-BTO-030 Insp

Technical Elements Objective Evidence/Comments 

AK-1: Do AK, training and nonconformance procedures adequately reflect the requirements of 40 CFR 194 and have they been adequately implemented? 

Yes. See Attachment D.1, checklist Item (AK-1). 

AK-2: Is the AK characterization process, including AK assembly, compilation and verification adequate? 

Yes, although characterization of the waste stream is in progress so that the complete prAvailable completed CCP-TP-005 attachments provide objective evidence of AK assemverification as completed at the time of the inspection. 

a. Attachment 1, Revision 24, Acceptable Knowledge Documentation Checklist: comp

b. Attachment 2, Record of Communication: N/A; none of the references provided we

c. Attachment 3s, various revisions, Acceptable Knowledge Source Document Summa

source documents. Most are Revision 24. 

d. Attachment 4, Revision 24, Acceptable Knowledge Information List: complete. 

e. Attachment 5, Hazardous Constituents: outside EPA’s purview; not reviewed. 

f. Attachment 6, Revision 23, Waste Form, Waste Material Parameters, Prohibited Ite

It and the associated WMP analysis memorandum support estimates in AKSR and d(AK-4). 

g. Attachment 7, Revision 18, Radionuclides: not completed for RH waste. See Check

radiological information. 

h. Attachment 8, Revision 24, Waste Containers List: updated periodically as waste co

storage. See checklist Item (AK-5) for additional information about the WSPF, Attamemorandum process, as they are interrelated in the case of this waste stream. 

i. Attachment 9, Waste Characterization Data Cross-Reference: reference tool, not a f

j. Attachment 10, Acceptable Knowledge Re-evaluation Checklist, No checklists have 

k. Attachment 11, Revision 24, Acceptable Knowledge Source Document Discrepancy 

appropriate [see checklist Item (AK-6)] (References DR005 and DR006). Original D

associated Attachment 3s were provided. 

l. Attachment 12, Example Form and Content Guide for AK Summary Reports: refere

completion; see review of completed AKSR in checklist Item (AK-4). 

m. Attachment 13, Revision 24, CCP Waste Stream Characterization Checklist. No exa

characterization has not been completed for this waste stream. 

n. Attachment 14, Revision 24, CCP Acceptable Knowledge Accuracy Report: comple

available because characterization has not been completed for this waste stream. 

o. Attachment 15, Revision 22, CCP TRU Waste Correlation and Surrogate Summary 

however, INL-CCP radiological characterization personnel determined that the two waste from different fuels, so unique sampling of IN-ID-BTO-030 is required and th

retracted. 

AK-3: Yes, based on the information that had been released by the Navy at the time of the insp

Waste Stream IN-ID-BTO-030 were generated at Bettis. The containers were shipped in 
D-15 

EPA Inspection No.: INL-CC-2013 Waste Stream: IN-ID-BTO-030 Insp

Technical Elements Objective Evidence/Comments 

Are waste containers traceable from retrieval through CCP’s EPA-approved characterization 

process? 

between 1987 and 1989, where they were unloaded and placed into HFEF canisters that 

RWMC ILTSF. The HFEF canisters remained in storage at the ILTSF for over 20 years

canisters were extracted, and original IN-41 containers were removed, repackaged and p

overpacked by 55-gallon containers. These containers have since undergone RTR and th

During the repackaging process, 8 of the 13 IN-41 containers underwent solid sampling development. (References U200 and U227). 

IN-41 

Can No. 

HFEF Canister No INL Container ID 

(repackaged drum) 

RTR BDR Sampled to 

Scaling Fac

42 1377, N-146, 88-107 IDBLANL880107A INLRHRTR12010 Yes 82 1380,B-364, 88-164 DBLANL880164A INLRHRTR12010 No 

AK-4: Does the AK summary report include sufficient information, supported by appropriate source documents, to support the statements below? a. All waste within the waste stream was 

generated from a single process/activity. 

b. All waste within the waste stream is similar in 

material and physical form. 

c. All waste within the waste stream has similar 

radiological properties. 

d. All of the waste in the waste stream is defense 

in origin. 

e. None of the waste in the waste stream is highlevel waste. 

f. None of the waste in the waste stream is spent 

nuclear fuel. 

Yes. CCP-AK-INL-590, Revision 2, contains all required items. Note that the documen

modifications when submitted to EPA with a T1 request. 

a. Bettis Laboratory MEL operations generated 28 containers of RH TRU waste durin

nuclear fuel assemblies from naval reactor programs. Waste was generated during dassemblies and consists of various metal fines. Of these 28 containers, 13 were solishipped to INL for storage. Waste was generated in the MEL between 1977 and 19

C207, C210, U212, U224 and U236). 

b. IN-ID-BTO-030 consists predominantly of inorganic waste materials generated dur

elements, grinding, mounting and polishing of metallographic specimens. It is com

debris solidified in cement (References P201, U221, U224 and U276). 

c. IN-ID-BTO-030 contains 137Cs and 80Sr as the predominant WIPP radionuclides ba

although 137mBa and 147Pm are the predominant overall radionuclides based on activ

the predominant WIPP radionuclides based on mass fraction and 235U and 232Th are 

radionuclides based on mass fraction (References U200, U275 and U305). 

d. IN-ID-BTO-030 was generated during the examination of fuel elements from prim

evaluation of fuel performance; fuel elements were sourced from nuclear-powered irradiated test specimens and the Shippingport Atomic Power Station. Although co

performed, it is not possible to segregate the fines that were solidified based on def

(References P102, P014 and U201). 

e. The MEL operations that generated IN-ID-BTO-030 did not involve separation or r

elements from reactor fuel and therefore do not contain high-level waste (Referenc

f. IN-ID-BTO-030 contains fines and debris from testing of post-irradiated fuel assem

irradiated fuel elements withdrawn from a reactor and therefore does not contain spP100, U201 and U256). 

AK-5: Are the waste stream profile form and related attachments complete and adequate/accurate? Related attachments include: a. Characterization information summary 

Indeterminate. WSPF was not prepared at the time of EPA’s inspection. As a result, CRaspects were not available for review, either. Attachment 8 dated 5/19/2012. IN-ID-BTO-030 is currently in the characterization process, which is complicated by th

must be thoroughly vetted by the Navy prior to release of any documentation. Thereforea draft WSPF or any other draft documents specifically for the inspection because of th
D-16 

EPA Inspection No.: INL-CC-2013 Waste Stream: IN-ID-BTO-030 Insp

Technical Elements Objective Evidence/Comments 

b. Summation of aspects 

c. Characterization Reconciliation Report 

d.WSPF Change notices e. Attachment 8 revisions and Add-Container 

Memos 

EPA has reviewed the WSPF preparation process for other INL-CCP waste streams and 

during the forthcoming IN-ID-BTO-030 T1 review. 

AK-6: Are nonconformances and discrepancy resolutions documented appropriately? 

Indeterminate. No NCRs have been prepared for the waste stream; characterization is stthe AKSR. DR005 and DR006 were prepared, but only the Attachment 3s for these DRs were availtime of the inspection. DR005 dealt with hazardous waste number identification, and Dcontainers used during the cementation process. EPA has reviewed the nonconformance 

process for other INL-CCP waste streams and may examine NCRs and DRs during the 

T1 review. 

AK-7: Is the AK accuracy report technically adequate? Has it been updated annually? 

Indeterminate. Characterization is not complete for ID-IN-BTO-030, so no AK accurac

has reviewed the AK accuracy process for other INL-CCP waste streams and may exam

during the forthcoming IN-ID-BTO-030 T1 review. 

AK-8: Do the radiological characterization report and AKSR agree on fundamental AK information as a demonstration of AK-radiological characterization communication? 

Indeterminate. The radiological characterization report for Waste Stream IN-ID-BTO-0

review at the time of the inspection. EPA has reviewed AK-radiological characterizatio

INL-CCP waste streams and may examine the radiological characterization report durin

BTO-030 T1 review. The sampling plan described the samples collected for radiologica

post-sampling memorandum described results of the sampling and analysis process. No

copy of the post-sampling memorandum and was only briefly allowed to examine its co

yet to release the document for public review. INL-CCP collected eight samples from W

the results of which will be used in future scaling factor development. 

AK-9: Has notification of applicable T2 changes been 

provided to EPA as required in the INL-CCP CH 

tiering table? 

No. Most of the documents required for T2 notification have not been completed and, t

notification of their completion. INL-CCP has completed CCP-AK-INL-590, Revision (12/27/2011) and Revision 2 (4/4/2012) but has not included these reports in the T2 qu

CCP has completed CCP-AK-INL-592, Revision 0 (4/18/2011) and Revision 1 (8/16/2also not included in any of the T2 quarterly reports. EPA expects that any future revisioincluded in the appropriate T2 quarterly report. 

AK-10 Is the certification plan adequately prepared? 

Yes. CCP-AK-INL-592, Revision 1, is being reviewed internally by the Navy and othe

submitted to EPA with the T1 request. Because the certification plan may be significancomment on the document until the revised version is provided as part of a forthcoming 
E-1 

ATTACHMENT E.1: NDA CONTINUED COMPLIANCE INSPECTION CHECKLIST: W

Technical Elements Objective Evidence 

General WAGS-1: Confirm the NDA system is the WAGS, its location and number. 

