EPA DOCKET NO. A-98-49, II-A4-103 

 

WASTE CHARACTERIZATION INSPECTION REPORT AND APPROVAL 

EPA BASELINE INSPECTION NO. EPA-ORNL-CCP-CH-11.07-8

OF THE CENTRAL CHARACTERIZATION PROJECT 

 WASTE CHARACTERIZATION PROGRAM 

AT THE OAK RIDGE NATIONAL LABORATORY 

 

November 13–15, 2007 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

August 2008 
i

TABLE OF CONTENTS 

Section Page

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

2.0 Purpose of Inspections ........................................................................................................ 4 

3.0 Purpose of This Report........................................................................................................ 5 

4.0 Scope of Inspection ............................................................................................................. 6 

5.0 Inspection-Related Definitions............................................................................................ 7 

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

6.1 EPA Inspection Team.............................................................................................. 7 

6.2 Personnel Contacted................................................................................................ 7 

7.0 Performance of the Inspection............................................................................................. 8 

7.1 Site Background and History .................................................................................. 8 

7.2 Inspection Process Overview .................................................................................. 9 

8.0 Technical Waste Characterization Areas ............................................................................ 9 

8.1 Acceptable Knowledge ........................................................................................... 9 

8.2 Nondestructive Assay............................................................................................ 29 

8.3 Real-Time Radiography ........................................................................................ 40 

8.4 WIPP Waste Information System ......................................................................... 47 

8.5 Container Management ......................................................................................... 50 

9.0 Response to Comments ..................................................................................................... 51 

10.0 Summary of Results .......................................................................................................... 51 

10.1 Findings and Concerns.......................................................................................... 51 

10.2 Conclusions ........................................................................................................... 52 

11.0 References ......................................................................................................................... 54 
ii

ATTACHMENTS 

Attachment A.1 Acceptable Knowledge (AK) Checklist 

Attachment A.2 Nondestructive Assay (NDA) Checklist,

Attachment A.3 Real-Time Radiography (RTR) Checklist 

Attachment A.4 WIPP Waste Information System (WWIS) Checklist 

Attachment B.1 Replicate Testing Data for Container X10C0501112 

Attachment B.2 Replicate Testing Results for Container X10C0501112 

Attachment B.3 Replicate Testing Data for Container X10C0501270 

Attachment B.4 Replicate Testing Results for, Container X10C0501270 

Attachment B.5 Replicate Testing Data for Container X10C0505990 

Attachment B.6 Replicate Testing Results for Container X10C0505990 

Attachment C.1 EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-CH-RTR-07-

001CR, Final

Attachment C.2 EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-CH-NDA-07-

002CR, Final 

Attachment C.3 EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-CH-CBFO-07-

003F, Final 

Attachment C.4 EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-CH-RTR-04-

004C, Final 

Attachment C.5 EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-CH-RTR-07-

005C, Final 

Attachment C.6 EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-CH-NDA-07-

006CR, Final 

Attachment C.7 EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-CH-AK-07-

007CR, Final 

Attachment C.8 EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-CH-AK-07-

008CR, Final 

Attachment C.9 EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-CH-AK-07-

009CR, Final 
iii

ACRONYMS 

ABS absorber 

ABSMOD absorber/moderator 

AK acceptable knowledge 

AKE Acceptable Knowledge Expert 

AKSR AK summary report 

Am americium 

BDR batch data report 

CBFO Carlsbad Area Field Office 

CCP Central Characterization Project 

Cf californium 

CFR Code of Federal Regulations

CH contact-handled 

CHMB Contact-Handled Marshalling Building 

CHSA Contact-Handled Container Storage Area 

Cs cesium 

CTAC Carlsbad Technical Assistance Contractor 

CTS Characterization Tracking System 

D&D decontamination and decommissioning 

DAC drum aging criteria 

DOE U.S. Department of Energy 

DRR discrepancy resolution report 

DU depleted uranium 

Dupont/SRO E.I. du Pont de Nemours/Savannah River Operations 

DVRF Decontamination and Volume Reduction Facility

DWAS Drum Waste Assay System 

DWAS IPAN/SGS Drum Waste Assay System Imaging Passive-Active Neutron/Segmented 

Gamma Scanner 

EA expert analyst 

EM environmental management 

EPA U.S. Environmental Protection Agency 

ES&H environmental safety and health 
iv

Eu europium 

FGE fissile gram equivalent 

FR Federal Register

FRAM fixed energy response function analysis with multiple efficiencies 

FWHM full-width-at-half-maximum 

g gram or grams 

g/cm3

 grams per cubic centimeter 

IPAN Imaging Passive Active Neutron 

ITR Independent Technical Reviewer 

kg kilogram or kilograms 

LANL Los Alamos National Laboratory 

LEGe low-energy germanium 

LLD lower limit of detection 

LLW low-level waste 

MCS Mobile Characterization Services 

Mev mega electron volt 

MGA multi-group analysis 

MOD moderator 

MOX mixed oxide 

N/A not applicable 

nCi/g nanocuries per gram 

NCR nonconformance report 

NDA nondestructive assay 

NDE nondestructive examination 

NFS Nuclear Fuel Services, Inc. 

Np neptunium 

ORIA Office of Radiation and Indoor Air 

ORNL Oak Ridge National Laboratory 

ORR Oak Ridge Reservation 

OSR off-site source recovery 

PDP Performance Demonstration Program 

PTS Program Tracking System 

Pu plutonium 
v

QC quality control 

RCRA Resource Conservation and Recovery Act 

RCTS radiation control technical supervisor 

RTR real-time radiography 

SEFOR Southwest Experimental Fast Oxide Reactor 

SGS Segmented Gamma Scanner 

SPM Site Project Manager 

Sr strontium 

SRS Savannah River Site 

SWB standard waste box 

T1 Tier 1 

T2 Tier 2 

Th thorium 

TMU total measurement uncertainty 

TRU transuranic 

TRUPACT transuranic packaging transporter 

TWCP TRU Waste Processing Center 

U uranium 

VAGAS Versatile Automated Gamma Assay System 

VE visual examination 

VPM vendor project manager 

WAC waste acceptance criteria 

WAP Waste Analysis Plan 

WEAF Waste Examination and Assay Facility 

WC waste characterization 

WCA Waste Certification Assistant 

WCO Waste Certification Official 

WG Pu weapons-grade plutonium 

WIPP Waste Isolation Pilot Plant 

WMC waste matrix code 

WMP waste material parameter 

WSPF Waste Stream Profile Form 

WTS Washington TRU Solutions 
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WWIS WIPP Waste Information System 
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1.0 EXECUTIVE SUMMARY 

In accordance with 40 CFR 194.8(b), the U.S. Environmental Protection Agency (EPA or the 

Agency) conducted Baseline Inspection No. EPA-ORNL-CCP-CH-11.07-8 of the Central 

Characterization Project (CCP) waste characterization (WC) program for contact-handled (CH) 

transuranic (TRU) wastes at the U.S. Department of Energy (DOE) Oak Ridge National 

Laboratory (ORNL) in Oak Ridge, Tennessee. This inspection occurred at the TRU Project 

Processing Center located on the Oak Ridge Reservation (ORR) in Oak Ridge, Tennessee, 

November 13 through 15, 2007. In accordance with the provisions of 40 CFR 194.8(b), as 

issued in a July 16, 2004, Federal Register (FR) notice (69 FR 42571–42583), EPA conducted a 

baseline inspection of the site’s program to characterize wastes proposed for disposal at the 

Waste Isolation Pilot Plant (WIPP). As a result of this baseline inspection, EPA is proposing to 

approve the ORNL-CCP CH TRU WC program based on a demonstration of the CCP’s 

capabilities to characterize retrievably-stored contact-handled (CH) transuranic (TRU) debris 

waste from ORNL, with the conditions and limitations that are discussed in this report, in 

accordance with 40 CFR 194.8(b). Upon finalization of this approval ORNL’s CH TRU debris 

waste may be disposed of at the Waste Isolation Pilot Plant (WIPP). 

EPA must verify compliance with 40 CFR 194.24 before waste may be disposed of at the WIPP, 

as specified in Condition 3 of the Agency’s certification of the WIPP’s compliance with disposal 

regulations for TRU radioactive waste (63 FR 27354, 27405, May 18, 1998). EPA had not 

previously evaluated WC systems at ORNL-CCP for characterizing TRU wastes. The purpose 

of this inspection was to evaluate the adequacy of the site’s WC programs for CH TRU debris 

waste to be disposed of at the WIPP. During the inspections, the Agency examined the 

following activities: 

• Acceptable knowledge (AK) for CH retrievably-stored TRU debris waste (S5000) 

• One nondestructive assay (NDA) system, the Drum Waste Assay System Imaging 

Passive-Active Neutron/Segmented Gamma Scanner (DWAS IPAN/SGS) system for 

characterizing debris (S5000) wastes 

• Real-time radiography (RTR) for CH retrievably-stored TRU debris waste (S5000) 

• WIPP Waste Information System (WWIS) for CH retrievably-stored TRU debris waste 

(S5000) 

During the inspection, ORNL-CCP personnel stated that the ORNL-CCP is not seeking approval 

to perform load management, and EPA excluded evaluation of load management from the scope 

of this inspection [see Section 8.1(5)]. Therefore, this approval does not include load 

management for ORNL-CCP. 

The EPA inspection team identified eight concerns, six of which required a response and two 

that did not require a response. EPA Inspection Issue Tracking Forms (see Attachments C.1, C.2 

and C.4 through C.9 to this report) document these concerns. Personnel from ORNL-CCP and 

CBFO provided information to resolve the other eight concerns to the EPA inspection team prior 

to the closeout of the onsite inspection and after the inspection. The information provided to 

EPA adequately addressed the concerns. The EPA inspection team also identified one finding 
2

(ORNL-CCP-CH-CBFO-003F, Final, see Attachment C.3 to this report) that was directed 

specifically to the DOE Carlsbad Area Field Office (CBFO). This report does not discuss the 

finding; however, CBFO, in a letter dated December 21, 2007, provided a commitment to EPA 

to prevent recurrence of the issues covered in the finding. EPA considers the one finding and the 

eight concerns related to ORNL-CCP to be resolved, and there are no open issues resulting from 

this inspection. 

The EPA inspection team determined that the ORNL-CCP WC program for retrievably-stored 

CH TRU debris waste was technically adequate. EPA, therefore, is proposing to approve the 

ORNL-CCP CH TRU WC program in the configuration observed during this inspection and 

described in this report and the attached checklists (Attachments A.1 through A.4). This 

approval includes the following: 

(1) The AK process for CH retrievably-stored TRU debris wastes 

(2) The DWAS IPAN/SGS system for assaying CH TRU wastes 

(3) The nondestructive examination (NDE) process of RTR for CH TRU debris wastes 

(4) The WWIS process for tracking waste contents of CH TRU wastes 

ORNL-CCP must report and receive EPA approval of any Tier 1 (T1) changes to the ORNLCCP WC activities from the date of the baseline inspection, and must notify EPA regarding 

Tier 2 (T2) changes according to Table 1, below. Table 1 in this report closely follows the 

format used in previous CH baseline approval reports. 

 

Footnote b in Tables 1 and 8 specifies that “substantive changes” are changes with the potential 

to impact the site’s WC activities under 40 CFR 194.24 or the documentation thereof, excluding 

changes that are solely related to environmental safety and health (ES&H), nuclear safety, or the 

Resource Conservation and Recovery Act (RCRA) or that are editorial in nature. 

All T1 changes must be submitted for evaluation and approval by EPA prior to implementation 

(see Section 2.0 of this report for a brief discussion of tiering). Upon approval, EPA will notify 

the public of the results of its evaluations by posting the results to the EPA Web site and by 

sending e-mails the WIPPNEWS list. Upon completion of its review of the T2 changes 

submitted at the end of each fiscal quarter, EPA will post the T2 changes. EPA expects the first 

report of ORNL-CCP’s T2 changes at the end of the first quarter following approval. 

The scope of the site baseline compliance decision is based on EPA’s inspection completed on 

November 13–15, 2007.
3

Table 1. Tiering of TRU WC Processes Implemented by ORNL 

Based on November 13–15, 2007, Site Baseline Inspection

WC Process Elements ORNL-CCP WC T1 Changes ORNL-CCP WC T2 C

Acceptable Knowledge (AK) and Load Management 

Implementation of load management; AK (5) Implementation of AK for wastes other than retrievablystored debris (i.e., retrievably stored soil/gravel and 

solids and/or any type of newly-generated waste); AK 

(15) 

Notification to EPA upon completion of AK a

Notification to EPA upon completion of new 

updates/substantive changesb of the following

- Changes to AK-NDA communicatio

- Changes to site procedure; AK (4) - AK summaries that describe wastes 

described in this report; AK (6) - Radiological Discrepancy Resolution 

NDA) pertinent to Waste Stream OR

- Completed Attachments 4 and 6 and 

Waste Stream OR-NFS-CH-HET; A

- AK Summaries/Waste Stream Profil

documentation reports; AK (15)

Non Destructive Assay (NDA) New equipment or physical modifications to approved 

equipmentc; NDA (1) 

Extension or changes to approved calibration range for approved equipment; NDA (2) 

Notification to EPA upon completion of chan

equipment, operating range(s), and site proceapproval; NDA (2) 

Real-Time Radiography (RTR) N/A Notification to EPA upon the following: - Implementation of new RTR equipm

approved RTR equipment; RTR (1) - Completion of changes to site RTR p

approvals; RTR (2) 

Visual Examination (VE) Not approved at this time Not approved at this WIPP Waste Information System (WWIS) 

Implementation of load management; WWIS (4) Notification to EPA upon the following: - Completion of changes to WWIS pro

approvals; WWIS (1) 

aUpon receiving EPA approval, ORNL-CCP will report all T2 changes to EPA at the end of each fiscal quarter. b“Substantive changes” are changes with the potential to impact the site’s WC activities or documentation thereof, excluding changes that ar

nuclear safety, or RCRA, or that are editorial in nature. 

cModifications to approved equipment include all changes with the potential to affect NDA data relative to waste isolation and exclude mino

addition of safety-related equipment. 
4

2.0 PURPOSE OF INSPECTIONS 

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

regulations at 40 CFR Part 191. In this certification, EPA also included Condition 3, which 

states that “the Secretary shall not allow shipment of any waste from...any waste generator site 

other than LANL [Los Alamos National Laboratory] for disposal at the WIPP until the Agency 

has approved the processes for characterizing those waste streams for shipment using the process 

set forth in §194.8.” The approval process described at 40 CFR 194.8 requires DOE to 

(1) provide EPA with information on AK1

 for waste streams proposed for disposal at the WIPP, 

and (2) implement a system of controls used to confirm that the total amount of each waste 

component that will be emplaced in the WIPP will not exceed limits identified in the WIPP 

Compliance Certification Application (DOE/CAO 1996-2184, 40 CFR Part 191, Compliance 

Certification Application for the Waste Isolation Pilot Plant, 1996). 

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, FR notice, EPA must 

perform a single baseline inspection of a TRU waste generator site’s WC program. The purpose 

of the baseline inspection is to approve the site’s WC program based on a demonstration that the 

program’s components, with applicable conditions and limitations, can adequately characterize 

TRU wastes and comply with the regulatory requirements imposed on TRU wastes destined for 

disposal at the WIPP. An EPA team conducts an onsite inspection to verify that the site’s system 

of controls is technically adequate and properly implemented. Specifically, the EPA inspection 

team verifies compliance with 40 CFR 194.24 (c)(4), which states the following: 

Any compliance application shall: . . . Provide information which demonstrates 

that a system of controls has been and will continue to be implemented to confirm 

that the total amount of each waste component that will be emplaced in the 

disposal system will not exceed the upper limiting value or fall below the lower 

limiting value described in the introductory text of paragraph I of this section.2

 

The system of controls shall include, but shall not be limited to: measurement; 

sampling; chain of custody records; record keeping systems; waste loading 

schemes used; and other documentation. 

In other words, the purpose of the baseline inspection is to assess whether DOE sites that 

characterize TRU waste prior to disposal at the WIPP are capable of characterizing and tracking 

the waste in such a manner that EPA is confident that the waste will not exceed the approved 

limits. Before proposing the approval of WC systems and processes at ORNL-CCP, EPA 

evaluated the capabilities of systems and processes to (1) identify and measure waste 

 

1

 As of the FR notice of July 16, 2004 (69 FR 42571–42583), EPA has replaced the term “process knowledge” 

with “acceptable knowledge.” Acceptable knowledge refers to any information about the process used to generate 

waste, material inputs to the process, and the time period during which the wastes were generated, as well as data 

resulting from the analysis of waste conducted prior to or separate from the waste certification process authorized by 

an EPA certification decision to show compliance with Condition 3 of the certification decision. 

2

 The introductory text of 40 CFR 194.24(c) states, “For each waste component identified and assessed pursuant 

to [40 CFR 194.24(b)], the Department shall specify the limiting value (expressed as an upper or lower limit of 

mass, volume, curies, concentration, etc.), and the associated uncertainty (i.e., margin of error) for each limiting 

value, of the total inventory of such waste proposed for disposal in the disposal system.” 
5

components (such as plutonium) that must be tracked for compliance,3 and (2) confirm that the 

waste in any given container has been properly identified as belonging to the group of approved 

waste streams. 

Following EPA’s approval of the WC processes evaluated during the baseline inspection, EPA is 

authorized to evaluate and approve, if necessary, changes to the site’s approved WC program by 

conducting additional inspections under the authority of 40 CFR 194.24(h). Under 

40 CFR 194.24, EPA has the authority to conduct continued compliance inspections to verify 

that the site continues to use only the approved WC processes to characterize the waste and 

remains in compliance with all regulatory requirements. Based on the adequacies of the WC 

processes demonstrated during the baseline inspection, including all conditions and limitations, 

EPA will specify which subsequent WC program changes or modifications must undergo further 

EPA inspection or approval under 40 CFR 194.24. EPA will accomplish this by assigning a tier 

level to each aspect of the characterization program. T1 activities have more stringent reporting 

requirements and require DOE to notify EPA and receive the Agency’s approval prior to 

implementing the change. DOE will report T2 activities to EPA based on the frequency 

established in the inspection report. DOE may choose to characterize and dispose of materials at 

its own risk while EPA considers the proposed T2 changes. If ORNL-CCP contemplates a 

change that is not identified in this report, EPA recommends that the site, in consultation with 

CBFO, discuss the nature of the change with EPA. This would minimize the possibility of EPA 

not approving the site-assigned tiers. The rule applying to this baseline inspection can be found 

in the FR (69 FR 42571–42583, July 16, 2004). 

3.0 PURPOSE OF THIS REPORT 

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

Baseline Inspection No. ORNL-CCP-CH-11.07-8 in terms of findings and concerns. 

Specifically, this report does the following: 

• Describes the characterization systems evaluated during the inspection that are approved 

• Provides objective evidence of the approval basis for all WC systems 

• Identifies all relevant system limitations and/or conditions for each WC system 

• Identifies the applicable T1 and T2 elements 

• Provides objective evidence of outstanding findings or concerns, as applicable 

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

their relevance to EPA’s approval decision 

 

3 The potential contents of a waste stream or group of waste streams determine which processes can adequately 

characterize the waste. For example, if AK information suggests that the waste form is heterogeneous, the site 

should select a suitable NDA technique to ensure adequate measurements. Radiography and VE help to confirm and 

quantify waste components, such as cellulosics, rubbers, plastics, and metals. Once the nature of the waste has been 

confirmed, the assay techniques then quantify selected radionuclides in the waste. In some cases, a TRU waste 

generator site may be able to characterize a wide range of heterogeneous waste streams or only a few. A site’s 

stated limits on the applicability of proposed WC processes govern EPA’s inspection scope.
6

The completed checklists (Attachments A.1 through A.4 to this report) reference the documents 

that the EPA inspection team reviewed in support of the technical determination. To see or 

obtain copies of any items identified in the attached checklists, write to the following address: 

Quality Assurance Manager 

USDOE/Carlsbad Area Field Office 

P.O. Box 3090 

Carlsbad, NM 88221 

EPA’s final approval decision on the ORNL-CCP WC program will be conveyed to DOE 

separately by letter. More information is also on EPA’s Web site at 

http://www.epa.gov/radiation/WIPP/index.html in accordance with 40 CFR 194.8(b)(3). 

4.0 SCOPE OF INSPECTION 

The scope of EPA Baseline Inspection No. EPA-ORNL-CCP-11.07-8 was the evaluation of the 

technical adequacy of the WC systems in use at ORNL-CCP to characterize TRU wastes. The 

EPA inspection team evaluated these systems with respect to their ability to perform the 

following functions: 

• Identify and quantify the activities of the 10 WIPP-tracked radionuclides (241Am, 137Cs, 

238Pu, 239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U, and 238U) using a combination of AK and NDA 

systems 

• Assign waste material parameters (WMPs) correctly using RTR for CH retrievably-stored 

debris waste 

• Perform effective waste information (data) transfer using the WWIS 

Specifically, these systems consisted of the following components: 

• AK processes that support retrievably-stored S5000 debris wastes 

• One NDA system, the DWAS IPAN/SGS system, for the analysis of S5000 debris wastes 

• RTR 

• The WWIS for the purpose of data transfer for all waste containers destined for WIPP 

emplacement 

During an inspection, EPA does not approve characterization data; that function is the sole 

responsibility of the site being evaluated—in this case, ORNL-CCP. EPA evaluated the site’s 

WC processes to characterize CH retrievably-stored TRU debris wastes. The evaluation 

consisted of interviewing personnel, observing equipment operations that follow site procedures, 

and inspecting records related to each of the WC processes within the inspection’s scope. An 

important aspect of this evaluation was the objective evidence documenting the effectiveness of 

the WC processes. Objective evidence typically takes the form of batch data reports (BDRs), 

radioassay data sheets, AK accuracy reports, RTR tapes, and WWIS printouts for specific TRU 

containers. During this inspection, EPA selected samples of each of these items, based on the 
7

number and variety of items each WC process produced, consistent with standard inspection 

techniques. Based on the evaluation of the WC processes in conjunction with the sample of 

objective evidence, EPA determined the technical adequacy of the WC processes within the 

inspection’s scope. 

5.0 INSPECTION-RELATED DEFINITIONS 

During an inspection, EPA inspectors may encounter items or activities that require further 

inquiry for their potential to adversely affect WC and/or isolation within the repository. The two 

main categories relevant to WC inspections are identified below: 

Finding: A determination that a specific item or activity does not conform to 

40 CFR 194.24(c)(4). A finding requires a response from CBFO. 

Concern: A judgment that a specific item or activity may or may not have a negative effect on 

compliance and, depending on the magnitude of the issue, may or may not require a 

response. 

Note that DOE does not need to address concerns not requiring a response prior to program 

approval. However, EPA recommends that when DOE accepts the site’s response to an EPA 

concern, it should inform EPA at the same time that the site implements the corresponding 

corrective action. This process is similar to a T2 change. 

6.0 PERSONNEL 

6.1 EPA Inspection Team 

Table 2 identifies the members of the EPA WC inspection team. 

Table 2. EPA Inspection Team Members 

Inspection Team Member Position Affiliation

Ed Feltcorn Inspection Team Leader U.S. EPA ORIA 

Rajani Joglekar Inspector U.S. EPA ORIA 

Lloyd Generette EPA Observer U.S. EPA Region 4 

Michael Eagle Quality Assurance Auditor U.S. EPA ORIA 

Connie Walker Inspector S. Cohen & Associates, Inc.

Aris Papadopolous Inspector S. Cohen & Associates, Inc 

Dorothy Gill Inspector S. Cohen & Associates, Inc. 

Colin Falato Inspector S. Cohen & Associates, Inc 

Patrick Kelly Inspector S. Cohen & Associates, Inc.

6.2 Personnel Contacted 

EPA and its support personnel conducted interviews with ORNL-CCP WC personnel in several 

disciplines. The personnel contacted represented only a sample of the CH TRU WC staff, and 

they are listed in Table 3, along with their affiliations and areas of expertise. 
8

Table 3. Personnel Contacted During Inspection

Personnel Affiliation Area of Expertise/Function 

Jeff Harrison CCP—Tech Specs AK-AKE 

David Larson WTS AK-AKE 

David Adkins WTS AK-AKE 

Dick Blauvelt CTAC AK 

Norman Frank CTAC NDA—DWAS IPAN/SGS 

John West MCS NDA—DWAS IPAN/SGS 

Joe Wachter MCS NDA—DWAS IPAN/SGS 

Sean Stanfield MCS NDA—DWAS IPAN/SGS 

Barry Smith MCS NDA—DWAS IPAN/SGS 

George Westik MCS NDA—DWAS IPAN/SGS 

Christa Chavez CCP-WTS NDA—DWAS IPAN/SGS 

Joseph Harvill CCP-WTS NDA—DWAS IPAN/SGS 

Susan Smith MCS NDE Operator/ITR 

E. Lee Smith MCS NDE Operator/ITR 

David Larson CCP WCA/WCO 

Bob Billet VPM Container Management 

Courtland Fesmire CBFO TRU Waste Certification Work Coordinator 

During the baseline inspection, ORNL-CCP provided a list of TRU WC personnel, from which 

EPA selected a sample of individuals to interview. The EPA inspectors reviewed the 

qualifications (including WC experience) and training records of these individuals to assess their 

WC capabilities. Based on this evaluation, EPA determined those ORNL-CCP WC personnel 

responsible for characterizing and certifying TRU waste were qualified and had received 

adequate training to perform their assigned function. When personnel changes occur, EPA may 

request qualification and training records of any new individuals identified as key WC personnel. 

EPA will review these records and may interview the personnel to determine their ability to 

produce quality data. This personnel qualification evaluation and review of training records is 

similar to EPA’s evaluation during each inspection. 

7.0 PERFORMANCE OF THE INSPECTION 

7.1 Site Background and History 

ORNL is one of the three main complexes located on the 35,299-acre DOE ORR, approximately 

8 miles southwest of the residential areas of Oak Ridge, Tennessee. ORNL encompasses 8,771 

acres and is bounded by the Clinch River on its eastern, southern, and western borders. First 

established in 1943 as part of the Manhattan Project to pioneer a method for producing and 

separating plutonium, ORNL’s later activities focused on research and development of nuclear 

research reactors, particle accelerators, hot cells, and engineering process development facilities. 

ORNL’s current mission includes environmental restoration and nuclear material stabilization 
9

and stewardship. The TRU Waste Processing Center (TWCP), located 2 miles east of ORNL on 

the ORR, is the site of all WC activities evaluated during this inspection. 

7.2 Inspection Process Overview 

EPA Baseline Inspection No.ORNL-CCP-11.07-8 took place November 13–15, 2007. EPA 

reviewed additional documents that were provided after the inspection to complete its evaluation 

of several of the technical areas within the inspection’s scope. The inspection was performed for 

the purpose of determining ORNL-CCP WC program compliance with 40 CFR 194.24. The 

inspection involved the following steps: 

(1) Preparing draft checklists specific to each technical area before the inspection 

(2) Obtaining and reviewing site procedures, reports, and other technical information related 

to WC activities at ORNL-CCP in advance of the inspection 

(3) Interacting with CBFO and ORNL-CCP personnel to arrange inspection logistics 

(4) Verifying onsite the technical adequacy or qualifications of WC personnel, procedures, 

processes, and equipment by means of interviews, observation, and demonstrations, and 

recording the results on checklists 

(5) Recording all concerns on EPA Inspection Issue Tracking Forms and providing 

completed forms to CBFO and site personnel as they were generated 

(6) Communicating all pertinent information to CBFO and ORNL-CCP personnel onsite, as 

appropriate 

(7) Pursuing resolution of all identified issues before completion of the inspection by 

discussions with CBFO and ORNL-CCP personnel 

(8) Conducting entrance, exit, and daily briefings for CBFO and ORNL-CCP management 

personnel, as appropriate 

(9) Reviewing additional information provided by ORNL-CCP after the inspection 

8.0 TECHNICAL WASTE CHARACTERIZATION AREAS 

Sections 8.1 through 8.5 of this report detail the five technical areas assessed during this 

inspection—AK and load management; NDA; NDE, consisting of RTR; the WWIS; and 

container management. 

