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

WASTE CHARACTERIZATION INSPECTION REPORT AND APPROV AL

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) Checklis t

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 Conta iner X10C0501112

Attachment B.3 Replicate Testing Data for Containe r X10C0501270

Attachment B.4 Replicate Testing Results for, Cont ainer X10C0501270

Attachment B.5 Replicate Testing Data for Containe r X10C0505990

Attachment B.6 Replicate Testing Results for Contai ner 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 Fo rm

, Issue No. ORNL-CCP-CH-NDA-07-

002CR, Final

Attachment C.3 EPA Inspection Issue Tracking Fo rm, 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 Fo rm

, Issue No. ORNL-CCP-CH-RTR-07-

005C, Final

Attachment C.6 EPA Inspection Issue Tracking Fo rm, 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 Fo rm, 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 Passi ve-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/cm 3 

## 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

### vi



## WWIS WIPP Waste Information System

### 1



## 1.0 EXECUTIVE SUMMARY

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

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

Characterization Project (CCP) waste characterizati on (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 in spection occurred at the TRU Project

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

November 13 through 15, 2007. In accordance with th e 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 charac terize 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 d emonstration of the CCP’s

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

waste from ORNL, with the conditions and limitation s 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 Pil ot Plant (WIPP).

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

as specified in Condition 3 of the Agency’s certifi cation 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 cha racterizing 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 in spections, the Agency examined the

following activities:

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

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

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

characterizing debris (S5000) wastes

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

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

(S5000)

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

to perform load management, and EPA excluded evalua tion 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 Is sue 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 eigh t 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 ins pection team also identified one finding

### 2



## (ORNL-CCP-CH-CBFO-003F, Final, see Attachment C.3 t o 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-CC P 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 obs erved during this inspection and

described in this report and the attached checklist s (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 an y Tier 1 (T1) changes to the ORNLCCP WC activities from the date of the baseline ins pection, and must notify EPA regarding

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

format used in previous CH baseline approval report s.

Footnote b in Tables 1 and 8 specifies that “substa ntive 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 sa fety and health (ES&H), nuclear safety, or the

Resource Conservation and Recovery Act (RCRA) or th at 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 discuss ion of tiering). Upon approval, EPA will notify

the public of the results of its evaluations by pos ting 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 wi ll post the T2 changes. EPA expects the first

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

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

November 13–15, 2007.3Table 1. Tiering of TRU WC Processes Implemented by ORNLBased on November 13–15, 2007, Site Baseline InspectionWC Process ElementsORNL-CCP WC T1 ChangesORNL-CCP WC T2 ChangesaAcceptable Knowledge (AK) andLoad ManagementImplementation of load management; AK (5)Implementation of AK for wastes other than retrievablystored debris (i.e., retrievably stored soil/gravelandsolids and/or any type of newly-generated waste); AK(15)Notification to EPA upon completion of AK accuracyreports; AK (2)Notification to EPA upon completion of new versionsorupdates/substantive changesbof the following:-Changes to AK-NDA communications and memoranda; AK(3)-Changes to site procedure; AK (4)-AK summaries that describe wastes beyond the 144 containersdescribed in this report; AK (6)-Radiological Discrepancy Resolution Reports (AK-AKand AKNDA) pertinent to Waste Stream OR-NFS-CH-HET; AK (11)-Completed Attachments 4 and 6 and associated memoranda forWaste Stream OR-NFS-CH-HET; AK (10) and (14)-AK Summaries/Waste Stream Profile Forms (WSPFs) andAKdocumentation reports; AK (15)Non Destructive Assay (NDA) New equipment or physical modifications to approvedequipmentc; NDA (1)Extension or changes to approved calibration rangeforapproved equipment; NDA (2)Notification to EPA upon completion of changes to software for approvedequipment, operating range(s), and site proceduresthat require CBFOapproval; NDA (2)Real-Time Radiography (RTR) N/A Notification to EPAupon the following:-Implementation of new RTR equipment or substantivechangesctoapproved RTR equipment; RTR (1)-Completion of changes to site RTR procedures requiring CBFOapprovals; RTR (2)Visual Examination (VE) Not approved at this timeNot approved at this timeWIPP Waste Information System(WWIS)Implementation of load management; WWIS (4) Notification to EPA upon the following:-Completion of changes to WWIS procedure(s) requiring CBFOapprovals; 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 are solely related to ES&H,nuclear safety, or RCRA, or that are editorial in nature.cModifications to approved equipment include all changes with the potential to affect NDA data relativeto waste isolation and exclude minor changes, suchas theaddition of safety-related equipment.

### 4



## 2.0 PURPOSE OF INSPECTIONS

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

regulations at 40 CFR Part 191. In this certificat ion, 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 describ ed at 40 CFR 194.8 requires DOE to

(1) provide EPA with information on AK 1 

## for waste streams proposed for disposal at the WIP P,

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

component that will be emplaced in the WIPP will no t exceed limits identified in the WIPP

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

Certification Application for the Waste Isolation P ilot Plant , 1996).

Under the changes to 40 CFR 194.8 promulgated in th e 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 an d limitations, can adequately characterize

TRU wastes and comply with the regulatory requireme nts imposed on TRU wastes destined for

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

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

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

Any compliance application shall: . . . Provide in formation which demonstrates

that a system of controls has been and will continu e 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 o f 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 inspect ion is to assess whether DOE sites that

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

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

limits. Before proposing the approval of WC system s 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 knowledg e”

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 prio r to or separate from the waste certification proce ss authorized by

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

2 

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

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 propose d 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 iden tified as belonging to the group of approved

waste streams.

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

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

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

40 CFR 194.24, EPA has the authority to conduct con tinued 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 requireme nts. Based on the adequacies of the WC

processes demonstrated during the baseline inspecti on, including all conditions and limitations,

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

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

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

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

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

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

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

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

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

not approving the site-assigned tiers. The rule ap plying 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 du ring the inspection that are approved

• Provides objective evidence of the approval basis f or all WC systems

• Identifies all relevant system limitations and/or c onditions 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 dur ing the course of the inspection and

their relevance to EPA’s approval decision

3 

### The potential contents of a waste stream or group o f waste streams determine which processes can adequ ately

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

should select a suitable NDA technique to ensure ad equate measurements. Radiography and VE help to co nfirm and

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

confirmed, the assay techniques then quantify selec ted radionuclides in the waste. In some cases, a T RU waste

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

stated limits on the applicability of proposed WC p rocesses 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 attach ed 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 pr ogram 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-CC P-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 re spect to their ability to perform the

following functions:

• Identify and quantify the activities of the 10 WIPP -tracked radionuclides ( 241 

## Am, 137 

## Cs,

238 

## Pu, 239 

## Pu, 240 

## Pu, 242 

## Pu, 90 

## Sr, 233 

## U, 234 

## U, and 238 

## U) using a combination of AK and NDA

systems

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

debris waste

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

Specifically, these systems consisted of the follow ing components:

• AK processes that support retrievably-stored S5000 debris wastes

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

• RTR

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

emplacement

During an inspection, EPA does not approve characte rization 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 equi pment operations that follow site procedures,

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

important aspect of this evaluation was the objecti ve evidence documenting the effectiveness of

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

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

containers. During this inspection, EPA selected s amples of each of these items, based on the

### 7



## number and variety of items each WC process produce d, consistent with standard inspection

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

objective evidence, EPA determined the technical ad equacy 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 iden tified 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 o r may not have a negative effect on

compliance and, depending on the magnitude of the i ssue, 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 ac cepts 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 inspec tion 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 OR IA

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 o nly a sample of the CH TRU WC staff, and

they are listed in Table 3, along with their affiliation s 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 traini ng records of these individuals to assess their

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

responsible for characterizing and certifying TRU w aste were qualified and had received

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

request qualification and training records of any n ew 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 R idge, Tennessee. ORNL encompasses 8,771

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

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

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

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

ORNL’s current mission includes environmental resto ration 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 pla ce November 13–15, 2007. EPA

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

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

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

inspection involved the following steps:

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

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

to WC activities at ORNL-CCP in advance of the insp ection

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

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

processes, and equipment by means of interviews, ob servation, and demonstrations, and

recording the results on checklists

(5) Recording all concerns on EPA Inspection Issue Trac king 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-C CP 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, consist ing of RTR; the WWIS; and

container management.

8.1 Acceptable Knowledge

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

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

waste.

### 10



## WC Element Description

As part of the inspection, EPA reviewed the followi ng 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 documen tation

• Characterization of required WMPs and radionuclides

• AK information assembly and compilation

• AK confirmation and associated discrepancy resoluti on

• Sufficiency of AK characterization results

• Assembly of required information and use of supplem ental information

• AK summary report preparation

• Reassignment of waste stream due to AK and discrepa ncy analysis

• AK accuracy

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

team. AK provides information on several aspects o f 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 va riety 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 documen t 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 docu ments 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 Pla n, 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 R eport for Nuclear Fuel

Services Contact-Handled Transuranic Waste Stored a t 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 Docu mentation Checklist, Revision 18,

October 30, 2007

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

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

November 30, 2007

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

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

Packaging, Revision 18, October 26, 2007

• CCP-TP-005, Attachment 6, Memorandum from Jeff Harr ison, 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 Labo ratory, Revision 0, September 25,

2007

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

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

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

• CCP-TP-005, Attachment 9, Waste Characterization Da ta 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, 2 007

• CCP-QP-002, CCP Training and Qualification Plan, Re vision 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 V erification, Revision 17, September

24, 2007

• Qualification Card for Jeff Harrison, provided Novem ber 15, 2007

• Qualification Card for David Adkins, provided Novem ber 15, 2007

• CCP Internal Surveillance Report (draft cover lette r 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 defens e 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 Ar ea B, Memorandum to Ron Mitchell,

Letter of Authorization, LOA-7000-018, March 20, 20 02

— 

## NFS Proprietary, Not Approved

for Public Release

• C121, DVRF Bale Packaging Glovebox Removal, Memoran dum to Ron Mitchell, LOA7000-034, February 15, 2001

— 

## NFS Proprietary, Not Approved for Public Release

• C122, Building 234 Characterization Results, Memora ndum 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 i n 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 De contamination 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, Mem orandum 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 Knowle dge Source Document

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

2007

• DR002, CCP-TP-005, Attachment 11, Acceptable Knowle dge 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 Characte rization Samples, DC-03-18,

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

• I056, Removal of Building 234 Wet Cell Permacon Con tainment Enclosure,

DC-SWI-03-041, June 20, 2002

— 

## NFS Proprietary, Not Approved for Public Release

• I058, Dismantlement of the West Wet Cell Wall in Bu ilding 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-0 1-020, 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 Sectio n 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, v arious dates

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

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

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

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

2005

• P212, Lattice Experiments with Simulated Burned-Up Fuel for D 2 

## O Power Reactors, DP1122, February 1968

— 

## NFS Proprietary, Not Approved for Public Release

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

• P254, Contact Handled Waste Repackaging, CH-P-OP-01 3, 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 Pro ject 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, 199 2

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

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

• P273, Nuclear Fuel Services, Inc., Waste Certificati on 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 Laborato ry, October 24, 1995

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

January 1996

### 14



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

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

Lawrence Livermore National Laboratory, April 3, 19 90

• 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 retrieva bly-stored debris waste stream, identified as

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

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

inspection. This waste stream consists of CH TRU m ixed 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-stor ed 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 S preadsheet. AK procedure

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

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

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

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

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

container basis. ORNL-CCP representatives indicate d 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 repre sentatives indicated that ORNL also has a

site EM database that tracks both historic and curr ent 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 dat abase.

### 15



## It should be noted that ORNL-CCP tracks each contai ner’s characterization status, while Energx 4



## is responsible for container movement and storage l ocations. 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 C CP-ORNL Program Manager, clarified that

the Contact-Handled Storage Area (CHSA) near the TW PC 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 strea m population on a weekly basis,

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

payloads include only those containers with appropr iate characterization.

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

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

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

EPA’s inspection, an AK accuracy report was not ava ilable 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 t he two most prevalent radionuclides as

indicated by available NDA characterization data, 240 

## Pu and 239 

## Pu, to the two most prevalent

radionuclides identified in the AK Summary Report ( AKSR), 239 

## Pu and 238 

## U. The NDA

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

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

contain relatively large quantities of 238 

## U by mass, causing 238 

## U to dominate the mass-based

determination of the most prevalent radionuclides p resented in the AKSR. The sample of

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

of 238 

## U, so this was excluded from the most prevalent rad ionuclides by mass based on actual

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

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

calculation must be done in terms of mass or activi ty.

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

waste stream is a T2 notification requirement. Con sistent 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 Ta ble 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 communica tion 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 onl y, evaluating the

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

4 

### Energx is the Foster Wheeler Environmental Corpora tion 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 wast e, the NDA Memorandum must

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

assessment should include a discussion of the limit ations of the radiological

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

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

discussed and resolved.

EPA examined the AK-NDA memorandum and identified se veral inconsistencies between the

memorandum and the AKSR, as well as questions conce rning 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 n ot specify how NDA personnel will

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

an EPA Inspection Issue Tracking Form (See Attachme nt 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 refere nce to the appropriate NDA procedure.

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

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

Fuel Services Contact-Handled Transuranic Waste Sto red at Oak Ridge National Laboratory

, Revision 1. This revision of the memorandum indica tes how and when default isotopics will be

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

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

memorandum is adequate and addressed the concerns r aised 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 memo randum would be revised when such

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

reflect changes in isotopics as more CH debris wast e 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. Cons istent 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 Ta ble 1, which includes this as a T2 change.)

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

Procedure CCP-TP-005 describes the processes used b y 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) ree valuates AK documentation; (3) resolves AK

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

(5) determines if a waste is hazardous.

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

Facility Permit, Waste Analysis Plan (WIPP WAP), wh ich 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 requir ements of the WIPP WAP, the WAC, and

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

notification to EPA regarding changes made to AK pr ocedures 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 Know ledge Expert (AKE) stated that ORNLCCP is not seeking approval to perform load managem ent, and EPA excluded evaluation of load

management from the scope. EPA did not evaluate lo ad management during the inspection.

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

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

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

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

process or from an activity which is similar in mat erial, 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 P art 261, Subpart C.

This waste stream contains debris from the final de commissioning 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 w aste. 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 2 007.

EPA reviewed the methodology and supporting AK docu mentation 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 S tream OR-NFS-CH-HET was

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

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

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

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

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

inorganic debris, so the physical form is well defi ned. Based on the assumption that the

### 18



## radiological components are distributed equally thr oughout 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 dat a suggest that the waste may contain

common hazardous constituents.

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

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

261 drums of NFS debris waste currently in storage a t 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 stre am. 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 ad ditional 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 requir ements. 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 recommen ds that this information be integrated to

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

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

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 personne l compiling

AK information for ORNL-CCP and evaluating and reso lving 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 specifi ed tasks. EPA inspectors reviewed the plan,

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

evaluated their qualification cards. These individ uals had performed required reading pertinent

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

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

site-specific procedures associated with WC using A K. 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 r ecertification application will be submitted in

2008 and could directly affect characterization req uirements. 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 an d found to be adequate.

### 19



## Several containers were selected to assess drum tra ceability for the 144-drum population

generated from approximately 2000–2003: X10C050111 2 (repackaged from drum

X1060506029), X10C0505990 (original drum), X10C0501 270 (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 perfo rmed on all drums that were not

repackaged. The later characterization sequence to ok 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 conta iner from NFS through the second Foster

Wheeler radioassay or assays (reference M017), radi ography 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 Whe eler 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 fu rther 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 defa ult isotopics used by Foster Wheeler and

ORNL-CCP differed, the isotopic distributions for t he 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 t he examples provided either listed a limitation or

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

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

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

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

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

updating of references during the inspection does n ot demonstrate that data limitations and

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

waste stream being inspected. Providing notificati on 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 re quest this information if EPA deems it

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

this as a T2 change.)

### 20



## (11) Discrepancy resolution (AK-AK) was examined a nd found to be adequate following

revision of specific documents.

ORNL-CCP prepared an AK-AK Discrepancy Resolution D R002 to assess numerous differences

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

• Incorrect reporting of 242 

## Pu by NFS, differences between scaled and actual mea sured data

from NFS (and subsequent decision to use TWPC data)

• Differences between the reported 235 

## U and 238 

## U masses by NFS and the TWCP

• 228 

## Th and 232 

## Th values reported by NFS that were not verified by the TWPC

• Different isotopic compositions for various fuels g enerated/managed within Building

234, including differences in plutonium isotopics a nd 235 

## U enrichment

• Different 238 

## U 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 res olve 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 discrep ancies, but discrepancy resolutions are

incomplete. For example, additional discrepancy re solutions are required for 235 

## U and 238 

## U

discrepancies between NFS and TWPC NDA data, detecti on of 228 

## Th and 232 

## Th, isotopic data

inconsistencies between Halden and Savannah River S ite (SRS) 5



## , 238 

## U occurrence

inconsistencies, and 235 

## U enrichment inconsistencies with respect to SRS ma terial. Resolution of

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

memorandum and the AKSR.

Resolution: Discrepancy Report DR002 was modified to indicate w hy 238 

## U was detected by

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

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

“significant gamma deadtime” that lead the NDA opera tor to not report 235 

## U/ 238 

## U in the

repackaged container. Overall discrepancies in rep orting uranium were attributed to differences

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

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

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

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

indicated that contract specifications and direct d ata 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 produce d according to specifications in contracts for four clients:

SEFOR, Consumer’s Power, Dupont/SRO (SRS) and Halde n.

### 21



## why the Halden isotopics presented in reference U01 6 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 err ors were also attributed to 235 

## U value

discrepancies.

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

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

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

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

may request this information if EPA deems it necess ary 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 acce pted.

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 “de fense” waste. TRU waste is eligible for

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

defense activities listed in Section 10101(3) of th e 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-oxid e (MOX) fuel fabrication and 233 

## U

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

Energy Commission as well as under two smaller comm ercial contracts. The two larger

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

defense use under Defense Material System, Regulati on 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, notin g that EPA does not perform a detailed and

thorough analysis of the defense determination stat us.

(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-0 01 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/app ropriateness of these distributions to the

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

C100, C122, DR002, M012, M016, M007, M017, P256, P2 68, 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 oth er activities related to MOX fuels.

Additionally, a portion of the building was used as a 233 

## U purification process facility. The

portion of the building that was used for 233 

## U 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 ea rly 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 m etals 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 a t 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 generate d during the later portion of the D&D

process included various debris materials typical o f 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 compositi ons 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 radion uclide in terms of mass for each material.

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

below.

