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

WASTE CHARACTERIZATION REPORT 

TIER 1 CHANGE EVALUATION: 

ADDITION OF THE MOBILE ISOCS LARGE CONTAINER COUNTER 

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 Confirmation ........................................... 8

6.6 Operating Range ................................................................................................... 11

6.7 Lower Limit of Detection Determination ............................................................. 11

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 Waste 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 Contact-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 Multiple 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 Protection Agency’s (EPA’s) approval of a Tier 1 

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

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

characterization program at Los Alamos National Laboratory (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 characterization program (see EPA 

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

characterization program are listed in Attachment A. 

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

add the MILCC as a new nondestructive assay (NDA) system 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 metal boxes (CMBs)1. 

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

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

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

characterization 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 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) change. However, if the EPA-approved 

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

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

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

calibration as a T1 change. 

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

the language and format of the tiering tables for all 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 personnel plan to use the MILCC to assay the CMBs and

pack them inside ten-drum overpacks (TDOPs) for shipment, as discussed in section 6.4.2 of this report. 
2 

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

(Based on May 23–25, 2006, Baseline Inspection and Subsequent T1 Evaluations, Updated Ju

Process Elements LANL-CCP Waste Characterization Process – T1 Changes LANL-CCP Waste Characterization 

Acceptable Knowledge, including Load Management 

Any new waste category, as well as any new OSRP waste streams addressed in AKSRs separate from CCP-AK-008 or new 

OSRP waste streams beyond LA-OS-00-01.001, LA-OS-00-03, and LA-OS-00-04 added to CCP-AK-008 Load management for waste streams other than as documented in CCP-AK-009 

Notification to EPA upon completion of or substa

• AK-NDA memoranda • AK accuracy reports (annually, at a minimum• AK reassessment memoranda and combination 

distinct at the time of the baseline inspection 

• Any new or updated WSPFs, including all ass

summation of aspects) and any change notices WSPFs, including additions to waste streams w

• AKSRs (new and updated versions), including 

• CCP-TP-005, Attachment 6, and associated m

• Site procedures requiring CBFO approval 

Nondestructive Assay New equipment or substantive physical modifications** to 

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

Notification to EPA upon: 

• Substantive modification** to software for ap

• Substantive modification** to operating range

• Substantive modification** to site procedures 

• Any change to the MILCC that does not di

calibration, including relocation of the syst

Real-Time Radiography None Notification to EPA upon: 

• New equipment or substantive physical modif

• Substantive modification** to site procedures 

Visual Examination and Visual Examination Technique 

None Notification to EPA upon substantive modificatio

CBFO approval, including OSRP visual examinat

WIPP Waste Data System 

None Notification to EPA upon substantive modificatio

• Site procedures requiring CBFO approval 

• Excel spreadsheet, Waste Data System data en

and certification requiring CBFO approval

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

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

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

administrative concerns. EPA may request copies of new references that DOE adds during a document revision. † LANL-CCP will report relocation of any NDA system to EPA immediately.
3

2.0 PURPOSE OF TIER 1 EVALUATIONS 

Any changes to the waste characterization activities 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 the 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 baseline 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 adequately characterize TRU wastes and comply with 

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

inspection team conducts an onsite inspection to verify 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 approve, if necessary, changes to the site’s 

approved waste characterization program by conducting additional inspections under the 

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

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

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

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

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

specified which subsequent waste characterization program 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-CCP characterization program. T1 activities 

have more stringent reporting requirements and require that DOE notify EPA and that EPA 

provide approval prior to implementation. Attachment 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 Federal 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 evaluation 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 the decision on its website at 

www.epa.gov/radiation/wipp, in accordance with 40 CFR 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 drums, 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 technical processes implemented by LANLCCP for the MILCC. EPA evaluated personnel qualifications and training, operating procedures, 

the physical configuration of the measurement system 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 evaluation, 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 used 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 procedures. 

• Knowledge and understanding of the personnel involved 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 technical elements of the MILCC system that 

are detailed in the checklist in Attachment B and are 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, creating a makeshift “box counter.” 