8.1 Acceptable Knowledge 

EPA examined the AK process and associated information to determine whether ORNL-CCP 

demonstrated compliance with 40 CFR 194.8 requirements for CH retrievably-stored debris 

waste. 
10

WC Element Description 

As part of the inspection, EPA reviewed the following elements of the AK process: 

• Overall procedural technical sufficiency and scope and ability to follow the AK WC 

process for containers and waste stream 

• Waste-generating procedures, processes, and documentation 

• Characterization of required WMPs and radionuclides

• AK information assembly and compilation 

• AK confirmation and associated discrepancy resolution 

• Sufficiency of AK characterization results 

• Assembly of required information and use of supplemental information 

• AK summary report preparation 

• Reassignment of waste stream due to AK and discrepancy analysis 

• AK accuracy 

Attachment A.1 to this report identifies objective evidence reviewed by the EPA inspection 

team. AK provides information on several aspects of TRU wastes at ORNL-CCP, including but 

not limited to the following: 

• Defense waste status 

• Material parameters 

• Waste stream 

• Radionuclide composition 

• Waste matrix codes (WMCs) 

Documents Reviewed

During the inspection, EPA inspectors examined a variety of documents related to AK, provided 

in paper and/or electronic format. The list of all documents reviewed as objective evidence is 

presented below. The number preceding each document reference (e.g., C100, I052, M012, 

P284) represents the identifier within the ORNL-CCP numbering system that is used for AK 

documentation. Please note that some of these documents are considered proprietary 

information for Nuclear Fuel Services, Inc. (NFS), of Erwin, Tennessee, and these documents 

may not be released to the general public. In the list below these documents are marked NFS 

Proprietary, Not Approved for Public Release. 

• CCP-PO-001, CCP Transuranic Waste Characterization Quality Assurance Project Plan, 

Revision 15, August 10, 2007 

• CCP-PO-002, CCP Transuranic Waste Certification Plan, Revision 19, May 22, 2007 
11

• CCP-PO-002, CCP Transuranic Waste Characterization Plan, Revision 20, Draft M 

• CCP-AK-ORNL-001, CCP Acceptable Knowledge Summary Report for Nuclear Fuel 

Services Contact-Handled Transuranic Waste Stored at Oak Ridge National Laboratory. 

Waste Stream: OR-NFS-CH-HET, Revision 0, September 25, 2007, Revision 1, November 

30, 2007 

• CCP-TP-005, CCP Acceptable Knowledge Documentation, Revision 18, with sample 

attachments, November, 16, 2006 

• CCP-TP-005, Attachment 1, Acceptable Knowledge Documentation Checklist, Revision 18, 

October 30, 2007 

• CCP-TP-005, Attachment 4, Acceptable Knowledge Source Document Reference List 

(Included in AK Summary Report: CCP-AK-ORNL-001), November 14, 2007, and 

November 30, 2007 

• CCP-TP-005, Attachment 5, Hazardous Constituents, Revision 18, October 26, 2007 

• CCP-TP-005, Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, and 

Packaging, Revision 18, October 26, 2007 

• CCP-TP-005, Attachment 6, Memorandum from Jeff Harrison, CCP AKE, to Records, Waste 

Material Parameter Analysis for Waste Stream OR-NFS-CH-HET, NFS Contact-Handled 

Transuranic Waste Stored at Oak Ridge National Laboratory, Revision 0, September 25, 

2007 

• CCP-TP-005, Attachment 7, Radionuclides (Radiological Characterization or NDA Memo), 

Revision 0, October 26, 2007; Revision 1, January 7, 2008 

• CCP-TP-005, Attachment 8, Waste Containers List, Revision 18, October 26, 2007 

• CCP-TP-005, Attachment 9, Waste Characterization Data Cross-Reference, Example Form, 

undated 

• CCP-TP-005, Attachment 10, Acceptable Knowledge Re-Evaluation Checklist, Example 

Form, undated 

• ORNL-AK Tracking Spreadsheet, printed November 15, 2007

• CCP-QP-002, CCP Training and Qualification Plan, Revision 25, May 8, 2007 

• Draft Waste Stream Profile Form for Waste Stream OR-NFS-CH-HET and Characterization 

Information, for audit purposes only, November 2007 

• CCR-TP-001, CCP Project Level Data Validation and Verification, Revision 17, September 

24, 2007 

• Qualification Card for Jeff Harrison, provided November 15, 2007 

• Qualification Card for David Adkins, provided November 15, 2007 

• CCP Internal Surveillance Report (draft cover letter only), provided November 14, 2007 

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

Background Information, May 3, 2005 
12

• C100, Interview with Richard Booth and Faxed defense and waste information for NFS, 

Erwin, TN TRU waste, February 4, 2005—NFS Proprietary, Not Approved for Public 

Release

• C119, Removal of Contaminated Pipe, Building 234 Area B, Memorandum to Ron Mitchell, 

Letter of Authorization, LOA-7000-018, March 20, 2002—NFS Proprietary, Not Approved 

for Public Release

• C121, DVRF Bale Packaging Glovebox Removal, Memorandum to Ron Mitchell, LOA7000-034, February 15, 2001—NFS Proprietary, Not Approved for Public Release

• C122, Building 234 Characterization Results, Memorandum to Heather Little, DCM-03-18, 

44T-99-0436, GPC-99-013, September 30,1999—NFS Proprietary, Not Approved for 

Public Release

• C127, Size Reduction of the NDA Station 2 Glovebox in the DVRF Decontamination Cell, 

Memorandum to Ron Mitchell and Rick Leitner, SWI-02-018, April 16, 2001—NFS 

Proprietary, Not Approved for Public Release

• C129, Size Reduction Process Ductwork within the Decontamination Cell, DVRF, 

Memorandum to Ron Mitchell and Rick Leitner, SWI-01-015, March 15, 2001—NFS 

Proprietary, Not Approved for Public Release 

• C130, Cleanout of DVRF Bale Packaging Glovebox, Memorandum to Ron Mitchell and 

Rick Leitner, SWI-01-013, March 3, 2001—NFS Proprietary, Not Approved for Public 

Release 

• DR001, CCP-TP-005, Attachment 11, Acceptable Knowledge Source Document 

Discrepancy Resolution (Radionuclide Determination), September 21, 2007; November 1, 

2007 

• DR002, CCP-TP-005, Attachment 11, Acceptable Knowledge Source Document 

Discrepancy Resolution (EPA Hazardous Waste Number Assignment), Revision 0, 

September 21, 2007; Revision 1, November 1, 2007 

• I052, Memorandum; Building 234 Shear Baler Characterization Samples, DC-03-18, 

44T-02-0633, GPC-02-013, September 11, 2002 

• I056, Removal of Building 234 Wet Cell Permacon Containment Enclosure, 

DC-SWI-03-041, June 20, 2002—NFS Proprietary, Not Approved for Public Release

• I058, Dismantlement of the West Wet Cell Wall in Building 234, DC-SWI-02-030, 

undated—NFS Proprietary, Not Approved for Public Release

• I059, Waste Packaging of Wet Cell Wall in Building 234, WST-SWI-02-002, Revision 1, 

September 19, 2002—NFS Proprietary, Not Approved for Public Release

• I061, Size Reduction of the DVRS Glovebox, DC-SWI-01-020, May 24, 2001—NFS 

Proprietary, Not Approved for Public Release

• I067, Procedure for the Operation of the Versatile Automated Gamma Assay System 

(VAGAS), NFS-ACC-104, Revision 0, May 8, 2000—NFS Proprietary, Not Approved for 

Public Release 
13

• I068, Size Reduction of 4-inch Diameter Duct Section in Area C, DC-SWI-02-004, Revision 

0, January 25, 2002—NFS Proprietary, Not Approved for Public Release

• M007, Finding of No Significant Impact, Receipt and Storage at Oak Ridge National 

Laboratory of Transuranic Waste, Mixed Transuranic Waste, and Mixed Oxide Waste from 

Nuclear Fuel Services, Inc., Letter No. ER-NEPA/92-05, November 9, 1996 

• M011, Material Safety Data Sheets for Products Used at NFS, undated 

• M012, Environmental Management (EM) Waste Database Query, August 9, 2007 

• M013, EM Waste Database Query—NFS Box Daughter and Repack Drums, August 23 and 

29, 2007 

• M016, Incoming Container Travelers for NFS Waste, various dates 

• M017, Foster Wheeler NDA Data for NFS TRU Waste, various dates 

• M018, Foster Wheeler NDE Date for NFS TRU Waste, various dates 

• M019, Foster Wheeler VE Data for NFS TRU Waste, various dates

• M021, Defense Determination Approval Form, Waste Stream ORNL/NFS-HD-001, May 13, 

2005 

• P212, Lattice Experiments with Simulated Burned-Up Fuel for D2O Power Reactors, DP1122, February 1968—NFS Proprietary, Not Approved for Public Release

• P251, Box Breakdown Area Operations, CH-P-OP-003, Revision 7, March 13, 2007 

• P254, Contact Handled Waste Repackaging, CH-P-OP-013, Revision 6, April 30, 2007 

• P255, Contact Handled Waste Acceptance Criteria, T-CH-FW-X-AD-001, Revision 5, 

October 19, 2006 

• P256, TRU/Alpha Low Level Waste (LLW) Treatment Project Documented Safety Analysis, 

T-CM-FW-R-AD-001, Revision 13, October 16, 1992 

• P268, ORNL WAC for Contact Handled Transuranic and Mixed Oxide Wastes from Nuclear 

Fuel Services, Inc., WMRA-WMPC-106, October 16, 1992 

• P272, Oak Ridge National Laboratory Waste Management Plan, ORNL/TM-11433, Revision 

1, December 1991; Revision 2, 1992; and Revision 3, 1993

• P273, Nuclear Fuel Services, Inc., Waste Certification Plan for Transuranic Waste, 28G-91-

001, Revision 0, July 1991; DCM-03-05, Revision 0, July 1991; Revision 1, February 1992 

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

Waste Constituents, March 1, 1992 

• U017, The Inter-Comparison of NDA Measurements on CH-TRU Waste Between Nuclear 

Fuel Services, Inc., and Oak Ridge National Laboratory, October 24, 1995 

• U040, NFS Response to “Transuranic Waste Baseline Inventory Report Questionnaire,” 

January 1996
14

• P284, Gunnink, R., MGA: A Gamma-Ray Spectrum Analysis Code for Determining 

Plutonium Isotopic Abundances, Volume 1, Methods and Algorithms, UCRL-LR-103220, 

Lawrence Livermore National Laboratory, April 3, 1990 

• P285, Voss, J., T., Los Alamos Radiation Monitoring Notebook, LA-UR-00-2584, June 

2000, updated February 2001 

Table 4 shows the BDRs that the EPA inspection team examined during this inspection. 

Table 4. BDRs Examined 

Container Number RTR BDR Number NDA BDR Number 

X10C0501112 OR-RTR6-0002 OR-DWAS-0001 

X10C0505990 OR-RTR6-0006 OR-DWAS-0002 

X10C0501382 OR-RTR6-0007 No data available 

X10C0501270 OR-RTR6-0007 OR-DWAS-0002 

Technical Evaluation

The EPA inspection team evaluated a single retrievably-stored debris waste stream, identified as 

OR-NFS-CH-HET. This is the only waste stream with containers that had undergone complete 

characterization at ORNL-CCP, and samples from it were selected for evaluation during the 

inspection. This waste stream consists of CH TRU mixed heterogeneous debris wastes that were 

generated at NFS from 2000 through 2003 as a result of the Building 234 decontamination and 

decommissioning (D&D) and that have been stored at ORNL. EPA evaluated the adequacy of 

AK pertaining only to these CH TRU retrievably-stored debris wastes, as described below. 

Accordingly, the addition of newly-generated wastes is a T1 change, as discussed in Section 

(16), below. (See Table 1, which includes this as a T1 change.) 

(1) Data management was evaluated and found to be adequate. 

ORNL-CCP uses two primary databases to document AK and characterization information, the 

Program Tracking System (PTS) and the AK Tracking Spreadsheet. AK procedure 

CCP-TP-005, CCP Acceptable Knowledge Documentation, requires development and 

maintenance of the AK Tracking Spreadsheet that lists containers within each waste stream as 

well as container identification, waste stream identification, generation date, vent date/status and 

changes, and container type. The PTS tracks the characterization status of each container, and 

the Characterization Tracking System module (CTS) of the PTS tracks nonconformances on a 

container basis. ORNL-CCP representatives indicated that drums that are subject to a 

nonconformance report (NCR) are identified by a hold tag that is physically attached to the drum 

to identify problematic containers. ORNL-CCP representatives indicated that ORNL also has a 

site EM database that tracks both historic and current characterization information for containers. 

ORNL-CCP personnel said while they might use the EM database for information, they are not 

responsible for input to or maintenance of this database. 
15

It should be noted that ORNL-CCP tracks each container’s characterization status, while Energx4

is responsible for container movement and storage locations. According to the AK Summary 

Report (AKSR), approximately four areas may be used to manage containers: Storage Areas 

7883, 7880, 7879, and 7574. Mr. Bob Billett, the CCP-ORNL Program Manager, clarified that 

the Contact-Handled Storage Area (CHSA) near the TWPC has additional container storage that 

Energx also uses to stage characterized containers. A new Contact-Handled [waste] Marshalling 

Building (CHMB), currently under construction, will be used to stage TRU containers and to 

load transuranic packaging transporters (TRUPACTs). ORNL-CCP representatives stated that 

Energx performs an inventory of the TRU waste stream population on a weekly basis, 

emphasizing that drum location and management are top-priority items to ensure that TRUPACT 

payloads include only those containers with appropriate characterization. 

(2) AK accuracy was assessed and found to be adequate. 

Attachment 14 of CCP-TP-005 documents the annual AK accuracy assessment. Because the 

ORNL-CCP characterization process had only been performed for a few months at the time of 

EPA’s inspection, an AK accuracy report was not available for review during the inspection. 

However, EPA received an AK accuracy report during the week of December 4, 2007, following 

the inspection. This AK accuracy report compared the two most prevalent radionuclides as 

indicated by available NDA characterization data, 240Pu and 239Pu, to the two most prevalent 

radionuclides identified in the AK Summary Report (AKSR), 239Pu and 238U. The NDA 

characterization data did not match the most prevalent radionuclides identified by the AKSR, as 

had been indicated as a possibility in the AKSR. AK data indicated that a few containers may 

contain relatively large quantities of 238U by mass, causing 238U to dominate the mass-based 

determination of the most prevalent radionuclides presented in the AKSR. The sample of 

containers that were chosen as part of the AK BDR review did not contain detectable quantities 

of 238U, so this was excluded from the most prevalent radionuclides by mass based on actual 

container assays. DOE-WIPP-02-3122, the Waste Acceptance Criteria (WAC), requires the 

determination of the two most prevalent radionuclides and does not specify whether this 

calculation must be done in terms of mass or activity. 

Providing notification to EPA upon completion of subsequent AK accuracy reports for every 

waste stream is a T2 notification requirement. Consistent with EPA’s authority under 40 CFR 

194.24(h), EPA may request this information if the Agency deems it necessary to ensure 

continued compliance with EPA regulations. (See Table 1, which includes this as a T2 change.) 

(3) NDA-AK communication was assessed and found to be adequate following revision of key 

documents. 

All TRU WC sites formally implement AK-NDA communication to ensure appropriate use of 

AK data. CCP-TP-005 requires the preparation of an AK-NDA memorandum: 

Prepare a NDA Memorandum to CCP Records CH waste only, evaluating the 

radionuclide characterization of the waste stream. The NDA Memorandum must include 

 

4

 Energx is the Foster Wheeler Environmental Corporation that operates the TRU Waste Processing Center on 

the ORR. In this report Energx and Foster Wheeler are synonymous. 
16

a section for an assessment written with the NDA EA determining how the AK will be 

applied during assay. For LANL sealed sources waste, the NDA Memorandum must 

include a section written with the Off-Site Source Recovery (OSR) RCTS. This 

assessment should include a discussion of the limitations of the radiological 

characterization in the AK document and a description of the required assay methods, if 

any. Any NDA issues for both measured and calculated radionuclides should be 

discussed and resolved. 

EPA examined the AK-NDA memorandum and identified several inconsistencies between the 

memorandum and the AKSR, as well as questions concerning the Discrepancy Resolution 

Report (DRR) that might ultimately affect the AK-NDA memorandum [see Items (11) and (16), 

below]. EPA noted that the AK-NDA memorandum did not specify how NDA personnel will 

use the AK data. EPA discussed this concern with ORNL-CCP AK personnel and included it on 

an EPA Inspection Issue Tracking Form (See Attachment C.9 of this report for a copy of this 

form); this issue is discussed below. 

EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-CH-AK-07-009CR: The AKNDA memorandum attached to CCP-TP-005, Attachment 7, does not specify how NDA 

personnel will use the AK data. The use of AK data by NDA personnel should be specified 

through statement in the AK-NDA memorandum or reference to the appropriate NDA procedure. 

Resolution: The AK-NDA memorandum was initially revised to address this concern directly 

following the inspection. EPA received another revision dated January 7, 2008, titled CCP-AKORNL-001, NDA Memo, Radiological Evaluation of Waste Stream OR-NFS-CH-HET, Nuclear 

Fuel Services Contact-Handled Transuranic Waste Stored at Oak Ridge National Laboratory, 

Revision 1. This revision of the memorandum indicates how and when default isotopics will be 

used. It also included the information used to develop the default isotopics for the waste stream 

and a complete discussion regarding how those default values were generated. The revised 

memorandum is adequate and addressed the concerns raised by EPA during the baseline 

inspection. 

Status of Concern: Issue No. ORNL-CH-AK-07-009CR is closed. 

Considering the importance of communication between AK and NDA staff to resolve 

discrepancies between the isotopics information in the AK record and what is observed during 

NDA measurements, it is possible that the AK-NDA memorandum would be revised when such 

discussion takes place. EPA needs to be notified if the AK-NDA memorandum is revised to 

reflect changes in isotopics as more CH debris waste drums or TRU drums containing other 

waste categories undergo NDA measurements. When the AK-NDA memorandum is revised, 

EPA must receive notification as a T2 change. Consistent with EPA’s authority under 

40 CFR 194.24(h), EPA may request this information if the Agency deems it necessary to ensure 

continued compliance with EPA regulations. (See Table 1, which includes this as a T2 change.) 

(4) AK procedural accuracy was assessed and was found to be adequate. 

Procedure CCP-TP-005 describes the processes used by ORNL-CCP to compile, review, 

evaluate, update, and report AK documentation. The procedure also describes how ORNL-CCP 
17

(1) determines AK sufficiency and accuracy; (2) reevaluates AK documentation; (3) resolves AK 

documentation discrepancies, when necessary; (4) uses AK to delineate waste streams; and 

(5) determines if a waste is hazardous. 

Implementation of CCP-TP-005 is based on the (1) Waste Isolation Pilot Plan Hazardous Waste 

Facility Permit, Waste Analysis Plan (WIPP WAP), which authorizes the use of AK to delineate 

waste streams and characterize hazardous waste; (2) CCP-PO-001, CCP Transuranic Waste 

Characterization Quality Assurance Project Plan; and (3) the WAC AK requirements addressed 

in CCP-PO-002, Transuranic Waste Certification Plan. EPA requires that CCP-TP-005 

adequately convey AK elements to address the requirements of the WIPP WAP, the WAC, and 

40 CFR 194.24. EPA found that the procedure satisfied these requirements. Providing 

notification to EPA regarding changes made to AK procedures that require CBFO approval is a 

T2 change. (See Table 1, which includes this as a T2 change.) 

 

(5) Load management was examined and found to not apply at ORNL-CCP at this time. 

During the inspection, the ORNL-CCP Acceptable Knowledge Expert (AKE) stated that ORNLCCP is not seeking approval to perform load management, and EPA excluded evaluation of load 

management from the scope. EPA did not evaluate load management during the inspection. 

Implementation of load management would be a T1 change and must be in accordance with the 

Appendix E of the CBFO WAC. (See Table 1, which includes this as a T1 change.) 

(6) The definition of the waste stream was evaluated and found to be appropriate. 

The WIPP WAP and WAC define a waste stream as “waste material generated from a single 

process or from an activity which is similar in material, physical form, and hazardous 

constituents.” Waste Stream OR-NFS-CH-HET consists of CH TRU mixed heterogeneous 

debris (S5400) waste generated at NFS and stored at ORNL. ORNL-CCP has characterized the 

waste stream as RCRA-hazardous waste under 40 CFR Part 261, Subpart C. 

This waste stream contains debris from the final decommissioning phase of NFS Building 234, 

which occurred between 2000 and 2003. It includes 144 55-gallon drums, some of which are the 

result of size reduction and repackaging of boxed waste. The wastes were packaged at NFS from 

April 2001 to September 2003, and a portion of the waste underwent size reduction and 

repackaging at the TWPC from December 2005 to May 2007. 

EPA reviewed the methodology and supporting AK documentation used by ORNL-CCP to 

define the waste stream in terms of physical form, radiological characteristics, chemical usage, 

potential hazardous materials, and prohibited items, as well as the ability of the site to segregate 

them from the waste stream. EPA found that Waste Stream OR-NFS-CH-HET was 

appropriately defined. The wastes were generated by the same D&D process that was performed 

over a specified time period. ORNL-CCP representatives stated that waste was not intentionally 

segregated based on physical, chemical, or radiological components (radionuclides). While 

individual containers may exhibit different physical properties, ORNL-CCP indicated that it 

anticipated that the waste stream will contain approximately equivalent amounts of organic and 

inorganic debris, so the physical form is well defined. Based on the assumption that the 
18

radiological components are distributed equally throughout the waste stream, a common 

radiological composition is assigned to containers within the waste stream. EPA does not assess 

hazardous components within the waste, although data suggest that the waste may contain 

common hazardous constituents. 

 

According to the AKSR, debris waste from the initial phase of decommissioning, in the early 

1990s, will be added to Waste Stream OR-NFS-CH-HET at a later date. These wastes consist of 

261 drums of NFS debris waste currently in storage at ORNL that will be evaluated for possible 

inclusion in OR-NFS-CH-HET. In addition, there are nine B-25 boxes that may be TRU waste 

after repackaging into 55-gallon drums at the ORNL TWPC, at which time they will also be 

evaluated for possible inclusion in this waste stream. EPA expects any AK Summaries that 

address wastes beyond the 144 drums covered by this baseline inspection to fit the waste stream 

as defined. Providing AK Summaries that include additional waste is a T2 change. (See Table 

1, which includes this as a T2 change.)

(7) The use of quick or fast scan was examined and found to be adequate. 

The CCP AKE indicated that Foster Wheeler performs a fast scan of containers using their own 

internal process and procedures to initially screen containers for the presence of prohibited items, 

WAC requirements, and other non-WIPP-related requirements. The data are used to release 

containers to ORNL-CCP, which performs 100% NDE (RTR) on TRU waste containers. 

Although not in the AK record to date, EPA recommends that this information be integrated to 

ensure the availability of potentially important data on containers as they are processed. ORNLCCP should ensure that quick or fast scan records are referenced in the AK record.

(8) Staff training was examined and found to be adequate. 

Qualification and training of ORNL-CCP personnel is implemented through CCP-QP-002, CCP 

Training and Qualification Plan. With respect to AK, the plan applies to personnel compiling 

AK information for ORNL-CCP and evaluating and resolving discrepancies associated with 

TRU waste destined for the WIPP. According to the plan, all qualification and training 

candidates are required to complete a qualification card to verify that they posses the knowledge 

and skills necessary to competently perform specified tasks. EPA inspectors reviewed the plan, 

interviewed Jeff Harrison (AKE) and David Adkins (Site Project Manager (SPM)), and 

evaluated their qualification cards. These individuals had performed required reading pertinent 

to applicable portions of the WIPP WAP and WAC, State and Federal RCRA regulations 

associated with solid and hazardous WC, discrepancy resolution and reporting processes, and 

site-specific procedures associated with WC using AK. However, ORNL-CCP does not 

specifically incorporate EPA requirements relative to WIPP Performance Assessment in the 

training program, and EPA suggests that the program be modified in the future to incorporate 

these requirements, particularly since the second recertification application will be submitted in 

2008 and could directly affect characterization requirements. EPA found that staff training of 

ORNL-CCP personnel was adequate. 

(9) Drum traceability was assessed, as well as the ability to follow the AK WC process for 

containers and waste streams that were evaluated and found to be adequate. 
19

Several containers were selected to assess drum traceability for the 144-drum population 

generated from approximately 2000–2003: X10C0501112 (repackaged from drum 

X1060506029), X10C0505990 (original drum), X10C0501270 (repackaged from drum 

X10C0506019), and X10C0501382 (repackaged from box AOC0506144). These containers 

were selected to sample containers from repackaged drums, containers from repackaged boxes, 

and drums that were not repackaged. All containers were assayed at NFS prior to shipment (see 

Item (15) for discussion of NFS assay). In addition, at the TWPC prior to ORNL-CCP’s 

involvement, each repackaged container underwent NDA twice (before and after packaging), as 

well as VE and RTR; a single NDA and RTR were performed on all drums that were not 

repackaged. The later characterization sequence took place in 2006. ORNL-CCP plans to 

characterize each container again via NDA and RTR. Therefore, traceability was followed from 

the original waste item descriptions for each container from NFS through the second Foster 

Wheeler radioassay or assays (reference M017), radiography sheets (M018), and VE (M019). 

ORNL-CCP representatives stated that the Oak Ridge EM Database documented data obtained 

from NFS as well as information from the Foster Wheeler characterization effort. Of the 

containers selected, all but X10C0501382 underwent both RTR and NDA by ORNL-CCP, and 

BDRs for these three containers were provided to further demonstrate traceability. Additionally, 

ORNL-CCP PTS data printouts for the containers and other container identification on the CCP 

AK Tracking Spreadsheet were examined. As a result of this analysis, data traceability was 

adequately demonstrated. Note that because the default isotopics used by Foster Wheeler and 

ORNL-CCP differed, the isotopic distributions for the same container often differed depending 

on the source of the values. 

(10) Limitations and exclusions associated with the AK record were assessed and found to be 

acceptable. 

Every AK source document has an associated Record of Communication (Attachment 3) that 

lists or identifies AK data limitations. Each of the examples provided either listed a limitation or 

stated that there were no limitations. It should be noted that the AKE indicated that additional 

references were being added to the AK record to address future containers. Several references 

identified had not yet been included in the AKSR (Attachment 4), so it was not possible to 

determine whether the AK record was complete. In the future, AK Summaries and related 

reference lists must be complete with respect to addition of data and references. The continual 

updating of references during the inspection does not demonstrate that data limitations and 

exclusions have been adequately assessed because data evaluation is still “in process” for the 

waste stream being inspected. Providing notification to EPA upon completion of Attachment 4 

for Waste Stream OR-NFS-CH-HET is necessary as a T2 change. Consistent with EPA’s 

authority under 40 CFR 194.24(h), the Agency may request this information if EPA deems it 

necessary to ensure continued compliance with EPA regulations. (See Table 1, which includes 

this as a T2 change.) 
20

(11) Discrepancy resolution (AK-AK) was examined and found to be adequate following 

revision of specific documents. 

ORNL-CCP prepared an AK-AK Discrepancy Resolution DR002 to assess numerous differences 

between NFS and Foster Wheeler NDA measurement data, as well Foster Wheeler pre- and postrepackaging discrepancies. The discrepancies identified included the following: 

• Incorrect reporting of 242Pu by NFS, differences between scaled and actual measured data 

from NFS (and subsequent decision to use TWPC data) 

• Differences between the reported 235U and 238U masses by NFS and the TWCP 

•

228Th and 232Th values reported by NFS that were not verified by the TWPC 

• Different isotopic compositions for various fuels generated/managed within Building 

234, including differences in plutonium isotopics and 235U enrichment 

• Different 238U values before and after measurement at the TWPC 

EPA noted that the AK discrepancy discussions were incomplete primarily because, while the 

discrepancies were identified, ORNL-CCP did not resolve them and instead stated that it 

believed the discrepancies would not pose an issue with respect to overall characterization of the 

waste stream. EPA discussed this concern with ORNL-CCP AK personnel and included it on an 

EPA Inspection Issue Tracking Form (see Attachment C.7 of this report for a copy of this form); 

this issue is discussed below. 

EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-CH-AK-07-007CR: 

Discrepancy Report DR002 identifies several discrepancies, but discrepancy resolutions are 

incomplete. For example, additional discrepancy resolutions are required for 235U and 238U 

discrepancies between NFS and TWPC NDA data, detection of 228Th and 232Th, isotopic data 

inconsistencies between Halden and Savannah River Site (SRS)5

, 

238U occurrence 

inconsistencies, and 235U enrichment inconsistencies with respect to SRS material. Resolution of 

these issues could result in changes to the waste stream ORNL-NFS-CH-HET AK-NDA 

memorandum and the AKSR. 

Resolution: Discrepancy Report DR002 was modified to indicate why 238U was detected by 

NFS and TWPC in a single container prior to repackaging, but not after repackaging, as this was 

due to “two segments of the assay being too dense to accurately quantify the radionuclides” and 

“significant gamma deadtime” that lead the NDA operator to not report 235U/238U in the 

repackaged container. Overall discrepancies in reporting uranium were attributed to differences 

in detection limits for the various instruments used. Thorium detection at NFS was attributed to 

possible background radiation (due to a lack of measurement system shielding), and the overall 

lack of precision and accuracy characteristics associated with the NFS VAGAS system was 

identified as a reason ORNL-CCP considered the NFS data to be questionable. ORNL-CCP 

indicated that contract specifications and direct data from SRS are the more credible sources of 

information pertinent to SRS isotopic discrepancies. However, ORNL-CCP provided no reason 

 

5

 The four waste streams are related to fuel produced according to specifications in contracts for four clients: 

SEFOR, Consumer’s Power, Dupont/SRO (SRS) and Halden. 
21

why the Halden isotopics presented in reference U016 were more credible than in other 

documents (it is assumed that this is because U016 is a “graphical worksheet” as opposed to a 

presentation, as shown in U017). Transcription errors were also attributed to 235U value 

discrepancies. 

 

Status of Concern: The response is adequate. ORNL-CCP has revised Discrepancy Resolution 

DR002 to address how the discrepancies were resolved, and this concern is closed. 

Providing notification to EPA upon completion of all radiological DRRs pertinent to this waste 

stream is a T2 change. Consistent with EPA’s authority under 40 CFR 194.24(h), the Agency 

may request this information if EPA deems it necessary to ensure continued compliance with 

EPA regulations. (See Table 1, which includes this as a T2 change.) 

(12) Defense origin of waste was examined and accepted.

The WIPP WAC requires generator sites to use AK to determine if the TRU waste streams to be 

disposed at the WIPP meet the definition of TRU “defense” waste. TRU waste is eligible for 

disposal at the WIPP if it has been generated in whole or in part by one of the atomic energy 

defense activities listed in Section 10101(3) of the Nuclear Waste Policy Act of 1982. 

According to the site, the basis for the “defense” nature of Waste Stream OR-NFS-CH-HET is 

that the Building 234 facility performed mixed-oxide (MOX) fuel fabrication and 233U 

purification under subcontracts to two government contracts administered by the U.S. Atomic 

Energy Commission as well as under two smaller commercial contracts. The two larger 

contracts were national defense-rated orders that were designated DO-E2 certified for national 

defense use under Defense Material System, Regulation 1. The defense and commercial 

activities used the same process equipment, so the source of contamination is indistinguishable. 

Therefore, the site argued that the TRU wastes from decommissioning are linked primarily to 

defense nuclear material production. EPA reviewed the site’s supporting documentation and 

found that the site’s argument is reasonable, noting that EPA does not perform a detailed and 

thorough analysis of the defense determination status. 

(13) AK information pertaining to the radiological characteristics of the waste was examined 

and found to be adequate. 

AK data presented in the Waste Stream CCP-AK-ORNL-001 AKSR, related AK-NDA 

memoranda, discrepancy resolution information, and various supporting references were 

examined to understand the anticipated radiological composition of the waste stream, 

development of default isotopics, and relevance/appropriateness of these distributions to the 

stream. Relevant references addressing radiological characteristics of the waste include C099, 

C100, C122, DR002, M012, M016, M007, M017, P256, P268, U016, U017, U040, and P284. 

CCP-AK-ORNL-001 states that waste within the stream was generated through D&D of 

Building 234, which was used for production and other activities related to MOX fuels. 

Additionally, a portion of the building was used as a 

233U purification process facility. The 

portion of the building that was used for 233U was decommissioned in 1983, and waste from this 

activity is not included in the waste stream. The D&D process was initiated in 1990 and 
22

continued to 1993. Wastes generated during this early D&D activity included cement that was 

removed to remediate concrete flooring in Building 234, rashig rings removed from production 

tanks, and various glovebox metals/other building metals and materials that were sent through a 

size reduction/shredder called the Decontamination and Volume Reduction Facility (DVRF). 

Waste from the DVRF was ultimately supercompacted at NFS and is not part of the waste 

stream. D&D of Building 234 ceased in 1993 due to financial considerations, but it resumed in 

2000–2001 and continued until 2003. Waste generated during the later portion of the D&D 

process included various debris materials typical of D&D operations; see Item (14), below. 

Building 234 managed and performed MOX fuel-related activities from four different contracts. 

Table 5, below, presents the radionuclide compositions of these materials (C099, C100, C122, 

DR002, P212, U016, U017). 

Table 5. MOX Fuel Compositions

Contract Pu Percent U Percent Pu (kg) U (kg) Total (kg) 

SEFOR 20 80 746 2984 3730 

Consumers 2.27 97.9 47 2027 2070.48 

SRS 0.31 99.7 16 5064 5079.37 

Halden 2.5 99.5 3 117 120 

Total - - 812 10,192 11,000 

These data show that uranium is the dominant radionuclide in terms of mass for each material. 

Fuels generated for the four contracts had specified isotopic distributions, as shown in Table 6, 

below. 

Table 6. Mass Isotopic Distributions of MOX Fuels by NFS Contract 

Radionuclide SEFOR Consumers SRS Halden 

238Pu 0.01 0.04 0.01 0.43 -- -- 0.01 0.29 

239Pu 18.13 90.63 1.73 76.24 0.29 90.94 2.00 79.89 

240Pu 1.67 8.33 0.37 16.34 0.02 7.99 0.36 14.51 

241Pu 0.10 0.48 0.07 2.91 0.003 0.99 0.06 2.24 

242Pu 0.01 0.05 0.03 1.1 0.0002 0.08 0.02 0.83 

241Am 0.09 0.47 0.06 2.86 -- -- 0.06 2.20 

Total 20.0 100 2.27 100 0.31 100 2.5 100 

 

234U 0.12 0.15 0.58 0.59 0.001 0.001 3.90 4.00 

235U 0.28 0.35 2.36 2.41 0.30 0.30 4.88 5.01 

238U 79.60 99.50 94.96 97.00 99.40 99.69 88.73 91.01 

Total 80.0 100 97.9 100 99.7 100 97.5 100 

Note: For each of these materials, the first column represents the overall mass fractions of the MOX fuel, 

and the second column provides the mass fractions of the fuel’s plutonium and uranium constituents 

separately. 

The AKSR states that NFS assayed TRU waste generated during the 2000–2003 (final) phase of 

decommissioning using the VAGAS. The VAGAS employed four to six high-efficiency 

germanium detectors to measure the contents of a 55-gallon drum (References I067, M003). 
23

After being shipped to ORNL, nearly all of this waste was reassayed at the TWPC in 2006 using 

Imaging Passive Active Neutron (IPAN) and Segmented Gamma Scanner (SGS) systems. 

Reference M017 states that ORNL-CCP considered the later TWPC assay to be AK, although it 

was performed in 2006, because “it was performed prior to implementation of the CCP TRU 

waste certification program at ORNL.” ORNL-CCP noted several discrepancies between the 

NFS and TWPC data and addressed these discrepancies in Discrepancy Report DR002, as 

discussed in Item (11), above. Based on the discrepancy analysis and resolution presented in 

Discrepancy Report DR002, ORNL-CCP considered the TWPC data to be more reliable than the 

NFS data, primarily because of unknowns associated with the NFS measurement system. This 

conclusion appears reasonable. ORNL-CCP therefore used this information to generate general 

isotopic ranges expected for various radionuclides, presented as Table 5-4 in the AKSR and as 

Table 7, below. 

Data on this table indicate that the waste stream is anticipated to consist primarily of a mixture of 

uranium and plutonium, with the predominant radionuclides by activity being 239Pu, 240Pu, 241Pu, 

and 241Am. The predominant radionuclides by mass are anticipated to be 238U and 239Pu based 

on AK data. As presented in Item (11), above, significant uncertainties are associated with 

measuring 238U, and the ORNL-CCP measurement system is not sensitive enough to detect 238U 

except when it is present in substantial quantities. Therefore, while previous systems identified 

238U as a predominant radionuclide by mass, measurements by ONRL-CCP may not identify 

238U; therefore, the predominant radionuclides by mass detected by ORNL-CCP may ultimately 

be 239Pu and 240Pu. This lack of instrument sensitivity may result in underreporting of 238U. 

ORNL-CCP representatives indicated that default isotopics were calculated based on the amount 

of MOX fuel processed for each material and its isotopic distributions characteristics. Based on 

this information, the radionuclide contribution from each material type was scaled to the amount 

of MOX it contributed to the total to derive a default isotopic distribution representative of the 

overall material managed in Building 234. Specifically, the default isotopics were calculated 

assuming each material type contributed to the total radionuclide content of the waste, but the 

percentage of plutonium contributed by each material type was scaled based on the quantity of 

material managed in Building 234. Default mass fractions were decay corrected to October 1, 

2007. The decay-corrected default mass fractions are as follows: 

Plutonium % Uncertainty 

238Pu 0.044% 0.0044% 

239 Pu 90.837% 9.0837% 

240Pu 8.893% 0.8893% 

241Pu 0.104% 0.0104% 

242Pu 0.122% 0.0122% 

241Am 1.115% 0.1115% 

Plutonium isotopic values for each material type were based upon contract/manufacturing 

specifications that ORNL-CCP believes to be the most accurate source of isotopic information 

for each material. ORNL-CCP assumed that this default isotopic distribution, based upon the 

type of plutonium managed in Building 234, was equally distributed in all material removed 

during D&D. ORNL-CCP representatives stated that there are no data to suggest that materials 
24

Table 7. Radionuclide Distribution for Waste Stream OR-NFS-CH-HET 

Radionuclide Radionuclide Total Weight Percent1 Range in Weight Percent by Radionuclide for Individual Containers2 Total Curies % Radionuclide3 Range in Curies b

Radionuclide for Individual Containe

WIPP Tracked Radionuclides 

241Am 0.15 0.03–2.86 4.97 2.08–17.09 

238Pu 0.01 0.00–0.43 1.81 0.00–5.88 239Pu 23.06 1.80–94.04 13.78 7.54–37.92 240Pu 2.74 0.26–16.34 5.99 3.30–17.81 242Pu 0.02 0.00–1.17 Trace 0.00–Trace 

233U7 Trace5 0.00–Trace Trace 0.00–Trace 

234U 3.42 0.00–4.00 0.21 0.00–0.80 238U 69.94 0.00–99.69 Trace 0.00–Trace 

137Cs Trace 0.00–Trace Trace 0.00–Trace 

90Sr8 Trace 0.00–Trace Trace 0.00–Trace 

Additional Radionuclides 

243Am Trace 0.00–Trace Trace 0.00–Trace 

237Np Trace 0.00–0.05 Trace 0.00–Trace 

241Pu 0.07 0.00–2.91 73.24 23.56–83.90 

235U 0.59 0.00–5.01 Trace 0.00–Trace 

1 This listing indicates the total weight percent of each radionuclide over the entire waste stream. 2 This listing is the weight percent range of each radionuclide on a container-by-container basis. Some containers where “0.00” is listed 

contain the specified radionuclide. 

3 This listing indicates the total activity percent (in curies) of each radionuclide over the entire waste stream. 4 This listing is the curie percent range of each radionuclide on a container-by-container basis. 5 “Trace” indicates less than 0.01 weight percent for that radionuclide. 6 241Am may be present in slightly larger percentages due to the further decay of 241Pu. 7 233U was not reported in waste assay data for this waste stream but may be present in trace quantities, as described above. 8 90Sr cannot be quantified by gamma spectrometry. Its value is calculated based on measured 137Cs values. A 90Sr/137Cs scaling factor o90Sr contribution. 9These weight percent ranges were expanded based on the plutonium and uranium isotopic distribution data provided in Table 6. 
25

were managed in specific areas or that D&D wastes can be tied to any individual material type, 

so assuming that the default isotopics occurred in all D&D waste is reasonable. EPA examined 

the default isotopic calculations and determined that the calculation approach used by ORNLCCP is reasonable, based on available data, noting that isotopic-specific values obtained by 

measuring each container may exhibit considerable variability. 

EPA also examined previous NDA measurements taken at NFS and the TWPC to understand the 

origin of these values and to assess if the individual measurements should have been used to 

derive isotopics instead of the material specification data. ORNL-CCP representatives indicated 

that the NFS data were obtained using a measurement system that appeared to be more sensitive 

than that used by either the TWPC or ORNL-CCP, so that actual radionuclides were identified 

and quantified via measurements. However, ORNL-CCP representatives also stated that because 

of the uncertainty associated with the measured NFS values, they were not confident in the 

accuracy of the measurements. TWPC measurements were obtained using the same 

instrumentation as used by ORNL-CCP, but ORNL-CCP representatives indicated that the 

default isotopics used by the TWPC were based on “generic” MOX distributions (reference 

U144) rather than material-specific calculations. Therefore, the TWPC measurements, while 

more reliable than NFS data, are not as accurate as those that will be obtained by ORNL-CCP. 

ORNL-CCP representatives indicated that the waste stream may be expanded to include 

additional material, and the radionuclide composition will also be assessed with the addition of 

containers. EPA assumes that this information will be included in the T2 submissions discussed 

in Section (10), below, and Sections (14) and (15), below. 

(14) Identification of WMPs and prohibited items was assessed and found to be adequate.

ORNL-CCP addresses WMP calculations in Attachment 6 of CCP-TP-005 and through an 

attached memorandum. ORNL-CCP first examined both RTR and VE information for the 144 

containers included in the inspected population to understand the overall physical composition of 

the stream and to calculate the amount of material present by WMP. Data from RTR, conducted 

by Foster Wheeler at the TWPC facility, were available for all containers in the population, and 

VE data were available for those containers that were repackaged. ORNL-CCP examined 

individual data sheets for each container and obtained the masses of specific waste items as 

identified on the original RTR/VE data sheets. ORNL-CCP then assigned the identified material 

to a WMP group and determined the total mass of each WMP and subsequent weight percent. 

Based on this information that showed the stream to be composed of approximately 43% organic 

debris and 57% inorganic debris, ORNL-CCP assigned a WMC of S5400 to the stream. 

Individual containers may vary significantly from this overall stream weight percent. Also, 

available data suggest that some of the drums may contain solidified fines as a solidified 

inorganic matrix, but the presence of this material does not change the Summary Category Group 

S5000 designation for any of the 144 drums in the stream. 

CCP-AK-ORNL-001 addresses prohibited items. This AKSR states that the only prohibited 

items identified in this waste stream were sealed containers greater than 4 liters. ORNL-CCP 

also stated that “small quantities” of liquids have also been identified in drums, and these shall 

be remediated prior to disposal at the WIPP. ORNL-CCP identifies containers with prohibited 

items, including liquids, through the NCR process. Items containing prohibited quantities of 
26

liquids are captured on NCRs and identified in the ORNL-CCP CTS; ORNL-CCP will not 

designate these containers as WIPP eligible until all NCRs are resolved. 

Providing notification to EPA when Attachment 6 and the associated memoranda are revised for 

this waste stream is a T2 change. Consistent with EPA’s authority under 40 CFR 194.24(h), the 

Agency may request this information if EPA deems it necessary to ensure continued compliance 

with EPA regulations. (See Table 1, which includes this as a T2 change.) 

(15) The AKSR for a waste stream for CCP-AK-ORNL-001 was assessed and found to be 

adequate following revision. 

A single AKSR for one waste stream was available for EPA inspection. Waste Stream OR-NFSCH-HET is CH TRU mixed heterogeneous debris waste generated at NFS in Erwin, Tennessee, 

and stored at ORNL. NFS Building 234 was used to fabricate MOX fuel for four clients, and 

related fuel-processing activities were performed in the building. A portion of the building was 

also used for a 233U purification process. Building 234 operated from 1965 through 1973, and 

D&D of the building took place from 1993 through 1994, and again from 2000 or 2001 through 

2003. The waste in Waste Stream OR-NFS-CH-HET was generated from 2000 through 2003 by 

the D&D of Building 234 at NFS and included both drummed and boxed wastes that were 

subjected to RTR and NDA prior to shipment to ORNL. Waste shipped to ORNL was 

characterized at the TWPC in 2006; boxed waste was repackaged at the TWPC and underwent 

VE, RTR, and NDA. Most of the drums created at NFS were repacked and also underwent VE, 

RTR, and NDA at the TWPC, but some of the original NFS drums were not repackaged and 

underwent only NDA and RTR at the TWPC. At the time of the EPA inspection, the waste 

stream consisted of 144 drums, 62 of which were created by repackaged boxes, 58 from 

repackaged drums, with the remaining 24 consisting of original drums. 

EPA reviewed the single AKSR and noted several discrepancies between the AKSR and the AKNDA memorandum (DR002), as discussed in Items (11) and (3) above. EPA discussed this 

concern with ORNL-CCP AK personnel and included it on an EPA Inspection Issue Tracking 

Form (see Attachment C.8 of this report for a copy of this form); this issue is discussed below. 

EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-CH-AK-07-008CR: AK 

Summary Report CCP-AK-ORNL-001 lacks sufficient detail with respect to technical issues that 

have the potential to impact AK WC. Examples include the following: 

• Occurrence, source, and potential distribution of 233U 

• Previous AKSR conclusions and information, including the distribution of default 

isotopic distributions 

• Consistency of isotopic and other information with respect to NDA-AK memorandum 

information 

• Examination and updating of document to include relevant information from references 

such as U044 that has not been added to the AK reference list or addressed in the AKSR 

• Additional process information (e.g., MOX generation) 
27

• Addition of references included in the NDA-AK memorandum 

• Additional changes based on the assessment and integration of AK data, including 

changes required due to discrepancy resolution as addressed in EPA Concern No. 

ORNL-CCP-CH-AK-07-007CR, Final, and the NDA-AK memorandum addressed in 

EPA Concern No. ORNL-CCP-CH-AK-07-009CR, Final. 

Resolution: The AKSR was revised, and changes pertinent to the EPA concern include the 

following: 

 

• Additional information pertaining to the two major government contracts for fuel 

fabrication 

• General data concerning decommissioning of facility areas that were used for 233U 

purification 

• Additional production operation information, including MOX pellet production, scrap 

dissolution and recovery, and additional decommissioning information 

• Overview of TRU waste generation and management information 

• Additional decommissioning information with an emphasis on early (1993–1994) 

activities 

• Historic assay processes and data, e.g., NFS, Waste Examination and Assay Facility 

(WEAF), TWPC 

• Revision to include 238U, 235U, 228Th, and 232Th discrepancy resolution information 

consistent with DR001, Revision 1 

• Additional discussion about the two most prevalent radionuclides by mass 

• Additional references, but not P284 and P285, that were identified in the NDA-AK 

memorandum 

Status of Concern: The AKSR was revised to address most of the issues raised by EPA. 

However, the revised AKSR did not reference the documents that were included in the AK-NDA 

memorandum nor did it address the development of default isotopics, as requested. However, 

the revised NDA-AK memorandum provided this information, and upon examination the EPA 

inspection team determined that all required information was provided, in either the AKSR or the 

NDA-AK memorandum. EPA considers this concern to be closed and EPA also considers the 

NDA-AK memorandum a necessary part of this response. When ORNL-CCP revises the AKSR, 

the revised version should reference the documents included in the NDA-AK memorandum such 

that both documents contain similar information. Accordingly, AK and NDA personnel will be 

aware of important information pertinent to the development of default isotopics.

This inspection was limited to retrievably-stored debris waste. Because AK data for wastes 

outside this category (i.e., soils/gravel and solids and newly-generated debris) may be very 

different than the information examined, implementation of the AK process for wastes other than 

retrievably-stored debris is a T1 change. (See Table 1, which includes this as a T1 change.) 

Revisions of existing WSPFs, associated AK Summaries, AK accuracy, Radiological DRRs, 
28

including those prepared to address AK-measurement discrepancy, may all be pertinent. 

Providing notification to EPA upon completion of revisions of the existing WSPF and associated 

AKSR and/or generating new WSPFs, AK summaries, and/or documentation reports is required 

as this is a T2 change. Consistent with EPA’s authority under 40 CFR 194.24(h), the Agency 

may request this information if EPA deems it necessary to ensure continued compliance with 

EPA regulations. (See Table 1, which includes this as a T2 change.) 

Summary of AK Findings and Concerns

The EPA inspection team did not identify any findings related to AK during this inspection. 

EPA did identify the three concerns that are discussed above. Attachments C.7, C.8 and C.9 to 

this report provide copies of the EPA Inspection Issue Tracking Forms documenting these 

concerns. EPA considers these three concerns to have been adequately addressed, and there are 

no open issues with respect to this inspection.

Baseline Approval

EPA is proposing for approval the AK process for CH retrievably-stored TRU debris (S5000) 

that was evaluated during this baseline inspection as described in this report. Application of the 

AK process described in this report to wastes other than retrievably-stored CH TRU debris is a 

T1 change. (See Table 1, which includes this as a T1 change.) 

AK Tiers

Based on the inspection and the results discussed above, EPA proposes assigning the following 

tiers: 

T1 AK changes will require EPA review and approval prior to implementation and will apply to 

any new waste category not evaluated during the baseline inspection. These include the 

following: 

• Implementation of load management 

• Implementation of AK for wastes other than retrievably-stored debris (i.e., retrievablystored solids and soil/gravel and/or any newly-generated waste) 

ORNL-CCP must report and submit documentation on T1 changes when it is ready for EPA 

review. Upon initial review, EPA will inform ORNL-CCP and CBFO whether a site inspection 

is necessary. EPA may request additional information, choose to conduct a desktop review, 

and/or confer with ORNL-CCP personnel. Upon evaluation (with or without site inspection), 

EPA will issue an approval letter, and only upon receiving the EPA approval can ORNL-CCP 

dispose of the new waste at the WIPP or implement the activity deemed to be a T1 change. 

T2 AK changes do not require EPA approval before implementation but require that ORNLCCP provide notification to EPA upon completion of the following: 
29

• Notification to EPA upon completion of new versions or updates/substantive 

modifications to AK accuracy reports (prepared annually) 

• Notification to EPA upon completion of new versions or updates/substantive 

modifications to AK-NDA communications and memoranda for Waste Stream 

OR-NFAS-CH-HET and/or forthcoming waste streams 

• Notification to EPA upon completion of new versions or updates/substantive 

modifications to site AK procedures 

• Notification to EPA upon completion of new versions or updates/substantive 

modifications to all AK Summaries that describe wastes beyond the 144 containers 

described in this report and updates to the existing Waste Stream OR-NFS-CH-HET 

summary 

• Notification to EPA upon completion of new versions or updates/substantive 

modifications to Radiological DRRs (AK-AK and AK-NDA) pertinent to Waste Stream 

OR-NFS-CH-HET 

• Notification to EPA upon completion of new versions or updates/substantive 

modifications to completed Attachment 4 and Attachment 6 for Waste Stream 

OR-NFS-CH-HET 

• Notification to EPA upon completion of AK accuracy reports, new WSPFs, or revisions 

to existing WSPFs (and attachments) 

Following EPA approval, at the end of each fiscal quarter, ORNL-CCP must provide EPA with 

information on T2 changes. EPA will evaluate these changes and inform ORNL-CCP whether 

the changes raise any concerns and require a response or if ORNL-CCP can continue to 

implement those changes. 

8.2 Nondestructive Assay 

During this inspection, EPA inspected a single NDA system, the DWAS IPAN/SGS located at 

the Foster Wheeler Melton Valley TRU Project Facility on the ORR. This unit is operated under 

the ORNL-CCP WC program, which EPA evaluated for the first time during this baseline 

inspection. The DWAS IPAN/SGS has operated previously but had not performed any WIPP 

assays. 

Technical Evaluation 

Since EPA had not reviewed this NDA system previously, this inspection included the following 

aspects: 

 

• Design and technical capability of the DWAS IPAN/SGS hardware and software to 

perform the required analyses 

• Adequacy of the ORNL-CCP assay program’s documents and procedures 
30

• Knowledge and understanding of the ORNL-CCP personnel involved in the NDA 

program 

The checklist in Attachment A.2 and the documents listed below comprise the documents that 

EPA examined in assessing the DWAS IPAN/SGS during this inspection: 

• CCP-TP-166, CCP Drum Waste Assay System Imaging Passive/Active Neutron Operations, 

Revision 0, October 12, 2007 

• CCP-TP-167, CCP Drum Waste Assay System Imaging Passive/Active Neutron Calibration, 

Revision 0, October 12, 2007 

• CCP-TP-168, CCP Drum Waste Assay System Imaging Passive/Active Neutron/Segmented 

Gamma Scanner Data Generation Level Validation, Revision 0, October 18, 2007 

• CCP-TP-169, CCP Operating the Mobile Segmented Gamma Scanner, Revision 0, October 

12, 2007 

• CCP-TP-172, CCP Calibrating the Mobile Segmented Gamma Scanner, Revision 0, October 

12, 2007 

• BII-5183-CVR-001, Calibration and Validation Report DWAS IPAN, Revision 2, March 9, 

2006, and Revision 3, November 2007 

• MV-SGS0101-CAL-001, Segmented Gamma Scanner-01 (SGS-01-01) Calibration, 

Confirmation and Verification Report, Revision 0, November 6, 2007 and Revision 1, 

December 19, 2007 

• BII-TMU-5183-001, Total Measurement Uncertainty Report, DWAS IPAN, Revision 0, 

November 11, 2005 

• CI-SGS01-TMU, Total Measurement Uncertainty for the MCS Melton Valley Segmented 

Gamma Scanner, Revision 1, October 23, 2007 

• Canberra Memorandum, G. Westik to Alan Simpson, Calibration Verification Performed on 

October 17, 2007 for the MCS SGS Located at the Melton Valley Site, November 8, 2007 

• CCP-TP-005, Revision 18, CCP-AK-ORNL-001 NDA Memorandum, October 17, 2007, 

with Attachments & Isotopic Calculations for NFS Waste 

• CCP-TP-005, Revision 18, Reference U-016, J. Chapman, Graphical Workbook for 

Estimating Important Quantities of NFS Radioactive s Waste Constituents; March 1992 

• CCP-AK-ORNL-001, Central Characterization Project Acceptable Knowledge Summary 

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

National Laboratory, Waste Stream: OR-NFS-CH-HET, Revision 0, September 25, 2007 

• ORNL Program List of Qualified Individuals, October 18, 2007 

• Performance Demonstration Program for NDA of Drums System Registration Form 

• Radionuclide Library Listing Filename C:\GENIE2K\CAMFILES\STD WIPP.NLB 
31

• MV-SGS0101-CAL-001, Segmented Gamma Scanner-01 (SGS-01-01) Calibration, 

Confirmation and Verification Report, Revision 0, November 6, 2007 

• BII-TMU-5183-001, Total Measurement Uncertainty Report, DWAS IPAN, Revision 0, 

November 11, 2005 

• CI-SGS01-TMU, Total Measurement Uncertainty for the MCS Melton Valley Segmented 

Gamma Scanner, Revision 1, October 23, 2007 

• BII-5109-TN00-003, MCNP Calculations of the Mass Correction Factor from Neutron 

Absorption in the PDP Stainless Steel Source Can with the PDP Aluminum Rack for Various 

Matrices and Source Positions, BNFL Instruments, Los Alamos, New Mexico 

• ORNL Program List of Qualified Individuals, October 18, 2007 

• NDA BDR No. OR-DWAS-001 

• NDA BDR No. OR-DWAS-002 

• NDA BDR No. OR-DWAS-003 

(1) The design and operational range of the DWAS IPAN/SGS were assessed and were found to 

be adequate. 