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

Radionuclide SEFOR Consumers SRS Halden

238 

### Pu 0.01 0.04 0.01 0.43 -- -- 0.01 0.29

239 

### Pu 18.13 90.63 1.73 76.24 0.29 90.94 2.00 79.89

240 

### Pu 1.67 8.33 0.37 16.34 0.02 7.99 0.36 14.51

241 

### Pu 0.10 0.48 0.07 2.91 0.003 0.99 0.06 2.24

242 

### Pu 0.01 0.05 0.03 1.1 0.0002 0.08 0.02 0.83

241 

### Am 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

234 

### U 0.12 0.15 0.58 0.59 0.001 0.001 3.90 4.00

235 

### U 0.28 0.35 2.36 2.41 0.30 0.30 4.88 5.01

238 

### U 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 colum n represents the overall mass fractions of the MOX fuel,

and the second column provides the mass fractions o f 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 employe d 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 was te 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 pr ior to implementation of the CCP TRU

waste certification program at ORNL.” ORNL-CCP not ed 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 discre pancy analysis and resolution presented in

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

NFS data, primarily because of unknowns associated w ith 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 i s anticipated to consist primarily of a mixture of

uranium and plutonium, with the predominant radionu clides by activity being 239 

## Pu, 240 

## Pu, 241 

## Pu,

and 241 

## Am. The predominant radionuclides by mass are anti cipated to be 238 

## U and 239 

## Pu based

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

measuring 238 

## U, and the ORNL-CCP measurement system is not sensi tive enough to detect 238 

## U

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

238 

## U as a predominant radionuclide by mass, measuremen ts by ONRL-CCP may not identify

238 

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

be 239 

## Pu and 240 

## Pu. This lack of instrument sensitivity may result in underreporting of 238 

## U.

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

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

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

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

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

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

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

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

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

Plutonium % Uncertainty

238 

## Pu 0.044% 0.0044%

239 

## Pu 90.837% 9.0837%

240 

## Pu 8.893% 0.8893%

241 

## Pu 0.104% 0.0104%

242 

## Pu 0.122% 0.0122%

241 

## Am 1.115% 0.1115%

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

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

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

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

during D&D. ORNL-CCP representatives stated that t here are no data to suggest that materials24Table 7. Radionuclide Distribution for Waste StreamOR-NFS-CH-HETRadionuclideRadionuclide TotalWeight Percent1Range in Weight Percent by Radionuclidefor Individual Containers2Total Curies %Radionuclide3Range in Curies byRadionuclide forIndividual Containers4Suspected To BePresent?(Yes or No)WIPP Tracked Radionuclides241Am 0.15 0.03–2.86 4.97 2.08–17.09 Yes6238Pu 0.01 0.00–0.43 1.81 0.00–5.88 Yes239Pu 23.06 1.80–94.04 13.78 7.54–37.92 Yes240Pu 2.74 0.26–16.34 5.99 3.30–17.81 Yes242Pu 0.02 0.00–1.17 Trace 0.00–Trace Yes233U7Trace50.00–Trace Trace 0.00–Trace Yes234U 3.42 0.00–4.00 0.21 0.00–0.80 Yes238U 69.94 0.00–99.69 Trace 0.00–Trace Yes137Cs Trace 0.00–Trace Trace 0.00–Trace Yes90Sr8Trace 0.00–Trace Trace 0.00–Trace YesAdditional Radionuclides243Am Trace 0.00–Trace Trace 0.00–Trace Yes9237Np Trace 0.00–0.05 Trace 0.00–Trace Yes241Pu 0.07 0.00–2.91 73.24 23.56–83.90 Yes235U 0.59 0.00–5.01 Trace 0.00–Trace Yes1This listing indicates the total weight percent ofeach radionuclide over the entire waste stream.2This listing is the weight percent range of each radionuclide on a container-by-container basis. Some containers where “0.00” is listed as the lower range will notcontain the specified radionuclide.3This listing indicates the total activity percent(in curies) of each radionuclide over the entire waste stream.4This 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.6241Am may be present in slightly larger percentages due to the further decay of241Pu.7233U was not reported in waste assay data for this waste stream but may be present in trace quantities, as described above.890Sr cannot be quantified by gamma spectrometry. Itsvalue is calculated based on measured137Cs values. A90Sr/137Cs scaling factor of 1.0 is used to calculate the90Sr contribution.9These weight percent ranges were expanded based onthe plutonium and uranium isotopic distribution data provided in Table 6.

### 25



## were managed in specific areas or that D&D wastes c an 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 th at 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 v ariability.

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

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

derive isotopics instead of the material specificat ion 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 t hat 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 we re obtained using the same

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

default isotopics used by the TWPC were based on “g eneric” 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 s tream may be expanded to include

additional material, and the radionuclide compositi on 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 wa s 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 availa ble for all containers in the population, and

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

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

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

to a WMP group and determined the total mass of eac h 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 t his overall stream weight percent. Also,

available data suggest that some of the drums may c ontain 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 s tream.

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

items identified in this waste stream were sealed c ontainers 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 a ll 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-00 1 was assessed and found to be

adequate following revision.

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

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

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

also used for a 233 

## U purification process. Building 234 operated from 1965 through 1973, and

D&D of the building took place from 1993 through 19 94, 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 dru mmed 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 N FS drums were not repackaged and

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

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

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

EPA reviewed the single AKSR and noted several disc repancies between the AKSR and the AKNDA memorandum (DR002), as discussed in Items (11) a nd (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 det ail with respect to technical issues that

have the potential to impact AK WC. Examples inclu de the following:

• Occurrence, source, and potential distribution of 233 

## U

• Previous AKSR conclusions and information, includin g 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 rel evant information from references

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

• Additional process information (e.g., MOX generatio n)

### 27



## • Addition of references included in the NDA-AK memora ndum

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

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

ORNL-CCP-CH-AK-07-007CR, Final, and the NDA-AK memo randum 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 233 

## U

purification

• Additional production operation information, includ ing MOX pellet production, scrap

dissolution and recovery, and additional decommissi oning information

• Overview of TRU waste generation and management inf ormation

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

activities

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

(WEAF), TWPC

• Revision to include 238 

## U, 235 

## U, 228 

## Th, and 232 

## Th 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 doc uments that were included in the AK-NDA

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

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

inspection team determined that all required inform ation 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. A ccordingly, AK and NDA personnel will be

aware of important information pertinent to the dev elopment of default isotopics.

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

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

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

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

Revisions of existing WSPFs, associated AK Summarie s, AK accuracy, Radiological DRRs,

### 28



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

Providing notification to EPA upon completion of re visions 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 auth ority under 40 CFR 194.24(h), the Agency

may request this information if EPA deems it necess ary 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 findin gs related to AK during this inspection.

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

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

concerns. EPA considers these three concerns to have been ade quately 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 a bove, EPA proposes assigning the following

tiers:

T1 AK changes will require EPA review and approval prior to impl ementation and will apply to

any new waste category not evaluated during the bas eline 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-gene rated 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 informati on, choose to conduct a desktop review,

and/or confer with ORNL-CCP personnel. Upon evalua tion (with or without site inspection),

EPA will issue an approval letter, and only upon re ceiving the EPA approval can ORNL-CCP

dispose of the new waste at the WIPP or implement t he 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 annu ally)

• 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 was tes beyond the 144 containers

described in this report and updates to the existin g 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 Attachm ent 6 for Waste Stream

OR-NFS-CH-HET

• Notification to EPA upon completion of AK accuracy r eports, new WSPFs, or revisions

to existing WSPFs (and attachments)

Following EPA approval, at the end of each fiscal q uarter, 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 respon se 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 Facili ty on the ORR. This unit is operated under

the ORNL-CCP WC program, which EPA evaluated for th e first time during this baseline

inspection. The DWAS IPAN/SGS has operated previous ly but had not performed any WIPP

assays.

Technical Evaluation

Since EPA had not reviewed this NDA system previousl y, 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 personn el involved in the NDA

program

The checklist in Attachment A.2 and the documents l isted below comprise the documents that

EPA examined in assessing the DWAS IPAN/SGS during t his inspection:

• CCP-TP-166, CCP Drum Waste Assay System Imaging Pas sive/Active Neutron Operations,

Revision 0, October 12, 2007

• CCP-TP-167, CCP Drum Waste Assay System Imaging Pas sive/Active Neutron Calibration,

Revision 0, October 12, 2007

• CCP-TP-168, CCP Drum Waste Assay System Imaging Pas sive/Active Neutron/Segmented

Gamma Scanner Data Generation Level Validation, Rev ision 0, October 18, 2007

• CCP-TP-169, CCP Operating the Mobile Segmented Gamm a Scanner, Revision 0, October

12, 2007

• CCP-TP-172, CCP Calibrating the Mobile Segmented Ga mma 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, No vember 6, 2007 and Revision 1,

December 19, 2007

• BII-TMU-5183-001, Total Measurement Uncertainty Rep ort, 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, Cal ibration Verification Performed on

October 17, 2007 for the MCS SGS Located at the Mel ton Valley Site, November 8, 2007

• CCP-TP-005, Revision 18, CCP-AK-ORNL-001 NDA Memoran dum, October 17, 2007,

with Attachments & Isotopic Calculations for NFS Wa ste

• CCP-TP-005, Revision 18, Reference U-016, J. Chapma n, Graphical Workbook for

Estimating Important Quantities of NFS Radioactive s Waste Constituents; March 1992

• CCP-AK-ORNL-001, Central Characterization Project A cceptable Knowledge Summary

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

National Laboratory, Waste Stream: OR-NFS-CH-HET, Re vision 0, September 25, 2007

• ORNL Program List of Qualified Individuals, October 18, 2007

• Performance Demonstration Program for NDA of Drums S ystem Registration Form

• Radionuclide Library Listing Filename C:\GENIE2K\CA MFILES\STD WIPP.NLB

### 31



## • MV-SGS0101-CAL-001, Segmented Gamma Scanner-01 (SGS -01-01) Calibration,

Confirmation and Verification Report, Revision 0, No vember 6, 2007

• BII-TMU-5183-001, Total Measurement Uncertainty Rep ort, 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 Corr ection Factor from Neutron

Absorption in the PDP Stainless Steel Source Can wi th 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/SG S 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-base d 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 det ector 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 co axial 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 segmen ted 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 FRAM 6 

## software packages to

determine the isotopic distribution of 238 

## Pu, 239 

## Pu, 240 

## Pu, 241 

## Pu, and 242 

## Pu, along with 241 

## Am, 235 

## U

and 237 

## Np. Other radionuclides are quantified directly us ing Genie 2000 and NDA 2000

software. The LEGe isotopic determination is perfo rmed 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 o f segments mode is appropriate for most

of the waste matrices expected at ORNL-CCP. The su mmed spectrum mode is better suited for

containers with low plutonium content and bulk dens ity up to 0.72 g/cm 3



## .

The IPAN component of the DWAS consists of the follo wing:

6 

### FRAM is an abbreviation for an isotopic identifica tion computer-based program properly called Fixed e nergy

Response function Analysis with Multiple efficiency

.

### 32



## • A shielded assay chamber that surrounds the waste c ontainer on all four sides, top, and

bottom, containing a turntable to rotate the drum d uring assay; one side of the enclosure

contains a 14 MeV neutron generator located inside a moderator assembly

• Shielded detector packages comprising a number of h elium-3 ( 3 

## He) 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 mode s and provides values for 239 

## Pu effective

mass ( 239 

## Pu EFF 

## ) and 240 

## Pu effective mass ( 240 

## Pu EFF 

## ), respectively. The IPAN is currently

configured to measure one of these two quantities d epending 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 dist ributions) or known or established

relationships (AK-based isotopics) in conjunction w ith the measured neutron-based quantity, or

by using computational or correlation techniques (e .g., 242 

## Pu). The IPAN component uses active

and passive mode determinations to provide two inde pendent measures of the plutonium content

of a waste container. The active mode result is ex pressed in terms of 239 

## Pu EFF 

## , and the passive

mode result is expressed in terms of 240 

## Pu EFF 

## . The system makes a selection to use the active o r

passive results based primarily on the number of me asured coincidence neutrons and the

magnitude of the moderator and/or absorber/moderato r correction factors (i.e., the moderator

(MOD) and/or absorber/moderator (ABSMOD) indices) f or passive and active modes,

respectively.

Previous EPA inspection reports present a detailed technical description of 239 

## Pu EFF 

## and 240 

## Pu EFF 

## 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 239 

## Pu EFF 

## , and the system’s passive mode LLD to 2.050 g of

240 

## Pu EFF 

## . The active mode has been confirmed at 10.494 g o f weapons-grade plutonium (WG

Pu), approximately 9.806 g 239 

## Pu EFF 

## , and the passive mode has been confirmed at 32.076 g of

WG Pu, approximately 1.89 g 240 

## Pu EFF 

## . Confirmations used WG Pu sources as described in BII5183-CVR-001, Revision 2, March 9, 2006. The activ e 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-CC P 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, followin g revision of one ORNL-CCP report.

Two reports document the calibration of the DWAS SG S/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 p rior to the system’s use

by ORNL-CCP. There are four separate aspects of th e gamma calibration:

• Energy calibration was performed using a 152 

## Eu source in 2005, including a term for

resolution (full width at half maximum) for the coa xial detector, and for the LEGe

detector using mixed gamma line sources; the coaxia l calibration is absolute

(i.e., expressed as observed counts per actual nucl ear disintegration of the calibration

source) while the LEGe calibration is relative.

• Reference peak calibration was performed in 2005 us ing a pulser to enable dead-time

corrections to the coaxial detector.

• Transmission source calibration was performed in 20 05 using a 152 

## Eu source to enable

transmission corrections.

• Matrix calibration was initially performed in 1996 and subsequently updated with

several additional data to produce the composite pl ot shown on page 43 of MVSGS0101-CAL-001 with a matrix density range of 0.0 to 0.72 g/cm 3



## .

The SGS component of the calibration was technicall y 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 Inspecti on Issue Tracking Form (see Attachment

C.2 of this report for a copy of this form). The i ssue 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, Revis ion 0, did not adequately document

calibration of this NDA system. In general, the rep ort’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 t he section on matrix drums (Section 3)

adequately document the system’s capabilities in th is area.

• SGS-01 does not list the use of default (AK) isotop ics as an option (19 of the 20 drums

assayed to date have used AK isotopics).

• The document is unclear regarding whether this syst em will be used to sort TRU/nonTRU wastes in accordance with the 100 nCi/g criteri on.

• Descriptions of the system’s calibration of record do not accurately document what

happened.

Resolution: ORNL-CCP personnel provided an electronic copy of R evision 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 D ecember 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 152 

## Eu/ 137 

## Cs/ 241 

## Am 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 crit eria. 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 t he system’s

implementation at ORNL-CCP in July 2005. Active mo de calibrations were performed using a

depleted uranium (DU) source, and the passive mode calibration was performed using a 252 

## Cf

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 f or each mode were developed using six

surrogate matrix drums with the DU and/or 252 

## Cf 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 252 

## Cf sources used for calibration, as

required by DOE/WIPP-02-3122. ORNL-CCP NDA personne l 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 (activ e 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 acti ve mode. This was expected due to selfshielding that is a function of the encapsulated so urce design and application within the

Performance Demonstration Program (PDP) stainless s teel containers, an effect that is

documented and which have been seen in previous ins pections (see BII-5109-TN00-003). The

upper limit of the IPAN’s range was set at 14.710 g 239 

## Pu EFF 

## , 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. Extens ion of or changes to the calibrated

range for either the SGS or IPAN component of the DW AS 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, it s SGS or IPAN operating range(s), and

site procedures that address the system’s calibrati on and/or operation that require CBFO

approval is a T2 change. (See Table 1, which inclu des this as a T2 change.)

### 35



## (3) The total measurement uncertainty (TMU) of assays p erformed on the DWAS IPAN/SGS

NDA system had been determined and documented, as re quired.

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 compone nt; and

BII-TMU-5183-001, Total Measurement Uncertainty Report, DWAS IPAN , Revision 0,

November 11, 2005, for the passive and active neutro n components. The components of

uncertainty included in the TMU determination for t he SGS of the DWAS included calibration

source uncertainties (including drum fill height), counting statistics, self-absorption effects,

matrix nonhomogeneities, nonuniform source distribu tions, and isotopic measurement

uncertainties, end effects, and attenuation. The c omponents of uncertainty included in the TMU

determination for the IPAN component of the DWAS, in cluding 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 syste m.

(4) The LLD, including the minimum detectable concentra tion of the DWAS IPAN/SGS system,

had been determined and documented, following revis ion of one ORNL-CCP report.

The LLD definition used by ORNL-CCP is consistent w ith that specified in DOE/WIPP-02-3122

(CH WAC). Specifically, the LLD is defined as “tha t level of radioactivity which, if present,

yields a measured value greater than the critical l evel with a 95% probability, where the critical

level is defined as that value which measurements o f 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) tim e, the properties of the waste matrix being

assayed, and the environmental background. For thi s 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 neu tron (IPAN) operational modes. Only

measured values that exceed the reported LLD for th at measurement will be reported and used in

calculations of derived quantities, such as total T RU alpha activity and TRU alpha activity

concentration. The LLD values for the SGS componen t 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 t he 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 238 

## Pu, 240 

## Pu, 242 

## Pu, and

90 

## Sr. Based on Section 6.0 of MV-SGS0101-CAL-001, a unique reporting threshold for 234 

## U is

not provided based on ORNL-CCP’s contention that it is not technically feasible to determine a

unique reporting threshold for 234 

## U. Section 5.0 of MV-SGS0101-CAL-001 also states t hat it is

possible to use the SGS to quantify wastes at level s below 100 nCi/g (i.e., the measurement

criterion for TRU wastes). However, ORNL-CCP perso nnel 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 t o be less than 100 nCi/g over this

mode’s entire calibration (ABSMOD) range. The pass ive mode LLD is expressed in terms of

grams of 240 

## Pu EFF 

## , which is technically appropriate since this mode is used for higher gram value

assays such that there is no expectation that the p assive 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 t his concern with ORNL-CCP NDA

personnel and included it on an EPA Inspection Issu e Tracking Form (see Attachment C.6 of this

report for a copy of this form). This concern is d iscussed below.

EPA Inspection Issue Tracking Form, Issue No. ORNL- CCP-CH-NDA-07-006CR, Final:

The calibration report for the DWAS IPAN NDA system B II-5183-CVR-001, Revision 2,

Section 5.4, Table 12, “LLD Implementation,” does n ot address the LLD determination for two

of the 10 WIPP-tracked radionuclides, 234 

## U and 90 

## Sr. The report is silent regarding the LLD

determination for these two radionuclides. The SGS calibration report appropriately addresses

the LLD determinations for 234 

## U and 90 

## Sr.

Resolution: ORNL-CCP personnel provided an electronic copy of R evision 3 of BII-5183-

CVR-001, dated November 2007. Section 5.4, page 24, was modified to address the LLD

determination for both 234 

## U and 90 

## Sr. Table 12 was not changed, but text was added b elow the

table that explained the exclusion of these radionu clides from Table 12 and presented the

approaches used for both radionuclides.

Status of Concern: ORNL-CCP’s revision adequately addressed EPA’s conc ern, and this

concern is closed.