Located in Building WMF-610 at INL RWMC. The WAGS has no other name or location designations. 

EPA to bunminsp

WAGS-2: Describe the WAGS. 

The WAGS utilizes six high-resolution BEGe gamma detectors, a drum turntable and a shielded enclosure. One bank (North top, middle and bottom) of each of three gamma detectors is fitted with approximately three millimeters of lead and 

three millimeters of cadmium, with a thin layer of copper to acquire quantitative gamma spectra for gamma analysis. Another bank (West top, middle and bottom) has been fitted with 32-mil cadmium filters to attenuate low-energy gamma rays, reduce dead time and improve isotopic analysis. 

N/A 

WAGS-3: Identify the consensus standards that were used for the system calibration 

ASTM C-1030, C-1133, C-1215, E-181. CCP-INL-WAGS-003, Revision 0. 

As 003dur

pers

WAGS-4: Describe the system’s operational history since the baseline approval. 

The WAGS assay system has been in operation supporting the work performed by 

INL-CCP since 4/26/2005. During this time, various QC criteria have been 

monitored to verify the continued acceptable performance of the system. 

As 003dur

pers

WAGS-5: Identify the container types assayed on the WAGS 

The WAGS may assay 55-gallon drums only. Vis

concouinst

WAGS-6: Identify the period of performance relevant to the WAGS and the number of BDRs and waste containers this system assayed during the period. 

From May 1, 2012 to May 6, 2013, the WAGS assayed 1,444 drums contained in 119 BDRs. The WAGS can assay a maximum of 13–14 drums each day. 

As dur

WAGS-7: Confirm that the WAGS is able to report quantitative values for the WIPP-tracked radionuclides 

Direct Measurements: 239Pu, 241Am, 233U, 235U, 238U and 137Cs. 

Isotopic Fractions: 238Pu, 240Pu, 241Pu, 242Pu by correlation and 241Am relative to 

Pu. Radionuclides by Scaling: 90Sr and 234U. 

CCP-INL-WAGS-003, Revision 0. 

As 003with insp

WAGS-8: Confirm the WAGS’s calibration of record. 

Documented in CCP-INL-WAGS-003 Revision 0 (5/2011).Reference peak, energy and shape calibrations are documented in INL-WAGS09-007. 

Condur
E-2 

Technical Elements Objective Evidence 

WAGS-9: Identify the procedures that govern this function and where the results of these calculations are documented. 

CCP-TP-019, Operating Procedure (Revision 6, 4/2013). CCP-TP-010, Calibration Procedure (Revision 4, 3/2011). CCP-TP-009, Data Validation Procedure (Revision 9, 2/2013). 2013 revisions were to clarify operator responsibilities. 

Thecurrwerat th

WAGS-10: Confirm that the methods used to derive the isotopic contribution for unmeasured radionuclides are MGA and MGA-U. 

MGA and MGA-U are integral parts of the WAGS operation as shown in CCPTP-019, Operating Procedure (Revision 6, 4/2013). Con

with dur

WAGS-11: Confirm the WAGS operational range with respect to matrix (density) and activity. 

~0.010 g to 200 g total Pu (calibration-based and administrative). Limited by LLD and system dead time. Calibration makes the assumption that matrix materials are mainly Z < 15. Waste matrix materials outside density range for calibrated efficiency together with presence of higher Z materials require expert 

review. 

EPA 

pers

as p

Calibration Verification and ConfirmationWAGS-12: Identify the date of the last calibration verification. Have any others been completed in the last year? 

11/29/2012, following the replacement of the DSA 1000 power supply (CCPINL- WAGS-12-005, 12/3/2012). Con

dur

WAGS-13: Confirm the pedigree of all radionuclide standards that were used for calibration confirmation and/or verifications. List or reference all standards used. 

Sources are summarized in Table 3 of CCP-INL-WAGS-003, WAGS Calibration, Confirmation and Verification Report, Revision 0, May 14, 2011. Source certifications are listed in Attachment 1. 

EPA certWAstancertthe 

WAGS-14: Requirements for accuracy and precision must be met, as specified in DOE/WIPP-02-3122, Appendix A, Table A-3.2 for calibration verifications. 

The calibration verification results are contained in Section 5 of CCP-INLWAGS-003, WAGS Calibration, Confirmation and Verification Report, Revision 0, May 14, 2011. % R was found to be between 70 and 130 % and % RSD was 

found to be less than 14%. 

Accwerveri

WAGS-15: Describe the mishandling of the DPC drum in December 2011 and corrective actions applied. 

CCP-INL-WAGS-11-005 describes the event and CCP-INL-WAGS-12-002 

describes corrective actions taken by INL-CCP. 

The appdocrevi

WAGS-16: The 133Be transmission source has a ~10-year 

half-life. When was the count rate last reevaluated

in the system? 

Sources were installed in January 2009 and were evaluated in July 2011 and July 

2012. This is documented in CCP-INL-WAGS-12-003, July 19, 2012. Reevaluation is prompted when the counts start to fall below the boundary conditions due to the decay of 133Ba. 

Condur
E-3 

Technical Elements Objective Evidence 

LLD WAGS-17: Confirm that the LLD for the WAGS has been determined. 

The LLD is documented in Section 5 of CCP-INL-WAGS-003, Revision 0. All transmission-corrected LLD results indicate that the instrument meets the WAC TRU/LLW discrimination criterion of 100 nCi/g or less, with the exception of 

241Am in a plastic foam matrix drum. 

Conwith dur

WAGS-18: Confirm if the WAGS is used to discriminate TRU/non-TRU wastes at the 100 nCi/g criterion and that it has the required sensitivity. 

The WAGS can discriminate between LLW and TRU waste based on the LLDs reported in Section 5 of CCP-INL-WAGS-003, Revision 0 for all measured radionuclides but 241Am. If the presence of 241Am is indicated but not reported in 

a drum with a density of less than 0.44 kg/L, then only higher energy gamma lines will be used for quantification of the 241Am activity. 

Totrepowith instof lin ththes

WAGS-19: Identify any/all instances where an LLD value for a non-measured radionuclide is not provided 

based on a lack of technical feasibility. 

 Because an LLD is a measurement-based parameter, it is not technically feasible to calculate for radionuclides that are not directly measured. Plutonium isotopes 

238Pu, 240Pu and 242Pu are not usually directly measured by gamma spectroscopy 

and are instead derived by ratios to measured 239Pu. The reporting threshold for 

90Sr is computed based on the reported 137Cs LLD using an activity ratio 

determined from AK NDA memos. INL-CCP states that it is not technically feasible to provide an LLD equivalent for 234U and that it is derived by algorithm 

from measured values of 235U, 238U and 238Pu. 

ThiCCP0. 

Quality Control WAGS-20: All operators have current CCP training as verified on LOQI. 

LOQI provided on 5/6/2013 contains six operators, all with current training. EPA 

listelistealso Grecurr

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indi201qua

WAGS-21: Confirm the WAGS’s status with respect to the CBFO NDA PDP and last cycle. 

The WAGS successfully participated in drum cycle 19A of the CBFO NDA PDP. EPA 

part

lette
E-4 

Technical Elements Objective Evidence 

WAGS-22: All WAGS data must be reviewed and approved 

by qualified personnel. Identify the name and 

function of the individuals performing technical review and approval of WAGS BDRs. 

Preston Abbott, ITR/SME/OJT, 5/2013. Brent Dial, ITR, 10/2013. Mary Carrol, ITR, 7/2013. Rick Green, ITR, 12/2014 (retired in 4/2013). Davis W. Crary, ITR/SME/OJT, 7/2014. David Brasier, ITR/SME/OJT/EA, 4/2013. Bob Ceo, EA. Bart Morales, EA. Tim Southwort, EA. 

All tech

WAGS-23: Identify any NCRs within the last year. 

There have been three NCRs on the WAGS in the last year: 

NCR-INL-0368-12. NCR-INL-0362-12. NCR-INL-0350-12. 

ConINLinsp

TMU WAGS-24: Identify any changes to the method or details of the TMU calculation since baseline. 

No changes to the TMU were made since EPA’s last inspection. Con

INLinsp

WAGS-25: Evaluate the magnitude of the TMU values observed in the WAGS BDRs that were examined during this inspection. 

The TMU for the WAGS is documented in CCP-INL-WAGS-002, Total Measurement Uncertainty for the WAGS System, dated April 20, 2005. This document does not have a revision number. The components of uncertainty included in the TMU determination consist of calibration source uncertainties, counting statistics, self-absorption effects, matrix nonhomogeneities, nonuniform source distributions and isotopic measurement uncertainties. The software for 

performing the TMU calculations is embedded in the NDA 2000 software. CCPINL-WAGS-002 calls for administrative procedures that would define a 

minimum fill-height requirement to reduce the potential for increased 

uncertainties due to end effects. TMU values in BDRs are generally consistent with expectations. 

ConINLinsp

Background and Performance Checks WAGS-26: Confirm that WAGS background measurements have been taken daily. 

Confirm that WAGS background measurements have been taken daily. EPA 

inteThe rand1/2/evid
E-5 

Technical Elements Objective Evidence 

WAGS-27: Assess how often background radiation was 

problematic to the extent that measurement personnel had to make adjustments. 