The DWAS IPAN/SGS is a multimode NDA system housed in Building 7880-I of the TWPC 

and operated by ORNL-CCP for gamma and neutron-based assays of CH retrievably-stored 

debris (S5000) wastes in 55-gallon drums. The SGS component of the DWAS consists of two 

detectors: a high-resolution coaxial germanium detector that measures photon-emitting 

radionuclides in nine vertical segments to provide quantitative gamma data, and a fixed-position 

low-energy germanium (LEGe) detector fitted with a cadmium filter on the detector face that is 

used to provide isotopic (relative) values. The coaxial detector has two operational modes, 

depending on a container’s specific attributes: a segmented efficiency mode, also called a 

summed spectrum or density-based mode, and a segmented transmission-corrected mode, also 

called a sum of segments or transmission-corrected mode. Gamma spectra from the LEGe are 

used in conjunction with either multigroup analysis (MGA) or FRAM6

 software packages to 

determine the isotopic distribution of 238Pu, 239Pu, 240Pu, 241Pu, and 242Pu, along with 241Am, 235U 

and 237Np. Other radionuclides are quantified directly using Genie 2000 and NDA 2000 

software. The LEGe isotopic determination is performed simultaneously with the coaxial-based 

quantitative assay, and spectra from both detectors are acquired and analyzed using Genie 2000 

and NDA 2000 software. The coaxial detector’s sum of segments mode is appropriate for most 

of the waste matrices expected at ORNL-CCP. The summed spectrum mode is better suited for 

containers with low plutonium content and bulk density up to 0.72 g/cm3

. 

The IPAN component of the DWAS consists of the following: 

 

6

 FRAM is an abbreviation for an isotopic identification computer-based program properly called Fixed energy 

Response function Analysis with Multiple efficiency. 
32

• A shielded assay chamber that surrounds the waste container on all four sides, top, and 

bottom, containing a turntable to rotate the drum during assay; one side of the enclosure 

contains a 14 MeV neutron generator located inside a moderator assembly 

• Shielded detector packages comprising a number of helium-3 (3He) neutron detectors 

embedded within blocks of polyethylene 

• Individual electronic counting units consisting of preamplifiers, amplifiers, 

discriminators, and other supporting hardware 

The system operates in both active and passive modes and provides values for 239Pu effective 

mass (239PuEFF) and 240Pu effective mass (240PuEFF), respectively. The IPAN is currently 

configured to measure one of these two quantities depending on the nuclear material (plutonium) 

loading of a specific container. Values for other WIPP-tracked radionuclides are quantified 

based on measured values (gamma-based isotopic distributions) or known or established 

relationships (AK-based isotopics) in conjunction with the measured neutron-based quantity, or 

by using computational or correlation techniques (e.g., 

242Pu). The IPAN component uses active 

and passive mode determinations to provide two independent measures of the plutonium content 

of a waste container. The active mode result is expressed in terms of 239PuEFF, and the passive 

mode result is expressed in terms of 240PuEFF. The system makes a selection to use the active or 

passive results based primarily on the number of measured coincidence neutrons and the 

magnitude of the moderator and/or absorber/moderator correction factors (i.e., the moderator 

(MOD) and/or absorber/moderator (ABSMOD) indices) for passive and active modes, 

respectively. 

Previous EPA inspection reports present a detailed technical description of 239PuEFF and 240PuEFF

masses, and IPAN ABS, MOD and ABSMOD indices (see EPA Docket No. A-98-49, II-A4-65). 

The IPAN is calibrated for assays from the system‘s active mode lower limit of detection (LLD) 

to a maximum of 14.710 g of 239PuEFF, and the system’s passive mode LLD to 2.050 g of 

240PuEFF. The active mode has been confirmed at 10.494 g of weapons-grade plutonium (WG 

Pu), approximately 9.806 g 239PuEFF, and the passive mode has been confirmed at 32.076 g of 

WG Pu, approximately 1.89 g 240PuEFF. Confirmations used WG Pu sources as described in BII5183-CVR-001, Revision 2, March 9, 2006. The active mode calibration is valid for waste 

matrices with ABSMOD indices between 22.251 and 276.800. The passive mode calibration is 

valid for waste matrices with MOD indices between 1.045 and 17.572. There are no issues 

relative to the design or operational range of the IPAN component of the ORNL-CCP DWAS 

system from this inspection. 

The use of new, unapproved NDA equipment by ORNL-CCP or physical modifications to the 

DWAS IPAN/SGS unit observed during this inspection is a T1 change. (See Table 1 where this 

is included as a T1 change.) 

(2) System calibration and calibration confirmation of the DWAS SGS/IPAN NDA system had 

been performed and documented as required, following revision of one ORNL-CCP report. 

Two reports document the calibration of the DWAS SGS/IPAN: the SGS component is 

described in MV-SGS0101-CAL-001, Segmented Gamma Scanner-01 (SGS-01-01) Calibration,
33

Confirmation and Verification Report, Revision 0, November 6, 2007, and the neutron 

component is described in BII-5183-CVR-001. 

Gamma Calibration: Calibration of the SGS component was performed prior to the system’s use 

by ORNL-CCP. There are four separate aspects of the gamma calibration: 

• Energy calibration was performed using a 152Eu source in 2005, including a term for 

resolution (full width at half maximum) for the coaxial detector, and for the LEGe 

detector using mixed gamma line sources; the coaxial calibration is absolute 

(i.e., expressed as observed counts per actual nuclear disintegration of the calibration 

source) while the LEGe calibration is relative. 

• Reference peak calibration was performed in 2005 using a pulser to enable dead-time 

corrections to the coaxial detector. 

• Transmission source calibration was performed in 2005 using a 152Eu source to enable 

transmission corrections. 

• Matrix calibration was initially performed in 1996 and subsequently updated with 

several additional data to produce the composite plot shown on page 43 of MVSGS0101-CAL-001 with a matrix density range of 0.0 to 0.72 g/cm3

. 

The SGS component of the calibration was technically adequate, but the report MV-SGS0101-

CAL-001 lacked several important technical details. EPA discussed this concern with ORNLCCP NDA personnel and included it on an EPA Inspection Issue Tracking Form (see Attachment 

C.2 of this report for a copy of this form). The issue is discussed below. 

EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-CH-NDA-07-002CR, Final: 

The SGS calibration report MV-SGS0101-CAL-01, Revision 0, did not adequately document 

calibration of this NDA system. In general, the report’s overall quality was lacking with respect 

to organization and attention to technical details. Examples include the following: 

• SGS-01, Calibration Qualification Summary, does not state the system’s operating range 

with respect to matrix (sample density), nor does the section on matrix drums (Section 3) 

adequately document the system’s capabilities in this area. 

• SGS-01 does not list the use of default (AK) isotopics as an option (19 of the 20 drums 

assayed to date have used AK isotopics). 

• The document is unclear regarding whether this system will be used to sort TRU/nonTRU wastes in accordance with the 100 nCi/g criterion. 

• Descriptions of the system’s calibration of record do not accurately document what 

happened. 

Resolution: ORNL-CCP personnel provided an electronic copy of Revision 1of MV-SGS0101-

CAL-01, dated December 19, 2007. ORNL-CCP modified the revised report to address the 

items listed above. 
34

Status of Concern: ORNL-CCP’s Revision 1 of MV-SGS0101-CAL-01, dated December 19, 

2007, adequately addressed EPA’s concern, and this concern is closed. 

Gamma Calibration Confirmation: Calibration confirmation of the SGS component of the 

DWAS was performed using sources other than the 152Eu/137Cs/241Am sources used for 

calibration, as required by DOE/WIPP-02-3122. ORNL-CCP NDA personnel provided 

objective evidence of the appropriate pedigree for all WG Pu sources that is documented in MVSGS0101-CAL-01. The calibration sources consisted of WG Pu sources in a variety of gram 

values that were combined to produce the following gram values: 0.3 g, 10.5 g, and 32.0 g. The 

system passed all WAC calibration confirmation criteria. There are no technical issues with the 

calibration and calibration confirmation of the SGS component of the ORNL-CCP DWAS NDA 

system. 

Neutron Calibration: The IPAN calibration was completely redone upon the system’s 

implementation at ORNL-CCP in July 2005. Active mode calibrations were performed using a 

depleted uranium (DU) source, and the passive mode calibration was performed using a 252Cf 

source. Both sources have the appropriate pedigree, as documented in BII-5183-CVR-001, and 

an effective mass value for each was developed and used in the IPAN calibration. ABS, MOD 

and ABSMOD indices and a matrix correction factor for each mode were developed using six 

surrogate matrix drums with the DU and/or 252Cf sources assayed in nine positions each. Based 

on the MOD and ABSMOD indices developed, the IPAN’s operational range adequately covers 

the breadth of waste matrices and activity loading anticipated at ORNL-CCP. 

Neutron Calibration Confirmation: Calibration confirmation of the IPAN component of the 

DWAS was performed using sources other than the DU and 252Cf sources used for calibration, as 

required by DOE/WIPP-02-3122. ORNL-CCP NDA personnel provided objective evidence of 

the appropriate pedigree for all WG Pu sources that is documented in BII-5183-CVR-001. The 

calibration sources consisted of WG Pu sources in a variety of gram values that were combined 

to produce the following gram values: 0.3 g (active mode), 10.5 g (active and passive modes), 

and 32.0 g (active and passive modes). The system passed all WAC calibration confirmation 

criteria except for the 32.0 g standard in the active mode. This was expected due to selfshielding that is a function of the encapsulated source design and application within the 

Performance Demonstration Program (PDP) stainless steel containers, an effect that is 

documented and which have been seen in previous inspections (see BII-5109-TN00-003). The 

upper limit of the IPAN’s range was set at 14.710 g 239PuEFF, as discussed above. 

There are no technical issues with the calibration and calibration confirmation of the SGS or 

IPAN components of the ORNL-CCP DWAS system. Extension of or changes to the calibrated 

range for either the SGS or IPAN component of the DWAS IPAN/SGS system is a T1 change. 

(See Table 1, which includes this as a T1 change.) Notification to EPA upon completion of 

changes to software for the DWAS IPAN/SGS system, its SGS or IPAN operating range(s), and 

site procedures that address the system’s calibration and/or operation that require CBFO 

approval is a T2 change. (See Table 1, which includes this as a T2 change.) 
35

(3) The total measurement uncertainty (TMU) of assays performed on the DWAS IPAN/SGS 

NDA system had been determined and documented, as required. 

The determination of the TMU of assays performed on the DWAS IPAN/SGS system is 

addressed in two reports; CI-SGS01-TMU, Total Measurement Uncertainty for the MCS Melton 

Valley Segmented Gamma Scanner, Revision 1, October 23, 2007, for the SGS component; and 

BII-TMU-5183-001, Total Measurement Uncertainty Report, DWAS IPAN, Revision 0, 

November 11, 2005, for the passive and active neutron components. The components of 

uncertainty included in the TMU determination for the SGS of the DWAS included calibration 

source uncertainties (including drum fill height), counting statistics, self-absorption effects, 

matrix nonhomogeneities, nonuniform source distributions, and isotopic measurement 

uncertainties, end effects, and attenuation. The components of uncertainty included in the TMU 

determination for the IPAN component of the DWAS, including matrix uncertainty, source 

distribution, gamma and neutron interferences (α, n), calibration, self-shielding, and isotopics. 

All aspects of TMU for both the SGS and passive and active modes of the IPAN were 

technically adequate and appropriately documented. There are no issues with the determination 

and documentation of TMU for the DWAS IPAN/SGS system. 

(4) The LLD, including the minimum detectable concentration of the DWAS IPAN/SGS system, 

had been determined and documented, following revision of one ORNL-CCP report. 

The LLD definition used by ORNL-CCP is consistent with that specified in DOE/WIPP-02-3122 

(CH WAC). Specifically, the LLD is defined as “that level of radioactivity which, if present, 

yields a measured value greater than the critical level with a 95% probability, where the critical 

level is defined as that value which measurements of the background will exceed with 5% 

probability.” The LLD of any given NDA measurement is a function of the type of 

measurement, the measurement (data acquisition) time, the properties of the waste matrix being 

assayed, and the environmental background. For this reason, the LLD will vary from drum to 

drum and may even vary between measurements of the same drum. 

The DWAS IPAN/SGS system reports an LLD for each of the 10 WIPP-tracked radionuclides 

for the gamma (SGS) and both passive and active neutron (IPAN) operational modes. Only 

measured values that exceed the reported LLD for that measurement will be reported and used in 

calculations of derived quantities, such as total TRU alpha activity and TRU alpha activity 

concentration. The LLD values for the SGS component of the DWAS IPAN/SGS system are 

documented in MV-SGS0101-CAL-001, Segmented Gamma Scanner-01 (SGS-01-01) 

Calibration, Confirmation and Verification Report, Revision 0, November 6, 2007. This 

document contains empirically determined LLDs for the sum of segments and summed spectrum 

modes, Tables 5 and 6, respectively. Table 6 lists reporting the sum of segments reporting 

thresholds for radionuclides that are not directly measured, specifically 238Pu, 240Pu, 242Pu, and 

90Sr. Based on Section 6.0 of MV-SGS0101-CAL-001, a unique reporting threshold for 234U is 

not provided based on ORNL-CCP’s contention that it is not technically feasible to determine a 

unique reporting threshold for 234U. Section 5.0 of MV-SGS0101-CAL-001 also states that it is 

possible to use the SGS to quantify wastes at levels below 100 nCi/g (i.e., the measurement 

criterion for TRU wastes). However, ORNL-CCP personnel stated that the SGS will not be used 

to discriminate TRU and non-TRU waste criterion. 
36

The LLD values for the passive and active modes of the IPAN are documented in BII-5183-

CVR-001. The active mode LLD has been determined to be less than 100 nCi/g over this 

mode’s entire calibration (ABSMOD) range. The passive mode LLD is expressed in terms of 

grams of 240PuEFF, which is technically appropriate since this mode is used for higher gram value 

assays such that there is no expectation that the passive mode would be used to sort wastes at the 

100 nCi/g TRU criterion. BII-5183-CVR-001 did not address the LLD determination for all of 

the 10 WIPP-tracked radionuclides. EPA discussed this concern with ORNL-CCP NDA 

personnel and included it on an EPA Inspection Issue Tracking Form (see Attachment C.6 of this 

report for a copy of this form). This concern is discussed below. 

EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-CH-NDA-07-006CR, Final: 

The calibration report for the DWAS IPAN NDA system BII-5183-CVR-001, Revision 2, 

Section 5.4, Table 12, “LLD Implementation,” does not address the LLD determination for two 

of the 10 WIPP-tracked radionuclides, 234U and 90Sr. The report is silent regarding the LLD 

determination for these two radionuclides. The SGS calibration report appropriately addresses 

the LLD determinations for 234U and 90Sr. 

Resolution: ORNL-CCP personnel provided an electronic copy of Revision 3 of BII-5183-

CVR-001, dated November 2007. Section 5.4, page 24, was modified to address the LLD 

determination for both 234U and 90Sr. Table 12 was not changed, but text was added below the 

table that explained the exclusion of these radionuclides from Table 12 and presented the 

approaches used for both radionuclides. 

Status of Concern: ORNL-CCP’s revision adequately addressed EPA’s concern, and this 

concern is closed. 

There are no issues with the determination and documentation of the LLD for the DWAS 

IPAN/SGS system. 

(5) ORNL-CCP had registered the DWAS IPAN/SGS to participate in the CBFO-sponsored 

PDP, as required. 

The DWAS IPAN/SGS was registered to participate in Cycle 14B of the CBFO-sponsored NDA 

PDP. This cycle had a start date of October 22, 2007, and data for the DWAS IPAN/SGS will be 

provided upon completion of the assays and data evaluation. Objective evidence that 

documented ORNL-CCP’s PDP participation was provided to and reviewed by the EPA 

inspection team. 

(6) EPA replicate testing of the DWAS IPAN/SGS unit was performed and evaluated, and was 

found to comply with the criteria for the EPA Replicate Testing Protocol. 

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

an independent means to verify that the DWAS IPAN/SGS unit can provide reproducible results 

for the determination of the quantity of 10 WIPP-tracked radionuclides (241Am, 137Cs, 238Pu, 
37

239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U, and 238U) and the TRU alpha concentration.7

 This is 

accomplished by reassaying drums previously measured on the same system in order to 

demonstrate the system’s ability to do the following: 

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

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

reported TMU. 

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

comparing the results of the replicate measurement(s) to the original reported values. 

As part of the inspection to evaluate the DWAS IPAN/SGS unit, EPA requested that the DWAS 

IPAN/SGS unit reassay three drums that EPA randomly selected from a list of previously 

assayed drums. EPA chose containers X10C0501112, X10C0505990, and X10C0501270. All 

three drums were reassayed on the DWAS IPAN/SGS unit five times, and the data for the five 

replicates and the original assay were analyzed using two statistical tests, a chi-squared (χ2

) test 

and a t-test. The EPA inspection team observed operation of the DWAS IPAN/SGS unit as it 

performed the assay of container X10C0501270. Attachments B.1–B.6 include data and results 

of the statistical analysis for all three assays. 

The t-test for all three containers assayed on the DWAS IPAN/SGS did not show any statistically 

significant differences between the original measurement assay values and the average of the 

five replicate measurements for the activities of any of the target radionuclides or the TRU alpha 

activity concentration. The χ2

 test for all containers assayed on the DWAS IPAN/SGS showed 

that the observed variances in the replicate measurements are less than or equal to the reported 

uncertainties within the statistical limits of the test. There are no technical issues associated with 

replicate testing of the DWAS IPAN/SGS. 

Summary of NDA Findings and Concerns

The EPA inspection team did not identify any findings related to NDA during this inspection. 

EPA did identify two concerns, one related to the SGS calibration report, and one related to LLD 

determination of the DWAS IPAN system, both of which are discussed in the preceding section. 

Attachments C.2 and C.6 of this report provide the two EPA Inspection Issue Tracking Forms 

documenting these issues. EPA considers both concerns to have been adequately addressed, and 

there are no open concerns related to NDA at ORNL-CCP resulting from this inspection. 

Baseline Approval

The baseline conditions that the EPA inspection team evaluated during this inspection consist of 

the DWAS IPAN/SGS NDA system currently located in Building 7880-I of the TWPC for 

gamma and neutron-based assays of CH retrievably-stored debris (S5000) wastes in 55-gallon 

drums, as described above and detailed in the DWAS IPAN/SGS Checklist (Attachment A.2 to 

 

7

 Revision 2 of the EPA Replicate Testing Protocol provides the details of the replicate testing assay protocol 

and data evaluation. 
38

this report), over the system’s operational ranges for gamma and neutron-based assays. The 

approved operational ranges for the DWAS IPAN/SGS NDA are as follows: 

• For gamma assays using the SGS component, the operational range is from the system’s 

LLD to 45 g total plutonium in terms of activity; and from 0 to 0.72 g/cm3

 in terms of 

waste matrix. 

• For passive mode neutron assays, the operational range is from the system’s passive 

mode LLD to 2.050 g 240PuEFF in terms of activity; and a MOD index range from 1.045 to 

17.572 in terms of matrix. 

• For active mode neutron assays, the operational range is the system’s active mode LLD 

to 14.710 g 239PuEFF in terms of activity, and an ABSMOD index range from 22.251 to 

176.800 in terms of matrix. 

EPA is approving the DWAS IPAN/SGS NDA system, along with its range of applicability for 

disintegration rate (activity) and matrix and any limitations, as described in this report and 

detailed in the DWAS IPAN/SGS checklist (Attachment A.2). This is discussed in the following 

section. 

NDA Tiers

Based on the inspection and the results discussed above, EPA assigns the following tiers: 

T1 NDA changes require EPA review and approval prior to implementation. They include the 

following: 

• New NDA equipment other than the DWAS IPAN/SGS system8

• Physical modifications to the DWAS IPAN/SGS NDA system approved9

 

• Extension or changes of the approved calibration range(s) for the DWAS IPAN/SGS 

system 

The last bulleted item above refers to the extension of a system’s approved calibration range with 

respect to determination of the disintegration rate (activity) or physical characteristics (matrix) of

any of the two NDA systems approved as a result of this inspection. An EPA technical 

inspection involves the evaluation of several characteristics of a measurement system. A key 

characteristic is the range of conditions for which the instrument is capable of producing 

technically defensible data with respect to the following two aspects: 

 

8

 New NDA equipment refers to a system or component not previously evaluated by EPA at ORNL-CCP. 

Specifically, this is defined as a physically distinct or different system or apparatus; an assay system that is reported 

to be the equivalent of or identical to a previously approved system, but which EPA has not formally inspected and 

approved, is a new system and EPA must approve it prior to its implementation to characterize WIPP wastes. 

9

 Physical modification to the DWAS IPAN/SGS system includes all changes and/or modifications to this 

system that have the potential to affect the quality of NDA data used for the purposes of WC and/or waste isolation. 

This does not include minor changes or safety-related changes (e.g., addition of handrails) that do not have the 

potential to affect WC data. 
39

• Activity—the nuclear disintegration rate of specific radiation types (neutron or gamma), 

typically special nuclear material or TRU radionuclides; units of activity and mass are 

interchangeable 

• Physical characteristics—the physical attributes of waste matrices as they relate to a 

radiometric system (i.e., how the matrix’s physical properties interact with the radiations 

that originate within the sample and affect the system’s ability to detect them); examples 

include attenuation of photons (gamma) and moderation and absorption of neutrons 

During the inspection, the system’s technical capabilities being evaluated represent the 

conditions observed, and they define the operational envelope in which WIPP measurements will 

occur. Changes to a system’s calibrated range with respect to disintegration rate and/or matrix 

may represent an essentially different set of conditions from those evaluated during the 

inspection. For this reason, a change to a system’s calibrated range is considered a T1 change. 

A system’s operating range is generally, but not always, a subset of a calibration range; that is, 

systems that are calibrated to make valid neutron measurements from 0.36 g to 30.1 g 240PuEFF

may operate in a subset of this range. This typically occurs when a system is calibrated for 

material control and accountability (MC&A) measurements as well as for WIPP assays, as is the 

case with many NDA systems used for TRU assays. Provided the system’s calibrated range is 

valid, a site can designate a different operating range(s) within the calibrated range as a T2 

change (i.e., a subset of the calibrated range). 

Similarly, for physical characteristics, NDA systems are often calibrated with respect to a range 

of sample attributes—for example, a matrix density range upper limit of 0.72 g/cm3 for the 

DWAS SGS component or an ABSMOD index range of 22.251 to 276.800 for the active neutron 

mode of the DWAS IPAN, discussed earlier in this report. This range may include materials that 

are commonly referred to using terms such as “debris (S5000),” which is within the calibrated 

density range and would be expected to be within the ABSMOD range. Actual waste assays 

may be restricted to a portion or subset of this range for a variety of technical and/or 

administrative reasons. Changing the calibrated range by extending the density range beyond 

0.72 g/cm3

 for the DWAS SGS unit, the MOD range beyond 1.045 to 17.572, or the ABSMOD 

range beyond 22.251 to 276.800 for the DWAS IPAN unit is a T1 change. Provided the original 

approved density range is valid, changing the operational range(s) of an approved NDA 

system—that is, decreasing it relative to the originally approved range—is a T2 change, as 

discussed below. 

ORNL-CCP will report and submit documentation for T1 changes when it is ready for EPA 

review. In the case of the first two T1 NDA changes listed above, CBFO should assume that an 

EPA inspection is likely. In the case of the last T1 NDA change, EPA will inform ORNL-CCP 

and CBFO whether a site inspection is necessary. EPA may request additional information, 

choose to conduct a desktop review, and/or confer with ORNL-CCP NDA personnel. Upon 

evaluation (with or without site inspection), EPA will issue an approval letter. Only upon 

receiving the EPA approval can ORNL-CCP continue to use the equipment affected by the 

change. 
40

T2 NDA changes do not require prior EPA approval but do require ORNL-CCP to notify EPA 

upon implementation of such changes and to submit a brief description of the changes. These 

include the following: 

• Changes to software for the DWAS IPAN/SGS system 

• Changes to the approved operating range(s) for either the SGS or IPAN operating 

range(s) (see discussion above) 

• Changes to procedures that address the DWAS IPAN/SGS system’s calibration and/or 

operation that require CBFO approval 

Examples of changes to software would include the following: 

• Changing a system’s operating system (e.g., first use of NDA 2000, MGA, or PCFRAM) 

• Identification of a systematic problem with a software package and subsequent 

modifications to address the problem, (e.g., use of an incorrect value for a radionuclide’s 

transition probability or branching ratio in the data reduction software) 

• Introduction of a new version of an existing software package beyond what is in currently 

use 

Regarding changes to the approved operating ranges, reducing a system’s operating range 

because of performance-related problems or equipment failure would be a T2 change. For 

example, if the DWAS failed to pass a PDP cycle for a specific matrix or activity range and 

ORNL-CCP or CBFO formally restricted its use as a result of those, this would be a T2 change. 

Any changes to the WC activities from the date of the baseline inspection must be reported to 

and approved by EPA according to Table 1. Following EPA approval, ORNL-CCP will provide 

EPA with information concerning T2 changes at the end of each fiscal quarter. EPA will 

evaluate these changes and communicate with ORNL-CCP as to whether the changes raise any 

concerns and require an ORNL-CCP response, or whether ORNL-CCP can continue to 

implement the changes. Consistent with EPA’s authority under 40 CFR 194.24(h), the agency 

may request information relative to these changes if EPA deems the information is necessary to 

ensure continued compliance with EPA regulations. 

8.3 Real-Time Radiography 

WC Element Description

As part of the inspection of the RTR activities, the team reviewed the elements of the RTR 

process listed below. Emphasis was placed on overall procedural technical adequacy and 

implementation and the identification of WMPs and prohibited items: 

• Documentation of RTR activities through use of an approved procedure 

• Proper execution of RTR activities 

• Management oversight and independent review of RTR activities 
41

• Training of RTR personnel 

The RTR facility uses radiography to help determine the following aspects of TRU WC: 

• Types and amounts of WMPs 

• Presence or absence of prohibited items 

• Capability demonstration testing for operators on the RTR system using specifically 

placed items 

ORNL-CCP has one RTR unit that can only be used to examine 55-gallon drums. Consequently, 

any standard waste boxes (SWBs) or other larger containers in Waste Stream OR-NFS-CH-HET 

must be repackaged into drums prior to RTR examination. 

Documents Reviewed

The checklist in Attachment A.3 in conjunction with the listing below provides the documents 

that were examined to evaluate the ORNL-CCP RTR operations: 

• CCP-TP-028, CCP Radiographic Test and Training Drum Requirements, Revision 3, 

January 19, 2006 

• Attachment 1, CCP NDE Test Drum Inventory Sheet for Training Drums ORNL-NDE-Test001 and ORNL-NDE-Test-002, to CCP-TP-028, CCP Radiographic Test and Training Drum 

Requirements, Revision 3, January 19, 2006 

• CCP-QP-002, CCP Training and Qualification Plan, Revision 25, May 8, 2007 

• CCP-TP-053, CCP Standard Real-Time Radiography (RTR) Inspection Procedure, 

Revision 5, November16, 2006 

• CCP-TP-001, CCP Project Level Data Validation and Verification, Revision 17, 

September 24, 2007 

• CCP-PO-001, CCP Transuranic Waste Characterization Quality Assurance Project Plan, 

Revision 15, August 10, 2007 

• CCP-PO-002, CCP Transuranic Waste Certification Plan, Revision 19, May 22, 2007 

A complete listing of all objective evidence that was evaluated during the inspection is provided 

below: 

• RTR BDRs: OR-RTR6-001, OR-RTR6-003, OR-RTR6-007 (S5000 debris waste) 

• Audio/visual recording of RTR events for drums from the above BDRs 

• Written record of the initial capability demonstration for drum RTR operators, September 

2007 

• Capability demonstration audio/visual recordings for selected operators 
42

• CCP-TP-053, Attachment 1, CCP RTR Measurement Control Reports, for all seven 

completed RTR BDRs 

• NCR-ORNL-0101-07 and NCR-ORNL-0500-07

• CCP Standing Order CCP-SO-011, Revision 4, November 1, 2007 

• CCP/ORNL 2007 NCR Log 

• CCP-TP-001, Attachment 2, CCP SPM Radiography Project Level Validation Checklist and 

Summary for BDRs OR-RTR6-001, OR-RTR6-003, OR-RTR6-007 

• CCP-TP-053, Attachment 2, CCP Radiography Data Sheet, for demonstration drum 

X10C0501308 

Technical Evaluation

During the inspection, the following technical elements of the RTR process were investigated: 

(1) Overall procedural technical adequacy and implementation were investigated and were found 

to be acceptable. 