There are no issues with the determination and docu mentation of the LLD for the DWAS

IPAN/SGS system.

(5) ORNL-CCP had registered the DWAS IPAN/SGS to partici pate in the CBFO-sponsored

PDP, as required.

The DWAS IPAN/SGS was registered to participate in C ycle 14B of the CBFO-sponsored NDA

PDP. This cycle had a start date of October 22, 20 07, and data for the DWAS IPAN/SGS will be

provided upon completion of the assays and data eva luation. Objective evidence that

documented ORNL-CCP’s PDP participation was provide d 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 Repli cate Testing Protocol.

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

an independent means to verify that the DWAS IPAN/SG S unit can provide reproducible results

for the determination of the quantity of 10 WIPP-tr acked radionuclides ( 241 

## Am, 137 

## Cs, 238 

## Pu,

### 37

239 

## Pu, 240 

## Pu, 242 

## Pu, 90 

## Sr, 233 

## U, 234 

## U, and 238 

## U) and the TRU alpha concentration. 7 

## This is

accomplished by reassaying drums previously measure d on the same system in order to

demonstrate the system’s ability to do the followin g:

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

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

reported TMU.

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

comparing the results of the replicate 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, X 10C0505990, 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 usi ng two statistical tests, a chi-squared (χ 2 

## ) test

and a t-test. The EPA inspection team observed ope ration of the DWAS IPAN/SGS unit as it

performed the assay of container X10C0501270. Atta chments 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 measur ement assay values and the average of the

five replicate measurements for the activities of a ny of the target radionuclides or the TRU alpha

activity concentration. The χ 2 

## test for all containers assayed on the DWAS IPAN/S GS showed

that the observed variances in the replicate measur ements are less than or equal to the reported

uncertainties within the statistical limits of the test. There are no technical issues associated wit h

replicate testing of the DWAS IPAN/SGS.

Summary of NDA Findings and Concerns

The EPA inspection team did not identify any findin gs related to NDA during this inspection.

EPA did identify two concerns, one related to the S GS 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 conce rns to have been adequately addressed, and

there are no open concerns related to NDA at ORNL-C CP resulting from this inspection.

Baseline Approval

The baseline conditions that the EPA inspection tea m evaluated during this inspection consist of

the DWAS IPAN/SGS NDA system currently located in Bu ilding 7880-I of the TWPC for

gamma and neutron-based assays of CH retrievably-st ored 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 p rovides 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 ND A are as follows:

• For gamma assays using the SGS component, the opera tional range is from the system’s

LLD to 45 g total plutonium in terms of activity; a nd from 0 to 0.72 g/cm 3 

## in terms of

waste matrix.

• For passive mode neutron assays, the operational ra nge is from the system’s passive

mode LLD to 2.050 g 240 

## Pu EFF 

## 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 ran ge is the system’s active mode LLD

to 14.710 g 239 

## Pu EFF 

## in terms of activity, and an ABSMOD index range fr om 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 l imitations, 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 a bove, 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 system 8



## • Physical modifications to the DWAS IPAN/SGS NDA syste m approved 9



## • Extension or changes of the approved calibration ra nge(s) for the DWAS IPAN/SGS

system

The last bulleted item above refers to the extensio n 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 t his inspection. An EPA technical

inspection involves the evaluation of several chara cteristics 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 fol lowing two aspects:

8 

### New NDA equipment refers to a system or component not previously eval uated by EPA at ORNL-CCP.

Specifically, this is defined as a physically disti nct or different system or apparatus; an assay syst em that is reported

to be the equivalent of or identical to a previousl y approved system, but which EPA has not formally i nspected and

approved, is a new system and EPA must approve it p rior to its implementation to characterize WIPP was tes.

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 qualit y of NDA data used for the purposes of WC and/or wa ste isolation.

This does not include minor changes or safety-relat ed changes (e.g., addition of handrails) that do no t have the

potential to affect WC data.

### 39



## • Activity—the nuclear disintegration rate of specifi c radiation types (neutron or gamma),

typically special nuclear material or TRU radionucl ides; 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 sys tem’s ability to detect them); examples

include attenuation of photons (gamma) and moderati on and absorption of neutrons

During the inspection, the system’s technical capab ilities being evaluated represent the

conditions observed, and they define the operationa l 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 condi tions 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 al ways, a subset of a calibration range; that is,

systems that are calibrated to make valid neutron m easurements from 0.36 g to 30.1 g 240 

## Pu EFF 

## may operate in a subset of this range. This typica lly occurs when a system is calibrated for

material control and accountability (MC&A) measurem ents as well as for WIPP assays, as is the

case with many NDA systems used for TRU assays. Pr ovided the system’s calibrated range is

valid, a site can designate a different operating r ange(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/cm 3 

## for the

DWAS SGS component or an ABSMOD index range of 22.2 51 to 276.800 for the active neutron

mode of the DWAS IPAN, discussed earlier in this rep ort. This range may include materials that

are commonly referred to using terms such as “debri s (S5000),” which is within the calibrated

density range and would be expected to be within th e ABSMOD range. Actual waste assays

may be restricted to a portion or subset of this ra nge for a variety of technical and/or

administrative reasons. Changing the calibrated ra nge by extending the density range beyond

0.72 g/cm 3 

## 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 uni t is a T1 change. Provided the original

approved density range is valid, changing the opera tional range(s) of an approved NDA

system—that is, decreasing it relative to the origi nally approved range—is a T2 change, as

discussed below.

ORNL-CCP will report and submit documentation for T 1 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. E PA may request additional information,

choose to conduct a desktop review, and/or confer w ith ORNL-CCP NDA personnel. Upon

evaluation (with or without site inspection), EPA w ill 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 O RNL-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 eith er 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 f ollowing:

• Changing a system’s operating system (e.g., first u se of NDA 2000, MGA, or PCFRAM)

• Identification of a systematic problem with a softw are 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 da ta reduction software)

• Introduction of a new version of an existing softwa re 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 equipmen t 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 r esult of those, this would be a T2 change.

Any changes to the WC activities from the date of t he baseline inspection must be reported to

and approved by EPA according to Table 1. Followin g EPA approval, ORNL-CCP will provide

EPA with information concerning T2 changes at the e nd of each fiscal quarter. EPA will

evaluate these changes and communicate with ORNL-CC P as to whether the changes raise any

concerns and require an ORNL-CCP response, or wheth er ORNL-CCP can continue to

implement the changes. Consistent with EPA’s autho rity under 40 CFR 194.24(h), the agency

may request information relative to these changes i f 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, th e team reviewed the elements of the RTR

process listed below. Emphasis was placed on overa ll procedural technical adequacy and

implementation and the identification of WMPs and p rohibited items:

• Documentation of RTR activities through use of an a pproved 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 t he 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 con tainers in Waste Stream OR-NFS-CH-HET

must be repackaged into drums prior to RTR examinat ion.

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 ope rations:

• 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 Radiog raphic Test and Training Drum

Requirements, Revision 3, January 19, 2006

• CCP-QP-002, CCP Training and Qualification Plan, Re vision 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 V erification, 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 Pla n, Revision 19, May 22, 2007

A complete listing of all objective evidence that w as evaluated during the inspection is provided

below:

• RTR BDRs: OR-RTR6-001, OR-RTR6-003, OR-RTR6-007 (S 5000 debris waste)

• Audio/visual recording of RTR events for drums from the above BDRs

• Written record of the initial capability demonstrat ion for drum RTR operators, September

2007

• Capability demonstration audio/visual recordings fo r selected operators

### 42



## • CCP-TP-053, Attachment 1, CCP RTR Measurement Contr ol 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 Proje ct Level Validation Checklist and

Summary for BDRs OR-RTR6-001, OR-RTR6-003, OR-RTR6- 007

• CCP-TP-053, Attachment 2, CCP Radiography Data Shee t, for demonstration drum

X10C0501308

Technical Evaluation

During the inspection, the following technical elem ents of the RTR process were investigated:

(1) Overall procedural technical adequacy and implement ation were investigated and were found

to be acceptable.

EPA reviewed the RTR procedure, CCP-TP-053, and det ermined that it was technically

adequate. The procedure contained specific informa tion on performing nonintrusive

radiography, including operational setup and check out, identification of prohibited items,

assignment of WMPs and estimation of weights and vo lumes, confirmation of WMCs, input of

data, and issuance of NCRs. Technical and project l evel 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 t hat 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 che cklist. During the onsite inspection, EPA

observed the RTR event for X10C0501308, a S5000 deb ris drum. EPA also reviewed the

previously generated written BDR and the audio/visu al recordings for selected drums and

determined that procedure CCP-TP-053 was implemente d as written.

Notification to EPA upon the implementation of new R TR equipment or substantive changes to

the approved RTR equipment is a T2 change. (See Ta ble 1, which includes this as a T2 change.)

(2) Characterization of WMPs and prohibited items w as investigated and was found to be

adequate following modifications to ORNL-CCP docume nts.

The RTR procedure requires that the radiography aud io/visual recording equipment be verified at

the beginning of every shift. Verification is achi eved 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 intervie wing RTR operators; reviewing

measurement control reports for BDRs OR-RTR6-001 th rough OR-RTR6-007; and reviewing

video/audio recordings for BDRs OR-RTR6-001, OR-RTR 6-003, and OR-RTR6-007. The RTR

operators demonstrating the RTR procedure had a har d copy of the waste stream description for

the waste stream being processed available for revi ew. The RTR operators were able to explain

### 43



## how they answered questions on the RTR data sheet w ith 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 o n 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 o bjects 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 varyin g densities in the material examined. During

the RTR examination, the operator also jogged the d rum to determine the presence of free

liquids. “Jogging” the drum is abruptly changing t he direction of the rotation to make the drum’s

contents move, a useful technique to cause free liq uids within the drum to splash, thereby

enabling the RTR operator to acknowledge their pres ence.

The RTR operator identified WMPs associated with th e container being examined, and a second

RTR operator electronically entered the data into a n RTR data sheet. At the end of the

examination, the operator estimated the weight of e ach recorded WMP and ensured that the total

WMP weight matched the weight value obtained by act ually weighing the container. Most

weight values that were recorded were estimates, al though Table 3 of the RTR procedure

contains historically derived weights for some comm on items. The absence of prohibited items

was recorded on the data sheet. EPA further verifi ed this by reviewing previously recorded

written and audio/visual records. The operator rec ording 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 t he 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 For m (see Attachment C.1 of this report for a

copy of this form). This concern is discussed belo w.

EPA Inspection Issue Tracking Form, Issue No. ORNL- CCP-CH-RTR-001CR: When the

templates used to complete Attachments 1 and 2 of C CP-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” (sati sfactory) for the questions for

“Video/Audio Recorded Media System Check” and “Imag e Test Pattern Test.”

• The entries indicating the number of lines-pair/ce ntimeter had already been filled in to

indicate “25.”

• Section 3 of Attachment 2 contained entries for “ho rsetail” and “plastic,” and the

question “NCR(s) associated with the container?” was checked “No.”

Even when the form was reset, the check marks did n ot 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 cont ain any information filled in upon opening.

The ORNL-CCP resident Quality Assurance Engineer ve rified 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 fi llable forms. ORNL-CCP training in lessons

learned was developed and distributed to all ORNL-C CP 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 t o 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 exa mined and was found to be adequate.

Simultaneous audio descriptions and video recording s are made as the waste is examined. These

data are also recorded on the electronic data sheet s, and hard copies of the examinations are

provided in the BDRs. The EPA inspector verified t his 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 r ecording matched the written RTR record in the

BDR.

(4) Documentation of radiography procedures was ass essed and was found to be adequate.

Radiography procedures are well defined, and the do cuments are controlled. During the

inspection, the EPA inspection tem reviewed the ade quacy and implementation of all current

radiography-related procedures. Quality control (Q C) examinations were performed as required

by the procedure. In BDR OR-RTR6-001, an independe nt observation was performed on

container X10C0501146, and a replicate scan was per formed on container X10C0501144. In

BDR OR-RTR6-003, an independent observation was per formed on container X10C0505973,

and a replicate scan was performed on container X10 C0506048. In BDR OR-RTR6-007, an

independent observation was performed on container X10C0501407, and a replicate scan was

performed on container X10C0501270. As required, d ifferent operators performed the analyses

of the original and the QC replicate samples. Reco nciliation 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 be low.

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 a s minor differences in the recorded WMP

weights. CCP-TP-053 only requires reconciliation o f discrepancies when “identification of the

WMC, liquids in excess of TSDF-WAC limits and compr essed gases differ between the two

operators.” The same situation applies to the inde pendent and original observations. While this

practice complies with the requirements of CCP-TP-0 53, 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 ne eds 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 initi ated for container X10C0501123

because the container’s waste did not match the was te 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 ap proved 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 viewe d 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 Octobe r 1, 2007

• Audio/visual recording of drum RTR capability demon stration for the four

operators/ITRs, dated September 26, 2007, or Octobe r 1, 2007

• Inventory for training drums, ORNL-NDE-TEST-001 and ORNL-NDE-TEST-002

The operator/ITRs successfully identified all of th e prohibited items contained in the training

drum. However, the operators/ITRs consistently dem onstrated that they were unable to identify

all of the unknown items in the drum, including car dboard 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 correc tly identified all of the required prohibited

items in the capability demonstration training cont ainers, they did not identify some additional

items, specifically cellulosics and plastic. All c ellulosics and plastics in the training drum need

to be identified and their identification documente d. To complete the training process, it is

critical that the operator receives feedback regard ing 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 findin gs in the area of RTR during this baseline

inspection. The EPA inspection team did identify t hree 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 the se issues. EPA considers all three

concerns to have been adequately addressed, and the re are no open concerns related to RTR at

ORNL-CCP resulting from this inspection.

Baseline Approval

The baseline conditions that the EPA inspection tea m 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 da ta 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 a bove, EPA proposes to assign the following

tiers:

### 47



## T1 RTR changes require EPA review and approval prior to implement ation. 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 requ ire 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 w hether 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 container s. 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 characterizati on 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 operat ions relative to the requirements of

CCP-TP-030, Revision 22, July 24, 2007:

• Waste Certification Assistant (WCA) Qualification C ard ( 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 LA0000006211 3

• 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 we ll 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 infor mation if EPA deems it necessary to ensure

continued compliance with EPA regulations. (See Ta ble 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 s o after being granted access by the WWIS

Administrator, and access is password protected. E PA 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 th e demonstration used container data from

other CCP sites. The demonstration consisted of ch anging data for containers 10086822 and

LA00000062113 to verify that the WWIS rejects conta iners that are not WIPP compliant. Both

compliant and noncompliant versions of the containe r data were submitted to the test instance of

the WWIS. The WWIS rejected the containers with no ncompliant 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 the y 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 demonstr ated. 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 t he 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, Ne w 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 t he WWIS process for the EPA

inspection team was not this individual. EPA obser ved 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 traini ng 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 record s 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 C ertification 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 n ot seeking approval to perform load

management, and EPA excluded evaluation of load man agement 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 cha nge.)

Summary of WWIS Findings and Concerns

The EPA inspection team did not identify any findin gs 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 wa s evaluated during this baseline inspection

consisted of the following:

• Trained WWIS WCAs and WCOs

• Approved and controlled operating procedure: CCP-T P-030, Revision 22

WWIS Tiers

Based on the inspection and the results discussed a bove, EPA proposes to assign the following

tiers:

T1 WWIS changes that require EPA review and approval prior to impl ementation include the

following:

• Addition of load management for CH TRU containers a t ORNL-CCP

ORNL-CCP will report and submit documentation for T 1 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 informati on, choose to conduct a desktop review,

and/or confer with ORNL-CCP WWIS personnel. Upon e valuation (with or without site

inspection), EPA will issue an approval letter. On ly 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 implemen tation 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 a nd 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 acco rdance with procedure CCP-TP-068,

CCP Container Management at the Idaho Laboratory (I NL) and TRU Waste Processing Center

, Revision 5, September 20, 2007. EPA inspectors eva luated 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 pro cessing at ORNL is provided below:

• Incoming containers of CH TRU waste are processed i n 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 it em is identified, an NCR is initiated

and the container is returned to Energx for remedia tion. 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 T RU alpha activity of the container

is less than 100 nCi/g and the container is returne d 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 p erforming 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 ti me does ORNL-CCP own the containers

processed. After receipt, the ORNL-CCP Container M anager initiates procedure CCP-TP-068,

and a container inspection is performed and documen ted 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 char acterization activities performed on containers

from this point forward are recorded on the travele r. 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 contain er management personnel which containers

need to be moved to NDE on that day. The NDE equipm ent is located in the CHSA. Upon

### 51



## completion of NDA, containers are moved to the DAC s torage areas, which are cargo containers

located close to the CHSA. Headspace and/or flamma ble gas analysis takes place in Room 122.

It is anticipated that the CHMB will be completed i n December 2007. Upon completion, the

containers presently stored in the DAC containers w ill be moved to CHMB to await shipment to

the WIPP. ORNL-CCP does not know what containers a re in each area at any one time because

Energx is responsible for tracking the containers.

Rejected containers are returned to Energx. The En ergx 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 contain er 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 th e WIPP. ORNL-CCP’s WCO will enter data

into the WWIS for container certification. The Tra nsportation Certification Official (TCO) will

build a payload and provide this to Energx. Load m anagement will not be used for these

containers. ORNL-CCP loaders will place the contai ners 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 manage ment.

9.0 RESPONSE TO COMMENTS

EPA did not receive any comments on the proposed ap proval.