No instances of problematic backgrounds were observed in the last year. EPA 

inte

WAGS-28: Confirm that system performance checks have 

been performed at least once per operational day. 

Confirm that performance checks include gamma and neutron efficiency, matrix correction checks, and gamma peak position and resolution checks. 

Performance checks are done once per day as stated in CCP-TP-019, Revision 6. EPA 

inteThe rand1/2/evid

Data Management WAGS-29: WAGS BDRs contain: • Testing facility name, testing batch number, 

container numbers, and signature of the SPM or designee 

• Table of contents 

• Background and performance check data or 

control charts for the relevant time period 

• Separate testing report sheets for each 

container 

EPA reviewed WAGS BDRs INNDAW130036 and INND120076 and found them to contain appropriate information. 

N/A 

WAGS-30: WAGS RDSs must include: • Title “Radioassay Data Sheet” 

• Method/procedure used 

• Date of radioassay 

• Activities and associated TMU for individual 

radionuclides 

• TRU alpha concentration and its associated 

TMU 

• Operator and reviewer signatures 

EPA reviewed WAGS BDRs INNDAW130036 and INND120076 and found that each drum contained in the two BDRs had an RDS containing the correct elements. 

N/A 
E-6 

ATTACHMENT E.2: NDA CONTINUED COMPLIANCE INSPECTION CHECKLIST: 

Technical Elements Objective Evidence 

GeneralSGRS-1: Confirm the NDA system is the SGRS, its location and number. 

Located in Building WMF-610 at INL RWMC. EPA 

be lo

unminsp

SGRS-2: Describe the SGRS. 

The SGRS is a gamma-based system that uses four high-resolution BEGe gamma detectors, a drum turntable, shielded enclosure, and supporting electronics. The SGRS performs quantitative assays and corrects the summed gamma peaks for attenuation using a multi-curve calibration that computes efficiency as a function of waste density and photon energy. Live-time corrections are performed using a 

pulser. Isotopics are determined from the same spectra using MGA and MGA-U. 

Default isotopics are employed when empirical results are not useable. The four gamma detectors are arranged vertically and acquire spectra for all vertical segments simultaneously. The system runs NDA 2000 as well as MGA and 

MGA-U. When plutonium isotopes are not detected, the software attempts to compute isotopic distributions for uranium isotopes using the MGA-U program. The isotopic determination is performed simultaneously with the quantitative 

assay, and, if measurement-based isotopics are not available, default AK values 

are used. The SGRS derives a value for 242Pu by correlation, and 90Sr is 

determined by application of a scaling factor based on 137Cs. 234U is quantified 

based on measured values for 235U and 238U. 

N/A 

SGRS-3: Identify the consensus standards that were used for the system calibration. 

The consensus standards that are used in the calibration are ASTM C-1030, C1133, C-1215 and E-181. As s

Reviinter

SGRS-4: Describe the system’s operational history since the last EPA inspection. 

Since the 2010 EPA inspection, the DETA4 has been replaced. Due to this change, the detector was recalibrated and required a T1 approval. EPA approved 

this change in February 2013. There have been no other significant changes since that time. 

As sReviinter

SGRS-5: Identify the container types assayed on the SGRS.

The SGRS can only assay 55-gallon drums. Visu

contcoulinstr

SGRS-6: Identify the period of performance relevant to thisapplication of the SGRS. Since this time, identify the number of waste containers this system has assayed and then number of BDRs assembled. 

From May 1, 2012, to May 6, 2013, the SGRS assayed 1,246 drums contained in 41 BDRs. Of these assays, 697 drum were production assays and 549 assays were for information purposes only. The WAGS can assay a maximum of 35 drums each day. 

As sdurin
E-7 

Technical Elements Objective Evidence 

SGRS-7: Confirm that the SGRS is able to report quantitative values for the WIPP-tracked radionuclides 

Direct Measurements: 239Pu, 241Am, 233U, 235U, 238U and 137Cs. 

Isotopic Fractions: 238Pu, 240Pu, 241Pu, 242Pu by correlation and 241Am relative to 

Pu. Radiouclides by Scaling: 90Sr and 234U. 

As sReviconfdurin

SGRS-8: Confirm the SGRS’s calibration of record. 

The calibration of record is documented in CCP-INL-SGRS-001, Revision 2. This is the same calibration document that was reviewed during the most recent SGRS T1 approval in February 2013. 

Condurin

SGRS-9: Identify the procedures that govern this function and where the results of these calculations are documented. 

CCP-TP-115, Operating Procedure (Revision 5.1, 4/2013). CCP-TP-010, Calibration Procedure (Revision 4, 3/2011). CCP-TP-109, Data Validation Procedure (Revision 9, 2/2013). 2013 revisions were to clarify operator responsibilities. 

Thescurrewere the S

SGRS-10: Confirm that the methods used to derive the isotopic contribution for unmeasured radionuclides are MGA and MGA-U. 

MGA and MGA-U are integral parts of the SGRS operation as shown in CCPTP-115, Operating Procedure (Revision 6, 4/2013). Interviews with INL-CCP SGRS personnel during inspection. 

ConINLinsp

SGRS-11: Where is the actual efficiency calibration for the SGRS documented? 

It is documented in CCP-INL-SGRS-001, Revision 2, and its attachments. N/A 

SGRS-12: Confirm the SGRS operational range with respect to matrix (density) and activity. 

~0.010 g to 200 g total Pu (calibration-based and administrative). Limited by LLD and system dead time. Calibration makes the assumption that matrix 

materials are mainly Z < 15. Waste matrix materials outside density range for calibrated efficiency together with presence of higher Z materials require expert 

review. 

This 

pers

oper

prev

Calibration Verification and Confirmation SGRS-13: Identify the date of the last calibration verification. Have any others been completed in the last year? 

A calibration verification was done on 10/17/2012 after the replacement of DET2A gamma detector, as is documented in CCP-INL-SGRS-12-005 and CCPINL-SGRS-12-003. No other calibration verifications have been done since the 

SGRS’s recalibration in November 2012. 

This 

pers

SGRS-14: Confirm the pedigree of all radionuclide standards that were used for calibration confirmation and/or verifications. List or reference all standards used. 

The standards are summarized in Table 1 of CCP-INL-SGRS-001, SGRS Calibration, Confirmation and Verification Report, Revision 2, November 14, 2012. Source certifications are listed in Attachment 1 of the same document. 

EPA certiSGRstandcertithe S
E-8 

Technical Elements Objective Evidence 

SGRS-15: Requirements for accuracy and precision must be met, as specified in DOE/WIPP-02-3122, Appendix A, Table A-3.2 for calibration verifications. 

The calibration verification results are contained in Section 5 of CCP-INLSGRS-003, SGRS Calibration, Confirmation and Verification Report, Revision 2. % R was found to be between 70 and 130% and % RSD was found to be less than 14%. 

Accuwere verif

LLD SGRS-16: Confirm that the LLD for the SGRS has been determined. 

Section 6 of CCP-INL-SGRS-001, Revision 2 documents the LLD determination of measured radioisotopes. LLDs for all measured radionuclides in plastic foam, 

soft board, particle board and sand matrices were below the 100 nCi/g TRU 

threshold. 

Inter

pers

SGRS-17: Confirm if the SGRS is used to discriminate TRU/non-TRU wastes at the 100 nCi/g criterion and that it has the required sensitivity. 

The SGRS can discriminate between LLW and TRU waste based on the LLDs reported in Section 6 of CCP-INL-SGRS-001, Revision 2 for all measured radionuclides. 

Totarepowith 

a dru100 INLwill 

SGRS-18: Identify any/all instances where an LLD value for a non-measured radionuclide is not provided 

based on a lack of technical feasibility. 

Because an LLD is a measurement-based parameter, it is not technically feasible to calculate for radionuclides that are not directly measured. Plutonium isotopes 

238Pu, 240Pu and 242Pu are not usually directly measured by gamma spectroscopy 

and are instead derived by ratios to measured 239Pu. The reporting threshold for 

90Sr is computed based on the reported 137Cs LLD using an activity ratio 

determined from AK NDA memos. INL-CCP states that it is not technically feasible to provide an LLD equivalent for 234U and it is derived by algorithm 

from measured values of 235U and 238U. 

This CCP

Quality Control SGRS-19: All operators have current CCP training as verified on LOQI 

LOQI provided 4/24/2012 contains six operators, all with current training. EPA 

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indic2013 qual
E-9 

Technical Elements Objective Evidence 

SGRS-20: Confirm the SGRS’s status with respect to the CBFO NDA PDP and last cycle. 

The SGRS has a temporary post-recalibration approval from CBFO NDA PDP 

that expires in August 18, 2013. The SGRS is scheduled to participate in the next PDP cycle. 

EPA 

parti

SGRS-21: All SGRS data must be reviewed and approved 

by qualified personnel. Identify the name and 

function of the individuals performing technical review and approval of SGRS BDRs. 

Jim Vermon, SPM. Preston Abbott, ITR/SME/OJT, 5/2013. Brent Dial, ITR, 10/2013. Mary Carrol, ITR, 7/2013. Davis W. Crary, ITR/SME/OJT, 7/2014. David Brasier, ITR/SME/OJT/EA, 4/2013. Bob Ceo, EA. Bart Morales, EA. Tim Southwort, EA. 

