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

WASTE CHARACTERIZATION INSPECTION

CONTINUED COMPLIANCE REPORT

EPA INSPECTION OF THE CENTRAL CHARACTERIZATION PROJ ECT

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 Spectromete r...................... 17

6.2.2 Technical Evaluation: Stored Waste Examination Pilo t 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 Wa ste Characterization Processes

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

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

Table 2. Tiering of Remote-Handled Transuranic Was te 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 In spection

Attachment C Inspection Personnel

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

Attachment D.2 AK Continued Compliance Inspection C hecklist: Waste Stream

ID-RF-S5300-A

Attachment D.3 AK Continued Compliance Inspection C hecklist: Waste Stream

ID-SDA-SOIL

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

Attachment D.5 AK Continued Compliance Inspection C hecklist: 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 ARP7 0420 – SGRS

Attachment F.2 Replicate Testing Data for Drum SRP1 3045 – SGRS

Attachment F.3 Replicate Testing Data for Drum ARP7 0259 – SGRS

Attachment G Dose-to-Curie Continued Compliance Ins pection Checklist

Attachment H NDE Continued Compliance Inspection Ch ecklist: 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, Is sue No. INL-CCP-CC-2013-01C,

Final

Attachment K EPA Inspection Issue Tracking Form, Is sue 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 Facili ty

INEL Idaho National Engineering Laboratory

INL Idaho National Laboratory

INTEC Idaho Nuclear Technology and Engineering Cent er

ITR independent technical review

keV kilo electron volt

kg kilogram

La lanthanum

La 3 

# Br(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 Protect ion Agency’s (EPA’s) determination that the

waste characterization program at the U.S. Departme nt 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 transuran ic (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 complia nce inspection of the site’s program to

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

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

activities:

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

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

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

Gamma-Ray Spectrometer (SGRS) and the Super High Ef ficiency 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 i nspection, EPA confirms that the INL-CCP

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

inspection are consistent with the limitations desc ribed 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) ap provals. 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) desig nations:

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 chara cterization 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) an d Site Project Mangers (SPMs)

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

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

characterization programs.

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

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

reporting practices. EPA also revised the tiering t ables 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 in itiated during the CH and RH baseline and

subsequent T1 approvals remain in effect. The langu age 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-mandat ed 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 acti ve, EPA-approved TRU waste site. The

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

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

characterization elements are personnel training, p rocedures and equipment capabilities. EPA

will evaluate these elements during T1 change evalu ations 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 characteriz ation program.

This streamlined approach allows EPA to consider th e results of continued compliance

inspections when setting the scope and evaluating s ite-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 2 014). 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 throu gh the EPA website and by sending emails to

the WIPPNEWS list, in accordance with 40 CFR 194.8( b)(3).3Table 1.Tiering of Contact-Handled Transuranic Waste Characterization Processes Implemented by INL-CCP(Based on May 3–5, 2005, Baseline Inspection and Subsequent Evaluations, Updated July 2013)Process ElementsINL-CCP CH Waste Characterization Processes – T1 ChangesINL-CCP CH Waste Characterization Processes – T2 Changes*Acceptable Knowledge,including LoadManagementAny new waste categoryChanges to the accelerated retrieval project targeted wastes fromwhat was presented in CCP-AK-INL-001, Revision 7Notification to EPA upon completion of or substantive modification** to:•AK-NDA memoranda•AK accuracy reports (annually, at a minimum)•AK-AK and AK-NDA/NDE discrepancy resolution reports•WSPFs, including updates or additions to waste streams within anapproved waste category•New and revised AK summary reports•The load management status of approved waste streams•Site procedures requiring CBFO approval•Any analysis evaluating effectiveness of the WasteIdentificationProcessSubmission of a list of active INL-CCP CH AKEs andSPMsNondestructive Assay New equipment or substantive physical modifications** to approvedequipmentExtension of or changes to approved calibration range for approvedequipmentNotification to EPA upon substantive modification**to:•Software for approved equipment•Operating ranges upon CBFO approval•Site procedures requiring CBFO approvalReal-Time Radiography NoneNotification to EPA upon:•Substantive modification** to site procedures requiring CBFO approval•New equipment or substantive physical modifications** to approvedequipmentVisual Examination andVisual ExaminationTechniqueChanges in the vendor performing visual examinationor visualexamination techniqueNotification to EPA upon substantive modification**to site proceduresrequiring CBFO approvalWIPP Waste DataSystemChanges to WDS algorithms specific to load management requiringrevisions to the load management provisions of DOE’s CH WACNotification to EPA upon substantive modification**to:•Site procedures requiring CBFO approval•WDS algorithms corresponding to changes to the loadmanagementprovisions of the CH WACNew T1s, T2s and significant modifications to existing T1s or T2s are inboldtext; T1s or T2s that were only revised for styleare not shown in bold.* 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 documentation of them, excluding changes thatare solely related to the environment, safety and health; nuclear safety; or the Resource Conservationand Recovery Act; or that are editorial in natureor are required toaddress administrative concerns. EPA may request copies of new references that DOE adds during a document revision.4Table 2. Tiering of Remote-Handled Transuranic Waste Characterization Processes Implemented by INL-CCP(Based on June 12–16 and August 9 and 26, 2006, Baseline Inspection and Subsequent Tier 1 Evaluations,Updated July 2013)Process ElementsINL-CCP RH Waste Characterization Process – T1 ChangesINL-CCP RH Waste Characterization Process – T2 Changes*Acceptable KnowledgeAny new waste stream not approved under the baselineAddition of containers to approved waste streams ifnew or differentradionuclide scaling factors are requiredSubstantive modification** to AKSRs and certification confirmationtest plans (e.g., CCP-AK-INL-500, CCP-AK-INL-502)Load management for any RH waste streamNotification to EPA upon availability or nonsubstantivemodification** of AKSRs and certification confirmation test plans(e.g., CCP‐AK‐INL-500, CCP-AK-INL-502)Notification to EPA upon availability or modification of:•CCP-TP-005, Attachment 4 that reflects the updatedAKSRSource Document Reference List•The WSPF or WSPF change notice; current related attachments,including the CRR, CIS and Summation of Aspects, should beprovided with each requested WSPF•AK accuracy reports (annually, at a minimum)•Discrepancy resolution reports and nonconformance reports•AK documentation as a result of Waste CharacterizationProgram Implementation Plan revisions (e.g., CRR)•Correlation or surrogate summary forms for each ofthe RHcontainers in this waste stream identified as contact-handled,based on measured dose rates that present nondestructive assayresults for assayed containersSubmission of a list of active INL-CCP RH AKEs andSPMsNotification to EPA of the intention to add containers to anapproved waste stream, including the approximate number ofcontainers and volume of waste, the timeframe for waste generation,characterization, and disposal and submission of anupdated AKSRdocumenting that the pedigree of the additional containers is thesame as those covered by the baseline or subsequentT1approvals***Submission of a list of fully characterized containers from apopulation of additional containers proposed as a T2 change,above***Radiological Characterization,including Dose-to-CurieAny new waste stream not approved under the baseline or subsequentT1 evaluations or addition of containers to an approved waste streamthat requires changing the established radionuclidescaling factorsUse of any alternate radiological characterizationprocedure other thanDTC with established scaling factors as documentedin CCP-TP-504Use of any alternate gamma detector with the OSPREYTM systemNotification to EPA upon nonsubstantive** modification ofprocedures or radiological technical reports (e.g.,CCP-TP-504,CCP‐AK‐INL‐501) requiring CBFO approvalSubmission of an updated radiological technical report (e.g., CCPAK-INL-501) documenting that the radiological characterizationprocesses used for the additional containers is thesame as those5Process ElementsINL-CCP RH Waste Characterization Process – T1 ChangesINL-CCP RH Waste Characterization Process – T2 Changes*characterization procedure other than the La3Br(Ce) detector observedin July 2010Application of new (i.e., not EPA-approved) scalingfactordevelopment processes for isotopic determination (applies to new RHwaste streams and to the addition of containers toan approved wastestream)Substantive modification** to EPA-approved procedures orradiological characterization technical reports (e.g., CCP-TP-504,CCP-AK-INL-501)covered by the baseline or subsequent T1 approvals***Submission of BDRs or calculation packagesfor containers selectedby EPA from a list of fully characterized containers provided byINL-CCP***Visual Examination Visual examination by any new process for SCG S3000, S4000 orS5000 waste.Visual examination by review of existing audio/visual recordings forSCG S3000 or S4000 waste.Notification to EPA upon substantive modification**to siteprocedures requiring CBFO approvalSubmission of BDRs for containers selected by EPA from a list offully characterized containers provided by INL-CCP***Real-Time Radiography Any new debris waste stream or waste from SCG S3000 or S4000Addition of any new RTR unitsNotification to EPA upon substantive modification**to siteprocedures requiring CBFO approvalSubmission of BDRs for containers selected by EPA from a list offully characterized containers provided by INL-CCP***WIPP Waste Data System NoneNotification to EPA upon substantive modification**to siteprocedures requiring CBFO approvalNew T1s, T2s and significant modifications to existing T1s or T2s are inboldtext; T1s or T2s that were only revised for styleare not shown in bold.* 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 documentation of them, excludingchanges that are solely related to the environment,safety and health; nuclear safety; or the ResourceConservation and Recovery Act; or that are editorial innature or are required to address administrative concerns. EPA may request copies of new references that DOE adds during a document revision.*** 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 th e 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 4 2571–42583, 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 a pplicable 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 auth ority to conduct continued compliance

inspections to verify that the site (1) continues t o 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 an d approve changes, if necessary, to the site’s

approved waste characterization program by conducti ng 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 wa stes. Specifically, this report:

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

this inspection.

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

was approved during the baseline inspection and oth er subsequent EPA T1 evaluations

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

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

waste characterization systems.

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

their relevance to EPA’s approval decision.

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

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

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 i ncluded 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 a nd subsequent T1 evaluations. Waste

characterization activities evaluated included AK f or CH Waste Streams ID-RF-S3114, ID-RF-

# 7



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

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

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

category groups (SCGs) and VE operations for multip le 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 con tacted represented a sample of the CH and RH

TRU waste characterization staff. The EPA inspectio n 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 examina tion (NDE), consisting of RTR and VE.

EPA completed inspection checklists based on respon ses 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 concu rring with quarterly T2 change

submissions, EPA may use these checklists to supple ment their review.

6.1 Acceptable Knowledge

6.1.1 Contact-Handled Waste Streams

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

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

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

EPA selected one waste stream from each approved SC G (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 t imes (EPA Docket Nos. A-98-49; IIA4-67, A-98-49; II-A4-112 and A-98-49; II-A4-142) a nd therefore focused this continued

compliance inspection on changes to the waste strea m 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 t heir 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 acc eptable knowledge documentation,

training of Acceptable Knowledge Experts and dispos ition of nonconformances were

examined and found to be adequate.

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

of nonconformances for technical sufficiency and sc ope. 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 o f the required documentation, as reviewed

below.

Notification to EPA upon completion of or substanti ve modification to site procedures requiring

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

(2) The acceptable knowledge characterization process f or containers, including acceptable

knowledge assembly, compilation and verification, w as adequately implemented.

EPA evaluated INL-CCP’s completion of each of the 1 5 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 at tachment 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 o bserved CCP’s diligence in revising the

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

revised. EPA will continue monitoring use of approp riate 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 re cord but the Attachment 4 had not been

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

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

complete and accurate. EPA will continue to check A ttachment 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 contain ers are traceable from their Rocky Flats

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

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

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

by INL-CCP. However, through use of the Waste Inven tory 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 asses sed 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 suppo rt the following statements:

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

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

• All waste within the waste stream has similar radio logical 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 nucl ear fuel. 2



# EPA found each AKSR to be adequate. Explanations an d 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 summariz es 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 tierin g 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 completen ess were evaluated and found to be

adequate.

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

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

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

adequate.

(6) Acceptable knowledge personnel training was assesse d 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. IN L-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 qual ification 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 inspect ion.

2 

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

Act of 1982.”

# 10



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

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

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

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

EPA of a list of AKEs and SPMs who performed work i n 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 documenta tion was assessed and found to

be adequate.

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

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

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

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

each sample waste stream and found them to be adequ ately prepared.

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

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

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

and found them to be adequate.

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

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

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

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

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

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

for. This appears to have been a one-time issue wit h 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 t he position that INL-CCP should consider

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

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

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

Notification to EPA upon completion of or substanti ve modification to AK accuracy reports

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

(9) Communication between acceptable knowledge and nond estructive 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 memoran da with the AKSRs. The AK-NDA

memoranda for Waste Streams ID-RF-S3114 and ID-RF-S 5300-A have not been updated since

# 11



# 2007 and 2005, respectively. EPA found that the lev el 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. E PA 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 c ompliance evaluation, EPA stated that, “if

information regarding the in-growth of [americium-2 41 ( 241 

# Am)] 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 241 

# Am to be

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

explaining that the data are not decay corrected an d therefore 241 

# Am values will be higher than

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

241 

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

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

if 241 

# Am and plutonium-241 ( 241 

# Pu) values were decay corrected, the difference doe s not impact

the final assay values. There are two reasons for t his:

(1) In the case of Waste Stream ID-SDA-SOIL and all oth er 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 we apons-grade Pu (WG Pu), highly

enriched uranium (HEU) and depleted uranium (DU), n ot based on AK-derived values.

(2) 241 

# Am is either detected and measured by the NDA equip ment 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 241 

# Am ingrowth is incorporated as appropriate.

Notification to EPA upon completion of or substanti ve 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 ma nagement such that a payload container

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

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

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

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

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

radioassay system used to characterize the waste, a nd 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 per forms 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-R F-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 m anagement 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 substa ntive modification to the waste-streamspecific documents listed below is required on a qu arterly basis. EPA compared the revision

dates of documents provided during this continued c ompliance inspection with the T2

notification reports provided to EPA by CBFO. EPA b egan 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 St reams ID-RF-S3114 and ID-RF-S5300-A

were not consistently included in the list of T2 ch anges 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 relat ed 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 tierin g 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 wor k 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 dat a examined, EPA determines that INL-CCP

demonstrated continued AK characterization complian ce for CH waste streams.

6.1.2 Remote-Handled Waste Streams

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

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

S3000 (homogeneous solids) and SCG S5000 (heterogen eous 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 representat ive 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 str eam. Therefore, the evaluation focused on the

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

drums of high-gamma waste in July 2012 (see EPA Doc ket 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 pr epared and reviewed by the U.S. Navy for

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

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

represents a “snapshot” of the documentation prepar ed 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 inspecti on 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 acc eptable knowledge documentation,

training of Acceptable Knowledge Experts and dispos ition of nonconformances were

examined and found to be adequate.

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

disposition of nonconformances for technical suffic iency and scope. The procedures adequately

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

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

discussion in section 6.1.1, Item (1).

Notification to EPA upon completion of or substanti ve modification to site procedures requiring

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

(2) The acceptable knowledge characterization process f or containers, including acceptable

knowledge assembly, compilation and verification, w as adequately implemented.

EPA evaluated INL-CCP’s completion of each of the 1 5 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 f or Waste Stream ID-ANLE-S5000 were

available, while many for Waste Stream IN-ID-BTO-03 0 were still in progress. Available

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

aware that significant revisions are currently bein g 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 cri tical 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 ch ange (see Table 2).

# 14



# (3) Waste traceability was adequately demonstrated.

EPA examined traceability from the generator throug h 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. Trace ability was examined for initial canister,

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

final drums can be traced to the original source ca nisters.

EPA examined traceability of waste containers to ev aluate characterization tracking. Waste

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

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

inspection, but EPA was able to examine select refe rences 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 C 207 and U200).

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

demonstrated.

(4) The acceptable knowledge summary reports were asses sed 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 an d source documents supporting this

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

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

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

comments from the T1 to add high-gamma drums.

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

the AKSR, CCP-AK-INL-590, Revision 2, which was und ergoing 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 sect ion 6.1.2, Item (10) below] remains a T2

change.

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

adequate.

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

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

3 

# INL was formerly known as INEL.

# 15



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

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

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

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

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

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

compliance inspections. A WSPF was not available fo r 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 assesse d 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, wi th Mr. Kevin Peters also trained for INL

waste and primarily providing oversight and guidanc e. INL-CCP provided complete

qualification cards and documentation of familiarit y with the current revision of the WCPIP

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

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

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

(7) Nonconformance and discrepancy resolution documenta tion was assessed and found to

be adequate.

EPA previously evaluated INL-CCP’s ability to produ ce 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 Str eams ID-ANLE-S5000 and IN-ID-BTO030.

Notification to EPA upon completion of or modificat ion 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 foun d 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 th e AK accuracy report for Lots 1–36 to

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

therefore, comparing the DTC results to AK data doe s 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 meaningf ul data comparisons are being made or that

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

conducted. AK accuracy reports were not available f or Waste Stream IN-ID-BTO-030.

# 16



# Notification to EPA upon completion of or substanti ve modification to AK accuracy reports

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

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

The WIPP waste acceptance criteria allow payload ma nagement 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 substa ntive 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 c ompliance 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 chang es 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 no tification of new or modified AKSRs and

certification plans applies to all waste streams, r egardless 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 R H baseline inspection and subsequent T1

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

(11) The radiological characterization report and the ac ceptable knowledge summary report

were reviewed as a demonstration of acceptable know ledge-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 relat ed to AK for RH wastes as a result of this

continued compliance inspection.

Notification to EPA upon completion of or modificat ion 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 pe rformed work in these roles for the INL-

# 17



# CCP RH waste characterization program during the pr evious quarter is also a new T2 change

(see Table 2).

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

demonstrated continued AK characterization complian ce for RH waste streams.

6.1.3 Acceptable Knowledge Findings and Approval

Summary of Acceptable Knowledge Findings and Concer ns

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

Acceptable Knowledge Approval

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

demonstrated continued AK characterization complian ce for CH and RH waste.

6.2 Nondestructive Assay for Contact-Handled Waste

EPA approved the WAGS and SGRS NDA systems initiall y 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 20 07 (EPA Docket No. A-98-49; II-A4-86).

The systems’ abilities to perform the required anal yses 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 capabili ties of the NDA systems’ hardware

and software had not changed since EPA’s last inspe ction.

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

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

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

6.2.1 Technical Evaluation: Waste Assay Gamma Spectromete r

EPA evaluated INL-CCP’s continued compliance with t he 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 o f the WAGS were evaluated during this

inspection.

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

that was approved previously.

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

Examination Pilot Plant (SWEPP), INL building WMF-6 10. EPA found that since the last

inspection, the power supply for detector No. DET3N B was replaced. A calibration verification

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

calibration was unaffected by the replacement. Othe r than the power supply replacement, there

# 18



# have been no substantive hardware or software chang es 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 la st inspection and were adequate for

the wastes currently being assayed.

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

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

which was 90% full and had a net weight of 136.2 ki lograms (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 measuremen ts were appropriately recorded and were in

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

(FWHM), energy calibration (gain) and barium-133 ( 133 

# Ba) transmission source checks were

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

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

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

controlled by boundary limits.

Decay correction of the 133 

# Ba transmission sources is performed in the softwar e. Due to the short

half-life of 133 

# Ba (approximately 10 years), the count rate boundar y limits of the sources must be

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

inspection in 2010, the boundary limits of the tran smission 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 o f the WAGS operation were acceptable.

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

Spectrometer had been performed and documented as r equired.

EPA verified that the system’s calibration was unch anged 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 we re technically acceptable and appropriately

documented.

(4) Determination and documentation for the total measu rement uncertainty for the Waste

Assay Gamma Spectrometer are adequate.

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

documented, as required. The EPA inspection team ve rified 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, adequatel y documents the technical basis for the

system’s lower limit of detection (LLD), including reporting thresholds for specific nonmeasured radionuclides 242 

# Pu and strontium-90 ( 90 

# Sr). 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 pro gram, as required.

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

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

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

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

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

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

6.2.2 Technical Evaluation: Stored Waste Examination Pilo t Plant Gamma-Ray

Spectrometer

EPA evaluated INL-CCP’s continued compliance with t he 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 follo wing 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 W aste Management Complex (RWMC) in

the facility formerly called the SWEPP, INL buildin g 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 T 1 change in February 2013 (EPA Docket

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

(2) The design and operational range of the Stored Wast e 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 as sayed.

Between May 1, 2012, and May 6, 2013, the SGRS assa yed 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 a ssay up to 35 55-gallon drums in a day. EPA

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

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

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

All daily performance measurements were appropriate ly 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 an d documented, as appropriate, and

background (~40 cps, full spectrum), FWHM and gain w ere 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 s ystem 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 calibra tion verification had been performed since

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

verification were technically acceptable and approp riately documented.

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

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

and documented, as required.

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

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

radionuclides uranium-234 ( 234 

# U), 238 

# Pu, 239 

# Pu, 242 

# Pu and 90 

# Sr. 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 e xpires August 18, 2013.

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

secheduled to participate in the PDP annually.

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

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

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

2012, that was provided during the inspection.

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

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

criteria for the Environmental Protection Agency Re plicate Testing Protocol.

