### EPA DOCKET NO. A- 98 - 49, II -A4 - 128

WASTE CHARACTERIZATION INSPECTION REPORT

AND PROPOSED APPROVAL EPA BASELINE INSPECTION NO. EPA- Hanford - CCP - CH - 04.10 - 8 OF THE CENTRAL CHARACTERIZATION PROJECT WASTE CHARACTERIZATION PROGRAM

AT THE HANFO RD SITE April 27–29, 2010

U.S. Environmental Protection Agency Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

August 2010i 

### TABLE OF CONTENTS Section Page Acronym s ................................ ................................ ................................ ................................ ....... iii 1.0 Executive Summary ................................ ................................ ................................ ............ 1 2.0 Purpose of Inspection s ................................ ................................ ................................ ........ 4 3.0 Purpose of This Report ................................ ................................ ................................ ....... 5 4.0 Scope of Inspection ................................ ................................ ................................ ............. 6 5.0 Inspection - Related Definitions ................................ ................................ ........................... 7 6.0 Personnel ................................ ................................ ................................ ............................. 7 6.1 EPA Inspection Team ................................ ................................ ............................. 7 6.2 Personnel Contacted ................................ ................................ ................................ 8 7.0 Performance of the Inspection ................................ ................................ ............................ 8 7.1 Site Background and History ................................ ................................ .................. 8 7.2 Inspection Process Overview ................................ ................................ .................. 9 8.0 Technical Waste Characterization Areas ................................ ................................ ............ 9 8.1 Acc eptable Knowledge (AK) ................................ ................................ ................ 10 8.2 Nondestructive Assay (NDA) ................................ ................................ ............... 25 8.3 Real - Time Radiography (RTR) ................................ ................................ ............ 32 8.4 Visual Examination (VE) ................................ ................................ ...................... 37 8.5 WIPP Waste Data System (WDS) ................................ ................................ ........ 42 9.0 Response to Comments ................................ ................................ ................................ ..... 46 10.0 Summary

of Results ................................ ................................ ................................ .......... 46 10.1 Findings and Concerns ................................ ................................ .......................... 46 10.2 Conc lusions ................................ ................................ ................................ ........... 46 11.0 References ................................ ................................ ................................ ......................... 49ii 

### ATTACHMENTS Attachment A.1 Acceptable Knowledge (AK) Checklist Attachment A.2 Nondestructive Assay (NDA) Checklist, Attachm ent A.3 Real - Time Radiography (RTR) Checklist Attachment A.4 Visual Examination (VE) Checklist Attachment A.5 WIPP Waste Data System (WDS) Checklist Attachment B.1 Replicate Testing Data for Container RL0063023, GEA - A Attachment B.2 Replicate Testing Results for Container RL0063023, GEA - A Attachment B.3 Replicate Testing Data for Container RL0050614, GEA - A Attachment B.4 Replicate Testing Results for, Container RL0050614, GEA - A Attachment B.5 Replicate Testing Data for Container RL0063005, GEA - A Attachment B.6 Replicate Testing Results for Container RL0063005, GEA - A Attachment B.7 Replicate Testing Data for Container RL0063034, GEA - B Attachment B.8 Replicate Testing Results for Container RL0063034, GEA - B Attachment B.9 Replicate Testing Data for Container RL 0056338, GEA - B Attachment B.10 Replicate Testing Results for, Container RL0056338, GEA - B Attachment B.11 Replicate Testing Data for Container RL062952, GEA - B Attachment B.12 Replicate Testing Results for Container RL062952, GEA - B Attachment C.1 E PA Inspection Issue Tracking Form, Issue No. Hanford - CCP - CH - RTR- 10 -

001CR, Final Attachment C.2 EPA Inspection Issue Tracking Form , Issue No. Hanford - CCP - CH - WDS - 10 - 002CR, Final Attachment C.3 EPA Inspection Issue Tracking Form, Issue No. Hanford - CCP - CH -NDA - 10 -

003CR, Final Attachment C.4 EPA Inspection Issue Tracking Form , Issue No. Hanford - CCP - CH - AK- 10 - 004CR, Final Attachment C.5 EPA Inspection Issue Tracking Form , Issue No. Hanford - CCP - CH - VE - 10 - 005F , Final Attachment C.6 EPA Inspection Issue Tracking Form, Issue No. Hanford - CCP - CH - VE - 10 -

006CR, Final Attachment D Acceptable Knowledge Source Documents Reviewediii 

### ACRONYMS AI TR Automated Independent Technical Review AK acceptable knowledge AKE Acceptable Knowledge Expert AKSR AK summary report Am americium Ba barium BDR batch data report CBFO Carlsbad Area Field Office CCP Central Characterization Project Cf californium CFR Code of Federal Regulations CH contact - handled CI S Characterization Information Summary Cm curium Co cobalt CRA Compliance Recertification Application Cs cesium D&D decontamination and decommissioning DA Database Administrator DOE U.S. Department of Energy DQO data quality objective DR discrepancy resolution EA expert analyst EPA U.S. Enviro nmental Protection Agency ES&H environmental safety and health Eu europium FR Federal Register FRAM fixed energy response function anal ys is with multiple efficiencies ftp file transfer protocol g gram or grams g/cc grams per cubic centimeteriv



### GEA C anberra Gamma Energy Analysis HEHF Emergency Decontamination Facility HLW high - level waste IDMS Integrated Document Management System IPAN Imaging Passive Active Neutron ITR Independent Technical Reviewer K potassium keV kiloelectron volt kg kilogram or kilograms LANL Los Alamos National Laboratory LEGe low - energy germanium LLD lower limit of detection LO Lead Operator LWA Land Withdrawal Act m 3 

### cubic meters MGA multi - group analysis MGA - U MGA Uranium MPFPD Mixed PFP Debris MPF PDD Mixed Plutonium Finishing Plant Decontamination and Decommissioning Na sodium Nb niobium nCi/g nanocuries per gram NCR nonconformance report NDA nondestructive assay NDE nondestructive examination Np neptunium NWPA Nuclear Waste Polic y Act ORIA Office of Radiation and Indoor Air ORNL Oak Ridge National Laboratory PDP Performance Demonstration Program PFP Plutonium Finishing Plant PTS Program Tracking S ys tem Pu plutoniumv



### QC quality control Ra radium RCRA Resource Conservation and Recovery Act RLMPFPCD Mixed Plutonium Finishing Plant Comprehensive Debris Waste Stream RTR real - time radiography SCG Summary Category Group SEGe standard electrode germanium SME Subject Matter Expert SNF spent nuclear fuel SPM Si te Project Manager Sr strontium SRS Savannah River Site SWB standard waste box SWITS Solidified Waste Information Tracking System T1 Tier 1 T2 Tier 2 Th thorium TMU total measurement uncertainty TRU transuranic TRUEDMT TRU Electronic Data Management Tool U uranium VE visual examination VEE Visual Examination Expert VEO Visual Examination Operator WAC waste acceptance criteria WAP Waste Analysis Plan WCA Waste Certification Assistant WCO Waste Certification Official WDS WIPP Waste Data System WG Pu weapons - grade plutonium WIPP Waste I solation Pilot Plant WMC waste matrix code WMP waste material parametervi



### WRAP Waste Reprocessing and Packaging WSPF Waste Stream Profile Form WWI S WIPP Waste Information System1



### 1.0 EXECUTIVE SUMMARY This report supports the U.S. Environmental Protection Agency (EPA or the Agency)’s proposed approval of the transurainc (TRU) waste characterization program implemented by the Central Characterization Project (CCP) at the Hanford site. Inaccordance with 40 CFR 194.8(b), the EPA conducted Baseline Inspection No. EPA - Hanford - CCP - CH - 04.10 - 8 of the waste characterization program for contact - handled (CH) TRU waste. This inspection occurred at the Hanford site, April 27 through 29, 2010. In accordance with the provisions of 40 CFR 194.8(b), as issued in a July 16, 2004, Federal Register (FR) notice (69 FR 42571