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

plutonium-238 (238Pu), 239Pu, 240Pu, americium-241 (241Am), uranium-233 (233U), 235U, 238U, 

cesium-137 (137Cs), neptunium-237 (237Np) 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 variations in matrix density. The MILCC is 

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

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

MILCC are as follows: 

• 55-gallon drum near position with 180o collimator (detectors 42 in. from drum) 

• 55-gallon drum far position with 90o collimator (detectors 72 in. from drum) 

• SWB near position with 180o collimator (detectors 42 in. from SWB) 

• SWB far position with 90o

 collimator (detectors 144 in. from SWB) 

• CMB near position with 180o collimator (detectors 42 in. from CMB) 

• CMB far position with 90o collimator (detectors 144 in. from CMB) 

All stated detector-to-container distances are approximate, 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 intend to use the system only in its 

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

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

relocated and successfully completes calibration verification, 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-CCP will request this as a T1 change. 

6.2 Documents Reviewed 

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

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

Revision 0, April 4, 2013. 
6

• Canberra Factory Document, “Total Measurement Uncertainty Report for MCS/LANL 

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

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

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

• MILCC BDR Nos. 4LANDA0001 (55-gallon drums), 4LANDA0002 (CMBs) and 

4LANDA0003 (SWBs). 

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

• LANL MILCC NDA Qualification Cards for Jared Francis, 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-005, Revision 2. 

• CCP-TP-076, CCP Operating the Mobile ISOCS Large Container 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 Reporting Procedure for the NDA 

Counters at LANL Using NDA 2000, Revision 11, May 16, 2013. 

6.3 Evaluation Checklist 

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

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

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

6.4 Measurement Geometries 

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

CMBs at fixed far and near distances only, as discussed 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 near- (approximately 42 in. from detector 

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

positions. The placement of the detectors is illustrated 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 operators 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 prior to assay using a tape measure or a laser 

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

with the detector face to ensure the detector is lined 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 initially be assayed for 30 minutes at the nearfield position. If an acceptable assay cannot be obtained 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 in near- (42 in.) and far- (144 in.) field 

positions. The placement of the detectors is illustrated 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 operators regarding approximate locations of 

detectors and the waste container. The forklift operator 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. All 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 held in line with the detector face and pointed at 

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

with the midline of the detector. The detector height on the cart is fixed at 26.7 in. and is subject 

55-

gallon

drum 

Near-Field Position 

Near-Field Position 

Far-Field Position 

42 in. 

Far-Field Position 

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 pallet) 3.6 in. above ground and with the center 

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

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

LANL-CCP indicated that SWBs and CMBs would initially 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 position 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 TDOP for shipping and eventual placement 

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

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

the CMB. 

6.5 Calibration, Calibration Validation and Confirmation 

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 contain 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 geometries: near- and far-field calibrations for 

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

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

performing the typical calibration measurements using 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 

CMB 

Far-Field Position 

42 in. 

Far-Field Position 

144 in. 144 in. 

42 in. 

Near-Field Position

Near-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 gamma energy range for the radionuclides of 

interest. Based on this assessment, LANL-CCP determined 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 documentation 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 bias 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 population 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 energy calibrations for both detectors were 

performed. The spectral gain was set at approximately 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 for the two gamma spectrometers via the use of 

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

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

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

6.5.3 Efficiency Calibration/Detector Characterization 

The MILCC uses two ISOCS model BE5030 planar BEGe detectors, 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 the multi-curve efficiency calibrations. 

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

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

evaluated the technical aspects of this process through technical discussions with Canberra 

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

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

characterizing gamma detectors for assaying WIPP-bound 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 relationship of the detector to the point-efficiency data and 

the validation of the resulting characterization file is generated, and this file is then used by the 
10

ISOCS user interface software. EPA reviewed both Canberra detector characterization reports 

and found them to adequately document the characterization 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 Canberra in Meriden, CT, in October 2001 and 

was subsequently returned to Canberra for repair, following 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 servicing the germanium crystal was removed, 

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

not require calibration verification; therefore, the 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 characterization 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 calibration verification; therefore, the detector 

characterization date on the detector did not change. 