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

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

determination of the quantity of 10 WIPP-tracked ra dionuclides [ 241 

# Am, cesium-137 ( 137 

# Cs),

# 21

238 

# Pu, 239 

# Pu, 240 

# Pu, 242 

# Pu, 90 

# Sr, 233 

# U, 234 

# U and 238 

# U] and the TRU alpha concentration. 4 

# This is

accomplished by the SGRS reassaying drums it previo usly 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 ta ken 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, an d the results were compared to the

original assay data. Two statistical tests, a chi-s quared (χ 2 

# ) test and a t test, were performed. Data

and results of the statistical analysis are include d in Attachments F.1 through F.3. The χ 2 

# 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 woul d 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 ther e

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

five replicate measurements.

For Drum Nos. ARP70420 and SRP13045, the χ 2 

# test showed that the observed variances in the

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

limits of the test. The t

test for Drum Nos. ARP70420 and SRP13045 also show ed no statistically

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

measurements.

The t test and χ

2 

# 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 238 

# U. This indicates that the variances in the replica te measurements for these items were

greater than the reported uncertainties for all val ues relative to the limits of the test and that the re

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

replicate measurements of 238 

# U. It is important to keep these in mind when evalu ating 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 238 

# U replicate values

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

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

temporal factors such as radioactive growth or deca y, 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 evaluatio n.

# 22



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

found that the replicate measurements for 238 

# U had high level of precision. All other

radionuclides in the replicate and original measure ments passed both statistical tests.

Additionally, replicate measurements of drum Nos. A RP70420 and SRP13045 showed the

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

drum exposed a “hot spot” in the drum that was prev iously 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 t he 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 buildin g 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 m odality at INL-CCP, it was only used

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

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

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

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

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

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

significant increase in the use of the instrument.

EPA evaluated the following aspects of the SuperHEN C 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 la st inspection and were adequate for

the wastes currently being assayed.

EPA verified that the original operational ranges f or 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 requir ed.

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

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

EPA inspection.

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

Neutron Counter had been determined and documented, as required.

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

configurations were unchanged since the last EPA in spection.

# 23



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

Super High Efficiency Neutron Counter, had been det ermined and documented, as

required.

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

previously approved assay configurations were uncha nged since the last EPA inspection.

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

17A (combustibles and metals matrices) and box cycl e 9A (combustibles and metals

matrices) of the Carlsbad Field Office-sponsored pe rformance 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 ade quate.

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

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

May 6, 2012, that was provided during the inspectio n.

6.2.4 Nondestructive Assay Findings and Approval

Summary of Nondestructive Assay Findings and Concer ns

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

Nondestructive Assay Approval

There are no changes to the T1 or T2 designations f or 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 comp liance 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 E PA-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 check s, was observed and found to be

adequate.

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

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

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

who were listed on the current LOQI dated May 7, 20 13. The INL-CCP DTC/OSPREY operator,

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

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

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

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

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

DTC personnel performed the source checks for Therm o 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 backg round 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 op erational logbook. DTC personnel

consulted “CCP Operator Aid: RH-DM-INL-002, Revisio n 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 oper ators also performed a source check for the

OSPREY LaBr 5 

# Probe No. 13000014 using 137 

# Cs 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. FC0100 B-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 d ata 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 parame ters were acceptable.

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

INL-CCP provided the LOQI dated May 7, 2012, for DT C 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 D TC at INL-CCP.

5 

# The OSPREY detector is a cerium-drifted lanthanum bromide crystal [La 3 

# Br(Ce)].

# 25



# Radiological Characterization Approval

There are no changes to the T1 or T2 designations f or 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 comp liance 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 E PA-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 inspect ion is included in Attachment H.

Technical Evaluation

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

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

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

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

container’s contents and entered characterization d ata 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 c ontainer. After the demonstration, EPA

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

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

examination.

The EPA inspector determined the procedure continue s 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 f or 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 char acterization data into an electronic data

sheet. The operator determined that the waste match ed 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. INLRHRTR1 3003. A 30-gallon can had been

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

was corrected in accordance with INL-CCP procedures

.

# 26



# Data were reviewed at the data generation and SPM l evel; the reviews were recorded on the

appropriate forms from CCP-TP-508.

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

accordance with written procedures.

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

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

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

training records of RTR operators.

RTR and VE personnel qualification records for on-t he-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 t hat 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 bee n 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 contin ued qualification status of all VE and RTR

personnel.

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

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

Attachment K) regarding the training containers use d 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 was te items. The only exception was that

Container Nos. 21 and 25 contained a “plastic bag w ith 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 know n, they are the only objective test of an RTR

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

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

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

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

skills.

EPA wrote a similar concern at INL-CCP on May 9, 20 12, 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. CB FO believes that the current practice of

developing RTR training drums meets the minimum req uirements but agrees with EPA that

# 27



# process improvements should be implemented. As a re sult, the CCP Cognizant Engineer for

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

that the locations and orientations of items, as we ll 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 acceptab le and EPA will confirm implementation

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

EPA determined that operators were trained in accor dance 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 examin ation discussed in section 6.4, Item (1)

above was properly qualified.

Summary of Real-Time Radiography Findings and Conce rns

EPA did not identify any findings related to RTR fo r 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) abo ve. 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 dat a 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 E PA-approved VE procedures for CH

and RH waste characterization. The VE checklists us ed 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 ob served and found to be adequate.

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

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

ID-RF-S3114. During the onsite demonstration, the a ctual 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 d emonstration 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 tha t oil dry is added to the waste if liquids are

present.

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

compliant CH VE data. EPA reviewed a LOQI and deter mined 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-0 02728 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 rec orded 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 abs ence of prohibited items. Data sheets were

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

with regard to generation and recording of RH VE da ta.

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

adequate.

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

response, INL-CCP-CC-2013-01C, regarding written tr aining 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 contin ued to be trained in accordance with

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

Summary of Visual Examination for Contact-Handled W aste

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 n ot requiring a response, INL-CCP-CC-2013-

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

Based on the results of this evaluation and the dat a 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 obs erved 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 duri ng 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 c ontainers. The three paint cans were designated

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

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

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

operators verified that no prohibited items were pr esent and that the waste matched the waste

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

guide the examination. EPA reviewed the container d ata sheets generated during the

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

operators.

EPA determined that the procedure continues to be a dequate 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 an d INLRHVE12001 and

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

these three BDRs was debris with WMC S5100 from was te 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, veri fied the WMC and confirmed the absence

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

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

adequate.

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

response, INL-CCP-CC-2013-01C, related to written t raining 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 contin ued to be trained in accordance with

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

# 30



# Summary of Visual Examination for Remote-Handled Wa ste

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 n ot requiring a response, INL-CCP-CC-2013-

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

Based on the results of this evaluation and the dat a 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), rel ated 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 dat a examined, EPA determines that INL-CCP

demonstrated continued VE compliance.

7.0 FINDINGS AND CONCERNS

There were no findings identified during this conti nued compliance inspection. The EPA

inspection team identified one concern related to R TR as performed by INL-CCP and one

concern related to RTR and VE operator qualificatio n records. These concerns are discussed in

section 6.4, Item (3) above and are provided in Att achments J and K. INL-CCP satisfactorily

responded to EPA’s concern in writing on June 26, 2 013. The concern is closed. There are no

open concerns as a result of this continued complia nce 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 pe rformed work in these roles for

the INL-CCP waste characterization program during t he previous quarter is a new T2

change applicable to both the CH and RH waste chara cterization programs.

# 31



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

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

reporting practices. EPA also revised the tiering t ables 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 in itiated during the CH and RH baseline and

subsequent T1 approvals remain in effect. The langu age 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 sc ope 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 rec ords. EPA brought these minor issues to the

attention of INL-CCP personnel and management durin g 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-mandat ed 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 acti ve, EPA-approved TRU waste site. The

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

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

characterization elements are personnel training, p rocedures and equipment capabilities. EPA

will evaluate these elements during T1 change evalu ations 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 characteriz ation program.

This streamlined approach allows EPA to consider th e results of continued compliance

inspections when setting the scope and evaluating s ite-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 2 014). 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 re port until the next continued compliance

investigation unless otherwise deemed necessary.

# A-1



# ATTACHMENT A.1: APPROVAL SUMMARY FOR INL-CCP CONTAC T-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 Novembe r 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 S eptember 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 fo r

the WAGS to Allow Filters June 23, 2011 A-98-49, II-A4-150

Unannounced Inspection – Waste Stream ID-NRD.1 Janu ary 4, 2012 A-98-49, II-A4-157

T1 Change – Approval of Recalibration of the SGRS F ebruary 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 Febru ary 12, 2007 A-98-49; II-A4-80

T1 Change – Approval of K Cell Wastes January 1, 20 08 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 I NSPECTION

CH AK

Common to all three CH waste streams:

AKE WCPIP Acknowledgements, May 7, 2013

CCP-QP-002, CCP Training and Qualification Plan, Re vision 34, January 30, 2013

CCP-QP-005, CCP TRU Nonconforming Item Reporting an d Control, Revision 20, April 26,

2011

CCP-TP-002, CCP Reconciliation of DQOs and Reportin g 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 S treams ID-RF-S5300-A, ID-RF-S3114 and IDSDA-SOIL, provided April 26, 2013

Qualification card for Carrie Johnson, June 16, 201 1

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 C ontainers, January 28, 2005

CCP-AK-INL-004, Central Characterization Project Ac ceptable 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, 200 6

CCP-TP-002, Revision 24, CCP Reconciliation of DQOs and Reporting Characterization Data,

Attachment 2 – CCP Waste Stream Profile Form (Examp le), ID-RF-S5300-A, Revision 0, April

18, 2006

CCP-TP-005, Revision 15, CCP Acceptable Knowledge D ocumentation, Attachment 7 –

Radionuclides, ID-RF-S5300-A, May 16, 2005

CCP-TP-005, Revision 17, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste

Containers List, ID-RF-S5300-A, June 20, 2006

CCP-TP-005, Revision 18, CCP Acceptable Knowledge D ocumentation, 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 D ocumentation, Attachment 1 –

Acceptable Knowledge Documentation Checklist, ID-RF -S5300-A, March 14, 2007

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 4 –

Acceptable Knowledge Source Document Information Li st, ID-RF-S5300-A, May 9, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP

Waste Stream Characterization Checklist – Example F orm, ID-RF-S5300-A, various dates

CCP-TP-005, various revisions, CCP Acceptable Knowl edge Documentation, Attachment 10 –

Acceptable Knowledge Re-evaluation Checklist, ID-RF -S5300-A, various dates

CCP-TP-005, various revisions, CCP Acceptable Knowl edge Documentation, Attachment 8 –

Waste Containers List, ID-RF-S5300-A, various dates

CCP-TP-005, various revisions, CCP Acceptable Knowl edge Documentation, Attachment 11 –

Acceptable Knowledge Source Document Discrepancy Re solution –Example Form, ID-RFS5300-A, various dates

D010, Discrepancy Resolution, Incorrect Waste Matri x Code, Jeff Harrison, Revision 1,

November 29, 2005

D011, Acceptable Knowledge Source Document Discrepa ncy Resolution (Drums Containing

Tile Material), Jeff Harrison, Revision 0, November 8, 2006

D020, Discrepancy Resolution, High Calculated Inorg anic 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-R F-S5300-A, May 17, 2007

Inter-Office Correspondence from J.A. Vernon to B.J . Broomfield, Acceptable Knowledge

Accuracy Report: Idaho National Laboratory Waste St ream 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 St ream 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, Ma y 26, 2011

Inter-Office Correspondence from J.A. Vernon to W.F . Verlanic, Acceptable Knowledge

Accuracy Report: Idaho National Laboratory Waste St ream Number ID-RF-S5300-A,

Combustible and Plastic Waste Items Assigned to Ite m 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 St ream Number ID-RF-S5300-A,

Combustible and Plastic Waste Items Assigned to Ite m 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-R F-S5300-A, November 15, 2006

Memorandum from Jeff Harrison to CCP Records, Evalu ation of the Radiological

Characterization of Rocky Flats Combustibles and Pl astic 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-Han dled Stored Transuranic Wastes, WMF1-82-021, October 1, 1982

P052, Backlog Waste Reassessment Baseline Book, Was te 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 Hist orical Emissions from Rocky Flats,

Chemrisk, November 1992

U082, EG&G Rocky Flats Plant Radionuclide and Hazar dous Constituent Reportable Quantity

Determination Guide, 1-10000-RQ, December 15, 1992

ID-RF-S3114

C184, Interview Record of Al Morgan by Jeff Harriso n, March 19, 1997

CCP-AK-INL-005, Central Characterization Program Ac ceptable 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-2862-1 1, 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-1759-1 2, 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, Revisio n 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 D ocumentation, Attachment 8 – Waste

Containers List, ID-RF-S3114, May 17, 2006

CCP-TP-005, Revision 18, CCP Acceptable Knowledge D ocumentation, Attachment 7 –

Radionuclides, ID-RF-S3114, February 19, 2007

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 1 –

Acceptable Knowledge Documentation Checklist, ID-RF -S3114, February 27, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 4 –

Acceptable Knowledge Source Document Information Li st, ID-RF-S3114, February 27, 2013,

and May 7, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, 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 D ocumentation, Attachment 13 – CCP

Waste Stream Characterization Checklist – Example F orm, ID-RF-S3114, various dates

CCP-TP-005, various revisions, CCP Acceptable Knowl edge Documentation, Attachment 8 –

Waste Containers List, ID-RF-S3114, various dates

CCP-TP-005, various revisions, CCP Acceptable Knowl edge Documentation, Attachment 10 –

Acceptable Knowledge Re-evaluation Checklist, ID-RF -S3114, various dates

CCP-TP-005, various revisions, CCP Acceptable Knowl edge Documentation, Attachment 11 –

Acceptable Knowledge Source Document Discrepancy Re solution –Example Form, ID-RFS3114, various dates

D023, Acceptable Knowledge Source Document Discrepa ncy 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 St ream 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 St ream 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 St ream 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 St ream 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-R F-S3114, January 10, 2008

Memorandum from Scott Smith to CCP Records, Additio n of Containers to Waste Stream IDRF-S3114, June 11, 2012

Memorandum from Scott Smith to CCP Records, Evaluat ion of the Radiological

Characterization of Rocky Flats Immobilized Organic Liquid Wastes Stored at the Idaho

National Laboratory, Waste Stream ID-RF-S3114: Orga nic Setups and ID-RF-S3150-A:

Solidified Organics, CCP-AK-INL-005 NDA Memo, Revis ion 1, February 8, 2007

P002, Organic and Sludge Immobilization System, RFP -4095, July 27, 1987

P024, Content Code Assessments for INEL Contact-Han dled Stored Transuranic Wastes, WMF1-82-021, October 1, 1982

P052, Backlog Waste Reassessment Baseline Book, Was te 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 Store d 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 Apri l 26, 2013

ANL-W-P003, Estimated Radiological Inventory Sent from the Argonne National LaboratoryWest to the Subsurface Disposal Area from 1952 thro ugh 1993, Michael L. Carboneau and

James A. Vail, INEEL/EXT-02-01385, Revision 1, Nove mber 2005

CCP-TP-005, Revision 18, CCP Acceptable Knowledge D ocumentation, 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 D ocumentation, Attachment 10 –

Acceptable Knowledge Re-evaluation Checklist, ID-SD A-SOIL, March 17, 2011

CCP-TP-005, Revision 23, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste

Containers List, ID-SDA-SOIL, November 9, 2011

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 1 –

Acceptable Knowledge Documentation Checklist, ID-SD A-SOIL, June 5, 2012

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 4 –

Acceptable Knowledge Source Document Information Li st, ID-SDA-SOIL, January 11, 2013

# B-6



# CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 7 –

Radionuclides, ID-SDA-SOIL, November 30, 2011

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP

Waste Stream Characterization Checklist – Example F orm, ID-SDA-SOIL, various dates

ID-C109, Record of Communication, Interview with Ab raham Romo, re: Accelerated Retrieval

Project (ARP) Drum Packaging Station (DPS) and Visu al 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, Nor man D. Rohrig, Oak Ridge Associated

Universities, Dade Moeller & Associates and MJW Cor poration, ORAUT-TKBS-0007-2,

Revision 2, July 29, 2005

ID-P275, Engineering Design File, Waste Inventory E stimate for the Accelerated Retrieval

Project III, Brent N. Burton, EDF-7884, Revision 0, April 11, 2007

ID-P421, Excavation Plan for the Accelerated Retrie val Project (WMF-1618)- Pit 4 Retrieval

Area (ARP VI), Idaho Cleanup Project, EDF-9873, Rev ision 0, December 21, 2010

ID-U349, Non-Rocky Flats Shipping Records ARP-VI (P 04P03), 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 St ream Number ID-SDA-SOIL, Interstitial

Soil from the Subsurface Disposal Area, Lots 38 - 5 7, 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 St ream Number ID-SDA-SOIL, Interstitial

Soil from the Subsurface Disposal Area, Lots 58 - 7 3, 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 St ream Number ID-SDA-SOIL, Interstitial

Soil from the Subsurface Disposal Area, Lots 74 - 7 6, Cumulative for Lots 1 - 76, April 29, 2013

Inter-Office Correspondence from M.F. Ramirez to CC P Records Custodian, Transmittal of

Idaho National Laboratory Change Notice for Waste S tream #ID-SDA-SOIL, Revision 1, June

22, 2011

Memorandum from Carrie Johnson to CCP Records, Eval uation of the Radiological

Characterization of Waste Streams ID-SDA-SLUDGE, ID A-SDA-SOIL and ID-SDA-DEBRIS,

CCP-AK-INL-001 NDA Memo, Revision 7, November 2, 20 11

RF-C416, Record of Communication, Interview with Ed Vejvoda, Waste Management Practices

at Rocky Flats, K. Peters, J. Harrison and C. Johns on, 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-S 5000, June 24, 2009

Add Container Memorandum, from Steve Schafer, CCP A KE to Larry Porter, CCP SPM, From:

Steve Schafer, CCP AKE, RE: Addition of 56 Containe rs 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-D efense Waste, January 21, 1997

C036, Letter to Sheildon Meyers, Deputy Assistant S ecretary 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 Drum s 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 Ha zardous Evaluation, June 6, 1990

C332, Memorandum to CCP Central Records: Assessment of Waste Material Parameters

(WMPs) for Waste Stream ID-ANLE-S5000, January 6, 2 006

# B-8



# C347, Evaluation of Combustible versus Noncombustib le Waste Drums in Waste Stream IDANLE-S5000, June 29, 2006

C348, Evaluation of Generator Reported Radionuclide s for Waste Stream ID-ANLE-S5000, June

30, 2006

C350, Evaluation for Radiological Waste Stream Deli neation 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 Radioa ctive 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 Ac ceptable Knowledge Summary Report

For Remote-Handled Transuranic Debris Waste from Ar gonne 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 Re mote-Handled Transuranic Radiological

Characterization Technical Report for Remote-Handle d 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 D ocumentation, Attachment 10 –

Acceptable Knowledge Re-evaluation Checklist, Waste Stream ID-ANLE-S5000, May 7, 2007

CCP-TP-005, Revision 23, CCP Acceptable Knowledge D ocumentation, 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 D ocumentation, Attachment 8 – Waste

Containers List, Waste Stream ID-ANLE-S5000, Novemb er 16, 2006

CCP-TP-005, Revision 23, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste

Containers List, Waste Stream ID-ANLE-S5000, August 29, 2011

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 1 –

Acceptable Knowledge Documentation Checklist, ID-AN LE-S5000, November 26, 2012

# B-9



# CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 4 –

Acceptable Knowledge Source Document Information Li st, ID-ANLE-S500, November 26,

2012

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste

Containers List, ID-ANLE-S5000, Heterogeneous Debri s from AGHCF Operations, April 30

2012

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste

Containers List, ID-ANLE-S5000, Heterogeneous Debri s from AGHCF Operations, August 29,

2012

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP

Waste Stream Characterization Checklist – Example F orm, ID-ANLE-S5000, Lot 32, October

24, 2012

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP

Waste Stream Characterization Checklist – Example F orm, ID-ANLE-S5000, Lot 36, February

13, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP

Waste Stream Characterization Checklist – Example F orm, ID-ANLE-S5000, Lot 36, dated

February 21, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, 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 o f EPA HWNS to Waste Stream IDANLE-S5000, November 16, 2006

DR016, Unsealed 1-gallon Waste Can Discrepancy Repo rt, August 14, 2007

DR017, Discrepancy Involving Free Liquids in Waste, May 7, 2007

DR018, Discrepancy Resolution Regarding: K Cell Was te Packaging, October 24, 2007

DR019, Discrepancy Resolution Re: Sealed Waste Cans , September 20, 2007

DR020, Discrepancy Resolution Re: Aerosol Cans, Sep tember 20, 2007

DR021, Discrepancy Resolution for 3-Gallon Cans, Oc tober 23, 2007

Inter-Office Correspondence from L.M. Nelson to NTP Records Custodian GSA-212,

Transmittal of Characterization Reconciliation Repo rt, 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 Repo rt, CRR-ID-ANLE-S5000-0032, for Remote

