# EPA DOCKET NO. A-98-49; II-A4-176

WASTE CHARACTERIZATION REPORT

TIER 1 CHANGE EVALUATION:

ADDITION OF THE MOBILE ISOCS LARGE CONTAINER COUNTE R

FOR THE CENTRAL CHARACTERIZATION PROGRAM

AT THE LOS ALAMOS NATIONAL LABORATORY

June 4–5, 2013

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air

Center for Waste Management and Regulations

1200 Pennsylvania Avenue, NW

Washington, DC 20460

July 2013

# i 

# TABLE OF CONTENTS

1.0 Introduction ......................................

................................................... ................................ 1

2.0 Purpose of Tier 1 Evaluations .....................

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

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

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

4.0 Scope of Review ...................................

................................................... ........................... 4

5.0 Evaluation Personnel ..............................

................................................... ......................... 4

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

................................................... ......................... 4

6.1 System Description ................................

................................................... .............. 5

6.2 Documents Reviewed ................................

................................................... .......... 5

6.3 Evaluation Checklist ..............................

................................................... .............. 6

6.4 Measurement Geometries ............................

................................................... ........ 6

6.5 Calibration, Calibration Validation and Confirmatio n ........................................... 8

6.6 Operating Range ...................................

................................................... ............. 11

6.7 Lower Limit of Detection Determination ............ ................................................. 1 1

6.8 Total Measurement Uncertainty .....................

................................................... ... 11

6.9 Batch Data Reports ................................

................................................... ............ 12

6.10 Replicate Assays ..................................

................................................... .............. 13

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

................................................... ...................... 14

8.0 Conclusions .......................................

................................................... ............................. 14

TABLES

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

by LANL-CCP .......................................

................................................... ........................ 2

Table 2. Evaluation Personnel .....................

................................................... ................................ 4

FIGURES

Figure 1. 55-gallon Drum Detector Placement .......

................................................... ..................... 7

Figure 2. SWB and CMB Detector Placement ..........

................................................... .................. 8

ATTACHMENTS

Attachment A Approval Summary for LANL-CCP Contac t-Handled Waste Characterization

Program

Attachment B Mobile ISOCS Large Container Counter Evaluation Checklist

Attachment C.1 MILCC Replicate Testing Results for Container No. 93683 (55-gallon Drum)

Attachment C.2 MILCC Replicate Testing Results for Container No. 52303 (CMB)

# ii 

# ACRONYMS AND ABBREVIATIONS

AK acceptable knowledge

AKSR AK summary report

Am americium

ASTM American Society for Testing and Materials

BDR batch data report

BEGe Broad Energy Germanium

CBFO Carlsbad Field Office

CCP Central Characterization Program

CFR Code of Federal Regulations

CH contact-handled

CIS characterization information summary

CMB corrugated metal boxes

cps counts per second

Cs cesium

CTAC CBFO Technical Assistance Contractor

DOE U.S. Department of Energy

EA Expert Analyst

EPA U.S. Environmental Protection Agency

FRAM Fixed-Energy Response-Function Analysis with M ultiple Efficiencies

g gram

g/cc grams per cubic centimeter

in. inch

ISOCS In Situ Object Counting System

ITR Independent Technical Reviewer

IUE ISOCS Uncertainty Estimator

keV kilo-electron volt

LANL Los Alamos National Laboratory

LLD lower limit of detection

LOQI list of qualified individuals

MCNP Monte Carlo N-Particle Transport Code

MCS Mobile Characterization Services

# iii



# MDA minimum detectable activity

MDC minimum detectable concentration

MeV mega-electron volt

MGA Multi-Group Analysis

MILCC Mobile ISOCS Large Container Counter

nCi/g nanocuries per gram

NCR nonconformance report

NDA nondestructive assay

Np neptunium

NWP Nuclear Waste Partnership, LLC

OSRP Offsite Source Recovery Project

PDP Performance Demonstration Program

PM Project Manager

Pu plutonium

%R percent recovery

%RSD percent relative standard deviation

RDS Radioassay Data Sheet

SCG Summary Category Group

SLB-2 Standard Large Box-2

SN serial number

SNM special nuclear material

SPM Site Project Manager

Sr strontium

SuperHENC Super High Efficiency Neutron Counter

SWB standard waste box

T1 Tier 1

T2 Tier 2

TDOP ten-drum overpack

TMU total measurement uncertainty

TRU transuranic

U uranium

WIPP Waste Isolation Pilot Plant

WSPF waste stream profile form

# 1



# 1.0 INTRODUCTION

This report supports the U.S. Environmental Protect ion Agency’s (EPA’s) approval of a Tier 1

(T1) change to add a Mobile In Situ Object Counting System (ISOCS) Large Container Cou nter

(MILCC) unit to the Central Characterization Progra m’s (CCP’s) approved waste

characterization program at Los Alamos National Lab oratory (LANL). In accordance with Title

40 of the Code of Federal Regulations (40 CFR) 194. 8(b), EPA conducted a baseline inspection

of CCP’s waste characterization program for contact -handled (CH) transuranic (TRU) wastes at

the U.S. Department of Energy’s (DOE’s) LANL in Los Alamos, New Mexico, in 2007. As a

result, EPA approved the LANL-CCP CH TRU waste char acterization program (see EPA

Docket No. A-98-49, II-A4-88). EPA’s reviews and ap provals of LANL-CCP’s CH waste

characterization program are listed in Attachment A

.

On May 30, 2013, the Carlsbad Field Office (CBFO) r equested EPA approval of a T1 change to

add the MILCC as a new nondestructive assay (NDA) s ystem at LANL. The MILCC will assay

summary category group (SCG) S3000 (solids) and SCG S5000 (debris) waste in 55-gallon

drums, standard waste boxes (SWBs) and corrugated m etal boxes (CMBs) 1



# .

EPA evaluated the proposed T1 change by reviewing L ANL-CCP documents and conducting an

onsite evaluation of the MILCC at LANL and the Mobi le Characterization Services (MCS)

offices in Los Alamos on June 4–5, 2013. EPA determ ined that the MILCC is adequate for

characterization of CH TRU waste in the configurati on observed during the evaluation. LANL

may make changes to the MILCC followed by performan ce testing to verify that the EPAapproved calibration is valid following the change, (e.g., change components in a like-for-like

replacement, or relocate it to another area at LANL ). If the performance testing is successful and

the EPA-approved calibration is verified, LANL-CCP may continue to operate the MILCC and

notify EPA regarding the change as a Tier (T2) chan ge. However, if the EPA-approved

calibration cannot be verified, LANL-CCP must notif y EPA and the MILCC must be

recalibrated and the new calibration must be approv ed by EPA as a T1 change. LANL-CCP may

not ship any containers characterized on the modifi ed MILCC until EPA approves the new

calibration as a T1 change.

EPA made minor modifications to the tiering table a s part of EPA’s ongoing efforts to harmonize

the language and format of the tiering tables for a ll CH TRU waste characterization programs

and added one new NDA T2 change (see Table 1).