Upon receipt of each detector from Canberra, LANL-CCP 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 the 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 each 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 and 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 documented in Tables 6a–6c of the Calibration 

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

the limits in DOE/WIPP-02-31223

, Appendix A, Table A-2, and EPA determined that the 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), 17.07 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 detectors are described as “ISOCS-characterized detectors.” 

3

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

DOE/WIPP-02-3122, Revision 7.4, Carlsbad, New Mexico, April 22, 2013. 
11

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

declared or certificate isotopics are used. The gamma 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 density, 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 density 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 operating 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 discrimination must have a minimum detectable 

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

Minimum detectable activities (MDAs) are variable and 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 near- and far-field positions, with no 

radioactive sources in order to establish an MDA typical 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 Tables 8a-8d of the Calibration Report. All 

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

assay with the exception of 241Am in the far-field detector. This was discussed with LANL-CCP 

NDA personnel who stated that this is unlikely to be 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, LANL-CCP personnel stated that it is not 

technically feasible to calculate for radionuclides that are not directly measured, i.e., 242Pu, 234U 

and strontium-90 (90Sr). Typical gamma reporting thresholds for selected radionuclides in each 

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

tables and found all reporting thresholds to be acceptable. 

6.8 Total Measurement Uncertainty 

Total measurement uncertainty (TMU) for the MILCC is 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 Uncertainty Estimator (IUE), a software tool 

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

primary components of uncertainty include calibration source uncertainties, ISOCS model 

uncertainties, detector positioning, matrix in homogeneity, non-uniform source distribution, fillheight uncertainty, self-attenuation of special nuclear material (SNM) “lumps”, counting 
12

statistics, background fluctuations, radionuclide interferences and isotopic measurement 

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

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

added in quadrature to derive the TMU, as documented 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 three BDRs. EPA verified that each BDR 

included the following: 

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

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

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

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

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

Attachment 4. 

• Assay Report for each container listed on Attachment 1. 

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

• Automated ITR for each container listed on Attachment 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 listed on Attachment 1. 

• Correct revisions of CCP-TP-0014 and CCP-TP-103. 

The MILCC reports direct quantitative values and uncertainties for 238Pu, 239Pu, 241Am, 233U, 

235U, 238U, 137Cs, and 237Np. The nuclides 90Sr, 234U, and 242Pu are obtained through scaling 

factors. LANL-CCP states the 234U scaling factor 0.014 is used for wastes containing 235U, and 

the scaling factor 0.427 is used for wastes containing primarily 238Pu. 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 TRU radionuclides at concentrations greater 

than 100 nCi/g. There were no concerns regarding the 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 determination of the 10 WIPP-tracked radionuclides 

(

241Am,137Cs,238Pu,239Pu,240Pu,242Pu,90Sr, 233U, 234U and 238U) and the TRU alpha concentration.5

This is accomplished by the MILCC reassaying containers 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 taken 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 values. 

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 of all containers previously assayed on the 

MILCC. EPA selected Drum No. 93683 and CMB No. 52303 which were reassayed five times 

and the results were compared to the original assay data. Two statistical tests, a chi-squared (χ2) 

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

Attachments C.1 and C.2 of this report. The χ2

 test (also known as the goodness-of-fit test or the 

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

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

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

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

statistically significant difference between the original assay values and the average of the five 

replicate measurements. 

For Container Nos. 93683 and 52303, the χ2 test showed that the observed variances in the 

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

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

differences between the original assay values and the 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 replicate measurements for 137Cs and 90Sr. Since 

90Sr is scaled to 137Cs, any problem with 137Cs measurement directly impacts 90Sr quantification. 

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

or Highly Significant results are not always representative of true measurement issues. 

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

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

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

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

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

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

 

5

 Revision 2 of the EPA Replicate Testing Protocol provides the details of the replicate testing assay 

protocol and data evaluation. 
14

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

137Cs and the original measurement differ by less than a microgram of 137Cs. Although it may be 

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

and is not indicative of a problem with the instrument. 