EPA reviewed the RTR procedure, CCP-TP-053, and determined that it was technically 

adequate. The procedure contained specific information on performing nonintrusive 

radiography, including operational setup and check out, identification of prohibited items, 

assignment of WMPs and estimation of weights and volumes, confirmation of WMCs, input of 

data, and issuance of NCRs. Technical and project level review of radiography results is 

performed in accordance with procedures CCP-TP-053, Attachment 3 and CCP-TP-001, 

Attachment 2. Standing Order CCP-SO-011 requires that the Independent Technical Reviewer 

(ITR) perform a review on 100% of the audio/visual recording for the drums processed. EPA 

verified that each BDR contained an ITR and SPM checklist. During the onsite inspection, EPA 

observed the RTR event for X10C0501308, a S5000 debris drum. EPA also reviewed the 

previously generated written BDR and the audio/visual recordings for selected drums and 

determined that procedure CCP-TP-053 was implemented as written. 

Notification to EPA upon the implementation of new RTR equipment or substantive changes to 

the approved RTR equipment is a T2 change. (See Table 1, which includes this as a T2 change.) 

(2) Characterization of WMPs and prohibited items was investigated and was found to be 

adequate following modifications to ORNL-CCP documents. 

The RTR procedure requires that the radiography audio/visual recording equipment be verified at 

the beginning of every shift. Verification is achieved by viewing a lines-pair resolution test 

gauge and ensuring that the visible image meets the minimum requirement. Adherence to 

verification requirements was confirmed by interviewing RTR operators; reviewing 

measurement control reports for BDRs OR-RTR6-001 through OR-RTR6-007; and reviewing 

video/audio recordings for BDRs OR-RTR6-001, OR-RTR6-003, and OR-RTR6-007. The RTR 

operators demonstrating the RTR procedure had a hard copy of the waste stream description for 

the waste stream being processed available for review. The RTR operators were able to explain 
43

how they answered questions on the RTR data sheet with regard to waste stream description and 

WMC. 

For each container undergoing examination, an audio/video recording of the RTR event is made. 

During the onsite inspection, EPA observed the RTR event for drum X10C0501308, a S5000 

debris waste container. The first notations made on the audio/video recording by the operator 

were the operator’s name, the drum number, and the date and time. The examination began at 

the top drum lid, where the operator identified the presence or absence of a drum liner. The 

drum was rotated through 360 degrees, so that all objects were viewed from all sides. The 

operator then moved down the drum in set increments, zooming in and out and increasing or 

decreasing the scan energy to compensate for varying densities in the material examined. During 

the RTR examination, the operator also jogged the drum to determine the presence of free 

liquids. “Jogging” the drum is abruptly changing the direction of the rotation to make the drum’s 

contents move, a useful technique to cause free liquids within the drum to splash, thereby 

enabling the RTR operator to acknowledge their presence. 

The RTR operator identified WMPs associated with the container being examined, and a second 

RTR operator electronically entered the data into an RTR data sheet. At the end of the 

examination, the operator estimated the weight of each recorded WMP and ensured that the total 

WMP weight matched the weight value obtained by actually weighing the container. Most 

weight values that were recorded were estimates, although Table 3 of the RTR procedure 

contains historically derived weights for some common items. The absence of prohibited items 

was recorded on the data sheet. EPA further verified this by reviewing previously recorded 

written and audio/visual records. The operator recording the RTR data opened templates for 

Attachment 1, CCP RTR Measurement Control Report, and Attachment 2, CCP Radiography 

Data Sheet, during the demonstration. Both of the templates had fields already completed; using 

the Reset function for Attachment 2 did not clear the existing information from these fields. The 

EPA inspection team member discussed this with ORNL-CCP RTR personnel, and EPA 

included it on an EPA Inspection Issue Tracking Form (see Attachment C.1 of this report for a 

copy of this form). This concern is discussed below. 

EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-CH-RTR-001CR: When the 

templates used to complete Attachments 1 and 2 of CCP-TP-053 were opened during the onsite 

RTR demonstration, answers were already present on the attachments for some of the questions. 

Examples include the following: 

• Attachment 1 had check marks indicating “SAT” (satisfactory) for the questions for 

“Video/Audio Recorded Media System Check” and “Image Test Pattern Test.” 

• The entries indicating the number of lines-pair/centimeter had already been filled in to 

indicate “25.” 

• Section 3 of Attachment 2 contained entries for “horsetail” and “plastic,” and the 

question “NCR(s) associated with the container?” was checked “No.” 

Even when the form was reset, the check marks did not disappear. 
44

Resolution: ORNL-CCP cleared Attachments 1 and 2 of all filled-in information, and these 

attachments were formatted so that they do not contain any information filled in upon opening. 

The ORNL-CCP resident Quality Assurance Engineer verified these actions on November 14, 

2007. ORNL-CCP procedure CCP-PO-005, Conduct of Operations, was revised to provide 

specific guidance for the development and use of fillable forms. ORNL-CCP training in lessons 

learned was developed and distributed to all ORNL-CCP operators, Vendor Project Managers, 

SPMs, and Waste Certification Officials (WCOs). 

Status of Concern: The response is complete and adequate. EPA accepts the resolution and 

considers the issue closed.

Notification to EPA upon the completion of changes to CCP-TP-001, CCP-TP-028, CCP-TP-053 

or other ORNL-CCP RTR procedures that require CBFO approval is a T2 change. (See Table 1, 

which includes this as a T2 change.) 

(3) Documentation of radiography activities was examined and was found to be adequate. 

Simultaneous audio descriptions and video recordings are made as the waste is examined. These 

data are also recorded on the electronic data sheets, and hard copies of the examinations are 

provided in the BDRs. The EPA inspector verified this during the onsite inspection by observing 

the examination of one waste container (X10C0501308 from RTR BRD OR-RTR6-0013) and 

further verified it by reviewing selected RTR BDRs in conjunction with the following 

audio/visual recordings: 

• OR-RTR6-001, drum X10C0501101 (S5000) 

• OR-RTR6-003, drum X10C0501391 (S5000) 

• OR-RTR6-007, drum X10C0501179 (S5000) 

In all cases, the information on the audio/visual recording matched the written RTR record in the 

BDR. 

(4) Documentation of radiography procedures was assessed and was found to be adequate. 

Radiography procedures are well defined, and the documents are controlled. During the 

inspection, the EPA inspection tem reviewed the adequacy and implementation of all current 

radiography-related procedures. Quality control (QC) examinations were performed as required 

by the procedure. In BDR OR-RTR6-001, an independent observation was performed on 

container X10C0501146, and a replicate scan was performed on container X10C0501144. In 

BDR OR-RTR6-003, an independent observation was performed on container X10C0505973, 

and a replicate scan was performed on container X10C0506048. In BDR OR-RTR6-007, an 

independent observation was performed on container X10C0501407, and a replicate scan was 

performed on container X10C0501270. As required, different operators performed the analyses 

of the original and the QC replicate samples. Reconciliation of the QC results is only required if 

there is a difference between operators with regard to the WMC, liquids, and compressed gases, 

as specified in CCP-TP-053, Sections 4.5.3 and 4.6.3. EPA discussed this with RTR personnel 
45

and included it on an EPA Inspection Issue Tracking Form (see Attachment C.5 of this report for 

a copy of this form). This concern is discussed below. 

EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-CH-RTR-005C: The replicate 

and original scans that were performed in batch OR-RTR6-0003, container X10C0506048, had a 

15% difference in the percent fill factor as well as minor differences in the recorded WMP 

weights. CCP-TP-053 only requires reconciliation of discrepancies when “identification of the 

WMC, liquids in excess of TSDF-WAC limits and compressed gases differ between the two 

operators.” The same situation applies to the independent and original observations. While this 

practice complies with the requirements of CCP-TP-053, Sections 4.5.3 and 4.6.3, it does not 

satisfy EPA’s requirement for a system of controls demonstrating consistent and accurate 

identification of waste attributes. A tolerance needs to be defined for waste attributes. 

Resolution: EPA did not require a response to this concern. 

Status of Concern: This issue is closed.

NCRs are generated as needed. For example, NCR-ORNL-0101-07 was initiated for drum 

X10C0501150 because the audio track was missing on the DVD that was generated during the 

container’s examination. NCR-ORNL-0500-07 was initiated for container X10C0501123 

because the container’s waste did not match the waste stream description. 

The BDRs that EPA inspection team evaluated during the inspection had been reviewed at the 

data generation and project levels, and had been approved by the ITR and SPM, respectively, as 

required, and the completed review checklists were contained in the BDRs. 

(5) Training of radiography personnel was adequate.

During the inspection, EPA reviewed the records of the capability demonstration for selected 

radiography personnel. The audio/visual recordings for the latest capability demonstration 

container for the drum RTR operator/ITRs were viewed during the inspection. Training records 

reviewed indicated that only trained personnel were operating the RTR equipment. The records 

reviewed included the following: 

• Radiography data sheet for capability demonstration for the four qualified RTR 

operators/ITRs, dated September 26, 2007, or October 1, 2007 

• Audio/visual recording of drum RTR capability demonstration for the four 

operators/ITRs, dated September 26, 2007, or October 1, 2007 

• Inventory for training drums, ORNL-NDE-TEST-001 and ORNL-NDE-TEST-002 

The operator/ITRs successfully identified all of the prohibited items contained in the training 

drum. However, the operators/ITRs consistently demonstrated that they were unable to identify 

all of the unknown items in the drum, including cardboard and a plastic measuring cylinder. 

EPA discussed this with RTR personnel and included it on an EPA Inspection Issue Tracking 
46

Form (see Attachment C.4 of this report for a copy of this form). This concern is discussed 

below. 

EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-CH-RTR-004C: The EPA 

inspector noted that while all RTR operators correctly identified all of the required prohibited 

items in the capability demonstration training containers, they did not identify some additional 

items, specifically cellulosics and plastic. All cellulosics and plastics in the training drum need 

to be identified and their identification documented. To complete the training process, it is 

critical that the operator receives feedback regarding missed items. More detailed 

documentation of the feedback given is needed when the results of the training drum are 

reviewed. 

Resolution: EPA did not require a response to this concern. 

Status of Concern: This issue is closed.

Summary of RTR Findings and Concerns

The EPA inspection team did not identify any findings in the area of RTR during this baseline 

inspection. The EPA inspection team did identify three concerns in the area of RTR that are 

discussed above. Attachments C.1, C.4, and C. 5 of this report provide a copy of each of the 

EPA Inspection Issue Tracking Forms documenting these issues. EPA considers all three 

concerns to have been adequately addressed, and there are no open concerns related to RTR at 

ORNL-CCP resulting from this inspection. 

Baseline Approval

The baseline conditions that the EPA inspection team evaluated during this baseline inspection 

consisted of the following: 

• Trained personnel: Drum RTR operators/ITR and SPM 

• Approved and controlled operating procedures: CCP-TP-053, Revision 5; CCP-QP-002, 

Revision 25; CCP-TP-028, Revision 3; and CCP-TP-001, Revision 17 

• Drum RTR unit for S5000 (debris) wastes 

• RTR records and supporting data: RTR electronic data recording forms, ITR and SPM 

review checklists, and RTR BDRs 

The drum RTR system is suitable for S5000 (debris) wastes. 

RTR Tiers 

Based on the inspection and the results discussed above, EPA proposes to assign the following 

tiers: 
47

T1 RTR changes require EPA review and approval prior to implementation. There are no T1 

RTR changes at this time. 

T2 RTR changes that do not require EPA approval prior to implementation but require reporting 

and submission of documentation discussing changes by ORNL-CCP include the following: 

• New RTR equipment or substantive changes to approved RTR equipment 

• Changes made to ORNL-CCP RTR procedure(s) that require CBFO approval 

Every 3 months from the date of EPA approval, ORNL-CCP will provide information 

concerning T2 changes. If new RTR equipment is in use, an EPA inspection may be necessary. 

EPA will evaluate changes and communicate with ORNL-CCP whether the changes raise any 

concerns and require a response from ORNL-CCP, or whether ORNL-CCP can continue to 

implement the changes. 

8.4 WIPP Waste Information System 

WC Element Description

At the time of the onsite inspection, ORNL-CCP had not entered either characterization or 

certification data into the WWIS for ORNL containers. However, ORNL-CCP has successfully 

submitted WC/waste certification data for numerous containers to the WWIS in the past (see Air 

Docket A-98-49, II-A4-65). Procedure CCP-TP-030, CCP TRU Waste Certification and WWIS 

Data Entry, is used to guide submittal of both characterization and certification data to the 

WWIS. 

Documents Reviewed

The checklist in Attachment A.4 in conjunction with the listing below provides the documents 

that were examined to evaluate ORNL-CCP WWIS operations relative to the requirements of 

CCP-TP-030, Revision 22, July 24, 2007: 

• Waste Certification Assistant (WCA) Qualification Card (not qualified for ORNL) 

• WCO Qualification Card (not qualified for ORNL) 

• WCO Qualification Card (qualified for ORNL) 

• List of Valid Emplacement Assembly Configurations 

• MS Excel 2000 and XP WWIS Spreadsheet for Container LA00000062113 

• Waste Container Data Report, Container LA00000062113 

• MS Excel 2000 and XP WWIS Spreadsheet for Container 10086822 

• Waste Container Data Report, Container 10086822 

• NCR-INL-0501-07 

• List of Qualified WCOs and WCAs 
48

Technical Evaluation

(1) Overall procedural technical adequacy was evaluated and found to be adequate. 

The WWIS procedure, documented in CCP-TP-030, is well defined, controlled, and contains 

complete instructions for entering, reviewing, and transmitting data. Adequate reviews are 

incorporated into the WWIS data entry procedure to minimize the transmittal of noncompliant or 

incorrect data. No adequacy issues were identified for this procedure. 

Providing notification to EPA upon completion of changes to CCP-TP-030 and other WWIS 

procedure(s) requiring CBFO approval is a T2 change. Consistent with EPA’s authority under 

40 CFR 194.24(h), the Agency may request this information if EPA deems it necessary to ensure 

continued compliance with EPA regulations. (See Table 1, which includes this as a T2 change.) 

(2) Implementation and documentation of WWIS activities were examined and found to be 

adequate. 

Personnel entering data into the WWIS can only do so after being granted access by the WWIS 

Administrator, and access is password protected. EPA observed manual entry of data for 

containers 10086822 and LA00000062113. At the time of the onsite inspection, the WWIS was 

not configured to accept data from ORNL-CCP, and the demonstration used container data from 

other CCP sites. The demonstration consisted of changing data for containers 10086822 and 

LA00000062113 to verify that the WWIS rejects containers that are not WIPP compliant. Both 

compliant and noncompliant versions of the container data were submitted to the test instance of 

the WWIS. The WWIS rejected the containers with noncompliant data as required and provided 

information as to the reason for the rejection. Containers that have open NCRs associated with 

them are identified during the data reconciliation process and do not progress to data entry until 

all NCRs are closed. After data entry, the data are reviewed and, if they are acceptable, they are 

sent to a WCO for review. Only after resolution of any discrepancies are the data transmitted to 

the WWIS. Data storage and retrieval were demonstrated. ORNL-CCP was able to retrieve and 

print requested records, including waste container data reports and Microsoft Excel spreadsheets. 

Although the WWIS process was demonstrated during the onsite inspection, EPA was not able to 

observe data entry for ORNL-CCP data by an ORNL-CCP qualified WCO. EPA may choose to 

review the ORNL-CCP WWIS process at a later date. 

(3) The training of WWIS personnel was reviewed and was found to be adequate. 

WWIS WCA and WCO personnel are based in Carlsbad, New Mexico, where all data entry 

takes place. At the time of the onsite inspection, ORNL-CCP had only one WCO qualified for 

ORNL-CCP data entry, and the WCO who demonstrated the WWIS process for the EPA 

inspection team was not this individual. EPA observed data entry by a WCO from a different 

CCP site for the purpose of verifying training and qualification. 

ORNL-CCP WWIS personnel receive general WWIS training plus training specific for each 

CCP site. The training records for the WCA and WCO individuals that the EPA inspection team 

interviewed were reviewed to ensure that the records were complete. Training included use of 
49

the WWIS User’s Manual, site-specific training, the Transuranic Waste Characterization Quality 

Assurance Project Plan, and the Transuranic Waste Certification Plan. All training for these 

individuals was appropriately documented, and their training records were complete and 

available for inspection. 

(4) Load management was evaluated and was found to not apply at ORNL-CCP at this time. 

At the time of the onsite inspection, ORNL-CCP is not seeking approval to perform load 

management, and EPA excluded evaluation of load management from the scope of this baseline 

inspection. The implementation of load management for CH TRU wastes at ORNL-CCP is a T1 

change. (See Table 1, which lists this as a T1 change.) 

Summary of WWIS Findings and Concerns

The EPA inspection team did not identify any findings or concerns in the area of the WWIS 

during this baseline inspection. There are no open concerns related to the WWIS at ORNL-CCP 

resulting from this inspection. 

Baseline Approval

The system used for container certification that was evaluated during this baseline inspection 

consisted of the following: 

• Trained WWIS WCAs and WCOs 

• Approved and controlled operating procedure: CCP-TP-030, Revision 22 

WWIS Tiers 

Based on the inspection and the results discussed above, EPA proposes to assign the following 

tiers: 

T1 WWIS changes that require EPA review and approval prior to implementation include the 

following: 

• Addition of load management for CH TRU containers at ORNL-CCP 

ORNL-CCP will report and submit documentation for T1 changes when it is ready for EPA 

review. Upon initial review, EPA will inform ORNL-CCP and CBFO whether a site inspection 

is necessary. EPA may request additional information, choose to conduct a desktop review, 

and/or confer with ORNL-CCP WWIS personnel. Upon evaluation (with or without site 

inspection), EPA will issue an approval letter. Only upon receiving the EPA approval can 

ORNL-CCP implement the load management or any other activity deemed to be a T1 change for 

WIPP wastes. 

T2 WWIS changes that do not require EPA approval prior to implementation but that require 

reporting and submitting documentation include the following: 
50

• Changes made to WWIS procedure(s) that require CBFO approval 

Every 3 months from the date of EPA approval, ORNL-CCP will provide information 

concerning T2 changes. EPA will evaluate changes and communicate with ORNL-CCP whether 

the changes raise any concerns and require ORNL-CCP response, or whether ORNL-CCP can 

continue to implement the changes. 

8.5 Container Management 

ORNL-CCP manages containers of CH TRU waste in accordance with procedure CCP-TP-068, 

CCP Container Management at the Idaho Laboratory (INL) and TRU Waste Processing Center, 

Revision 5, September 20, 2007. EPA inspectors evaluated ORNL-CCP’s container 

management process to verify that adequate controls are in place to ensure that any container 

selected for disposal at the WIPP has gone through all WC components and is duly certified for 

shipment to the WIPP. An overview of container processing at ORNL is provided below: 

• Incoming containers of CH TRU waste are processed in accordance with CCP-TP-068. 

ORNL-CCP verifies that containers are listed in the AK Tracking Spreadsheet, inspects 

and weighs the containers, and attaches a traveler, either an affixed label or a paper copy, 

to each accepted container. 

• Containers are subjected to NDE. If a prohibited item is identified, an NCR is initiated 

and the container is returned to Energx for remediation. After successful removal of the 

prohibited item, the container is returned to ORNL-CCP for continued characterization. 

• Containers undergo NDA. An NCR is initiated if the TRU alpha activity of the container 

is less than 100 nCi/g and the container is returned to Energx. 

• After the drum aging criteria (DAC) have been met, headspace and/or flammable gas 

analysis is performed, as necessary. 

• Fissile Gram Equivalent (FGE) is determined. 

• Containers are stored until shipment to the WIPP. 

Energx owns the containers and is responsible for performing container safety checks prior to 

transferring them to the ORNL-CCP CH storage area. Energx personnel are responsible for 

physically moving containers on the site. At no time does ORNL-CCP own the containers 

processed. After receipt, the ORNL-CCP Container Manager initiates procedure CCP-TP-068, 

and a container inspection is performed and documented using Attachment 2. If the container 

fails the inspection, ORNL-CCP returns it to Energx. A traveler (Attachment 1) is attached to 

those containers that pass inspection, and all characterization activities performed on containers 

from this point forward are recorded on the traveler. Each container is weighed, and weights are 

recorded on Attachment 3. 

The ORNL-CCP Vendor Project Manager (VPM) receives a list of containers that have been 

through integrity checks and informs Energx container management personnel which containers 

need to be moved to NDE on that day. The NDE equipment is located in the CHSA. Upon 
51

completion of NDA, containers are moved to the DAC storage areas, which are cargo containers 

located close to the CHSA. Headspace and/or flammable gas analysis takes place in Room 122. 

It is anticipated that the CHMB will be completed in December 2007. Upon completion, the 

containers presently stored in the DAC containers will be moved to CHMB to await shipment to 

the WIPP. ORNL-CCP does not know what containers are in each area at any one time because 

Energx is responsible for tracking the containers. 

Rejected containers are returned to Energx. The Energx Waste Operation Leader receives a 

verbal communication from ORNL-CCP that containers are rejected. Energx also receives a 

copy of the ORNL-CCP NCR to assist Energx in container disposition. ORNL-CCP receives 

only 55-gallon drums. Some of this waste stream is in SWBs, and these are processed by Energx 

and repackaged into 55-gallon drums. 

Energx is responsible for shipping containers to the WIPP. ORNL-CCP’s WCO will enter data 

into the WWIS for container certification. The Transportation Certification Official (TCO) will 

build a payload and provide this to Energx. Load management will not be used for these 

containers. ORNL-CCP loaders will place the containers into the TRUPACTs for transportation 

to the WIPP. 

Although EPA was not able to observe all phases of this process, the ORNL-CCP procedure 

adequately addressed all phases of container management. 

9.0 RESPONSE TO COMMENTS 

EPA did not receive any comments on the proposed approval. 

10.0 SUMMARY OF RESULTS 

10.1 Findings and Concerns 

The concerns identified during the inspection, as well as ORNL-CCP responses, are discussed in 

the preceding sections of this report. Attachment C includes copies of the EPA Inspection Issue 

Tracking Forms that capture these issues. 

As stated previously in this report, EPA Concern No. ORNL-CCP-CH-CBFO-003F, Final, was 

not addressed as part of the ORNL-CCP baseline inspection process. Due to the nature of the 

concern, the fact that it occurred in conjunction with this inspection is coincidental and does not 

reflect on the technical adequacy of the ORNL-CCP WC program. CBFO, in a letter dated 

December 21, 2007, provided a commitment to EPA to prevent recurrence of the issues in the 

finding. EPA accepts the CBFO response and considers this issue to be closed. 

ORNL-CCP responded to the other eight EPA concerns that required a response prior to the 

inspection closeout on site as well as subsequent to the inspection. The EPA inspection team 

members evaluated all responses for completeness and adequacy and concluded that each EPA 

issue requiring a response had been resolved satisfactorily. No EPA issues related to the baseline 

inspection of ORNL-CCP remain open at this time. 
52

10.2 Conclusions 

The EPA inspection team determined that the ORNL-CCP WC program activities were 

technically adequate. EPA is proposing to approve the ORNL-CCP WC program in the 

configuration observed during this inspection and described in this report and the attached 

checklists (Attachments A.1 through A.4). This approval includes the following: 

(1) The AK process for retrievably-stored CH TRU debris wastes 

(2) The DWAS IPAN/SGS system for assaying CH TRU wastes 

(3) The NDE process of RTR for CH TRU debris wastes 

(4) The WWIS process for tracking of waste contents of CH TRU wastes 

This baseline approval of ORNL-CPP does not include load management. 

ORNL-CCP must report and receive EPA approval of any T1 changes to the ORNL-CCP WC 

activities from the date of the baseline inspection. It must notify EPA regarding T2 changes 

according to Table 8, below. (See Section 2.0 of this report for a brief discussion of tiering.) 

Table 8 closely follows the format used in the two previous CH baseline approval reports of 

Hanford and the LANL-CCP (see EPA Docket Nos. A-98-49, II-A4-93; and A-98-49, II-A4-88, 

respectively). All T1 changes must be submitted for evaluation and approval by EPA prior to 

their implementation. Upon approval, EPA will post the results of the evaluations to the EPA 

Web site and by sending e-mails to the WIPPNEWS list, as described above. Upon completion 

of its review of the T2 changes submitted at the end of each fiscal quarter, EPA will post the T2 

changes. EPA expects the first report of ORNL-CCP’s T2 changes at the end of the first quarter 

following approval.

The scope of the site baseline compliance decision is based on EPA’s inspection completed 

November 13–15, 2007.
53 

Table 8. Tiering of TRU WC Processes Implemented by ORNL 

Based on November 13–15, 2007, Onsite Baseline Inspection 

WC Process Elements ORNL-CCP WC T1 Changes ORNL-CCP WC T2 

Acceptable Knowledge (AK) and Load Management 

Implementation of load management; AK (5) Implementation of AK for wastes other than retrievablystored debris (i.e., retrievably stored soil/gravel and 

solids and/or any type of newly-generated waste); AK (15) 

Notification to EPA upon completion of AK 

Notification to EPA upon completion of new 

updates/substantive changesb of the followin

- Changes to AK-NDA communicati

- Changes to site procedure; AK (4) - AK Summaries that describe wastes 

described in this report; AK (6) - Radiological Discrepancy Resolutio

NDA) pertinent to Waste Stream O

- Completed Attachments 4 and 6 and 

Waste Stream OR-NFS-CH-HET; A

- AK Summaries/Waste Stream Profi

documentation reports; AK (15)

Non Destructive Assay (NDA) New equipment or physical modifications to approved 

equipmentc; NDA (1) Extension or changes to approved calibration range for approved equipment; NDA (2) 

Notification to EPA upon completion of cha

equipment, operating range(s), and site proce

approval; NDA (2) 

Real-Time Radiography (RTR) N/A Notification to EPA upon the following: - Implementation of new RTR equipm

approved RTR equipment; RTR (1) - Completion of changes to site RTR 

approvals; RTR (2) 

Visual Examination (VE) Not approved at this time Not approved at thiWIPP waste Information System (WWIS) 

Implementation of load management; WWIS (4) Notification to EPA upon the following: - Completion of changes to WWIS pr

approvals; WWIS (1) 

aUpon receiving EPA approval, ORNL-CCP will report all T2 changes to EPA at the end of each fiscal quarter. b“Substantive changes” means changes with the potential to impact the site’s WC activities or documentation thereof, excluding changes tha

nuclear safety, or RCRA, or that are editorial in nature. 

cModifications to approved equipment include all changes with the potential to affect NDA data relative to waste isolation and exclude mino

of safety-related equipment. 
54 

11.0 REFERENCES

New Mexico Environment Department, Waste Isolation Pilot Plant Hazardous Waste Facility 

Permit (WAP), NM48901 139088-TSDF, Santa Fe, New Mexico, 1989. 

U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 191, 

“Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear 

Fuel, High-Level and Transuranic Radioactive Wastes.” 

U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 194, “Criteria for 

the Certification and Re-Certification of the Waste Isolation Pilot Plant’s Compliance with the 

40 CFR Part 191 Disposal Regulations.” 

U.S. Department of Energy, “40 CFR Part 191, Compliance Certification Application for the 

Waste Isolation Pilot Plant,” DOE/CAO 1996-2184, Carlsbad, New Mexico, 1996. 

U.S. Department of Energy, “40 CFR Part 191, Subparts C and D, Compliance Recertification 

Application 2004,” DOE/WIPP/2004-3231, 2004. 

U.S. Department of Energy, “Transuranic Waste Baseline Inventory Report,” Revision 0, 

DOE/TRU-2206-3344. 

U.S. Department of Energy, Carlsbad Area Field Office, “Contact-Handled Transuranic Waste 

Acceptance Criteria for the Waste Isolation Pilot Plant (CH-WAC),” Revision 3, DOE/WIPP-02-

3122, Carlsbad, New Mexico, April 25, 2005. 

U.S. Department of Energy, Carlsbad Area Field Office, “Quality Assurance Program 

Description (QAPD),” DOE/CBFO-94-1012, Revision 7, Carlsbad, New Mexico, July 2005. 

U.S. Environmental Protection Agency, “Criteria for the Certification and Recertification of the 

Waste Isolation Pilot Plant’s Compliance with the Disposal Regulations: Certification Decision; 

Final Rule,” Federal Register, Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405. 