–42583), EPA conducted a baseline inspection of the site’s program to characterize wastes proposed for disposal at the Waste I solation Pilot Plant (WIPP). As a result of this baseline inspection, EPA determines that the CH TRU waste characterization program of the CCP at Hanford is technically adequate. In addition, in accordance with 40 CFR 194.8(b), based on a demonstration of the CCP’s capabilities to characterize Hanford’s retrievabl y- stored CH TRU debris waste, the EPA proposes the conditions and limitations that are discussed in this report. EPA is seeking public comment on the proposed approval which, when finalized, will all ow the Hanford - CCP to characterize and dispose of CH TRU debris waste at the WIPP. EPA must verify

compliance with 40 CFR 194.24 before waste may be disposed of at the WIPP, as specified in Condition 3 of the Agency ’s certification of the WIPP’s complianc e with disposal regulations for TRU radioactive waste (63 FR 27354, 27405, May 18, 1998). In the Fall of 2009, the CCP took over TRU waste characterization activities at Hanford. In addition, since then, the CCP has been disposing of CH - TRU waste at WIPP characterized by the now terminated Hanford program 1 

### . EPA had not previously evaluated waste characterization systems implemented by

the CCP at Hanford for characterizing CH TRU wastes. The purpose of this inspection was to evaluate the technical adequacy of the site’s waste characterization programs for CH TRU debris waste to be disposed of at WIPP. During the inspections, the Agency examined the following activities:

 Acceptable knowledge (AK) for CH retrievably- stored TRU debris waste (S5000)  Two nondestructive assay (NDA) systems, the Canberra Gamma Energy Analysis System Units A and B (GEA - A and GEA - B) for characterizing debris (S5000) wastes  Real - time radiography (RTR) for CH retrievably- stored TRU debris waste (S5000)  Visual Examination (VE) for C H retrievabl y- stored TRU debris waste (S5000)  WIPP Waste Data System (WDS) for CH retrievably- stored TRU debris waste (S5000) During the inspection, Hanford - CCP personnel stated that the Hanford - CCP was not seeking approval to perform load management, and EPA excluded evaluation of load management from the scope of this inspection [see Section 8.1(5)]. Therefore, this proposed approval does not include load management for Hanford- CCP.

1 EPA originally approved Hanford’s TRU waste characterization program in mid - 2002 and gave subsequent baseline approval in mid - 2008.2



### The EPA inspection team identified five concerns, all of which required a response. EPA Inspection Issue Tracking Forms (see Attachments C.1 through C.4 and C.6 of this report) document these concerns. The EPA inspection team also identified one finding (Hanford - CCP - CH - VE - 10 - 005F , Final, see Attachment C.5 of this report) . Personnel from Hanford - CCP and Carlsbad Field Office (CBFO) provided information to resolve these concerns to the EPA inspection team after the inspection. The information provided to EPA adequatel y addressed the finding and concerns. EPA considers th e one finding and the five concerns related to Hanford - CCP to be resolved, and there are no open issues resulting from this inspection. The EPA inspection team determined that the Hanford- CCP waste characterization program for retrievabl y- stored CH TRU debris waste was technically adequate. EPA, therefore, is proposing to approve the Hanford - CCP CH TRU waste characterization program in the configuration observed during this inspection and described in this report and the attached checklists (Attachments A .1 through A.5). This approval includes the following: (1) The AK process for CH retrievabl y- stored TRU debris wastes (2) The GEA - A and GEA - B system units for assaying CH TRU wastes (3) The nondestructive examination (NDE) process of RTR for CH TRU debris wastes (4) The NDE process of VE for CH TRU debris waste (5) The WDS process for tracking waste contents of CH TRU wastes As part of Item # 3 above, when estimating observable, free liquid in a CH container, if a mathematical equation is used to calculate the quantities o f liquid , the calculation must be documented so it can be verified b y another RTR operator, an independent technical reviewer, or a technical auditor and/or Federal inspector. Hanford - CCP must report any Tier 1 (T1) or Tier 2 (T2) changes to the Hanford - C CP waste characterization activities from the date of the baseline inspection according to Table 1, below. Reference to the specific section of this report where each T1 or T2 change is discussed is included in parentheses following the change. Table 1 in this report closel y follows the format used in previous CH baseline approval reports. Footnote b in Tables 1 and 10 specifies that “substantive changes” are changes with the potential to impact the site’s waste characterization activities under 40 CFR 1 94.24 or the documentation thereof, excluding changes that are solely related to environmental safety and health (ES&H), nuclear safety, or the Resource Conservation and Recovery Act (RCRA), or that are editorial in nature. All T1 changes must be submitte d for evaluation and approval b y EPA prior to implementation (see Section 2.0 of this report for a brief discussion of tiering). Upon approval, EPA will notify the public of the results of its evaluations by posting the results to the EPA Web site and by sending e - mails through the WIPPNEWS list. Upon completion of its review of the T2 changes submitted at the end of each fiscal quarter, EPA will post the T2 changes . EPA expects the first report of Hanford - CCP’s T2 changes at the end of the first quarter following approval.3 

### Table 1. Tiering of TRU Waste Characterization Processes Implemented by Hanford - CCP

Based on April 27 - 29, 2010 Site Baseline Inspection Process Elements Hanford - CCP T1 Changes Needing EPA Review and Approval Hanford - CCP T2 Changes a Acceptable Knowledge (AK) Im plementation of load management (AK 13) Im plementation of AK for wastes other than retrievably stored debris (i.e., retrievably - stored soil/gravel and/or solids) (AK 1) Notification to EPA upon completion of new versions or updates/ substantive changes b of

the following:

- Modification of CCP - TP - 005, Revision 18 (AK 4)

- Availability of modifications to the AKSR (AK 5)

- Availability of all final WSPF with related attachments (AK 9)

- Availability of all AK Accuracy Reports (AK 12)

- Availability of successful training records (AK 10)

- Availability of the AK -NDA memorandum (AK 14) Non Destructive Assay (NDA) New equipment or physical modifications to approved equipmentc (NDA 1) Extension or changes to approved calibration range for approved equipment (NDA 2) Notification to EPA upon completion of c hanges to software for approved equipment, operating range(s), and site procedures that require CBFO approval (NDA 2) Real - Time Radiography (RTR) Im plementation of a different type of RTR e quipment (RTR 2) Notification to EPA upon the following:

- Modificationc to approved equipment, RTR units A and B (RTR 2)

- Com pletion of c hanges to site RTR procedures requiring CBFO approvals (RTR 2)

- Addition of new SCG to the RTR processes that are subject to this approval (RTR 2) Visual Examination (VE) P erformance of VE by any method other than using two trained operators to perform actual VE at the time of packaging (VE 1) Notification to EPA upon the following:

- Com pletion of c hanges to site VE procedure (s) requiring CBFO approvals (VE 2)

- Addition of new SCG to the VE processes that are subject to this approval (VE 2) Waste Data System (WDS) There are no T1 changes at this time Notification to EPA upon the following:

- Com pletion of changes to WDS procedure(s) requiring CBFO approvals (WDS 2)

- Changes to the Excel spreadsheet titled WDS Master Template.xls, Revision 2, Addendum #2, SCO #1065 (WDS 2) a Upon receiving EPA approval, Hanford - CCP will report all T2 changes to EPA at the end of each fiscal quarte r. b “ Substantive changes” are changes with the potential to impact the site’s waste characterization activities or documentation thereof, excluding changes that are solely related to ES&H, nuclear safety, or RCRA, or that are editorial in nature. c Modifi cations to approved equipment include all changes with the potential to affect NDA data relative to waste isolation and exclude minor changes, such as the addition of safety - related equipment.4



### 2.0 PURPOSE OF INSPECTIO NS On May 18, 1998, EPA certified that th e WIPP will comply with the radioactive waste disposal regulations at 40 CFR Part 191. In this certification, EPA also included Condition 3, which states that “the Secretary

shall not allow shipment of any waste from...any waste generator site other than LA

NL [Los Alamos National Laboratory] for disposal at the WIPP until the Agency has approved the processes for characterizing those waste streams for shipment using the process set forth in §194.8.” The approval process described at 40 CFR 194.8 requires DO E to (1) provide EPA with information on AK2 