7.0 FINDINGS AND CONCERNS 

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

8.0 CONCLUSIONS 

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

not identify any concerns or findings related to the 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-corrected SWB calibration and SWBs. The 

MILCC is not currently approved to assay SLB-2 containers. 

EPA determined that the MILCC is adequate for characterization 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-approved 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, LANLCCP may continue to operate the MILCC and notify EPA 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 calibration must be approved by EPA as a T1 

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

EPA approves the new calibration as a T1 change. 

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

the language and format of the tiering tables for all 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 — June 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, 2011 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-A4-168 
B-1 

ATTACHMENT B 

MOBILE ISOCS LARGE CONTAINER COUNTER EVALUATION CHECKLIST 

Technical Elements Objective Evidence Additio

General Confirm the NDA system is the MILCC, its location and number. 

The instrument is located in the east end of Dome 283 in Area G at TA-54 at LANL. It is also referred to as the MCS/LANL “Box Counter” in some documentation. 

This was confirmed during evaluation. Econfirmed the instru

Describe the MILCC. The detectors are BEGe detectors, i.e., planar detectors that provide excellent 

response and energy resolution from 45 keV to 3 MeV. The detectors are 

identified as Nos. 08004606 and 07048046, and were ISOCS characterized in 

2001 and 2006, respectively. The two MILCC detectors are placed equidistant 

from, on opposite sides, of the container to be assayed. Two distances are fixed for each container type, the selection of which is determined by the dead 

time of the detector. The farther position, referred to as the “far-field” 

position, is positioned to accommodate the measurement of containers with 

high dead times. A 90° collimator is utilized on the gamma detector for measurements taken in the far position. 

This was confirmed during evaluation. 

Identify the consensus standards that were used for the system calibration. 

LANL-CCP used consensus standards ASTM C-1030, C-1133, C-1207 and 

C-1500 for the MILCC calibration. 

 This is stated in CIwas confirmed with evaluation. 

Identify the container and wastes types assayed on the MILCC. 

The MILCC is capable of assaying debris, soils and gravel, and homogeneous solid wastes in 55-gallon drums, CMBs and SWBs. 

The MILCC is limitdead time. The MILwastes with densitieLANL TRU waste irange. 

Identify the period of performance relevant to the MILCC and the number of BDRs and waste containers this system assayed during the period. 

The MILCC is a new system with a limited performance history. LANL-CCP 

provided a BDR containing three containers for each of the three container 

types, MILCC BDR Nos. 4LANDA0001 (55-gallon drums), 4LANDA0002 (CMBs) and 4LANDA0003 (SWBs), which EPA Inspectors reviewed. 

A total of nine contthe near-field positi52316 resulted in an was unable to verify TRU criteria. 
B-2 

Technical Elements Objective Evidence Additio

Confirm that the MILCC is able to report quantitative values for the WIPP-tracked radionuclides. 

Direct Measurements: 238Pu, 239Pu, 241Am, 233U, 235U, 238U, 137Cs and 237Np. 

Nuclides by Scaling: 90Sr, 234U and 242Pu. 

Pu and other TRU isotopic ratios are determined using the MGA or FRAM software, or AK. 

This was confirmed during evaluation. 

Confirm the MILCC’s calibration of record. 

The calibration is documented in CI-MILCC-NDA-1006, Revision 0, the 

MILCC Calibration Report. Each detector factory characterization report was 

provided to EPA reviewers. 

This was confirmed during evaluation. 

Identify the procedures that govern this function and where the results of these calculations are 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 confirmCopies of the currencalibration procedurcontrol room to ope

Confirm the methods used to derive the isotopic contribution for unmeasured radionuclides. 

241Am and Pu isotopics determined by MGA or FRAM software when enough 

mass exists. 

This was confirmed during evaluation. 

Calibration Verification and ConfirmationConfirm the pedigree of all radionuclide standards that were used for calibration confirmation and/or verifications. List or reference all standards used. 

Sources are summarized in Table 6.1 of CI-MILCC-NDA-1006, Revision 0, with source certificates in Attachment 1. 

EPA reviewed all soCI-MILCC-NDA-1Attachment 1. All sindependently certiffor the MILCC calib

Confirm the MILCC operational range with respect to matrix (density) and activity. 