Handled Lot 32, at the Idaho National Laboratory, O ctober 24, 2012

# B-10



# Inter-Office Correspondence from L.M. Nelson to NTP Records Custodian GSA-212,

Transmittal of Characterization Information Summaryfor Remote-Handled Lot 32, ID-ANLES5000, at the Idaho National Laboratory, October 24 , 2012

M00l, Smith, Scott, Evaluation of Additional Contai ners Added to Waste Stream ID-ANLES5000, Evaluation of Drums from Repack of ANL-E Hig h 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 Str eam ID-ANLE-S5000, April 22, 2013,

and April 16, 2012

P001, AGHCF Operations Manual, IPS-2-00-00, Revisio n 2, September 10, 1990

P002, Central Characterization Project Acceptable K nowledge 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 ve rsus 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 80 9, 1995

U017, Data from Logbooks for RH TRU Drums 778 to 79 7, Book 8, 1994

U018, Data from Logbooks for RH TRU Drums 748 to 77 7, Book 7, 1993

U1003, Argonne Special Material Receipt and Transfe r 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 R H-TRU Liners

U3900, Collection of Retrievable Storage Canister D ata, 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 Storag e Canister Data Irradiated High-Level

Gamma Transuranic Scrap Material Sheets and Associa ted Paperwork, February 6, 1975,

through November 18, 1991

Waste Stream Profile Form, Waste Stream ID-ANLE-S50 00, 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 O ffice, Re: Shipment of Special Nuclear

Materials: PZA-CZC-3, November 14, 1987

# B-11



# C206, Letter to S.D. Harkness, Re: Request for Mate rial Description and History of Thirteen

Sludge Containers, March 17, 1989

C207, Letter to ANL, Re: Shipping Information, West inghouse 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 Ac ceptable Knowledge Summary Report

For Bettis Laboratory Remote-Handled Transuranic Wa ste Stored at Idaho National Laboratory

Waste Stream IN-ID-BTO-030, Revision 2, April 4, 20 12

CCP-AK-INL-592, Central Characterization Project RH TRU Waste Certification Plan for 40

CFR Part 194 Compliance for Bettis Laboratory Remot e-Handled Transuranic Debris Waste

Stored at the Idaho National Laboratory, Waste Stre am: IN-ID-BTO-030, Revision 1, August 16,

2012

CCP-AK-INL-595A, Central Characterization Program R adiological Sampling and Analysis

Plan For Bettis Laboratory Remote-Handled Transuran ic 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 D ocumentation, Attachment 6 – Waste

Form, Waste Material Parameters, Prohibited Items, and Packaging, IN-ID-BTO-030, May 19,

2011, and related Waste Material Parameter Memorand um dated May 25, 2011

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 1 –

Acceptable Knowledge Documentation Checklist, IN-ID -BTO-030, January 4, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 4 –

Acceptable Knowledge Source Document Information Li st, IN-ID-BTO-030, January 4, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste

Containers List, IN-ID-BTO-030, May 19, 2012

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 15 – CCP

TRU Waste Correlation and Surrogate Summary Form, B ettis 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 Pr ogram, July 21, 1998

P102, Cultural Resource Assessment: Bettis Atomic P ower Laboratory, Allegheny County,

Pennsylvania, May 2002

# B-12



# P201, Memo to M.J. Holzemer with waste profile atta chment Re: TRU Waste Profile Sheet for

Bettis Content Code 30 Approval, JDW-23-88, April 6 , 1988

U200, ANL-W Radioactive Waste Disposal Request Cert ification 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, th rough July 13, 1987

U236, COW Logbook #2, Waste Disposal Log, January 1 973 through November 1979

U256, Bettis Experimental Facilities, Bettis Hot La boratory, November 1978

U275, Radiological Data from INL-W Shipping Documen ts (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 Ind ividuals, May 7, 2013, 4 pages, prepared at

request of EPA Inspectors

CCP-INL-174, Operator Aid: WAGS Pulser Parameter Da ta, December 21, 2009

CCP-INL-244, Operator Aid: SGRS Pulser Parameter Da ta, August 8, 2012

CCP-INL-251, Operator Aid: SGRS/WAGS Weekly Perform ance 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 th e SGRS System after Detector

Replacement and Energy Calibration, August 8, 2012

CCP-INL-SGRS-12-005, Measurement Control Limit Upda te on the SGRS, October 17, 2012

CCP-INL-WAGS-001, Revision 1, April 2008

CCP-INL-WAGS-003, WAGS Calibration, Confirmation an d Verification Report, Revision 0,

May 18, 2011

# B-13



# CCP-INL-WAGS-12-003, Measurement Control Limit Upda te for 356 keV count rate on the

WAGS, July 19, 2012

CCP-INL-WAGS-12-005, Calibration Verification of th e WAGS System after replacement of

DSA 1000 power supply for DET3NB, December 3, 2012

CCP-SHENC-12-002, INL SuperHENC Calibration Verific ation, Revision 0, September 12,

2012

CCP-SHENC-12-004, Investigation of INL SuperHENC PD P Cycle B12A Bias Criteria Failure

for the Combustibles Matrix, Revision 0, November 2 8, 2012

CCP-TP-010, WAGS and SGRS Calibration Procedure, Re vision 4, March 2011

CCP-TP-019, WAGS Operating Procedure, Revision 6, A pril 2013

CCP-TP-109, CCP Data Reviewing, Validating and Repo rting Procedure, Revision 9, February

2013

CCP-TP-115, SGRS Operating Procedure, Revision 5, A pril 2013

CCP-TP-146, CCP SuperHENC Operating Procedure, Revi sion 8, March 2013

CCP-TP-148, CCP SuperHENC Data Reviewing, Validatin g and Reporting Procedure, Revision

8, January 2013

CCP-TP-170, CCP SuperHENC Calibartion Procedure, Re vision 2, March 2007

SGRS BDR Nos. INNDAS130001 and INNDAS120034

SGRS Operational Logbook, May 7, 2013, correspondin g to day of EPA inspection and

sampling of entries

SuperHENC BDR No. INNDAB12005

SuperHENC Operational Logbook, May 7, 2013, corresp onding to day of EPA inspection and

sampling of entries

Summary of Containers Assayed on SGRS, WAGS and HEN C, May 1, 2012 to May 6, 2013,

prepared for inspection

WAGS BDR Nos. INNDAW120076 and INNDAW130036

WAGS Operational Logbook, May 7, 2013, correspondin g to day of EPA inspection and

sampling of entries

DTC

CCP-TP-504, CCP DTC Survey Procedure for RH TRU Was te, 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, O ctober 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 fro m RH RTR BDR Nos. INLRHRTR13001,

INLRHRTR13003 and INLRHRTR13004

CCP AK training attendance sheets for VE and RTR op erators

CCP Transuranic Waste Certification Plan, CCP-PO-00 2, Revision 26, July 14, 2011

CCP Transuranic Waste Characterization Quality Assu rance Project Plan, CCP-PO-001,

Revision 21, May 31, 2013

CCP Training and Qualification Plan, CCP-QP-002, Re vision 26, January 30, 2013

CCP TRU Nonconforming Item Reporting and Control, C CP-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 C onstruction, 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 Pr ocedure, 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 betwe en 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 IN LRHRTR13004 and