### for waste streams proposed for disposal at the WIPP, and (2) implement a s ys tem of controls used to confirm that the total amount of each waste component that will be emplaced in the WIPP will not exceed limits identified in the WIPP Compliance Certification Application (DOE/CAO 1996 - 2184, 40 CFR Part 191, Compliance Certification Application for the W aste Isolation Pilot Plant, 1996). Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, FR notic e, 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 a demonstration that the program’s components, with applicable conditions and limitations, can adequately characterize TRU wastes and compl y with the regulatory requirements imposed on TRU wastes destined for disposal at the WIPP. An EPA team conducts an onsite inspection to verify that the s ite’s s ys tem of controls is technicall y adequate and properl y implemented. Specificall y, the EPA inspection team verifies compliance with 40 CFR 194.24 (c)(4), which states the following: Any compliance application shall: . . . Provide information which demonstrates that a system of controls has been and will continue to be implemented to confirm that the total amount of each waste component that will be emplaced in the disposal system will not exceed the upper limiting value or fall below the lower limi ting value described in the introductory text of paragraph I of this section. 3 

### The system of controls shall include, but shall not be limited to: measurement; sampling; chain of custody records; record keeping systems; waste loading schemes used; and oth er documentation. In other words, the purpose of the baseline inspection is to assess whether DOE sites that characterize TRU waste prior to disposal at the WIPP are capable of characterizing and tracking the waste in a manner to demonstrate regulatory c ompliance and document that the waste will not exceed the approved limits. Before proposing the approval of TRU waste characterization

2 As of the FR notice of July 16, 2004 (69 FR 42571

–42583), EPA has replaced the term “process knowledge” with “ acceptable knowledge .” Acceptable knowledge refers to any information about the process used to generate wa ste, material inputs to the process, and the time period during which the wastes were generated, as well as data resulting from the analysis of waste conducted prior to or separate from the waste certification process authorized by an EPA certification decision to show com pliance with Condition 3 of the certification decision. 3 The introductory text of 40 CFR 194.24( c) states, “For each waste component identified and assessed pursuant to [40 CFR 194.24(b)], the Department shall specify the limiting value (expressed as an upper or lower limit of mass, volume, curies, concentration, etc.), and the associated uncertainty (i.e., margin of error) for each limiting value, of the total inventory of such waste proposed for disposal in the disposal system.”5



### systems and processes at Hanford - CCP, EPA evaluated the capabilities of systems and processes to (1) identify

and measure waste components (such as plutonium) that must be tracked for compliance, 4 

### and (2) confirm that the waste in any given container has been properl y identified as belonging to the group of approved waste streams. Following EPA’s baseline approval, 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 c ompliance 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 regulatory requirements. Based on the adequacies of the waste characterization p rocesses demonstrated during the baseline inspection, including all conditions and limitations, EPA specifies which subsequent waste characterization program changes or modifications must undergo further EPA inspection or approval under 40 CFR 194.24. EPA accomplishes this by

assigning a tier level to each aspect of the characterization program. T1 activities have more stringent reporting requirements and the Agency ’s approval prior to implementing the change is necessary . The EPA - approved sites must rep ort T2 activities to EPA based on the frequency

established in the inspection report. DOE may choose to characterize and dispose of materials at its own risk while EPA considers the proposed T2 changes. If Hanford - CCP contemplates a change that is not identified in this report, EPA recommends that the site, in consultation with CBFO, discuss the nature of the change with EPA. This would minimize the possibility

of EPA not approving the site - assigned tiers. The rule appl ying to this baseline inspection c an be found in the Federal Register notice at 69 FR 42571

–42583, July 16, 2004. 3.0 PURPOSE OF THIS REPO RT This report documents the basis for EPA’s proposed approval decision and explains the results of EPA Baseline Inspection No. EPA - Hanford - CCP - CH - 04.10 - 8 in terms of findings and concerns. Specificall y, this report does the following:

 Describes the characterization systems evaluated during the inspection that are approved  Provides objective evidence of the approval basis for all waste characterization systems  Id entifies all relevant s ys tem limitations and/or conditions for each waste characterization system  Id entifies the applicable T1 and T2 elements  Provides objective evidence of outstanding findings or concerns, as applicable

4 The potential contents of a waste stream or group of waste streams determine which processes can adequately characterize the waste. For example, if AK information suggests that the waste form is heterogeneous, the site should select a suitable NDA technique to ensure adequate measurements. Radiography and VE help to confirm and quantify waste components, such as cellulosi cs, rubbers, plastics, and metals. Once the nature of the waste has been confirmed, the assay techniques then quantify selected radionuclides in the waste. In some cases, a TRU waste generator site may be able to characterize a wide range of heterogeneou s waste streams or only a few. A site’s stated limits on the applicability of proposed WC processes govern EPA’s inspection scope.6



###  Describes any tests or demonstrations completed during the course of the inspection and their relevance to EPA’s approval decision The completed checklists (Attachments A.1 through A.5 to this report) reference the documents that the EPA inspection team reviewed in support of th e technical determination. To see or obtain copies of any items identified in the attached checklists, write to the following address: Quality Assurance Manager USDOE/Carlsbad Area Field Office P.O. Box 3090 Carlsbad, NM 88221 EPA’s final approval deci sion on the Hanford - CCP waste characterization program will be conveyed to DOE separately by letter. More information is also on EPA’s Web site at http://www.epa.gov/radiation/WIPP/index.html in accordance with 40 CFR 194.8(b)(3). 4.0 SCOPE OF INSPECTION The scope of EPA Baseline Inspection No. EPA - Hanford - CCP - CH - 04.10 - 8 was the evaluation of the technical adequacy of the waste characterization systems in use at Hanford - CCP to characterize CH TRU wa stes. The EPA inspection team evaluated these s ystems with respect to their ability

to perform the following functions:

 Id entify

and quantify

the activities of the 10 WIPP - tracked radionuclides ( 241 

### Am, 137 

### Cs, 238 

### Pu, 239 

### Pu, 240 

### Pu, 242 

### Pu, 90 

### Sr, 233 

### U, 234

### U, and 238 

### U) using a combination of AK and NDA systems  Assign waste material parameters (WMPs) correctly using RTR for CH retrievably- stored debris waste  Perform effective waste information (data) transfer using the WDS Specificall y, these s ys tems consisted of the following components:

 AK processes that support retrievabl y- stored S5000 debris wastes  Two NDA s ys tems, GEA - A and GEA - B, for the analysis of S5000 debris wastes  RTR  VE  The WDS for the purpose of compiling TRU waste data by container and tracking o f all waste containers emplaced in the WIPP repository During its inspection, EPA does not approve or certify waste characterization data per se; that function is the sole responsibility of the site being evaluated

—in this case, Hanford - CCP. EPA, however , evaluated adequacy of the site’s waste characterization processes and ability of personnel and equipment to characterize contents of CH retrievably- stored TRU waste7



### containers. The evaluation consisted of interviewing personnel, observing equipment operations that follow site procedures, and inspecting records related to each of the waste characterization processes within the inspection’s scope. An important aspect of this evaluation was the objective evidence documenting the effectiveness of the wast e characterization processes. Objective evidence typically takes the form of batch data reports (BDRs), radioassay data sheets, AK accuracy reports, RTR tapes, and WDS printouts for specific TRU containers. During this inspection, EPA selected samples of each of these items, based on the number and variety of items each waste characterization process produced, consistent with standard inspection techniques. Based on the evaluation of the waste characterization processes in conjunction with the sample of objective evidence, EPA determined the technical adequacy

of the waste characterization processes within the inspection’s scope. 5.0 INSPECTION - RELATED DEFINITIONS During an inspection, EPA inspectors may encounter items or activities that require further inquiry for their potential to adversel y affect waste characterization and/or isolation within the repository . The two main categories relevant to waste characterization inspections are identified below: Finding : A determination that a specific item or activity does not conform to 40 CFR 194.24(c)(4). A finding requires a response from CBFO . Concern : A judgment that a specific item or activity may or may not have a negative effect on compliance and, depending on the magnitude of the issue, may or may not require a response. Note that DOE does not need to address concerns not requiring a response prior to program approval. However, EPA recommends that when DOE accepts the site’s response to an EPA concern, it should inform EPA at the same time that the site implements the corresponding corrective action. This process is similar to a T2 change. 6.0 PERSONNEL 6.1 EPA Inspection Team Table 2 identifies the members of the EPA waste characterization inspection team. Table 2. EPA Inspection Team Members Inspection Team Member Position Affiliation Rajani Joglekar Inspection Team Leader U.S. EPA ORIA Ed Feltcorn Inspector U.S. EPA ORIA Lindsey Bender Observer U.S. EPA ORIA Jonathan Walsh Observer U.S. EPA ORIA Connie Walker Technical Inspector, AK S. Cohen & Ass ociates, Inc. Kira Darlow Inspector- In - Training, AK S. Cohen & Associates, Inc Dorothy Gill Technical Inspector, NDE S. Cohen & Associates, Inc. Patrick Kelly Technical Inspector, NDA S. Cohen & Associates, Inc Abe Zeitoun Inspector- In - Training, NDE S. Cohen & Associates, Inc.8