10.0 SUMMARY OF RESULTS

10.1 Findings and Concerns

The concerns identified during the inspection, as w ell 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 insp ection process. Due to the nature of the

concern, the fact that it occurred in conjunction w ith this inspection is coincidental and does not

reflect on the technical adequacy of the ORNL-CCP W C 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 conside rs 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 t o the inspection. The EPA inspection team

members evaluated all responses for completeness an d adequacy and concluded that each EPA

issue requiring a response had been resolved satisf actorily. 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-CC P WC program activities were

technically adequate. EPA is proposing to approve the ORNL-CCP WC program in the

configuration observed during this inspection and d escribed in this report and the attached

checklists (Attachments A.1 through A.4). This app roval 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 an y 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 t his 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 fo r 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 en d 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, 2007.53Table 8. Tiering of TRU WC Processes Implemented by ORNLBased on November 13–15, 2007, Onsite Baseline InspectionWC Process ElementsORNL-CCP WC T1 ChangesORNL-CCP WC T2 ChangesaAcceptable Knowledge (AK) andLoad ManagementImplementation of load management; AK (5)Implementation of AK for wastes other than retrievablystored debris (i.e., retrievably stored soil/gravelandsolids and/or any type of newly-generated waste); AK(15)Notification to EPA upon completion of AK accuracyreports; AK (2)Notification to EPA upon completion of new versionsorupdates/substantive changesbof the following:-Changes to AK-NDA communications and memoranda; AK(3)-Changes to site procedure; AK (4)-AK Summaries that describe wastes beyond the 144 containersdescribed in this report; AK (6)-Radiological Discrepancy Resolution Reports (AK-AKand AKNDA) pertinent to Waste Stream OR-NFS-CH-HET; AK (11)-Completed Attachments 4 and 6 and associated memoranda forWaste Stream OR-NFS-CH-HET; AK (10) and (14)-AK Summaries/Waste Stream Profile Forms (WSPFs) andAKdocumentation reports; AK (15)Non Destructive Assay (NDA) New equipment or physical modifications to approvedequipmentc; NDA (1)Extension or changes to approved calibration rangeforapproved equipment; NDA (2)Notification to EPA upon completion of changes to software for approvedequipment, operating range(s), and site proceduresthat require CBFOapproval; NDA (2)Real-Time Radiography (RTR) N/A Notification to EPAupon the following:-Implementation of new RTR equipment or substantivechangesbtoapproved RTR equipment; RTR (1)-Completion of changes to site RTR procedures requiring CBFOapprovals; RTR (2)Visual Examination (VE) Not approved at this timeNot approved at this timeWIPP waste Information System(WWIS)Implementation of load management; WWIS (4) Notification to EPA upon the following:-Completion of changes to WWIS procedure(s) requiring CBFOapprovals; 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 that are solely related to ES&H,nuclear safety, or RCRA, or that are editorial in nature.cModifications to approved equipment include all changes with the potential to affect NDA data relativeto waste isolation and exclude minor changes, suchas the additionof safety-related equipment.

### 54



## 11.0 REFERENCES

New Mexico Environment Department, Waste Isolation P ilot Plant Hazardous Waste Facility

Permit (WAP), NM48901 139088-TSDF, Santa Fe, New Mexi co, 1989.

U.S. Code of Federal Regulations , Title 40, Protection of Environment, Part 191,

“Environmental Radiation Protection Standards for M anagement 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, Compli ance Certification Application for the

Waste Isolation Pilot Plant,” DOE/CAO 1996-2184, Ca rlsbad, New Mexico, 1996.

U.S. Department of Energy, “40 CFR Part 191, Subpar ts C and D, Compliance Recertification

Application 2004,” DOE/WIPP/2004-3231, 2004.

U.S. Department of Energy, “Transuranic Waste Basel ine Inventory Report,” Revision 0,

DOE/TRU-2206-3344.

U.S. Department of Energy, Carlsbad Area Field Offi ce, “Contact-Handled Transuranic Waste

Acceptance Criteria for the Waste Isolation Pilot P lant (CH-WAC),” Revision 3, DOE/WIPP-02-

3122, Carlsbad, New Mexico, April 25, 2005.

U.S. Department of Energy, Carlsbad Area Field Offi ce, “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 D isposal Regulations: Certification Decision;

Final Rule,” Federal Register , Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405.

U.S. Environmental Protection Agency, “EPA Replicat e Testing for WIPP Nondestructive Assay

(NDA) Systems,” Revision 2, June 2002.

U.S. Nuclear Regulatory Commission, “Contact-Handle d Transuranic Waste Authorized