INLRHRTR13006

RH VE BDR Nos. INLRHVE11002, INLRHVE11003 and INLRH VE12001

RTR Measurement Control Report, dated May 8, 2013

Training drum inventories, container Nos. 17, 21 an d 25

VEE appointment letters dated between 2007 and 2011C-1ATTACHMENT C: INSPECTION PERSONNELPersonnelAffiliationArea of Expertise/FunctionEntranceMeetingInterviewedExitMeetingEd Feltcorn U.S. EPA ORIAInspector-Team LeaderRajani Joglekar U.S. EPA ORIA InspectorConnie Walker SC&A, Inc. AK InspectorDorothy Gill SC&A, Inc. RTR/VE InspectorKira Darlow SC&A, Inc. AK InspectorPatrick Kelly SC&A, Inc. NDA/DTC InspectorRose Gogliotti SC&A, Inc. NDA/DTC InspectorBen Roberts DOEBill Verlanic CCP/NWP PMBret Palmer CWI VE OperatorBruce LaRue DEQ INL OP Environmental ScientistChris Davis CWI VE, DTC OperatorChris Heavit DOECody Remsburg Site Operations ManagerCrary Davis CCP/MCS NDA LeadDavid Ams CCP/NWP LANL AKDoug Pruitt DOEEd Gulbransen CCP NTP Certification ManagerGreg Smith CCP/NWP VPMIrene Joo CCP/NWP RH Project ManagerJeff Poole CCP CH, RH VEEJeri Miles CCP/NWP VPMJim Vernon CCP/NWP SPMKevin J. Peters CCP AKKeith Farmer NFMLarry Hutsek CWI WM Operations DirectorLarry Klingler CCP/NWP QALisa Frost CWI CH SupportLisa Watson CCP/NWP LANL AKEMarcus A. Pinzel DOE/CBFOMark Doherty CTAC/NTP ObserverMary Carrol NDA OperatorPreston Abbott CCP/MCS NDA LeadC-2Rajir N. Bhau CWI/INL TRU Waste ProgramRoger Vawter CTAC/CBFO ObserverScott Smith CCP AKESharron Cummins NDA OperatorTammy Hobbes CWI WMThomas L. Clements, Jr CWI/INL TRU Waste ProgramTom Johnsen CWI CH TRU STRTyson Christensen CCP/VJT RTR LeadD-1ATTACHMENT D.1: AK CONTINUED COMPLIANCE INSPECTIONCHECKLIST: WASTE STREAM ID-RF-S3114EPA Inspection No.: INL-CC-2013Waste Stream: ID-RF-S3114Inspection Date: May 7–9, 2013Technical ElementsObjective Evidence/CommentsAK-1:Do AK, training and nonconformance proceduresadequately reflect the requirements of 40 CFR194 and have they been adequately implemented?Yes. Examples of adequate implementation:CCP-QP-002, Revision 34, training and qualificationplan: report body Item (6)CCP-QP-005, Revision 20, nonconforming item report:checklist Item (AK-6)-NCRsCCP-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) and (AK-8)AK-2:Is the AK characterization process, including AKassembly, compilation and verification adequate?Yes. Completed CCP-TP-005 attachments provide objective evidence of AK assembly, compilation and verification.a.Attachment 1, Revision 24, Acceptable Knowledge Documentation Checklist: complete.b.Attachment 2, Record of Communication: not used. All interviews took place prior to implementation ofCCP-TP005; therefore, those communications are appropriately not documented on CCP-TP-005, Attachment 2.c.Attachment 3s, various revisions, Acceptable Knowledge Source Document Summary: attached to all inspectedsource documents. Most are Revision 24.d.Attachment 4, Revision 24, Acceptable Knowledge Information List: revised during inspection to includeDRs thatwere written since the last AK update.e.Attachment 5, Hazardous Constituents: outside EPA’spurview; not reviewed.f.Attachment 6, Revision 24, Waste Form, Waste Material Parameters, Prohibited Items, and Packaging: complete.It and the associated WMP analysis memorandum support estimates in AKSR and discussed in checklist Item(AK-4b).g.Attachment 7, Revision 18, Radionuclides: complete.Supports estimates given in AKSR and discussed inchecklist Item (AK-4c). See also discussion in checklist Item (AK-8).h.Attachment 8, Revisions 15–23, Waste Containers List: updated periodically as waste containers are identified instorage. Each revision of Attachment 8 is comprehensive for the whole waste stream as identified to date, but theaccompanying container lists include only those containers added since the last Attachment 8. Since the lastrevision of Attachment 8, additional containers were added to the waste stream through use of an add containermemorandum (dated 6/11/2012) that describes the evaluation of the additional containers.i.Attachment 9, Waste Characterization Data Cross-Reference: reference tool, not a form for completion.j.Attachment 10, various revisions, Acceptable Knowledge Re-evaluation Checklist: completed as necessary; dated3/28/2006–2/20/2013. DRs and revisions to AKSR werecompleted as indicated in Attachment 10s.k.Attachment 11, various revisions, Acceptable Knowledge Source Document Discrepancy Resolution: completedas appropriate [see checklist Item (AK-6)]. The associated Attachment 3s for the older DR reports werenotcreated until fall 2012. Attachment 3s for the DR reports created in 2013 were created at the same time as the DRreports, but Attachment 4 was not updated to reflect the 2013 DR reports until during this evaluation.l.Attachment 12, Example Form and Content Guide for AK Summary Reports: reference tool, not a form forcompletion; see review of completed AKSR in checklist Item (AK-4).m.Attachment 13, Revision 24, CCP Waste Stream Characterization Checklist: completed for Lots 75–86. CCPWaste Stream Characterization Checklists were alsocompleted for Lots 1–74; however, these checklistsare notcompleted as forms out of CCP-TP-005.n.Attachment 14, Revisions 18, 22 and 24, CCP Acceptable Knowledge Accuracy Report: completed annually;seechecklist Item (AK-7).D-2EPA Inspection No.: INL-CC-2013Waste Stream: ID-RF-S3114Inspection Date: May 7–9, 2013Technical ElementsObjective Evidence/Commentso.Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form: not applicable to this waste stream.AK-3:Are waste containers traceable from retrievalthrough CCP’s EPA-approved characterizationprocess?Yes. Tracked Container 10082578. AMWTP retrieves container, uses RWMS and TWMS databases to identify IDCsfor each retrieved container, and sends historicaldrum numbers, IDC, and original closure dates to AKE forconfirmation of waste stream inclusion. This container added in Attachment 8 memorandum on 5/17/2006:historicalDrum No. IDRF074311957; IDC 003; initial closure date 7/5/1973. “RF0743” indicates waste from RFP Building 774(References P024, P052 and U505). RTR BDR: INRTR5110074, 6/27/2011 (Reference list of fully characterizedcontainers); NDA BDR: INNDAW110114, 6/28/2011 (Reference list of fully characterized containers).AK-4:Does the AK summary report include sufficientinformation, supported by appropriate sourcedocuments, to support the statements below?a.All waste within the waste stream wasgenerated from a single process/activity.b.All waste within the waste stream is similar inmaterial and physical form.c.All waste within the waste stream has similarradiological properties.d.All of the waste in the waste stream is defensein origin.e.None of the waste in the waste stream is highlevel waste.f.None of the waste in the waste stream is spentnuclear 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 Grease Plant (Building 774)(References P024 and P052). Organic liquid waste was transferred by pipeline or in containers from mostbuildings at RFP and processed through an extruderwith a synthetic calcium silicate to form paste-like material(References P002, P024 and P053). Grease Plant shutdown in 1985 and was replaced by the OASIS process.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), disassembly of site-returnparts (site-return Pu with higher241Am decay product, HEU and tritium). Wastes contaminated with DU may alsobe 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 retired nuclear weapons(Reference P053).e.RFP did not reprocess spent nuclear fuel (ReferenceP053).f.RFP did not handle irradiated fuel elements (Reference P053).AK-5:Are the waste stream profile form and relatedattachments complete and adequate/accurate?Related attachments include:a.Characterization information summaryb.Summation of aspectsYes. WSPF, Revision 0: dated 1/24/2006. WSPF is complete; package includes complete CIS for Lot 1 containers andcomplete summation of aspects based on the current-at-the-time AKSR (CCP-AK-INL-005, Revision 1).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 is complete; packageincludescomplete CIS for Lot 87 containers and complete summation of aspects based on the current-at-the-timeAKSR (CCPAK-INL-005, Revision 7).AK-6:Are nonconformances and discrepancyresolutions documented appropriately?Yes. NCR-INL-2862-11: RTR found unexpected packaging configuration; AK reevaluated and AKSR revised.NCR-INL-1759-12: VE BDR incorrectly identified WMPfor “absorbent mixed with waste;” reworked BDR.D023 written because VE identified graphite in thewaste; AK review determined graphite from cold process and doesnot contain hazardous constituents; drums remain primarily inorganic sludge so drums remain in waste stream andINL-CCP revised the AKSR to include information about graphite.D-3EPA Inspection No.: INL-CC-2013Waste Stream: ID-RF-S3114Inspection Date: May 7–9, 2013Technical ElementsObjective Evidence/CommentsAK-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 Lots 82–100 as well ascumulative AK accuracy for Lots 1–100. Accuracy report includes a memorandum summarizing AK accuracyanalysis, lists correlating containers in Lots 82–100 to their BDRs, and CCP-TP-005, Revision 24, Attachment 14,listing containers from Lots 1–100 that have been evaluated for reassignment. AK accuracy for Lots 82–100 is 100%.INL-CCP completed two AK reevaluation checklists during the reporting period: one added graphite to the potentialwaste items in the AKSR; the other updated the hazardous waste numbers to include D008 (lead). As a result, AKaccuracy for the waste stream as a whole changed from 99.9% to 99.5% during the reporting period.EPA also reviewed AK accuracy reports prepared 5/21/2010, 5/27/2011 and 5/31/2012. There are someinconsistencies in the past reports (e.g., 2 containers inconsistent with AK in 2011, 0 containers in2012, and 18 newplus the 2 existing inconsistent containers in 2013). This appears to be a one-time issue with the 2012 AK accuracyreport.AK-8:Is AK-NDA communication adequatelydocumented?Yes. AK-NDA communication documented in CCP-TP-005,Revision 18, Attachment 7, dated 2/19/2007, and theattached NDA memorandum dated 2/8/2007. As stated in checklist Item (AK-4c) above, the AK identified WG Pu, Puwith high241Am decay product, HEU and DU. NDA memorandum, Revision 1, only lists WG Pu, HEU and DU asprimary radiological contaminants. The NDA memorandum presents relative weight percent calculations forradionuclides in ID-RF-S3114. Memorandum identifiesthe predominant radionuclides (starting with the highestweight percent) as238U (largest expected from DU),239Pu (largest expected from WG Pu),240Pu (second largestexpected from WG Pu),235U (largest expected from HEU), and then241Am. Estimating by weight percent only is notan ideal way to document the expected radionuclides.AK-9:Has notification of applicable T2 changes beenprovided to EPA as required in the INL-CCP CHtiering table?Yes. EPA tracking began with 4thquarter 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; however, EPA only receivednotification in 2011. SPM was unaware that this requirement applied to all waste streams.c.AK-AK and AK-NDA/NDE DR reports – D018 was revisedand D022–D025 written post-EPA tracking. EPAreceived two notifications of D018 in the FY 2011 3rdquarter report and infers that this should have been D018and D022. Notification of D023, D024 provided withFY 2013 2ndquarter report as expected. Notification of D025is expected with the FY 2013 3rdquarter report.d.WSPFs, including updates or additions to waste streams within an approved waste category – WSPF, Revision 1,notification to EPA in FY 2013 2ndquarter report as expected.e.The load management status of approved waste streams – Status has not changed.D-4ATTACHMENT D.2: AK CONTINUED COMPLIANCE INSPECTIONCHECKLIST: WASTE STREAM ID-RF-S5300-AEPA Inspection No.: INL-CC-2013Waste Stream: ID-RF-S5300-AInspection Date: May 7–9, 2013Technical ElementsObjective Evidence/CommentsAK-1:Do AK, training and nonconformance proceduresadequately reflect the requirements of 40 CFR194 and have they been adequately implemented?Yes. See Attachment D.1, checklist Item (AK-1).AK-2:Is the AK characterization process, including AKassembly, compilation and verification adequate?Yes. Completed CCP-TP-005 attachments provide objective evidence of AK assembly, compilation and verification.a.Attachment 1, Revision 18, Acceptable Knowledge Documentation Checklist: complete.b.Attachment 2, Revision 14, Record of Communication:Completed when appropriate (e.g., C501). Most interviewstook place prior to implementation of CCP-TP-005; therefore those communications are appropriately notdocumented on CCP-TP-005, Attachment 2.c.Attachment 3s, various revisions, Acceptable Knowledge Source Document Summary: attached to all inspectedsource documents. Most are Revision 15 from initialAK compilation. The AK source document summary forU082 is dated 6/30/2011 and was completed using Revision 22 of the form. CCP-TP-005, Revision 23, wasapproved on 6/30/2011, so the summary should have been done or redone using the Revision 23 Attachment3.d.Attachment 4, Revision 24, Acceptable Knowledge Information List: revised during this inspection to include DRswritten since the last AK update.e.Attachment 5, Hazardous Constituents: outside EPA’spurview; not reviewed.f.Attachment 6, Revision 18, Waste Form, Waste Material Parameters, Prohibited Items, and Packaging: complete.It and the associated WMP analysis memorandum support estimates in AKSR and discussed in checklist Item(AK-4b).g.Attachment 7, Revision 15, Radionuclides: complete.Supports estimates given in AKSR and discussed inchecklist Item (AK-4c). See also discussion in checklist Item (AK-8).h.Attachment 8, Revisions 15–18, Waste Containers List: Updated periodically as waste containers were identifiedin storage. Each revision of Attachment 8 is comprehensive for the whole waste stream as identified todate, butthe accompanying container lists include only thosecontainers added since the last Attachment 8. TheAttachment8 dated 6/5/2006 was completed using Revision 16 ofthe form. CCP-TP-005, Revision 17, was approved on6/5/2006, so the Attachment 8 should have been doneor redone using the Revision 17 Attachment 8.i.Attachment 9, Waste Characterization Data Cross-Reference: reference tool, not a form for completion.j.Attachment 10, Revisions 15, 17 and 18, AcceptableKnowledge Re-evaluation Checklist: completed as necessary;dated 5/16/2007–2/11/2008. DRs and revisions to AKSR were completed as indicated in Attachment 10s.k.Attachment 11, Revisions 15 and 18, Acceptable Knowledge Source Document Discrepancy Resolution:completed as appropriate [see checklist Item (AK-6)]. The associated Attachment 3s were created at thesametime, but Attachment 4 was not updated to reflect the most recent DRs until during this evaluation.l.Attachment 12, Example Form and Content Guide for AK Summary Reports: reference tool, not a form forcompletion; see review of completed AKSR in checklist Item (AK-4).m.Attachment 13, Revision 24, CCP Waste Stream Characterization Checklist: completed for Lots 136–137. CCPWaste Stream Characterization Checklists were alsocompleted for Lots 1–135; however, these checklistsare notcompleted as forms out of CCP-TP-005.n.Attachment 14, Revisions 18, 22 and 24, CCP Acceptable Knowledge Accuracy Report: completed annually;seeD-5EPA Inspection No.: INL-CC-2013Waste Stream: ID-RF-S5300-AInspection Date: May 7–9, 2013Technical ElementsObjective Evidence/Commentschecklist Item (AK-7).o.Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form: not applicable to this waste stream.AK-3:Are waste containers traceable from retrievalthrough CCP’s EPA-approved characterizationprocess?Yes. Tracked Container 10102536. AMWTP retrieves container, uses RWMS and TWMS databases to identify IDCsfor each retrieved container, and sends historicaldrum numbers, IDC, and original closure dates to AKE forconfirmation of waste stream inclusion. This container added in Attachment 8 memorandum on 6/20/2006:historicalDrum No. IDRF000216988; IDC 330; initial closure date 3/4/1974. “RF0002” indicates waste from RFP Building771-Pu recovery facility (Reference P052). RTR BDR:INRTR5120005, 8/9/2012 (Reference list of fullycharacterized containers); NDA BDR: INNDAW120056, 8/16/2012 (Reference list of fully characterized containers).AK-4:Does the AK summary report include sufficientinformation, supported by appropriate sourcedocuments, to support the statements below?a.All waste within the waste stream wasgenerated from a single process/activity.b.All waste within the waste stream is similar inmaterial and physical form.c.All waste within the waste stream has similarradiological properties.d.All of the waste in the waste stream is defensein origin.e.None of the waste in the waste stream is highlevel waste.f.None of the waste in the waste stream is spentnuclear 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 retrieved container is traceable to theoriginal building. EPA questioned inclusion of allof the waste from distinct generating locations ina single wastestream. INL-CCP explained that all the RFP activities were components within the same process: Pu processing.Pu processing included Pu production, Pu recovery,and all the supporting activities. INL-CCP also stated thatthere is historical precedent for shipping RFP waste by IDC instead of by building (References P004 and P053)b.ID-RF-S5300-A is composed of combustibles and plastic debris waste: IDC 330, dry combustibles; IDC 336, wetcombustibles; IDC 337, plastics. RFP managed all three types of waste on a single Waste Form for TRUCombustible Waste (References P001, P024 and P052).c.Primary radionuclides expected in the waste streamare WG Pu and241Am from Pu component production and Purecovery and purification. These activities are also expected to have produced waste contaminated withHEU andDU. These processes were carried out over all of RFP; the waste from all RFP buildings is expected tohavesimilar radiological properties (References C039, P053, P069 and P161).d.RFP mission was to produce Pu targets for nuclear weapons and to recover Pu from retired nuclear weapons(Reference P053).e.RFP did not reprocess spent nuclear fuel (ReferenceP053).f.RFP did not handle irradiated fuel elements (Reference P053).AK-5:Are the waste stream profile form and relatedattachments complete and adequate/accurate?Related attachments include:a.Characterization information summaryb.Summation of aspectsYes. WSPF, Revision 0: dated 4/18/2006. WSPF is complete; package includes complete CIS for Lot 1 containers andcomplete summation of aspects based on the current-at-the-time AKSR (CCP-AK-INL-004, Revision 1).Change Notice 1: submitted 11/15/2006 to update generation dates and expected WMPs.Change Notice 2: submitted 5/17/2007 to update theexpected radionuclides.AK-6:Are nonconformances and discrepancyresolutions documented appropriately?Yes. EPA did not specifically review any NCRs associated with Waste Stream ID-RF-S5300-A.D011 written to resolve recurring issue of drums being identified by VE and RTR to contain unexpectedasbestos floortiles (WMP: other inorganic materials). INL-CCP determined that while each tile-containing drum is less than 80%combustible or plastic material, the drums would not cause the waste stream as a whole to contain lessthan 80%combustible or plastic material. Therefore the drums remain in Waste Stream ID-RF-S5300-A and INL-CCPrevisedthe AKSR to include information about asbestos tiles.D-6EPA Inspection No.: INL-CC-2013Waste Stream: ID-RF-S5300-AInspection Date: May 7–9, 2013Technical ElementsObjective Evidence/CommentsAK-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 Lot 137 as well as cumulativeAK accuracy for Lots 1–137. Accuracy report includes a memorandum summarizing AK accuracy analysis, alistcorrelating containers in Lot 137 to their BDRs, and CCP-TP-005, Revision 24, Attachment 14, listing the containersfrom Lots 1–137 that have been evaluated for reassignment. AK accuracy for Lot 137 is 100% and AK accuracy forthe 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 adequatelydocumented?Yes. AK-NDA communication documented in CCP-TP-005,Revision 15, Attachment 7, dated 5/16/2005, and theattached NDA memorandum dated 5/13/2005. As statedin checklist Item (AK-4c) above, the AK explicitlyidentified241Am as one of the primary radionuclides in the wastestream. The NDA memorandum does not explicitly address241Am as one of the primary expected radionuclides, instead only explicitly mentioning WG Pu, HEU and DU.NDAMemo Addendum 1 presents the relative weight percent calculations for radionuclides in ID-RF-S5300-A.Theaddendum identifies the predominant radionuclides (starting with the highest weight percent) as238U (largest expectedfrom DU),239Pu (largest expected from WG Pu),235U (largest expected from HEU),240Pu (second largest expectedfrom WG Pu), and then241Am. Estimating by weight percent only is not an ideal way to document the expectedradionuclides.AK-9:Has notification of applicable T2 changes beenprovided to EPA as required in the INL-CCP CHtiering table?Yes. EPA tracking began with 4thquarter 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; however, EPA only receivednotification in 2011. SPM was unaware that this requirement applied to all waste streams.c.AK-AK and AK-NDA/NDE DR reports – The most recent DR was written in November 2006, before EPA startedtracking T2 notifications.d.WSPFs, including updates or additions to waste streams within an approved waste category – The WSPF hasnever been revised and both change notices were submitted prior to EPA’s T2 tracking.e.The load management status of approved waste streams – Status has not changed.D-7ATTACHMENT D.3: AK CONTINUED COMPLIANCE INSPECTIONCHECKLIST: WASTE STREAM ID-SDA-SOILEPA Inspection No.: INL-CC-2013Waste Stream: ID-SDA-SOILInspection Date: May 7–9, 2013Technical ElementsObjective Evidence/CommentsAK-1:Do AK, training and nonconformance proceduresadequately reflect the requirements of 40 CFR194 and have they been adequately implemented?Yes. See Attachment D.1, checklist Item (AK-1).AK-2:Is the AK characterization process, including AKassembly, compilation and verification adequate?Yes. Completed CCP-TP-005 attachments provide objective evidence of AK assembly, compilation and verification.a.Attachment 1, Revision 24, Acceptable Knowledge Documentation Checklist: complete.b.Attachment 2, Revisions 13 and 18, Record of Communication: Completed when appropriate (e.g., ID-C109,RF-C416)c.Attachment 3s, various revisions, Acceptable Knowledge Source Document Summary: attached to all inspectedsource documents. Most are Revisions 13–24.d.Attachment 4, Revision 24, Acceptable Knowledge Information List: last revised 1/11/2013.e.Attachment 5, Hazardous Constituents: outside EPA’spurview; not reviewed.f.Attachment 6, Revision 18, Waste Form, Waste Material Parameters, Prohibited Items, and Packaging: complete.Not updated since last EPA review. It and the associated WMP analysis memorandum support estimates inAKSRand discussed in checklist Item (AK-4b).g.Attachment 7, Revision 24, Radionuclides: complete.Supports estimates in AKSR and discussed in checklist Item(AK-4c). See also discussion in checklist Item (AK-8).h.Attachment 8, Revision 23, Waste Containers List: last updated 11/9/2011. Each revision of Attachment8 iscomprehensive for the whole waste stream as identified to date, but the accompanying container lists include onlythose containers added since the last Attachment 8.Containers assigned to ID-SDA-SOIL and are added directlyto the AK tracking spreadsheet after VE; therefore,Attachment 8 is usually only updated when the AKSRisrevised.i.Attachment 9, Waste Characterization Data Cross-Reference: reference tool, not a form for completion.j.Attachment 10, Revision 21, Acceptable Knowledge Re-evaluation Checklist: last completed 3/17/2011 andconsiders EPA HWNs. This is the only AK reevaluation completed since EPA’s last review.k.Attachment 11, Acceptable Knowledge Source DocumentDiscrepancy Resolution: none since last EPA inspectionof this waste stream.l.Attachment 12, Example Form and Content Guide for AK Summary Reports: reference tool, not a form forcompletion; see review of completed AKSR in checklist Item (AK-4).m.Attachment 13, Revision 24, CCP Waste Stream Characterization Checklist: completed for Lots 70–76. CCPWaste Stream Characterization Checklists were alsocompleted for Lots 1–69; however, these checklistsare notcompleted as forms out of CCP-TP-005.n.Attachment 14, Revisions 22 and 24, CCP AcceptableKnowledge Accuracy Report: completed annually; seechecklist Item (AK-7).o.Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form: not applicable to this waste stream.AK-3:Are waste containers traceable from retrievalYes. Targeted waste is identified through query ofWILD and engineering design files compiled for eachretrieval area(References ID-P421, ID-P426). Containers are created during VE process, then added to AK tracking spreadsheet,then characterized by NDA. Lists of containers correlating drum numbers to VE and NDA BDRs and includingD-8EPA Inspection No.: INL-CC-2013Waste Stream: ID-SDA-SOILInspection Date: May 7–9, 2013Technical ElementsObjective Evidence/Commentsthrough CCP’s EPA-approved characterizationprocess?emplacement dates as applicable are readily available (References list of fully characterized containers and AKtracking spreadsheet).AK-4:Does the AK summary report include sufficientinformation, supported by appropriate sourcedocuments, to support the statements below?a.All waste within the waste stream wasgenerated from a single process/activity.b.All waste within the waste stream is similar inmaterial and physical form.c.All waste within the waste stream has similarradiological properties.d.All of the waste in the waste stream is defensein origin.e.None of the waste in the waste stream is highlevel waste.f.None of the waste in the waste stream is spentnuclear fuel.Yes. CCP-AK-INL-001, Revision 11, was updated appropriately to include ARP-VI and ARP-VII.a.Targeted waste in ARP-VI and -VII remains RFP-generated waste from the same processes and time period.Thepits contained within ARP-VI, and -VII received waste from RFP during the same time period as previouslyapproved waste (March 1964–November 1968, comparedto May 1964–September 1968), indicating that thewastes have the same origin (References ID-U349, ID-P421, RF-U1313 and RF-U1315). AKSR updatedaccordingly. One new RFP generator building identified on waste disposal forms (Building 887) and added to theAKSR (Reference RF-U1313).b.ID-SDA-SOIL drums contain less than 50%, by volume,targeted debris or sludge with the remainder composed ofinterstitial soil from the SDA. Targeted waste in ARP-I–ARP-VII remains limited to RFP First-Stage Sludge (741-Series), RFP Second-Stage Sludge (742-Series), RFPOrganic Setups (743-Series), RFP Roaster Oxide, RFPGraphite, and RFP Filters. Expected volumes of eachwaste type in ARP-VI and -VII added to AKSR (ReferencesID-P275, RF-U1313 and RF-U1315). Did not result inchanges to WMP estimates for ID-SDA-SOIL becauseWMP estimates for ID-SDA-SOIL are based entirely onexisting VE records. WMP estimates will be revisedasnecessary; however, the AKE indicated that the population on which the current estimates are based issufficientlylarge that the estimates will likely not need further revision.c.INL-CCP calculates the expected radionuclides basedon AK data (Reference ID-U313), and continues to updatethese calculations every time additional ARP phasesare added, historically adding one new ARP phase per AKSRrevision, as evidenced by comparing Tables 5-2, 5-3and 5-4 in AKSR, Revisions 9 and 11. INL-CCP indicatesthat the most prevalent radionuclides by mass are238U (99.63%), with235U and239Pu as the second and third mostprevalent by mass in almost equal concentrations.241Pu and241Am are the most prevalent radionuclides byactivity.d.As previously evaluated, all SDA targeted waste isfrom RFP, which produced Pu targets for nuclear weapons andto recover Pu from retired nuclear weapons. EPA also previously determined that targeted (defense-related) andnon-targeted wastes are commingled in the pits dueto lack of container integrity. This continues to be true forARP-VI and -VII.e.As previously evaluated, ID-SDA-SOIL does not contain spent nuclear fuel because while some may have beenburied in Pit 4, it would be segregated and not packaged with the WIPP-bound waste. Addition of ARP-VIand-VII did not change this situation.f.While high-level waste was produced at some of thesmall waste-contributing generators (FCF and HFEF at ANLW), it was sent to a different facility and not buried in the retrieval area (References ANL-W-P003 and ID-P118).AK-5:Are the waste stream profile form and relatedattachments complete and adequate/accurate?Related attachments include:a.Characterization information summaryb.Summation of aspectsYes. WSPF, Revision 1, plus CIS and summation of aspects reviewed during last EPA inspection.Change Notice 1: submitted 6/22/2011 to update thewaste volume and generating facilities.D-9EPA Inspection No.: INL-CC-2013Waste Stream: ID-SDA-SOILInspection Date: May 7–9, 2013Technical ElementsObjective Evidence/CommentsAK-6:Are nonconformances and discrepancyresolutions documented appropriately?Yes. EPA has previously evaluated INL-CCP’s abilityto produce compliant NCRs several times and did notspecifically review any NCRs associated with ID-SDA-SOIL. INL-CCP has not written any DRs since EPA’slastinspection.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 Lots 74–76 as well ascumulative AK accuracy for Lots 1–76. Accuracy report includes a memorandum summarizing AK accuracy analysis,lists correlating the containers in Lots 74–76 to their BDRs, and CCP-TP-005, Revision 24, Attachment14, notingthat no containers from Lots 1–76 have been evaluated for reassignment. AK accuracy for Lots 1–76 is 100%.EPA also reviewed AK accuracy reports prepared 5/26/2011 and 6/1/2012.AK-8:Is AK-NDA communication adequatelydocumented?Yes. AK-NDA communication documented in CCP-TP-005,Revision 24, Attachment 7, dated 11/30/2011, and theattached NDA memorandum dated 11/2/2011. As statedin checklist Item (AK-4c) above, INL-CCP revises theexpected radionuclides each time an ARP phase is added based on information in WILD. Expected radionuclidesidentified in the NDA memorandum are the same as discussed in checklist Item (4c) above. Because the targetedwaste is from RFP, the NDA memorandum also states that if NDA does not yield valid isotopic results, defaultisotopics based on RFP WG Pu, HEU and DU will be used.AK-9:Has notification of applicable T2 changes beenprovided to EPA as required in the INL-CCP CHtiering table?Yes. EPA tracking began with 4thquarter FY 2009. T2 change notification required for:a.AK-NDA memoranda – EPA received notification of availability of Revision 7 of this memorandum in FY 20121stquarter report as expected.b.AK accuracy reports (annually, at a minimum) – EPAhas received notification of availability of AK accuracyreports annually in the 3rdquarter report. EPA expects this will continue andthat EPA will receive notification ofthe 2013 AK accuracy report (provided to EPA duringthe inspection) in the FY 2013 3rdquarter report.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 category – EPA receivednotification of the availability of the change notice in the FY11 3rdquarter report as expected.e.The load management status of approved waste streams – Status has not changed.D-10ATTACHMENT D.4: AK CONTINUED COMPLIANCE INSPECTIONCHECKLIST: WASTE STREAM ID-ANLE-S5000EPA Inspection No.: INL-CC-2013Waste Stream: ID-ANLE-S5000Inspection Date: May 7–9, 2013Technical ElementsObjective Evidence/CommentsAK-1:Do AK, training and nonconformance proceduresadequately reflect the requirements of 40 CFR194 and have they been adequately implemented?Yes. See Attachment D.1, checklist Item (AK-1).AK-2:Is the AK characterization process, including AKassembly, compilation and verification adequate?Yes. Completed CCP-TP-005 attachments provide objective evidence of AK assembly, compilation and verification.a.Attachment 1, Revision 24, Acceptable Knowledge Documentation Checklist: complete.b.Attachment 2, Record of Communication: Interviews performed post-implementation of CCP-TP-005 aredocumented on CCP-TP-005, Attachment 2 (ReferencesC006, C121, C144, C148 and C380).c.Attachment 3s, various revisions, Acceptable Knowledge Source Document Summary: attached to all inspectedsource documents. Most are Revision 24.d.Attachment 4, Revision 24, Acceptable Knowledge Information List: complete.e.Attachment 5, Hazardous Constituents: outside EPA’spurview; not reviewed.f.Attachment 6, Revision 23, Waste Form, Waste Material Parameters, Prohibited Items, and Packaging: complete.It and the associated WMP analysis memorandum support estimates in AKSR and discussed in checklist Item(AK-4).g.Attachment 7, Revision 18, Radionuclides: Not completed for RH waste. See checklist Item (AK-4) forradiological information.h.Attachment 8, Revision 24, Waste Containers List: updated periodically as waste containers are identified instorage. See checklist Item (AK-5) for additional information about the WSPF, Attachment 8, and add-containermemorandum process, as they are interrelated in thecase of this waste stream. Latest Attachment 8 provided wasdated 4/30/2012.i.Attachment 9, Waste Characterization Data Cross-Reference: reference tool, not a form for completion.j.Attachment 10, Revision 18, Acceptable Knowledge Re-evaluation Checklist, example provided correspondstoDR017.k.Attachment 11, various revisions, Acceptable Knowledge Source Document Discrepancy Resolution: completed asappropriate [see checklist Item (AK-6)]. AssociatedAttachment 3s for the older DR reports were not created untilfall 2012, in response to a programmatic overhaul performed in response to corrective action requiredbyCTAC/CBFO QA audit results.l.Attachment 12, Example Form and Content Guide for AK Summary Reports: reference tool, not a form forcompletion; see review of completed AKSR in checklist Item (AK-4).m.Attachment 13, Revision 24, CCP Waste Stream Characterization Checklist: example provided for Lot 36.n.Attachment 14, Revision 24, CCP Acceptable Knowledge Accuracy Report: completed annually; see checklistItem (AK-7).o.Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form: not applicable to this waste stream.D-11EPA Inspection No.: INL-CC-2013Waste Stream: ID-ANLE-S5000Inspection Date: May 7–9, 2013Technical ElementsObjective Evidence/CommentsAK-3:Are waste containers traceable from retrievalthrough CCP’s EPA-approved characterizationprocess?Yes. Traceability to original container packaging was established during multiple T1 reviews. Drum traceability wasevaluated to determine traceability from original HFEF canister through DTC and found to be adequate.Drum HFEF Canister Repackage Date RTR BDR DTC BDR Lot 32 CIS Lot 32 CRRANLE7E ANLE7 7/23/12 INLRHRTR12014 INLRHDTC12012 10/23/12 10/23/12ANLE12A ANLE12 8/8/12 INLRHRTR12015 INLRHDTC12013 10/23/12 10/23/12AK-4:Does the AK summary report include sufficientinformation, supported by appropriate sourcedocuments, to support the statements below?a.All waste within the waste stream wasgenerated from a single process/activity.b.All waste within the waste stream is similar inmaterial and physical form.c.All waste within the waste stream has similarradiological properties.d.All of the waste in the waste stream is defensein origin.e.None of the waste in the waste stream is highlevel waste.f.None of the waste in the waste stream is spentnuclear fuel.Yes. CCP-AK-INL-500, Revision 11, was reviewed extensively for the selected items as part of the Lot 2b T1approval (EPA Docket No. A-98-49, II-A4-163). The AKSR continues to contain all required items.a.ID-ANLE-S5000 was generated in the ANLE AGHCF M-Wing hot cell facility. The AGHCF is a hot cellcomplex in which metallurgical research and fuel material evaluation and testing are performed. Debriswaste wasgenerated primarily from activities associated withanalysis of post-irradiated nuclear fuel assemblies from fastbreeder and light-water reactors (References C066,C350, C380, C1031, DR018, U015, U017, U018 and U343).b.ID-ANLE-S5000 is composed primarily of organic (22%) and inorganic (78%) debris waste, including cellulosicmaterial such as paper, wood items, boxes, variousplastics (e.g., tygon tubing), rubber items such asgaskets, glassitems such as test tubes, and various metals including carbon and stainless steel from glove box operations. It isassigned to WMC S5400, heterogeneous debris (References C332, C347, C1031, U343, C1002 and U3900).c.ID-ANLE-S5000 was generated during processing of irradiated and unirradiated fuel pins from numerous reactorprograms. The predominant WIPP radionuclides by weight percent are239Pu and240Pu, although the predominantradionuclides overall by weight are235U and239Pu. The predominant WIPP radionuclides by curie percent are137Cs and90Sr, and the predominant overall radionuclides by curie percent are137Cs and55Fe. The high-gammacomponent of the waste stream is composed predominantly of238U and235U by mass, and mixed fission productsand144Ce by curie percent (References C348, C3660, U3607,U3900 and U3901).d.The ANLE mission included defense and non-defense activities. As a result of waste management practices in MWing and the AGHCF, segregation of defense and non-defense waste was not feasible, so Waste Stream IDANLE-S5000 is a commingled defense waste stream generated in part by atomic energy defense activities(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 constituent elements fromreactorfuel and is not considered high-level waste.f.ID-ANLE-S5000 consists of debris generated from thepreparation of irradiated test specimens and includes thosespecimens or portions of specimens. Because the material includes test specimens, DOE does not classify thismaterial as spent nuclear fuel.AK-5:Are the waste stream profile form and relatedattachments complete and adequate/accurate?Related attachments include:a.Characterization information summaryb.Summation of aspectsc.Characterization Reconciliation Reportd.WSPF change noticese.Attachment 8 revisions and add containerYes. WSPF, Revision 0: dated 1/12/2007 and includedthe CIS and summation of aspects. An example CRR for Lot36 was provided, dated 2/13/2013 (latest CRR developed). EPA has evaluated CRR preparation as part ofseveral T1reviews, so previous CRRs were not requested.Change Notice #1: dated 7/6/2007 to add TRUCON codeID 321 to support containers of up to 50% organicwaste.New CIS and CRR are prepared on a lot basis as characterization proceeds; 36 CIS/CRR lots have been prepared forID-ANLE-S5000.INL-CCP does not update the WSPF as the waste stream volume changes, although CCP-TP-002 does indicatethatsignificant changes in waste volume may prompt revision of the WSPF. EPA examined the progression of Attachment8 revisions and add-container memoranda to understand how the waste stream has grown over time. SinceWSPFissuance in 2007, there have been three Attachment8 revisions and eight add-container memoranda (ReferencesD-12EPA Inspection No.: INL-CC-2013Waste Stream: ID-ANLE-S5000Inspection Date: May 7–9, 2013Technical ElementsObjective Evidence/Commentsmemoranda C3660 and M001).AK-6:Are nonconformances and discrepancyresolutions documented appropriately?Yes. EPA examined NCR and DR report preparation during several T1 reviews specific to this waste stream. EPAselected one example NCR, RHINL-0427-13, that was prepared for Drum No. ANLE34E, which is a repackagedhigh-gamma drum that received an NCR due to fissile-gram equivalent requirements. Additionally, EPA obtainedseveral DR reports specific to this waste stream, none of which were recently prepared. The newest DRreport,DR021, was prepared to address document and characterization discrepancies with respect to the size ofinner gallonwaste containers (References NCR RHINL-0427-13, DR014, DR016, DR017, DR018, DR019, DR020 and DR021).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 Lots 1–36. AK accuracy reportmust identify the percentage of containers for which there are significant discrepancies in radionuclide informationbetween the AK record and measured values. INL-CCPstating in the AK accuracy report that there are nosignificantdiscrepancies between the AK information used in the modeling and the qualification of that AK (modeling andsampling). The scaling factors developed for ID-ANLE-S5000 were based on AK, which means that the AKSRis notamenable to AK accuracy evaluations by comparing measurements against AK because this is essentially comparingAK against itself. INL-CCP revised the AK accuracyreport to state, “The scaling factors were developed using AKdata. Comparing the dose-to-curie results to AK data does not result in a meaningful AK accuracy evaluation.” Notethat AK use in the aforementioned scaling factor development was previously approved by EPA (EPA Docket No. A98-49; II-A4-163). With this revision, the AK accuracy report for ID-ANLE-S5000, Lots 1–36 was adequate.The report is updated annually and EPA has examinedAK accuracy report preparation as part of the T1 process.AK-8:Do the radiological characterization report andAKSR agree on fundamental AK information asa demonstration of AK-radiologicalcharacterization communication?Yes. AK-radiological characterization communicationwas thoroughly evaluated during the EPA’s T1 review of IDANLE-S5000 adding the 48 high-gamma drums. AKSR, Revision 11, included radiological data and tables specific tothe high-gamma drums to ensure that the information presented in the radiological characterization report pertaining toradiological characterization unique to the high-gamma drums was identified by AK personnel. Nothing with respectto waste characterization has changed since that review.AK-9:Has notification of applicable T2 changes beenprovided to EPA as required in the INL-CCP CHtiering table?Yes. EPA tracking began with 4thquarter FY 2009. T2 change notification required for:a.WSPF and related attachments – No WSPF changes since EPA tracking began. CRR and CIS prepared byshipping lots but only required to be submitted when WSPF updated.b.Modification of CCP-AK-INL-500 – Revision 11 completed 11/20/2012; notification provided to EPA in FY20131stquarter report as expected.c.CCP-AK-INL-502 – Revision 6 completed 8/1/2012; notification provided to EPA in FY 2012 4thquarter report asexpected.d.AK Accuracy – completed 4/29/2013; EPA expects toreceive notification in the FY 2013 3rdquarter report.e.Attachment 4 – revised 11/26/2012; Notification notprovided to EPA.f.CSSF – CSSF is not applicable.g.Add container memoranda or similar list, when adding to a previously approved population for a waste stream –Not required; add-container memoranda were issued to explain addition of containers within an approvedpopulation or to add containers via approved T1s. Have not yet added containers to the population OUTSIDE ofthe baseline population or approved T1s, although multiple add container memoranda and Attachment 8 revisionshave been prepared to explain drum number changes due to repackaging.D-13EPA Inspection No.: INL-CC-2013Waste Stream: ID-ANLE-S5000Inspection Date: May 7–9, 2013Technical ElementsObjective Evidence/CommentsAK-10Is the certification plan adequately prepared?Yes. The certification plan for ID-ANLE-S5000 was reviewed by EPA during the T1 review approving the Lot 2bhigh-gamma drums (EPA Docket No. A-98-49; II-A4-163) and INL-CCP prepared CCP-AK-INL-502, Revision 6,which adequately addressed EPA’s T1 comments.D-14ATTACHMENT D.5: AK CONTINUED COMPLIANCE INSPECTIONCHECKLIST: WASTE STREAM IN-ID-BTO-030EPA Inspection No.: INL-CC-2013Waste Stream: IN-ID-BTO-030Inspection Date: May 7–9, 2013Technical ElementsObjective Evidence/CommentsAK-1:Do AK, training and nonconformance proceduresadequately reflect the requirements of 40 CFR194 and have they been adequately implemented?Yes. See Attachment D.1, checklist Item (AK-1).AK-2:Is the AK characterization process, including AKassembly, compilation and verification adequate?Yes, although characterization of the waste streamis in progress so that the complete process could not be verified.Available completed CCP-TP-005 attachments provideobjective evidence of AK assembly, compilation andverification as completed at the time of the inspection.a.Attachment 1, Revision 24, Acceptable Knowledge Documentation Checklist: complete.b.Attachment 2, Record of Communication: N/A; none ofthe references provided were interviews.c.Attachment 3s, various revisions, Acceptable Knowledge Source Document