### 6.2 Personnel Contacted EPA and its support personnel conducted interviews with Hanford - CCP waste characterization personnel in several disciplines. The personnel contacted represented only a sample of the CH TRU waste characteriz ation staff, and they are listed in Table 3, along with their affiliations and areas of expertise. Table 3. Personnel Contacted During Inspection

Personnel Affiliation Area of Expertise/Function Sherri Nance CCP Acceptable Knowledge Expert (AKE) Steve Schafer CCP Acceptable Knowledge Expert (AKE) Joe Harvill CCP NDA, Technical Liason George Westik AREVA/CCP NDA, Expert Analyst (EA) Brett Templeton MCS/CCP NDA, Lead Operator (LO) Ed Gulbransen AREVA NDA, Expert Analyst (EA) Deborah Zentner CCP Visual Examination Expert (VEE) Carissa Marquez CCP Visual Examination Operator (VEO) Yulanda Gates CCP Visual Examination Operator (VEO) Charles McCants CCP Visual Examination Operator (VEO) Dale Simpson CCP RTR Subject Matter Expert (SME) Jeremy Veseley CCP RTR Operator/Independent Technical Revie wer (ITR) Larry Porter CCP Site Program Manager (SPM) Mike Ramirez CCP Waste Certification Official (WCO) 

### During the baseline inspection, Hanford - CCP provided a list of TRU waste characterization personnel, from which EPA selected a sample of individuals to interview. The EPA inspectors reviewed the qualifications (including waste characterization experience) and training records of these individuals to assess their waste characterization capabilities. After resolution of a finding, EPA has determined that those Hanford - CCP waste characterization personnel responsible for characterizing and certifying TRU waste were qualified and had received adequate training to perform their assigned function. When personnel changes occur, EPA may request qualification and training records of any new individuals identified as key waste characterization personnel. EPA will review these records and may interview the personnel to determine their ability to produce quality data. This personnel qualification evaluation and review of training records is similar to EPA’s evaluation during each inspection. 7.0 PERFORMANCE OF THE I NSPECTION 7.1 Site Background and History The DOE’s Hanford site covers a 560 - square mile area on the C olumbia River near Richland, Washington. The Hanford site was established during World War II to produce plutonium for U.S. nuclear weapons, and the site’s nine production reactors created approximately 75% of the9



### plutonium used in the U.S. nuclear arsenal. Peak plutonium production years were in the 1960s, and all nuclear material production was halted in late 1989. Hanford’s current mission involves environmental restoration and nuclear material stabilization and stewardship and Hanford is also an interim storage facility for TRU - contaminated waste, including defense waste. EPA inspected and approved Hanford’s waste characterization program in 2008 . In 2009, TRU waste characterization activities at Hanford were taken over b y CCP, and the Hanford - CCP T RU waste characterization program is the subject of this baseline inspection. 7.2 Inspection Process Overview EPA Baseline Inspection No. EPA - Hanford - CCP - CH - 04.10 - 8 took place April 27 - 29, 2010 . EPA reviewed additional documents that were provided after the inspection to complete its evaluation of several of the technical areas within the inspection’s scope. The inspection was performed for the purpose of determining Hanford - CCP waste characterization program compliance with 40 CFR 194.24. The inspection involved the following steps: (1) Preparing draft checklists specific to each technical area before the inspection (2) Obtaining and reviewing site procedures, reports, and other technical information related to waste characterization activities at Hanford- CCP in advance of the inspection (3) Interacting with CBFO and Hanford - CCP personnel to arrange inspection logistics (4) Verifying onsite the technical adequacy or qualifications of waste characterization personnel, procedures, processes, and equipment by means of interviews, observation, and demonstrations, and recording the results on checklists (5) Recording all findings and concerns on EPA Inspection I ssue Tracking Forms and providing completed forms to CBFO and site personnel as they were generated (6) Communicating all pertinent information to CBFO and Hanford - CCP personnel onsite, as appropriate (7) Pursuing resolution of all identified issues before completion of the inspection by discussions with CBFO and Hanford - CCP personnel (8) Conducting entrance, exit, and daily briefings fo r CBFO and Hanford - CCP management personnel, as appropriate (9) Reviewing additional information provided b y Hanford - CCP after the inspection 8.0 TECHNICAL WASTE CHAR ACTERIZATION AREAS Sections 8.1 through 8.5 of this report detail the five technical areas asses sed during this inspection

— AK, NDA, NDE consisting of RTR and VE, and the WDS.10



### 8.1 Acceptable Knowledge (AK) EPA examined the AK process and associated information to determine whether Hanford- CCP complies with 40 CFR 194.24 and 194.8 requirements for CH retrievabl y- stored and newl ygenerated debris wastes. Waste Characterization Element Description Attachment A.1 to this report is a checklist that identifies technical elements and objective evidence reviewed b y the EPA inspection team. AK provides information on several aspects of TRU wastes at Hanford - CCP, including, but not limited to, the following:

 Defense waste status  Spent Nuclear Fuel (SNF), High - Level Waste (HLW) presence  Material parameters  Waste stream definition  Radionuclide composition  Waste matrix codes (WMCs) EPA examined the following AK technical elements:

 Waste stream identification and definition  Radionuclide content of waste  Physical composition of waste  Overall procedural technical sufficiency and scope and ability

to follo w the AK waste characterization process for containers and waste streams including AK information assembly , compilation, confirmation, and AK discrepancy resolution (DR)  Sufficiency

of AK Summary

including source document integration and source document su fficiency  Drum data traceability  Defense origin of waste  SNF and HLW status  The Waste Stream Profile Form (WSPF)  Personnel training  Non Conformance Reports (NCRs)  AK accuracy  Load management  AK-NDA Communication Documents Reviewed During the inspecti on, EPA inspectors examined or accepted a variety of documents related to AK, some provided as paper cop y, others in electronic format. The list of all documents reviewed or accepted as objective evidence is presented in Attachment D. The following BDRs were examined:11 Drum Number RTR BDR No. NDA BDR No. 0056238 RLRTRB0002 RLGEAA0001 0063057 RLRTRA0001 RLGEAA0002 

### Technical Evaluation Hanford - CCP had completed characterization of one waste stream that was provided to EPA for inspection, the Mixed Plutonium Finishing Plan Decontamination and Decommissioning (MPF PDD) waste stream representative of Summary Category Group (SCG) S5000 waste. Waste stream MPFPDD is composed of newl y- generated and retrievabl y- stored debris waste generated from production through D&D activities at the Plutonium Finishing Plan (PFP). The MPFPDD waste stream consists of debris from several sources within the PFP complex as discussed in Item (1) below. EPA evaluated the adequacy of AK information specific to this CH TRU retrievabl y- stored and newly- generated waste stream in the following areas. (1) The definition of waste stream was evaluated and found to be adequate. The WIPP Waste Acceptance Criteria (2009) defines a waste stream as: “waste material generated from a single process or from an activity which is similar in material, physical form, and hazardous constituents.” The MPFPDD waste stream was evaluated based on this definition. The MPFPDD waste stream is composed of TRU mixed heterogeneous debris created by various production, maintenance, cleanout, stabilization, decontamination, and decommissioning activities at PFP. The waste stream may contain a number of debris materials including metals, plastics, and cellulosics, as detailed in Item (3), below. MPFPDD waste stream was created b y Hanford - CCP by

combining the Mixed PFP Debris (MPFPD) waste stream, and Mixed Plutonium Finishing Plant Comprehensive Debris (RLMPFPCD) Waste Stream. A total of 4,528 debris containers from the MPFPD waste stream were characterized under the old Hanford waste characterization program before its termination in August 2009 and have been disposed of at the WIPP. Several thousand of the MPFPD debris containers remain to be characterized which Hanford - CCP will characterize for WIPP disposal. Prior to the termination of its program in August 2009, Hanford created the RLMPFPCD waste stream but none of the containers were approved for WIPP disposal. Hanford - CCP indicated that the MPFPD waste stream was a subset of the larger RLMPFPCD waste stream. Hanford - CCP has redefined waste stream, RLMPFPCD, including MPFPD, to capture three additional facilities or areas within the PFP complex, specifically

the Waste Treatment and Americium Facility (Building 242 - Z), Ventilation and Exhaust shaf ts (291 - Z) and Ancillary

cribs/trenches. Between 2001 - 2008, EPA evaluated the MPFPD waste stream as part of the original Hanford program inspection to approve debris (S5000) waste and reevaluated the same during the subsequent site inspections, but never evaluated RLMPFPCD. Therefore, EPA’s anal ys is includes the acceptability of combining the Hanford- defined and Hanford - CCP - defined waste streams and if the new MPFPDD waste stream has been adequatel y defined.12