Methods for Payload Control.”AK-1ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective EvidenceGENERALAK-1:Is the waste TRU by definition as presented in theLWA?(P.L.102-579)CCP-TP-005, Revision 18; Section4.4.31; CH-WAC Revision 3; P.L.102-579Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-AK-ORNL-001 Revisions 0 and 1.Load Management will not be performed;The implementation of Load managementis a T1 change.AK-2:Do the presented volumes comport with LWAcapacity restrictions?(P.L.102-579)CCP-TP-005, Revision 18; CH-WACRevision 3; P.L. 102-579Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCP-AK-001 Revisions 0 and 1, M012.Available data indicate that assessed wastestream is within the LWA capacityenvelope.AK-3:Are any wastes considered (or previouslyconsidered) high level wastes (HLW)? HLW areprohibited.(P.L.102-579)CCP-TP-005, Revision 18; CH-WACRevision 3; P.L. 102-579Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-AK-ORNL-001 Revisions 0 and 1.HLW are not present in the waste streamexamined during this inspection.AK-4:Are any wastes considered (or previouslyconsidered) Spent Nuclear Fuel?(P.L.102-579)CCP-TP-005, Revision 18; CH-WACRevision 3; P.L. 102-579Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-AK-ORNL-001 Revisions 0 and 1,P273. CCP representatives indicate that noSNL are in examined waste stream.AK-5:Are these defense wastes?(P.L.102-579)CCP-TP-005, Revision 18; CH-WACRevision 3; P.L. 102-579Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-AK-ORNL-001 Revisions 0 and 1,M021, C099, C100AK-6:What is the scope of authorization sought (i.e.,SCG, newly generated vs. retrievably stored, othersitespecific breakdowns?)CCP-TP-005, Revision 18; CH-WACRevision 3; P.L. 102-579, CRA 2004Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-AK-ORNL-001 Revisions 0 and 1.Scope of authorization is retrievably storedcontact handled debris S5000 wastes. Anywaste outside of this scope is considered aT1 change.AK-7:Is AK being used that was assembled prior to anEPA approved QA program (retrievably stored)? If so,what qualification process is used? Is this wasteundergoing confirmation as per the CCA/CRA (100%sampling)?CCP-TP-005, Revision 18; CH-WACRevision 3; P.L. 102-579Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-AK-ORNL-001 Revision. 0 and 1.Waste is retrievably stored and willundergo 100% RTR and NDA (allcontainers will be assayed) via the ORNLCCP processes.AK-2ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidence[194.24(c)(2)-(5), 194.22(a)]AK-8:Is AK being assembled as waste is generated afterEPA approval of the QA program (newly generated)?Isthis waste undergoing confirmation as per the CCA/CRA(100% sampling)?[194.24(c)(2)-(5)]CCP-TP-005, Revision 18; CH-WACRevision 3; P.L. 102-579Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-AK-ORNL-001 Revisions 0 and 1.Newly generated waste was not in thescope of this inspection.AK-9:Procedures require staff to be qualified toassemble, compile, and confirm AK data, including,butnot limited to:a. Identification of required reading list and successfulcompletion of all required reading including, but notlimited to:•Applicable portions of the WIPP WAP and TSDFWAC•WIPP Compliance Certification Decision Conditions2 and 3•State and Federal RCRA regulations associated withsolid and hazardous waste characterization•Discrepancy resolution and reporting processes•Site-specific procedures associated with wastecharacterization using acceptable knowledgeb. Successful completion of testing to demonstrateunderstanding of required reading listc. Completion of internal and/or external trainingprograms pertinent to AKd.Participation in internal audits to assess AK programe.Other methodologies for demonstrating AKproficiency as developed on a site-specific basis(WAP B4, B4-3a)CCP-TP-005, Revision 18, Section4.1.2; CCP-QP-002, Section 4.2Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsTraining records for Jeff Harrison andDave Atkins were reviewed. Dataavailable indicate that both were trained inall areas, but there was no evidence ofWIPP CCA training. EPA suggests thatORNL-CCP incorporate CCA/CRAtraining into its programs.AK-10:CCP-TP-005, Revision 18; CCP-TP- Review of objectiveProcedures examined include AK forAK-3ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidencea. Are procedures adequate to encompass the spectrum ofwastes for which authorization is sought?b. Are there different procedures for newly generated vs.retrievably stored waste? Are there differentprocedures for solid, debris, or soil waste? Shouldthere be?c. For newly generated waste, have adequate proceduresbeen developed and implemented to characterize wasteusing acceptable knowledge prior to packaging?(WAP B4, B4-3b)066 evidence and interview ofJeff Harrison and DaveAtkinsretrievably stored debris waste; thereforethe scope of the procedures examinedcompasses the desired authorization. Theinspection did not include newly generatedwaste. Note that any substantive changesto CCP-TP-005 would be a T1 change.ASSEMBLING AK INFORMATION AND COMPILING AK DOCUMENTATION INTO AN AUDITABLE RECORDAK-11:What is the breakdown of the types andquantities of TRU waste generated/stored at the site?(WAP B4, B4-2a)CCP-TP-005, Revision 18, Section4.4.8Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsTWBIR Reference 9, M012, U040 includesthe most recent breakdown of wastes at thesite. Note that CCP accepts wastes/streamsidentified by the site and indicated duringinterviews that personnel are not involvedwith full-site inventory analysis.AK-12:Do procedures call for AK information to becollected for:a.241Am,238Pu,239Pu,240Pu,242Pu,233U,234U,238U,90Sr,137Cs + unexpected radionuclidesb. Ferrous metals (in containers)c. Cellulosics, plastics, rubberd. Nonferrous metals (in containers)(CRA/CCA Ch 4 and Attachments/Appendices)CCP-TP-005, Revision 18, Sections4.4.21, 4.4.22, 4.4.24Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsAttachment 6 of CCP-TP-005; Attachment7 CCP-TO-005. Weight percent of WMPsand radiological characteristics areincluded in Attachments 6 and 7 as the AKNDE and AK-NDA memoranda. Changesto the AK-NDA memorandum would be aT2 change, while revision to the AK-NDAmemorandum specifically to address issuesidentified by EPA during the inspection is aT1 change.AK-13:Do procedures require documentation ofradionuclide process origin?Are the facility and TRU waste management operationscorrelated to specific waste stream information?(Attachment B4; WAC Appendix A.2.2)CCP-TP-005, Revision 18, Section4.4Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-AK-ORNL-001 Revisions 0 and 1,C122, P268, P272, P273, U016, U017,P284, I056, I058, I059, I061AK-4ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective EvidenceAK-14:Are correlations between waste streams, withregard to time of generation, waste generating processes,and site-specific facilities clearly described? For newlygenerated wastes, the rate and quantity of waste tobegenerated shall be defined.(Attachment B4, B4-3c; WAC Appendix A, Section A.2)CCP-TP-005, Revision 18, Section4.4Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-AK-ORNL-001 Revisions 0 and 1,U233, C100, C119, C121, C127, C130,I052, M007,M017-M019. CCPrepresentatives indicated that newreferences (i.e.,233U) would be added to therecord (Attachment 4) to more thoroughlyaddress the dates of D&D to ensure thatrecord reflects waste stream generation.AK-15:a.Are waste streams appropriately identified and arewastes characterized on a waste stream basis?b.Are wastes grouped on a waste stream basis usingAcceptable Knowledge?(Attachment B4, Section B-1a)CCP-TP-005, Revision 18, Section4.4, 4.2.3Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-AK-ORNL-001 Revisions 0 and 1,U038. Describes the waste stream in detailfor the post 2000 time period. Note that themachine compacted waste associated withthe stream were not included in the streamas inspected.AK-16:Do procedures demonstrate a logical progressionfrom general facility information to more detailedwastestream-specific information?CCP-TP-005, Revision 18, Section4.4Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-AK-ORNL-001 Revisions 0 and 1,M001-M013, M016-M019, M021, P256,P272, P273. Can track waste throughgeneration at building 234 to Energx/FosterWheeler processes, to CCP management ofcontainers.AK-17:Does the process include review of AKinformation to evaluate and document AK-AKinformation discrepancies?(WAC Section A.2.2.3, Attachment B4, Section B4-3)CCP-TP-005, Revision 18, Section4.8Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsDR002 deals with radiologicaldiscrepancies. Note that this DR requiredrevisions to more completely address howthe issues were resolved (i.e., to state issueresolution). The revision of DR002 andany DRs are T2 changes.AK-5ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective EvidenceAK-18:Do procedures require collection of informationregarding how waste is tracked and managed at thegenerator site (including historical and currentoperations)?(WAC Section A.2; Attachment B4 Section B4-2a)CCP-TP-005, Revision 18, Section4.4Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsPTS (and related CTS) printouts; AKTracking Spreadsheet, M017, M018,M019. Site’s EM-12 database tracksoverall drums. The PTS’s CTS moduletracks NRCs internally. Historic trackingrecords included in M017-M019.AK-19:Is AK information compiled in an auditablerecord, including a road map for all applicableinformation?CCP-TP-005, Revision 18,Attachment 4Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsAttachments 1 and 4, of CCP-TP-005.Stream and general reference lists.AK-20:Has a reference list been provided that identifiesdocuments, databases, Quality Assurance protocols,andother sources of information that support AKinformation?(Attachment B4, Section B4-3c)CCP-TP-005, Revision 18,Attachment 4Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-TP-005, Attachment 4. Note thatCCP representatives indicated this list willbe substantially revised to expand thestream in the near future; providingrevisions to this checklist is a T2 change.AK-21:Have the following mandatory informationrequirements been identified?•Map of the site that identifies the areas and facilitiesinvolved in TRU waste generation, treatment, andstorage•Facility mission description related to TRU wastegeneration and management•Description of the operations that generate TRU wasteat the site and process information, including:- Area(s) or building(s) from which the waste streamwas or is generated- Estimated waste stream volume and time period ofgeneration- Waste generating process description for eachbuilding or area- Process flow diagrams, if appropriateCCP-TP-005, Revision 18, Section4.4Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-AK-ORNL-001 Revisions 0 and 1;P273, CCP-TP-005, Attachment 8; C122,Attachment 7 AK-NDA Memorandum.The AK summary and associatedreferences address mandatory informationrequirements noting that flow diagrams andother information may be in references,rather than the AK summary.AK-NDA memorandum includesinformation pertaining to scaling factorsand general radiological characterization.Note that the CCP process calculateddefault isotopics based on MOXcomposition; several NDA analysesperformed prior to CCP, but CCP does notbelieve that the measurements are valid.Specification for WIPP isotopes isprovided in the AK-NDA memo.Revisions to this memorandum are requiredto explain ratio basis and other issues. AnyAK-6ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidence- Generalized material inputs or other information thatidentifies the radionuclide content of the wastestream and the physical waste form- Types and quantities of TRU waste generated,including historical generation through futureprojections•Physical/chemical waste composition that could affectisotopic distribution (i.e., processes to remove ingrown241Am)•Statement of all numerical adjustments applied toderive the material’s isotopic distribution, e.g.,scalingfactors, decay/ingrowth corrections and secularequilibrium considerations•Specification of isotopic ratios for the 10 WIPP-trackedradionuclides and, if applicable, the radionuclidesthatcomprise 95% of the hazard(WAC Section A.2.2; Attachment B4, B4-2a, B4-2b)changes to the AK-NDA memorandum toaddress EPA’s concerns is a T1 change,while future changes to AK-NDAcommunications and memoranda are T2changes.AK-22:Does the site have procedures for the collectionof supporting information? Examples of supplementalinformation, from WAC, include:•Safeguards and security and other material controlsystems/programs•Reports of nuclear safety or criticality•Accidents involving SNM waste packaging and wastedisposal•Building or nuclear material management area logs orinventory records•Site databases that provide SNM or nuclear materialinformation test plans•Research project reports, or laboratory notebooks thatdescribe the radionuclide content of materials usedinCCP-TP-005, Revision 18, Section4.4Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-TP-005, Attachment 4, C100, M012,M016, M017, M018, I056, M007, M011,P251, P256, P272, U016, U017, U040,P284. Adequate supporting information ispresent, noting that updates to Attachment4 would be a T2 change.AK-7ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidenceexperiments•Information from site personnel•Historical analytical data relevant to isotopicdistribution in the waste stream(WAC Section A.2.2.2; Attachment B4 Section B4-2c)AK-23:Is all necessary supporting informationassembled and has it been appropriately used?(Section B4-2c)CCP-TP-005, Revision 18, Section4.4Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-TO-005 Attachment 1. Crossreferences of data to requirements arepresented, but site representatives indicatedthat additional information was beingassembled to augment listing.AK-24:a. Are waste categorization schemes presented and arethey appropriate?b. Are waste identification/categorization schemesrelevant to the isotopic composition of waste?(Attachment B4 Section B1, WAC page ix, AppendixA.2)CCP-TP-005, Revision 18, Section4.4Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-AK-ORNL-001 Revisions 0 and 1,Attachment 6. Note that wastecategorization schemes are based onWMPs and do not include isotopicdistribution, because it is not mandated bythe CH definition of waste stream.AK-25:Have data uses and limitations been assembledand are they technically adequate?(CRA/CCA; WAC Appendix A, Section A.2.2.3)CCP-TP-005, Revision 18, Section4.4Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-TP-005, Attachment 3 is included oneach source document and sites datalimitations. Example U044 should includea data limitation associated with the use ofdefault isotopics, and future EPAinspections will include examination of thisreference.AK-26:Site documents/procedures require the facility toprepare an AK summary document that summarizes allinformation collected, including the basis for allwastestream designations. Is the AK Summary of sufficientscope and detail?(WAC Appendix A Section A.2.2; Attachment B4Section B4-2b, Attachment B Section B-3d (1), (2))CCP-TP-005, Revision 18, Section4.4Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-AK-ORNL-001 Revisions 0 and 1.Revisions to the AK Summary to addressEPA concerns and outstanding issues wereconsidered a T1 change (note that Revision1 was provided to EPA).AK-8ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective EvidenceAK-27:Are conclusions and interpretations presented inthe AK Summary technically sound and supported byreferenced mandatory and supplemental information?CCP-TP-005, Revision 18 Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsSee AK-26. Note that CCP intends toupdate the AK Summary and providedRevision 1; additional revisions couldoccur in the future to expand the streamand would be considered a T2 change.Also note that updated Attachments 4 and 6are considered T2 changes, both of whichwill document future expansions of thestream.AK-28:If AK data discrepancy is identified, site willevaluate the source of the discrepancy to determineifdiscrepant information is credible. Information that is notcredible will be identified as such and reasons fordismissing will be justified in writing. Limitationsconcerning information will be documented in the AKrecord and summarized in the AK report. If adiscrepancy cannot be resolved, the site will performdirect measurements for the impacted population.(WAC Appendix A.2, Section A.2.2.3)CCP-TP-005, Revision 18, section4.4Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsDR002; note that changes to this DR wererequired to address EPA issues identifiedduring the inspection.AK-29:Has the use of load management been proposed?Does the AK Summary include the following from theWAC, Revision 3, Appendix E?•Each TRU waste stream selected for payloadmanagement must include in its acceptable knowledgesummary report an estimate of the total waste volumeand the percentage of the waste volume that is aboveand below 100 nCi/g. (It should be noted that thisinformation, although based on the best available AKinformation, is preliminary and subject to theperformance of WIPP-certified NDA measurementsand cannot and will not be used as a measure of AKaccuracy.) (Reference E3)(WAC, Appendix E)CCP-TP-005, Revision 18, Section4.4Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsLoad management is not proposed.Implementation of load management wouldbe a T1 change.AK-30:Are nonconforming wastes segregated? AreNCRs dispositioned in an appropriate and technicallyCCP-TP-005, Revision 18 Review of objectiveevidence and interview ofNCR examples were provided from CTS.Note that EPA assessed container trackingAK-9ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidencedefensible manner?(Attachment B4, Section B4-3b, Attachment B3, SectionB3-13)Jeff Harrison and DaveAtkinsseparately from the evaluation of AK.AK-31:Do site procedures require that additionalinformation be collected before waste may be shipped ifthe required AK information is not available for awastestream or if available AK is poor or unacceptable?(Attachment B4 )CCP-TP-005, Revision 18, Section4.4Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsNot Applicable. Necessary informationwas available for the stream OR-NFS-CHHET, as examined during the inspection.AK-32:Do these procedures facilitate the mandatorytraceability analysis performed for each Summary WasteCategory Group examined during the audit, noting thatEPA will determine whether the available waste streamsadequately demonstrate the full characterization processfor the proposed scope?(Attachment B4, Section B4-2)CCP-TP-005, Revision 18, Section4.4Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsBatch Data Reports OR-RTR-002, 006 and007; OR-DWAS-001, 002; M016, M017,M018, Attachment 8 of CCP-TP-005; DraftWSPF and CCR. Traceability can beperformed from original NFS-shippedcontainers through Energyx/Foster wheelerprocesses/repackaging, to CCP.AK-33:If AK was used (i.e., data collected prior to QAprogram), what method was employed to qualify theinformation? Approved methods or peer review,corroborating data, confirmatory testing, and QA programequivalency? If confirmatory testing is used, hasthefollowing been considered (from WAC)?*•At a minimum, to confirm existing AK data, it isnecessary to compare ratios of the two most prevalentradionuclides in the isotopic mixa. For238Pu,239Pu,240Pu,241Pu,242Pu and241Am:•Confirmation can be accomplished via comparison ofmeasured and AK values for239Pu/240Pu for weaponsgrade plutonium;238Pu/239Pu for heat source•Measured241Am can be used to calculate241Pu (forsubsequent AK comparison) if time of chemicalseparation is known (no241Am at time of separationassumed)CCP-TP-005, Revision 18 Review of objectiveevidence and interview ofJeff Harrison and DaveAtkins; NDA personnelalso involved withdiscussions: NormanFrank, John West, JoeWachter, Sean Stanfield,Barry Smith, GeorgeWestik, Christa Chavez,and Joseph HarvillAK-NDA memo default isotopics; note thatdefault isotopics are used for all plutoniumisotopes except for241Am. Defaultisotopics were calculated assuming theradionuclide distributions for each fuelmaterial type were distributed equivalentlythroughout the D&D waste. Quantities ofPu for each material type were scaled basedon the amount of that material managed inBuilding 234, with SEFOR providing thegreatest contribution. Plutonium isotopicswere calculated based on the actualcontract composition of the fuel. Uraniumcontent was scaled based upon percentageuranium in the various MOX fuels andcalculated in accordance with procedureLA-UR-00-2584. Note that a referenceshould be added to the record supportingAK-10ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidence•241Pu can be compared (by ratio) to confirm AK ofany Pu isotope associated with WG/RG (i.e.,239Pu or240Pu)•238Pu from AK for WG/RG Pu is assumed to be validif the AK values of239Pu and240Pu have beenconfirmed by measurement•242Pu calculated by correlation techniques, since itcan’t be measuredb. For235U,233U,238U,234U:•Were they tracked or measured in AK information?•If no valid AK exists, data generated can only beused to detect or calculate, or confirm absence ratiosfor234U calculated from235U enrichment•If valid AK exists can confirm with certified systems•234U calculated by235U enrichment, because234Ucan’t be measuredc. For137Cs and90Sr:•Confirmed by WIPP-certified system (directmeasurement or comparison of241Am peak at 662keV to other241Am peaks (disproportionate241Ampeak at 662 keV could mean presence of137Cs)•90Sr calculated from137Cs using scaling factorsOther radionuclides – must identify via NDA and shouldidentify via AK*If the WAC requirements are not followed, identifyhowthe specific radionuclides are characterized via AK, andhow these data are used by NDA.(40 CFR 149.22(b), WAC, Appendix A, Section A.2.1)the 1:1 ratio used for137Cs and90Sr.AK-11ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective EvidenceAK-34:If waste is generated after an EPA approved QAprogram, are radioassay and NDE results compared tothedata assembly process as a cross reference to verifyimplementation of the as-generated characterizationprogram?(194.24 (c)(3); 194.22(b))CCP-TP-005, Revision 18 Not ApplicableNot applicable; newly generated waste wasnot included in the scope of EPA’sinspection.AK-35:This procedure requires a reevaluation of AK ifNDE identifies it to be a different waste matrix code.This procedure describes how the waste must bereassigned, based on the AK reevaluation.(Attachment B4, Section B4-3d)CCP-TP-005, Revision 18, Section4.9CCP-TP-005, Attachment 10 (exampleonly); NDE has not to date misidentifiedwastes by waste matrix code such thatwaste reassignment was required.AK-36:Does the generator site have written proceduresfor newly generated waste to document the confirmationof acceptable knowledge information with visualexamination 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 objectiveevidence and interview ofJeff Harrison and DaveAtkinsNot applicable; newly generated waste wasnot included in the scope of EPA’sinspection.AK-37:Procedures require the following steps to befollowed if wastes are reassigned to a different wastematrix code based on NDE:•Review existing information based on the containeridentification number and document all differences•Reassess and document all analytical data associatedwith the waste•Reevaluate waste material parameter determinationsand document any changes•Reevaluate the radionuclide content and document anychanges•Verify and document that the reassigned waste matrixcode was generated within the specified time period,area and buildings, waste generating process, and thatCCP-TP-005, Revision 18,Attachment 10Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP-TP-005, Attachment 10; exampleprovided from alternative site; no exampleavailable yet for ORNL-CCPAK-12ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidencethe process material inputs are consistent with thewastematerial parameters identified during radiography orvisual examination•Record all changes to acceptable knowledge records•If discrepancies exist in the acceptable knowledgeinformation for the reassigned waste matrix code,complete a nonconformance report, document thesegregation of this container, and define the correctiveactions necessary to fully characterize the waste(Attachment B4, Section B4-3e)AK-38:Has the acceptable knowledge expert calculatedthe percent changes in waste matrix code based on AKand NDE/VE? Were accuracy evaluations assigned? Arethese acceptable?(Attachment B3, Section B3-9; WAC Appendix A,Section A.6.5)An AK accuracy report has not yet beenprepared for ORNL-CCP. However, EPAhas evaluated the AK accuracy preparationprocess at other sites.AK-39:Are the following items addressed with respectto AK-NDA communication and the use of AK data byNDA personnel?•Do procedures require the identification of AK datalimitations?•Are AK data and associated limitations communicatedto NDA personnel and is this required by procedure?•How is AK used by NDA personnel?•Do AK and NDA personnel communicate and agreeabout the use of AK?•Is this agreement proceduralized?(WAC, Appendix A)CCP-TP-005, Revision 18,Attachment 6 and Section 4.4.22CCP-TP-005 Attachment 6 includes theAK-NDA memorandum. Thismemorandum required revision to addressEPA concerns regarding continuity of theMemo, AK Summary, and DR002. Thememorandum does not address specificallyhow NDA personnel use default isotopics,even though AK and NDA personnelindicated that default isotopics were usedfor most of the drums from this CH wastestream. EPA requires that while CCP didnot revise the AK-NDA memorandum tobe more specific in this regard, CCP shalldocument and justify the use of defaultisotopics when used, and all forthcomingAK-NDA memoranda must specify howNDA personnel use AK data.AK-13ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective EvidenceAK-40:Have internal AK audits been performed?(Attachment B4, Section B4-3d, g)CCP-TP-005, Revision 18 CCP-TP005, Revision 18Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP Internal Surveillance DatedNovember 14, 2007AK-41:If data consistently indicate discrepancies withacceptable knowledge information, the site increasessampling, reassesses the materials and processes thatgenerate the waste, and resubmits waste stream profileinformation.(WAC Section A.2.2.3; Attachment B4, Sections B4-3b,B4-33, Attachment B3)CCP-TP-005, Revision 18 Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsNot Applicable to this site; baselineinspection, so not enough informationcollected to require this reassessment.AK-42:Are acceptable knowledge processesconsistently applied among all generator sites, anddoeseach generator site comply with the following dataqualityrequirements for acceptable knowledge documentation:a. Precision - Precision is not applicable to AK (seeAttachment B4)b. Accuracy - Accuracy is the degree of agreementbetween an observed sample result and the true value.The percentage of waste containers which requirereassignment to a new waste matrix code is based onthe reevaluation of acceptable knowledge and samplingand analysis data will be reported as a measure ofacceptable knowledge accuracy. Accuracy based onradionuclide content is typically assessed by comparingmeasured results with AK data.c. Completeness - Completeness is an assessment ofthenumber of waste streams or number of samplescollected to the number of samples determined to beuseable through the data validation process. Theacceptable knowledge record must contain 100 percentof the information specified in Section B4-2. Theusability of the acceptable knowledge information willCCP-TP-005, Revision 18 Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsNo AK Accuracy report was prepared (seeAK-38). Note that the AKE indicated thatthe AK Summary would be updatedimmediately post-inspection to includeadditional references and to update the AKRecord (e.g., reference C233).Section A.6.5 of the WAC has not beenaddressed or completed, as no comparisonswere completed at the time of theinspection.Minimum standards were established.AK-14ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidencebe assessed for completeness during audits.d. Comparability - Data are considered comparable whenone set of data can be compared to another set of data.Comparability is ensured through sites meeting thetraining requirements and complying with the minimumstandards outlined for procedures that are used toimplement the acceptable knowledge process. WACSection A.6.5: Additionally, comparison of measureddata with AK-derived or -based values, as applicable,provides a means to assess comparability on a wastestream basis.e. Representativeness - Representativeness expresses thedegree to which sample data accurately and preciselyrepresent characteristics of a population.Representativeness is a qualitative parameter thatwillbe satisfied by ensuring that the process of obtaining,evaluating, and documenting acceptable knowledgeinformation is performed in accordance with theminimum standards established in Section B3. Sitesalso must assess and document the limitations of theacceptable knowledge information used to assign wasteparameters.