Summary: attached to all inspectedsource documents. Most are Revision 24.d.Attachment 4, Revision 24, Acceptable Knowledge Information List: complete.e.Attachment 5, Hazardous Constituents: outside EPA’spurview; not reviewed.f.Attachment 6, Revision 23, Waste Form, Waste Material Parameters, Prohibited Items, and Packaging: complete.It and the associated WMP analysis memorandum support estimates in AKSR and discussed in checklist Item(AK-4).g.Attachment 7, Revision 18, Radionuclides: not completed for RH waste. See Checklist Item (AK-4) forradiological information.h.Attachment 8, Revision 24, Waste Containers List: updated periodically as waste containers are identified instorage. See checklist Item (AK-5) for additional information about the WSPF, Attachment 8, and add containermemorandum process, as they are interrelated in thecase of this waste stream.i.Attachment 9, Waste Characterization Data Cross-Reference: reference tool, not a form for completion.j.Attachment 10, Acceptable Knowledge Re-evaluation Checklist, No checklists have been required.k.Attachment 11, Revision 24, Acceptable Knowledge Source Document Discrepancy Resolution: completed asappropriate [see checklist Item (AK-6)] (ReferencesDR005 and DR006). Original DRs were not available,but theassociated Attachment 3s were provided.l.Attachment 12, Example Form and Content Guide for AK Summary Reports: reference tool, not a form forcompletion; see review of completed AKSR in checklist Item (AK-4).m.Attachment 13, Revision 24, CCP Waste Stream Characterization Checklist. No example available becausecharacterization has not been completed for this waste stream.n.Attachment 14, Revision 24, CCP Acceptable Knowledge Accuracy Report: completed annually. No exampleavailable because characterization has not been completed for this waste stream.o.Attachment 15, Revision 22, CCP TRU Waste Correlation and Surrogate Summary Form: completed 5/19/2011;however, INL-CCP radiological characterization personnel determined that the two streams were composedofwaste from different fuels, so unique sampling of IN-ID-BTO-030 is required and the original CSSF is beingretracted.AK-3:Yes, based on the information that had been released by the Navy at the time of the inspection. The 13IN-41 cans inWaste Stream IN-ID-BTO-030 were generated at Bettis. The containers were shipped in casks to ANL-W atINLD-15EPA Inspection No.: INL-CC-2013Waste Stream: IN-ID-BTO-030Inspection Date: May 7–9, 2013Technical ElementsObjective Evidence/CommentsAre waste containers traceable from retrievalthrough CCP’s EPA-approved characterizationprocess?between 1987 and 1989, where they were unloaded andplaced into HFEF canisters that were transferred to theRWMC ILTSF. The HFEF canisters remained in storageat the ILTSF for over 20 years, at which point theHFEFcanisters were extracted, and original IN-41 containers were removed, repackaged and placed in 30-gallon containersoverpacked by 55-gallon containers. These containers have since undergone RTR and the RTR BDR was provided.During the repackaging process, 8 of the 13 IN-41 containers underwent solid sampling for scaling factordevelopment. (References U200 and U227).IN-41Can No.HFEF Canister No INL Container ID(repackaged drum)RTR BDR Sampled to EstablishScaling Factors42 1377, N-146, 88-107 IDBLANL880107A INLRHRTR12010Yes82 1380,B-364, 88-164 DBLANL880164A INLRHRTR12010 NoAK-4:Does the AK summary report include sufficientinformation, supported by appropriate sourcedocuments, to support the statements below?a.All waste within the waste stream wasgenerated from a single process/activity.b.All waste within the waste stream is similar inmaterial and physical form.c.All waste within the waste stream has similarradiological properties.d.All of the waste in the waste stream is defensein origin.e.None of the waste in the waste stream is highlevel waste.f.None of the waste in the waste stream is spentnuclear fuel.Yes. CCP-AK-INL-590, Revision 2, contains all required items. Note that the document is in flux and may includemodifications when submitted to EPA with a T1 request.a.Bettis Laboratory MEL operations generated 28 containers of RH TRU waste during analysis of post-irradiatednuclear fuel assemblies from naval reactor programs. Waste was generated during destructive examination ofassemblies and consists of various metal fines. Ofthese 28 containers, 13 were solidified in IN-41 cans andshipped to INL for storage. Waste was generated inthe MEL between 1977 and 1987 (References C117, C206,C207, C210, U212, U224 and U236).b.IN-ID-BTO-030 consists predominantly of inorganic waste materials generated during the sectioning of fuelelements, grinding, mounting and polishing of metallographic specimens. It is composed of inorganic metaldebris solidified in cement (References P201, U221,U224 and U276).c.IN-ID-BTO-030 contains137Cs and80Sr as the predominant WIPP radionuclides based on activity fraction,although137mBa and147Pm are the predominant overall radionuclides basedon activity fraction.233U and90Sr arethe predominant WIPP radionuclides based on mass fraction and235U and232Th are the predominant overallradionuclides based on mass fraction (References U200, U275 and U305).d.IN-ID-BTO-030 was generated during the examinationof fuel elements from primarily naval reactor fuelsforevaluation of fuel performance; fuel elements weresourced from nuclear-powered warships, prototype plants,irradiated test specimens and the Shippingport Atomic Power Station. Although commercial activities were alsoperformed, it is not possible to segregate the fines that were solidified based on defense and non-defense origin(References P102, P014 and U201).e.The MEL operations that generated IN-ID-BTO-030 didnot involve separation or reprocessing of constituentelements from reactor fuel and therefore do not contain high-level waste (References P100, U201 and U256).f.IN-ID-BTO-030 contains fines and debris from testing of post-irradiated fuel assemblies but does not contain fullirradiated fuel elements withdrawn from a reactor and therefore does not contain spent nuclear fuel (ReferencesP100, U201 and U256).AK-5:Are the waste stream profile form and relatedattachments complete and adequate/accurate?Related attachments include:a.Characterization information summaryIndeterminate. WSPF was not prepared at the time ofEPA’s inspection. As a result, CRR, CIS and summation ofaspects were not available for review, either.Attachment 8 dated 5/19/2012.IN-ID-BTO-030 is currently in the characterizationprocess, which is complicated by the fact that thewaste streammust be thoroughly vetted by the Navy prior to release of any documentation. Therefore, INL-CCP couldnot preparea draft WSPF or any other draft documents specifically for the inspection because of this mandatory review process.D-16EPA Inspection No.: INL-CC-2013Waste Stream: IN-ID-BTO-030Inspection Date: May 7–9, 2013Technical ElementsObjective Evidence/Commentsb.Summation of aspectsc.Characterization Reconciliation Reportd.WSPF Change noticese.Attachment 8 revisions and Add-ContainerMemosEPA has reviewed the WSPF preparation process for other INL-CCP waste streams and may examine the WSPFduring the forthcoming IN-ID-BTO-030 T1 review.AK-6:Are nonconformances and discrepancyresolutions documented appropriately?Indeterminate. No NCRs have been prepared for the waste stream; characterization is still in progress,as is review ofthe AKSR.DR005 and DR006 were prepared, but only the Attachment 3s for these DRs were available for EPA reviewat thetime of the inspection. DR005 dealt with hazardouswaste number identification, and DR006 addressed innercontainers used during the cementation process.EPA has reviewed the nonconformance and discrepancyresolutionprocess for other INL-CCP waste streams and may examine NCRs and DRs during the forthcoming IN-ID-BTO-030T1 review.AK-7:Is the AK accuracy report technically adequate?Has it been updated annually?Indeterminate. Characterization is not complete forID-IN-BTO-030, so no AK accuracy report was prepared. EPAhas reviewed the AK accuracy process for other INL-CCP waste streams and may examine AK Accuracy reportsduring the forthcoming IN-ID-BTO-030 T1 review.AK-8:Do the radiological characterization report andAKSR agree on fundamental AK information asa demonstration of AK-radiologicalcharacterization communication?Indeterminate. The radiological characterization report for Waste Stream IN-ID-BTO-030 was not available for EPAreview at the time of the inspection. EPA has reviewed AK-radiological characterization communicationfor otherINL-CCP waste streams and may examine the radiological characterization report during the forthcomingIN-IDBTO-030 T1 review. The sampling plan described thesamples collected for radiological characterization, and thepost-sampling memorandum described results of the sampling and analysis process. Note that EPA was notprovided acopy of the post-sampling memorandum and was only briefly allowed to examine its contents because theNavy hadyet to release the document for public review. INL-CCP collected eight samples from Waste Stream IN-ID-BTO-030,the results of which will be used in future scalingfactor development.AK-9:Has notification of applicable T2 changes beenprovided to EPA as required in the INL-CCP CHtiering table?No. Most of the documents required for T2 notification have not been completed and, therefore, EPA hasnot receivednotification of their completion. INL-CCP has completed CCP-AK-INL-590, Revision 0 (6/7/2011), Revision 1(12/27/2011) and Revision 2 (4/4/2012) but has notincluded these reports in the T2 quarterly report.Similarly, INLCCP has completed CCP-AK-INL-592, Revision 0 (4/18/2011) and Revision 1 (8/16/2012), and these reportswerealso not included in any of the T2 quarterly reports. EPA expects that any future revisions of these reports will beincluded in the appropriate T2 quarterly report.AK-10Is the certification plan adequately prepared?Yes. CCP-AK-INL-592, Revision 1, is being reviewedinternally by the Navy and others and may be revised whensubmitted to EPA with the T1 request. Because the certification plan may be significantly revised, EPAwill reservecomment on the document until the revised version is provided as part of a forthcoming T1.E-1ATTACHMENT E.1: NDA CONTINUED COMPLIANCE INSPECTIONCHECKLIST: WAGSTechnicalElementsObjective EvidenceAdditional CommentsGeneralWAGS-1:Confirm the NDA system is the WAGS, itslocation and number.Located in Building WMF-610 at INL RWMC. The WAGS has no other name orlocation designations.EPA inspectors found the WAGSto be located in Building 610,unmoved since the previousinspection.WAGS-2:Describe the WAGS.The WAGS utilizes six high-resolution BEGe gamma detectors, a drum turntableand a shielded enclosure. One bank (North top, middle and bottom) of each ofthree gamma detectors is fitted with approximatelythree millimeters of lead andthree millimeters of cadmium, with a thin layer ofcopper to acquire quantitativegamma 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/AWAGS-3:Identify the consensus standards that were usedfor the system calibrationASTM C-1030, C-1133, C-1215, E-181.CCP-INL-WAGS-003, Revision 0.As stated in CCP-INL-WAGS003, Revision 0, and confirmedduring interview with NDApersonnel.WAGS-4:Describe the system’s operational history sincethe baseline approval.The WAGS assay system has been in operation supporting the work performed byINL-CCP since 4/26/2005. During this time, variousQC criteria have beenmonitored to verify the continued acceptable performance of the system.As stated in CCP-INL-WAGS003, Revision 0, and confirmedduring interview with NDApersonnel.WAGS-5:Identify the container types assayed on theWAGSThe WAGS may assay 55-gallon drums only. Visual inspection confirms nocontainers larger than 55 gallonscould be assayed by theinstrument.WAGS-6:Identify the period of performance relevant to theWAGS and the number of BDRs and wastecontainers this system assayed during the period.From May 1, 2012 to May 6, 2013, the WAGS assayed 1,444 drums contained in119 BDRs. The WAGS can assay a maximum of 13–14 drums each day.As stated by NDA personnelduring inspection.WAGS-7:Confirm that the WAGS is able to reportquantitative values for the WIPP-trackedradionuclidesDirect Measurements:239Pu,241Am,233U,235U,238U and137Cs.Isotopic Fractions:238Pu,240Pu,241Pu,242Pu by correlation and241Am relative toPu.Radionuclides by Scaling:90Sr and234U.CCP-INL-WAGS-003, Revision 0.As stated in CCP-INL-WAGS003, Revision 0, and confirmedwith NDA personnel duringinspection.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.Confirmed with NDA personnelduring inspection.E-2TechnicalElementsObjective EvidenceAdditional CommentsWAGS-9:Identify the procedures that govern this functionand where the results of these calculations aredocumented.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.These procedures are the mostcurrent revisions. Copies of eachwere found and easily accessibleat the WAGS operator station.WAGS-10:Confirm that the methods used to derive theisotopic contribution for unmeasuredradionuclides 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).Confirmed through interviewswith INL-CCP WAGS personnelduring inspection.WAGS-11:Confirm the WAGS operational range withrespect to matrix (density) and activity.~0.010 g to 200 g total Pu (calibration-based and administrative). Limited byLLD and system dead time. Calibration makes the assumption that matrixmaterials are mainlyZ< 15. Waste matrix materials outside density rangeforcalibrated efficiency together with presence of higherZmaterials require expertreview.EPA confirmed this with NDApersonnel. This range is the sameas previously approved by EPA.Calibration Verification and ConfirmationWAGS-12:Identify the date of the last calibrationverification. Have any others been completed inthe last year?11/29/2012, following the replacement of the DSA 1000 power supply (CCPINL- WAGS-12-005, 12/3/2012).Confirmed with NDA personnelduring the inspection.WAGS-13:Confirm the pedigree of all radionuclidestandards that were used for calibrationconfirmation and/or verifications. List orreference 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. Sourcecertifications are listed in Attachment 1.EPA reviewed all sourcecertificated found in CCP-INLWAGS-003, Attachment 1. Allstandards are independentlycertified and acceptable to use forthe WAGS calibration.WAGS-14:Requirements for accuracy and precision must bemet, as specified in DOE/WIPP-02-3122,Appendix A, Table A-3.2 for calibrationverifications.The calibration verification results are containedin Section 5 of CCP-INLWAGS-003, WAGS Calibration, Confirmation and Verification Report, Revision0, May 14, 2011. % R was found to be between 70 and130 % and % RSD wasfound to be less than 14%.Accuracy and precision criteriawere met for all calibrationverifications.WAGS-15:Describe the mishandling of the DPC drum inDecember 2011 and corrective actions applied.CCP-INL-WAGS-11-005 describes the event and CCP-INL-WAGS-12-002describes corrective actions taken by INL-CCP.The event was responded toappropriately and was correctlydocumented as confirmed by EPAreviewers.WAGS-16:The133Be transmission source has a ~10-yearhalf-life. When was the count rate last reevaluatedin the system?Sources were installed in January 2009 and were evaluated in July 2011 and July2012. This is documented in CCP-INL-WAGS-12-003, July 19, 2012.Reevaluation is prompted when the counts start to fall below the boundaryconditions due to the decay of133Ba.Confirmed with NDA personnelduring the inspection.E-3TechnicalElementsObjective EvidenceAdditional CommentsLLDWAGS-17:Confirm that the LLD for the WAGS has beendetermined.The LLD is documented in Section 5 of CCP-INL-WAGS-003, Revision 0. Alltransmission-corrected LLD results indicate that the instrument meets the WACTRU/LLW discrimination criterion of 100 nCi/g or less, with the exception of241Am in a plastic foam matrix drum.Confirmed through interviewswith INL-CCP WAGS personnelduring inspection.WAGS-18:Confirm if the WAGS is used to discriminateTRU/non-TRU wastes at the 100 nCi/g criterionand that it has the required sensitivity.The WAGS can discriminate between LLW and TRU wastebased on the LLDsreported in Section 5 of CCP-INL-WAGS-003, Revision0 for all measuredradionuclides but241Am. If the presence of241Am is indicated but not reported ina drum with a density of less than 0.44 kg/L, thenonly higher energy gammalines will be used for quantification of the241Am activity.Total nCi/g of each drum isreported in the BDR associatedwith the drum. In severalinstances, a drum with an activityof less than 100 nCi/g was foundin the BDRs. INL-CCP indicatedthese drums will be load managed.WAGS-19:Identify any/all instances where an LLD value foranon-measuredradionuclide is not providedbased on a lack of technical feasibility.Because an LLD is a measurement-based parameter, it is not technically feasibleto calculate for radionuclides that are not directly measured. Plutonium isotopes238Pu,240Pu and242Pu are not usually directly measured by gamma spectroscopyand are instead derived by ratios to measured239Pu. The reporting threshold for90Sr is computed based on the reported137Cs LLD using an activity ratiodetermined from AK NDA memos. INL-CCP states that it is not technicallyfeasible to provide an LLD equivalent for234U and that it is derived by algorithmfrom measured values of235U,238U and238Pu.This is confirmed in section 7 ofCCP-INL-WAGS-003, Revision0.Quality ControlWAGS-20:All operators have current CCP training asverified on LOQI.LOQI provided on 5/6/2013 contains six operators, all with current training.EPA verified that the operatorslisted in the LOQI match thoselisted in the logbook. The logbookalso included an operator, R.Green, who was not listed on thecurrent LOQI but was listed onprevious LOQIs. NDA personnelindicated that he retired in May2013 and thus was no longer aqualified operator.WAGS-21:Confirm the WAGS’s status with respect to theCBFO NDA PDP and last cycle.The WAGS successfully participated in drum cycle 19A of the CBFO NDA PDP.EPA verified the successfulparticipation in the PDP approvalletter.E-4TechnicalElementsObjective EvidenceAdditional CommentsWAGS-22:All WAGS data must be reviewed and approvedby qualified personnel. Identify the name andfunction of the individuals performing technicalreview 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 individuals performing thetechnical review are qualified.WAGS-23:Identify any NCRs within the last year.There have been three NCRs on the WAGS in the lastyear:NCR-INL-0368-12.NCR-INL-0362-12.NCR-INL-0350-12.Confirmed during interviews withINL-CCP personnel duringinspection.TMUWAGS-24:Identify any changes to the method or details ofthe TMU calculation since baseline.No changes to the TMU were made since EPA’s last inspection.Confirmed during interviews withINL-CCP personnel duringinspectionWAGS-25:Evaluate the magnitude of the TMU valuesobserved in the WAGS BDRs that wereexamined during this inspection.The TMU for the WAGS is documented in CCP-INL-WAGS-002, TotalMeasurement Uncertainty for the WAGS System, datedApril 20, 2005. Thisdocument does not have a revision number. The components of uncertaintyincluded in the TMU determination consist of calibration source uncertainties,counting statistics, self-absorption effects, matrix nonhomogeneities, nonuniformsource distributions and isotopic measurement uncertainties. The software forperforming the TMU calculations is embedded in theNDA 2000 software. CCPINL-WAGS-002 calls for administrative procedures that would define aminimum fill-height requirement to reduce the potential for increaseduncertainties due to end effects. TMU values in BDRs are generally consistentwith expectations.Confirmed during interviews withINL-CCP personnel duringinspection.Background and Performance ChecksWAGS-26:Confirm that WAGS background measurementshave been taken daily.Confirm that WAGS background measurements have beentaken daily. EPA confirmed this occurs duringinterviews with NDA personnel.The logbook entries selected atrandom by EPA to review (dated1/2/13 and 1/31/13) containedevidence of these measurements.E-5TechnicalElementsObjective EvidenceAdditional CommentsWAGS-27:Assess how often background radiation wasproblematic to the extent that measurementpersonnel had to make adjustments.No instances of problematic backgrounds were observed in the last year. EPA confirmed this duringinterviews with NDA personnel.WAGS-28:Confirm that system performance checks havebeen performed at least once per operational day.Confirm that performance checks include gammaand neutron efficiency, matrix correction checks,and gamma peak position and resolution checks.Performance checks are done once per day as statedin CCP-TP-019, Revision 6. EPA confirmed this occurs duringinterviews with NDA personnel.The logbook entries selected atrandom by EPA to review (dated1/2/13 and 1/31/13) containedevidence of these checks.Data ManagementWAGS-29:WAGS BDRs contain:•Testing facility name, testing batch number,container numbers, and signature of the SPMor designee•Table of contents•Background and performance check data orcontrol charts for the relevant time period•Separate testing report sheets for eachcontainerEPA reviewed WAGS BDRs INNDAW130036 and INND120076and foundthem to contain appropriate information.N/AWAGS-30:WAGS RDSs must include:•Title “Radioassay Data Sheet”•Method/procedure used•Date of radioassay•Activities and associated TMU for individualradionuclides•TRU alpha concentration and its associatedTMU•Operator and reviewer signaturesEPA reviewed WAGS BDRs INNDAW130036 and INND120076and found thateach drum contained in the two BDRs had an RDS containing the correctelements.N/AE-6ATTACHMENT E.2: NDA CONTINUED COMPLIANCE INSPECTIONCHECKLIST: SGRSTechnicalElementsObjective EvidenceAdditional CommentsGeneralSGRS-1:Confirm the NDA system is the SGRS, itslocation and number.Located in Building WMF-610 at INL RWMC. EPA inspectors found the SGRS tobe located in Building 610,unmoved since the previousinspection.SGRS-2:Describe the SGRS.The SGRS is a gamma-based system that uses four high-resolution BEGe gammadetectors, a drum turntable, shielded enclosure, and supporting electronics. TheSGRS performs quantitative assays and corrects thesummed gamma peaks forattenuation using a multi-curve calibration that computes efficiency as a functionof waste density and photon energy. Live-time corrections are performed using apulser. Isotopics are determined from the same spectra using MGA and MGA-U.Default isotopics are employed when empirical results are not useable. The fourgamma detectors are arranged vertically and acquirespectra for all verticalsegments simultaneously. The system runs NDA 2000 as well as MGA andMGA-U. When plutonium isotopes are not detected, the software attempts tocompute isotopic distributions for uranium isotopesusing the MGA-U program.The isotopic determination is performed simultaneously with the quantitativeassay, and, if measurement-based isotopics are notavailable, default AK valuesare used. The SGRS derives a value for242Pu by correlation, and90Sr isdetermined by application of a scaling factor basedon137Cs.234U is quantifiedbased on measured values for235U and238U.N/ASGRS-3:Identify the consensus standards that were usedfor the system calibration.The consensus standards that are used in the calibration are ASTM C-1030, C1133, C-1215 and E-181.As stated in CCP-INL-SGRS-001,Revision 2, and confirmed duringinterview with NDA personnel.SGRS-4:Describe the system’s operational history sincethe last EPA inspection.Since the 2010 EPA inspection, the DETA4 has been replaced. Due to thischange, the detector was recalibrated and requireda T1 approval. EPA approvedthis change in February 2013. There have been no other significant changes sincethat time.As stated in CCP-INL-SGRS-001,Revision 2, and confirmed duringinterview with NDA personnel.SGRS-5:Identify the container types assayed on the SGRS.The SGRS can only assay 55-gallon drums. Visual inspection confirms nocontainers larger than 55 gallonscould be assayed by theinstrument.SGRS-6:Identify the period of performance relevant to thisapplication of the SGRS. Since this time, identifythe number of waste containers this system hasassayed and then number of BDRs assembled.From May 1, 2012, to May 6, 2013, the SGRS assayed1,246 drums contained in41 BDRs. Of these assays, 697 drum were productionassays and 549 assays werefor information purposes only. The WAGS can assay amaximum of 35 drumseach day.As stated by NDA personnelduring inspection.E-7TechnicalElementsObjective EvidenceAdditional CommentsSGRS-7:Confirm that the SGRS is able to reportquantitative values for the WIPP-trackedradionuclidesDirect Measurements:239Pu,241Am,233U,235U,238U and137Cs.Isotopic Fractions:238Pu,240Pu,241Pu,242Pu by correlation and241Am relative toPu.Radiouclides by Scaling:90Sr and234U.As stated in CCP-INL-SGRS-001,Revision 2. This was alsoconfirmed with NDA personnelduring inspection.