All itechn

SGRS-22: Identify any hardware and/or software changes made to the SGRS since the baseline approval. Determine which changes, if any, are significant, where they are documented, and how they affect the SGRS’s baseline approval. 

DET2A gamma detector was replaced in November 2012. This required the SGRS be recalibrated. EPA evaluated this recalibration and approved it in February 2013. There have been no changes to the system since that time. 

ConINLinsp

SGRS-23: Identify any NCRs within the last year. 

There have been three NCRs on the SGRS in the last year: 

NCR-INL-1245-12. NCR-INL-0349-12. NCR-INL-0065-13. 

ConINLinsp

TMU SGRS-24: Identify any changes to the method or details of the TMU calculation since baseline. 

No changes to the TMU were made since EPA’s last inspection. Con

INLinsp
E-10 

Technical Elements Objective Evidence 

SGRS-25: Evaluate the magnitude of the TMU values observed in the SGRS BDRs that were examined during this inspection. 

The TMU for the SGRS was documented in CCP-INL-SGRS-002, Total 

Measurement Uncertainty for the SGRS System, dated April 21, 2005. This 

document does not have a revision number. The components of uncertainty included in the TMU determination consisted of calibration source uncertainties, counting statistics, self-absorption effects, matrix nonhomogeneities, nonuniform 

source distributions and isotopic measurement uncertainties. The software for 

performing the TMU calculations is embedded in the NDA 2000 software. CCPINL-SGRS-002 calls for “administrative procedures” that would define a 

minimum fill-height requirement to reduce the potential for increased uncertainties due to end effects. Addressing this is left to the expert reviewer, who “should assess those assays for the potential end effects uncertainties and 

add the appropriate uncertainty amounts to the TMU where applicable.” TMU 

values in BDRs are generally consistent with expectations based on CCP-INLSGRS-002. 

ConINLinsp

Background and Performance Checks SGRS-26: Confirm that SGRS background measurements have been taken daily. 

All records evaluated indicate compliant background performance. EPA 

interThe randcontmea

SGRS-27: Assess how often background radiation was 

problematic to the extent that measurement personnel had to make adjustments. 

No instances of problematic backgrounds were observed. Between the SGRS and 

the outside wall of Building 610 is a layer of lead sheeting designed to reduce 

background increases from material being moved outside of the building. This 

layer has been in place since before EPA’s last inspection. 

EPA occu

probNDA 

SGRS-28: Confirm that system performance checks have 

been performed at least once per operational day. 

Confirm that performance checks include gamma and neutron efficiency, matrix correction checks, and gamma peak position and resolution checks. 

Performance checks are done once per day as stated in CCP-TP-115, Revision 5. EPA 

interThe randcontchec
E-11 

Technical Elements Objective Evidence 

Data Management SGRS-29: SGRS BDRs contain: • Testing facility name, testing batch number, 

container numbers, and signature of the SPM or designee 

• Table of contents 

• Background and performance check data or 

control charts for the relevant time period 

• Data validation per the QAPD and site 

procedures 

• Separate testing report sheets for each 

container 

EPA reviewed SGRS BDRs INNDAS130001 and INNDAS120034 and found 

them to contain appropriate information. 

N/A 

SGRS-30: SGRS RDSs must include: • Title “Radioassay Data Sheet” 

• Method/procedure used 

• Date of radioassay 

• Activities and associated TMU for individual 

radionuclides 

• TRU alpha concentration and its associated 

TMU 

• Operator and reviewer signatures 

EPA reviewed SGRS BDRs INNDAS130001 and INNDAS120034 and found that each drum contained in the two BDRs had an RDS containing the correct elements. 

N/A 
F-1 

ATTACHMENT F.1: REPLICATE TESTING DATA FOR DRUM ARP70420 – SGR

Instrument: SGRS Drum: ARP70420 

Quantity of Interest 

Original Measurement Replicate #1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) 8.26E-05 5.12E-05 6.20E-01 8.84E-05 5.47E-05 6.19E-01 8.40E-05 238U Activity (Ci) 4.18E-04 1.53E-04 3.66E-01 4.29E-04 1.57E-04 3.66E-01 4.09E-04 238Pu Activity (Ci) 3.43E-04 2.22E-04 6.47E-01 3.71E-04 2.02E-04 5.45E-01 3.45E-04 239Pu Activity (Ci) 1.24E-02 6.51E-03 5.25E-01 1.35E-02 5.26E-03 3.90E-01 1.25E-02 240Pu Activity (Ci) 2.76E-03 1.46E-03 5.29E-01 2.99E-03 1.20E-03 4.01E-01 2.78E-03 242Pu Activity (Ci) 3.58E-07 2.62E-07 7.32E-01 3.88E-07 2.50E-07 6.44E-01 3.61E-07 241Am Activity (Ci) 7.29E-02 3.36E-02 4.61E-01 7.63E-02 2.99E-02 3.92E-01 7.27E-02 90Sr Activity (Ci) 5.63E-07 2.37E-07 4.21E-01 5.21E-07 2.10E-07 4.03E-01 5.45E-07 137Cs Activity (Ci) 5.11E-07 2.16E-07 4.23E-01 4.74E-07 1.91E-07 4.03E-01 4.95E-07 TRU Alpha Conc. (nCi/g) 9.19E+02 3.56E+02 3.87E-01 9.68E+02 3.16E+02 3.26E-01 9.18E+02 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) 8.37E-05 5.18E-05 6.19E-01 8.15E-05 5.04E-05 6.18E-01 8.22E-05 238U Activity (Ci) 4.30E-04 1.57E-04 3.65E-01 4.19E-04 1.53E-04 3.65E-01 4.17E-04 238Pu Activity (Ci) 3.48E-04 1.90E-04 5.46E-01 3.43E-04 1.92E-04 5.60E-01 3.37E-04 239Pu Activity (Ci) 1.26E-02 4.93E-03 3.91E-01 1.24E-02 5.10E-03 4.11E-01 1.22E-02 240Pu Activity (Ci) 2.80E-03 1.12E-03 4.00E-01 2.76E-03 1.16E-03 4.20E-01 2.71E-03 242Pu Activity (Ci) 3.64E-07 2.34E-07 6.43E-01 3.59E-07 2.35E-07 6.55E-01 3.52E-07 241Am Activity (Ci) 7.40E-02 2.92E-02 3.95E-01 7.07E-02 2.79E-02 3.95E-01 7.19E-02 90Sr Activity (Ci) 5.71E-07 2.18E-07 3.82E-01 5.86E-07 2.23E-07 3.81E-01 5.58E-07 137Cs Activity (Ci) 5.19E-07 1.98E-07 3.82E-01 5.32E-07 2.03E-07 3.82E-01 5.07E-07 TRU Alpha Conc. (nCi/g) 9.34E+02 3.08E+02 3.30E-01 8.97E+02 2.95E+02 3.29E-01 9.06E+02 
F-2 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <|c

Reported Value Absolute Uncertainty 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N234U Activity (Ci) 8.26E-05 5.12E-05 8.40E-05 2.69E-06 3.20E-02 1.10E-02 1.00E238U Activity (Ci) 4.18E-04 1.53E-04 4.21E-04 8.79E-06 2.09E-02 1.32E-02 1.00E238Pu Activity (Ci) 3.43E-04 2.22E-04 3.49E-04 1.30E-05 3.74E-02 1.38E-02 1.00E239Pu Activity (Ci) 1.24E-02 6.51E-03 1.26E-02 5.03E-04 3.98E-02 2.39E-02 1.00E240Pu Activity (Ci) 2.76E-03 1.46E-03 2.81E-03 1.07E-04 3.81E-02 2.15E-02 1.00E242Pu Activity (Ci) 3.58E-07 2.62E-07 3.65E-07 1.37E-08 3.76E-02 1.09E-02 1.00E241Am Activity (Ci) 7.29E-02 3.36E-02 7.31E-02 2.15E-03 2.93E-02 1.63E-02 1.00E90Sr Activity (Ci) 5.63E-07 2.37E-07 5.56E-07 2.49E-08 4.47E-02 4.41E-02 1.00E137Cs Activity (Ci) 5.11E-07 2.16E-07 5.05E-07 2.23E-08 4.41E-02 4.26E-02 1.00ETRU Alpha Conc. (nCi/g) 9.19E+02 3.56E+02 9.25E+02 2.79E+01 3.02E-02 2.46E-02 1.00E

Quantity of Interest t Pr(x <|t|) χ2 Test t Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable 234U Activity (Ci) -4.62E-01 6.68E-01 Not Significant Not Significant 238U Activity (Ci) -2.91E-01 7.86E-01 Not Significant Not Significant 238Pu Activity (Ci) -4.06E-01 7.06E-01 Not Significant Not Significant 239Pu Activity (Ci) -4.36E-01 6.86E-01 Not Significant Not Significant 240Pu Activity (Ci) -4.09E-01 7.03E-01 Not Significant Not Significant 242Pu Activity (Ci) -4.53E-01 6.74E-01 Not Significant Not Significant 241Am Activity (Ci) -9.36E-02 9.30E-01 Not Significant Not Significant 90Sr Activity (Ci) 2.50E-01 8.15E-01 Not Significant Not Significant 137Cs Activity (Ci) 2.29E-01 8.30E-01 Not Significant Not Significant TRU Alpha Conc. (nCi/g) -1.83E-01 8.64E-01 Not Significant Not Significant 
F-3 