### Hanford - CCP representatives and the AKSR indicate that the PFP has been in operation since 1949 and performed weapons fabrication support activities through the late 1960s, after which time operations began shifting to supporting commercial nuclear reactor activities. HanfordCCP representatives indicated that all waste generated prior to 1970 has already been shipped to WIPP as part of the MPFPD waste stream. As a result, waste containers in inventory and to be shipped as part of the MPFPDD waste stream were generated after 1970. The AKSR estimates that 2,455 containers of waste from this waste stream are in retrievable storage as standard waste boxes, 55 - gallon drums and 85 - gallon drums, most of which will be repackaged. Approximately 6,694.0 cubic meters (m 3 

### ) of TRU waste debris will be generat ed at PFP during D&D activities that began in 2009. The AKSR states that the “combined” MPFPDD waste stream consists of TRU mixed heterogeneous debris resulting from production, maintenance, cleanout, stabilization, and decontamination and decommissioning (D&D) at PFP. The PFP Facility includes several buildings and areas. These are:

 232 - Z Waste Incinerator Facility Incinerator (e.g., Contaminated Waste Recovery)  234 - 5Z Plutonium Finishing Plant  236 - Z Plutonium Reclamation Facility Process Cell  242 - Z W aste Treatment Facility Waste Treatment Facility and Americium Facility  291 - Z Ventilation/Exhaust Air Stack  PFP Ancillary

Areas (2736 - Zb Areas PFP Effluent Infrastructure, 241 - Z Treatment and Storage Tanks, 241 - Z - 361 Settling Tank, 241 - Z - 8 Silica Slurry Tank, 216 - Z - 9 Crib, 216 - Z - 1A Crib/Tile Field, Ancillary Facilities, 216 - Z - 12 Process Crib, 2904 - ZA Monitoring Station) Hanford - CCP provided a freeze file change generated two weeks prior to the EPA inspection that removed all of the PFP Effluent Infrastruct ure units in 2736 - Zb Areas from the waste stream, based on the results of an earlier CBFO audit of the site. EPA agrees with this determination. Subsequently , EPA examined the information presented in the AK Summary and supporting references and supplemental documentation, and questioned the inclusion of the incinerator waste (232 - Z) in this waste stream, because information suggested it managed material from outside the PFP. Hanford - CCP provided supporting information that indicated no other facilitie s other than PFP provided feed material to the incinerator [see Item (5)], and EPA accepts this explanation. EPA examined the AKSR, supporting documents, and interviewed Hanford - CCP personnel to ascertain waste and material movement in and through the P FP facility and related areas. EPA determined that material movement and subsequent waste generation occurred through each of these facilities including “back and forth” material movement and management, and Hanford CCP AKEs stated that there is no indication that major contributions of materials or wastes from other site sources were managed at the complex. Radiological and phys ical characteristics of the waste stream are discussed in Items (2) and (3), below.13



### EPA noted that the MPFPDD waste stream is broad and includes both process and D&D waste from a number of PFP activities. This suggests that these activities may constitute a multitude of processes, bringing to question whether these processes should have been singled out as separate waste streams . However, Hanford - CCP personnel stated that in almost all instances, it was impossible to differentiate “where” in the PFP complex the waste was generated, (i.e., 236 - X waste cannot be distinguished from 242 - Z waste), so no further segregation into indiv idual waste streams can be accomplished, based on AK. Additionally , data suggest that the waste material has a general radiological signature supporting the waste stream definition [see Item (2), below]. Based on this information, the waste stream design ation is appropriate. See Items (2) and (3) below for radiological and physical waste characterization analyses that support this determination. Since this waste stream included only debris (S5000) waste, characterization of solids and sludge (S3000) and soil and gravel (S4000) waste will require a T1 change approval. (2) AK information pertaining to the radiological characteristics of TRU wastes was examined and found to be adequate. A primary

function of PFP during its earl y ye ars of operation was the p roduction and fabrication of plutonium for weapons parts, which included conversion of Pu nitrate to metal and casting/machining operations. Plutonium recovery from scrap and waste was also performed. In the 1960s, the mission began to shift to commercial nuclear support, and hence a change in the isotopic distribution of the plutonium fabricated or managed at the PFP. The isotopic distribution of plutonium within waste reflects this shift in plutonium production and fabrication activities. Radiological Characteristics of the MPFPDD Waste Stream Hanford - CCP examined previous AK reports and data in the WWI S for the portion of this waste stream already emplaced in WIPP to determine the general isotopic composition of the waste stream. The AK Summary states that data from 5,856 drums were evaluated to obtain this information, which is presented in Table 4, below. The source of this information is entirely the WWI S, which includes the 4,528 drums emplaced, as well as 1,328 certified drums in the WWI S that were not shipped at the time the data were obtained from the WWI S. This table shows that 239 

### Pu and 238 

### U are the most prevalent isotopes b y mass. This waste stream also contains isotopes of uranium, americium, neptunium, cesium, and strontium.14 

### Table 4. Waste Stream MPFPD WWIS Reported Radionuclides Isotope Total Radionuclide Wt% Suspected Present (Yes/No) WIPP Required Radionuclides Am - 241 0.63% Yes Pu- 238 0.04% Yes Pu- 239 67.34% Yes Pu- 240 6.19% Yes Pu- 242 0.07% Yes U - 233 0.03% Yes U - 234 Trace 1 Yes U - 238 24.65% Yes Sr - 90 Trace Yes Cs - 137 Trace Yes Additional Radionuclides Am - 243 Trace Yes Ba - 133 Trace Yes Cf - 249 Trace Yes Cm - 243 Trace Yes Co - 60 Trace Yes Eu- 152 Trace Yes Eu- 154 Trace Yes K- 40 0.01% Yes Na - 22 Trace Yes Nb - 94 Trace Yes Np - 237 0.11% Yes Pu- 241 0.22% Yes Ra - 226 Trace Yes Th - 228 Trace Yes Th - 232 0.37% Yes U - 232 Trace Yes U - 235 0.34% Yes Notes: 1 “Trace” indicates <0.1 w t% for that radionuclide. 

### Hanford - CCP representatives also evaluated the general isotopic distribution of key isotopes based on historic AK data in various references. These ranges are presented in Table 5, below.

Table 5. Plutonium and Uranium Isotopic Distributions Pu and Associated Distributions Uranium Distributions Isot ope Wt% Distribution Isotope Wt% Distribution Pu- 238 0.01

– 0.05% U - 232 Trace Pu- 239 74.78

– 97.77% U - 233 Trace Pu- 240 2.13

– 20.72% U - 234 0.006

– 0.008% Pu- 241 0.02

– 0.81% U - 235 0.57

– 0.97% Pu- 242 0.001

– 0.66% U - 236 0.07

– 0.08% Am - 241 0.07

– 2.8 8% U - 238 98.95

– 99.35% Np - 237 0.00

– 0.09%15



### AK data indicate that the initial weapons - grade plutonium (WG Pu) produced at Hanford exhibited a 240

### Pu weight percentage between approximately 0.9 - 7%, and fuel material processed at Hanford exhibited a 8 - 27% range of 240 

### Pu weight percent for experimental reactor and other technologies. Hanford - CCP concluded that a range of isotopic distributions would be expected for this waste stream, as shown in Table 5, above. The table was generated assuming 241 

### Am is present due to decay of 241 

### Pu, but AK data show that 241 

### Am may also be present in waste generated from the Waste Treatment complex (242 - Z). Therefore, the estimated percentage of americium may be greater than what is presented. Uranium is present as an impurity as slightl y depleted uranium (0.6 percent 235 

### U) and slightly enriched uranium (>1% 235 

### U). Impurities that may be present include 232 

### Th, 249 

### Cf, and trace amounts of other radionuclides. Isotopic Distributions for the MPFPDD Waste Stream Numerous references (e.g., P976) indicate that several isotopic distributions have been developed and used b y Hanford prior to CCP’s involvement, including distributions applicable to PFP. The Hanford characterization program used these distributions when mea surement values could not be obtained, and were used to characterize approximately 10% of the containers from the MPFPD waste stream (which is now included in the MPFPDD waste stream). Hanford developed these distributions by examining the AK records for 4,655 containers, and determining the three most frequent percent plutonium isotopic distributions processed at the 235 - 5Z complex, based on the percent of 240

### Pu identified on the drum records. The following distributions (shown in Tables 6, 7, and 8) were used by Hanford personnel, and were also adopted b y Hanford - CCP. Based on review of the AK record, these distributions are reasonable.