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 recentSGRS T1 approval in February 2013.Confirmed with NDA personnelduring inspection.SGRS-9:Identify the procedures that govern this functionand where the results of these calculations aredocumented.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.These procedures are the mostcurrent revisions. Copies of eachwere found and easily accessible atthe SGRS operator station.SGRS-10:Confirm that the methods used to derive theisotopic contribution for unmeasuredradionuclides 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.Confirmed through interviews withINL-CCP SGRS personnel duringinspection.SGRS-11:Where is the actual efficiency calibration for theSGRS documented?It is documented in CCP-INL-SGRS-001, Revision 2, and its attachments. N/ASGRS-12:Confirm the SGRS operational range with respectto matrix (density) and activity.~0.010 g to 200 g total Pu (calibration-based and administrative). Limited byLLD and system dead time. Calibration makes the assumption that matrixmaterials are mainlyZ< 15. Waste matrix materials outside density rangeforcalibrated efficiency together with presence of higherZmaterials require expertreview.This was confirmed with NDApersonnel. It is the sameoperational range that has beenpreviously approved by EPA.Calibration Verification and ConfirmationSGRS-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 ofDET2A gamma detector, as is documented in CCP-INL-SGRS-12-005 and CCPINL-SGRS-12-003. No other calibration verificationshave been done since theSGRS’s recalibration in November 2012.This was confirmed with NDApersonnel.SGRS-14:Confirm the pedigree of all radionuclidestandards that were used for calibrationconfirmation and/or verifications. List orreference all standards used.The standards are summarized in Table 1 of CCP-INL-SGRS-001, SGRSCalibration, Confirmation and Verification Report,Revision 2, November 14,2012. Source certifications are listed in Attachment 1 of the same document.EPA reviewed all sourcecertificates found in CCP-INLSGRS-001, Attachment 1. Allstandards are independentlycertified and acceptable to use forthe SGRS calibration.E-8TechnicalElementsObjective EvidenceAdditional CommentsSGRS-15:Requirements for accuracy and precision must bemet, as specified in DOE/WIPP-02-3122,Appendix A, Table A-3.2 for calibrationverifications.The calibration verification results are containedin 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 than14%.Accuracy and precision criteriawere met for all calibrationverifications.LLDSGRS-16:Confirm that the LLD for the SGRS has beendetermined.Section 6 of CCP-INL-SGRS-001, Revision 2 documentsthe LLD determinationof measured radioisotopes. LLDs for all measured radionuclides in plastic foam,soft board, particle board and sand matrices were below the 100 nCi/g TRUthreshold.Interviews with INL-CCP SGRSpersonnel during inspection.SGRS-17:Confirm if the SGRS is used to discriminateTRU/non-TRU wastes at the 100 nCi/g criterionand that it has the required sensitivity.The SGRS can discriminate between LLW and TRU wastebased on the LLDsreported in Section 6 of CCP-INL-SGRS-001, Revision2 for all measuredradionuclides.Total nCi/g of each drum isreported in the BDR associatedwith the drum. In several instances,a drum with an activity of less than100 nCi/g was found in the BDRs.INL-CCP indicated these drumswill be load managed.SGRS-18:Identify any/all instances where an LLD value foranon-measuredradionuclide is not providedbased on a lack of technical feasibility.Because an LLD is a measurement-based parameter, itis not technically feasibleto calculate for radionuclides that are not directly measured. Plutonium isotopes238Pu,240Pu and242Pu are not usually directly measured by gamma spectroscopyand are instead derived by ratios to measured239Pu. The reporting threshold for90Sr is computed based on the reported137Cs LLD using an activity ratiodetermined from AK NDA memos. INL-CCP states that it is not technicallyfeasible to provide an LLD equivalent for234U and it is derived by algorithmfrom measured values of235U and238U.This is confirmed in section 7 ofCCP-INL-SGRS-001, Revision 2.Quality ControlSGRS-19:All operators have current CCP training asverified on LOQILOQI provided 4/24/2012 contains six operators, allwith current training. EPA verified that the operatorslisted in the LOQI match thoselisted in the logbook. The logbookalso included an operator, R.Green, who was not listed on thecurrent LOQI but was listed onprevious LOQIs. NDA personnelindicated that he retired in May2013 and thus was no longer aqualified operator.E-9TechnicalElementsObjective EvidenceAdditional CommentsSGRS-20:Confirm the SGRS’s status with respect to theCBFO NDA PDP and last cycle.The SGRS has a temporary post-recalibration approval from CBFO NDA PDPthat expires in August 18, 2013. The SGRS is scheduled to participate in the nextPDP cycle.EPA verified the successfulparticipation in the PDP letter.SGRS-21:All SGRS data must be reviewed and approvedby qualified personnel. Identify the name andfunction of the individuals performing technicalreview 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 individuals performing thetechnical review are qualified.SGRS-22:Identify any hardware and/or software changesmade to the SGRS since the baseline approval.Determine which changes, if any, are significant,where they are documented, and how they affectthe SGRS’s baseline approval.DET2A gamma detector was replaced in November 2012.This required theSGRS be recalibrated. EPA evaluated this recalibration and approved it inFebruary 2013. There have been no changes to the system since that time.Confirmed during interviews withINL-CCP personnel duringinspection.SGRS-23:Identify any NCRs within the last year.There have been three NCRs on the SGRS in the lastyear:NCR-INL-1245-12.NCR-INL-0349-12.NCR-INL-0065-13.Confirmed during interviews withINL-CCP personnel duringinspection.TMUSGRS-24:Identify any changes to the method or details ofthe TMU calculation since baseline.No changes to the TMU were made since EPA’s last inspection.Confirmed during interviews withINL-CCP personnel duringinspection.E-10TechnicalElementsObjective EvidenceAdditional CommentsSGRS-25:Evaluate the magnitude of the TMU valuesobserved in the SGRS BDRs that were examinedduring this inspection.The TMU for the SGRS was documented in CCP-INL-SGRS-002, TotalMeasurement Uncertainty for the SGRS System, datedApril 21, 2005. Thisdocument does not have a revision number. The components of uncertaintyincluded in the TMU determination consisted of calibration source uncertainties,counting statistics, self-absorption effects, matrix nonhomogeneities, nonuniformsource distributions and isotopic measurement uncertainties. The software forperforming the TMU calculations is embedded in theNDA 2000 software. CCPINL-SGRS-002 calls for “administrative procedures”that would define aminimum fill-height requirement to reduce the potential for increaseduncertainties due to end effects. Addressing this is left to the expert reviewer,who “should assess those assays for the potential end effects uncertainties andadd the appropriate uncertainty amounts to the TMUwhere applicable.” TMUvalues in BDRs are generally consistent with expectations based on CCP-INLSGRS-002.Confirmed during interviews withINL-CCP personnel duringinspection.Background and Performance ChecksSGRS-26:Confirm that SGRS background measurementshave been taken daily.All records evaluated indicate compliant backgroundperformance. EPA confirmed this occurs duringinterviews with NDA personnel.The logbook entries selected atrandom by EPA to reviewcontained evidence of thesemeasurements.SGRS-27:Assess how often background radiation wasproblematic to the extent that measurementpersonnel had to make adjustments.No instances of problematic backgrounds were observed. Between the SGRS andthe outside wall of Building 610 is a layer of leadsheeting designed to reducebackground increases from material being moved outside of the building. Thislayer has been in place since before EPA’s last inspection.EPA confirmed background checksoccur daily but have not been aproblem during interviews withNDA personnel.SGRS-28:Confirm that system performance checks havebeen performed at least once per operational day.Confirm that performance checks include gammaand neutron efficiency, matrix correction checks,and gamma peak position and resolution checks.Performance checks are done once per day as statedin CCP-TP-115, Revision 5. EPA confirmed this occurs duringinterviews with NDA personnel.The logbook entries selected atrandom by EPA to reviewcontained evidence of thesechecks.E-11TechnicalElementsObjective EvidenceAdditional CommentsData ManagementSGRS-29:SGRS BDRs contain:•Testing facility name, testing batch number,container numbers, and signature of the SPMor designee•Table of contents•Background and performance check data orcontrol charts for the relevant time period•Data validation per the QAPD and siteprocedures•Separate testing report sheets for eachcontainerEPA reviewed SGRS BDRs INNDAS130001 and INNDAS120034 and foundthem to contain appropriate information.N/ASGRS-30:SGRS RDSs must include:•Title “Radioassay Data Sheet”•Method/procedure used•Date of radioassay•Activities and associated TMU for individualradionuclides•TRU alpha concentration and its associatedTMU•Operator and reviewer signaturesEPA reviewed SGRS BDRs INNDAS130001 and INNDAS120034 and foundthat each drum contained in the two BDRs had an RDScontaining the correctelements.N/AF-1ATTACHMENT F.1: REPLICATE TESTING DATA FOR DRUM ARP70420 – SGRSInstrument: SGRSDrum: ARP70420Quantity of InterestOriginal Measurement Replicate #1 Replicate #2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci)8.26E-055.12E-056.20E-018.84E-055.47E-056.19E-018.40E-055.20E-056.19E-01238U Activity (Ci)4.18E-041.53E-043.66E-014.29E-041.57E-043.66E-014.09E-041.50E-043.67E-01238Pu Activity (Ci)3.43E-042.22E-046.47E-013.71E-042.02E-045.45E-013.45E-041.88E-045.45E-01239Pu Activity (Ci)1.24E-026.51E-035.25E-011.35E-025.26E-033.90E-011.25E-024.90E-033.92E-01240Pu Activity (Ci)2.76E-031.46E-035.29E-012.99E-031.20E-034.01E-012.78E-031.11E-033.99E-01242Pu Activity (Ci)3.58E-072.62E-077.32E-013.88E-072.50E-076.44E-013.61E-072.32E-076.43E-01241Am Activity (Ci)7.29E-023.36E-024.61E-017.63E-022.99E-023.92E-017.27E-022.85E-023.92E-0190Sr Activity (Ci)5.63E-072.37E-074.21E-015.21E-072.10E-074.03E-015.45E-072.08E-073.82E-01137Cs Activity (Ci)5.11E-072.16E-074.23E-014.74E-071.91E-074.03E-014.95E-071.89E-073.82E-01TRU Alpha Conc. (nCi/g)9.19E+023.56E+023.87E-019.68E+023.16E+023.26E-019.18E+023.00E+023.27E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci)8.37E-055.18E-056.19E-018.15E-055.04E-056.18E-018.22E-052.62E-053.19E-01238U Activity (Ci)4.30E-041.57E-043.65E-014.19E-041.53E-043.65E-014.17E-041.53E-043.67E-01238Pu Activity (Ci)3.48E-041.90E-045.46E-013.43E-041.92E-045.60E-013.37E-041.84E-045.46E-01239Pu Activity (Ci)1.26E-024.93E-033.91E-011.24E-025.10E-034.11E-011.22E-024.81E-033.94E-01240Pu Activity (Ci)2.80E-031.12E-034.00E-012.76E-031.16E-034.20E-012.71E-031.09E-034.02E-01242Pu Activity (Ci)3.64E-072.34E-076.43E-013.59E-072.35E-076.55E-013.52E-072.28E-076.48E-01241Am Activity (Ci)7.40E-022.92E-023.95E-017.07E-022.79E-023.95E-017.19E-022.83E-023.94E-0190Sr Activity (Ci)5.71E-072.18E-073.82E-015.86E-072.23E-073.81E-015.58E-072.13E-073.82E-01137Cs Activity (Ci)5.19E-071.98E-073.82E-015.32E-072.03E-073.82E-015.07E-071.94E-073.83E-01TRU Alpha Conc. (nCi/g)9.34E+023.08E+023.30E-018.97E+022.95E+023.29E-019.06E+022.99E+023.30E-01F-2Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|c2|)ReportedValueAbsoluteUncertainty233U Activity (Ci)0.00E+00 N/AN/A N/A N/AN/A N/A234U Activity (Ci)8.26E-05 5.12E-058.40E-05 2.69E-06 3.20E-021.10E-02 1.00E+00238U Activity (Ci)4.18E-04 1.53E-044.21E-04 8.79E-06 2.09E-021.32E-02 1.00E+00238Pu Activity (Ci)3.43E-04 2.22E-043.49E-04 1.30E-05 3.74E-021.38E-02 1.00E+00239Pu Activity (Ci)1.24E-02 6.51E-031.26E-02 5.03E-04 3.98E-022.39E-02 1.00E+00240Pu Activity (Ci)2.76E-03 1.46E-032.81E-03 1.07E-04 3.81E-022.15E-02 1.00E+00242Pu Activity (Ci)3.58E-07 2.62E-073.65E-07 1.37E-08 3.76E-021.09E-02 1.00E+00241Am Activity (Ci)7.29E-02 3.36E-027.31E-02 2.15E-03 2.93E-021.63E-02 1.00E+0090Sr Activity (Ci)5.63E-07 2.37E-075.56E-07 2.49E-08 4.47E-024.41E-02 1.00E+00137Cs Activity (Ci)5.11E-07 2.16E-075.05E-07 2.23E-08 4.41E-024.26E-02 1.00E+00TRU Alpha Conc. (nCi/g)9.19E+02 3.56E+029.25E+02 2.79E+01 3.02E-022.46E-02 1.00E+00Quantity of InteresttPr(x<|t|)χ2TesttTest233U Activity (Ci)N/A N/ANot Applicable Not Applicable234U Activity (Ci)-4.62E-01 6.68E-01Not Significant Not Significant238U Activity (Ci)-2.91E-01 7.86E-01Not Significant Not Significant238Pu Activity (Ci)-4.06E-01 7.06E-01Not Significant Not Significant239Pu Activity (Ci)-4.36E-01 6.86E-01Not Significant Not Significant240Pu Activity (Ci)-4.09E-01 7.03E-01Not Significant Not Significant242Pu Activity (Ci)-4.53E-01 6.74E-01Not Significant Not Significant241Am Activity (Ci)-9.36E-02 9.30E-01Not Significant Not Significant90Sr Activity (Ci)2.50E-01 8.15E-01Not Significant Not Significant137Cs Activity (Ci)2.29E-01 8.30E-01Not Significant Not SignificantTRU Alpha Conc. (nCi/g)-1.83E-01 8.64E-01Not Significant Not SignificantF-3ATTACHMENT F.2: REPLICATE TESTING DATA FOR DRUM SRP13045– SGRSInstrument: SGRSDrum: SRP13045Quantity of InterestOriginal Measurement Replicate #1 Replicate #2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci)N/AN/AN/A238U Activity (Ci)N/AN/AN/A238Pu Activity (Ci)3.29E-041.60E-044.86E-013.22E-041.56E-044.85E-013.30E-041.59E-044.82E-01239Pu Activity (Ci)1.19E-023.60E-033.03E-011.17E-023.46E-032.96E-011.20E-023.54E-032.95E-01240Pu Activity (Ci)2.65E-038.29E-043.13E-012.60E-038.00E-043.08E-012.66E-038.17E-043.07E-01242Pu Activity (Ci)3.44E-072.04E-075.93E-013.37E-072.00E-075.94E-013.46E-072.04E-075.90E-01241Am Activity (Ci)N/AN/AN/A90Sr Activity (Ci)N/AN/AN/A137Cs Activity (Ci)N/AN/AN/ATRU Alpha Conc. (nCi/g)1.39E+023.45E+012.48E-011.37E+023.33E+012.43E-011.40E+023.40E+012.43E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci)N/AN/AN/A238U Activity (Ci)N/AN/AN/A238Pu Activity (Ci)3.23E-041.56E-044.83E-013.23E-041.56E-044.83E-013.28E-041.58E-044.82E-01239Pu Activity (Ci)1.17E-023.46E-032.96E-011.17E-023.46E-032.96E-011.19E-023.51E-032.95E-01240Pu Activity (Ci)2.60E-038.00E-043.08E-012.60E-038.00E-043.08E-012.64E-038.10E-043.07E-01242Pu Activity (Ci)3.38E-072.00E-075.92E-013.38E-072.00E-075.92E-013.43E-072.03E-075.92E-01241Am Activity (Ci)N/AN/AN/A90Sr Activity (Ci)N/AN/AN/A137Cs Activity (Ci)N/AN/AN/ATRU Alpha Conc. (nCi/g)1.37E+023.33E+012.43E-011.37E+023.33E+012.43E-011.39E+023.37E+012.42E-01F-4Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|c2|)ReportedValueAbsoluteUncertainty233U Activity (Ci)0.00E+00 N/AN/A N/A N/AN/A N/A234U Activity (Ci)0.00E+00 N/AN/A N/A N/AN/A N/A238U Activity (Ci)0.00E+00 N/AN/A N/A N/AN/A N/A238Pu Activity (Ci)3.29E-04 1.60E-043.25E-04 3.56E-06 1.10E-021.98E-03 1.00E+00239Pu Activity (Ci)1.19E-02 3.60E-031.18E-02 1.41E-04 1.20E-026.17E-03 1.00E+00240Pu Activity (Ci)2.65E-03 8.29E-042.62E-03 2.83E-05 1.08E-024.66E-03 1.00E+00242Pu Activity (Ci)3.44E-07 2.04E-073.40E-07 3.91E-09 1.15E-021.47E-03 1.00E+00241Am Activity (Ci)0.00E+00 N/AN/A N/A N/AN/A N/A90Sr Activity (Ci)0.00E+00 N/AN/A N/A N/AN/A N/A137Cs Activity (Ci)0.00E+00 N/AN/A N/A N/AN/A N/ATRU Alpha Conc. (nCi/g)1.39E+02 3.45E+011.38E+02 1.41E+00 1.02E-026.72E-03 1.00E+00Quantity of InteresttPr(x<|t|)χ2TesttTest233U Activity (Ci)N/A N/ANot Applicable Not Applicable234U Activity (Ci)N/A N/ANot Applicable Not Applicable238U Activity (Ci)N/A N/ANot Applicable Not Applicable238Pu Activity (Ci)9.73E-01 3.85E-01Not Significant Not Significant239Pu Activity (Ci)6.45E-01 5.54E-01Not Significant Not Significant240Pu Activity (Ci)9.68E-01 3.88E-01Not Significant Not Significant242Pu Activity (Ci)8.40E-01 4.48E-01Not Significant Not Significant241Am Activity (Ci)N/A N/ANot Applicable Not Applicable90Sr Activity (Ci)N/A N/ANot Applicable Not Applicable137Cs Activity (Ci)N/A N/ANot Applicable Not ApplicableTRU Alpha Conc. (nCi/g)6.45E-01 5.54E-01Not Significant Not SignificantF-5ATTACHMENT F.3: REPLICATE TESTING DATA FOR DRUM ARP70259– SGRSInstrument: SGRSDrum: ARP70259Quantity of InterestOriginal Measurement Replicate #1 Replicate #2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci)1.98E-051.17E-055.91E-012.01E-051.19E-055.92E-011.99E-051.18E-055.93E-01238U Activity (Ci)6.03E-091.95E-093.23E-016.05E-051.94E-053.21E-016.00E-051.93E-053.22E-01238Pu Activity (Ci)2.21E-041.14E-045.16E-012.22E-041.13E-045.09E-012.20E-041.13E-045.14E-01239Pu Activity (Ci)7.98E-032.76E-033.46E-018.05E-032.71E-033.37E-017.99E-032.77E-033.47E-01240Pu Activity (Ci)1.77E-036.30E-043.56E-011.79E-036.57E-043.67E-011.77E-036.33E-043.58E-01242Pu Activity (Ci)2.30E-071.42E-076.17E-012.32E-071.42E-076.12E-012.31E-071.42E-076.15E-01241Am Activity (Ci)7.84E-022.56E-023.27E-017.74E-022.49E-023.22E-017.83E-022.53E-023.23E-0190Sr Activity (Ci)N/AN/AN/A137Cs Activity (Ci)N/AN/AN/ATRU Alpha Conc. (nCi/g)9.19E+022.67E+022.91E-019.10E+022.61E+022.87E-019.18E+022.64E+022.88E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci)1.96E-051.16E-055.92E-012.00E-051.19E-055.95E-011.97E-051.17E-055.94E-01238U Activity (Ci)6.08E-051.95E-053.21E-016.14E-051.97E-053.21E-016.00E-051.93E-053.22E-01238Pu Activity (Ci)2.19E-041.11E-045.07E-012.26E-041.14E-045.04E-012.20E-041.11E-045.05E-01239Pu Activity (Ci)7.95E-032.67E-033.36E-018.18E-032.73E-033.34E-017.98E-032.67E-033.35E-01240Pu Activity (Ci)1.77E-036.12E-043.46E-011.82E-036.26E-043.44E-011.77E-036.11E-043.45E-01242Pu Activity (Ci)2.29E-071.40E-076.11E-012.36E-071.44E-076.10E-012.30E-071.41E-076.13E-01241Am Activity (Ci)7.58E-022.44E-023.22E-017.81E-022.52E-023.23E-017.67E-022.47E-023.22E-0190Sr Activity (Ci)N/AN/AN/A137Cs Activity (Ci)N/AN/AN/ATRU Alpha Conc. (nCi/g)8.91E+022.56E+022.87E-019.18E+022.63E+022.87E-019.01E+022.59E+022.88E-01F-6Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|c2|)ReportedValueAbsoluteUncertainty233U Activity (Ci)0.00E+00 N/AN/A N/A N/AN/A N/A234U Activity (Ci)1.98E-05 1.17E-051.99E-05 2.07E-07 1.04E-021.26E-03 1.00E+00238U Activity (Ci)6.03E-09 1.95E-096.05E-05 5.90E-07 9.74E-033.66E+05 0.00E+00238Pu Activity (Ci)2.21E-04 1.14E-042.21E-04 2.79E-06 1.26E-022.40E-03 1.00E+00239Pu Activity (Ci)7.98E-03 2.76E-038.03E-03 9.14E-05 1.14E-024.38E-03 1.00E+00240Pu Activity (Ci)1.77E-03 6.30E-041.78E-03 2.19E-05 1.23E-024.84E-03 1.00E+00242Pu Activity (Ci)2.30E-07 1.42E-072.32E-07 2.70E-09 1.17E-021.45E-03 1.00E+00241Am Activity (Ci)7.84E-02 2.56E-027.73E-02 1.03E-03 1.33E-026.49E-03 1.00E+0090Sr Activity (Ci)0.00E+00 N/AN/A N/A N/AN/A N/A137Cs Activity (Ci)0.00E+00 N/AN/A N/A N/AN/A N/ATRU Alpha Conc. (nCi/g)9.19E+02 2.67E+029.08E+02 1.16E+01 1.28E-027.59E-03 1.00E+00Quantity of InteresttPr(x<|t|)χ2TesttTest233U Activity (Ci)N/A N/ANot Applicable Not Applicable234U Activity (Ci)-2.64E-01 8.05E-01Not Significant Not Significant238U Activity (Ci)-9.37E+01 7.79E-08Highly Significant Highly Significant238Pu Activity (Ci)-1.31E-01 9.02E-01Not Significant Not Significant239Pu Activity (Ci)-5.00E-01 6.44E-01Not Significant Not Significant240Pu Activity (Ci)-5.83E-01 5.91E-01Not Significant Not Significant242Pu Activity (Ci)-5.41E-01 6.17E-01Not Significant Not Significant241Am Activity (Ci)1.01E+00 3.70E-01Not Significant Not Significant90Sr Activity (Ci)N/A N/ANot Applicable Not Applicable137Cs Activity (Ci)N/A N/ANot Applicable Not ApplicableTRU Alpha Conc. (nCi/g)8.95E-01 4.22E-01Not Significant Not Significant