1 

# The CMB is not an approved shipping container for the Waste Isolation Pilot Plant (WIPP) but LANL has

an inventory of CMBs containing TRU wastes. LANL pe rsonnel plan to use the MILCC to assay the CMBs and

pack them inside ten-drum overpacks (TDOPs) for shi pment, as discussed in section 6.4.2 of this report

.2Table 1. Tiering of Contact-Handled Transuranic Waste Characterization Processes Implemented by LANL-CCP(Based on May 23–25, 2006, Baseline Inspection andSubsequent T1 Evaluations, Updated July 2013)Process ElementsLANL-CCP Waste Characterization Process – T1 ChangesLANL-CCP Waste Characterization Process – T2 Changes*Acceptable Knowledge,including LoadManagementAny new waste category, as well as any new OSRP wastestreams addressed in AKSRs separate from CCP-AK-008or newOSRP waste streams beyond LA-OS-00-01.001, LA-OS-00-03,and LA-OS-00-04 added to CCP-AK-008Load management for waste streams other than as documented inCCP-AK-009Notification to EPA upon completion of or substantive modification** to:•AK-NDA memoranda•AK accuracy reports (annually, at a minimum)•AK reassessment memoranda and combination of wastestreams that weredistinct at the time of the baseline inspection•Any new or updated WSPFs, including all associatedattachments (e.g., CIS andsummation of aspects) and any change notices used to modify and updateWSPFs, including additions to waste streams withinan approved waste category•AKSRs (new and updated versions), including CCP-AK-008•CCP-TP-005, Attachment 6, and associated memoranda•Site procedures requiring CBFO approvalNondestructive Assay New equipment or substantivephysical modifications** toapproved equipmentExtension of or changes to approved calibration ranges forapproved equipmentNotification to EPA upon:•Substantive modification** to software for approvedequipment•Substantive modification** to operating ranges uponCBFO approval•Substantive modification** to site procedures requiring CBFO approval•Any change to the MILCC that does not directly impact the EPA-approvedcalibration, including relocation of the system atLANL†Real-Time RadiographyNoneNotification to EPA upon:•New equipment or substantive physical modifications** to approved equipment•Substantive modification** to site procedures requiring CBFO approvalVisual Examination andVisual ExaminationTechniqueNoneNotification to EPA upon substantive modification**to site procedures requiringCBFO approval, including OSRP visual examination technique procedureWIPP Waste DataSystemNoneNotification to EPA upon substantive modification**to:•Site procedures requiring CBFO approval•Excel spreadsheet, Waste Data System data entry summary, characterizationand certification requiring CBFO approvalNew T1s, T2s and significant modifications to existing T1s or T2s are inboldtext; T1s or T2s that were only revised for style are not shown in bold.* LANL-CCP will report all T2 changes to EPA everythree months.** “Substantive modification” refers to a change with the potential to affect LANL-CCP’s CH waste characterization processes or documentation of them, excluding changes thatare solely related to the environment, safety and health; nuclear safety; or the Resource Conservationand Recovery Act; or that are editorial in natureor are required to addressadministrative concerns. EPA may request copies ofnew references that DOE adds during a document revision.† LANL-CCP will report relocation of any NDA systemto EPA immediately.

# 3



# 2.0 PURPOSE OF TIER 1 EVALUATIONS

Any changes to the waste characterization activitie s from the date of the baseline inspection must

be reported to and, if applicable, approved by EPA according to the tiering requirements set forth

in the LANL baseline final report cited above.

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

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

characterization program. The purpose of the baseli ne inspection is to approve the site’s waste

characterization program based on the demonstration that the program’s components, with

applicable conditions and limitations, can adequate ly characterize TRU wastes and comply with

the regulatory requirements imposed on TRU wastes d estined for disposal at the WIPP. An EPA

inspection team conducts an onsite inspection to ve rify that the site’s system of controls is

technically adequate and properly implemented.

Following EPA’s approval of waste characterization processes evaluated during the baseline

inspection, EPA is authorized to evaluate and appro ve, if necessary, changes to the site’s

approved waste characterization program by conducti ng additional inspections under the

authority of 40 CFR 194.24(h). Under 40 CFR 194.24, EPA has the authority to conduct

continued compliance inspections to verify that the site continues to use only the approved waste

characterization processes to characterize the wast e and remains in compliance with all of the

regulatory requirements. Based on the adequacies of the waste characterization processes

demonstrated during the baseline inspection, includ ing all conditions and limitations, EPA

specified which subsequent waste characterization p rogram changes or modifications must

undergo further EPA inspection or approval under 40 CFR 194.24. This was accomplished by

assigning a tier level to each aspect of the LANL-C CP characterization program. T1 activities

have more stringent reporting requirements and requ ire that DOE notify EPA and that EPA

provide approval prior to implementation. Attachmen t A lists all of EPA’s non-T2 approvals of

the LANL-CCP CH TRU waste characterization program. The rule under which baseline

inspections are conducted can be found in the Feder al Register (Vol. 69, No. 136, pages 42571–

42583) of July 16, 2004.

3.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluatio n of a T1 change to allow the use of the

MILCC for assays of 55-gallon drums, SWBs and CMBs. This report documents the basis for

EPA’s approval decision and explains the results of the technical evaluation of the system,

including any limitations. EPA’s approval decision regarding the MILCC has been conveyed to

DOE separately by letter. EPA will also announce th e decision on its website at

www.epa.gov/radiation/wipp, in accordance with 40 C FR 194.8(b)(3).

The documents that EPA reviewed for this evaluation that are cited in this report can be

requested from:

# 4



# Carlsbad Field Office

Manager, National TRU Program

P.O. Box 3090

Carlsbad, NM 88221-3090

4.0 SCOPE OF REVIEW

The scope of this review is limited to the addition of a new LANL-CCP NDA system, the

MILCC. The MILCC will be used to assay 55-gallon dr ums, SWBs and CMBs. EPA evaluated

this proposed change request in accordance with 40 CFR 194.8(b) to assess the technical

adequacy, implementation and effectiveness of the t echnical processes implemented by LANLCCP for the MILCC. EPA evaluated personnel qualific ations and training, operating procedures,

the physical configuration of the measurement syste m and replicate testing of the MILCC to

assess the system’s adequacy.

5.0 EVALUATION PERSONNEL

Table 2 lists all personnel involved in this T1 eva luation, along with their professional

affiliations and T1 evaluation functions.

Table 2. Evaluation Personnel

6.0 TECHNICAL EVALUATION

EPA evaluated the MILCC NDA system that will be use d to characterize CH TRU wastes at

LANL-CCP. The evaluation occurred on-site on June 4 –5, 2013. The evaluation of the MILCC

and associated records and personnel took place at LANL and the MCS offices. As part of the

evaluation, EPA reviewed the following elements of the MILCC process:

• Capability of the measurement hardware and software to perform the required analyses.

• Technical adequacy of the NDA documents and procedu res.

• Knowledge and understanding of the personnel involv ed in the NDA program.

Personnel Name Affiliation T1 Evaluation Function

Ed Feltcorn EPA EPA Evaluation Lead

Patrick Kelly SC&A/EPA EPA Technical Evaluator

Rose Gogliotti SC&A/EPA EPA Technical Evaluator

Terri-Ann Groover NWP/CCP SPM

Sean Stanfield Canberra NDA Director

Tom Morgan DOE/CBFO Observer

Neil Dickes NWP/CCP NDA Support

Ed Gulbransen NWP/CCP CCP Management

Bruce Gillespie Canberra/ MCS NDA

Jared Francis Canberra/ MCS NDA

Miles Littlefield CBFO/CTAC Observer

Craig Simmons NWP/CCP PM

Curt (Richard) Bauman MCS/CCP NDA

Joseph Wachter Canberra/ MCS/ CCP NDA

# 5



# Attachment B identifies the objective evidence that was examined for EPA’s evaluation. During

the evaluation, the EPA team members assessed techn ical elements of the MILCC system that

are detailed in the checklist in Attachment B and a re discussed below.

6.1 System Description

The MILCC is operated by LANL-CCP and is currently located in the Eastern end of Dome 283

in the G Area of TA-54 at LANL. The MILCC consists of two ISOCS Broad Energy Germanium

(BEGe) gamma detectors that are affixed to wheeled mobile carts and placed at fixed distances

equidistant, on opposite sides of the container to be measured. The detectors are connected to

computers with the ISOCS user interface software, c reating a makeshift “box counter.”