ATTACHMENT F.2: REPLICATE TESTING DATA FOR DRUM SRP13045 – SGR

Instrument: SGRS Drum: SRP13045 

Quantity of Interest 

Original Measurement Replicate #1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) N/A N/A 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 3.29E-04 1.60E-04 4.86E-01 3.22E-04 1.56E-04 4.85E-01 3.30E-04 239Pu Activity (Ci) 1.19E-02 3.60E-03 3.03E-01 1.17E-02 3.46E-03 2.96E-01 1.20E-02 240Pu Activity (Ci) 2.65E-03 8.29E-04 3.13E-01 2.60E-03 8.00E-04 3.08E-01 2.66E-03 242Pu Activity (Ci) 3.44E-07 2.04E-07 5.93E-01 3.37E-07 2.00E-07 5.94E-01 3.46E-07 241Am Activity (Ci) N/A N/A 90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 1.39E+02 3.45E+01 2.48E-01 1.37E+02 3.33E+01 2.43E-01 1.40E+02 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) N/A N/A 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 3.23E-04 1.56E-04 4.83E-01 3.23E-04 1.56E-04 4.83E-01 3.28E-04 239Pu Activity (Ci) 1.17E-02 3.46E-03 2.96E-01 1.17E-02 3.46E-03 2.96E-01 1.19E-02 240Pu Activity (Ci) 2.60E-03 8.00E-04 3.08E-01 2.60E-03 8.00E-04 3.08E-01 2.64E-03 242Pu Activity (Ci) 3.38E-07 2.00E-07 5.92E-01 3.38E-07 2.00E-07 5.92E-01 3.43E-07 241Am Activity (Ci) N/A N/A 90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 1.37E+02 3.33E+01 2.43E-01 1.37E+02 3.33E+01 2.43E-01 1.39E+02 
F-4 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <

Reported Value Absolute Uncertainty 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 234U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 238U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 238Pu Activity (Ci) 3.29E-04 1.60E-04 3.25E-04 3.56E-06 1.10E-02 1.98E-03 1.00E239Pu Activity (Ci) 1.19E-02 3.60E-03 1.18E-02 1.41E-04 1.20E-02 6.17E-03 1.00E240Pu Activity (Ci) 2.65E-03 8.29E-04 2.62E-03 2.83E-05 1.08E-02 4.66E-03 1.00E242Pu Activity (Ci) 3.44E-07 2.04E-07 3.40E-07 3.91E-09 1.15E-02 1.47E-03 1.00E241Am Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 90Sr Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 137Cs Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 1.39E+02 3.45E+01 1.38E+02 1.41E+00 1.02E-02 6.72E-03 1.00E

Quantity of Interest t Pr(x <|t|) χ2Test t Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable 234U Activity (Ci) N/A N/A Not Applicable Not Applicable 238U Activity (Ci) N/A N/A Not Applicable Not Applicable 238Pu Activity (Ci) 9.73E-01 3.85E-01 Not Significant Not Significant 239Pu Activity (Ci) 6.45E-01 5.54E-01 Not Significant Not Significant 240Pu Activity (Ci) 9.68E-01 3.88E-01 Not Significant Not Significant 242Pu Activity (Ci) 8.40E-01 4.48E-01 Not Significant Not Significant 241Am Activity (Ci) N/A N/A Not Applicable Not Applicable 90Sr Activity (Ci) N/A N/A Not Applicable Not Applicable 137Cs Activity (Ci) N/A N/A Not Applicable Not Applicable TRU Alpha Conc. (nCi/g) 6.45E-01 5.54E-01 Not Significant Not Significant 
F-5 

ATTACHMENT F.3: REPLICATE TESTING DATA FOR DRUM ARP70259 – SGR

Instrument: SGRS Drum: ARP70259 

Quantity of Interest 

Original Measurement Replicate #1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) 1.98E-05 1.17E-05 5.91E-01 2.01E-05 1.19E-05 5.92E-01 1.99E-05 238U Activity (Ci) 6.03E-09 1.95E-09 3.23E-01 6.05E-05 1.94E-05 3.21E-01 6.00E-05 238Pu Activity (Ci) 2.21E-04 1.14E-04 5.16E-01 2.22E-04 1.13E-04 5.09E-01 2.20E-04 239Pu Activity (Ci) 7.98E-03 2.76E-03 3.46E-01 8.05E-03 2.71E-03 3.37E-01 7.99E-03 240Pu Activity (Ci) 1.77E-03 6.30E-04 3.56E-01 1.79E-03 6.57E-04 3.67E-01 1.77E-03 242Pu Activity (Ci) 2.30E-07 1.42E-07 6.17E-01 2.32E-07 1.42E-07 6.12E-01 2.31E-07 241Am Activity (Ci) 7.84E-02 2.56E-02 3.27E-01 7.74E-02 2.49E-02 3.22E-01 7.83E-02 90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 9.19E+02 2.67E+02 2.91E-01 9.10E+02 2.61E+02 2.87E-01 9.18E+02 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) 1.96E-05 1.16E-05 5.92E-01 2.00E-05 1.19E-05 5.95E-01 1.97E-05 238U Activity (Ci) 6.08E-05 1.95E-05 3.21E-01 6.14E-05 1.97E-05 3.21E-01 6.00E-05 238Pu Activity (Ci) 2.19E-04 1.11E-04 5.07E-01 2.26E-04 1.14E-04 5.04E-01 2.20E-04 239Pu Activity (Ci) 7.95E-03 2.67E-03 3.36E-01 8.18E-03 2.73E-03 3.34E-01 7.98E-03 240Pu Activity (Ci) 1.77E-03 6.12E-04 3.46E-01 1.82E-03 6.26E-04 3.44E-01 1.77E-03 242Pu Activity (Ci) 2.29E-07 1.40E-07 6.11E-01 2.36E-07 1.44E-07 6.10E-01 2.30E-07 241Am Activity (Ci) 7.58E-02 2.44E-02 3.22E-01 7.81E-02 2.52E-02 3.23E-01 7.67E-02 90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 8.91E+02 2.56E+02 2.87E-01 9.18E+02 2.63E+02 2.87E-01 9.01E+02 
F-6 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <

Reported Value Absolute Uncertainty 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 234U Activity (Ci) 1.98E-05 1.17E-05 1.99E-05 2.07E-07 1.04E-02 1.26E-03 1.00E238U Activity (Ci) 6.03E-09 1.95E-09 6.05E-05 5.90E-07 9.74E-03 3.66E+05 0.00E238Pu Activity (Ci) 2.21E-04 1.14E-04 2.21E-04 2.79E-06 1.26E-02 2.40E-03 1.00E239Pu Activity (Ci) 7.98E-03 2.76E-03 8.03E-03 9.14E-05 1.14E-02 4.38E-03 1.00E240Pu Activity (Ci) 1.77E-03 6.30E-04 1.78E-03 2.19E-05 1.23E-02 4.84E-03 1.00E242Pu Activity (Ci) 2.30E-07 1.42E-07 2.32E-07 2.70E-09 1.17E-02 1.45E-03 1.00E241Am Activity (Ci) 7.84E-02 2.56E-02 7.73E-02 1.03E-03 1.33E-02 6.49E-03 1.00E90Sr Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 137Cs Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 9.19E+02 2.67E+02 9.08E+02 1.16E+01 1.28E-02 7.59E-03 1.00E

Quantity of Interest t Pr(x <|t|) χ2 Test t Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable 234U Activity (Ci) -2.64E-01 8.05E-01 Not Significant Not Significant 238U Activity (Ci) -9.37E+01 7.79E-08 Highly Significant Highly Significant 238Pu Activity (Ci) -1.31E-01 9.02E-01 Not Significant Not Significant 239Pu Activity (Ci) -5.00E-01 6.44E-01 Not Significant Not Significant 240Pu Activity (Ci) -5.83E-01 5.91E-01 Not Significant Not Significant 242Pu Activity (Ci) -5.41E-01 6.17E-01 Not Significant Not Significant 241Am Activity (Ci) 1.01E+00 3.70E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A Not Applicable Not Applicable 137Cs Activity (Ci) N/A N/A Not Applicable Not Applicable TRU Alpha Conc. (nCi/g) 8.95E-01 4.22E-01 Not Significant Not Significant 
G-1 

ATTACHMENT G: DOSE-TO-CURIE CONTINUED COMPLIANCE INSPECTION 

CHECKLIST 

EPA Inspectors Present: Rose Gogliotti and Patrick Kelly 

Location of DTC: DTC occurs in Room 306 and observed by operators in Room 302

Location of Waste Storage: EDR Room 418

CCP-TP-504 Revision: Revision 13, September 17, 2012

Operators and Training Renewal Due: 

Lashall Adade DTC Operator/ITR due 6/2013 

Sway Andrews DTC Operator/ITR due 5/2014 

Mary Carroll DTC Operator/ITR due 4/2014 

 OSPREY Operator/ITR due 8/2014 

Chris Davis DTC Operator/ITR due 4/2014 

Crary Davis DTC Operator/ITR due 9/2014 

 OSPREY Operator/ITR due 10/2014 

Brent Dial DTC Operator/ITR due 4/2014 

 OSPREY Operator/ITR due 4/2014 

Spencer Pattee DTC Operator/ITR due 3/2014 

Dave Pinnock DTC Operator/ITR due 8/2013

EPA reviewed the logbook pages and found that all operators listed in the logbook have 

current training in LOQI dated May 7, 2013 

Scale No: 724422 Same as previously observed by EPA

Scale Calibration Due Date: June 21, 2013

Instrument No: 020555 with option to use 02558 (Thermo Geiger Mueller)

Instrument Calibration Due Date: January 8, 2014

Probe No.: XC060674 with option to also use Probe No: XC060675

Probe Calibration/Due Date: January 8, 2014

Probe Range: low range: 10 uR/hr–800 mR/h; high range: 800 mR/hr–1,000 R/hr

DSC Source No: Both high and low range 137Cs source INL-ID: CP-TCS001 (Manufacturer 

Serial # 181-64)

Source Activity: 744.9 Ci

Reference Date: May 1, 2010 

Operator Aide(s) Used: RH-DM-INL-003, Revision 2, November 29, 20/12 

RH-DM-INL-002, Revision 17, April 8, 2013 

Copies of both operator aids were posted in the DTC Control Area. EPA received copies of 

both forms. 