Acceptable density range for gamma is approximately 0.0–2.50 g/cc; activity 

is limited by spectral parameters (peak shape and resolution) and system dead 

time. 

This was confirmed during evaluation. 

Identify the date of the last calibration verification. Have any others been completed in the last year? 

5/7/2013. On 5/6/2013, Detector #01 failed to acquire spectrum and the 

“Rate” indicator light was lit. Troubleshooting steps were ineffective. The 

detector was powered down and was operational the next day. Attempts to 

replicate error were unsuccessful. 

The cause of this erLANL-CCP took apthat the MILCC waEPA personnel revientry on 5/6/2013, awas documented. Econflicting entry in that recorded the encorrected the entry ireceived a copy of t

page. 
B-3 

Technical Elements Objective Evidence Additio

Requirements for accuracy and 

precision must be met, as 

specified in DOE/WIPP-02-3122, Appendix A, Table A-2 for calibration verifications. 

The Calibration Verification results are contained in section 6.0 of MILCC 

Calibration Report, %R was found to be between 70-130 % and % RSD was found to be less than 14%. 

NA 

LLD Confirm that the LLD for the MILCC has been determined. 

Typical MDAs are found by performing three replicate assays on each 

container type and detector position with matrix containers without radioactive sources. MDAs are then averaged and converted to MDCs using matrix weight. The MDAs documented in section 8 of CI-MILCC-NDA1006, Revision 0, indicate that the instrument meets the TRU discrimination 

criterion of 100 nCi/g with the exception of 241Am in a metals SWB in farfield geometry. This is only an example of a typical assay. 

MDAs are variable measurement conditrate and matrix typeexample MDAs and and a 55-gallon drufield positions. 

Confirm if the MILCC is used to discriminate TRU/Non-TRU wastes at the 100 nCi/g criterion and that it has the required sensitivity. 

See previous entry. This was confirmed 

during the EPA eva

Identify any/all instances where an LLD value for a non-measured radionuclide is not provided 

based on a lack of technical 

feasibility. 

Because an LLD is a measurement-based parameter, it is not technically 

feasible to calculate for radionuclides that are not directly measured. 242Pu is 

derived from the measured mass of 239Pu times an appropriate scaling factor 

computed from measured or declared mass fractions. LANL-CCP states the 

234U scaling factor 0.014 is used for wastes containing 235U, and the scaling 

factor 0.427 is used for wastes containing primarily 238Pu. Since MDAs for 

235U and 238Pu vary according to measurement conditions, the reporting 

thresholds for 234U will also vary. 90Sr activity is assumed equal to 137Cs 

activity in wastes containing fission products. Typical gamma reporting thresholds for these nuclides are shown in CI-MILCC-NDA-1006, Revision 0, Tables 8e through 8h. 

This is confirmed in 

NDA-1006, Revisio

with NDA personnewere determined to limits. 

Quality Control All Operators have current CCP training as verified on LOQI. 

 A June 3, 2013, LOQI was provided to EPA reviewers. Five operators were listed on the LOQI, all with current training requirements met. 

EPA confirmed the operator on their rescards. 
B-4 

Technical Elements Objective Evidence Additio

Confirm the MILCC’s status with respect to the CBFO NDA PDP and last cycle. 

The MILCC was in the process of participating in the PDP Drum Cycle 20A 

and Supplemental Box Cycle B13C during the EPA evaluation. The items to 

be assayed included 4 drums and 2 SWBs. 

The results letter haLANL-CCP agreed copy of the approvacourtesy. 

All MILCC data must be reviewed and approved by qualified personnel. Identify the name and function of the individuals performing technical review and approval of MILCC BDRs. 

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 inspectors for all pe

Identify any NCRs within the last year. 

There was one NCR (NCR-LANL-0054-13) that resulted in an indeterminate 

assay of SWB 52316. This was sufficiently documented. 

This was discussed during the evaluatiothe SWB at the far-sufficient assay can30-minute count timconsider a longer as

TMU Evaluate the magnitude of the TMU values observed in the MILCC BDRs that were examined during this evaluation. 