The BEGe detectors (gamma spectrometers) are approp riate for the direct quantification of

plutonium-238 ( 238 

# Pu), 239 

# Pu, 240 

# Pu, americium-241 ( 241 

# Am), uranium-233 ( 233 

# U), 235 

# U, 238 

# U,

cesium-137 ( 137 

# Cs), neptunium-237 ( 237 

# Np) and other gamma-emitting radionuclides. Both

detectors are covered with 0.01 inch (in.) tin and 0.02 in. copper filters and a multi-curve

efficiency calibration is used to compensate for va riations in matrix density. The MILCC is

capable of assaying debris, soils, gravel and homog eneous solids waste matrices with densities

from 0 to 2.5 grams per cubic centimeter (g/cc). Th e acceptable assay configurations for the

MILCC are as follows:

• 55-gallon drum near position with 180 o 

# collimator (detectors 42 in. from drum)

• 55-gallon drum far position with 90 o 

# collimator (detectors 72 in. from drum)

• SWB near position with 180 o 

# collimator (detectors 42 in. from SWB)

• SWB far position with 90 o 

# collimator (detectors 144 in. from SWB)

• CMB near position with 180 o 

# collimator (detectors 42 in. from CMB)

• CMB far position with 90 o 

# collimator (detectors 144 in. from CMB)

All stated detector-to-container distances are appr oximate, and the actual distance is measured

for each item as described below. Diagrams of each configuration are shown in Figures 1 and 2,

below.

Unlike other CH NDA systems used in the DOE complex , the MILCC system is designed to be a

mobile system. LANL-CCP conveyed to EPA that they i ntend to use the system only in its

current location in the near term; however, it is p ossible the system may be relocated in the

future. During the evaluation, EPA and LANL-CCP agr eed that if the MILCC system is

relocated and successfully completes calibration ve rification, LANL-CCP will immediately

submit a T2 notification. If after relocation, the system’s calibration cannot be successfully

verified and a new calibration is required, LANL-CC P will request this as a T1 change.

6.2 Documents Reviewed

EPA evaluated the following documents to support th e approval of the addition of the MILCC:

• CI-MILCC-NDA-1006, “Mobile ISOCS Large Container Co unter Calibration Report,”

Revision 0, April 4, 2013.

# 6



# • Canberra Factory Document, “Total Measurement Uncer tainty Report for MCS/LANL

ISOCS ‘Box Counter’,” Revision 2, April 2, 2013.

• Canberra Factory Document, “White Paper on the Eval uation of Measuring Corrugated

Metal Boxes Using the Standard Waste Box Calibratio n,” March 25, 2013.

• MILCC BDR Nos. 4LANDA0001 (55-gallon drums), 4LANDA 0002 (CMBs) and

4LANDA0003 (SWBs).

• “Mobile ISOCS Large Container Counter Calibration V erification,” May 7, 2013.

• LANL MILCC NDA Qualification Cards for Jared Franci s, Richard Baumann, Tim

Barton, Ryan Hammon and Israel Aragon.

• LANL MILCC Expert Analyst (EA) Qualification Cards for Jared Francis, Richard

Baumann, Tim Barton, Ryan Hammon.

• Operator Aids: OA-NDA-006, Revision 1, and OA-NDA-0 05, Revision 2.

• CCP-TP-076, CCP Operating the Mobile ISOCS Large Co ntainer Counter Using NDA

2000, Revision 0, May 16, 2013.

• CCP-TP-077, CCP Calibrating the Mobile ISOCS Large Container Counter Using NDA

2000, Revision 0, May 16, 2013.

• CCP-TP-103, CCP Data Reviewing, Validating, and Rep orting Procedure for the NDA

Counters at LANL Using NDA 2000, Revision 11, May 1 6, 2013.

6.3 Evaluation Checklist

Based on EPA’s review of the LANL-CCP documents lis ted above, EPA prepared a revised

checklist for this evaluation that addressed the re levant aspects of the proposed change to the

measurement configuration. The checklist is include d as Attachment B to this report.

6.4 Measurement Geometries

LANL-CCP will use the MILCC to characterize TRU was te in 55-gallon drums, SWBs and

CMBs at fixed far and near distances only, as discu ssed in sections 6.4.1 and 6.4.2, below. Some

MILCC documentation provided to EPA also discusses a MILCC calibration for Standard Large

Box-2s (SLB-2s). LANL-CCP did not include the SLB-2 container in the approval request for

the MILCC system; consequently, EPA did not review any documentation related to assaying an

SLB-2. The MILCC may not be used to formally assay SLB-2s and the addition of an SLB-2 to

the MILCC approval would require a T1 change.

6.4.1 55-gallon Drum

The MILCC may be used to assay 55-gallon drums in n ear- (approximately 42 in. from detector

faces to drum surface) and far- (approximately 72 i n. from detector faces to drum surface) field

positions. The placement of the detectors is illust rated in Figure 1, below. A similar diagram

(Operator Aid OA-NDA-006, Revision 1) was posted in the MILCC system control room. Lines

on the floor of Dome 283 are used to guide operator s regarding approximate locations of

detectors and the waste container.

# 7



# All containers are moved by forklift. The forklift operator places the edge of the drum as close as

possible to a line on the south edge of the floor. This line is shown in red in Figure 1 and the

Operator Aid diagram. All distances are measured pr ior to assay using a tape measure or a laser

distance measuring tool, both of which are stored i n the operational area. A laser is held in-line

with the detector face to ensure the detector is li ned up correctly with the midline of the drum’s

height. The detector height on the cart is fixed at 26.7 in. and is subject to minor height

fluctuations caused from cart wheel inflation. The detector aligns with the center height of the

55-gallon drum approximately 9.8 in. off the ground . The detector height and fluctuations are

incorporated in the modeling of the ISOCS geometry and calibration uncertainty.

LANL-CCP indicated that 55-gallon drums would initi ally be assayed for 30 minutes at the nearfield position. If an acceptable assay cannot be ob tained at the near position, NDA personnel

may elect to assay at the far-field position and/or increase the counting time.

6.4.2 Corrugated Metal Box and Standard Waste Box

The MILCC may also be used to assay SWBs and CMBs i n near- (42 in.) and far- (144 in.) field

positions. The placement of the detectors is illust rated in Figure 2, below. A similar diagram

(Operator Aid OA-NDA-006, Revision 1) was posted in the MILCC system control room. Lines

on the floor of Dome 283 are used to guide operator s regarding approximate locations of

detectors and the waste container. The forklift ope rator places the edge of the container’s longest

edge as close as possible and parallel to a line on the south edge of the floor. This line is shown

in red in Figure 1 and the Operator Aid diagram. Al l distances are measured prior to assay using

a tape measure or a laser distance measure that are stored in the operational area.

Prior to placement, the CMB is measured lengthwise and a mark is made in the center. SWBs

have a support bar at the midline. The laser is hel d in line with the detector face and pointed at

the waste container. Using the laser the cart is mo ved to ensure that the detector face is aligned

with the midline of the detector. The detector heig ht on the cart is fixed at 26.7 in. and is subject 55-

gallon

drumNear-Field PositionNear-Field PositionFar-Field PositionFar-Field Position



# 42 in.

72 in. 72 in. 42 in.

Figure 1. 55-gallon Drum Detector Placement

# 8



# to minor height fluctuations caused by inflation of the ISOCS cart’s wheels. The detector center

aligns with the center height of an SWB (on a palle t) 3.6 in. above ground and with the center

height of a CMB (which has a built-in pallet) 0.3 i n. above the ground. The detector height and

fluctuations are incorporated in the modeling of th e ISOCS geometry and calibration uncertainty.

LANL-CCP indicated that SWBs and CMBs would initial ly be assayed for 30 minutes at the

near-field position. If a satisfactory assay cannot be obtained at the near-field position, NDA

personnel may elect to assay at the far-field posit ion and/or elect to increase count times.

The CMB is not an approved WIPP shipping container and CMBs that contain TRU waste will

be assayed using the MILCC system and placed in a T DOP for shipping and eventual placement

into WIPP. For the CMB to fit inside a TDOP, the to p corners along the length of the CMB are

removed, wrapped in heavy-duty plastic to prevent t he spread of contamination and placed inside

the CMB.

6.5 Calibration, Calibration Validation and Confirmatio n

The MILCC’s calibration of record is documented in the Calibration Report (CI-MILCC-NDA1006, Revision 0) in sections 3.0–6.0 and Appendix 7, and evaluated in sections 6.5.1–6.5.5 of

this report. The calibration of record does not con tain all relevant information because the two

BEGe detectors were ISOCS characterized at Canberra in Meriden, CT, as discussed in detail in

section 6.5.3, below.