BDR No: Not yet assigned number. CCP will provide BDR to EPA when it is finalized.

Packaging Configuration: 55-gallon drum 

Container No: FC0100B-1
G-2 

Container Gross Wt: 65.0 kg

BKG: 0.018 mR/h

Dose Rate @ 0o

: 83.7 mR/h

Dose Rate @ 90o: 100 mR/h

Dose Rate @ 180o: 84.9 mR/h

Dose Rate @ 270o: 67.8 mR/h

Highest measured Dose Rate >3 x BKG: Yes

Dose Rate Average: 84.1 mR/h

Estimated Contact Dose Rate: >200 mR/h 
H-1 

ATTACHMENT H: NDE CONTINUED COMPLIANCE INSPECTION CHECKLIST: R

EPA Inspection No.: INL-CC-2013 Inspe

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Evidenc

RTR-1: Site procedures identify required training and qualifications for RTR 

personnel. 

CCP-TP-028, Revision 7 CCP-QP-002, Revision 26 

Operator training was consistent with applicable 

procedures. 

Operator certification is current. OJT was documented for each operator. Operators are requalified every two years. 

RTR operators passed a training drum test that includes items common to the waste streams examined at the site (biannually). RTR operators receive training on the waste matrix parameters and typical packaging configurations expected in each waste stream. 

CCP RTR training procedures and proinclude elements of OJT, required reaSome of the qualification cards reviewsigned by the SME, although a signatrequalification was a result of disqual

verified that no RTR operators had be

periods covered by the records review

Not Requiring a Response, INL-CCP-

issue. Qualified operators are required to su

test every six months in order to main

Training containers include all require

are typical for the waste streams being reviewed the inventories for three traithe waste items in them were almost i

reviewed the contents of Container N

top layer of waste to be almost identic

positioning. EPA generated a Concern 

CCP-CC-2013-02CR, to address thesObjective evidence:

1. Selected LOQIs, dated between J2. Training drum inventories, Conta3. Qualification records for selected 4. CCP AK training attendance shee5. EPA Concern Not Requiring a R

01C. 

6. EPA Concern Requiring a Respo

02CR. 

7. CCP-QP-002, Revision 26, CCP 

Plan. 

RTR-2: Site procedures provide complete instructions for operators to perform the 

CCP-TP-508, Revision 7, section 4.0 

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

INL-CCP demonstrated the RTR proc

FCO100B-1 from BDR No. INLRHRdemonstration, the operator had alreadquality test required by the procedure 

properly examined the container’s con
H-2 

EPA Inspection No.: INL-CC-2013 Inspe

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Evidenc

RTR examination and completion of the associated documentation. 

characterization data into the electrondetermined that the waste matched the verified the WMC. No prohibited item

After the demonstration, EPA revieweand determined that they had been com

by the RTR operator. EPA did not ide

RTR demonstration. Objective evidence:

1. RTR measurement control report 

2. Completed data sheets for Contai3. BDR Nos. INLRHRTR13001, IN

INLRHRTR13004. 

4. Audio/visual recordings for selec

5. CCP-TP-508, Revision 7, CCP R

Radiography Inspection Procedur

RTR-3: The RTR procedures require an image quality check to be performed. 

CCP-TP-508, Revision 7, section 4.2.3, Attachment 1 

Operator adequately explained how the acceptability of an image is determined. Image quality check is performed once per day. Performance of the image quality check is documented and recorded.

EPA reviewed image quality check reINLRHRTR13001, INLRHRTR1300determined these records to be complas required by the procedure. Objective evidence:

1. RTR measurement control report 

2. BDR Nos. INLRHRTR13001, IN

INLRHRTR13004. 

3. CCP-TP-508, Revision 7, CCP R

Radiography Inspection Procedur

RTR-4: The procedure allows the operator to adjust the RTR to accommodate the 

physical properties of the 

waste and waste containers likely to be encountered at the site. 

CCP-TP-508, Revision 7, section 4.3 

Operator could identify applicable policies and 

procedures governing the operation of RTR 

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

EPA inspectors observed the complet

Container No. FCO100B-1. The oper

equipment to obtain the clearest imag

accurate identification of those items. during the onsite visit, and those in th

present any challenges that prevented 

waste items in the subject containers. Objective evidence:

1. BDR Nos. INLRHRTR13001, IN

INLRHRTR13004. 

2. Completed data sheets for Contai

3. CCP-TP-508, Revision 7, CCP R
H-3 

EPA Inspection No.: INL-CC-2013 Inspe

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Evidenc

Radiography Inspection Procedur

RTR-5: Data records are of sufficiently high quality for complete review. 

CCP-TP-508, Revision 7, section 4.3, Attachments 1 & 2 

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

package for the same drum. 

EPA reviewed the audio/visual recordBDR Nos. INLRHRTR13001, INLRHINLRHRTR13004 to ensure that the rof high quality, on both the audio and 

recordings. EPA did not identify any 

Objective evidence:

1. BDR Nos. INLRHRTR13001, IN

INLRHRTR13004. 

2. Audio/visual recordings for conta

INLRHRTR13001, INLRHRTR1

3. CCP-TP-508, Revision 7, CCP R

Radiography Inspection Procedur

RTR-6: There is a procedure for determining whether the waste matches the waste stream description and waste matrix code, and for determining waste material parameters and weights. 

CCP-TP-508, Revision 7, section 4.3.3, Attachment 2 

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

previous RTR/VE exams or updated AK 

information? 

The operator followed written proced

execution of the demonstration exami

and recorded WMPs and verified the Procedure CCP-TP-508 does not inclu

waste items, and the operator uses his to make these determinations. Objective evidence:

1. Data sheets for containers in BDR 

INLRHRTR13003 and INLRHR

2. Audio/visual recordings for conta

INLRHRTR13001, INLRHRTR1

3. CCP-TP-508, Revision 7, CCP R

Radiography Inspection Procedur

RTR-7: The RTR procedure 

provides instructions for 

identifying prohibited items and for processing drums containing 

prohibited items. 

CCP-TP-508, Revision 7, section 4.3.3, Table 1 CCP-QP-005, Revision 22 

Operator could name prohibited items. Operator adequately explained how the 

presence of free liquids is determined. 

Operator’s explanation of required actions if 

prohibited items were encountered was 

consistent with procedure. 

There were no prohibited items found 

BDRs reviewed as part of this inspect

identified in the demonstration contai

has clear and complete instructions foand how these items are processed wh

508 identifies and lists prohibited item

NCR-RHINL-0430-13 was written by 

discrepancy between the independent 
H-4 

EPA Inspection No.: INL-CC-2013 Inspe

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Evidenc

Corrective actions are taken when necessary. certification scan for a container from 

The NCR was properly processed and CCP procedures. Objective evidence:

1. BDR Nos. INLRHRTR13001, IN

INLRHRTR13004. 

2. Audio/visual recordings for conta

INLRHRTR13001, INLRHRTR1

3. NCR-RHINL-0430-13. 

4. CCP-TP-508, Revision 7, CCP R

Radiography Inspection Procedur

5. CCP-QP-005, Revision 22, CCP 

Reporting and Control. 

RTR-8: RTR procedures include the required QC examinations, evaluation, accuracy and reproducibility of the RTR 

process. 

CCP-TP-508, Revision 7, sections 4.4 & 4.5 

An independent replicate scan is performed on one waste container per day or on one container 

per testing batch (whichever is less frequent). 

An independent observation of one scan (not the replicate) is performed by a qualified RTR operator (anyone but the initial RTR operator). 

A replicate scan and independent obse

for the BDRs reviewed. An NCR was observation in batch INLRHRTR1300container had not been recorded. This 

time of the onsite inspection. The QC 

requirements for all BDRs reviewed. Objective evidence:

1. BDR Nos. INLRHRTR13001, IN

INLRHRTR13004. 