(Attachment B3, Section B3-9)AK-43:Does the generator site address quality controlby tracking its performance with regard to the useofacceptable knowledge by: (1) assessing the frequency ofinconsistencies among information, and (2) documentingthe results of acceptable knowledge confirmation throughradiography or visual examination? In addition, theacceptable knowledge process and waste streamdocumentation must be evaluated through internalassessments by quality assurance organizations andassessments by auditors or observers external to theorganization (i.e., CBFO, NMED, EPA).(Attachment B3, Section B3-9)CCP-TP-005, Revision 18 Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP tracks via “L” trend code analysis.CCP AK representatives indicated that thiswas outside of the AK scope. CCPrepresentatives also indicated that annualinternal surveillances are performed toassess AK performance. EPA will assess Ltrend code performance for Oak Ridge inthe future, once characterization has beenongoing for a period of time.AK-15ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective EvidenceAK-44:Did the generator site implement, ordoes it currently implement, process controls toensure that prohibited items are documented andmanaged in accordance with site-specificcertification plans? What process controls are inplace to assess prohibited items and other wastecharacteristics (i.e. is fast scan used, and, if so,by whom)?(Attachment B4, Section B4-3b)CCP-TP-005, Revision 18 Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsP254. CCP representatives indicated thathistoric AK VE/RTR data are used toassess the presence of prohibited items, andthat Foster Wheeler may (then) process orrepackage waste to address issues usingnon-WIPP methods. CCP would thenperform VE on these processed containersin accordance with CCP/WIPP procedures.If a prohibited item is found, it will beaddressed via NCR and sent back to FosterWheeler/Energx. CCP does not performfast scan on the containers.AK-45:Does the generator site document, justify, andconsistently delineate waste streams based on site-specificpermit requirements or state-enforced agreements?Howdo these agreements impact waste characterization?(Section B4-3e)CCP-TP-005, Revision 18 Review of objectiveevidence and interview ofJeff Harrison and DaveAtkinsCCP representatives indicated that OR’sCH program deadlines have apparentlybeen affected or otherwise impacted bystate agreements to establish a CHcharacterization program by a certain date(Jan, 2008). A similar requirement is inplace for RH waste (Jan, 2009). Therefore,state agreements have impacted theschedule associated with CH andforthcoming RH waste characterization.ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13 – 15, 2007NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/SGS)NDA-1Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceSystem DescriptionIdentify the NDA system by name, locationand number, as appropriate.NA Not Applicable The NDA system is the Drum wasteAssay System (DWAS)consisting of an Imaging Passive/Active Neutron andsegmented Gamma Scanner (IPAN SGS). It is locatedinBuilding 7880-I of the TRU Waste Processing Center(TWPC).NA Not ApplicableDescribe the system’s operational historyincluding deployment at other DOE sites.NA Not Applicable This is the first time this system has been evaluated by EPAfor conducting WIPP assaysNA Not ApplicableFor systems that have been deployed atmultiple DOE sites document pertinentaspects 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 priorto this inspection but notfor WIPP-bound TRU wastes.NA Not ApplicableSystem PerformanceIdentify the period of performance relevantto this inspection and if this NDA system hasprior EPA approval(s).NA Not Applicable Operation of the DWAS IPAN/SGS began on 10-07-07. NA Interviews with ORNL-CCPNDA personnel. J. Wachter,S. Stanfield, G. WestsikIdentify the type (55-gallon drums, or SWBs)and number of waste containers this systemassayed during the period of performance.Of these, indicate how many Batch DataReports (BDRs) were assembled. Of theassembled BDRs, indicate how many havebeen promoted through Project Level Reviewand are available for evaluation during thisinspection. If multiple waste containers havebeen assayed assign a total to each containertype.CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19As of 11-13-07 a total of 20 55-gallon (208 liter)drums havebeen assayed, and these have been compiled in 3 Batch DataReports (BDRs) all of which have been promoted throughProject Level Review.Interviews with ORNL-CCPNDA personnel. J. Wachter,S. Stanfield, G. WestsikATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13 – 15, 2007NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/SGS)NDA-2Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceGeneral Reporting RequirementsAssay systems must report quantitativevalues and uncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr, and137Cs.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The DWAS reports quantitative values and uncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr, and137Cs.Y DWAS BDRs OR-DWAS0001, OR-DWAS-0002 andOR-DWAS-0003Each container characterized and intendedfor disposal at WIPP must contain TRUwaste.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19Only wastes containing greater than TRU radionuclides atconcentrations greater than 100 nCi/g are promotedas WIPPeligible by ORNL-CCP.Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1; DWASBDRs OR-DWAS-0001, ORDWAS-0002 and ORDWAS-0003NDA instruments and procedures areappropriate for the waste streams beingassayed.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The DWAS system and supporting procedures are appropriatefor the waste stream within the scope of this inspection.Y DWAS BDRs OR-DWAS0001, OR-DWAS-0002 andOR-DWAS-0003NDA instruments and procedures result inunbiased values for the cumulative activity ofthe WIPP radionuclide inventory.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The DWAS and supporting procedures produce values thatare appropriate for calculation of the WIPP-trackedradionuclidesY DWAS BDRs OR-DWAS0001, OR-DWAS-0002 andOR-DWAS-0003Some radionuclides are derived by theapplication of scaling factors or correlationtechniques. Identify all radionuclides thatare quantified in this manner.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 1990Sr,234U and242Pu are determined by the application ofscaling factors for gamma determinations. For active andpassive neutron determinations, radionuclide-specific valuesare derived based on the measured239PuEFFand240PuEFF,respectively.Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, ConfirmationATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13 – 15, 2007NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/SGS)NDA-3Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidenceand Verification Report,Revisions 0 & 1Assess the technical adequacy of thecalculations involving the application ofscaling factors and/or correlation techniques.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 1990Sr,234U and242Pu are determined by the application ofscaling factors whose technical bases and derivation aredocumented in the gamma calibration report. ActiveandPassive Mode neutron assays rely on the measurementof239PuEFFand240PuEFF, respectively, and the application ofisotopic distributions to obtain radionuclide-specific values asdocumented in the neutron calibration report.Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1; CCP-TP168, CCP DWAS IPAN/SGSData Generation LevelValidation, Revision 0Identify the procedures that govern thisfunction and where the results of thesecalculations are documented.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The procedures that govern this function are provided to theright. The results of the calculations are documented in theDWAS BDRs.Y CCP-TP-169, Operating theMobile Segmented GammaScanner, Revision 0; CCPTP-166, Drum Waste AssaySystem ImagingPassive/Active NeutronOperations, Revision 0; CCPTP-168, CCP DWASIPAN/SGS Data GenerationLevel Validation, Revision 0Acceptable Knowledge (AK)If isotopic ratios based on AK are used thevalues are qualified by confirmatory testing.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19AK-based isotopics are used when such values can besupported by the AK documentation process.. All containers(one hundred percent) are subjected to radioassay using theDWAS.Y CCP-AK-ORNL-001,Revision 0; CCP-AK-ORNL001, NDA Memo, October17, 2007; supporting AKdocuments; CCP-TP-168,Revision 0ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13 – 15, 2007NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/SGS)NDA-4Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceDo NDA personnel use AK derived isotopicvalues to calculate radionuclide values? Ifso, is this function performed according to aformal procedure? Assess the technicaladequacy of this process(s).Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The NDA Expert Analyst (EA) used AK-derived isotopicvalues to calculate radionuclide values in conjunction withapproved AK values as documented in the referenceslisted inthe right column of this row.Y CCP-AK-ORNL-001,Revision 0; CCP-AK-ORNL001, NDA Memo, October17, 2007; supporting AKdocuments; CCP-TP-168,Revision 0Identify the procedure and where the resultsof these calculations are documented.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The application of AK-based isotopics is addressedin thedata generation level validation procedure and theresults ofthe calculation are in the DWAS BDRs.Y CCP-TP-168, Revision 0,Section 4.1Isotopic DeterminationIdentify the radionuclides that are measureddirectly and the specific radiation type (γ,AN or PN) that is measured.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19Gamma: Directly measured radionuclides include:238Pu,239Pu,240Pu,241Am,233U,238U and137Cs.Active and passive neutron: Radionuclide-specific values arederived based on the measured239PuEFFand240PuEFF,respectively.Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1Identify the method(s) used to derive theisotopic contribution for the unmeasuredradionuclides, e.g., MGA, PC FRAM orother technique.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The DWAS uses Multi Group Analysis (MGA), PC FRAMand the application of AK-based isotopics. The useof thesetechniques is subject to expert decision.Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13 – 15, 2007NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/SGS)NDA-5Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceLower Level of Detection (LLD)The LLD for each NDA system must bedetermined. For multi modal systems thismay require a separate determination for eachmode, i.e., active neutron, passive neutronand gamma.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19An LLD has been determined for all operational modes:active mode neutron assays, passive mode assays andgammaassays. The LLD determination for the active and passivemodes was not adequately addressed for90Sr and234U. Theseare required according to CCP-TP-167, Section 4.6.1, butRevision 2 of BII-5183-CVR-001 did not contain informationregarding them. BII-5183-CVR-001was revised and Revision3 included the required information for90Sr and234U.Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1Site-specific environmental backgrounds andcontainer-specific interferences must beaccounted for in LLD determinations.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19Site-specific environmental backgrounds and containerspecific interferences are addressed in the DWAS LLDdeterminations.Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1NDA instruments performing TRU/NonTRU waste discrimination measurements arerequired to have a LLD no greater than 100nCi/g.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The DWAS IPAN/SGS will not be used to discriminateTRU& Non-TRU wastes at the 100 nCi/g criterion.NA Not ApplicableThe technical basis and derivation for LLDsmust be adequate and appropriatelydocumented.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The technical basis and derivation for the LLDs forall threeoperational modes are technically adequate and appropriatelydocumented.Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13 – 15, 2007NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/SGS)NDA-6Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceFor radionuclides that are not determinedprimarily by measurement an LLD analog,i.e., a reporting threshold must be used whenit is technically feasible. Identify allinstances when this occurs and the form ofthe documentation of these activities.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19Gamma: LLDs for238Pu,240Pu and242Pu are derived from themeasured239Pu value; the LLD for90Sr is based on themeasured137Cs value.Neutron: The Active and Passive Mode LLDs are derived byapplication of isotopic ratios to the measured239PuEFFand240PuEFF, respectively. Sample values based on a239PuEFFvalue of 10 mg are shown in BII-5183-CVR-001, Table12.Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1Identify any/all instances where an LLDvalue for anon-measuredradionuclide is notprovided basis on a lack of technicalfeasibility.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19For gamma assays ORNL-CCP personnel stated that thedetermination of a unique reporting threshold for234U is nottechnically feasible. There are no instances wherea uniquereporting threshold in not provided on the basis ofa lack oftechnical feasibility for neutron-based assays.Y MV-SGS-0101-CAL-001,Segmented Gamma Scanner01 (SGS-01-01) Calibration,Confirmation andVerification Report,Revisions 0 & 1Are LLD values container/assay eventspecific or are typical LLD values applied toa class or type of wastes, i.e., those withsimilar attributes? If LLD values are notcontainer/assay event specific identify theattributes or characteristics whereby wastecontainers are grouped.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19Gamma: LLD values are assay-event specificNeutron: Active and Passive Mode LLD values are assayevent specific and are provided as a function of the ABSMODand MOD indices, respectively.Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1Total Measurement Uncertainty (TMU)The method used to calculate the TMU for allrequired quantities must be documented andtechnically justified.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The method used to calculate the TMU for all threeoperational modes of the DWAS are technically adequate andappropriately documented.Y BII-TMU-5183-001, DWASIPAN Total MeasurementUncertainty Report; CISGS01-TMU, TotalMeasurement Uncertainty forthe MCS Melton ValleySGS, Revision 1ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13 – 15, 2007NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/SGS)NDA-7Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceTMU determination accounts for all sourcesof uncertainty, specifically•Random errors•Calibration•Isotopic determination•Matrix inhomogeneity•Difference between calibrationassumptions and actual waste•Non uniform source distribution•End effects•Self absorption•Transmission source•Self shielding•Neutron multiplicationY CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The TMU determination accounts for all sources ofuncertainty for the three operational modes of theDWAS.Y BII-TMU-5183-001, DWASIPAN Total MeasurementUncertainty Report; CISGS01-TMU, TotalMeasurement Uncertainty forthe MCS Melton ValleySGS, Revision 1Methods to determine TMU must bedocumented, reviewed and approved byCBFO for each NDA instrument.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19Approval of TMU for the DWAS was performed as partofthe CBFO audit that occurred concurrently with thisEPAinspection.NA Not ApplicableATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13 – 15, 2007NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/SGS)NDA-8Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceSystem CalibrationEach NDA instrument must be calibratedbefore its initial use. Determine the date ofthe system’s calibration of record and wherethis is documented.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The DWAS was calibrated prior to use for WIPP assays atORNL-CCP. The calibration reports listed provide allnecessary information regarding the system’s calibration.Calibration reports for the gamma and neutron operationalmodes had minor problems, as indicted in several places inthis checklist, all of which were fixed in the reviseddocuments that ORNL-CCP submitted following theinspection. This checklist shows both revisions for thegamma and neutron calibration reports.Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1The range of applicability of the system ‘scalibration(s) must be specified in siteprocedures or other formal documentation.Identify the manner in which the range isexpressed, i.e., curies (or mass) of Pu/SNMfor activity and salient physicalcharacteristics for matrix.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19Gamma: Calibrated range is LLD to 45 g Total Pu(administrative limit), limited by system performance;efficiency range is 59 to 1332 keV; matrix is generallyZ<15, density from 0 to 0.72 g/cm3(Summed SpectrumMode)Neutron: Active Mode range is LLD to 14.710 g239PuEFF,ABSMOD range 22.251 to 276.800; Passive Mode rangeisLLD to 2.050 g240PuEFF, MOD range from 1.045 to 17.572Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1Any matrix/source surrogate wastecombinations must be representative of theactivity ranges and relevant waste matrixcharacteristics currently in use or planned foruse by the system. The system must becalibrated to 100% recovery.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The matrix/source surrogate waste combinations usedforcalibration are representative of the activity ranges andrelevant waste matrix characteristics of the wasteswithinthe scope of this inspection. The DWAS is calibrated to100% recovery for all three operational modes.Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13 – 15, 2007NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/SGS)NDA-9Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceThe use of consensus standards forcalibration is required, when such standardsexist. If consensus standards do not exist,the calibration technique must be approvedby CBFO.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19Consensus 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 neutronsY BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1Identify the specific consensus standards thatwere used for the system calibration or, intheir absence, the alternate calibrationtechnique. Evaluate the CBFO approval ofthe alternate technique.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19See response to previous checklist entry. Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1Primary standards must be obtained fromsuppliers maintaining a nationally accreditedmeasurement program. Identify thenationally accredited measurement program.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19All primary standards were obtained from suppliersthatmaintain a nationally accredited measurement program;Isotope Products Laboratory and LANLY BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13 – 15, 2007NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/SGS)NDA-10Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceList the standards used for calibration andverify the pedigree of each standard.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The gamma and neutron standards used for calibration arelisted in the calibration reports and their pedigrees havebeen verified.Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1Calibration Verification & ConfirmationVerification of an NDA instrument’scalibration must be performed after any ofthe following occurrences: major systemrepairs and/or modifications, replacement ofthe system’s components, significantchanges to the system’s software, andrelocation of the system.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The gamma, active and passive neutron calibrationshavebeen verified as required.Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1Recalibration of the system must occur if thecalibration verification demonstrates that thesystem’s response has significantly changed.NA CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19A system recalibration has not occurred. NA Not ApplicableATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13 – 15, 2007NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/SGS)NDA-11Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceThe system calibration must be confirmed byperforming replicate measurements of a noninterfering matrix.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The calibration confirmations for gamma, active neutronand passive neutron have been performed.Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1Replicate measurements must be performedwith containers of the same nominal size andaccording to the same procedures used foractual waste assays.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19Replicate measurements were performed with containers ofthe same size and with the same procedures used forroutine waste assays for all three operational modesY BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1Replicate measurements must be performedusing nationally recognized standards orstandards derived from nationally recognizedstandards that span the range of use of theinstrument with respect to disintegration rateand/or matrix effects. Identify all standardsthat were used and indicate their application(verification or confirmation).Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19Replicate measurements were performed using standardsderived from nationally recognized standards that span therange of use of the instrument with respect to disintegrationrate and/or matrix effects. All standards that were used andtheir applications are documented. The instrumentcalibration reports cited provide all required informationrelative to the DWAS calibration..Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1Identify the nationally accreditedmeasurement program. List the standardsused for verification/confirmation and verifythe pedigree of each standard.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19See previous checklist entry. Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13 – 15, 2007NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/SGS)NDA-12Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1The standards used for calibrationconfirmation must not be the same sourcesas those used for the system’s calibration ofrecord.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The standards used for calibration confirmation weredistinct from those that were used for the calibration of allthree operational modes.Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1Requirements 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 precisionas a function of the number of replicates thatwere measured and∀30% for accuracy.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19Requirements for accuracy and precision that are specifiedin DOE/WIPP-02-3122, Appendix A, Table A-3.2 weremet for all three operational modes except for the32 g Pu(nominal) standard that failed due to low bias. This failurewas attributed to self-absorption of the encapsulated sourcefor which a correction factor can be applied.Y BII-5183-CVR-001, DWASIPAN Calibration andValidation Report, Revisions2 & 3; MV-SGS-0101-CAL001, Segmented GammaScanner-01 (SGS-01-01)Calibration, Confirmationand Verification Report,Revisions 0 & 1ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13 – 15, 2007NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/SGS)NDA-13Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceQuality ControlAll radioassay and data validation must beperformed by appropriately trained andqualified personnel.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19Personnel performing radioassay and datavalidation are appropriately trained and qualified.Y ORNL-CCP Program List ofQualified Individuals, 10-18-2007,1:56PM provided prior to theinspection; CCP-TP-168, CCP DWASIPAN/SGS Data Generation LevelValidation, Revision 0Identify the name, title and function of allpersonnel performing NDA data validation.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19Expert Analysts (EAs) are Bob Ceo, AlanSimpson, John West and George Westsik.Independent Technical Reviewers (ITRs) are BarrySmith, Ron Whitson and Debbie SatterfieldY ORNL-CCP Program List ofQualified Individuals, 10-18-2007,1:56PM provided prior to theinspection.Requalification of personnel must be basedon evidence of continued satisfactoryperformance and must be performed at leastevery two years.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19Training for all DWAS Operators, EAs and ITRswere current.Y ORNL-CCP Program List ofQualified Individuals, 10-18-2007,1:56PM provided prior to theinspection.The site must participate in relevantmeasurement comparison programssponsored or approved by CBFO, includingthe NDA PDP.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The DWAS had participated in NDA PDP Cycle13A prior to its use by ORNL-CCP for WIPPassays. The DWAS is registered to participate infuture PDP cyclesY Performance Demonstration Programfor NDA of Drums, SystemRegistration Form, signed by ChristaChavez October 10, 2007Background and Performance ChecksAssay system background measurementsmust be taken daily, unless otherwiseapproved by CBFO. Determine the form ofCBFO approval documentation of thealternate approach to backgrounds, ifapplicable. Contributions to backgroundsfrom nearby radiation sources must becarefully controlled, or more frequentbackgrounds must be measured.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The DWAS BDRs reviewed provide evidence ofappropriate background measurements.Y DWAS BDRs OR-DWAS-0001, ORDWAS-0002 and OR-DWAS-0003ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13 – 15, 2007NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/SGS)NDA-14Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceAssess how often background radiation wasproblematic to the extent that measurementpersonnel had to make adjustments.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19No instances of this were observed in the BDRsevaluated during this inspection.NA Not ApplicableIdentify the criteria used to evaluateinstrument backgrounds and assess thetechnical adequacy of this criterion, i.e.,statistical or administrative.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The criteria for gamma and neutron assays areprovided in the operating procedures andcalibration reports for the SGS and IPANoperational modes.Y Revision 0 of CCP-TP-166, CCP-TP172, CCP-TP-167, CCP-TP-169 andCCP-TP-168; BII-5183-CVR-001;MV-SGS-0101-CAL-001Identify the number of data points required toderive the initial control limit. At whatinterval(s) will new limits be calculated?Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The initial gamma control limits that are statisticalin nature were derived using 5 pointsSystem performance checks must beperformed at least once per operational day.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The DWAS BDRs evaluated for this inspectiondocument performance checks at the requiredintervals.Y DWAS BDRs OR-DWAS-0001, ORDWAS-0002 and OR-DWAS-0003;CCP-TP-168, Revision 0; CCP-TP166, Revision 0, Attachments 2 & 3System performance checks must include, asapplicable, efficiency, matrix correctionchecks, and systems peak position andresolution for spectrometric systems.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19Gamma checks include 344.3 keV centroid andFull-Width-at-Half-Maximum (FWHM),background, transmission and calibration checksand Weighted Mean Activity. Neutron checksinclude Raw Coincidence Count rate,239PuEFFMass and240PuEFFMassY DWAS BDRs OR-DWAS-0001, ORDWAS-0002 and OR-DWAS-0003;CCP-TP-168, Revision 0At a minimum of once per operational weekan interfering matrix must be assayed toassess the long-term stability of the NDAinstrument and its matrix corrections andhow this performance is documented.