The MILCC system effectively has four calibrated ge ometries: near- and far-field calibrations for

both a 55-gallon drum and an SWB. Although the MILC C is also approved to assay the CMB

container type, it does not have its own calibratio n per se. There are no CMBs available for

performing the typical calibration measurements usi ng either an empty container or a matrix

container, and LANL-CCP was unable to perform a CMB -specific calibration. Instead, Canberra

compared the CMB and SWB containers as they relate to ISOCS calibration. This comparison is

documented in a white paper by Canberra dated March 25, 2013. It was found that the ratio SWB

or

CMBFar-Field PositionFar-Field Position



# 42 in.

144 in. 144 in. 42 in.Near-Field PositionNear-Field Position



# Figure 2 . SWB and CMB Detector Placement

# 9



# between the two container types remains consistent (12-24%) over a wide range of densities.

There is also only minor variation in the typical g amma energy range for the radionuclides of

interest. Based on this assessment, LANL-CCP determ ined that applying a bias correction of

18% to the SWB calibration provides an uncertainty of approximately 2% at 1 sigma and was

acceptable for assaying a CMB. EPA reviewed the doc umentation supporting the use of SWB

calibration with an 18% correction factor for a CMB assay and found it to be technically

adequate. NDA personnel conveyed to EPA that the bi as correction is done automatically by the

computer software when the operator indicates that a CMB is being assayed. For a CMB assay,

the NDA 2000 Assay Report states that the container type is SWB and CMB is indicated in the

comments line. LANL-CCP estimates that there is a p opulation of 24–38 CMB containers that

will be assayed on the MILCC; however, this was for information only and there is no formal

limit on how many CMBs the MILCC can assay.

6.5.1 Gamma Ray Peak Shape and Energy Calibrations

In December 2012, the gamma ray peak shape and ener gy calibrations for both detectors were

performed. The spectral gain was set at approximate ly 0.90 kilo-electron volt (keV)/channel with

an offset of approximately 0.0 keV. The results of the gamma energy and peak shape calibrations

are shown in Appendix 2 of the Calibration Report. EPA reviewed this documentation and found

it to be technically adequate.

6.5.2 Reference Peak Calibration

A pulser is used to provide dead time corrections f or the two gamma spectrometers via the use of

a reference peak at an area of the spectrum relativ ely free of interferences. The reference peak

calibration for the MILCC was performed with no was te container present and was set to 1,200

keV and adjusted to approximately 100 counts per se cond (cps).

6.5.3 Efficiency Calibration/Detector Characterization

The MILCC uses two ISOCS model BE5030 planar BEGe d etectors, each with an active area of

50 square centimeters. Canberra performed an ISOCS- generated multi-curve efficiency

calibration of each detector at their Meriden, CT, location. Appendix 7.0 of the Calibration

Report documents the parameters used to generate th e multi-curve efficiency calibrations.

Calibration efficiency charts are depicted in Figur es 1–4 of the Calibration Report.

Both detectors were ISOCS characterized by their ma nufacturer Canberra. EPA has previously

evaluated the technical aspects of this process thr ough technical discussions with Canberra

personnel at the Meriden, CT, facility. Although th e exact method Canberra uses to characterize

detectors is proprietary, it was described to EPA w ith sufficient detail to support its use in

characterizing gamma detectors for assaying WIPP-bo und waste. It involves the development

and validation of an MCNP model for each detector, which includes generating efficiency data

sets to predict a detector’s response to point-like sources at many locations. A detector

characterization file that contains the relationshi p of the detector to the point-efficiency data and

the validation of the resulting characterization fi le is generated, and this file is then used by the

# 10



# ISOCS user interface software. EPA reviewed both Ca nberra detector characterization reports

and found them to adequately document the character ization of the detectors. 2



# Detector #01 is currently located on the south side of Dome 283 and has serial number (SN)

BE08004606. This detector is also referred to as No . 08004606 or No. 4606 in some

documentation. It was originally characterized by C anberra in Meriden, CT, in October 2001 and

was subsequently returned to Canberra for repair, f ollowing which its calibration was verified in

November 2002. This date is listed on the detector. In November 2011 the detector was again

returned to Canberra for servicing. During servicin g the germanium crystal was removed,

modified slightly and repositioned in the detector. Canberra determined that this servicing did

not require calibration verification; therefore, th e detector characterization date on the detector

did not change. This was discussed at length during the EPA evaluation and LANL-CCP

provided sufficient documentation to support the ch aracterization of record.

Detector #02 is currently located on the north side of Dome 283 and has SN BE07048046. This

detector is also referred to as No. 07048046 or No. 8046 in some documentation. It was

originally characterized by Canberra in Meriden, CT , in January 2006. This date is listed on the

detector. It was subsequently returned to Canberra for servicing in October 2011. Canberra

determined that this servicing did not require cali bration verification; therefore, the detector

characterization date on the detector did not chang e.

Upon receipt of each detector from Canberra, LANL-C CP performed a calibration validation to

confirm that the calibration was still technically adequate.

6.5.4 Calibration Verification

LANL-CCP performed a calibration verification of th e MILCC using both combustibles and

metals matrices in an SWB. Additional verification measurements were done using a foam

matrix 55-gallon drum. Three assays were done on ea ch container using National Institute of

Standards and Technology traceable mixed-gamma line sources to verify the calibration. These

sources and their placement in the 55-gallon drum a nd SWB are discussed in section 6.0 of the

Calibration Report. Using the two SWBs and the drum , each with different densities, the multicurve efficiency calibration was verified, as docum ented in Tables 6a–6c of the Calibration

Report. The accuracy and precision of the calibrati on verification data were in compliance with

the limits in DOE/WIPP-02-3122 3 

# , Appendix A, Table A-2, and EPA determined that th e results

of the calibration verification indicated that the MILCC is operating within the acceptable limits.

6.5.5 Calibration Confirmation

The gamma calibration was confirmed by measuring Pu sources in an SWB and a 55-gallon

drum. Each container type was measured six times at both near and far detector positions with

mass loadings of approximately 13.5 grams (g), 17.0 7 g, 138 g and 253 g of total Pu. Sources in

each mass loading are summarized in Tables 7 and 7a and detailed in Appendix 1 of the

2 

# As a result of this characterization, the BEGe det ectors are described as “ISOCS-characterized detect ors.”

3 

# U.S. DOE CBFO, “Transuranic Waste Acceptance Crite ria for the Waste Isolation Pilot Plant,”

DOE/WIPP-02-3122, Revision 7.4, Carlsbad, New Mexic o, April 22, 2013.

# 11



# Calibration Report. When viable isotopic fractions are available they are used, otherwise the

declared or certificate isotopics are used. The gam ma confirmation measurements are listed in

Tables 7b through 7q of the Calibration Report. The percent recovery and precision of each of

the six replicate measurements met the criteria in DOE/WIPP-02-3122, Appendix A, Table A-2.

6.6 Operating Range

The operating range for the MILCC is limited by den sity, spectral parameters, dead time and

lower limit of detection (LLD). The MILCC may assay wastes with densities ranging from

0.001–2.50 g/cc. This includes and exceeds the dens ity ranges LANL-CCP expects to encounter

in the population of waste containers to be assayed by the MILCC. Although not a formal

operating range, LANL-CCP stated that the mass oper ating range of the MILCC is a total Pu

content from the LLD to 325 g.

6.7 Lower Limit of Detection Determination

Instruments performing TRU/Non-TRU waste discrimina tion must have a minimum detectable

concentration (MDC) of less than 100 nanocuries per gram (nCi/g) TRU radionuclides.