2. NCR-RHINL-0430-13. 3. CCP-TP-508, Revision 7, CCP R

Radiography Inspection Procedur

RTR-9: Procedures contain standardized forms for recording RTR data. 

CCP-TP-508, Revision 7, Attachment 2 

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

by the RTR operator using a computer while the 

operator is still in the RTR booth. The electronic data file undergoes the same QC checks used for hand-written data entries. 

The operator entered waste items into 

they were identified during the onsite assigned to each item at this time. The 

presence of free liquids and other proh

examination. Objective evidence:

1. Written data sheets for BDR Nos

INLRHRTR13003 and INLRHR

2. Completed data sheets for Contai3. CCP-TP-508, Revision 7, CCP R

Radiography Inspection Procedur
H-5 

EPA Inspection No.: INL-CC-2013 Inspe

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Evidenc

RTR-10: Site procedures require review of BDRs at the data generation and 

project level. 

CCP-TP-508, Revision 7, section 4.10, Attachments 3 (ITR) & 4 (SPM) 

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

EPA reviewed written BDRs as part ofound that they had been reviewed at 

project levels as required by the proce

checklists had been completed and sigObjective evidence:

1. BDR Nos. INLRHRTR13001, IN

INLRHRTR13004. 

2. CCP-TP-508, Revision 7, CCP R

Radiography Inspection Procedur
I-1 

ATTACHMENT I.1: NDE CONTINUED COMPLIANCE INSPECTION CHECKLIST: C

EPA Inspection No.: INL-CC-2013 Inspe

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Evidenc

VE-1: Site procedures identify required training and qualifications for VE 

personnel. 

CCP-QP-002, Revision 34 

VEE’s explanation of job duties was consistent with applicable procedures. VE personnel’s training was consistent with applicable procedures. VE personnel’s certification is current. VE personnel are requalified every two years. VE personnel received training on specific waste generating processes, typical packaging configurations and WMPs expected to be found in each WMC. 

CCP VE training procedures and proc

include elements of OJT, required reaqualification cards reviewed showed the VEE although a signature was onwas a result of disqualification of an VE operators had been disqualified d

by the records reviewed. EPA genera

Response, INL-CCP-CC-2013-01C, tThe EPA inspector reviewed objectivreceived training about the waste streat the site. 

Objective evidence:

1. Initial qualification and requalific

operators /ITRs. 

2. Selected LOQIs, dated between J

3. CCP attendance sheets for VE pe

training. 

4. CCP-QP-002, Revision 34, CCP 

Plan. 

5. VEE appointment letters dated be

VE-2: Procedures and technical guidance documents 

provide complete 

instructions for 

performing VE. 

CCP-TP-006, Revision 17 

The site uses AK to identify the waste matrix code category and to estimate waste material 

parameters present. 

Procedures are sufficiently detailed to enable the operator to determine if a waste container meets the criteria of 194.24 with regard to identifying applicable parameters with waste limits. Establish standard nomenclature, based on current site practice, so that all staff recognize waste by the same descriptors. 

CCP-TP-006 is well established and h

numerous occasions. Table 4 of the p

Historical Weights and Weighing Co

that are used by VE personnel when r

Attachment 1, Waste Visual Examina

detailed and requires operators to rec

segregate prohibited items and verify 

that all required information had been in the BDRs reviewed. Objective evidence:

1. BDR Nos. IN-ARP-VE-002792, 

IN-SRP-VE-000120. 

2. CCP-TP-006, Revision 17, CCP V

for Idaho National Laboratory (INWaste Retrieved from Pits. 
I-2 

EPA Inspection No.: INL-CC-2013 Inspe

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Evidenc

VE-3: VEE has overall responsibility for VE. 

CCP-TP-006, Revision 17, section 3.1

Evaluates and resolves any VE Technician questions. Approves Attachment 4, CCP Waste VE Technique Batch Data Report Cover Sheet. Evaluates the need for additional training.

The waste used to demonstrate the V

sludge from RFP. The receiving drum IN-SRP-VE-000175) and the waste sDuring the onsite demonstration, the the glove box was performed by CW

operators performing the VE and reco

The VEE was available to the operatogeneration. EPA obtained the data shonsite demonstration and verified thaand accurately recorded. EPA inspectoperators and VEE were currently quObjective evidence:

1. BDR Nos. IN-ARP-VE-002792, 

IN-SRP-VE-000120. 

2. VEE appointment letters dated be

3. Completed data sheets for demon4. Initial and requalification records 

operators/ITRs. 

VE-4: Checks are performed 

before the start of VE. 

CCP-TP-006, Revision 17, sections 4.1.5–4.1.8

VEO performs scale checks. Empty container is weighed. Verifies that the container is empty. 

Any necessary scale checks had been observation of operations. EPA verifi

currently calibrated by review of caliinspectors observed the receiving con

prior to waste loading. 

Objective evidence:

1. BDR Nos. IN-ARP-VE-002792, 

IN-SRP-VE-000120. 

2. Calibration certificates for scales 

VE-5: There is a procedure for handling instances when the VE Expert is unable to see through the inner 

plastic bags/packages/containers 

of waste. 

CCP-TP-006, Revision 17, 

section 4.2

The VEE has decision-making criteria for assessing the need to open the bags/packages in order to identify all of their contents. Two VE operators perform VE. If the bags are not opened, a brief written description of the contents of the bags is 

prepared with estimates of the amount of each 

waste type in the bags.

The waste used to demonstrate the VE sludge from RFP. The receiving drum IN-SRP-VE-000175) and the waste sDuring the onsite demonstration, the the glove box was performed by CWI 

operators performing the VE and reco

The VEE was available to the operatogeneration. EPA obtained the data shonsite demonstration and verified thaaccurately recorded. EPA inspectors 
I-3 

EPA Inspection No.: INL-CC-2013 Inspe

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Evidenc

and VEE were currently qualified. 

Objective evidence:

1. Completed data sheets for demon2. BDR Nos. IN-ARP-VE-002792, 

IN-SRP-VE-000120. 

3. Selected LOQIs, dated between J

4. VEE appointment letters dated be

VE-6: The VE procedure requires verification of WMC and WMP weights. 

CCP-TP-006, Revision 17, Attachment 1 

VE operators complete Attachment 1, Visual Examination Technique Data Form, and 

personnel could navigate through the various 

screens. A VE data form is used to document the waste matrix code and estimated WMP weights of the waste (CCP-TP-006, Table 3). VE staff have access to standardized charts or tables to aid in the consistent estimation/assignment of weights, waste material parameters, and waste matrix codes (CCP-TP-006, Table 4). The estimated or weighed WMP weights are determined by compiling an inventory of waste items, residual materials and packaging materials.

During the onsite demonstration, the the glove box was performed by CWoperators performing the VE and reco

The VEE was available to the operatogeneration. EPA obtained the data shonsite demonstration and verified thaaccurately recorded. Table 4 of procedure CCP-TP-006 cowaste items frequently found in the wObjective evidence:

1. BDR Nos. IN-ARP-VE-002792, 

IN-SRP-VE-000120. 

2. Completed data sheets for demon

VE-7: Procedure provides instructions for 

processing of containers 

with prohibited items. 

CCP-TP-006, Revision 17, sections 4.2–4.3, Attachment 1, Table 1 

VEE/VEO expert could name prohibited items. VEE/VEO explanation of required actions if 

prohibited items were encountered was 

consistent with procedure. The VEO describes any liquids found, including a description of their location in the container and estimated volume. Other prohibited items, including sealed containers, are identified and segregated. 

Table 1 of procedure CCP-TP-006 id

There were no prohibited items ident

demonstration. A VE operator perforexamination stated that oil dry is add

present. The area of the glove box set 

items was visible to the EPA inspecto

There were no prohibited items identnor during the demonstration of the VObjective evidence:

1. BDR Nos. IN-ARP-VE-002792, 

IN-SRP-VE-000120. 

2. Completed data sheets for demon
I-4 

EPA Inspection No.: INL-CC-2013 Inspe

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Evidenc

VE-8: Operators follow the 

procedure. 

Operators initiate corrective action when necessary. 

CCP-TP-006, Revision 17

The procedure is adequately implemented. Corrective actions are taken when necessary. 

EPA did not identify any issues for thBDRs were complete and contained c

container. There were no NCRs generated for th

Objective evidence:

1. BDR Nos. IN-ARP-VE-002792, 

IN-SRP-VE-000120. 

VE-09: Site procedures require data generation and 

project-level reviews of 

BDRs. 

CCP-TP-006, Revision 17, Attachments 2–4

CCP-TP-001, Revision 20 

BDRs contain all required information. Data generation and project-level reviews are complete. 

The BDRs reviewed by EPA had beelevel and project level as required by were complete and contained charactcontainer. Objective evidence:

BDR Nos. IN-ARP-VE-002792, IN-AIN-SRP-VE-000120. 
I-5 

ATTACHMENT I.2: NDE CONTINUED COMPLIANCE INSPECTION CHECKLIST: R

EPA Inspection No.: INL-CC-2013 Inspe

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Evidenc

RHVE-1: Site procedures identify required training and qualifications for RH VE 

personnel.

CCP-QP-002, Revision 34 

Formal training elements include: project requirements, container identification and labeling, and applicable state and federal regulations. Site-specific training program: OJT, identification of summary category groups, WMPs, packaging configurations and residual liquids. 