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The DWAS BDRs evaluated for this inspectiondocument interfering matrix checks at the requiredintervals.Y DWAS BDRs OR-DWAS-0001, ORDWAS-0002 and OR-DWAS-0003;CCP-TP-168, Revision 0; CCP-TP169, Revision 0Interfering surrogate waste matrices must beconstructed in a way that the salient matrixcharacteristics do not change over time.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Surrogate matrices are constructed appropriately. YBII-5183-CVR-001, DWAS IPANCalibration and Validation Report,Revisions 2 & 3; MV-SGS-0101-CAL-001, Segmented GammaATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13 – 15, 2007NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/SGS)NDA-15Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceRevision 19Scanner-01 (SGS-01-01) Calibration,Confirmation and Verification Report,Revisions 0 & 1The radionuclide sources used forperformance checks must be long-lived andof sufficient strength (activity) to providestatistically sufficient results over a shortmeasurement time.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The radionuclide sources used for performancechecks are technically appropriate.Y BII-5183-CVR-001, DWAS IPANCalibration and Validation Report,Revisions 2 & 3; MV-SGS-0101-CAL-001, Segmented GammaScanner-01 (SGS-01-01) Calibration,Confirmation and Verification Report,Revisions 0 & 1Radioactive sources are decay corrected as afunction of their physical half life, asappropriate, specifically133Ba,252Cf,137Cs,75Se and109Cd.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19Decay corrections for the252Cf (240PuEFFMass) areperformed as requiredY CCP-TP-166, Revision 0, Section4.2.4; CCP-TP-168, Revision 0;DWAS BDRs OR-DWAS-0001, ORDWAS-0002 and OR-DWAS-0003Performance checks must be quantitative andbased on 2 and 3 sigma limits.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19Gamma control limits are non-statistical(background, transmission source peak centroid,FWHM and count rate)Y CCP-TP169, Revision 0, Sections 4.3& 4.4ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13 – 15, 2007NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/SGS)NDA-16Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceData ManagementAll radioassay data must be reviewed andapproved by qualified personnel before beingreported to WWIS.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19All radioassay data examined during thisinspection contained evidence of review andapproval by qualified personnel, i.e., ITRs andEAs, as appropriate.Y DWAS BDRs OR-DWAS-0001,OR-DWAS-0002 and ORDWAS-0003; CCP-TP-168,Revision 0Identify the name, title and function of theindividual(s) performing technical reviewand approval of NDA BRDs.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19EAs are Bob Ceo, Alan Simpson, John West,George Westsik. ITRs are Barry Smith, RonWhitson and Debbie SatterfieldY ORNL-CCP Program List ofQualified Individuals, 10-18-2007, 1:56PM provided prior tothe inspection.Radioassay BDRs must consist of thefollowing elements:•Testing facility name, testing batchnumber, container numbers, andsignature of the Site Project Officer(SPO) or designee(s)•Table of Contents•Background and performance check dataor control charts for the relevant timeperiod.•Data validation per the QAPD and siteprocedures•Separate testing report sheets for eachcontainer.Y CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The DWAS BDRs that were reviewed duringthis inspection contained all required elements.Y DWAS BDRs OR-DWAS-0001,OR-DWAS-0002 and ORDWAS-0003ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13 – 15, 2007NDA System: Drum Waste Assay System – Imaging Passive-Active Neutron/Mobile Segmented Gamma Assay System (DWAS-IPAN/SGS)NDA-17Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceRadioassay data sheets must include:•Title “Radioassay Data Sheet”•Method/procedure used•Date of radioassay•Activities and associated TMU forindividual radionuclides•TRU alpha concentration and itsassociated TMU•Operator signature•Reviewer signatureY CCP-PO-002, CCPTransuranic WasteCertification Plan,Revision 19The radioassay data sheets from the DWASBDRs that were reviewed contained allrequired elements.Y OR-DWAS-0001:X10C0501223, X10C0501359OR-DWAS-0002:X10C0501369, X10C0501407OR-DWAS-0003:X10C0501146, X10C0501111The following nonpermanent records must bemaintained at the radioassay-testing facilityor forwarded to the site project office:•Testing batch reports•All raw data, including instrumentreadouts, calculation records, andradioassay QC results•All applicable instrument calibrationreportsNA Not Applicable Not assessed during this inspection NA Not ApplicableRTR-1ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentsRTR-1:Site procedures identifyrequired training and qualificationsfor RTR personnel.CCP-TP-028,Revision 3CCP-QP-002,Revision 25•Operator training was consistent withapplicable procedures.•Operator certification is current.•OJT was documented for each operator.•Operators are re-qualified every two years.•RTR operators passed a training drum testthat includes items common to the wastestreams examined at the site (biannually.)•RTR operators receive training on the wastematrix parameters and typical packagingconfigurations expected in each waste stream.YThere are four qualified RTR operators/ITRs atthe site, all of whom were qualified in Septemberor October 2007. At least two of the operatorswere transferred to ORNL from Savannah RiverSite and have considerable experience in theexecution of RTR examinations.During the inspection, EPA reviewed the recordsof the capability demonstration for selectedradiography personnel. The audio/visualrecordings for the latest capability demonstrationcontainer for the drum RTR operator/ITRs wereviewed during the inspection. The operatorsperforming the on-site demonstration had a hardcopy of the AK Summary Report, CCP-AKORNL-001, available to verify the WMC andphysical form of the waste examined. Trainingrecords reviewed indicated that only trainedpersonnel were operating the RTR equipment.The operator/ITRs successfully identified all ofthe prohibited items contained in the trainingdrum. However, the operators/ITRs consistentlydemonstrated that they were unable to identify allof the unknown items in the drum, includingcardboard and a plastic measuring cylinder. EPAgenerated concern ORNL-CCP-CH-RTR-004CRto address this issue.ORNL-CCP-CH-RTR-004CR:In the capability demonstration trainingcontainers, the EPA inspector noted that while allthe required prohibited items were identifiedcorrectly by all RTR operators, some additionalitems (cellulosics and plastics) were notidentified. All cellulosics and plastics in thetraining drum need to be identified and theirRTR-2ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentsidentification documented. To complete thetraining process, it is critical that the operatorreceives feedback regarding missed items. Moredetailed documentation of the feedback given isneeded when the results of the training drum arereviewed.Objective evidence:1.Radiography Data Sheet for capabilitydemonstration for the four (4) qualified RTRoperators/ITRs, dated 9/26/07 or 10/1/072.Audio/visual recording of drum RTRcapability demonstration for the four (4)operators/ITRs, dated 9/26/07 or 10/1/073.Inventory for training drums, ORNL-NDETEST-001 and ORNL-NDE-TEST-002RTR-2:Site procedure(s) providecomplete instructions for operatorsto perform the RTR examination andcompletion of the associateddocumentation.CCP-TP-053,Revision 5•RTR operator adequately explained theprocess followed for examining a drum andentering data into data forms (whether hardcopy or electronic data entry is used).Y EPA observed the RTR examination of drumX10C0501308, Batch OR-RTR6-0013. Oneoperator performed the examination and called outthe items identified. The operators were able toexplain and demonstrate how RTR data areentered into the electronic data sheet (Attachment2) and how WMP weights are estimated. Theprocedure used contains complete instructions forperforming RTR examinations and recording data.The procedure was implemented as written.When opened, the templates for Attachments 1and 2 of procedure CCP-TP-053 alreadycontained some RTR data. This could have led toincorrect reporting of the specific drum data andEPA generated concern ORNL-CCP-CH-RTR001CR to address this issue.RTR-3ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentsORNL-CCP-CH-RTR-001CR:When the templates used to complete Attachments1 and 2 of CCP-TP-053 were opened during theon-site RTR demonstration, some of the questionswere already answered. For example:• Attachment 1, CCP RTR Measurement ControlReport, had check marks indicating that thequestions for “Video/Audio Recorded MediaSystem Check” and “Image Test Pattern Test”were checked to indicate that they were “SAT”(satisfactory).• The entries to indicate the number of linespair/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) associatedwith the container?” was checked “No.” Evenwhen the form was reset, the check marks did notdisappear.Objective evidence:1.RTR Batch Data Reports: OR-RTR6-001,OR-RTR6-003, OR-RTR6-007, (S5000,debris waste)2.Audio/visual recording of RTR events fordrums from the above BDRsRTR-3:The RTR procedure(s)require an image quality check to beperformed.CCP-TP-053,Revision 5,Section 4.3•Operator adequately explained how theacceptability of an image is determined.•Image quality (IQI) check is performed onceY CCP at ORNL does not have the capability togenerate a linear diode array image (LDA).At the time of the on-site demonstration, theRTR-4ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentsper day.•LDA acceptability test performed atbeginning of each shift.•Performance of the image quality check isdocumented and recorded.operators had already completed the requiredaudio/visual check. EPA reviewed this check toverify the written record and acceptability of theRTR image. As a further check, EPA reviewedAttachment 1, RTR Measurement Control Report,for all seven of the BDRs completed at the time ofthe inspection.Objective evidence:1.CCP-TP-053, Attachment 1, CCP RTRMeasurement Control Reports, for all sevencompleted BDRs2.CCP-TP-053, Attachment 2, CCPRadiography Data Sheet, for demonstrationdrum X10C0501308RTR-4:The procedure allows theoperator to adjust the RTR toaccommodate the physical propertiesof the waste and waste containerslikely to be encountered at the site.CCP-TP-053,Revision 5,Section 4.4•Operator could identify applicable policiesand procedures governing the operation ofRTR equipment.•The RTR system could be adjusted.•High-density material was examined with theX-ray device set on the maximum voltageand low density material at a lower voltage.•Operator adequately explained what is done ifan image is unacceptable (e.g., the waste issolidified or the container is lead-lined).Y During the RTR demonstration, the operatoradjusted the unit to maximize the image clarity.The RTR operators interviewed wereknowledgeable and able to answer all questionsasked by EPA. During the demonstration, theoperator changed the Kv setting to accommodatethe density of different materials and adjusted theunit as needed to obtain the clearest images of thewaste items.The operators were able to explain the NCRprocess and in what circumstances an NCR wouldbe initiated. EPA reviewed selected NCRs toensure that they were complete and processed inaccordance with site procedures.Objective evidence:1.RTR Batch Data Reports: OR-RTR6-001,RTR-5ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentsOR-RTR6-003, OR-RTR6-007, (S5000,debris waste)2.Nonconformance Reports (NCRs) NCRORNL-0101-07 and NCR-ORNL-0500-07RTR-5:CCP-TP-053,Revision 5,Section 4.3•RTR tape is high quality, the sound track isaudible, and the required information iscontained on the audible portion of the tape.•The RTR tape is consistent with the datapackage for the same drum.Y EPA compared the written record (BDR) and theaudio/visual recordings for the followingcontainers to ensure consistency:X10C0501101X10C0501391X10C0501179EPA did not identify any differences between thewritten and audio/visual records for thesecontainers.Objective evidence:1.RTR Batch Data Reports: OR-RTR6-001,OR-RTR6-003, OR-RTR6-0072.Audio/visual recordings for drumsX10C0501101, X10C0501391,X10C0501179RTR-6:There is a procedure fordetermining whether the wastematches the waste stream descriptionand Waste Matrix Code, and fordetermining Waste MaterialParameters 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 thewaste stream description.•Waste Matrix Code is verified. If not,corrective action is taken.•WMP weights are estimated by compiling aninventory of waste items andresidual/packaging materials.•Does the RTR operator use a standard weightY During the on-site demonstration, the operatorsscanned the container as required, usinginstructions contained in the procedure. WMPswere identified and entered electronically into adata sheet. At the end of the examination, theWMP weights were estimated and recorded. Theprocedure contains a table, Table 3, whichprovides standard weights for some items. Thelist is not comprehensive and the operator usesexperience and training to assign the weights.During the demonstration, the operator alsoRTR-6ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentslookup table to provide an estimate of WMPweights? If so, has the table been updated toreflect additional information gained throughprevious RTR/VE exams or updated AKinformation?“jogged” the drum to determine thepresence/absence of free liquids.As part of the demonstration, the operator verifiedthat the waste matched the waste streamdescription and the Waste Matrix Code. Theabsence/presence of prohibited items wasrecorded on the data sheet as part of thedemonstration.Objective evidence:1.CCP-TP-053, Attachment 2, CCPRadiography Data Sheet, for demonstrationdrum X10C05013082.RTR Batch Data Reports: OR-RTR6-001,OR-RTR6-003, OR-RTR6-007 (S5000,debris waste)3.Audio/visual recording of RTR events fordrums from the above BDRsRTR-7:The RTR procedureprovides instructions for identifyingprohibited items and for processingdrums containing prohibited.CCP-TP-053,Revision 5,Section 4.4,Table 1,Attachment 2•Operator could name prohibited items•Operator adequately explained how thepresence of free liquids is determined.•Operator’s explanation of required actions ifprohibited items were encountered wasconsistent with procedure.•Corrective actions are taken when necessary.The operators interviewed were able to answer allquestions and were experienced in theperformance of RTR examinations. During thedemonstration, the operator also “jogged” thedrum to determine the presence of free liquids.During the interview, the operators correctlystated when an NCR would be initiated.Objective evidence:1.RTR Batch Data Reports: OR-RTR6-001,OR-RTR6-003, OR-RTR6-007, (S5000,debris waste)2.Nonconformance Reports (NCRs) NCRORNL-0101-07 and NCR-ORNL-0500-07RTR-7ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentsRTR-8:RTR procedures includethe required QC examinations,evaluation accuracy andreproducibility of the RTR process.CCP-TP-053,Revision 5,Sections 4.5,4.6•An independent replicate scan is performedon one waste container per day or on onecontainer per testing batch (whichever is lessfrequent).•An independent observation of one scan (notthe replicate) is performed by a qualifiedRTR operator (anyone but the initial RTRoperator).Y QC examinations were performed as required bythe procedure. In batch OR-RTR6-001, anindependent observation was performed oncontainer X10C0501146 and a replicate scan wasperformed on container X10C0501144. In batchOR-RTR6-003, an independent observation wasperformed on container X10C0505973 and areplicate scan was performed on containerX10C0506048. In batch OR-RTR6-007, anindependent observation was performed oncontainer X10C0501407 and a replicate scan wasperformed on container X10C0501270. The QCsamples were performed by a different operatorfrom the original event. Reconciliation of the QCresults is only required if there is a differencebetween operators with regard to the WasteMatrix Code, liquids, and compressed gases(CCP-TP-053, Sections 4.5.3 and 4.6.3). EPAgenerated concern ORNL-CCP-CH-RTR-005C toaddress this issue.ORNL-CCP-CH-RTR-005C:The replicate and original scans that wereperformed in batch OR-RTR6-0003,Container X10C0506048, had a 15% difference inthe percent fill factor, as well as minor differencesin the recorded WMP weights. CCP-TP-053 onlyrequires reconciliation of discrepancies when“identification of the waste matrix code, liquids inexcess of TSDF-WAC limits and compressedgases differ between the two operators.” Thesame situation applies to the independent andoriginal observations. While this practicecomplies with the requirements of CCP-TP-053,Sections 4.5.3 and 4.6.3, it does not satisfy EPA’sRTR-8ATTACHMENT A.3: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentsrequirement for a system of controls todemonstrate consistent and accurate identificationof waste attributes. A tolerance needs to bedefined for waste attributes.Objective evidence:1.RTR Batch Data Reports: OR-RTR6-001,OR-RTR6-003, OR-RTR6-007, (S5000,debris waste)RTR-9:Procedure(s) containstandardized forms for recordingRTR data.CCP-TP-053,Revision 5,Attachment 1and 2•RTR operator adequately explained theprocess followed for examining a drum andentering data into data forms (whether hardcopy or electronic data entry is used).•Direct data entry into an electronic form isdone by the RTR operator using a computer,while the operator is still in the RTR booth.•The electronic data file undergoes the samequality control (QC) checks used for handwritten data entries.Y EPA observed the operator complete theelectronic data form (Attachment 2) for thedemonstration drum X10C0501308. All entrieswere made as required. The entries were made atthe time of the examination and signed by theoperator performing the examination.Attachments 1 and 2 are printed and become partof the BDR, which undergoes both ITR and SPMlevel review.Objective evidence:1.RTR Batch Data Reports: OR-RTR6-001,OR-RTR6-003, OR-RTR6-007, (S5000,debris waste)RTR-10:Site procedures requirereview of Batch Data Reports(BDRs) at the data generation andproject level.CCP-TP-053,Revision 5,Attachment 3CCP-TP-001,Revision 17,Attachment 2•Data generation level reviews are performedand documented (ITR).•Project level reviews are performed anddocumented (SPM).Y All of the BDRs reviewed by EPA had beenreviewed at both the generation (ITR) and project(SPM) level. The review checklists werecomplete and signed as required.Objective evidence:1.RTR Batch Data Reports: OR-RTR6-001,OR-RTR6-003, OR-RTR6-007, (S5000,debris waste)RTR-9Information Included in BDRRequired Testing Batch ContentPresentY or NRequired Testing Batch ContentPresentY or NRequired Testing Batch ContentPresentY or NBatch DateVerification that waste matches wastestream descriptionContainer gross weightReport DateEstimated weights for Waste MaterialParametersReference to or copies of any NCRsWaste Container NumberLayers of confinementOperator signature and test dateWaste Matrix CodeIndication of vented rigid linersData generation checklistVideotape referenceDescription of container contentsProject level checklistDescription of linersIndication of sealed containers >4LQC documentationAmount of free liquidRevision No.: 1.0WWIS-1Date of Revision: 10/20/05ATTACHMENT A.4: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentWWIS-1:WWIS and Data EntryPersonnel must be trained to assessdata and properly enter data into theWWIS.YCCP-TP-030,Revision 22, Section2.2; CCP-QP-002,Revision 25WCO and Data Entry Personnel are trained toassess data and properly enter and transfer alldata in the WWIS.Training for Data Entry Personnel and datareviewers/verifiers include the WIPP WasteInformation System User’s Manual and theapplicable site procedures.Training records are available for review andare complete.YTraining for WCA and WCO personnel includes the WIPPWaste Information System User’s Manual and specificsitetraining. WCO/WCAs are based in Carlsbad, NewMexico, where data entry into WWIS takes place. Thetraining records contained in the personnel QualificationCard for a WCA/WCO were reviewed during the on-siteinspection. The training was complete and appropriate forthis position.Objective evidence reviewed:1.Qualification Card for WCA and WCOWWIS-2:Security measures forensuring data integrity and accessingWWIS are sufficient.YCCP-TP-030,Revision 22, Section4.1Access to WWIS is controlled. WWIS accessrequests are recorded in an access log, howevernamed, that is available for review.Y The WWIS Data Administrator controls access to WWIS.CCP requests access for personnel and the approvalandpassword are transmitted to CCP via e-mail. The WWISData Administrator in Carlsbad, New Mexico, maintainsthe WWIS access log.Objective evidence:1.List of Qualified Individuals for WWISWWIS-3:There are adequateprocedures for entering data into theWWIS and transmitting data toWIPP.YCCP-TP-030Revision 22, Section4.0Employee’s explanation of job duties wasconsistent with applicable procedures. WWISand Data Entry Personnel adequately explainedhow data are assessed, input, and transferredinto WWIS.YData entry and WWIS submission of data for all CCPsitestakes place in Carlsbad, New Mexico. For the purpose ofdemonstration, a WCA/WCO was present at ORNL for thisinspection. An Excel spreadsheet is used to entercharacterization or certification data into WWIS.Aftercompletion, the spreadsheet is printed and reviewed. Theinitials of personnel entering and reviewing the spreadsheetdata are recorded on the spreadsheet. By signing thissummary, the WCO accepts the data for submission toWWIS. After the spreadsheet data have been approved bythe WCO, flat files are generated and then uploadedintoWWIS. All container NCRs must be closed prior to dataentry.At the time of the on-site inspection, WWIS was notable toreceive ORNL data, but the WCA/WCO interviewed wasable to demonstrate the process using the Test Instance ofRevision No.: 1.0WWIS-2Date of Revision: 10/20/05ATTACHMENT A.4: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentWWIS.Objective evidence reviewed:1.MS Excel 2000 and XP WWIS spreadsheet forcontainer LA000000621132.Waste Container Data Report, containerLA000000621133.MS Excel 2000 and XP WWIS spreadsheet forcontainer 100868224.Waste Container Data Report, container 10086822WWIS-4:Procedures require thatonly verified and validated data areentered into WWIS.YCCP-TP-030,Revision 22, Table 1Data generation and project level reviews ofcontainer data for WWIS entry have beenperformed and review checklists are complete.Y At the time of the on-site inspection, WWIS was not able toreceive ORNL data but the WCA/WCO interviewed wasable to demonstrate the process. Only BDRs that have beenthrough SPM review and reconciliation are eligibleforWWIS data entry.Objective evidence reviewed:1.MS Excel 2000 and XP WWIS spreadsheet forcontainer LA000000621132.Waste Container Data Report, containerLA000000621133.MS Excel 2000 and XP WWIS spreadsheet forcontainer 100868224.Waste Container Data Report, container 100868225.RTR Batch Data Reports: OR-RTR6-001, OR-RTR6-003, OR-RTR6-007 (S5000, debris waste)WWIS-5:Procedures includeinstructions for submission of datainto the Characterization and theCertification module of WWIS.YCCP-TP-030Revision 22, Sections4.3 – 4.5To enable Waste Stream Profile Formapproval, data are entered into theCharacterization module of WWIS on acontainer basis.To obtain shipping certification of a container,Y At the time of the on-site inspection, WWIS was not able toreceive ORNL data, but the WCA/WCO interviewed wasable to demonstrate the process. The CWA/WCO uploadeddata into the Test Instance of WWIS, using both compliantand non-compliant data. To enable approval of a WasteRevision No.: 1.0WWIS-3Date of Revision: 10/20/05ATTACHMENT A.4: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentdata are entered into the Certification moduleof WWIS.Stream Profile Form (WSPF), CCP will upload ORNL datainto the Characterization data module of WWIS. AfterWSPF approval, data will be submitted to the Certificationmodule of WWIS.Objective evidence reviewed:1.MS Excel 2000 and XP WWIS spreadsheet forcontainer LA000000621132.Waste Container Data Report, containerLA000000621133.MS Excel 2000 and XP WWIS spreadsheet forcontainer 100868224.Waste Container Data Report, container 10086822WWIS-6:Procedures include arequirement for review of data priorto submission to WWIS.YCCP-TP-030,Revision 22, Section4.3, 4.4There is an independent review of data prior tosubmission to WIPP via the WWIS.Procedures for resolution/correction ofnonconforming data are adequatelyimplemented.Y A WCA enters data and the data are checked by a secondWCA. Prior to WWIS submittal, a WCO also reviews thedata contained on the spreadsheet. WWIS contains checksthat do not allow incorrect or unusable data to beuploaded.The initials of the reviewers are recorded on the Excelspreadsheet. If data are rejected by WWIS, CCP issues anNCR for the rejected data, makes the corrections, andresubmits the data to WWIS.Objective evidence reviewed:1.MS Excel 2000 and XP WWIS spreadsheet forcontainer LA000000621132.MS Excel 2000 and XP WWIS spreadsheet forcontainer 100868223.NCR NCR-INL-0501-07WWIS-7:There are adequateprocedures for entering data into theWWIS and transmitting the data toYCCP-TP-030,The site has successfully submittedcharacterization and certification data to WIPPY CCP has successfully submitted characterization andcertification data for many containers from other sites toWIPP via WWIS. The WCO was able to access multipleRevision No.: 1.0WWIS-4Date of Revision: 10/20/05ATTACHMENT A.4: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentWIPP. Revision 22, Section4.0via WWIS.certified containers to demonstrate CCP’s processes.Objective evidence reviewed:1.MS Excel 2000 and XP WWIS spreadsheet forcontainer LA000000621132.Waste Container Data Report, containerLA000000621133.MS Excel 2000 and XP WWIS spreadsheet forcontainer 100868224.Waste Container Data Report, container 10086822WWIS-8:Procedures provideinstructions for data correction if dataare rejected by WWIS.YCCP-TP-030,Revision 22, Section4.3-4.4E-mail notifications from WWIS(acceptance/modification/rejection of data)If data are rejected by the WWIS DataAdministrator, processes for datareconciliation/correction are implemented.Y WWIS contains checks that do not allow incorrectorunusable data to be uploaded. During the on-sitedemonstration the WCA/WCO entered non-compliant intothe existing spreadsheet for a container and then tried toupload this into WWIS. WWIS rejected the containerasrequired and provided information with regard to the reasonfor rejection. If data are rejected, an NCR is issued, thedata corrected, and the container resubmitted to WWIS.Objective evidence reviewed:1.MS Excel 2000 and XP WWIS spreadsheet forcontainer LA000000621132.Waste Container Data Report, containerLA000000621133.MS Excel 2000 and XP WWIS spreadsheet forcontainer 100868224.Waste Container Data Report, container 10086822WWIS-9:Procedures for wastecontainercharacterization/certification datasubmittal to WWIS require theYCCP-TP-030,Revision 22, Section5.0WWIS access requestsWWIS access logsWaste container data input reportsY CCP was able to retrieve the records requested, including alist of qualified individuals, waste container datareports,and training records.Objective evidence reviewed:Revision No.: 1.0WWIS-5Date of Revision: 10/20/05ATTACHMENT A.4: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLISTEPA Inspection No.: EPA-ORNL-CCP-CH-11.07-8Inspection Date: November 13-15, 2007Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentappropriate records to be retained.1.MS Excel 2000 and XP WWIS spreadsheet forcontainer LA000000621132.Waste Container Data Report, containerLA000000621133.MS Excel 2000 and XP WWIS spreadsheet forcontainer 100868224.Waste Container Data Report, container 100868225.List of Qualified IndividualsWWIS-10:NA Plans and procedures for payload managementhave been approved by CBFO.CBFO informed EPA prior to approving thesite to payload- manage containers.TRU alpha activity concentration is > 100nCi/g for the entire waste stream.Only waste containers from the same wastestream are payload managed in the samepayload container.Each waste container selected for payloadmanagement contains at least one TRU isotope.TRU alpha activity concentration of thepayload container is determined and reported.NA At the time of the inspection, CCP/ORNL had notformallyinformed EPA of their intention to load-manage CH TRUwaste 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 equi valent -