Minimum detectable activities (MDAs) are variable a nd depend on measurement conditions such

as background rate and matrix. LANL-CCP performed a set of three replicate measurements on a

surrogate matrix SWB and 55-gallon drum, at the nea r- and far-field positions, with no

radioactive sources in order to establish an MDA ty pical of a MILCC assay. The NDA 2000

software calculated the MDA from these measurements applying weapons-grade isotopics. The

MDAs were used to calculate MDCs, as shown in Table s 8a-8d of the Calibration Report. All

WIPP-tracked radionuclides were found to have an MD A above 100 nCi/g in a typical waste

assay with the exception of 241 

# Am in the far-field detector. This was discussed wi th LANL-CCP

NDA personnel who stated that this is unlikely to b e a problem because the default assay

position for an SWB is the near-field position, for which the MDA was acceptable. The SWB

would only be assayed at the far-field position if the dead-time was excessive at the near-field

position, a condition that indicates the container’ s activity would exceed the MDC. EPA agreed

with LANL-CCP’s explanation.

Because the LLD is a measurement-based parameter, L ANL-CCP personnel stated that it is not

technically feasible to calculate for radionuclides that are not directly measured, i.e., 242 

# Pu, 234 

# U

and strontium-90 ( 90 

# Sr). Typical gamma reporting thresholds for selecte d radionuclides in each

container type are listed in Tables 8e through 8h o f the Calibration Report. EPA evaluated these

tables and found all reporting thresholds to be acc eptable.

6.8 Total Measurement Uncertainty

Total measurement uncertainty (TMU) for the MILCC i s documented in “Total Measurement

Uncertainty for the MCS/LANL ISOCS ‘Box Counter’,” Revision 2, dated April 2, 2013. The

TMU determination was performed with the ISOCS Unce rtainty Estimator (IUE), a software tool

that generates models associated with errors caused by the evaluation of these parameters. The

primary components of uncertainty include calibrati on source uncertainties, ISOCS model

uncertainties, detector positioning, matrix in homo geneity, non-uniform source distribution, fillheight uncertainty, self-attenuation of special nuc lear material (SNM) “lumps”, counting

# 12



# statistics, background fluctuations, radionuclide i nterferences and isotopic measurement

uncertainty. Other potential sources of uncertainty are expected to be small. The uncertainty for

each of the quantifiable uncertainty sources is ass umed to be statistically independent and is

added in quadrature to derive the TMU, as documente d in the TMU report. EPA discussed the

evaluation of TMU with LANL-CCP and found it to be technically appropriate.

6.9 Batch Data Reports

At the time of the evaluation only nine containers had been assayed on the MILCC. The assays

were documented in three batch data reports (BDRs): 4LANDA001, 4LANDA002 and

4LANDA003. The EPA evaluation team reviewed all thr ee BDRs. EPA verified that each BDR

included the following:

• Site Project Manager (SPM) Checklist, CCP-TP-001, R evision 20, Attachment 3.

• BDR Cover Sheet, CCP-TP-103, Revision 11, Attachmen t 1.

• BDR Table of Contents, CCP-TP-103, Revision 11, Att achment 2.

• NDA Batch Report Narrative Summary, CCP-TP-103, Rev ision 11, Attachment 3.

• Independent Technical Reviewer (ITR) Review Checkli st, CCP-TP-103 Revision 11,

Attachment 4.

• Assay Report for each container listed on Attachmen t 1.

• Radioassay Data Sheet (RDS) for each container list ed on Attachment 1.

• Automated ITR for each container listed on Attachme nt 1.

• Genie Quality Assurance Reports.

• CCP Records Transmittal/Receiving Form, Attachment 2.

• Evidence of signatures by the ITR on Attachment 1, an SPM on Attachment 3 and an EA

on the Automated ITR report for each container list ed on Attachment 1.

• Correct revisions of CCP-TP-001 4 

# and CCP-TP-103.

The MILCC reports direct quantitative values and un certainties for 238 

# Pu, 239 

# Pu, 241 

# Am, 233 

# U,

235 

# U, 238 

# U, 137 

# Cs, and 237 

# Np. The nuclides 90 

# Sr, 234 

# U, and 242 

# Pu are obtained through scaling

factors. LANL-CCP states the 234 

# U scaling factor 0.014 is used for wastes containin g 235 

# U, and

the scaling factor 0.427 is used for wastes contain ing primarily 238 

# Pu. The Pu isotopic ratios are

determined using the Multi-Group Analysis (MGA) or Fixed-Energy Response-Function

Analysis with Multiple-Efficiencies (FRAM) Software , or are based on site-approved acceptable

knowledge (AK). Each assayed container contained TR U radionuclides at concentrations greater

than 100 nCi/g. There were no concerns regarding th e technical adequacy of the radionuclide

documentation in NDA BDRs for the MILCC.

4 

# CCP-TP-001, CCP Project Level Data Validation and Verification, Revision 20, September 27, 2012.

# 13



# 6.10 Replicate Assays

The purpose of replicate testing is to provide EPA with an independent means to verify that the

MILCC can provide reproducible results for determin ation 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) and the TRU alpha concentration. 5



# This is accomplished by the MILCC reassaying contai ners it previously measured to demonstrate

the system’s ability to:

• 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 by comparing the results of the

replicate measurements to the original reported val ues.

As part of this evaluation, EPA requested that LANL -CCP reassay a 55-gallon drum and a CMB.

EPA randomly selected both containers from a list o f all containers previously assayed on the

MILCC. EPA selected Drum No. 93683 and CMB No. 5230 3 which were reassayed five times

and the results were compared to the original assay data. Two statistical tests, a chi-squared (χ 2 

# )

test and a t-test , were performed. Data and results of the statistic al analyses are included in

Attachments C.1 and C.2 of this report. The χ 2 

# test (also known as the goodness-of-fit test or th e

chi-squared test for independence) is used to show how observed data compare with what we

would expect to obtain according to a specific hypo thesis. It is applied in this instance to assess

the difference between the replicate and original m easurements. The t-test is used to tell if two

sets of data are statistically different. It is app lied in this instance to determine if there is a

statistically significant difference between the or iginal assay values and the average of the five

replicate measurements.

For Container Nos. 93683 and 52303, the χ 2 

# test showed that the observed variances in the

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

limits of the test. The t-test for Drum No. 93683 also showed no statistically si gnificant

differences between the original assay values and t he average of the five replicate measurements.

For CMB No. 52303, the t-test showed Highly Significant statistical differences between the

original assay values and the average of the five r eplicate measurements for 137 

# Cs and 90 

# Sr. Since

90 

# Sr is scaled to 137 

# Cs, any problem with 137 

# Cs measurement directly impacts 90 

# Sr quantification.

It is important to keep this in mind when evaluatin g replicate data and to realize that Significant

or Highly Significant

results are not always representative of true meas urement issues.

There are several possible reasons for the Highly Significant differences in 137 

# Cs replicate values

versus original values: actual changes in the physi cal configuration of the drum’s contents due to

movement or settling; fluctuations in the measureme nt system’s background; temporal factors

such as radioactive growth or decay; or, actual cha nges in the measurement system, the aspect

that these tests are designed to query. Although th e software identified these variances as Highly

Significant , this does not necessarily indicate a measurement issue that warrants additional

5 

# Revision 2 of the EPA Replicate Testing Protocol p rovides the details of the replicate testing assay

protocol and data evaluation.

# 14



# attention at this time. Further inspection found th at the average of the replicate measurements for

137 

# Cs and the original measurement differ by less than a microgram of 137 

# Cs. Although it may be

statistically significant, this degree of measureme nt uncertainly is built into the TMU modeling

and is not indicative of a problem with the instrum ent.

7.0 FINDINGS AND CONCERNS

There were no findings or concerns regarding the us e of the MILCC by LANL-CCP.

8.0 CONCLUSIONS

During this T1 evaluation, EPA evaluated the perfor mance of the LANL-CCP MILCC. EPA did

not identify any concerns or findings related to th e operation of the LANL-CCP MILCC. Based

on the results of this evaluation, EPA is approving the LANL-CCP MILCC NDA system for

assaying 55-gallon drums, CMBs using the bias-corre cted SWB calibration and SWBs. The

MILCC is not currently approved to assay SLB-2 cont ainers.