Table 6. Default 6 Percent Pu - 240 20 -Year Aged Mass Fraction Isotope Weight Percent Uncertainty (1 σ) Pu- 238 0.0 302 0.0030 Pu- 239 93.6784 9.3678 Pu- 240 6.0503 0.6050 Pu- 241 0.2211 0.0221 Pu- 242 0.0201 0.0020 Am - 241 0.5025 0.0502 

### Table 7. Default 12 Percent Pu - 240 20 -Year Aged Mass Fraction Isotope Weight Percent Uncertainty (1 σ) Pu- 238 0.0815 0.0082 Pu- 239 85.5498 8.5550 Pu- 240 13.2172 1.3217 Pu- 241 1.1210 0.1121 Pu- 242 0.0306 0.0031 Am - 241 1.7833 0.178316 

### Table 8. Default 23 Percent Pu - 240 20 -Year Aged Mass Fraction Isotope Weight Percent Uncertainty (1 σ) Pu- 238 0.0924 0.0092 Pu- 239 72.4474 7. 2447 Pu- 240 24.4844 2.4484 Pu- 241 1.6419 0.1642 Pu- 242 1.3340 0.1334 Am - 241 2.6167 0.2617 

### As discussed previousl y, Hanford - CCP AKEs acquired data for over 5 , 800 drums from the original MPFPD waste stream and related AK to evaluate the general radiol ogical composition of the portion of the waste stream that is currentl y emplaced at WIPP. The drums evaluated are assumed to be representative of the waste stream as a whole, but are biased toward waste contaminated b y WG Pu. Hanford - CCP AKEs indicated that the values obtained from the WWI S were almost entirely derived (approximately

90%) from actual measurements, and therefore did not rel y heavily on the above default isotopics. To evaluate whether actual measured data w ere well represented by the default isotopic values, Hanford - CCP AKEs developed the isotopic distribution of the emplaced waste stream that is primarily contaminated by WG Pu. The following weight percent distributions for MPFPD wastes in the WWI S were obtained: 241 

### Am

– 0.86%; 238 

### Pu

– 0. 05%; 239 

### Pu

– 91.18%; 240 

### Pu

– 8.39%; 241 

### Pu

– 0.29%; 242 

### Pu

– 0.09%. These values adequately correspond with Table 6 above, and the comparison verified that the default isotopic distributions used by Hanford - CCP match the measured values in the WWI S. Based o n this analysis, the potential isotopic composition of the waste stream is well understood, and the default isotopics were verified by measurement data. (3) Id entification of phys ical form including WMPs and prohibited items was assessed and found to be adeq

uate. Waste stream MPFPDD is composed of a variety of debris material represented by a host of activities including plutonium processing, waste treatment, incineration, and D&D activities. M PFPDD is comprised primarily of numerous organic and inorganic debris waste items. Potential debris items that may be present in the waste include, but are not limited, to metal tools, metal tanks, metal pipes/pumps, glass, glove box panels, hot plates, sample racks stirrers, burners, slip lid cans, un - tinned cans, torpedo levels, grease guns, aluminum foil, mask filters, leaded aprons, leaded gloves, lead tape, lead chromate paint, lead seals, fluorescent light bulbs, scraps from maintenance activities, glass thermometers, various glass tubes, vials, beakers, asbesto s pot liners, ceramic kitty litter, vermiculite, cardboard “ice - cream” cartons, PPE rags, wood, filter media, various rubber items, plastic items, and occasional absorbed or unabsorbed liquids. As indicated in Item (1) above, this range of activities may be considered separate waste processes or separate waste streams, but they have been grouped into a single waste stream because AK cannot differentiate the drums. The physical composition of the waste stream is described generally

in site records. However, wastes generated prior to 1970 have already been disposed of in WIPP as waste stream MPFPD, so the WWI S was reviewed by Hanford - CCP to develop an accurate picture of the waste streams’ physical composition.17



### The AKSR freeze file indicates that 5,856 c ontainers were certified for shipment from Hanford, but only 4,528 containers were actuall y shipped as of August 2009. WWI S records were examined by

Hanford - CCP representatives to determine the physical composition of the waste stream, noting that this po rtion of the waste stream is biased toward process waste, rather than D&D waste. These data showed that the waste stream is composed of more than 50% heterogeneous inorganic and organic debris, so a WMC of S5400, Heterogeneous Debris, was applied to this waste stream. To estimate the WMPs for waste stream MPFPDD, Hanford - CCP evaluated data for 4,994 of the 5,856 containers in the WWI S and NDE information from AK reference HNF - 36515. Based on this analysis, Hanford - CCP generated the WMP contents of the w aste that are presented in Table 9 below. This distribution is expected to change to include an increased percentage of metal as more D&D waste is included in the waste stream.

Table 9. Waste Stream MPFPDD Waste Material Parameters WMP Description Ave rage Weight Percent Weight Percent Range Iron -based Metals/Alloys 48% 0 - 100% Aluminum - based Metals/Alloys < 1% 0 - 83% Other Metals 5% 0 - 87% Other Inorganic Materials 8% 0 - 100% Cellulosics 12% 0 - 92% Rubber 9% 0 - 91% Plastics (waste material s) 18% 0 - 100% Organic Matrix < 1% -- Inorganic Matrix < 1% -- Soils/gravel < 1% -- TOTAL INORGANIC 61% TOTAL ORGANIC 39% 

### Hanford - CCP representatives indicated that phys ical composition information would be obtained through NDE of each container , which will also identify the presence of prohibited items (i.e., liquids). Based on this information, the phys ical composition of the waste stream documented in the WWI S is expected to agree with the material anticipated to be present in the waste stream as a whole. (4) AK procedural adequacy and implementation was assessed and found to be adequate (assembl y compilation, interpretation, confirmation, discrepancy resolution). CCP - TP - 005, Revision 18 is Hanford- CCP’s AK procedure. It includes processes and procedures for the following activities:

 AK Documentation Management  Compiling AK Documentation  Recording AK Documentation  Review and Submittal of AK Documentation18



###  Waste Stream Characterization  Determining AK Documentation Accuracy  Re - evaluating AK Do cumentation  Resolving AK Discrepancies  Updating AK for Additional Waste Stream Containers  Container Tracking Spreadsheet Development and Maintenance EPA examined the AK document management process used to acquire all available AK references (C, D, DR, M, P, U) pertinent to the waste stream, including new references that were recentl y added. EPA found that Hanford - CCP followed the procedure appropriately to record and review AK documentation. EPA questioned elements of the waste stream identification proc ess [see Item (5), below], and noted that data limitations are identified for each source document on the source document summary form. Hanford - CCP provided example DR forms as well as the container tracking spreadsheet for review. S everal attachments support these activities : Attachment 1

– Acceptable Knowledge Documentation Checklists Attachment 2

– Record of Communication Attachment 3

– Acceptable Knowledge Source Document Summary Attachment 4

– Acceptable Knowledge Source Document Reference List Attachment 5

– Hazardous Constituents Attachment 6

– Waste Form, Waste Material Parameters, Prohibited Items, and Packaging Attachment 7