U.S. Environmental Protection Agency, “EPA Replicate Testing for WIPP Nondestructive Assay 

(NDA) Systems,” Revision 2, June 2002. 

U.S. Nuclear Regulatory Commission, “Contact-Handled Transuranic Waste Authorized 

Methods for Payload Control.”
AK-1 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

GENERAL 

AK-1: Is the waste TRU by definition as presented in the 

LWA? (P.L.102-579) 

CCP-TP-005, Revision 18; Section 4.4.31; CH-WAC Revision 3; P.L. 102-579 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-AK-OLoad ManThe implemis a T1 cha

AK-2: Do the presented volumes comport with LWA capacity restrictions? (P.L.102-579) 

CCP-TP-005, Revision 18; CH-WAC Revision 3; P.L. 102-579 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CP-AK-00Available stream is wenvelope. 

AK-3: Are any wastes considered (or previously considered) high level wastes (HLW)? HLW are 

prohibited. 

(P.L.102-579) 

CCP-TP-005, Revision 18; CH-WAC Revision 3; P.L. 102-579 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-AK-OHLW are nexamined 

AK-4: Are any wastes considered (or previously considered) Spent Nuclear Fuel? (P.L.102-579) 

CCP-TP-005, Revision 18; CH-WAC Revision 3; P.L. 102-579 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-AK-OP273. CCSNL are in 

AK-5: Are these defense wastes? (P.L.102-579) 

CCP-TP-005, Revision 18; CH-WAC Revision 3; P.L. 102-579 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-AK-OM021, C0

AK-6: What is the scope of authorization sought (i.e., SCG, newly generated vs. retrievably stored, other sitespecific breakdowns?) 

CCP-TP-005, Revision 18; CH-WAC Revision 3; P.L. 102-579, CRA 2004 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-AK-OScope of acontact hanwaste outsT1 change

AK-7: Is AK being used that was assembled prior to an EPA approved QA program (retrievably stored)? If so, what qualification process is used? Is this waste undergoing confirmation as per the CCA/CRA (100% sampling)? 

CCP-TP-005, Revision 18; CH-WAC Revision 3; P.L. 102-579 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-AK-OWaste is reundergo 10containers CCP proce
AK-2 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

[194.24(c)(2)-(5), 194.22(a)] AK-8: Is AK being assembled as waste is generated after EPA approval of the QA program (newly generated)? Is this waste undergoing confirmation as per the CCA/CRA (100% sampling)? [194.24(c)(2)-(5)] 

CCP-TP-005, Revision 18; CH-WAC Revision 3; P.L. 102-579 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-AK-O

Newly gen

scope of th

AK-9: Procedures require staff to be qualified to assemble, compile, and confirm AK data, including, but not limited to: 

a. Identification of required reading list and successful 

completion of all required reading including, but not limited to: 

• Applicable portions of the WIPP WAP and TSDF 

WAC 

• WIPP Compliance Certification Decision Conditions 

2 and 3 

• State and Federal RCRA regulations associated with 

solid and hazardous waste characterization 

• Discrepancy resolution and reporting processes 

• Site-specific procedures associated with waste 

characterization using acceptable knowledge 

b. Successful completion of testing to demonstrate 

understanding of required reading list 

c. Completion of internal and/or external training 

programs pertinent to AK 

d. Participation in internal audits to assess AK program 

e. Other methodologies for demonstrating AK 

proficiency as developed on a site-specific basis 

(WAP B4, B4-3a) 

CCP-TP-005, Revision 18, Section 4.1.2; CCP-QP-002, Section 4.2 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

Training reDave Atkiavailable iall areas, bWIPP CCA ORNL-CCtraining in

AK-10: CCP-TP-005, Revision 18; CCP-TP- Review of objective Procedure
AK-3 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

a. Are procedures adequate to encompass the spectrum of 

wastes for which authorization is sought? 

b. Are there different procedures for newly generated vs. 

retrievably stored waste? Are there different 

procedures for solid, debris, or soil waste? Should 

there be? 

c. For newly generated waste, have adequate procedures 

been developed and implemented to characterize waste 

using acceptable knowledge prior to packaging? 

(WAP B4, B4-3b) 

066 evidence and interview of 

Jeff Harrison and Dave Atkins 

retrievably the scope ocompasses inspection waste. Noto CCP-TP

ASSEMBLING AK INFORMATION AND COMPILING AK DOCUMENTATION INTO AN AUDITABLE RECORD AK-11: What is the breakdown of the types and quantities of TRU waste generated/stored at the site? (WAP B4, B4-2a) 

CCP-TP-005, Revision 18, Section 4.4.8 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

TWBIR Rthe most resite. Note identified binterviews with full-s

AK-12: Do procedures call for AK information to be collected for: a. 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr, 

137Cs + unexpected radionuclides 

b. Ferrous metals (in containers) 

c. Cellulosics, plastics, rubber d. Nonferrous metals (in containers) (CRA/CCA Ch 4 and Attachments/Appendices) 

CCP-TP-005, Revision 18, Sections 4.4.21, 4.4.22, 4.4.24 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

Attachmen7 CCP-TOand radioloincluded in 

NDE and A

to the AK-T2 changememorandidentified bT1 change

AK-13: Do procedures require documentation of radionuclide process origin? Are the facility and TRU waste management operations correlated to specific waste stream information? (Attachment B4; WAC Appendix A.2.2) 

CCP-TP-005, Revision 18, Section 4.4 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-AK-OC122, P26P284, I056
AK-4 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

AK-14: Are correlations between waste streams, with regard to time of generation, waste generating processes, and site-specific facilities clearly described? For newly generated wastes, the rate and quantity of waste to be generated shall be defined. (Attachment B4, B4-3c; WAC Appendix A, Section A.2)

CCP-TP-005, Revision 18, Section 4.4 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-AK-OU233, C10I052, M00

representareferences 

record (Ataddress the record refl

AK-15:a. Are waste streams appropriately identified and are 

wastes characterized on a waste stream basis? 

b.Are wastes grouped on a waste stream basis using 

Acceptable Knowledge? 

(Attachment B4, Section B-1a) 

CCP-TP-005, Revision 18, Section 4.4, 4.2.3 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-AK-OU038. Desfor the posmachine cothe stream as inspecte

AK-16: Do procedures demonstrate a logical progression from general facility information to more detailed waste stream-specific information? 

CCP-TP-005, Revision 18, Section 4.4 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-AK-OM001-M0P272, P27generation Wheeler pcontainers

AK-17: Does the process include review of AK information to evaluate and document AK-AK information discrepancies? (WAC Section A.2.2.3, Attachment B4, Section B4-3) 

CCP-TP-005, Revision 18, Section 4.8 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

DR002 dediscrepancrevisions tthe issues resolution)any DRs a
AK-5 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

AK-18: Do procedures require collection of information regarding how waste is tracked and managed at the generator site (including historical and current operations)? (WAC Section A.2; Attachment B4 Section B4-2a) 

CCP-TP-005, Revision 18, Section 4.4 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

PTS (and rTracking SM019. Sitoverall drutracks NRCrecords inc

AK-19: Is AK information compiled in an auditable record, including a road map for all applicable information? 

CCP-TP-005, Revision 18, Attachment 4 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

AttachmenStream and 

AK-20: Has a reference list been provided that identifies documents, databases, Quality Assurance protocols, and other sources of information that support AK information? (Attachment B4, Section B4-3c) 

CCP-TP-005, Revision 18, Attachment 4 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-TP-0CCP repre

be substan

stream in trevisions t

AK-21: Have the following mandatory information requirements been identified? • Map of the site that identifies the areas and facilities 

involved in TRU waste generation, treatment, and storage 

• Facility mission description related to TRU waste 

generation and management 

• Description of the operations that generate TRU waste 

at the site and process information, including: 

 - Area(s) or building(s) from which the waste stream 

was or is generated 

 - Estimated waste stream volume and time period of 

generation 

 - Waste generating process description for each 

building or area 

 - Process flow diagrams, if appropriate 

CCP-TP-005, Revision 18, Section 4.4 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-AK-OP273, CCPAttachmenThe AK sureferences requiremenother inforrather than AK-NDA informatioand genera

Note that t

default isocompositio

performed believe tha

Specificati

provided in 

Revisions to explain 
AK-6 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

 - Generalized material inputs or other information that 

identifies the radionuclide content of the waste stream and the physical waste form 

 - Types and quantities of TRU waste generated, 

including historical generation through future 

projections 

• Physical/chemical waste composition that could affect 

isotopic distribution (i.e., processes to remove ingrown 

241Am) 

• Statement of all numerical adjustments applied to 

derive the material’s isotopic distribution, e.g., scaling 

factors, decay/ingrowth corrections and secular equilibrium considerations 

• Specification of isotopic ratios for the 10 WIPP-tracked 

radionuclides and, if applicable, the radionuclides that comprise 95% of the hazard 

(WAC Section A.2.2; Attachment B4, B4-2a, B4-2b) 

changes to address EPwhile futurcommunicchanges. 

AK-22: Does the site have procedures for the collection of supporting information? Examples of supplemental information, from WAC, include: • Safeguards and security and other material control 

systems/programs 

• Reports of nuclear safety or criticality 

• Accidents involving SNM waste packaging and waste 

disposal 

• Building or nuclear material management area logs or 

inventory records 

• Site databases that provide SNM or nuclear material

information test plans 

• Research project reports, or laboratory notebooks that 

describe the radionuclide content of materials used in 

CCP-TP-005, Revision 18, Section 4.4 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-TP-0M016, M0P251, P25P284. Ade

present, no

4 would be 
AK-7 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

experiments 

• Information from site personnel 

• Historical analytical data relevant to isotopic 

distribution in the waste stream 

(WAC Section A.2.2.2; Attachment B4 Section B4-2c) 

AK-23: Is all necessary supporting information assembled and has it been appropriately used? (Section B4-2c) 

CCP-TP-005, Revision 18, Section 4.4 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-TO-0references 

presented, 

that additioassembled 

AK-24:

a. Are waste categorization schemes presented and are 

they appropriate? 

b. Are waste identification/categorization schemes 

relevant to the isotopic composition of waste? 

(Attachment B4 Section B1, WAC page ix, Appendix A.2) 

CCP-TP-005, Revision 18, Section 4.4 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-AK-OAttachmencategorizaWMPs and distributiothe CH def

AK-25: Have data uses and limitations been assembled and are they technically adequate? (CRA/CCA; WAC Appendix A, Section A.2.2.3) 

CCP-TP-005, Revision 18, Section 4.4 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-TP-0each sourclimitationsa data limidefault isoinspectionreference. 

AK-26: Site documents/procedures require the facility to 

prepare an AK summary document that summarizes all 

information collected, including the basis for all waste 

stream designations. Is the AK Summary of sufficient scope and detail? (WAC Appendix A Section A.2.2; Attachment B4 Section B4-2b, Attachment B Section B-3d (1), (2)) 

CCP-TP-005, Revision 18, Section 4.4 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-AK-ORevisions EPA conceconsidered 1 was prov
AK-8 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

AK-27: Are conclusions and interpretations presented in the AK Summary technically sound and supported by referenced mandatory and supplemental information? 

CCP-TP-005, Revision 18 Review of objective 

evidence and interview of Jeff Harrison and Dave Atkins 

See AK-26update the Revision 1occur in thand would Also note are considwill documstream. 

AK-28: If AK data discrepancy is identified, site will evaluate the source of the discrepancy to determine if discrepant information is credible. Information that is not credible will be identified as such and reasons fordismissing will be justified in writing. Limitations concerning information will be documented in the AKrecord and summarized in the AK report. If a discrepancy cannot be resolved, the site will perform direct measurements for the impacted population. (WAC Appendix A.2, Section A.2.2.3) 

CCP-TP-005, Revision 18, section 4.4 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

DR002; norequired to during the 

AK-29: Has the use of load management been proposed? Does the AK Summary include the following from the WAC, Revision 3, Appendix E? • Each TRU waste stream selected for payload 

management must include in its acceptable knowledge

summary report an estimate of the total waste volume and the percentage of the waste volume that is above and below 100 nCi/g. (It should be noted that thisinformation, although based on the best available AK information, is preliminary and subject to the 

performance of WIPP-certified NDA measurements 

and cannot and will not be used as a measure of AK accuracy.) (Reference E3) 

(WAC, Appendix E) 

CCP-TP-005, Revision 18, Section 4.4 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

Load manaImplement

be a T1 ch

AK-30: Are nonconforming wastes segregated? Are 

NCRs dispositioned in an appropriate and technically 

CCP-TP-005, Revision 18 Review of objective 

evidence and interview of 

NCR examNote that E
AK-9 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

defensible manner? (Attachment B4, Section B4-3b, Attachment B3, Section B3-13) 

Jeff Harrison and Dave Atkins 

separately 

AK-31: Do site procedures require that additional information be collected before waste may be shipped if the required AK information is not available for a waste stream or if available AK is poor or unacceptable? (Attachment B4 ) 

CCP-TP-005, Revision 18, Section 4.4 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

Not Applic

was availaHET, as ex

AK-32: Do these procedures facilitate the mandatory traceability analysis performed for each Summary Waste Category Group examined during the audit, noting that EPA will determine whether the available waste streams adequately demonstrate the full characterization process for the proposed scope? (Attachment B4, Section B4-2) 

CCP-TP-005, Revision 18, Section 4.4 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

Batch Data 007; OR-DM018, AttWSPF and 

performed 

containers 

processes/

AK-33: If AK was used (i.e., data collected prior to QA 

program), what method was employed to qualify the 

information? Approved methods or peer review, corroborating data, confirmatory testing, and QA program 

equivalency? If confirmatory testing is used, has the following been considered (from WAC)?* • At a minimum, to confirm existing AK data, it is 

necessary to compare ratios of the two most prevalent 

radionuclides in the isotopic mix 

a. For 238Pu, 239Pu, 240Pu, 241Pu, 242Pu and 241Am:

• Confirmation can be accomplished via comparison of 

measured and AK values for 239Pu/ 240Pu for weapons 

grade plutonium; 238Pu/ 239Pu for heat source 

• Measured 241Am can be used to calculate 241Pu (for 

subsequent AK comparison) if time of chemical separation is known (no 241Am at time of separation 

assumed) 

CCP-TP-005, Revision 18 Review of objective 

evidence and interview of Jeff Harrison and Dave Atkins; NDA personnel also involved with discussions: Norman Frank, John West, Joe Wachter, Sean Stanfield, Barry Smith, George Westik, Christa Chavez, and Joseph Harvill 

AK-NDA default isoisotopes ex

isotopics wradionuclidmaterial tythroughouPu for each on the amoBuilding 2greatest cowere calcucontract cocontent wauranium in calculated LA-UR-00should be 
AK-10 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

• 241Pu can be compared (by ratio) to confirm AK of 

any Pu isotope associated with WG/RG (i.e., 239Pu or 

240Pu) 

• 238Pu from AK for WG/RG Pu is assumed to be valid 

if the AK values of 239Pu and 240Pu have been 

confirmed by measurement 

• 242Pu calculated by correlation techniques, since it 

can’t be measured 

b. For 235U, 233U, 238U, 234U:

• Were they tracked or measured in AK information? 

• If no valid AK exists, data generated can only be 

used to detect or calculate, or confirm absence ratios for 234U calculated from 235U enrichment 

• If valid AK exists can confirm with certified systems 

• 234U calculated by 235U enrichment, because 234U 

can’t be measured 

c. For 137Cs and 90Sr:

• Confirmed by WIPP-certified system (direct 

measurement or comparison of 241Am peak at 662 

keV to other 241Am peaks (disproportionate 241Am 

peak at 662 keV could mean presence of 137Cs) 

• 90Sr calculated from 137Cs using scaling factors 

Other radionuclides – must identify via NDA and should identify via AK *If the WAC requirements are not followed, identify how the specific radionuclides are characterized via AK, and how these data are used by NDA. (40 CFR 149.22(b), WAC, Appendix A, Section A.2.1) 

the 1:1 rati
AK-11 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

AK-34: If waste is generated after an EPA approved QA 

program, are radioassay and NDE results compared to the 

data assembly process as a cross reference to verify implementation of the as-generated characterization

program? 

(194.24 (c)(3); 194.22(b)) 

CCP-TP-005, Revision 18 Not Applicable Not applic

not includeinspection

AK-35: This procedure requires a reevaluation of AK if 

NDE identifies it to be a different waste matrix code. 

This procedure describes how the waste must be reassigned, based on the AK reevaluation. (Attachment B4, Section B4-3d) 

CCP-TP-005, Revision 18, Section 4.9 

CCP-TP-0only); NDE wastes by waste reas

AK-36: Does the generator site have written procedures for newly generated waste to document the confirmation of acceptable knowledge information with visual examination prior to or during waste packaging? Dothese procedures address the required elements in B4-3e? 

 (Attachment B4, Section B4-3e) 

CCP-TP-005, Revision 18 Review of objective 

evidence and interview of Jeff Harrison and Dave Atkins 

Not applic

not includeinspection

AK-37: Procedures require the following steps to be followed if wastes are reassigned to a different waste matrix code based on NDE: • Review existing information based on the container 

identification number and document all differences 

• Reassess and document all analytical data associated 

with the waste 

• Reevaluate waste material parameter determinations 

and document any changes 

• Reevaluate the radionuclide content and document any 

changes 

• Verify and document that the reassigned waste matrix 

code was generated within the specified time period, area and buildings, waste generating process, and that 

CCP-TP-005, Revision 18, Attachment 10 

Review of objective evidence and interview of Jeff Harrison and Dave Atkins 

CCP-TP-0

provided f

available y
AK-12 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

the process material inputs are consistent with the waste material parameters identified during radiography or visual examination 

• Record all changes to acceptable knowledge records 

• If discrepancies exist in the acceptable knowledge 

information for the reassigned waste matrix code, complete a nonconformance report, document the segregation of this container, and define the corrective actions necessary to fully characterize the waste 

(Attachment B4, Section B4-3e) 

AK-38: Has the acceptable knowledge expert calculated the percent changes in waste matrix code based on AK and NDE/VE? Were accuracy evaluations assigned? Are these acceptable? (Attachment B3, Section B3-9; WAC Appendix A, Section A.6.5) 

An AK acc

prepared f

has evalua

process at 

AK-39: Are the following items addressed with respect to AK-NDA communication and the use of AK data by 

NDA personnel? 

• Do procedures require the identification of AK data

limitations? 

• Are AK data and associated limitations communicated

to NDA personnel and is this required by procedure?

• How is AK used by NDA personnel? • Do AK and NDA personnel communicate and agree 

about the use of AK? 

• Is this agreement proceduralized? 

(WAC, Appendix A) 

CCP-TP-005, Revision 18, Attachment 6 and Section 4.4.22 

CCP-TP-0AK-NDA memorandEPA conceMemo, AK memorandhow NDA even thougindicated tfor most ostream. EPnot revise 

be more sp

document isotopics wAK-NDA 

NDA pers
AK-13 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

AK-40: Have internal AK audits been performed? (Attachment B4, Section B4-3d, g) 

CCP-TP-005, Revision 18 CCP-TP005, Revision 18 Review of objective evidence and interview of 

Jeff Harrison and Dave Atkins 

CCP Intern

November 

AK-41: If data consistently indicate discrepancies with acceptable knowledge information, the site increases sampling, reassesses the materials and processes that generate the waste, and resubmits waste stream profile information. (WAC Section A.2.2.3; Attachment B4, Sections B4-3b, B4-33, Attachment B3) 

CCP-TP-005, Revision 18 Review of objective 

evidence and interview of Jeff Harrison and Dave Atkins 

Not Applic

inspectioncollected t

AK-42: Are acceptable knowledge processes consistently applied among all generator sites, and does each generator site comply with the following data quality requirements for acceptable knowledge documentation: a. Precision - Precision is not applicable to AK (see 

Attachment B4) 

b. Accuracy - Accuracy is the degree of agreement 

between an observed sample result and the true value. 

The percentage of waste containers which require reassignment to a new waste matrix code is based onthe reevaluation of acceptable knowledge and sampling and analysis data will be reported as a measure of acceptable knowledge accuracy. Accuracy based on radionuclide content is typically assessed by comparing measured results with AK data. 

c. Completeness - Completeness is an assessment of the 

number of waste streams or number of samples collected to the number of samples determined to beuseable through the data validation process. The acceptable knowledge record must contain 100 percent of the information specified in Section B4-2. The usability of the acceptable knowledge information will 

CCP-TP-005, Revision 18 Review of objective 

evidence and interview of Jeff Harrison and Dave Atkins 

No AK Ac

AK-38). Nthe AK Suimmediateadditional Record (e.Section A.addressed were compinspectionMinimum 
AK-14 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

be assessed for completeness during audits. 

d. Comparability - Data are considered comparable when 

one set of data can be compared to another set of data. Comparability is ensured through sites meeting the training requirements and complying with the minimum standards outlined for procedures that are used to implement the acceptable knowledge process. WAC Section A.6.5: Additionally, comparison of measured data with AK-derived or -based values, as applicable, 

provides a means to assess comparability on a waste

stream basis. 

e. Representativeness - Representativeness expresses the 

degree to which sample data accurately and precisely represent characteristics of a population. Representativeness is a qualitative parameter that will 

be satisfied by ensuring that the process of obtaining, 

evaluating, and documenting acceptable knowledge information is performed in accordance with the minimum standards established in Section B3. Sitesalso must assess and document the limitations of the acceptable knowledge information used to assign waste 

parameters. 

(Attachment B3, Section B3-9) 

AK-43: Does the generator site address quality control 

by tracking its performance with regard to the use of 

acceptable knowledge by: (1) assessing the frequency of inconsistencies among information, and (2) documenting the results of acceptable knowledge confirmation through radiography or visual examination? In addition, the acceptable knowledge process and waste stream documentation must be evaluated through internal assessments by quality assurance organizations and assessments by auditors or observers external to the organization (i.e., CBFO, NMED, EPA). (Attachment B3, Section B3-9) 

CCP-TP-005, Revision 18 Review of objective 

evidence and interview of Jeff Harrison and Dave Atkins 

CCP trackCCP AK rwas outsidrepresentainternal suassess AK trend code the future, ongoing fo
AK-15 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

AK-44: Did the generator site implement, or does it currently implement, process controls to ensure that prohibited items are documented and managed in accordance with site-specific certification plans? What process controls are in 

place to assess prohibited items and other waste 

characteristics (i.e. is fast scan used, and, if so, 

by whom)? 

 (Attachment B4, Section B4-3b) 

CCP-TP-005, Revision 18 Review of objective 

evidence and interview of Jeff Harrison and Dave Atkins 

P254. CChistoric AK assess the that Foster repackage non-WIPP 

perform V

in accordaIf a prohibaddressed Wheeler/Efast scan o

AK-45: Does the generator site document, justify, and consistently delineate waste streams based on site-specific 

permit requirements or state-enforced agreements? How 

do these agreements impact waste characterization? (Section B4-3e) 

CCP-TP-005, Revision 18 Review of objective 

evidence and interview of Jeff Harrison and Dave Atkins 

CCP repreCH progra

been affec

state agreecharacteriz(Jan, 2008

place for R

state agreeschedule aforthcomin
ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13 – 15, 2007

NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/S

NDA-1 

Required Technical Elements Y/N Location Verification of Activity Y

System Description Identify the NDA system by name, location and number, as appropriate. 

NA Not Applicable The NDA system is the Drum waste Assay System (DWAS) 

consisting of an Imaging Passive/Active Neutron and

segmented Gamma Scanner (IPAN SGS). It is located in Building 7880-I of the TRU Waste Processing Center (TWPC). 

N

Describe the system’s operational history including deployment at other DOE sites. 

NA Not Applicable This is the first time this system has been evaluated by EPA 

for conducting WIPP assays 

N

For systems that have been deployed at multiple DOE sites document pertinent aspects of each system’s development, e.g., installation of new or different detectors, software or other relevant features. 

NA Not Applicable This system was operational prior to this inspection but not 

for WIPP-bound TRU wastes. 

N

System Performance Identify the period of performance relevant to this inspection and if this NDA system has 

prior EPA approval(s). 

NA Not Applicable Operation of the DWAS IPAN/SGS began on 10-07-07. N

Identify the type (55-gallon drums, or SWBs) and number of waste containers this system assayed during the period of performance. Of these, indicate how many Batch Data Reports (BDRs) were assembled. Of the assembled BDRs, indicate how many have 

been promoted through Project Level Review 

and are available for evaluation during this inspection. If multiple waste containers have 

been assayed assign a total to each container 

type. 

 CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

As of 11-13-07 a total of 20 55-gallon (208 liter) drums have 

been assayed, and these have been compiled in 3 Batch Data 

Reports (BDRs) all of which have been promoted through 

Project Level Review. 
ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13 – 15, 2007

NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/S

NDA-2 

Required Technical Elements Y/N Location Verification of Activity Y

General Reporting Requirements Assay systems must report quantitative values and uncertainties for 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 233U, 234U, 238U, 90Sr, and 137Cs. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The DWAS reports quantitative values and uncertainties for 

238Pu, 239Pu, 240Pu, 242Pu, 241Am, 233U, 234U, 238U, 90Sr, and 137Cs. 

Each container characterized and intended for disposal at WIPP must contain TRU waste. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

Only wastes containing greater than TRU radionuclides at concentrations greater than 100 nCi/g are promoted as WIPP eligible by ORNL-CCP. 

NDA instruments and procedures are 

appropriate for the waste streams being assayed. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The DWAS system and supporting procedures are appropriate for the waste stream within the scope of this inspection. 

NDA instruments and procedures result in 

unbiased values for the cumulative activity of the WIPP radionuclide inventory. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The DWAS and supporting procedures produce values that are appropriate for calculation of the WIPP-trackedradionuclides 

Some radionuclides are derived by the application of scaling factors or correlation techniques. Identify all radionuclides that are quantified in this manner. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

90Sr, 234U and 242Pu are determined by the application of 

scaling factors for gamma determinations. For active and 

passive neutron determinations, radionuclide-specific values 

are derived based on the measured 239PuEFF and 240PuEFF, 

respectively. 
ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13 – 15, 2007

NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/S

NDA-3 

Required Technical Elements Y/N Location Verification of Activity Y

Assess the technical adequacy of the calculations involving the application of scaling factors and/or correlation techniques. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

90Sr, 234U and 242Pu are determined by the application of 

scaling factors whose technical bases and derivation are documented in the gamma calibration report. Active and Passive Mode neutron assays rely on the measurement of 

239PuEFF and 240PuEFF, respectively, and the application of 

isotopic distributions to obtain radionuclide-specific values as documented in the neutron calibration report. 

Identify the procedures that govern this function and where the results of these calculations are documented. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The procedures that govern this function are provided to the right. The results of the calculations are documented in the DWAS BDRs. 

Acceptable Knowledge (AK) If isotopic ratios based on AK are used the values are qualified by confirmatory testing. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

AK-based isotopics are used when such values can besupported by the AK documentation process.. All containers 

(one hundred percent) are subjected to radioassay using the 

DWAS. 
ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13 – 15, 2007

NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/S

NDA-4 

Required Technical Elements Y/N Location Verification of Activity Y

Do NDA personnel use AK derived isotopic values to calculate radionuclide values? If so, is this function performed according to a formal procedure? Assess the technical adequacy of this process(s). 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The NDA Expert Analyst (EA) used AK-derived isotopic values to calculate radionuclide values in conjunction with approved AK values as documented in the references listed in 

the right column of this row. 

Identify the procedure and where the results of these calculations are documented. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The application of AK-based isotopics is addressed in the data generation level validation procedure and the results of 

the calculation are in the DWAS BDRs. 

Isotopic Determination Identify the radionuclides that are measured directly and the specific radiation type (γ, 

AN or PN) that is measured. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

Gamma: Directly measured radionuclides include: 238Pu, 

239Pu, 240Pu, 241Am, 233U, 238U and 137Cs. 

Active and passive neutron: Radionuclide-specific values are derived based on the measured 239PuEFF and 240PuEFF, 

respectively. 