EPA determined that the MILCC is adequate for chara cterization of CH TRU waste in the

configuration observed during the evaluation. LANL may make changes to the MILCC followed

by performance testing to verify that the EPA-appro ved calibration is valid following the change,

(e.g., change components in a like-for-like replace ment, or relocate it to another area at LANL).

If the performance testing is successful and the EP A-approved calibration is verified, LANLCCP may continue to operate the MILCC and notify EP A regarding the change as a T2 change.

However, if the EPA-approved calibration cannot be verified, LANL-CCP must notify EPA and

the MILCC must be recalibrated and the new calibrat ion must be approved by EPA as a T1

change. LANL-CCP may not ship any containers charac terized on the modified MILCC until

EPA approves the new calibration as a T1 change.

EPA made minor modifications to the tiering table a s part of EPA’s ongoing efforts to harmonize

the language and format of the tiering tables for a ll CH TRU waste characterization programs

and added one new NDA T2 change (see Table 1).

# A-1 

# ATTACHMENT A

APPROVAL SUMMARY FOR LANL-CCP

CONTACT-HANDLED WASTE CHARACTERIZATION PROGRAM

Approved Activity EPA Inspection Number, Approval Dates Docket Number

LANL-CCP CH Baseline Approval LANL-CCP-05.06-8 — Ju ne 21, 2007 A-98-49, II-A4-88