– Radionuclides Attachment 8

– Waste Containers List Attachment 9

– Waste Characterization Data Cross - Reference Attachment 10

– Acceptable Knowledge Re - evaluation Checklist Attachment 11

– Acceptable Knowledge Source Document Discrepancy Resolution Form Attachment 12

– Form and Content Guide for AK Summary Reports Attachment 13

– CCP Waste Stream Characterization Checkl ist Attachment 14

– CCP Acceptable Knowledge Accuracy Report Only Attachment 5 is not relevant to EPA’s review. EPA was provided examples of relevant Attachments (see Attachment D ), which demonstrated Hanford- CCP’s ability to prepare these items. EPA f

ound it difficult to examine the AK Source Document Summaries separate from the Source Documents (they

are usuall y attached to the source documents), and recommends that Attachment 3 actually

be “attached” to the relevant source document as has been done at all other CCP sites. EPA determined that Hanford - CCP demonstrated the ability to follow the AK procedure for the elements examined. Notification of modification of CCP - TP - 005 Revision 18 is a Tier 2 change. (5) The AK Summary was assessed and found to b e adequate. The AK Summary

was examined to determine whether major technical components were present, and to ensure that the document adequately justified and described the waste stream.19



### Hanford - CCP representatives provided a freeze file modification representing changes in progress; these changes were appropriate and necessary to clarify the contents of the AKSR, Revision 2. EPA identified several concerns associated with the AKSR, and these were discussed with Hanford - CCP personnel and were incorporate d in an EPA Inspection Issue Tracking Form. These issues are summarized below (see Attachment C.4 for a cop y of this form): EPA Inspection Issue Tracking Form, Hanford - CCP - CH - AK- 10 - 004CR:

 Examine feed and other data for 232 - Z Incinerator to verify its inclusion in the waste stream.  Examine the use of “offsite sources” throughout the document.  In Section 4.6.1, modify the discussion pertaining to waste stream definition to include the lack of ability to correlate drums to specific PFP processes. Also modify Section 5.3 to indicate whether to -be - generated waste will be segregated upon generation or packaging.  Clarify

intent of last paragraph p. 30 regarding plutonium grades and defense waste.  Add information to Section 5.4.2 pertaining to the 6%, 12%, and 23% plutonium isotopic distributions as presented in AK Source Documents and the AK-NDA memorandum, including data that support generation of these distributions at the PFP, as well as other pertinent historical data.  Remove first sentence from the first paragraph in Section 4.5 regarding intent to segregate waste during packaging or repackaging, as it contradicts later statements.  Verify

number of HEHF (Emergency Decontamination Facility) drums and how it is included in the PFP drum population.  Add the total volume (cubic meters) of waste in inventory .  In the final paragraph of Section 5.4.2, add the second predominant radionuclide by activity , to be consistent with the previous portion of the sentence that identifies the two predominant radionuclides by mass. Resolution: Hanford - CCP provided a discrepancy resolution (DR013) documenting the gathering of information that adequatel y addressed the first bullet showing that only PFP material was processed through the incinerator facility . Also, Hanford - CCP modified the existing freeze file to remove or modify language pertaining to material managed in the 232 - Z In cinerator . The remaining issues were addressed through modification of the existing freeze file. Status of Concern : The response is adequate , EPA considers this issue to be closed. The AKSR will be updated to include information on the freeze file, which is in the AK Record, Notification of availability of modifications to the AKSR is a Tier 2 change.20



### (6) Drum traceability and the ability

to f ollow the AK waste characterization process for containers was assessed and found to be adequate. Drum traceability

data for drum Nos. 0056238 and 0063057 were examined, from initial AK documentation through Hanford - CCP characterization and drum management. Drum records examined for each included the following:

 Historic Documentation from the Hanford Site Records Storage Facility and Integrated Document Management System (IDMS), including TRU/TRU Mixed Waste Contents Inventory Sheet, Waste Designation Wo rksheet, Inspection Sheet for Loaded/Sealed TRU/TRU Mixed Waste Drum, Inspection Sheet for Empty 55 - Gallon Waste Drum, and Certificate of Conformance  Solid Waste Information Tracking S ys tem (SWITS) database records including the SWITS Container Listing Rep ort  TRU Electronic Data Management Tool (TRUEDMT) Database Print Outs  BDRs (NDA and RTR)  CCP Program Tracking System (PTS) printout

– each container These data indicate that historic information pertaining to waste drum content is available. EPA als o requested information about a container that had not yet undergone Hanford - CCP waste characterization. The Hanford- CCP AKE provided drum information for container 0055034. These data included additional information not available for the two Hanford - CCP D&D containers that had been characterized (0056238 and 0063057), because container 0055034 was generated in 1979 as a process waste. Information examined included SWITS database information, TRUEDMT database, Onsite Radioactive Shipment Records, and Sol id Waste Burial Records. These data indicated that drum No. 0055034 was not composed of S5000 debris but was instead a “solid sludge” per information on the drum record. EPA inspectors asked for additional information about this drum, including the Quick scan RTR that had been performed to verify the SCG. The Quickscan showed that the drum contained small containers that held some solidified material, but the small containers constituted much less than 50% of the drum by volume, so the overall drum content was composed of debris. In formation examined showed that Hanford- CCP personnel could obtain historic information for drums within the waste stream, had access to site screening to verify waste contents, and could trace information for the container from the AK record through the characterization process. (7) Defense origin of TRU wastes was examined and found to be adequate. TRU waste streams to be disposed at WIPP must be “defense” waste. Hanford - CCP states that based on DOE guidance, a waste is defense in origin if it has been generated “in whole or part by one of the atomic energy

defense activities listed in section 10101(3) of the Nuclear Waste Policy Act of 1982 (NWPA).” AK data indicate that PFP TRU waste is contaminated with radionuclides generated from energy defense activities, including defense nuclear material21



### processing and fabrication of plutonium for weapons, defense nuclear waste materials b yproducts management, and defense research and development. Based on the information provided in the AKSR, supporting references and the DOE’s guidance regarding defense waste, the waste stream is defense in origin. (8) Spent Nuclear Fuel and High - Level Waste Status was evaluated and found to be in compliance with the WIPP L and Withdrawal Act (LWA). The WIPP LWA prohibits the disposal of SNF and HLW as defined by the NWPA at WIPP. The NWPA states that SNF is “fuel that has been withdrawn from a nuclear reactor following irradiation, the constituent elements of which have not been separated b y reproce ssing. SNF may not include test specimens irradiated for research and development only (i.e., these may

be classified as waste when it is technically infeasible, cost prohibitive, or would increase worker exposure.” HLW is defined by the NWPA as “the highl y radioactive material resulting from the reprocessing of spent nuclear fuel, including liquid waste produced directly in reprocessing and any solid material derived from such liquid waste that contains fission products in sufficient concentrations, and other highl y radioactive material that the Commission, consistent with existing law, determines by rule requires permanent isolation.” The AKSR and Hanford - CCP AKEs indicate that PFP did not reprocess spent nuclear fuel, as waste contains only unirradiate d materials derived from testing and other sources. Therefore, the waste is not SNF and because SNF was not reprocessed at PFP, HLW could not have been generated. EPA concurs that the data provided in the AKSR support this determination. (9) Waste Stream P rofile Form (WSPF) preparation and completeness was evaluated and found to be adequate. A draft WSPF was provided for EPA review to demonstrate Hanford - CCP’s ability to prepare this required document. The WSPF includes the Profile Form, Characterization In formation Summary (CIS), DQO Reconciliation Checklist, and Summation of Aspects of the AK Summary Report: MPFPDD. Comparison of the WSPF with the AKSR revealed discrepancies with respect to the exact number of containers in the waste stream (containers versus drums and SWBs). Also, the WSPF references Revision 1 of the AKSR; Revision 2 is now in effect. When the final WSPF is prepared, EPA expects that the correct AKSR will be referenced, and all necessary changes to tables, figures, and section references will be made as necessary and references will be added to the Supplemental Document listing on the WSPF. A draft WSPF does demonstrate Hanford - CCP’s ability to prepare this document and associated attachments. Notification of availability of all final WSPFs with related attachments is a Tier 2 change. (10) Staff training was examined and found to be adequate. Training documentation for the following personnel was provided: The qualification cards were provided for the SPM, Natasha McCants, and two AKEs -- Sherri Nance and Steve Schafer. These cards indicated that Ms. McCants had been trained to the appropriate procedures, but there was no indication she had been trained to the specific AK Documents (e.g., AKSR) associated with the EPA inspection. The Qualification Cards for Ms.22