The TMU for the MILCC is documented in “Total Measurement Uncertainty 

for the MCS/LANL ISOCS ‘Box Counter’,” Revision 2, March 27, 2013. The 

components of uncertainty included in the TMU determination consist of 

calibration source uncertainties, ISOCS Model uncertainties, detector 

positioning, matrix in homogeneity, non-uniform source distribution, fillheight uncertainty, self-attenuation of SNM “lumps”, counting statistics, background fluctuations, radionuclide interferences and isotopic measurement 

uncertainty. The ISOCS Uncertainty estimator is used to calculate TMU. This is a companion program to the MILCC system. 

EPA evaluated the 3 was within the expe

Background and Performance Checks Confirm that MILCC background measurements have been taken daily. 

Background measurements are required in CCP-TP-076, Operating Procedure 

(Revision 0, 5/2013). Evidence of daily background measurements was seen 

in the logbook pages reviewed. 

EPA reviewed the l30–31, 2013, and Jushowed that backgromade and acceptabl
B-5 

Technical Elements Objective Evidence Additio

Assess how often background radiation was problematic to the extent that measurement 

personnel had to make 

adjustments. 

This was originally a problem when the MILCC was first assembled. Wastes stored in Dome 283 were removed. This reduced background to acceptable 

levels. Background has not been a problem since these wastes were relocated. 

This was discussed during the evaluatio

Confirm that system performance checks have been performed at least once per operational day. Confirm that performance checks include gamma matrix correction checks, and gamma peak position and resolution checks. 

Performance measurements are required in CCP-TP-076, Operating Procedure (Revision 0, 5/2013). Evidence of daily performance checks was seen in the logbook pages reviewed. 

EPA reviewed the l30–31, 2013, and Jushowed that performmeasurements were 

MILCC BDRs contain • Testing facility name, testing 

batch number, container 

numbers, and signature of the SPM or designee. 

• Table of Contents. 

• Background and performance 

check data or control charts for the relevant time period. 

• Separate testing report sheets 

for each container. 

EPA reviewed MILCC BDR Nos. 4LANDA0001 (55-gallon drums), 4LANDA0002 (CMBs) and 4LANDA0003 (SWBs). The BDRs contained all required information. 

NA 

MILCC RDSs must include: • Title “Radioassay Data 

Sheet.” 

• Method/procedure used. 

• Date of radioassay. 

• Activities and associated 

TMU for individual radionuclides. 

• TRU alpha concentration and 

its associated TMU. 

• Operator and reviewer 

signatures. 

EPA reviewed MILCC BDR Nos. 4LANDA0001 (55-gallon drums), 4LANDA0002 (CMBs) and 4LANDA0003 (SWBs). The RDSs contained all required information. 

NA 
C.1-1 

ATTACHMENT C.1. MILCC REPLICATE TESTING RESULTS FOR CONTAINER No. 93683 (55-G

Instrument: MILCC Drum: 93683 

Quantity of Interest 

Original Measurement Replicate #1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) 2.64E-05 9.65E-06 3.65E-01 2.69E-05 9.72E-06 3.61E-01 2.66E-05 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 3.11E-02 1.17E-02 3.75E-01 3.25E-02 1.20E-02 3.70E-01 3.66E-02 239Pu Activity (Ci) 9.85E-01 3.49E-01 3.54E-01 9.89E-01 3.52E-01 3.56E-01 9.50E-01 240Pu Activity (Ci) 2.35E-01 8.33E-02 3.54E-01 2.34E-01 8.33E-02 3.56E-01 2.21E-01 242Pu Activity (Ci) 2.32E-05 8.55E-06 3.68E-01 2.39E-05 8.82E-06 3.69E-01 2.21E-05 241Am Activity (Ci) 3.17E-01 1.20E-01 3.77E-01 3.42E-01 1.29E-01 3.77E-01 3.10E-01 90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 8.90E+03 2.15E+03 2.42E-01 9.07E+03 2.18E+03 2.40E-01 8.62E+03 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) 3.13E-05 1.12E-05 3.58E-01 2.87E-05 1.04E-05 3.61E-01 2.14E-05 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 3.73E-02 1.37E-02 3.66E-01 4.35E-02 1.58E-02 3.64E-01 3.94E-02 239Pu Activity (Ci) 9.80E-01 3.49E-01 3.56E-01 9.98E-01 3.56E-01 3.57E-01 9.75E-01 240Pu Activity (Ci) 2.47E-01 8.79E-02 3.56E-01 2.31E-01 8.26E-02 3.58E-01 2.23E-01 242Pu Activity (Ci) 2.54E-05 9.38E-06 3.69E-01 2.37E-05 8.77E-06 3.70E-01 2.20E-05 241Am Activity (Ci) 3.16E-01 1.19E-01 3.77E-01 3.41E-01 1.29E-01 3.77E-01 3.08E-01 90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 8.98E+03 2.16E+03 2.41E-01 9.17E+03 2.20E+03 2.40E-01 8.79E+03 
C.1-2 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <|