T1 Change – Extension of range for the

High Efficiency Neutron Counter No. 2 October 28, 2007 A-98-49; II-A4-91

T1 Change – Extension of range for the

High Efficiency Neutron Counter No. 1 December 7, 2007 A-98-49, II-A4-95

T1 Change – Assay of lead-lined drums on

the High Efficiency Neutron Counter

No. 2 November 10, 2010 A-98-49, II-A4-139

T1 Change – Addition of the SuperHENC October 28, 2 011 A-98-49, II-A4-153

T1 Change – Calibration extension of High

Efficiency Neutron Counter No.1 and

SuperHENC August 14, 2012 A-98-49; II-A4-164

T1 Change – Addition of SCG S3000 December 31, 2012 A-98-49; II-A4-168B-1ATTACHMENT BMOBILE ISOCS LARGE CONTAINER COUNTER EVALUATION CHECKLISTTechnicalElementsObjective EvidenceAdditional CommentsGeneralConfirm the NDA system is theMILCC, its location and number.The instrument is located in the east end of Dome 283 in Area G at TA-54 atLANL. It is also referred to as the MCS/LANL “Box Counter” in somedocumentation.This was confirmed with NDA personnelduring evaluation. EPA inspectors visuallyconfirmed the instrument’s location.Describe the MILCC. The detectors are BEGe detectors, i.e., planar detectors that provide excellentresponse and energy resolution from 45 keV to 3 MeV. The detectors areidentified as Nos. 08004606 and 07048046, and wereISOCS characterized in2001 and 2006, respectively. The two MILCC detectors are placed equidistantfrom, on opposite sides, of the container to be assayed. Two distances arefixed for each container type, the selection of which is determined by the deadtime of the detector. The farther position, referred to as the “far-field”position, is positioned to accommodate the measurement of containers withhigh dead times. A 90° collimator is utilized on the gamma detector formeasurements taken in the far position.This was confirmed with NDA personnelduring evaluation.Identify the consensus standardsthat were used for the systemcalibration.LANL-CCP used consensus standards ASTM C-1030, C-1133, C-1207 andC-1500 for the MILCC calibration.This is stated in CI-MILCC-NDA-1006 andwas confirmed with NDA personnel duringevaluation.Identify the container and wastestypes assayed on the MILCC.The MILCC is capable of assaying debris, soils andgravel, and homogeneoussolid wastes in 55-gallon drums, CMBs and SWBs.The MILCC is limited by waste density anddead time. The MILCC is calibrated to assaywastes with densities of 0-250 g/cc. AllLANL TRU waste is expected to fall in thisrange.Identify the period ofperformance relevant to theMILCC and the number of BDRsand waste containers this systemassayed during the period.The MILCC is a new system with a limited performance history. LANL-CCPprovided a BDR containing three containers for eachof the three containertypes, MILCC BDR Nos. 4LANDA0001 (55-gallon drums),4LANDA0002(CMBs) and 4LANDA0003 (SWBs), which EPA Inspectorsreviewed.A total of nine containers were assayed, all atthe near-field position. The assay of SWB No.52316 resulted in an NCR because the EAwas unable to verify that the SWB met WIPPTRU criteria.B-2TechnicalElementsObjective EvidenceAdditional CommentsConfirm that the MILCC is ableto report quantitative values forthe WIPP-tracked radionuclides.Direct Measurements:238Pu,239Pu,241Am,233U,235U,238U,137Cs and237Np.Nuclides by Scaling:90Sr,234U and242Pu.Pu and other TRU isotopic ratios are determined using the MGA or FRAMsoftware, or AK.This was confirmed with NDA personnelduring evaluation.Confirm the MILCC’s calibrationof record.The calibration is documented in CI-MILCC-NDA-1006,Revision 0, theMILCC Calibration Report. Each detector factory characterization report wasprovided to EPA reviewers.This was confirmed with NDA personnelduring evaluation.Identify the procedures thatgovern this function and wherethe results of these calculationsare documented.CCP-TP-076, Operating Procedure (Revision 0, 5/2013)CCP-TP-077, Calibration Procedure (Revision 0, 5/2013)CCP-TP-103, Data Review Procedure (Revision 11, 5/2013)These were confirmed with NDA personnel.Copies of the current operating andcalibration procedures were available in thecontrol room to operators.Confirm the methods used toderive the isotopic contributionfor unmeasured radionuclides.241Am and Pu isotopics determined by MGA or FRAM software when enoughmass exists.This was confirmed with NDA personnelduring evaluation.Calibration Verification and ConfirmationConfirm the pedigree of allradionuclide standards that wereused for calibration confirmationand/or verifications. List orreference all standards used.Sources are summarized in Table 6.1 of CI-MILCC-NDA-1006, Revision 0,with source certificates in Attachment 1.EPA reviewed all source certificates found inCI-MILCC-NDA-1006, Revision 0,Attachment 1. All standards areindependently certified and acceptable to usefor the MILCC calibration.Confirm the MILCC operationalrange with respect to matrix(density) and activity.Acceptable density range for gamma is approximately0.0–2.50 g/cc; activityis limited by spectral parameters (peak shape and resolution) and system deadtime.This was confirmed with NDA personnelduring evaluation.Identify the date of the lastcalibration verification. Have anyothers been completed in the lastyear?5/7/2013. On 5/6/2013, Detector #01 failed to acquire spectrum and the“Rate” indicator light was lit. Troubleshooting steps were ineffective. Thedetector was powered down and was operational the next day. Attempts toreplicate error were unsuccessful.The cause of this error is unclear; however,LANL-CCP took appropriate actions to verifythat the MILCC was functioning properly.EPA personnel reviewed the logbook pageentry on 5/6/2013, and found that the errorwas documented. EPA reviewers identified aconflicting entry in the logbook. The operatorthat recorded the entry clarified the entry andcorrected the entry in the logbook. EPAreceived a copy of the corrected logbookpage.B-3TechnicalElementsObjective EvidenceAdditional CommentsRequirements for accuracy andprecision must be met, asspecified in DOE/WIPP-02-3122,Appendix A, Table A-2 forcalibration verifications.The Calibration Verification results are containedin section 6.0 of MILCCCalibration Report, %R was found to be between 70-130 % and % RSD wasfound to be less than 14%.NALLDConfirm that the LLD for theMILCC has been determined.Typical MDAs are found by performing three replicate assays on eachcontainer type and detector position with matrix containers withoutradioactive sources. MDAs are then averaged and converted to MDCs usingmatrix weight. The MDAs documented in section 8 ofCI-MILCC-NDA1006, Revision 0, indicate that the instrument meets the TRU discriminationcriterion of 100 nCi/g with the exception of241Am in a metals SWB in farfield geometry. This is only an example of a typical assay.MDAs are variable and depend onmeasurement conditions such as backgroundrate and matrix type. LANL-CCP providedexample MDAs and MDCs for a metals SWBand a 55-gallon drum in both near- and farfield positions.Confirm if the MILCC is used todiscriminate TRU/Non-TRUwastes at the 100 nCi/g criterionand that it has the requiredsensitivity.See previous entry.This was confirmed with NDA personnelduring the EPA evaluation.Identify any/all instances wherean LLD value for anon-measuredradionuclide is not providedbased on a lack of technicalfeasibility.Because an LLD is a measurement-based parameter, itis not technicallyfeasible to calculate for radionuclides that are not directly measured.242Pu isderived from the measured mass of239Pu times an appropriate scaling factorcomputed from measured or declared mass fractions.LANL-CCP states the234U scaling factor 0.014 is used for wastes containing235U, and the scalingfactor 0.427 is used for wastes containing primarily238Pu. Since MDAs for235U and238Pu vary according to measurement conditions, the reportingthresholds for234U will also vary.90Sr activity is assumed equal to137Csactivity in wastes containing fission products. Typical gamma reportingthresholds for these nuclides are shown in CI-MILCC-NDA-1006, Revision0, Tables 8e through 8h.This is confirmed in section 8 of CI-MILCCNDA-1006, Revision 0, and was discussedwith NDA personnel. All reporting thresholdswere determined to be within acceptablelimits.Quality ControlAll Operators have current CCPtraining as verified on LOQI.A June 3, 2013, LOQI was provided to EPA reviewers. Five operators werelisted on the LOQI, all with current training requirements met.EPA confirmed the qualifications of eachoperator on their respective qualificationcards.B-4TechnicalElementsObjective EvidenceAdditional CommentsConfirm the MILCC’s status withrespect to the CBFO NDA PDPand last cycle.The MILCC was in the process of participating in the PDP Drum Cycle 20Aand Supplemental Box Cycle B13C during the EPA evaluation. The items tobe assayed included 4 drums and 2 SWBs.The results letter has not yet been issued.LANL-CCP agreed to provide EPA with acopy of the approval letter, when issued, as acourtesy.All MILCC data must bereviewed and approved byqualified personnel. Identify thename and function of theindividuals performing technicalreview and approval of MILCCBDRs.Data review in the BDR obtained by EPA was performed by:Tim Burton, ITR.Israel Francis, ITR.Ryan Hammon, ITR.Jared Francis, EA.Qualification Cards were reviewed by EPAinspectors for all personnel listed.Identify any NCRs within thelast year.There was one NCR (NCR-LANL-0054-13) that resultedin an indeterminateassay of SWB 52316. This was sufficiently documented.This was discussed with NDA personnelduring the evaluation. They intend to assaythe SWB at the far-field position. If asufficient assay cannot be obtained using a30-minute count time, LANL-CCP mayconsider a longer assay.TMUEvaluate the magnitude of theTMU values