INL-CCP VE training procedures and 

and include elements of OJT, require

Objective evidence:

1. Selected LOQIs, dated between J

2. Qualification records for selected 3. CCP AK training attendance she

4. CCP-QP-002, Revision 34, CCP 

Plan. 

RHVE-2: Operator qualification and requalification requirements are described. 

CCP-QP-002, Revision 34, section 4.3.8

To become qualified, the RH VE operator must 

pass a comprehensive written test based on 

training objectives with a minimum score of 80%. Demonstrate capability in the presence of the site VEE during OJT. RH VE operators requalified every two years 

based on continued satisfactory performance. 

Unsatisfactory performance: failed to identify 

prohibited item during OJT or score of less 

than 80% on exam. 

EPA inspectors reviewed initial and roperators and VEEs. Some of the qualification cards review

been signed by the VEE although a si

requalification was a result of disqualverified that no VE operators had bee

periods covered by the records review

Not Requiring a Response, INL-CCP

issue. Objective evidence:

1. Initial qualification and requalifi

operators. 

2. INL-CCP attendance sheets for V

training. 

3. EPA Concern Not Requiring a R

01C. 

RHVE-3: Each site has a designated VEE. 

CCP-QP-002, Revision 34, section 4.4.1CCP-PO-001, Revision 21 

VEE designation is documented. VEE has knowledge of the RH TRU waste 

being characterized. 

Responsible for overall direction and implementation of VE at the facility. Certification plan specifies the selection, qualification and training requirements of VEE. 

CCP had designated VEEs, and EPA for some of those VEEs. VEE designcorrect and current. 

Objective evidence:

1. VEE appointment letters dated bet

2. Selected LOQIs, dated between Ju
I-6 

EPA Inspection No.: INL-CC-2013 Inspe

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Evidenc

RHVE-4: Procedures and technical guidance documents 

provide complete 

instructions for 

performing RH VE. 

CCP-TP-500, Revision 11, sections 4.1–4.2, Attachment 1 

All existing VE tapes will be reviewed and the VE data will be documented. Existing waste container packaging records will be qualified by VE or RTR. 100% of containers will be subject to VE at the time of packaging. Waste stream description and WMC verified. Presence/absence of prohibited items confirmed. Two operators used even if audio/visual recording of VE is generated. 

VE is performed by two operators wiINL-CCP demonstrated the VE proceANLE3D-3, BDR No. INLRHVE130the items subjected to VE during the 3D. This container had an unacceptab

the VE activity was to separate the th

separate 30-gallon containers. The thas ANLE3D-1, ANLE3D-2 and ANL

personnel for this examination consis

one VEE, who completed the require

overseeing the process. CWI personnwaste in the glove box. The operators 

items were present and that the waste description and WMC. Objective evidence:

1. VE data form for Container No. A

INLRHVE13001 (demonstration c

2. BDR Nos. INLRHVE11002, INLR

INLRHVE12001. 

RHVE-5: Corrective actions are taken when necessary. 

CCP-TP-500, Revision 11, section 2.4.2 

Operators were able to describe how they initiate a corrective action. 

No NCR reports were generated for t

inspectors reviewed qualification recwhich included CCP’s Nonconformin

procedure (CCP-QP-005). 

RHVE-6: Site procedures require data generation and 

project-level reviews of 

BDRs. 

CCP-TP-500, Revision 11

ITRs review Attachment 2. SPMs review Attachment 3. 

All of the BDRs reviewed by EPA hageneration (ITR) and project (SMP) lhad been completed and signed as reqObjective evidence:

1. BDR Nos. INLRHVE11002, INL

INLRHVE12001. 

RHVE-7: Records are available for review. 

CCP-TP-500, Revision 11, section 5.0

Lifetime/QA records – Attachments 1–5, Copy of NCRs. QA/nonpermanent records – VHS tape or DVD (primary and backup). 

INL-CCP was able to provide to EPA 

was performed using two operators, awere made for the BDRs reviewed an

on site. Objective evidence:

1. BDR Nos. INLRHVE11002, INL
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EPA Inspection No.: INL-CC-2013 Inspe

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Evidenc

INLRHVE12001. 

2. VEE appointment letters dated b

3. Selected LOQIs dated between J

4. Initial qualification and requalifi

operators. 

5. CCP attendance sheets for VE pe

training. 

RHVE-8: Quality assurance objectives are defined and met. 

40 CFR Part 194.22(b) 

Data Accuracy: 

194.22(b)(1) the degree to which data agree 

with an acceptable reference or true value. WCPIP: maintained by requiring operators to 

pass a comprehensive test with a score of 80% 

and demonstrated satisfactory performance for initial qualification and requalification. 

Data Precision: 

194.22(b)(2) a measure of the mutual 

agreement between comparable data gathered or developed under similar conditions expressed in terms of a standard deviation. WCPIP: maintained by reconciling any 

discrepancies between 2 operators (or operator and ITR) with regard to physical form of waste, absence of residual liquid. 

Data Representativeness: 

194.22(b)(3) the degree to which data 

accurately and precisely represent a characteristic of a population, a parameter, variations at a sampling point, or environmental conditions. WCPIP: contents placed in a container will be 

described on the data forms. 

Data Completeness: 

194.22(b)(4) a measure of the amount of valid 

Data Accuracy & Comparability: 

Qualification and requalification reco

demonstrate that operators pass a com

examination as required by the WCP

procedure CCP-QP-002. Data Precision: 

Two operators perform VE and concudata forms. This is evidenced by the o

Data Representativeness & Complete

EPA determined that all waste items 

EPA verified this by review of selectthe onsite demonstration of VE operaObjective evidence:

1. BDR Nos. INLRHVE11002, INL

INLRHVE12001. 

2. CCP-QP-002, Revision 34, CCP 

Plan. 

3. Initial qualification and requalifi

operators. 
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EPA Inspection No.: INL-CC-2013 Inspe

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Evidenc

data obtained compared to the amount that was expected. WCPIP: relevant waste information must be collected and documented on a videotape and/or data form or other unalterable media. 

Data Comparability: 

194.22(b)(5) a measure of the confidence with which one data set can be compared to another. WCPIP: ensured by site meeting training 

requirements and complying with the minimum standards used to implement VE. 
J-1 

ATTACHMENT J: EPA INSPECTION ISSUE TRACKING FORM, 

ISSUE NO. INL-CCP-CC-2013-01C, FINAL

Inspection No. INL-CC-2013 Issue Number: INL-CCP-CC-2013-01C 

Date: May 8, 2013, Final 

Inspector: D. Gill 

Attachments? YES NO 

Sample Size: 14 qualification records 

Population size (if known): Unknown 

A. Description of Issue: For both RTR and VE, personnel qualification records for Onthe-Job Training (OJT) marked as “Requalification” are not required to be signed by the 

VEE/SME unless the requalification is a result of disqualification of the operator. Seven of the 

fourteen records reviewed had been signed by the VEE/SME attesting that the requalification 

was a result of operator disqualification. Telephonic interview of CCP training records 

personnel reveal that none of the subject operators had actually been disqualified for the dates 

listed on the requalification records. 

EPA requests that INL-CCP consider this concern and evaluate it with an eye towards 

ensuring that training records accurately reflect the continued qualification status of all VE and 

RTR personnel. 

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable 

D. Discussed with: I. Joo, M. Pinzel, J. Vernon, W. Verlanic, E. Gulbransen 

E. Additional Comments: EPA requests that CCP address this issue for all active TRU 

waste characterization sites.

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: Not applicable 

X

X
K-1 

ATTACHMENT K: EPA INSPECTION ISSUE TRACKING FORM, 

ISSUE NO. INL-CCP-CC-2013-02CR, FINAL

Inspection No. INL-CC-2013 Issue Number: INL-CCP-CC-2013-02CR 

Date: May 9, 2013, Final 

Inspector: D. Gill 

Attachments? YES NO 

Sample Size: 3 RTR Training Containers 

Population size (if known): Unknown 

A. Description of Issue: RTR training Container Nos. 17, 21 and 25, assembled on 

01/10/2012, 08/15/2012, and 04/02/2013 respectively, contained the same waste items. The 

only exception was that Container Nos. 21 and 25 contained a “plastic bag with horsetail” 

while Container No. 17 did not. A cursory review of RTR tapes for Container Nos. 21 and 25 

indicates that waste items in both drums are in the same positions and relative orientations. 

Because the contents of the training containers are known, they are the only objective test of 

an RTR operator's competency. EPA requests that INL-CCP consider adding different, varied, 

discretionary waste items and varying their positions in training drums to provide a process 

improvement and enhanced level of operator skills testing. EPA requests that INL-CCP 

evaluate this concern and ensure that RTR containers constitute a rigorous test of RTR 

operators’ skills. 

EPA wrote a similar concern at INL-CCP on May 9, 2012, while reviewing an RH Tier 1 

change for Lot 2 (INL-CCP-RH-RTR-2012-01C, Final). 

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable 

D. Discussed with: I. Joo, J. Vernon, W. Verlanic, E. Gulbransen, A. Stallings 

E. Additional Comments: EPA requests that CCP address this issue for all active TRU 

waste characterization sites.

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: May 30, 2013 

X

X