Reported Value Absolute Uncertainty 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 234U Activity (Ci) 2.64E-05 9.65E-06 2.70E-05 3.64E-06 1.35E-01 5.69E-01 9.66E238U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 238Pu Activity (Ci) 3.11E-02 1.17E-02 3.79E-02 4.03E-03 1.06E-01 4.77E-01 9.76E239Pu Activity (Ci) 9.85E-01 3.49E-01 9.78E-01 1.81E-02 1.85E-02 1.08E-02 1.00E240Pu Activity (Ci) 2.35E-01 8.33E-02 2.31E-01 1.04E-02 4.48E-02 6.18E-02 1.00E242Pu Activity (Ci) 2.32E-05 8.55E-06 2.34E-05 1.41E-06 6.03E-02 1.09E-01 9.99E241Am Activity (Ci) 3.17E-01 1.20E-01 3.23E-01 1.68E-02 5.19E-02 7.89E-02 9.99E90Sr Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 137Cs Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 8.90E+03 2.15E+03 8.93E+03 2.21E+02 2.48E-02 4.21E-02 1.00E

Quantity of Interest t Pr(x <|t|) χ2 Test t Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable 234U Activity (Ci) -1.46E-01 8.91E-01 Not Significant Not Significant238U Activity (Ci) N/A N/A Not Applicable Not Applicable238Pu Activity (Ci) -1.53E+00 2.00E-01 Not Significant Not Significant239Pu Activity (Ci) 3.32E-01 7.57E-01 Not Significant Not Significant 240Pu Activity (Ci) 3.35E-01 7.54E-01 Not Significant Not Significant 242Pu Activity (Ci) -1.42E-01 8.94E-01 Not Significant Not Significant 241Am Activity (Ci) -3.48E-01 7.45E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A Not Applicable Not Applicable137Cs Activity (Ci) N/A N/A Not Applicable Not ApplicableTRU Alpha Conc. (nCi/g) -1.07E-01 9.20E-01 Not Significant Not Significant 
C.2-1 