Site ID - Pu 239 FGE uncertainty - present

Waste Stream Profile Number - Radionuclide name

Waste Matrix Code - Radionuclide activity

Waste Matrix Code Group - Radionuclide activity unc ertainty

Waste Material Weight - Radionuclide mass

Waste Material Parameter - Radionuclide mass uncert ainty

Hazardous Code - Radioassay method -

Layers of packaging - Assay date -

Liner exists - Characterization method -

Filter model - Characterization method date -

Number of filters installed - Alpha surface concen tration -

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 concent ration -

TRU alpha activity concentration uncertainty - Anal yte 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-1ATTACHMENT B.1: REPLICATE TESTING DATA FOR CONTAINERX10C0501112Instrument: DWAS/IPAN/SGSContainer: X10C0501112Original Measurement Replicate #1 Replicate #2Quantity of Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value Uncertainty Uncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 3.51E-04 1.06E-04 3.03E-012.42E-04 7.31E-05 3.02E-012.51E-04 7.63E-05 3.04E-01239Pu Activity (Ci) 2.63E-03 7.06E-04 2.68E-011.82E-03 4.85E-04 2.67E-011.89E-03 5.07E-04 2.69E-01240Pu Activity (Ci) 9.43E-04 2.85E-04 3.03E-016.50E-04 1.96E-04 3.02E-016.75E-04 2.05E-04 3.04E-01242Pu Activity (Ci) 2.23E-07 6.76E-08 3.03E-011.54E-07 4.65E-08 3.02E-011.60E-07 4.85E-08 3.04E-01241Am Activity (Ci) 1.78E-03 5.40E-04 3.03E-011.23E-03 3.71E-04 3.02E-011.28E-03 3.88E-04 3.04E-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 2.10E+02 5.76E+01 2.74E-011.45E+02 3.96E+01 2.73E-011.50E+02 4.14E+01 2.75E-01Replicate #3 Replicate #4 Replicate #5Quantity of Relative Relative Reported Reported Reported Relative Reported Absolute RelativeInterest Uncertainty Uncertainty Value Value Value Uncertainty Value Uncertainty Uncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 2.84E-04 8.49E-05 2.99E-013.39E-04 1.02E-04 3.01E-012.69E-04 8.04E-05 2.98E-01239Pu Activity (Ci) 2.13E-03 5.62E-04 2.64E-012.55E-03 6.76E-04 2.65E-012.02E-03 5.31E-04 2.63E-01240Pu Activity (Ci) 7.63E-04 2.28E-04 2.99E-019.11E-04 2.74E-04 3.01E-017.24E-04 2.16E-04 2.98E-01242Pu Activity (Ci) 1.81E-07 5.40E-08 2.99E-012.16E-07 6.49E-08 3.01E-011.71E-07 5.11E-08 2.98E-01241Am Activity (Ci) 1.44E-03 4.32E-04 2.99E-011.72E-03 5.18E-04 3.01E-011.37E-03 4.08E-04 2.98E-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 1.70E+02 4.59E+01 2.70E-012.03E+02 5.52E+01 2.72E-011.61E+02 4.34E+01 2.69E-01B-2ATTACHMENT B.2: REPLICATE TESTING RESULTS FOR CONTAINER X10C0501112Instrument: DWAS/IPAN/SGSContainer: X10C0501112Original Measurement Sample RelativeQuantity of Reported Absolute Sample Standard StandardInterest Value Uncertainty Mean Deviation Deviationχ2Pr(x<| χ2|)233U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!234U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!238U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!238Pu Activity (Ci) 3.51E-04 1.06E-042.77E-04 3.83E-05 1.38E-015.19E-01 9.72E-01239Pu Activity (Ci) 2.63E-03 7.06E-042.08E-03 2.87E-04 1.38E-016.63E-01 9.56E-01240Pu Activity (Ci) 9.43E-04 2.85E-047.45E-04 1.03E-04 1.38E-015.20E-01 9.72E-01242Pu Activity (Ci) 2.23E-07 6.76E-081.76E-07 2.44E-08 1.38E-015.19E-01 9.72E-01241Am Activity (Ci) 1.78E-03 5.40E-041.41E-03 1.95E-04 1.38E-015.19E-01 9.72E-0190Sr Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!137Cs Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!TRU Alpha Conc. (nCi/g) 2.10E+02 5.76E+011.66E+02 2.29E+01 1.38E-016.33E-01 9.59E-01Quantity ofInterest tPr(x<|t|)χ2Testt Test233U Activity (Ci) N/A N/A#VALUE! Not Applicable234U Activity (Ci) N/A N/A#VALUE! Not Applicable238U Activity (Ci) N/A N/A#VALUE! Not Applicable238Pu Activity (Ci) 1.76E+00 1.53E-01Not Significant Not Significant239Pu Activity (Ci) 1.76E+00 1.53E-01Not Significant Not Significant240Pu Activity (Ci) 1.76E+00 1.53E-01Not Significant Not Significant242Pu Activity (Ci) 1.76E+00 1.53E-01Not Significant Not Significant241Am Activity (Ci) 1.76E+00 1.53E-01Not Significant Not Significant90Sr Activity (Ci) N/A N/A#VALUE! Not Applicable137Cs Activity (Ci) N/A N/A#VALUE! Not ApplicableTRU Alpha Conc. (nCi/g) 1.76E+00 1.53E-01Not Significant Not SignificantB-3ATTACHMENT B.3: REPLICATE TESTING DATA FOR CONTAINERX10C0501270Instrument: DWAS/IPAN/SGSContainer: X10C0501270Original Measurement Replicate #1 Replicate #2Quantity of Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value Uncertainty Uncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 4.23E-04 1.22E-04 2.88E-013.68E-04 1.06E-04 2.88E-013.98E-04 1.15E-04 2.88E-01239Pu Activity (Ci) 3.17E-03 7.99E-04 2.52E-012.77E-03 6.94E-04 2.51E-012.99E-03 7.50E-04 2.51E-01240Pu Activity (Ci) 1.14E-03 3.28E-04 2.88E-019.90E-04 2.85E-04 2.88E-011.07E-03 3.08E-04 2.88E-01242Pu Activity (Ci) 2.69E-07 7.76E-08 2.88E-012.34E-07 6.75E-08 2.88E-012.53E-07 7.30E-08 2.88E-01241Am Activity (Ci) 3.11E-03 1.25E-03 4.02E-012.39E-03 7.52E-04 3.15E-014.26E-03 1.33E-03 3.12E-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 4.31E+02 1.21E+02 2.81E-013.58E+02 9.37E+01 2.62E-014.79E+02 1.27E+02 2.65E-01Replicate #3 Replicate #4 Replicate #5Quantity of Relative Relative Reported Reported Reported Relative Reported Absolute RelativeInterest Uncertainty Uncertainty Value Value Value Uncertainty Value Uncertainty Uncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 3.90E-04 1.12E-04 2.88E-013.86E-04 1.11E-04 2.88E-014.15E-04 1.19E-04 2.88E-01239Pu Activity (Ci) 2.93E-03 7.35E-04 2.51E-012.90E-03 7.26E-04 2.51E-013.12E-03 7.81E-04 2.51E-01240Pu Activity (Ci) 1.05E-03 3.02E-04 2.88E-011.04E-03 2.98E-04 2.88E-011.12E-03 3.21E-04 2.88E-01242Pu Activity (Ci) 2.48E-07 7.14E-08 2.88E-012.45E-07 7.07E-08 2.88E-012.64E-07 7.60E-08 2.88E-01241Am Activity (Ci) 1.98E-03 5.71E-04 2.88E-011.96E-03 5.64E-04 2.88E-012.11E-03 6.07E-04 2.88E-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 3.49E+02 8.99E+01 2.58E-013.45E+02 8.89E+01 2.58E-013.71E+02 9.56E+01 2.57E-01B-4ATTACHMENT B.4: REPLICATE TESTING RESULTS FOR CONTAINER X10C0501270Instrument: DWAS/IPAN/SGSContainer: X10C0501270Original Measurement Sample RelativeQuantity of Reported Absolute Sample Standard StandardInterest Value Uncertainty Mean Deviation Deviationχ2Pr(x<| χ2|)233U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!234U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!238U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!238Pu Activity (Ci) 4.23E-04 1.22E-043.92E-04 1.71E-05 4.36E-027.83E-02 9.99E-01239Pu Activity (Ci) 3.17E-03 7.99E-042.94E-03 1.28E-04 4.36E-021.03E-01 9.99E-01240Pu Activity (Ci) 1.14E-03 3.28E-041.05E-03 4.59E-05 4.36E-027.83E-02 9.99E-01242Pu Activity (Ci) 2.69E-07 7.76E-082.49E-07 1.09E-08 4.36E-027.84E-02 9.99E-01241Am Activity (Ci) 3.11E-03 1.25E-032.54E-03 9.78E-04 3.85E-012.46E+00 6.52E-0190Sr Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!137Cs Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!TRU Alpha Conc. (nCi/g) 4.31E+02 1.21E+023.80E+02 5.62E+01 1.48E-018.62E-01 9.30E-01Quantity ofInterestt Pr(x<|t|)χ2Testt Test233U Activity (Ci) N/A N/A#VALUE! Not Applicable234U Activity (Ci) N/A N/A#VALUE! Not Applicable238U Activity (Ci) N/A N/A#VALUE! Not Applicable238Pu Activity (Ci) 1.68E+00 1.69E-01Not Significant Not Significant239Pu Activity (Ci) 1.68E+00 1.69E-01Not Significant Not Significant240Pu Activity (Ci) 1.68E+00 1.69E-01Not Significant Not Significant242Pu Activity (Ci) 1.67E+00 1.69E-01Not Significant Not Significant241Am Activity (Ci) 5.26E-01 6.26E-01Not Significant Not Significant90Sr Activity (Ci) N/A N/A#VALUE! Not Applicable137Cs Activity (Ci) N/A N/A#VALUE! Not ApplicableTRU Alpha Conc. (nCi/g) 8.16E-01 4.60E-01Not Significant Not SignificantB-5ATTACHMENT B.5: REPLICATE TESTING DATA FOR CONTAINERX10C0505990Instrument: DWAS/IPAN/SGSContainer: X10C0505990Original Measurement Replicate #1 Replicate #2Quantity of Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value Uncertainty Uncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 5.36E-04 1.59E-04 2.96E-014.62E-04 1.35E-04 2.93E-014.63E-04 1.36E-04 2.92E-01239Pu Activity (Ci) 4.03E-03 1.05E-03 2.60E-013.47E-03 8.89E-04 2.56E-013.48E-03 8.91E-04 2.56E-01240Pu Activity (Ci) 1.44E-03 4.26E-04 2.96E-011.24E-03 3.63E-04 2.93E-011.25E-03 3.64E-04 2.92E-01242Pu Activity (Ci) 3.41E-07 1.01E-07 2.96E-012.94E-07 8.60E-08 2.93E-012.95E-07 8.62E-08 2.92E-01241Am Activity (Ci) 2.83E-03 1.03E-03 3.64E-012.02E-03 7.67E-04 3.80E-012.40E-03 7.16E-04 2.98E-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 3.01E+02 8.27E+01 2.75E-012.45E+02 6.65E+01 2.72E-012.58E+02 6.80E+01 2.63E-01Replicate #3 Replicate #4 Replicate #5Quantity of Relative Relative Reported Reported Reported Relative Reported Absolute RelativeInterest Uncertainty Uncertainty Value Value Value Uncertainty Value Uncertainty Uncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 7.07E-04 2.06E-04 2.91E-014.32E-04 1.27E-04 2.94E-019.14E-04 2.68E-04 2.93E-01239Pu Activity (Ci) 5.31E-03 1.36E-03 2.56E-013.24E-03 8.37E-04 2.58E-016.86E-03 1.76E-03 2.57E-01240Pu Activity (Ci) 1.90E-03 7.07E-04 3.72E-011.16E-03 3.41E-04 2.94E-012.45E-03 7.20E-04 2.93E-01242Pu Activity (Ci) 4.50E-07 1.31E-07 2.91E-012.75E-07 8.08E-08 2.94E-015.81E-07 1.70E-07 2.93E-01241Am Activity (Ci) 3.60E-03 1.05E-03 2.92E-012.21E-03 7.55E-04 3.41E-014.73E-03 1.85E-03 3.91E-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 3.92E+02 6.17E+01 1.57E-012.40E+02 6.48E+01 2.70E-015.09E+02 1.41E+02 2.76E-01B-6ATTACHMENT B.6: REPLICATE TESTING RESULTS FOR CONTAINER X10C0505990Instrument: DWAS/IPAN/SGSContainer: X10C0505990Original Measurement Sample RelativeQuantity of Reported Absolute Sample Standard StandardInterest Value Uncertainty Mean Deviation Deviationχ2Pr(x<| χ2|)233U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!234U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!238U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!238Pu Activity (Ci) 5.36E-04 1.59E-045.96E-04 2.10E-04 3.52E-016.97E+00 1.37E-01239Pu Activity (Ci) 4.03E-03 1.05E-034.47E-03 1.57E-03 3.52E-019.02E+00 6.05E-02240Pu Activity (Ci) 1.44E-03 4.26E-041.60E-03 5.63E-04 3.52E-016.97E+00 1.37E-01242Pu Activity (Ci) 3.41E-07 1.01E-073.79E-07 1.33E-07 3.52E-016.97E+00 1.37E-01241Am Activity (Ci) 2.83E-03 1.03E-032.99E-03 1.15E-03 3.85E-014.98E+00 2.90E-0190Sr Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!137Cs Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!TRU Alpha Conc. (nCi/g) 3.01E+02 8.27E+013.29E+02 1.19E+02 3.61E-018.24E+00 8.31E-02Quantity ofInterestt Pr(x<|t|)χ2Testt Test233U Activity (Ci) N/A N/A#VALUE! Not Applicable234U Activity (Ci) N/A N/A#VALUE! Not Applicable238U Activity (Ci) N/A N/A#VALUE! Not Applicable238Pu Activity (Ci) -2.59E-01 8.09E-01Not Significant Not Significant239Pu Activity (Ci) -2.59E-01 8.09E-01Not Significant Not Significant240Pu Activity (Ci) -2.59E-01 8.09E-01Not Significant Not Significant242Pu Activity (Ci) -2.59E-01 8.09E-01Not Significant Not Significant241Am Activity (Ci) -1.26E-01 9.06E-01Not Significant Not Significant90Sr Activity (Ci) N/A N/A#VALUE! Not Applicable137Cs Activity (Ci) N/A N/A#VALUE! Not ApplicableTRU Alpha Conc. (nCi/g) -2.16E-01 8.40E-01Not 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, h ad check marks indicating that the

questions for “Video/Audio Recorded Media System Ch eck” and “Image Test Pattern Test” were

checked to indicate that they were “SAT” (satisfact ory).

• 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 t he container?” was checked “No”. Even when

the form was reset the check marks did not disappea r.

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, Revi sion 0 did not adequately

document calibration of this NDA system. The EPA in spector could not determine the adequacy of this

instrument’s calibration on the basis of the calibr ation report alone. As a result of interviewing NDA

personnel during the inspection the SGS calibration was determined to be technically adequate. In gen eral,

the report’s overall quality is lacking with respec t to organization and attention to technical detail s.

Examples include:

• SGS-01 Calibration Qualification Summary does not s tate the system’s operating range with

respect to matrix (sample density) nor does the sec tion on Matrix Drums (Section 3) adequately

document the system’s capabilities in this area

• SGS-01 Calibration Qualification Summary does not l ist the use of default (AK) isotopics as an

option (19 of the 20 drums assayed to date have use d AK isotopics)

• The document is unclear regarding whether this syst em 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 discusse d 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 pr epared for the EPA Baseline

Inspection for several technical areas. Examples i nclude:

• NDA - EPA found the SGS Calibration Report was not a dequate 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 insuffici ent detail. Information that should have been

assessed and integrated in the document was availab le to the AKE and was identified during the

inspection. It was clear that continued developmen t 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 co ordinated 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 containe rs the EPA inspector noted that

while all the required items (prohibited items) wer e identified correctly by all RTR operators, some

additional items (cellulosics and plastics) were no t identified. All cellulosics and plastics in the training

drum need to be identified and their identification documented. To complete the training process it i s

critical that the operator receives feedback regard ing missed items. More detailed documentation of t he

feedback given is needed when the results of the tr aining 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 perfor med 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 rec onciliation of discrepancies when “identification o f

the waste matrix code, liquids in excess of TSDF-WA C limits and compressed gases differ between the tw o

operators”. The same situation applies to the inde pendent and original observations. While this prac tice

complies with the requirements of CCP-TP-053, Secti ons 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 wa ste 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 syste m 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, 234 

## U and 90 

## Sr. Inclusion of LLDs is required by CCP-TP-167, S ection

4.6.1 but the report is silent regarding the LLD de termination for these two radionuclides.

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): CCP-PO-002, CCP Transuranic Waste Certification Pla n

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 Memo randum with

regard to the LLDs for 234 

## U and 90 

## Sr. The LLD determinations for 234 

## U and 90 

## Sr 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 discr epancies, but resolution of these

discrepancies is incomplete. For example, resoluti ons are required to address 235 

## U and 238 

## U discrepancies

between NFS and TWPC NDA data, detection of 228 

## Th and 232 

## Th, isotopic inconsistencies (e.g., Halden,

SRO), and inconsistencies regarding the occurrence of 238 

## U and 235 

## U 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 als o 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 resp ect to technical issues that

could impact AK waste characterization. Examples o f technical areas that need additional information

include:

• Occurrence, source, and potential distribution of 233 

## U

• AK Summary conclusions and the development of defau lt isotopic distribution values

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

• Examination and updating of document to include rel evant information from references such as

U044 that has not been added to the AK reference li st or addressed in the AK Summary

• Additional process information (e.g., MOX generatio n)

• Addition of references included in the AK-NDA memo

• Additional changes based on assessment and integrat ion 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 docum ents, 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 mann er in which NDA personnel will use the AK data

should be specified in the AK-NDA memo or by referen ce 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