Identify the method(s) used to derive the isotopic contribution for the unmeasured radionuclides, e.g., MGA, PC FRAM or other technique. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The DWAS uses Multi Group Analysis (MGA), PC FRAM and the application of AK-based isotopics. The use of these 

techniques is subject to expert decision. 
ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13 – 15, 2007

NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/S

NDA-5 

Required Technical Elements Y/N Location Verification of Activity Y

Lower Level of Detection (LLD) The LLD for each NDA system must be determined. For multi modal systems this may require a separate determination for each mode, i.e., active neutron, passive neutron and gamma. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

An LLD has been determined for all operational modes: 

active mode neutron assays, passive mode assays and gamma assays. The LLD determination for the active and passive modes was not adequately addressed for 90Sr and 234U. These 

are required according to CCP-TP-167, Section 4.6.1, but Revision 2 of BII-5183-CVR-001 did not contain information regarding them. BII-5183-CVR-001was revised and Revision 3 included the required information for 90Sr and 234U. 

Site-specific environmental backgrounds and container-specific interferences must be accounted for in LLD determinations. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

Site-specific environmental backgrounds and containerspecific interferences are addressed in the DWAS LLD 

determinations. 

NDA instruments performing TRU/NonTRU waste discrimination measurements are 

required to have a LLD no greater than 100 nCi/g. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The DWAS IPAN/SGS will not be used to discriminate TRU & Non-TRU wastes at the 100 nCi/g criterion. 

N

The technical basis and derivation for LLDs must be adequate and appropriately documented. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The technical basis and derivation for the LLDs for all three operational modes are technically adequate and appropriately 

documented. 
ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13 – 15, 2007

NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/S

NDA-6 

Required Technical Elements Y/N Location Verification of Activity Y

For radionuclides that are not determined 

primarily by measurement an LLD analog, 

i.e., a reporting threshold must be used when it is technically feasible. Identify all instances when this occurs and the form of the documentation of these activities. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

Gamma: LLDs for 238Pu, 240Pu and 242Pu are derived from the 

measured 239Pu value; the LLD for 90Sr is based on the 

measured 137Cs value. 

Neutron: The Active and Passive Mode LLDs are derived by 

application of isotopic ratios to the measured 239PuEFF and 

240PuEFF, respectively. Sample values based on a 239PuEFF value of 10 mg are shown in BII-5183-CVR-001, Table 12. 

Identify any/all instances where an LLD value for a non-measured radionuclide is not 

provided basis on a lack of technical 

feasibility. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

For gamma assays ORNL-CCP personnel stated that the

determination of a unique reporting threshold for 234U is not 

technically feasible. There are no instances where a unique reporting threshold in not provided on the basis of a lack of technical feasibility for neutron-based assays. 

Are LLD values container/assay event specific or are typical LLD values applied to a class or type of wastes, i.e., those with similar attributes? If LLD values are not container/assay event specific identify the attributes or characteristics whereby waste containers are grouped. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

Gamma: LLD values are assay-event specific 

Neutron: Active and Passive Mode LLD values are assayevent specific and are provided as a function of the ABSMOD 

and MOD indices, respectively. 

Total Measurement Uncertainty (TMU) The method used to calculate the TMU for all required quantities must be documented and technically justified. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The method used to calculate the TMU for all three operational modes of the DWAS are technically adequate and 

appropriately documented. 
ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13 – 15, 2007

NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/S

NDA-7 

Required Technical Elements Y/N Location Verification of Activity Y

TMU determination accounts for all sources of uncertainty, specifically 

• Random errors • Calibration • Isotopic determination • Matrix inhomogeneity • Difference between calibration 

assumptions and actual waste 

• Non uniform source distribution 

• End effects • Self absorption • Transmission source • Self shielding • Neutron multiplication 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The TMU determination accounts for all sources of uncertainty for the three operational modes of the DWAS. 

Methods to determine TMU must be documented, reviewed and approved by CBFO for each NDA instrument. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

Approval of TMU for the DWAS was performed as part of 

the CBFO audit that occurred concurrently with this EPA inspection. 

N
ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13 – 15, 2007

NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/S

NDA-8 

Required Technical Elements Y/N Location Verification of Activity Y/

System Calibration Each NDA instrument must be calibrated 

before its initial use. Determine the date of 

the system’s calibration of record and where this is documented. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The DWAS was calibrated prior to use for WIPP assays at ORNL-CCP. The calibration reports listed provide all 

necessary information regarding the system’s calibration. Calibration reports for the gamma and neutron operational modes had minor problems, as indicted in several places in 

this checklist, all of which were fixed in the revised documents that ORNL-CCP submitted following the inspection. This checklist shows both revisions for the gamma and neutron calibration reports. 

Y 

The range of applicability of the system ‘s calibration(s) must be specified in site 

procedures or other formal documentation. 

Identify the manner in which the range is expressed, i.e., curies (or mass) of Pu/SNM for activity and salient physical characteristics for matrix. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

Gamma: Calibrated range is LLD to 45 g Total Pu (administrative limit), limited by system performance; 

efficiency range is 59 to 1332 keV; matrix is generally Z<15, density from 0 to 0.72 g/cm

3 (Summed Spectrum 

Mode) 

Neutron: Active Mode range is LLD to 14.710 g 239PuEFF,

ABSMOD range 22.251 to 276.800; Passive Mode range is LLD to 2.050 g 240PuEFF, MOD range from 1.045 to 17.572 

Y 

Any matrix/source surrogate waste combinations must be representative of the activity ranges and relevant waste matrix characteristics currently in use or planned for use by the system. The system must be calibrated to 100% recovery. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The matrix/source surrogate waste combinations used for calibration are representative of the activity ranges and relevant waste matrix characteristics of the wastes within the scope of this inspection. The DWAS is calibrated to 

100% recovery for all three operational modes. 

Y 
ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13 – 15, 2007

NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/S

NDA-9 

Required Technical Elements Y/N Location Verification of Activity Y/

The use of consensus standards for calibration is required, when such standards exist. If consensus standards do not exist, the calibration technique must be approved 

by CBFO. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

Consensus standards were used to calibrate the DWAS; 

ASTM-C-1030, C-1133, C-1215 and E-181 for gamma; 

NUREG/CR-5550 (LA-UR-90-732) for neutrons 

Y 

Identify the specific consensus standards that were used for the system calibration or, in their absence, the alternate calibration technique. Evaluate the CBFO approval of the alternate technique. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

See response to previous checklist entry. Y 

Primary standards must be obtained from suppliers maintaining a nationally accredited measurement program. Identify the nationally accredited measurement program. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

All primary standards were obtained from suppliers that maintain a nationally accredited measurement program; Isotope Products Laboratory and LANL 

Y 
ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13 – 15, 2007

NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/S

NDA-10 

Required Technical Elements Y/N Location Verification of Activity Y/

List the standards used for calibration and verify the pedigree of each standard. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The gamma and neutron standards used for calibration are listed in the calibration reports and their pedigrees have 

been verified. 

Y 

Calibration Verification & Confirmation Verification of an NDA instrument’s calibration must be performed after any of the following occurrences: major system repairs and/or modifications, replacement of the system’s components, significant changes to the system’s software, and relocation of the system. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The gamma, active and passive neutron calibrations have 

been verified as required. 

Y 

Recalibration of the system must occur if the calibration verification demonstrates that the system’s response has significantly changed. 

NA CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

A system recalibration has not occurred. N
ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13 – 15, 2007

NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/S

NDA-11 

Required Technical Elements Y/N Location Verification of Activity Y/

The system calibration must be confirmed by 

performing replicate measurements of a noninterfering matrix. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The calibration confirmations for gamma, active neutron and passive neutron have been performed. 

Y 

Replicate measurements must be performed with containers of the same nominal size and according to the same procedures used for actual waste assays. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

Replicate measurements were performed with containers of the same size and with the same procedures used forroutine waste assays for all three operational modes 

Y 

Replicate measurements must be performed using nationally recognized standards or standards derived from nationally recognized standards that span the range of use of the instrument with respect to disintegration rate and/or matrix effects. Identify all standards that were used and indicate their application (verification or confirmation). 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

Replicate measurements were performed using standards derived from nationally recognized standards that span the range of use of the instrument with respect to disintegration rate and/or matrix effects. All standards that were used and their applications are documented. The instrument calibration reports cited provide all required information relative to the DWAS calibration.. 

Y 

Identify the nationally accredited measurement program. List the standards used for verification/confirmation and verify the pedigree of each standard. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

See previous checklist entry. Y 
ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13 – 15, 2007

NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/S

NDA-12 

Required Technical Elements Y/N Location Verification of Activity Y/

The standards used for calibration confirmation must not be the same sources as those used for the system’s calibration of record. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The standards used for calibration confirmation were distinct from those that were used for the calibration of all three operational modes. 

Y 

Requirements for accuracy, expressed as %R, and precision, expressed as %RSD, must be met as specified in DOE/WIPP-02-3122, Appendix A, Table A-3.2 for precision as a function of the number of replicates that were measured and 

∀30% for accuracy. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

Requirements for accuracy and precision that are specified in DOE/WIPP-02-3122, Appendix A, Table A-3.2 were met for all three operational modes except for the 32 g Pu 

(nominal) standard that failed due to low bias. This failure was attributed to self-absorption of the encapsulated source for which a correction factor can be applied. 

Y 
ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13 – 15, 2007

NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/S

NDA-13 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Quality Control All radioassay and data validation must be 

performed by appropriately trained and 

qualified personnel. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

Personnel performing radioassay and data validation are appropriately trained and qualified.

Y OR

Qu1:5inspIPAVal

Identify the name, title and function of all 

personnel performing NDA data validation. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

Expert Analysts (EAs) are Bob Ceo, Alan Simpson, John West and George Westsik. Independent Technical Reviewers (ITRs) are Barry Smith, Ron Whitson and Debbie Satterfield 

Y OR

Qu1:5insp

Requalification of personnel must be based on evidence of continued satisfactory 

performance and must be performed at least 

every two years. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

Training for all DWAS Operators, EAs and ITRs were current. 

Y OR

Qu1:5insp

The site must participate in relevant measurement comparison programs sponsored or approved by CBFO, including the NDA PDP. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The DWAS had participated in NDA PDP Cycle 13A prior to its use by ORNL-CCP for WIPP assays. The DWAS is registered to participate in future PDP cycles 

Y Per

for RegCha

Background and Performance Checks Assay system background measurements must be taken daily, unless otherwise approved by CBFO. Determine the form of CBFO approval documentation of the alternate approach to backgrounds, if applicable. Contributions to backgrounds from nearby radiation sources must be carefully controlled, or more frequent 

backgrounds must be measured. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The DWAS BDRs reviewed provide evidence of appropriate background measurements. 

Y DW

DW
ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13 – 15, 2007

NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/S

NDA-14 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Assess how often background radiation was 

problematic to the extent that measurement personnel had to make adjustments. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

No instances of this were observed in the BDRs 

evaluated during this inspection. 

NA 

Identify the criteria used to evaluate instrument backgrounds and assess the technical adequacy of this criterion, i.e., statistical or administrative. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The criteria for gamma and neutron assays are 

provided in the operating procedures and 

calibration reports for the SGS and IPAN operational modes. 

Y Rev

172CCMV

Identify the number of data points required to derive the initial control limit. At what interval(s) will new limits be calculated? 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The initial gamma control limits that are statistical in nature were derived using 5 points 

System performance checks must be 

performed at least once per operational day. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The DWAS BDRs evaluated for this inspection document performance checks at the required intervals. 

Y DW

DWCC166

System performance checks must include, as applicable, efficiency, matrix correction checks, and systems peak position and resolution for spectrometric systems. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

Gamma checks include 344.3 keV centroid and Full-Width-at-Half-Maximum (FWHM), 

background, transmission and calibration checks 

and Weighted Mean Activity. Neutron checks include Raw Coincidence Count rate, 239PuEFF 

Mass and 240PuEFF Mass 

Y DW

DWCC

At a minimum of once per operational week an interfering matrix must be assayed to assess the long-term stability of the NDA instrument and its matrix corrections and how this performance is documented. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The DWAS BDRs evaluated for this inspection document interfering matrix checks at the required intervals. 

Y DW

DWCC169

Interfering surrogate waste matrices must be constructed in a way that the salient matrix characteristics do not change over time. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, 

Surrogate matrices are constructed appropriately. Y BII

CalRevCA
ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13 – 15, 2007

NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/S

NDA-15 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Revision 19 Sca

ConRev

The radionuclide sources used for 

performance checks must be long-lived and 

of sufficient strength (activity) to provide statistically sufficient results over a short measurement time. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The radionuclide sources used for performance checks are technically appropriate. 

Y BII

CalRevCAScaConRev

Radioactive sources are decay corrected as a function of their physical half life, as appropriate, specifically133Ba, 252Cf, 137Cs, 75Se and 109Cd. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

Decay corrections for the 252Cf (240PuEFF Mass) are 

performed as required 

Y CC

4.2DWDW

Performance checks must be quantitative and 

based on 2 and 3 sigma limits. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

Gamma control limits are non-statistical (background, transmission source peak centroid, FWHM and count rate) 

Y CC

& 4
ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13 – 15, 2007

NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/S

NDA-16 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Data Management All radioassay data must be reviewed and approved by qualified personnel before being reported to WWIS. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

All radioassay data examined during this inspection contained evidence of review and approval by qualified personnel, i.e., ITRs and EAs, as appropriate. 

Y D

ODR

Identify the name, title and function of the individual(s) performing technical review and approval of NDA BRDs. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

EAs are Bob Ceo, Alan Simpson, John West, George Westsik. ITRs are Barry Smith, Ron Whitson and Debbie Satterfield 

Y O

Q2t

Radioassay BDRs must consist of the following elements: 

• Testing facility name, testing batch 

number, container numbers, and signature of the Site Project Officer (SPO) or designee(s) 

• Table of Contents 

• Background and performance check data 

or control charts for the relevant time 

period. 

• Data validation per the QAPD and site 

procedures 

• Separate testing report sheets for each 

container. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The DWAS BDRs that were reviewed during this inspection contained all required elements. 

Y D

OD
ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13 – 15, 2007

NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/S

NDA-17 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Radioassay data sheets must include: 

• Title “Radioassay Data Sheet” 

• Method/procedure used 

• Date of radioassay 

• Activities and associated TMU for 

individual radionuclides 

• TRU alpha concentration and its 

associated TMU 

• Operator signature 

• Reviewer signature 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan, Revision 19 

The radioassay data sheets from the DWAS BDRs that were reviewed contained all required elements. 

Y O

XOXOX

The following nonpermanent records must be maintained at the radioassay-testing facility or forwarded to the site project office: 

• Testing batch reports 

• All raw data, including instrument 

readouts, calculation records, and radioassay QC results 

• All applicable instrument calibration 

reports 

NA Not Applicable Not assessed during this inspection NA 
RTR-1 

ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective E

RTR-1: Site procedures identify required training and qualifications for RTR personnel. 

 CCP-TP-028, Revision 3 CCP-QP-002, Revision 25 

• Operator training was consistent with 

applicable procedures. 

• Operator certification is current. 

• OJT was documented for each operator. • Operators are re-qualified every two years. 

• RTR operators passed a training drum test 

that includes items common to the waste streams examined at the site (biannually.) 

• RTR operators receive training on the waste 

matrix parameters and typical packaging configurations expected in each waste stream.

Y There are four qualif

the site, all of whom or October 2007. At were transferred to OSite and have considexecution of RTR exDuring the inspectionof the capability demradiography personnerecordings for the latcontainer for the drum viewed during the in

performing the on-sit

copy of the AK SumORNL-001, available 

physical form of the 

records reviewed ind

personnel were opera

The operator/ITRs suthe prohibited items cdrum. However, the demonstrated that theof the unknown itemcardboard and a plastgenerated concern Oto address this issue. 

ORNL-CCP-CH-RTR

In the capability democontainers, the EPA inthe required prohibitecorrectly by all RTR oitems (cellulosics and identified. All cellulotraining drum need to 
RTR-2 

ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective E

identification documetraining process, it is receives feedback regdetailed documentationeeded when the resureviewed.

Objective evidence:

1. Radiography Da

demonstration fooperators/ITRs, 

2. Audio/visual rec

capability demonoperators/ITRs, 

3. Inventory for tra

TEST-001 and O

RTR-2: Site procedure(s) provide complete instructions for operators to perform the RTR examination and completion of the associated documentation. 

CCP-TP-053, Revision 5 

• RTR operator adequately explained the 

process followed for examining a drum and 

entering data into data forms (whether hard copy or electronic data entry is used). 

Y EPA observed the RT

X10C0501308, Batch operator performed ththe items identified. Texplain and demonstrentered into the electr2) and how WMP we

procedure used contai

performing RTR exam

The procedure was imWhen opened, the temand 2 of procedure CCcontained some RTR incorrect reporting of EPA generated conce001CR to address this 
RTR-3 

ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective E

ORNL-CCP-CH-RTR

When the templates u1 and 2 of CCP-TP-05on-site RTR demonstrwere already answere• Attachment 1, CCP Report, had check maquestions for “Video/System Check” and “were checked to indic(satisfactory). • The entries to indica

pair/cm had already b

“25.” • Attachment 2, CCP Section 3, contained e“plastic,” and the quewith the container?” wwhen the form was redisappear. Objective evidence:

1. RTR Batch Data 

OR-RTR6-003, Odebris waste) 

2. Audio/visual reco

drums from the a

RTR-3: The RTR procedure(s) require an image quality check to be 

performed. 

CCP-TP-053, Revision 5, Section 4.3 

• Operator adequately explained how the 

acceptability of an image is determined. 

• Image quality (IQI) check is performed once 

Y CCP at ORNL does n

generate a linear diodAt the time of the on-
RTR-4 

ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective E

per day. 

• LDA acceptability test performed at 

beginning of each shift. 

• Performance of the image quality check is 

documented and recorded. 

operators had already audio/visual check. Everify the written recoRTR image. As a furAttachment 1, RTR Mfor all seven of the BDthe inspection. Objective evidence:

1. CCP-TP-053, Att

Measurement Cocompleted BDRs 

2. CCP-TP-053, Att

Radiography Datdrum X10C05013

RTR-4: The procedure allows the operator to adjust the RTR to accommodate the physical properties of the waste and waste containers likely to be encountered at the site. 

CCP-TP-053, Revision 5, Section 4.4 

• Operator could identify applicable policies 

and procedures governing the operation of RTR equipment. 

• The RTR system could be adjusted. 

• High-density material was examined with the 

X-ray device set on the maximum voltage and low density material at a lower voltage. 

• Operator adequately explained what is done if 

an image is unacceptable (e.g., the waste is solidified or the container is lead-lined). 

Y During the RTR demo

adjusted the unit to mThe RTR operators inknowledgeable and abasked by EPA. Durinoperator changed the the density of differen

unit as needed to obta

waste items. The operators were ab

process and in what cbe initiated. EPA rev

ensure that they were accordance with site pObjective evidence:

1. RTR Batch Data 
RTR-5 

ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective E

OR-RTR6-003, Odebris waste) 

2. Nonconformance 

ORNL-0101-07 a

RTR-5: CCP-TP-053, 

Revision 5, Section 4.3 

• RTR tape is high quality, the sound track is 

audible, and the required information is contained on the audible portion of the tape. 

• The RTR tape is consistent with the data 

package for the same drum. 

Y EPA compared the wr

audio/visual recordincontainers to ensure c

X10C0501101 X10C0501391 X10C0501179 

EPA did not identify written and audio/visucontainers. Objective evidence:

1. RTR Batch Data 

OR-RTR6-003, O

2. Audio/visual reco

X10C0501101, XX10C0501179 

RTR-6: There is a procedure for determining whether the waste matches the waste stream description and Waste Matrix Code, and for determining Waste Material Parameters and weights. 

CCP-TP-053, Revision 5, Section 4.4, Table 3, Attachment 2 

• The procedure is adequately implemented. 

• Operators verify that the waste matches the 

waste stream description. 

• Waste Matrix Code is verified. If not, 

corrective action is taken. 

• WMP weights are estimated by compiling an 

inventory of waste items and residual/packaging materials. 

• Does the RTR operator use a standard weight 

Y During the on-site dem

scanned the container instructions contained were identified and endata sheet. At the end WMP weights were e

procedure contains a tprovides standard wei

list is not comprehensexperience and traininDuring the demonstra
RTR-6 

ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective E

lookup table to provide an estimate of WMP weights? If so, has the table been updated to reflect additional information gained through 

previous RTR/VE exams or updated AK 

information? 

“jogged” the drum to 

presence/absence of f

As part of the demonsthat the waste matchedescription and the Wabsence/presence of precorded on the data sdemonstration. Objective evidence:

1. CCP-TP-053, Att

Radiography Datdrum X10C0501

2. RTR Batch Data 

OR-RTR6-003, Odebris waste) 

3. Audio/visual reco

drums from the a

RTR-7: The RTR procedure 

provides instructions for identifying prohibited items and for processing 

drums containing prohibited. 

CCP-TP-053, Revision 5, Section 4.4, Table 1, Attachment 2 

• Operator could name prohibited items 

• Operator adequately explained how the 

presence of free liquids is determined. 

• Operator’s explanation of required actions if 

prohibited items were encountered was 

consistent with procedure. 

• Corrective actions are taken when necessary. 

 The operators intervie

questions and were ex

performance of RTR 

demonstration, the opdrum to determine the During the interview, stated when an NCR wObjective evidence:

1. RTR Batch Data 

OR-RTR6-003, Odebris waste) 

2. Nonconformance 

ORNL-0101-07 a
RTR-7 

ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective E

RTR-8: RTR procedures include the required QC examinations, evaluation accuracy and reproducibility of the RTR process. 

CCP-TP-053, Revision 5, Sections 4.5, 4.6 

• An independent replicate scan is performed 

on one waste container per day or on one container per testing batch (whichever is less frequent). 

• An independent observation of one scan (not 

the replicate) is performed by a qualified RTR operator (anyone but the initial RTR operator). 

Y QC examinations wer

the procedure. In batcindependent observaticontainer X10C05011

performed on contain

OR-RTR6-003, an ind

performed on contain

replicate scan was perX10C0506048. In baindependent observaticontainer X10C05014

performed on contain

samples were performfrom the original evenresults is only require

between operators wit

Matrix Code, liquids, (CCP-TP-053, Sectiogenerated concern ORaddress this issue. ORNL-CCP-CH-RTR

The replicate and orig

performed in batch O

Container X10C0506the percent fill factor, in the recorded WMP requires reconciliation “identification of the excess of TSDF-WAC gases differ between tsame situation applies original observations. complies with the reqSections 4.5.3 and 4.6
RTR-8 

ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8

Inspection Date: November 13-15, 2007

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective E

requirement for a systdemonstrate consistenof waste attributes. A defined for waste attriObjective evidence:

1. RTR Batch Data 

OR-RTR6-003, Odebris waste) 

RTR-9: Procedure(s) contain standardized forms for recording RTR data. 

CCP-TP-053, Revision 5, Attachment 1 and 2 

• RTR operator adequately explained the 

process followed for examining a drum and 

entering data into data forms (whether hard copy or electronic data entry is used). 

• Direct data entry into an electronic form is 

done by the RTR operator using a computer, while the operator is still in the RTR booth. 

• The electronic data file undergoes the same 

quality control (QC) checks used for handwritten data entries. 

Y EPA observed the ope

electronic data form (demonstration drum Xwere made as requiredthe time of the examinoperator performing tAttachments 1 and 2 aof the BDR, which unlevel review. Objective evidence:

1. RTR Batch Data 

OR-RTR6-003, Odebris waste) 

RTR-10: Site procedures require review of Batch Data Reports (BDRs) at the data generation and 

project level. 

CCP-TP-053, Revision 5, Attachment 3 CCP-TP-001, Revision 17, Attachment 2 

• Data generation level reviews are performed 

and documented (ITR). 

• Project level reviews are performed and 

documented (SPM). 

Y All of the BDRs revie

reviewed at both the g(SPM) level. The revcomplete and signed a

Objective evidence:

1. RTR Batch Data 

OR-RTR6-003, Odebris waste) 
RTR-9 

Information Included in BDR 

Required Testing Batch Content Present 

Y or N 

Required Testing Batch Content Present 

Y or N 

Required Testing Batc

Batch Date  Verification that waste matches waste stream description  Container gross weight Report Date  Estimated weights for Waste Material Parameters  Reference to or copies of aWaste Container Number  Layers of confinement  Operator signature and tesWaste Matrix Code  Indication of vented rigid liners  Data generation checklist Videotape reference  Description of container contents  Project level checklist Description of liners  Indication of sealed containers >4L QC documentation  Amount of free liquid 
Revision No.: 1.0 WWIS-1 

ATTACHMENT A.4: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECK

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13-15, 2007

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objectiv

WWIS-1: WWIS and Data Entry Personnel must be trained to assess data and properly enter data into the WWIS. 

Y 

CCP-TP-030, Revision 22, Section 2.2; CCP-QP-002, Revision 25 

WCO and Data Entry Personnel are trained to assess data and properly enter and transfer all data in the WWIS. Training for Data Entry Personnel and data reviewers/verifiers include the WIPP Waste Information System User’s Manual and the applicable site procedures. Training records are available for review and are complete. 

Y Training for WCA and 

Waste Information Sytraining. WCO/WCAMexico, where data entraining records contaiCard for a WCA/WCO inspection. The traininthis position. 

Objective evidence rev

1. Qualification Card 

WWIS-2: Security measures for ensuring data integrity and accessing WWIS are sufficient. 

Y 

CCP-TP-030, Revision 22, Section 4.1 

Access to WWIS is controlled. WWIS access requests are recorded in an access log, however named, that is available for review. 

Y The WWIS Data Admi

CCP requests access fo

password are transmitt

Data Administrator in the WWIS access log. Objective evidence:

1. List of Qualified In

WWIS-3: There are adequate 

procedures for entering data into the 

WWIS and transmitting data to WIPP. 

Y 

CCP-TP-030 Revision 22, Section 4.0 

Employee’s explanation of job duties was consistent with applicable procedures. WWIS and Data Entry Personnel adequately explained how data are assessed, input, and transferred into WWIS. 

Y Data entry and WWIS 

takes place in Carlsbaddemonstration, a WCAinspection. An Excel scharacterization or certcompletion, the spread

initials of personnel en

data are recorded on thsummary, the WCO acWWIS. After the spreathe WCO, flat files are WWIS. All container N

entry. At the time of the on-sireceive ORNL data, buable to demonstrate the 
Revision No.: 1.0 WWIS-2 

ATTACHMENT A.4: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECK

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13-15, 2007

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objectiv

WWIS. Objective evidence rev

1. MS Excel 2000 an

container LA0000

2. Waste Container D

LA00000062113 

3. MS Excel 2000 an

container 1008682

4. Waste Container D

WWIS-4: Procedures require that only verified and validated data are entered into WWIS. 

Y 

CCP-TP-030, Revision 22, Table 1 

Data generation and project level reviews of container data for WWIS entry have been 

performed and review checklists are complete. 

Y At the time of the on-si

receive ORNL data but able to demonstrate the through SPM review an

WWIS data entry. Objective evidence rev

1. MS Excel 2000 an

container LA0000

2. Waste Container D

LA00000062113 

3. MS Excel 2000 an

container 1008682

4. Waste Container D

5. RTR Batch Data R

003, OR-RTR6-00

WWIS-5: Procedures include instructions for submission of data into the Characterization and the Certification module of WWIS. 

Y 

CCP-TP-030 Revision 22, Sections 4.3 – 4.5 

To enable Waste Stream Profile Form approval, data are entered into the Characterization module of WWIS on a container basis. To obtain shipping certification of a container, 

Y At the time of the on-si

receive ORNL data, buable to demonstrate the data into the Test Insta

and non-compliant data
Revision No.: 1.0 WWIS-3 

ATTACHMENT A.4: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECK

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13-15, 2007

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objectiv

data are entered into the Certification module of WWIS. 

Stream Profile Form (Winto the CharacterizatioWSPF approval, data wmodule of WWIS. Objective evidence rev

1. MS Excel 2000 an

container LA0000

2. Waste Container D

LA00000062113 

3. MS Excel 2000 an

container 1008682

4. Waste Container D

WWIS-6: Procedures include a requirement for review of data prior to submission to WWIS. 

Y 

CCP-TP-030, Revision 22, Section 4.3, 4.4 

There is an independent review of data prior to submission to WIPP via the WWIS. Procedures for resolution/correction of nonconforming data are adequately implemented. 