ATTACHMENT C.2. MILCC REPLICATE TESTING RESULTS FOR CONTAINER No. 523

Instrument: MILCC CMB: 52303 

Quantity of Interest 

Original Measurement Replicate #1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) 2.15E-04 1.47E-04 6.84E-01 2.13E-04 1.46E-04 6.84E-01 2.24E-04 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 1.38E+00 9.44E-01 6.84E-01 1.37E+00 9.36E-01 6.83E-01 1.44E+00 239Pu Activity (Ci) 1.17E-03 8.19E-04 7.00E-01 1.16E-03 8.12E-04 7.00E-01 1.22E-03 240Pu Activity (Ci) 5.82E-04 4.07E-04 7.00E-01 5.77E-04 4.03E-04 6.98E-01 6.06E-04 242Pu Activity (Ci) 5.83E-07 4.07E-07 6.98E-01 5.78E-07 4.04E-07 6.99E-01 6.07E-07 241Am Activity (Ci) 3.71E-02 2.60E-02 7.00E-01 4.16E-02 2.83E-02 6.80E-01 3.48E-02 90Sr Activity (Ci) 3.85E-06 2.50E-06 6.49E-01 5.66E-07 3.71E-07 6.55E-01 5.19E-07 137Cs Activity (Ci) 3.85E-06 2.50E-06 6.49E-01 5.66E-07 3.71E-07 6.55E-01 5.19E-07 TRU Alpha Conc. (nCi/g) 1.42E+03 9.46E+02 6.66E-01 1.41E+03 9.38E+02 6.65E-01 1.48E+03 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) 2.03E-04 1.39E-04 6.84E-01 2.10E-04 1.43E-04 6.83E-01 2.15E-04 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 1.30E+00 8.90E-01 6.85E-01 1.35E+00 9.19E-01 6.81E-01 1.38E+00 239Pu Activity (Ci) 1.11E-03 7.72E-04 6.96E-01 1.14E-03 7.98E-04 7.00E-01 1.17E-03 240Pu Activity (Ci) 5.50E-04 3.84E-04 6.98E-01 5.68E-04 3.96E-04 6.98E-01 5.82E-04 242Pu Activity (Ci) 5.51E-07 3.84E-07 6.97E-01 5.69E-07 3.97E-07 6.97E-01 5.82E-07 241Am Activity (Ci) 3.66E-02 2.53E-02 6.90E-01 4.02E-02 2.77E-02 6.90E-01 4.54E-02 90Sr Activity (Ci) 3.97E-07 2.63E-07 6.62E-01 4.07E-07 2.70E-07 6.63E-01 4.21E-07 137Cs Activity (Ci) 3.97E-07 2.63E-07 6.62E-01 4.07E-07 2.70E-07 6.63E-01 4.21E-07 TRU Alpha Conc. (nCi/g) 1.34E+03 8.90E+02 6.64E-01 1.39E+03 9.22E+02 6.63E-01 1.43E+03 
C.2-2 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <|c

Reported Value Absolute Uncertainty 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N234U Activity (Ci) 2.15E-04 1.47E-04 2.13E-04 7.65E-06 3.59E-02 1.08E-02 1.00E+238U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N238Pu Activity (Ci) 1.38E+00 9.44E-01 1.37E+00 5.07E-02 3.71E-02 1.15E-02 1.00E+239Pu Activity (Ci) 1.17E-03 8.19E-04 1.16E-03 4.06E-05 3.50E-02 9.84E-03 1.00E+240Pu Activity (Ci) 5.82E-04 4.07E-04 5.77E-04 2.05E-05 3.55E-02 1.01E-02 1.00E+242Pu Activity (Ci) 5.83E-07 4.07E-07 5.77E-07 2.04E-08 3.53E-02 1.01E-02 1.00E+241Am Activity (Ci) 3.71E-02 2.60E-02 3.97E-02 4.18E-03 1.05E-01 1.04E-01 9.99E90Sr Activity (Ci) 3.85E-06 2.50E-06 4.62E-07 7.58E-08 1.64E-01 3.68E-03 1.00E+137Cs Activity (Ci) 3.85E-06 2.50E-06 4.62E-07 7.58E-08 1.64E-01 3.68E-03 1.00E+TRU Alpha Conc. (nCi/g) 1.42E+03 9.46E+02 1.41E+03 5.15E+01 3.65E-02 1.19E-02 1.00E+

Quantity of Interest t Pr(x <|t|) χ2 Test t Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable 234U Activity (Ci) 2.39E-01 8.23E-01 Not Significant Not Significant238U Activity (Ci) N/A N/A Not Applicable Not Applicable238Pu Activity (Ci) 2.16E-01 8.39E-01 Not Significant Not Significant 239Pu Activity (Ci) 2.25E-01 8.33E-01 Not Significant Not Significant 240Pu Activity (Ci) 2.41E-01 8.21E-01 Not Significant Not Significant 242Pu Activity (Ci) 2.51E-01 8.15E-01 Not Significant Not Significant 241Am Activity (Ci) -5.72E-01 5.98E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A Not Applicable Not Applicable137Cs Activity (Ci) N/A N/A Not Applicable Not ApplicableTRU Alpha Conc. (nCi/g) -1.07E-01 9.20E-01 Not Significant Not Significant