# G-1



# ATTACHMENT G: DOSE-TO-CURIE CONTINUED COMPLIANCE IN SPECTION

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 o perators 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 Muel ler)

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 137 

# Cs 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 EP A 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 @ 0 o 

# : 83.7 mR/h

Dose Rate @ 90 o 

# : 100 mR/h

Dose Rate @ 180 o 

# : 84.9 mR/h

Dose Rate @ 270 o 

# : 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/hH-1ATTACHMENT H: NDE CONTINUED COMPLIANCE INSPECTION CHECKLIST: RTREPA Inspection No.: INL-CC-2013Inspection Date: May 7–9, 2013Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentsRTR-1:Site procedures identifyrequired training andqualifications for RTRpersonnel.CCP-TP-028,Revision 7CCP-QP-002,Revision 26Operator training was consistent with applicableprocedures.Operator certification is current.OJT was documented for each operator.Operators are requalified every two years.RTR operators passed a training drum test thatincludes items common to the waste streamsexamined at the site (biannually).RTR operators receive training on the wastematrix parameters and typical packagingconfigurations expected in each waste stream.CCP RTR training procedures and processes are welldeveloped andinclude elements of OJT, required reading and testing.Some of the qualification cards reviewed showed that OJT had beensigned by the SME, although a signature was only required ifrequalification was a result of disqualification ofan operator. EPAverified that no RTR operators had been disqualified during the timeperiods covered by the records reviewed. EPA generated a ConcernNot Requiring a Response, INL-CCP-CC-2013-01C, to address thisissue.Qualified operators are required to successfully complete a practicaltest every six months in order to maintain their qualification.Training containers include all required items andsome items thatare typical for the waste streams being examined. EPA inspectorsreviewed the inventories for three training containers and found thatthe waste items in them were almost identical. EPAinspectorsreviewed the contents of Container Nos. 21 and 25 and found thetop layer of waste to be almost identical in both orientation andpositioning. EPA generated a Concern Requiring a Response, INLCCP-CC-2013-02CR, to address these issues.Objective evidence:1. Selected LOQIs, dated between June 2011 and April 2013.2. Training drum inventories, Container Nos. 17, 21and 25.3. Qualification records for selected operators.4. CCP AK training attendance sheets for RTR operators.5. EPA Concern Not Requiring a Response, INL-CCP-CC-2013-01C.6. EPA Concern Requiring a Response, INL-CCP-CC-2013-02CR.7.CCP-QP-002, Revision 26, CCP Training and QualificationPlan.RTR-2:Site procedures providecomplete instructions foroperators to perform theCCP-TP-508,Revision 7,section 4.0RTR operator adequately explained the processfollowed for examining a drum and enteringdata into data forms (whether hard copy orelectronic data entry is used).INL-CCP demonstrated the RTR process for ContainerNo.FCO100B-1 from BDR No. INLRHRTR13006. At the time of thedemonstration, the operator had already performed the imagequality test required by the procedure CCP-TP-508.The operatorproperly examined the container’s contents and enteredH-2EPA Inspection No.: INL-CC-2013Inspection Date: May 7–9, 2013Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentsRTR examination andcompletion of theassociated documentation.characterization data into the electronic data sheet. The operatordetermined that the waste matched the waste streamdescription andverified the WMC. No prohibited items were found inthe container.After the demonstration, EPA reviewed the containerdata sheetsand determined that they had been completed correctly and signedby the RTR operator. EPA did not identify any issues during theRTR demonstration.Objective evidence:1.RTR measurement control report dated 5/8/2013.2.Completed data sheets for Container No. FCO100B-1.3.BDR Nos. INLRHRTR13001, INLRHRTR13003 andINLRHRTR13004.4.Audio/visual recordings for selected containers.5.CCP-TP-508, Revision 7, CCP RH Standard Real-TimeRadiography Inspection Procedure.RTR-3:The RTR proceduresrequire an image qualitycheck to be performed.CCP-TP-508,Revision 7,section 4.2.3,Attachment 1Operator adequately explained how theacceptability of an image is determined.Image quality check is performed once per day.Performance of the image quality check isdocumented and recorded.EPA reviewed image quality check records in BDR Nos.INLRHRTR13001, INLRHRTR13003 and INLRHRTR13004 anddetermined these records to be complete, compliantand generatedas required by the procedure.Objective evidence:1.RTR measurement control report dated 5/8/2013.2.BDR Nos. INLRHRTR13001, INLRHRTR13003 andINLRHRTR13004.3.CCP-TP-508, Revision 7, CCP RH Standard Real-TimeRadiography Inspection Procedure.RTR-4:The procedure allows theoperator to adjust the RTRto accommodate thephysical properties of thewaste and wastecontainers likely to beencountered at the site.CCP-TP-508,Revision 7,section 4.3Operator could identify applicable policies andprocedures governing the operation of RTRequipment.The RTR system could be adjusted.High-density material was examined with theX-ray device set on the maximum voltage andlow-density material at a lower voltage.Operator adequately explained what is done ifan image is unacceptable (e.g., the waste issolidified or the container is lead lined).EPA inspectors observed the complete RTR examination ofContainer No. FCO100B-1. The operator adjusted theRTRequipment to obtain the clearest image of waste items to facilitateaccurate identification of those items. The container examinedduring the onsite visit, and those in the BDRs reviewed, did notpresent any challenges that prevented complete identification of allwaste items in the subject containers.Objective evidence:1.BDR Nos. INLRHRTR13001, INLRHRTR13003 andINLRHRTR13004.2.Completed data sheets for Container No. FCO100B-1.3.CCP-TP-508, Revision 7, CCP RH Standard Real-TimeH-3EPA Inspection No.: INL-CC-2013Inspection Date: May 7–9, 2013Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentsRadiography Inspection Procedure.RTR-5:Data records are ofsufficiently high qualityfor complete review.CCP-TP-508,Revision 7,section 4.3,Attachments 1 &2RTR tape is high quality, the sound track isaudible, and the required information iscontained on the audible portion of the tape.The RTR tape is consistent with the datapackage for the same drum.EPA reviewed the audio/visual recordings of some containers fromBDR Nos. INLRHRTR13001, INLRHRTR13003 andINLRHRTR13004 to ensure that the recordings were complete andof high quality, on both the audio and the visual portions of therecordings. EPA did not identify any issues with recording quality.Objective evidence:1.BDR Nos. INLRHRTR13001, INLRHRTR13003 andINLRHRTR13004.2.Audio/visual recordings for containers in BDR Nos.INLRHRTR13001, INLRHRTR13003 and INLRHRTR13004.3.CCP-TP-508, Revision 7, CCP RH Standard Real-TimeRadiography Inspection Procedure.RTR-6:There is a procedure fordetermining whether thewaste matches the wastestream description andwaste matrix code, and fordetermining wastematerial parameters andweights.CCP-TP-508,Revision 7,section 4.3.3,Attachment 2The procedure is adequately implemented.Operators verify that the waste matches thewaste stream description.Waste matrix code is verified. If not, correctiveaction is taken.WMP weights are estimated by compiling aninventory of waste items andresidual/packaging materials.Does the RTR operator use a standard weightlookup table to provide an estimate of WMPweights? If so, has the table been updated toreflect additional information gained throughprevious RTR/VE exams or updated AKinformation?The operator followed written procedure CCP-TP-508duringexecution of the demonstration examination. The operator estimatedand recorded WMPs and verified the WMC.Procedure CCP-TP-508 does not include a standard weight table forwaste items, and the operator uses his or her professional judgmentto make these determinations.Objective evidence:1.Data sheets for containers in BDR Nos. INLRHRTR13001,INLRHRTR13003 and INLRHRTR13004.2.Audio/visual recordings for containers in BDR Nos.INLRHRTR13001, INLRHRTR13003 and INLRHRTR13004.3.CCP-TP-508, Revision 7, CCP RH Standard Real-TimeRadiography Inspection Procedure.RTR-7:The RTR procedureprovides instructions foridentifying prohibiteditems and for processingdrums containingprohibited items.CCP-TP-508,Revision 7,section 4.3.3,Table 1CCP-QP-005,Revision 22Operator could name prohibited items.Operator adequately explained how thepresence of free liquids is determined.Operator’s explanation of required actions ifprohibited items were encountered wasconsistent with procedure.There were no prohibited items found in containersincluded inBDRs reviewed as part of this inspection. No prohibited items wereidentified in the demonstration container. However,the procedurehas clear and complete instructions for prohibiteditem identificationand how these items are processed when found. Table1 of CCP-TP508 identifies and lists prohibited items.NCR-RHINL-0430-13 was written by a CCP SPM to address adiscrepancy between the independent observation andthe RTRH-4EPA Inspection No.: INL-CC-2013Inspection Date: May 7–9, 2013Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentsCorrective actions are taken when necessary. certification scan for a container from BDR No. INLRHRTR13003.The NCR was properly processed and closed in accordance withCCP procedures.Objective evidence:1.BDR Nos. INLRHRTR13001, INLRHRTR13003 andINLRHRTR13004.2.Audio/visual recordings for containers in BDR Nos.INLRHRTR13001, INLRHRTR13003 and INLRHRTR13004.3.NCR-RHINL-0430-13.4.CCP-TP-508, Revision 7, CCP RH Standard Real-TimeRadiography Inspection Procedure.5.CCP-QP-005, Revision 22, CCP TRU Nonconforming ItemReporting and Control.RTR-8:RTR procedures includethe required QCexaminations, evaluation,accuracy andreproducibility of the RTRprocess.CCP-TP-508,Revision 7,sections 4.4 &4.5An independent replicate scan is performed onone waste container per day or on one containerper testing batch (whichever is less frequent).An independent observation of one scan (notthe replicate) is performed by a qualified RTRoperator (anyone but the initial RTR operator).A replicate scan and independent observation had been performedfor the BDRs reviewed. An NCR was generated for theindependentobservation in batch INLRHRTR13003 because the 30-galloncontainer had not been recorded. This NCR had beenclosed at thetime of the onsite inspection. The QC performed metCCPrequirements for all BDRs reviewed.Objective evidence:1.BDR Nos. INLRHRTR13001, INLRHRTR13003 andINLRHRTR13004.2.NCR-RHINL-0430-13.3.CCP-TP-508, Revision 7, CCP RH Standard Real-TimeRadiography Inspection Procedure.RTR-9:Procedures containstandardized forms forrecording RTR data.CCP-TP-508,Revision 7,Attachment 2RTR operator adequately explained the processfollowed for examining a drum and enteringdata into data forms (whether hard copy orelectronic data entry is used).Direct data entry into an electronic form is doneby the RTR operator using a computer while theoperator is still in the RTR booth.The electronic data file undergoes the same QCchecks used for hand-written data entries.The operator entered waste items into the electronic data forms asthey were identified during the onsite demonstration. A WMP wasassigned to each item at this time. The operator checked for thepresence of free liquids and other prohibited itemsas part of theexamination.Objective evidence:1.Written data sheets for BDR Nos. INLRHRTR13001,INLRHRTR13003 and INLRHRTR13004.2.Completed data sheets for Container No. FCO100B-1.3.CCP-TP-508, Revision 7, CCP RH Standard Real-TimeRadiography Inspection Procedure.H-5EPA Inspection No.: INL-CC-2013Inspection Date: May 7–9, 2013Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentsRTR-10:Site procedures requirereview of BDRs at thedata generation andproject level.CCP-TP-508,Revision 7,section 4.10,Attachments 3(ITR) & 4 (SPM)Data generation level reviews are performedand documented (ITR).Project level reviews are performed anddocumented (SPM).EPA reviewed written BDRs as part of the onsite inspection andfound that they had been reviewed at both the datageneration andproject levels as required by the procedure. The respectivechecklists had been completed and signed as required.Objective evidence:1.BDR Nos. INLRHRTR13001, INLRHRTR13003 andINLRHRTR13004.2.CCP-TP-508, Revision 7, CCP RH Standard Real-TimeRadiography Inspection Procedure.I-1ATTACHMENT I.1: NDE CONTINUED COMPLIANCE INSPECTIONCHECKLIST: CH VEEPA Inspection No.: INL-CC-2013Inspection Date: May 7–9, 2013Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentsVE-1:Site procedures identifyrequired training andqualifications for VEpersonnel.CCP-QP-002,Revision 34VEE’s explanation of job duties was consistentwith applicable procedures.VE personnel’s training was consistent withapplicable procedures.VE personnel’s certification is current.VE personnel are requalified every two years.VE personnel received training on specificwaste generating processes, typical packagingconfigurations and WMPs expected to befound in each WMC.CCP VE training procedures and processes are well developed andinclude elements of OJT, required reading and testing. Some of thequalification cards reviewed showed that OJT had been signed bythe VEE although a signature was only required if requalificationwas a result of disqualification of an operator. EPA verified that noVE operators had been disqualified during the timeperiods coveredby the records reviewed. EPA generated a Concern Not Requiring aResponse, INL-CCP-CC-2013-01C, to address this issue.The EPA inspector reviewed objective evidence thatVE operatorsreceived training about the waste stream currentlybeing processedat the site.Objective evidence:1.Initial qualification and requalification cards forselected VEoperators /ITRs.2.Selected LOQIs, dated between June 2011 and April 2013.3.CCP attendance sheets for VE personnel for selectedAKtraining.4.CCP-QP-002, Revision 34, CCP Training and QualificationPlan.5.VEE appointment letters dated between 2007 and 2011.VE-2:Procedures and technicalguidance documentsprovide completeinstructions forperforming VE.CCP-TP-006,Revision 17The site uses AK to identify the waste matrixcode category and to estimate waste materialparameters present.Procedures are sufficiently detailed to enablethe operator to determine if a waste containermeets the criteria of 194.24 with regard toidentifying applicable parameters with wastelimits.Establish standard nomenclature, based oncurrent site practice, so that all staff recognizewaste by the same descriptors.CCP-TP-006 is well established and has been reviewed by EPA onnumerous occasions. Table 4 of the procedure, WasteItemHistorical Weights and Weighing Codes, contains standard weightsthat are used by VE personnel when recording VE data.Attachment 1, Waste Visual Examination Technique Data Form, isdetailed and requires operators to record all wasteitems identified,segregate prohibited items and verify the WMC. EPAdeterminedthat all required information had been recorded forthe containersin the BDRs reviewed.Objective evidence:1.BDR Nos. IN-ARP-VE-002792, IN-ARP-VE-ARP-002728 andIN-SRP-VE-000120.2.CCP-TP-006, Revision 17, CCP Visual Examination Techniquefor Idaho National Laboratory (INL) Newly GeneratedTRUWaste Retrieved from Pits.I-2EPA Inspection No.: INL-CC-2013Inspection Date: May 7–9, 2013Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentsVE-3:VEE has overallresponsibility for VE.CCP-TP-006,Revision 17,section 3.1Evaluates and resolves any VE Technicianquestions.Approves Attachment 4, CCP Waste VETechnique Batch Data Report Cover Sheet.Evaluates the need for additional training.The waste used to demonstrate the VE process was anorganicsludge from RFP. The receiving drum was SRP14510 (BDR No.IN-SRP-VE-000175) and the waste stream was ID-RF-S3114.During the onsite demonstration, the actual handling of the waste inthe glove box was performed by CWI personnel, withthe INL-CCPoperators performing the VE and recording the VE data generated.The VEE was available to the operators at the timeof datageneration. EPA obtained the data sheets generatedduring theonsite demonstration and verified that VE data werecompletelyand accurately recorded. EPA inspectors verified that the VEoperators and VEE were currently qualified.Objective evidence:1.BDR Nos. IN-ARP-VE-002792, IN-ARP-VE-ARP-002728 andIN-SRP-VE-000120.2.VEE appointment letters dated between 2007 and 2011.3.Completed data sheets for demonstration VE waste.4.Initial and requalification records for selected VEoperators/ITRs.VE-4:Checks are performedbefore the start of VE.CCP-TP-006,Revision 17,sections 4.1.5–4.1.8VEO performs scale checks.Empty container is weighed.Verifies that the container is empty.Any necessary scale checks had been performed priorto EPA’sobservation of operations. EPA verified that the scales werecurrently calibrated by review of calibration records. The EPAinspectors observed the receiving container being verified as emptyprior to waste loading.Objective evidence:1.BDR Nos. IN-ARP-VE-002792, IN-ARP-VE-ARP-002728 andIN-SRP-VE-000120.2.Calibration certificates for scales Nos. 729257 andXC0918.VE-5:There is a procedure forhandling instances whenthe VE Expert is unableto see through the innerplasticbags/packages/containersof waste.CCP-TP-006,Revision 17,section 4.2The VEE has decision-making criteria forassessing the need to open the bags/packagesin order to identify all of their contents.Two VE operators perform VE.If the bags are not opened, a brief writtendescription of the contents of the bags isprepared with estimates of the amount of eachwaste type in the bags.The waste used to demonstrate the VE process was anorganicsludge from RFP. The receiving drum was SRP14510 (BDR No.IN-SRP-VE-000175) and the waste stream was ID-RF-S3114.During the onsite demonstration, the actual handling of the waste inthe glove box was performed by CWI personnel with the INL-CCPoperators performing the VE and recording the VE data generated.The VEE was available to the operators at the timeof datageneration. EPA obtained the data sheets generatedduring theonsite demonstration and verified that VE was completely andaccurately recorded. EPA inspectors verified that the VE operatorsI-3EPA Inspection No.: INL-CC-2013Inspection Date: May 7–9, 2013Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/Commentsand VEE were currently qualified.Objective evidence:1.Completed data sheets for demonstration VE waste.2.BDR Nos. IN-ARP-VE-002792, IN-ARP-VE-ARP-002728 andIN-SRP-VE-000120.3.Selected LOQIs, dated between June 2011 and April 2013.4.VEE appointment letters dated between 2007 and 2011.VE-6:The VE procedurerequires verification ofWMC and WMP weights.CCP-TP-006,Revision 17,Attachment 1VE operators complete Attachment 1, VisualExamination Technique Data Form, andpersonnel could navigate through the variousscreens.A VE data form is used to document the wastematrix code and estimated WMP weights ofthe waste (CCP-TP-006, Table 3).VE staff have access to standardized charts ortables to aid in the consistentestimation/assignment of weights, wastematerial parameters, and waste matrix codes(CCP-TP-006, Table 4).The estimated or weighed WMP weights aredetermined by compiling an inventory of wasteitems, residual materials and packagingmaterials.During the onsite demonstration, the actual handling of the waste inthe glove box was performed by CWI personnel, withthe INL-CCPoperators performing the VE and recording the VE data generated.The VEE was available to the operators at the timeof datageneration. EPA obtained the data sheets generatedduring theonsite demonstration and verified that VE was completely andaccurately recorded.Table 4 of procedure CCP-TP-006 contains historicalweights forwaste items frequently found in the waste examined.Objective evidence:1.BDR Nos. IN-ARP-VE-002792, IN-ARP-VE-ARP-002728 andIN-SRP-VE-000120.2.Completed data sheets for demonstration VE waste.VE-7:Procedure providesinstructions forprocessing of containerswith prohibited items.CCP-TP-006,Revision 17,sections 4.2–4.3,Attachment 1,Table 1VEE/VEO expert could name prohibited items.VEE/VEO explanation of required actions ifprohibited items were encountered wasconsistent with procedure.The VEO describes any liquids found,including a description of their location in thecontainer and estimated volume.Other prohibited items, including sealedcontainers, are identified and segregated.Table 1 of procedure CCP-TP-006 identifies prohibited items.There were no prohibited items identified during the VEdemonstration. A VE operator performing the demonstrationexamination stated that oil dry is added to the waste if liquids arepresent. The area of the glove box set aside to segregate prohibiteditems was visible to the EPA inspectors during thedemonstration.There were no prohibited items identified in the BDRs reviewed,nor during the demonstration of the VE process.Objective evidence:1.BDR Nos. IN-ARP-VE-002792, IN-ARP-VE-ARP-002728 andIN-SRP-VE-000120.2.Completed data sheets for demonstration VE waste.I-4EPA Inspection No.: INL-CC-2013Inspection Date: May 7–9, 2013Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentsVE-8:Operators follow theprocedure.Operators initiatecorrective action whennecessary.CCP-TP-006,Revision 17The procedure is adequately implemented.Corrective actions are taken when necessary.EPA did not identify any issues for the three BDRsreviewed. TheBDRs were complete and contained characterization data for eachcontainer.There were no NCRs generated for the three BDRs reviewed.Objective evidence:1. BDR Nos. IN-ARP-VE-002792, IN-ARP-VE-ARP-002728andIN-SRP-VE-000120.VE-09:Site procedures requiredata generation andproject-level reviews ofBDRs.CCP-TP-006,Revision 17,Attachments 2–4CCP-TP-001,Revision 20BDRs contain all required information.Data generation and project-level reviews arecomplete.The BDRs reviewed by EPA had been reviewed at datagenerationlevel and project level as required by INL-CCP procedures. BDRswere complete and contained characterization data for eachcontainer.Objective evidence:BDR Nos. IN-ARP-VE-002792, IN-ARP-VE-ARP-002728 andIN-SRP-VE-000120.I-5ATTACHMENT I.2: NDE CONTINUED COMPLIANCE INSPECTIONCHECKLIST: RH VEEPA Inspection No.: INL-CC-2013Inspection Date: May 7–9, 2013Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentsRHVE-1:Site procedures identifyrequired training andqualifications for RH VEpersonnel.CCP-QP-002,Revision 34Formal training elements include: projectrequirements, container identification andlabeling, and applicable state and federalregulations.Site-specific training program: OJT,identification of summary category groups,WMPs, packaging configurations and residualliquids.INL-CCP VE training procedures and processes are well developedand include elements of OJT, required reading and testing.Objective evidence:1.Selected LOQIs, dated between June 2011 and April 2013.2.Qualification records for selected operators.3.CCP AK training attendance sheets for VE operators.4.CCP-QP-002, Revision 34, CCP Training and QualificationPlan.RHVE-2:Operator qualificationand requalificationrequirements aredescribed.CCP-QP-002,Revision 34,section 4.3.8To become qualified, the RH VE operator mustpass a comprehensive written test based ontraining objectives with a minimum score of80%.Demonstrate capability in the presence of thesite VEE during OJT.RH VE operators requalified every two yearsbased on continued satisfactory performance.Unsatisfactory performance: failed to identifyprohibited item during OJT or score of lessthan 80% on exam.EPA inspectors reviewed initial and requalificationrecords for VEoperators and VEEs.Some of the qualification cards reviewed showed that OJT hadbeen signed by the VEE although a signature was only required ifrequalification was a result of disqualification ofan operator. EPAverified that no VE operators had been disqualifiedduring the timeperiods covered by the records reviewed. EPA generated a ConcernNot Requiring a Response, INL-CCP-CC-2013-01C, to address thisissue.Objective evidence:1.Initial qualification and requalification cards forselected VEoperators.2.INL-CCP attendance sheets for VE personnel for selected AKtraining.3.EPA Concern Not Requiring a Response, INL-CCP-CC-2013-01C.RHVE-3:Each site has a designatedVEE.CCP-QP-002,Revision 34,section 4.4.1CCP-PO-001,Revision 21VEE designation is documented.VEE has knowledge of the RH TRU wastebeing characterized.Responsible for overall direction andimplementation of VE at the facility.Certification plan specifies the selection,qualification and training requirements ofVEE.CCP had designated VEEs, and EPA reviewed appointment lettersfor some of those VEEs. VEE designation was determined to becorrect and current.Objective evidence:1.VEE appointment letters dated between 2007 and 2011.2.Selected LOQIs, dated between June 2011 and April 2013.I-6EPA Inspection No.: INL-CC-2013Inspection Date: May 7–9, 2013Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentsRHVE-4:Procedures and technicalguidance documentsprovide completeinstructions forperforming RH VE.CCP-TP-500,Revision 11,sections 4.1–4.2,Attachment 1All existing VE tapes will be reviewed and theVE data will be documented.Existing waste container packaging recordswill be qualified by VE or RTR.100% of containers will be subject to VE at thetime of packaging.Waste stream description and WMC verified.Presence/absence of prohibited itemsconfirmed.Two operators used even if audio/visualrecording of VE is generated.VE is performed by two operators with the assistance of a VEE.INL-CCP demonstrated the VE process for Container No.ANLE3D-3, BDR No. INLRHVE13001. The source container forthe items subjected to VE during the onsite visit was No. ANLE3D. This container had an unacceptable FGE, and thepurpose ofthe VE activity was to separate the three 1-gallonpaint cans intoseparate 30-gallon containers. The three paint canswere designatedas ANLE3D-1, ANLE3D-2 and ANLE3D-3. INL-CCP VEpersonnel for this examination consisted of two VEoperators andone VEE, who completed the required data forms as welloverseeing the process. CWI personnel physically manipulated thewaste in the glove box. The operators verified thatno prohibiteditems were present and that the waste matched the waste streamdescription and WMC.Objective evidence:1.VE data form for Container No. ANLE3D-3, BDR No.INLRHVE13001 (demonstration container).2.BDR Nos. INLRHVE11002, INLRHVE11003 andINLRHVE12001.RHVE-5:Corrective actions aretaken when necessary.CCP-TP-500,Revision 11,section 2.4.2Operators were able to describe how theyinitiate a corrective action.No NCR reports were generated for the BDRs reviewed. EPAinspectors reviewed qualification records for operators and VEEs,which included CCP’s Nonconforming Item Reporting and Controlprocedure (CCP-QP-005).RHVE-6:Site procedures requiredata generation andproject-level reviews ofBDRs.CCP-TP-500,Revision 11ITRs review Attachment 2.SPMs review Attachment 3.All of the BDRs reviewed by EPA had been reviewed at the datageneration (ITR) and project (SMP) level. The respective checklistshad been completed and signed as required.Objective evidence:1.BDR Nos. INLRHVE11002, INLRHVE11003 andINLRHVE12001.RHVE-7:Records are available forreview.CCP-TP-500,Revision 11,section 5.0Lifetime/QA records – Attachments 1–5, Copyof NCRs.QA/nonpermanent records – VHS tape orDVD (primary and backup).INL-CCP was able to provide to EPA all requested records. VEwas performed using two operators, and no audio/visual recordingswere made for the BDRs reviewed and the demonstration observedon site.Objective evidence:1.BDR Nos. INLRHVE11002, INLRHVE11003 andI-7EPA Inspection No.: INL-CC-2013Inspection Date: May 7–9, 2013Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentsINLRHVE12001.2.VEE appointment letters dated between 2007 and 2011.3.Selected LOQIs dated between June 2011 and April 2013.4.Initial qualification and requalification cards forselected VEoperators.5.CCP attendance sheets for VE personnel for selectedAKtraining.RHVE-8:Quality assuranceobjectives are defined andmet.40 CFR Part194.22(b)Data Accuracy:194.22(b)(1)the degree to which data agreewith an acceptable reference or true value.WCPIP:maintained by requiring operators topass a comprehensive test with a score of 80%and demonstrated satisfactory performance forinitial qualification and requalification.Data Precision:194.22(b)(2)a measure of the mutualagreement between comparable data gatheredor developed under similar conditionsexpressed in terms of a standard deviation.WCPIP:maintained by reconciling anydiscrepancies between 2 operators (or operatorand ITR) with regard to physical form ofwaste, absence of residual liquid.Data Representativeness:194.22(b)(3)the degree to which dataaccurately and precisely represent acharacteristic of a population, a parameter,variations at a sampling point, orenvironmental conditions.WCPIP:contents placed in a container will bedescribed on the data forms.Data Completeness:194.22(b)(4)a measure of the amount of validData Accuracy & Comparability:Qualification and requalification records for VE operatorsdemonstrate that operators pass a comprehensive writtenexamination as required by the WCPIP and INL-CCP trainingprocedure CCP-QP-002.Data Precision:Two operators perform VE and concur with entries made into thedata forms. This is evidenced by the operator signatures.Data Representativeness & Completeness:EPA determined that all waste items are recorded ondata forms.EPA verified this by review of selected BDRs and observation ofthe onsite demonstration of VE operations.Objective evidence:1.BDR Nos. INLRHVE11002, INLRHVE11003 andINLRHVE12001.2.CCP-QP-002, Revision 34, CCP Training and QualificationPlan.3.Initial qualification and requalification cards forselected VEoperators.I-8EPA Inspection No.: INL-CC-2013Inspection Date: May 7–9, 2013Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/Commentsdata obtained compared to the amount that wasexpected.WCPIP: relevant waste information must becollected and documented on a videotapeand/or data form or other unalterable media.Data Comparability:194.22(b)(5)a measure of the confidence withwhich one data set can be compared to another.WCPIP:ensured by site meeting trainingrequirements and complying with theminimum 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 rec ords 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 d isqualification of the operator. Seven of the

fourteen records reviewed had been signed by the VE E/SME attesting that the requalification

was a result of operator disqualification. Telephon ic 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 t he 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. Gulbr ansen

E. Additional Comments: EPA requests that CCP address this issue for all ac tive 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, assem bled 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 co ntained 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 positio ns in training drums to provide a process

improvement and enhanced level of operator skills t esting. EPA requests that INL-CCP

evaluate this concern and ensure that RTR container s constitute a rigorous test of RTR

operators’ skills.

EPA wrote a similar concern at INL-CCP on May 9, 20 12, 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. S tallings

E. Additional Comments: EPA requests that CCP address this issue for all ac tive TRU

waste characterization sites.

F. Site Response Information:

Site Response Required? YES NO

Site Response Due Date: May 30, 2013

X

X