Y A WCA enters data an

WCA. Prior to WWIS data contained on the s

that do not allow incorrThe initials of the reviespreadsheet. If data ar

NCR for the rejected d

resubmits the data to WObjective evidence rev

1. MS Excel 2000 an

container LA0000

2. MS Excel 2000 an

container 100868

3. NCR NCR-INL-0

WWIS-7: There are adequate 

procedures for entering data into the 

WWIS and transmitting the data to 

Y 

CCP-TP-030, 

The site has successfully submitted characterization and certification data to WIPP 

Y CCP has successfully s

certification data for mWIPP via WWIS. The 
Revision No.: 1.0 WWIS-4 

ATTACHMENT A.4: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECK

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13-15, 2007

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objectiv

WIPP. Revision 22, Section 

4.0 

via WWIS. certified containers to d

Objective evidence rev

1. MS Excel 2000 an

container LA0000

2. Waste Container D

LA00000062113 

3. MS Excel 2000 an

container 100868

4. Waste Container D

WWIS-8: Procedures provide instructions for data correction if data are rejected by WWIS. 

Y 

CCP-TP-030, Revision 22, Section 4.3-4.4 

E-mail notifications from WWIS (acceptance/modification/rejection of data) If data are rejected by the WWIS Data Administrator, processes for data reconciliation/correction are implemented. 

Y WWIS contains checks 

unusable data to be upldemonstration the WCthe existing spreadsheeupload this into WWISrequired and provided for rejection. If data ar

data corrected, and the Objective evidence rev

1. MS Excel 2000 an

container LA0000

2. Waste Container D

LA00000062113 

3. MS Excel 2000 an

container 100868

4. Waste Container D

WWIS-9: Procedures for waste container characterization/certification data submittal to WWIS require the 

Y 

CCP-TP-030, Revision 22, Section 5.0 

WWIS access requests WWIS access logs Waste container data input reports

Y CCP was able to retriev

list of qualified individand training records. 

Objective evidence rev
Revision No.: 1.0 WWIS-5 

ATTACHMENT A.4: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECK

EPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8 

Inspection Date: November 13-15, 2007

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objectiv

appropriate records to be retained. 1. MS Excel 2000 an

container LA0000

2. Waste Container D

LA00000062113 

3. MS Excel 2000 an

container 100868

4. Waste Container D5. List of Qualified I

WWIS-10: NA Plans and procedures for payload management 

have been approved by CBFO. CBFO informed EPA prior to approving the site to payload- manage containers. TRU alpha activity concentration is > 100 nCi/g for the entire waste stream. Only waste containers from the same waste stream are payload managed in the same 

payload container. 

Each waste container selected for payload management contains at least one TRU isotope. TRU alpha activity concentration of the 

payload container is determined and reported.

NA At the time of the inspe

informed EPA of their waste at ORNL. 
Revision No.: 1 WWIS-6 Date of Revision: 10/20/05

WWIS Data Requirements 

Characterization Module Data Fields 

Partial List 

This table was not completed because ORNL data were not entered in WWIS at the time of the 

inspection. 

Container ID - Pu 239 equivalent activity - 

Generator EPA ID – present Pu 239 fissile gram equivalent - 

Site ID - Pu 239 FGE uncertainty - present 

Waste Stream Profile Number - Radionuclide name 

Waste Matrix Code - Radionuclide activity 

Waste Matrix Code Group - Radionuclide activity uncertainty 

Waste Material Weight - Radionuclide mass 

Waste Material Parameter - Radionuclide mass uncertainty 

Hazardous Code - Radioassay method - 

Layers of packaging - Assay date - 

Liner exists - Characterization method - 

Filter model - Characterization method date - 

Number of filters installed - Alpha surface concentration - 

TRUCON code - Dose rate - 

Decay heat – present - Sample ID - 

Decay heat uncertainty - Sample type - 

TRU alpha activity - Sample date - 

TRU alpha activity uncertainty - Analyte - 

TRU alpha activity concentration - Analyte concentration - 

TRU alpha activity concentration uncertainty - Analyte detection method - 

Waste type code - Analyte detection method - 

Certification Module Data Fields 

Container ID - Container Certification date - 

Container Type - Container Closure date - 

Container weight - Handling Code - 

Contact Dose Rate - 
B-1 

ATTACHMENT B.1: REPLICATE TESTING DATA FOR CONTAINER X10C05011

Instrument: DWAS/IPAN/SGS

Container: X10C0501112

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238Pu Activity (Ci) 3.51E-04 1.06E-04 3.03E-01 2.42E-04 7.31E-05 3.02E-01 2.51E-0239Pu Activity (Ci) 2.63E-03 7.06E-04 2.68E-01 1.82E-03 4.85E-04 2.67E-01 1.89E-0240Pu Activity (Ci) 9.43E-04 2.85E-04 3.03E-01 6.50E-04 1.96E-04 3.02E-01 6.75E-0242Pu Activity (Ci) 2.23E-07 6.76E-08 3.03E-01 1.54E-07 4.65E-08 3.02E-01 1.60E-0241Am Activity (Ci) 1.78E-03 5.40E-04 3.03E-01 1.23E-03 3.71E-04 3.02E-01 1.28E-090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0TRU Alpha Conc. (nCi/g) 2.10E+02 5.76E+01 2.74E-01 1.45E+02 3.96E+01 2.73E-01 1.50E+0

Replicate #3 Replicate #4 

Quantity of Relative Relative Reported Reported Reported Relative ReporteInterest Uncertainty Uncertainty Value Value Value Uncertainty Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238Pu Activity (Ci) 2.84E-04 8.49E-05 2.99E-01 3.39E-04 1.02E-04 3.01E-01 2.69E-0239Pu Activity (Ci) 2.13E-03 5.62E-04 2.64E-01 2.55E-03 6.76E-04 2.65E-01 2.02E-0240Pu Activity (Ci) 7.63E-04 2.28E-04 2.99E-01 9.11E-04 2.74E-04 3.01E-01 7.24E-0242Pu Activity (Ci) 1.81E-07 5.40E-08 2.99E-01 2.16E-07 6.49E-08 3.01E-01 1.71E-0241Am Activity (Ci) 1.44E-03 4.32E-04 2.99E-01 1.72E-03 5.18E-04 3.01E-01 1.37E-090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0TRU Alpha Conc. (nCi/g) 1.70E+02 4.59E+01 2.70E-01 2.03E+02 5.52E+01 2.72E-01 1.61E+0
B-2 

ATTACHMENT B.2: REPLICATE TESTING RESULTS FOR CONTAINER X10C050

Instrument: DWAS/IPAN/SGS

Container: X10C0501112

Original Measurement Sample Relative 

Quantity of Reported Absolute Sample Standard Standard Interest Value Uncertainty Mean Deviation Deviation χ2 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VAL234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VAL238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VAL238Pu Activity (Ci) 3.51E-04 1.06E-04 2.77E-04 3.83E-05 1.38E-01 5.19239Pu Activity (Ci) 2.63E-03 7.06E-04 2.08E-03 2.87E-04 1.38E-01 6.63240Pu Activity (Ci) 9.43E-04 2.85E-04 7.45E-04 1.03E-04 1.38E-01 5.20242Pu Activity (Ci) 2.23E-07 6.76E-08 1.76E-07 2.44E-08 1.38E-01 5.19241Am Activity (Ci) 1.78E-03 5.40E-04 1.41E-03 1.95E-04 1.38E-01 5.1990Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VAL137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALTRU Alpha Conc. (nCi/g) 2.10E+02 5.76E+01 1.66E+02 2.29E+01 1.38E-01 6.33

Quantity of Interest t Pr(x <|t|) χ2 Test t Test 233U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A #VALUE! Not Applicable 238U Activity (Ci) N/A N/A #VALUE! Not Applicable 238Pu Activity (Ci) 1.76E+00 1.53E-01 Not Significant Not Significant 239Pu Activity (Ci) 1.76E+00 1.53E-01 Not Significant Not Significant 240Pu Activity (Ci) 1.76E+00 1.53E-01 Not Significant Not Significant 242Pu Activity (Ci) 1.76E+00 1.53E-01 Not Significant Not Significant 241Am Activity (Ci) 1.76E+00 1.53E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A #VALUE! Not Applicable 137Cs Activity (Ci) N/A N/A #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) 1.76E+00 1.53E-01 Not Significant Not Significant 
B-3 

ATTACHMENT B.3: REPLICATE TESTING DATA FOR CONTAINER X10C05012

Instrument: DWAS/IPAN/SGS

Container: X10C0501270

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238Pu Activity (Ci) 4.23E-04 1.22E-04 2.88E-01 3.68E-04 1.06E-04 2.88E-01 3.98E-0239Pu Activity (Ci) 3.17E-03 7.99E-04 2.52E-01 2.77E-03 6.94E-04 2.51E-01 2.99E-0240Pu Activity (Ci) 1.14E-03 3.28E-04 2.88E-01 9.90E-04 2.85E-04 2.88E-01 1.07E-0242Pu Activity (Ci) 2.69E-07 7.76E-08 2.88E-01 2.34E-07 6.75E-08 2.88E-01 2.53E-0241Am Activity (Ci) 3.11E-03 1.25E-03 4.02E-01 2.39E-03 7.52E-04 3.15E-01 4.26E-090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0TRU Alpha Conc. (nCi/g) 4.31E+02 1.21E+02 2.81E-01 3.58E+02 9.37E+01 2.62E-01 4.79E+0

Replicate #3 Replicate #4 

Quantity of Relative Relative Reported Reported Reported Relative ReporteInterest Uncertainty Uncertainty Value Value Value Uncertainty Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238Pu Activity (Ci) 3.90E-04 1.12E-04 2.88E-01 3.86E-04 1.11E-04 2.88E-01 4.15E-0239Pu Activity (Ci) 2.93E-03 7.35E-04 2.51E-01 2.90E-03 7.26E-04 2.51E-01 3.12E-0240Pu Activity (Ci) 1.05E-03 3.02E-04 2.88E-01 1.04E-03 2.98E-04 2.88E-01 1.12E-0242Pu Activity (Ci) 2.48E-07 7.14E-08 2.88E-01 2.45E-07 7.07E-08 2.88E-01 2.64E-0241Am Activity (Ci) 1.98E-03 5.71E-04 2.88E-01 1.96E-03 5.64E-04 2.88E-01 2.11E-090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0TRU Alpha Conc. (nCi/g) 3.49E+02 8.99E+01 2.58E-01 3.45E+02 8.89E+01 2.58E-01 3.71E+0
B-4 

ATTACHMENT B.4: REPLICATE TESTING RESULTS FOR CONTAINER X10C050

Instrument: DWAS/IPAN/SGS

Container: X10C0501270

Original Measurement Sample Relative 

Quantity of Reported Absolute Sample Standard Standard Interest Value Uncertainty Mean Deviation Deviation χ2 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VAL234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VAL238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VAL238Pu Activity (Ci) 4.23E-04 1.22E-04 3.92E-04 1.71E-05 4.36E-02 7.83239Pu Activity (Ci) 3.17E-03 7.99E-04 2.94E-03 1.28E-04 4.36E-02 1.03240Pu Activity (Ci) 1.14E-03 3.28E-04 1.05E-03 4.59E-05 4.36E-02 7.83242Pu Activity (Ci) 2.69E-07 7.76E-08 2.49E-07 1.09E-08 4.36E-02 7.84241Am Activity (Ci) 3.11E-03 1.25E-03 2.54E-03 9.78E-04 3.85E-01 2.46E90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VAL137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALTRU Alpha Conc. (nCi/g) 4.31E+02 1.21E+02 3.80E+02 5.62E+01 1.48E-01 8.62

Quantity of Interest t Pr(x <|t|) χ2 Test t Test 233U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A #VALUE! Not Applicable 238U Activity (Ci) N/A N/A #VALUE! Not Applicable 238Pu Activity (Ci) 1.68E+00 1.69E-01 Not Significant Not Significant 239Pu Activity (Ci) 1.68E+00 1.69E-01 Not Significant Not Significant 240Pu Activity (Ci) 1.68E+00 1.69E-01 Not Significant Not Significant 242Pu Activity (Ci) 1.67E+00 1.69E-01 Not Significant Not Significant 241Am Activity (Ci) 5.26E-01 6.26E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A #VALUE! Not Applicable 137Cs Activity (Ci) N/A N/A #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) 8.16E-01 4.60E-01 Not Significant Not Significant 
B-5 

ATTACHMENT B.5: REPLICATE TESTING DATA FOR CONTAINER X10C05059

Instrument: DWAS/IPAN/SGS

Container: X10C0505990

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238Pu Activity (Ci) 5.36E-04 1.59E-04 2.96E-01 4.62E-04 1.35E-04 2.93E-01 4.63E-0239Pu Activity (Ci) 4.03E-03 1.05E-03 2.60E-01 3.47E-03 8.89E-04 2.56E-01 3.48E-0240Pu Activity (Ci) 1.44E-03 4.26E-04 2.96E-01 1.24E-03 3.63E-04 2.93E-01 1.25E-0242Pu Activity (Ci) 3.41E-07 1.01E-07 2.96E-01 2.94E-07 8.60E-08 2.93E-01 2.95E-0241Am Activity (Ci) 2.83E-03 1.03E-03 3.64E-01 2.02E-03 7.67E-04 3.80E-01 2.40E-090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0TRU Alpha Conc. (nCi/g) 3.01E+02 8.27E+01 2.75E-01 2.45E+02 6.65E+01 2.72E-01 2.58E+0

Replicate #3 Replicate #4 

Quantity of Relative Relative Reported Reported Reported Relative ReporteInterest Uncertainty Uncertainty Value Value Value Uncertainty Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238Pu Activity (Ci) 7.07E-04 2.06E-04 2.91E-01 4.32E-04 1.27E-04 2.94E-01 9.14E-0239Pu Activity (Ci) 5.31E-03 1.36E-03 2.56E-01 3.24E-03 8.37E-04 2.58E-01 6.86E-0240Pu Activity (Ci) 1.90E-03 7.07E-04 3.72E-01 1.16E-03 3.41E-04 2.94E-01 2.45E-0242Pu Activity (Ci) 4.50E-07 1.31E-07 2.91E-01 2.75E-07 8.08E-08 2.94E-01 5.81E-0241Am Activity (Ci) 3.60E-03 1.05E-03 2.92E-01 2.21E-03 7.55E-04 3.41E-01 4.73E-090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0TRU Alpha Conc. (nCi/g) 3.92E+02 6.17E+01 1.57E-01 2.40E+02 6.48E+01 2.70E-01 5.09E+0
B-6 

ATTACHMENT B.6: REPLICATE TESTING RESULTS FOR CONTAINER X10C050

Instrument: DWAS/IPAN/SGS

Container: X10C0505990

Original Measurement Sample Relative 

Quantity of Reported Absolute Sample Standard Standard Interest Value Uncertainty Mean Deviation Deviation χ2 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VAL234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VAL238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VAL238Pu Activity (Ci) 5.36E-04 1.59E-04 5.96E-04 2.10E-04 3.52E-01 6.97E239Pu Activity (Ci) 4.03E-03 1.05E-03 4.47E-03 1.57E-03 3.52E-01 9.02E240Pu Activity (Ci) 1.44E-03 4.26E-04 1.60E-03 5.63E-04 3.52E-01 6.97E242Pu Activity (Ci) 3.41E-07 1.01E-07 3.79E-07 1.33E-07 3.52E-01 6.97E241Am Activity (Ci) 2.83E-03 1.03E-03 2.99E-03 1.15E-03 3.85E-01 4.98E90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VAL137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALTRU Alpha Conc. (nCi/g) 3.01E+02 8.27E+01 3.29E+02 1.19E+02 3.61E-01 8.24E

Quantity of Interest t Pr(x <|t|) χ2 Test t Test 233U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A #VALUE! Not Applicable 238U Activity (Ci) N/A N/A #VALUE! Not Applicable 238Pu Activity (Ci) -2.59E-01 8.09E-01 Not Significant Not Significant 239Pu Activity (Ci) -2.59E-01 8.09E-01 Not Significant Not Significant 240Pu Activity (Ci) -2.59E-01 8.09E-01 Not Significant Not Significant 242Pu Activity (Ci) -2.59E-01 8.09E-01 Not Significant Not Significant 241Am Activity (Ci) -1.26E-01 9.06E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A #VALUE! Not Applicable 137Cs Activity (Ci) N/A N/A #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) -2.16E-01 8.40E-01 Not Significant Not Significant 
 

C-1 

ATTACHMENT C.1 

INSPECTION ISSUE TRACKING FORM, ISSUE NO. ORNL-CCP-CH-RTR-07-001CR, FINAL 

Inspection No. EPA-ORNL-CCP-CH-11.07-8 Issue Number: ORNL-CCP-CH-RTR-07-001CR, Final 

Date: November 14, 2007 

Inspector: Dorothy E Gill 

Attachments? YES NO 

Sample Size: Not Applicable 

Population size (if known): Not Applicable 

Description of Issue: When the templates used to complete Attachments 1 and 2 of CCP-TP-053 were 

opened during the on-site RTR demonstration some of the questions were already answered. For example:

• Attachment 1, CCP RTR Measurement Control Report, had check marks indicating that the 

questions for “Video/Audio Recorded Media System Check” and “Image Test Pattern Test” were 

checked to indicate that they were “SAT” (satisfactory). 

• The entries to indicate the number of lines-pair/cm had already been filled in to indicate “25”. 

• Attachment 2, CCP Radiography Data Sheet”, Section 3 contained entries for “horsetail” and 

“plastic” and the question “NCR(s) associated with the container?” was checked “No”. Even when 

the form was reset the check marks did not disappear. 

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): 

D. Discussed with: Susan Smith and Lee Smith 

E. Additional Comments: 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: December 10, 2007 
 

C-2 

ATTACHMENT C.2 

INSPECTION ISSUE TRACKING FORM, ISSUE NO. ORNL-CCP-CH-NDA-07-002CR, FINAL 

Inspection No. EPA-ORNL-CCP-CH-11.07-8 Issue Number: ORNL-CCP-CH-NDA-07-002CR, Final 

Date: November 14, 2007 

Inspector: P. Kelly 

Attachments? YES NO 

Sample Size: NA (single document) 

Population size (if known): NA 

Description of Issue: The SGS calibration report MV-SGS0101-CAL-01, Revision 0 did not adequately 

document calibration of this NDA system. The EPA inspector could not determine the adequacy of this 

instrument’s calibration on the basis of the calibration report alone. As a result of interviewing NDA

personnel during the inspection the SGS calibration was determined to be technically adequate. In general, 

the report’s overall quality is lacking with respect to organization and attention to technical details. 

Examples include: 

• SGS-01 Calibration Qualification Summary does not state the system’s operating range with 

respect to matrix (sample density) nor does the section on Matrix Drums (Section 3) adequately 

document the system’s capabilities in this area 

• SGS-01 Calibration Qualification Summary does not list the use of default (AK) isotopics as an 

option (19 of the 20 drums assayed to date have used AK isotopics) 

• The document is unclear regarding whether this system will be used to sort TRU/Non-TRU wastes 

in accordance with the 100 nCi/g criterion 

• Descriptions of the system’s calibration of record do not accurately document what happened

EPA expects this document to be revised as discussed during the inspection.

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): 

D. Discussed with: Joe Harvill, Joe Wachter, George Westik, John West, Barry Smith, Christa Chavez 

E. Additional Comments: 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: December 10, 2007 
 

C-3 

ATTACHMENT C.3 

INSPECTION ISSUE TRACKING FORM, ISSUE NO. ORNL-CCP-CH-CBFO-07-003F, FINAL 

Inspection No. EPA-ORNL-CCP-CH-11.07-8 Issue Number: ORNL-CCP-CH-CBFO-07-003F, Final 

Date: November 14, 2007 

Inspector: E. Feltcorn /R.Joglekar/M. Eagle 

Attachments? YES NO 

Sample Size: Not Applicable

Population size (if known): Not Applicable 

Description of Issue: EPA finds that the ORNL-CCP was not adequately prepared for the EPA Baseline 

Inspection for several technical areas. Examples include: 

• NDA - EPA found the SGS Calibration Report was not adequate as documented in EPA Finding 

ORNL-CCP-CH-NDA-07-002CR 

• RTR - Records (RTR and DVDs) needed to support the inspection were not available at the 

beginning of the inspection 

• AK - The AK Summary that was provided had insufficient detail. Information that should have been 

assessed and integrated in the document was available to the AKE and was identified during the 

inspection. It was clear that continued development of the document was anticipated in the near 

future to integrate additional information 

• WWIS - The WCA/WCO who demonstrated the WWIS to the EPA inspector was not a qualified 

WCA/WCO for ORNL-CCP. 

B. Regulatory Reference: 40 CFR 194.8 and 40 CFR 24

C. Site requirement(s): 

D. Discussed with: Court Fesmire, Bob Billett 

 

E. Additional Comments: EPA expects the response to this finding will be coordinated between CBFO 

and CCP management. 

F. Site Response Information: 

 Response Required? YES NO 

 Response Due Date: December 10, 2007 
 

C-4 

ATTACHMENT C.4 

INSPECTION ISSUE TRACKING FORM, ISSUE NO. ORNL-CCP-CH-RTR-07-004C, FINAL 

Inspection No. EPA-ORNL-CCP-CH-11.07-8 Issue Number: ORNL-CCP-CH-RTR-07-004C, Final 

Date: November 15, 2007 

Inspector: Dorothy E Gill 

Attachments? YES NO 

Sample Size: Not Applicable 

Population size (if known): Not Applicable 

Description of Issue: In the capability demonstration training containers the EPA inspector noted that 

while all the required items (prohibited items) were identified correctly by all RTR operators, some 

additional items (cellulosics and plastics) were not identified. All cellulosics and plastics in the training 

drum need to be identified and their identification documented. To complete the training process it is 

critical that the operator receives feedback regarding missed items. More detailed documentation of the 

feedback given is needed when the results of the training drum are reviewed. 

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): 

D. Discussed with: Susan Smith, Lee Smith 

 

E. Additional Comments: Copies of the Attachment 3s for the four qualified RTR operators are 

attached for information purposes. 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: NA 
 

C-5 

ATTACHMENT C.5 

INSPECTION ISSUE TRACKING FORM, ISSUE NO. ORNL-CCP-CH-RTR-07-005C, FINAL 

Inspection No. EPA-ORNL-CCP-CH-11.07-8 Issue Number: ORNL-CCP-CH-RTR-07-005C, Final 

Date: November 14, 2007 

Inspector: D. Gill 

Attachments? YES NO 

Sample Size: Not Applicable 

Population size (if known): Not Applicable 

Description of Issue: The replicate and original scans that were performed in batch OR-RTR6-0003, 

Container X10C0506048, had a 15% difference in the percent fill factor as well as minor differences in the 

recorded WMP weights. CCP-TP-053 only requires reconciliation of discrepancies when “identification of 

the waste matrix code, liquids in excess of TSDF-WAC limits and compressed gases differ between the two 

operators”. The same situation applies to the independent and original observations. While this practice 

complies with the requirements of CCP-TP-053, Sections 4.5.3 and 4.6.3, it does not satisfy EPA’s 

requirement for a system of controls demonstrating consistent and accurate identification of waste 

attributes. A tolerance needs to be defined for waste attributes. 

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): 

D. Discussed with: Susan Smith, Lee Smith 

E. Additional Comments: 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: NA
 

C-6 

ATTACHMENT C.6 

INSPECTION ISSUE TRACKING FORM, ISSUE NO. ORNL-CCP-CH-NDA-07-006CR, FINAL 

Inspection No. EPA-ORNL-CCP-CH-11.07-8 Issue Number: ORNL-CCP-CH-NDA-07-006CR, Final 

Date: November 14, 2007 

Inspector: P. Kelly 

Attachments? YES NO 

Sample Size: Not Applicable 

Population size (if known): One report 

Description of Issue: The calibration report for the DWAS IPAN NDA system BII-5183-CVR-001, 

Revision 2, Section 5.4, Table 12, LLD Implementation, does not address the LLD determination for two of 

the ten WIPP-tracked radionulcides, 234U and 90Sr. Inclusion of LLDs is required by CCP-TP-167, Section 

4.6.1 but the report is silent regarding the LLD determination for these two radionuclides.

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): CCP-PO-002, CCP Transuranic Waste Certification Plan 

D. Discussed with: John West, Joe Harvill, Joe Wachter, George Westsik, Barry Smith, Christa Chavez 

E. Additional Comments: CCP-TP-168, Section 4.1, Note references the NDA Memorandum with 

regard to the LLDs for 234U and 90Sr. The LLD determinations for 234U and 90Sr are addressed appropriately 

in the SGS calibration report. 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: December 10, 2007 
 

C-7 

ATTACHMENT C.7 

INSPECTION ISSUE TRACKING FORM, ISSUE NO. ORNL-CCP-CH-AK-07-007CR, FINAL 

Inspection No. EPA-ORNL-CCP-CH-11.07-8 Issue Number: ORNL-CCP-CH-AK-07-007CR, Final 

Date: November 14, 2007 

Inspector: C. Walker 

Attachments? YES NO 

Sample Size: DR002 

Population size (if known): single discrepancy report 

Description of Issue: Discrepancy Report DR002 identifies several discrepancies, but resolution of these 

discrepancies is incomplete. For example, resolutions are required to address 235U and 238U discrepancies 

between NFS and TWPC NDA data, detection of 228Th and 232Th, isotopic inconsistencies (e.g., Halden, 

SRO), and inconsistencies regarding the occurrence of 238U and 235U enrichment with respect to SRO 

material. Resolution of these issues could result in changes to the AK-NDA memorandum and revisions to

the AK Summary for waste stream ORNL-NFS-CH-HET. 

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): CCP-TP-005, Section 4.9.10 (additional sections also apply) 

D. Discussed with: Jeff Harrison and Dave Adkins 

E. Additional Comments: 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: December 10, 2007 
 

C-8 

ATTACHMENT C.8 

INSPECTION ISSUE TRACKING FORM, ISSUE NO. ORNL-CCP-CH-AK-07-008CR, FINAL 

Inspection No. EPA-ORNL-CCP-CH-11.07-8 Issue Number: ORNL-CCP-CH-AK-07-008CR, Final 

Date: November 14, 2007 

Inspector: C. Walker 

Attachments? YES NO 

Sample Size: Document CCP-AK-ORNL-001

Population size (if known): One AK Summary Report 

Description of Issue: AK Summary CCP-AK-ORNL-001 lacks detail with respect to technical issues that 

could impact AK waste characterization. Examples of technical areas that need additional information 

include: 

• Occurrence, source, and potential distribution of 233U 

• AK Summary conclusions and the development of default isotopic distribution values 

• Consistency of isotopic and other information with respect to AK-NDA memo information 

• Examination and updating of document to include relevant information from references such as 

U044 that has not been added to the AK reference list or addressed in the AK Summary 

• Additional process information (e.g., MOX generation) 

• Addition of references included in the AK-NDA memo 

• Additional changes based on assessment and integration of AK data including changes required due 

to Discrepancy Resolution (ORNL-CCP-CH-AK-07-007CR) and AK-NDA Memo (ORNL-CCPCH-AK-07-009CR). 

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): CCP-TP-005, Revision 18 

D. Discussed with: Jeff Harrison and Dave Adkins 

E. Additional Comments: The AKE has indicated that additional revisions to the AK Summary are 

anticipated based on receipt of new AK source documents, and the above technical issues and other 

corresponding revisions may be accomplished. 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: December 10, 2007 
 

C-9 

ATTACHMENT C.9 

INSPECTION ISSUE TRACKING FORM, ISSUE NO. ORNL-CCP-CH-AK-07-009CR, FINAL 

Inspection No. EPA-ORNL-CCP-CH-11.07-8 Issue Number: ORNL-CCP-CH-AK-07-009CR, Final 

Date: November 14, 2007 

Inspector: C. Walker 

Attachments? YES NO 

Sample Size: CCP-TP-005 Revision18, Attachment 7 

AK NDA Memo

Population size (if known): One AK-NDA Memo 

Description of Issue: The AK-NDA memo included in CCP-TP-005 Attachment 7 does not specify how 

the AK data will be used by NDA personnel. The manner in which NDA personnel will use the AK data 

should be specified in the AK-NDA memo or by reference to the appropriate NDA procedure. The AKNDA memo needs to incorporate applicable components of the responses addressing EPA Issue Nos. 

ORNL-CCP-CH-AK-07-007CR and ORNL-CCP-CH-AK-07-008CR to convey to NDA personnel resultant 

changes.

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): CCP-TP-005, Revision 18, Section 4.4.22 

D. Discussed with: Jeff Harrison and Dave Adkins 

E. Additional Comments: 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: December 10, 2007