observed in theMILCC BDRs that wereexamined during this evaluation.The TMU for the MILCC is documented in “Total Measurement Uncertaintyfor the MCS/LANL ISOCS ‘Box Counter’,” Revision 2,March 27, 2013. Thecomponents of uncertainty included in the TMU determination consist ofcalibration source uncertainties, ISOCS Model uncertainties, detectorpositioning, matrix in homogeneity, non-uniform source distribution, fillheight uncertainty, self-attenuation of SNM “lumps”, counting statistics,background fluctuations, radionuclide interferencesand isotopic measurementuncertainty. The ISOCS Uncertainty estimator is used to calculate TMU. Thisis a companion program to the MILCC system.EPA evaluated the 3 BDRs provided. TMUwas within the expected range in all instances.Background and Performance ChecksConfirm that MILCC backgroundmeasurements have been takendaily.Background measurements are required in CCP-TP-076,Operating Procedure(Revision 0, 5/2013). Evidence of daily backgroundmeasurements was seenin the logbook pages reviewed.EPA reviewed the logbook entries from May30–31, 2013, and June 5, 2013. All entriesshowed that background measurements weremade and acceptable.B-5TechnicalElementsObjective EvidenceAdditional CommentsAssess how often backgroundradiation was problematic to theextent that measurementpersonnel had to makeadjustments.This was originally a problem when the MILCC was first assembled. Wastesstored in Dome 283 were removed. This reduced background to acceptablelevels. Background has not been a problem since these wastes were relocated.This was discussed with NDA personnelduring the evaluation.Confirm that system performancechecks have been performed atleast once per operational day.Confirm that performance checksinclude gamma matrix correctionchecks, and gamma peak positionand resolution checks.Performance measurements are required in CCP-TP-076, OperatingProcedure (Revision 0, 5/2013). Evidence of daily performance checks wasseen in the logbook pages reviewed.EPA reviewed the logbook entries from May30–31, 2013, and June 5, 2013. All entriesshowed that performance checkmeasurements were made and acceptable.MILCC BDRs contain•Testing facility name, testingbatch number, containernumbers, and signature of theSPM or designee.•Table of Contents.•Background and performancecheck data or control chartsfor the relevant time period.•Separate testing report sheetsfor each container.EPA reviewed MILCC BDR Nos. 4LANDA0001 (55-gallon drums),4LANDA0002 (CMBs) and 4LANDA0003 (SWBs). The BDRs contained allrequired information.NAMILCC RDSs must include:•Title “Radioassay DataSheet.”•Method/procedure used.•Date of radioassay.•Activities and associatedTMU for individualradionuclides.•TRU alpha concentration andits associated TMU.•Operator and reviewersignatures.EPA reviewed MILCC BDR Nos. 4LANDA0001 (55-gallon drums),4LANDA0002 (CMBs) and 4LANDA0003 (SWBs). The RDSs contained allrequired information.NAC.1-1ATTACHMENT C.1. MILCC REPLICATE TESTING RESULTS FORCONTAINER No. 93683 (55-GALLON DRUM)Instrument: MILCCDrum: 93683Quantity of InterestOriginal Measurement Replicate #1 Replicate #2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci)2.64E-059.65E-063.65E-012.69E-059.72E-063.61E-012.66E-059.66E-063.63E-01238U Activity (Ci)N/AN/AN/A238Pu Activity (Ci)3.11E-021.17E-023.75E-013.25E-021.20E-023.70E-013.66E-021.34E-023.66E-01239Pu Activity (Ci)9.85E-013.49E-013.54E-019.89E-013.52E-013.56E-019.50E-013.38E-013.56E-01240Pu Activity (Ci)2.35E-018.33E-023.54E-012.34E-018.33E-023.56E-012.21E-017.87E-023.56E-01242Pu Activity (Ci)2.32E-058.55E-063.68E-012.39E-058.82E-063.69E-012.21E-058.17E-063.70E-01241Am Activity (Ci)3.17E-011.20E-013.77E-013.42E-011.29E-013.77E-013.10E-011.17E-013.77E-0190Sr Activity (Ci)N/AN/AN/A137Cs Activity (Ci)N/AN/AN/ATRU Alpha Conc. (nCi/g)8.90E+032.15E+032.42E-019.07E+032.18E+032.40E-018.62E+032.08E+032.41E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci)3.13E-051.12E-053.58E-012.87E-051.04E-053.61E-012.14E-058.23E-063.84E-01238U Activity (Ci)N/AN/AN/A238Pu Activity (Ci)3.73E-021.37E-023.66E-014.35E-021.58E-023.64E-013.94E-021.44E-023.65E-01239Pu Activity (Ci)9.80E-013.49E-013.56E-019.98E-013.56E-013.57E-019.75E-013.48E-013.57E-01240Pu Activity (Ci)2.47E-018.79E-023.56E-012.31E-018.26E-023.58E-012.23E-017.97E-023.58E-01242Pu Activity (Ci)2.54E-059.38E-063.69E-012.37E-058.77E-063.70E-012.20E-058.13E-063.69E-01241Am Activity (Ci)3.16E-011.19E-013.77E-013.41E-011.29E-013.77E-013.08E-011.16E-013.77E-0190Sr Activity (Ci)N/AN/AN/A137Cs Activity (Ci)N/AN/AN/ATRU Alpha Conc. (nCi/g)8.98E+032.16E+032.41E-019.17E+032.20E+032.40E-018.79E+032.13E+032.42E-01C.1-2Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|c2|)ReportedValueAbsoluteUncertainty233U Activity (Ci)0.00E+00 N/AN/A N/A N/AN/A N/A234U Activity (Ci)2.64E-05 9.65E-062.70E-05 3.64E-06 1.35E-015.69E-01 9.66E-01238U Activity (Ci)0.00E+00 N/AN/A N/A N/AN/A N/A238Pu Activity (Ci)3.11E-02 1.17E-023.79E-02 4.03E-03 1.06E-014.77E-01 9.76E-01239Pu Activity (Ci)9.85E-01 3.49E-019.78E-01 1.81E-02 1.85E-021.08E-02 1.00E+00240Pu Activity (Ci)2.35E-01 8.33E-022.31E-01 1.04E-02 4.48E-026.18E-02 1.00E+00242Pu Activity (Ci)2.32E-05 8.55E-062.34E-05 1.41E-06 6.03E-021.09E-01 9.99E-01241Am Activity (Ci)3.17E-01 1.20E-013.23E-01 1.68E-02 5.19E-027.89E-02 9.99E-0190Sr Activity (Ci)0.00E+00 N/AN/A N/A N/AN/A N/A137Cs Activity (Ci)0.00E+00 N/AN/A N/A N/AN/A N/ATRU Alpha Conc. (nCi/g)8.90E+03 2.15E+038.93E+03 2.21E+02 2.48E-024.21E-02 1.00E+00Quantity of Interest t Pr(x<|t|)χ2Testt Test233U Activity (Ci)N/A N/ANot Applicable Not Applicable234U Activity (Ci)-1.46E-01 8.91E-01Not SignificantNot Significant238U Activity (Ci)N/A N/ANot ApplicableNot Applicable238Pu Activity (Ci)-1.53E+00 2.00E-01Not SignificantNot Significant239Pu Activity (Ci)3.32E-01 7.57E-01Not Significant Not Significant240Pu Activity (Ci)3.35E-01 7.54E-01Not Significant Not Significant242Pu Activity (Ci)-1.42E-01 8.94E-01Not Significant Not Significant241Am Activity (Ci)-3.48E-01 7.45E-01Not Significant Not Significant90Sr Activity (Ci)N/A N/ANot ApplicableNot Applicable137Cs Activity (Ci)N/A N/ANot ApplicableNot ApplicableTRU Alpha Conc. (nCi/g)-1.07E-01 9.20E-01Not Significant Not SignificantC.2-1ATTACHMENT C.2. MILCC REPLICATE TESTING RESULTS FORCONTAINER No. 52303 (CMB)Instrument: MILCCCMB: 52303Quantity of InterestOriginal Measurement Replicate #1 Replicate #2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci)2.15E-041.47E-046.84E-012.13E-041.46E-046.84E-012.24E-041.53E-046.84E-01238U Activity (Ci)N/AN/AN/A238Pu Activity (Ci)1.38E+009.44E-016.84E-011.37E+009.36E-016.83E-011.44E+009.81E-016.81E-01239Pu Activity (Ci)1.17E-038.19E-047.00E-011.16E-038.12E-047.00E-011.22E-038.51E-046.98E-01240Pu Activity (Ci)5.82E-044.07E-047.00E-015.77E-044.03E-046.98E-016.06E-044.23E-046.98E-01242Pu Activity (Ci)5.83E-074.07E-076.98E-015.78E-074.04E-076.99E-016.07E-074.23E-076.97E-01241Am Activity (Ci)3.71E-022.60E-027.00E-014.16E-022.83E-026.80E-013.48E-022.47E-027.10E-0190Sr Activity (Ci)3.85E-062.50E-066.49E-015.66E-073.71E-076.55E-015.19E-073.42E-076.59E-01137Cs Activity (Ci)3.85E-062.50E-066.49E-015.66E-073.71E-076.55E-015.19E-073.42E-076.59E-01TRU Alpha Conc. (nCi/g)1.42E+039.46E+026.66E-011.41E+039.38E+026.65E-011.48E+039.83E+026.64E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci)2.03E-041.39E-046.84E-012.10E-041.43E-046.83E-012.15E-041.47E-046.83E-01238U Activity (Ci)N/AN/AN/A238Pu Activity (Ci)1.30E+008.90E-016.85E-011.35E+009.19E-016.81E-011.38E+009.41E-016.82E-01239Pu Activity (Ci)1.11E-037.72E-046.96E-011.14E-037.98E-047.00E-011.17E-038.17E-046.98E-01240Pu Activity (Ci)5.50E-043.84E-046.98E-015.68E-043.96E-046.98E-015.82E-044.06E-046.98E-01242Pu Activity (Ci)5.51E-073.84E-076.97E-015.69E-073.97E-076.97E-015.82E-074.06E-076.97E-01241Am Activity (Ci)3.66E-022.53E-026.90E-014.02E-022.77E-026.90E-014.54E-022.95E-026.50E-0190Sr Activity (Ci)3.97E-072.63E-076.62E-014.07E-072.70E-076.63E-014.21E-072.76E-076.55E-01137Cs Activity (Ci)3.97E-072.63E-076.62E-014.07E-072.70E-076.63E-014.21E-072.76E-076.55E-01TRU Alpha Conc. (nCi/g)1.34E+038.90E+026.64E-011.39E+039.22E+026.63E-011.43E+039.44E+026.60E-01C.2-2Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|c2|)ReportedValueAbsoluteUncertainty233U Activity (Ci)0.00E+00 N/AN/A N/A N/AN/A N/A234U Activity (Ci)2.15E-04 1.47E-042.13E-04 7.65E-06 3.59E-021.08E-02 1.00E+00238U Activity (Ci)0.00E+00 N/AN/A N/A N/AN/A N/A238Pu Activity (Ci)1.38E+00 9.44E-011.37E+00 5.07E-02 3.71E-021.15E-02 1.00E+00239Pu Activity (Ci)1.17E-03 8.19E-041.16E-03 4.06E-05 3.50E-029.84E-03 1.00E+00240Pu Activity (Ci)5.82E-04 4.07E-045.77E-04 2.05E-05 3.55E-021.01E-02 1.00E+00242Pu Activity (Ci)5.83E-07 4.07E-075.77E-07 2.04E-08 3.53E-021.01E-02 1.00E+00241Am Activity (Ci)3.71E-02 2.60E-023.97E-02 4.18E-03 1.05E-011.04E-01 9.99E-0190Sr Activity (Ci)3.85E-06 2.50E-064.62E-07 7.58E-08 1.64E-013.68E-03 1.00E+00137Cs Activity (Ci)3.85E-06 2.50E-064.62E-07 7.58E-08 1.64E-013.68E-03 1.00E+00TRU Alpha Conc. (nCi/g)1.42E+03 9.46E+021.41E+03 5.15E+01 3.65E-021.19E-02 1.00E+00Quantity of Interest t Pr(x<|t|)χ2Testt Test233U Activity (Ci)N/A N/ANot Applicable Not Applicable234U Activity (Ci)2.39E-01 8.23E-01Not SignificantNot Significant238U Activity (Ci)N/A N/ANot ApplicableNot Applicable238Pu Activity (Ci)2.16E-01 8.39E-01Not Significant Not Significant239Pu Activity (Ci)2.25E-01 8.33E-01Not Significant Not Significant240Pu Activity (Ci)2.41E-01 8.21E-01Not Significant Not Significant242Pu Activity (Ci)2.51E-01 8.15E-01Not Significant Not Significant241Am Activity (Ci)-5.72E-01 5.98E-01Not Significant Not Significant90Sr Activity (Ci)N/A N/ANot ApplicableNot Applicable137Cs Activity (Ci)N/A N/ANot ApplicableNot ApplicableTRU Alpha Conc. (nCi/g)-1.07E-01 9.20E-01Not Significant Not Significant