### Nance and Mr. Schaffer were signed in 2004 and 2003, respectivel y, and did not indicate training had been accomplished to the most recent regulatory documents or internal procedures (e.g., WAP, WAC, CCP - TP - 005 and EPA’s CRA) . Hanford - CCP provided information to indicate that Ms. McCants had been trained to the appropriate AKSR, but documentation to indicate that Hanford - CCP AKEs were trained to the most recent versions of procedures, particularl y CCP - TP - 005 Revision 18, was not available. The objective evidence indicates that AKEs are familiar with the relevant waste characterization procedures, but documentation also must be available to demonstrate that the AKEs have been appropriatel y trained to the most recent versions o f these procedures. EPA will verify the paperwork at future inspections. Notification of availability

of successful training is a T2 change. (11) Preparation of NCRs was evaluated and found to be adequate. Several NCRs have been generated for this waste s tream. Issues addressed through the NCR process include identification of impenetrable items (i.e., lead lining or materials obscure RTR examination of drum contents), presence of liquids, presence of prohibited items (i.e., disposable lighter), sealed co ntainers greater than 4 liters, and measurement less than 100 nCi/g TRU. In all of these instances, the example NCRs provided rejected the drum and returned it to the Host Site for remediation or other disposition. The examples provided show that Hanford - CCP satisfactoril y documents the NCR process. (12) AK accuracy

was assessed and found to be adequate. Hanford - CCP provided an Acceptable Knowledge Accuracy report for the MPFPDD Waste Stream, Lot 1, which included only 10 drums. This report noted that the AKSR identified 238 

### U and 239 

### Pu as the most predominant radionuclides by weight, but 239 

### Pu and 240 

### Pu were the most predominant radionuclides by weight for the 10 containers. The AK Accuracy report concludes that if this situation is persistent through the waste stream, revision of the most prevalent radionuclides within the AKSR would be warranted, but an AK re - evaluation was not performed at this time. The physical composition of the waste stream agreed with what was presented in the AKSR. Provision of this report demonstrates Hanford - CCP’s ability to prepare this document and implement AK accuracy calculations per CCP - TP - 005 Revision 18. Notification of the availability

of all AK Accuracy

Reports is a T2 change. (13) Load management was found to be not applicable. Hanford - CCP AKEs indicated that load management would not be performed on waste under the Hanford - CCP program. Performance of load management is a Tier 1 change. (14) NDA - AK communication was assessed and found to be adequate. CCP - TP - 005 Revisio n 18, Section 4.4.22 requires the preparation of an NDA memorandum that evaluates the radionuclide characterization of the waste stream. The memorandum is required to include a section that shows how NDA personnel will apply AK during assay . The memorand

um addresses limitations associated with AK- based information, and must also include a description of the assay methods, and also requires that NDA issues (for both measured23



### and calculated radionuclides) should be discussed and resolved. The NDA memorand um for CCP - AK- RL - 101 MPFPDD waste first describes the isotopic information based on AK data derived through AK record examination and through WWI S data collection and anal ys is. The memorandum also describes limitations associated with the AK data, and how the AK data will be applied during assay . Additionally , the memorandum presents how 242 

### Pu, 234

### U, and 90 

### Sr will be determined, and discusses potential gamma spectrometry and neutron interferences. The NDA memorandum is an excellent way to document how AK is used in the NDA process, and serves as an important link between the two characterization programs by providing identical information to both AK and NDA personnel. Notification of revisions to this NDA memorandum and the availability of any NDA memorandum is a T2 change. (15) Data management was evaluated and found to be adequate. Hanford - CCP AKEs indicated that they could obtain data from the site through various sources. These include:

 SWITS, which presents radiological, physical, and chemical data on a container basis  Hanford Site Records Storage Facility (Hard Copy Files) and related Integrated Document Management System (IDMS) that includes scanned versions of hard- cop y files  TRU Electronic Data Management Tool, which is a Hanford database that documents drum history

up to acceptance b y the characterization facility (CCP) Hanford - CCP generates a full list of all containers in the waste stream and presents these drums on CCP - TP - 005 Attachment 8. Hanford - CCP also maintains the AK Container Tracking Spreadsheet per CCP - TP - 005 Revision 18, which keeps track of individual drum status including Container I.D., Waste Stream I.D. Generation Date, Vent Date, Change Reason (for vent date), New Closure Date, New Vent Date, and Container Ty pe. Hanford - CCP posts the Container Tracking Spreadsheet to the file transfer protocol (ftp) site and EPA has access to this site. This spreadsheet (and Attachment 8) is updated as new containers are added to the waste stream. Hanford - CCP also keeps detailed records of container characterization status, including the presence of NCRs that might have been issued for a container. This is CCP’s PTS (Program Tracking S ys tem), and NCRs are also tracked in the system. Information from the PTS is used to populate the WWI S . Based on this information, historical data are available to the Hanford- CCP AKE, and Hanford CCP, as part of the characterization process, uses information from the site. Hanford - CCP tracks each container from the site systems through its own internal s ys tem, which in turn provides information to the WWIS. The data management system observed adequately tracked and managed evaluated information. (16) The integration of previous site documents into the Hanford- CCP process was examined and was found to be satisf actory . EPA first approved the Hanford Site in September of 2002, with a later baseline approval of the Hanford Program in 2007. The Hanford Site program was terminated in 2009, and CCP took24



### over the characterization responsibilities. The Hanford TRU w aste characterization program has a tremendous amount of information in hard cop y documents, electronic data, and human intellectual capital available to Hanford - CCP that should serve as a starting point for Hanford CCP’s characterization program. Examination of data available for the first debris waste stream characterized b y Hanford - CCP (MPFPDD) shows that many of the references available with Hanford TRU program have been integrated into the Hanford- CCP documentation system. Also, waste databases are available to CCP personnel. CCP used the site’s AKSRs for MPFPD and RLPFPCD waste stream to create the larger CCP - defined combined waste stream MPFPDD. Many of the references and concepts in both reports were rooted in Hanford’s original program. CCP should rely

on this information and examine all references and data to ensure that Hanford CCP defined TRU wastes have complete pedigree and ownership as “their own” stand - alone program. Integration of site documents and activities is a work in progress, and is expected to proceed in a satisfactory

manner. Summary of AK Findings and Concerns The EPA inspection team did not identify any findings related to AK during this inspection. EPA did identify

the single concern that is discussed above. A copy of th e EPA Inspection Issue Tracking Form documenting this concern is provided in Attachment C.4 to this report. EPA considers this concern to have been adequatel y addressed and there are no open findings or concerns related to AK resulting from this inspectio n. Proposed Baseline Approval EPA is proposing to approve the AK s ys tems evaluated during this baseline inspection as described in this report for CH retrievably- stored and newl y- generated TRU debris (S5000). Application of the AK process described in this report to wastes other than these is a T1 change. (See Table 1 where this is included as a T1 change). AK Tiers Based on the inspection and results discussed above, EPA assigns the following tiers: T1 AK changes will require EPA review and app roval prior to implementation and will apply to any new waste category

not evaluated during the baseline inspection. These include the following:

 Categories of waste not approved under this baseline inspection (e.g., S3000 and S4000 wastes)  Implementation of load management Hanford - CCP must report and submit documentation on T1 changes when it is ready for EPA review and approval. Upon initial review, EPA will inform Hanford- CCP and CBFO whether a site inspection is necessary . EPA may request additi onal information, choose to conduct a desktop review, and/or confer with Hanford- CCP personnel. Upon AK evaluation with or without site inspection, EPA will issue a decision. Only upon receiving EPA written approval may Hanford - CCP characterize and dispo se of the new waste at the WIPP.25



### T2 AK changes do not require EPA approval before implementation, but require that HanfordCCP provide notification to EPA upon completion of the following:

 Modification of CCP - TP - 005 Revision 18  Availability

of modifi cations to the AKSR  Availability

of all final WSPF with related attachments  Availability

of all AK Accuracy

Reports  Availability

of successful training records  Revisions to the NDA memorandum for MPFPDD, and availability of any NDA memorandum 8.2 Nondestruc tive Assay (NDA) Waste Characterization Element Description During this inspection, EPA inspected two NDA systems located at the Waste Reprocessing and Packaging (WRAP) Facility : the Canberra Gamma Energy Anal ys is System Units A and B (GEA - A and GEA - B). Documents Reviewed The GEA - B Unit was refurbished and recalibrated in March 2006, following which both GEA systems were equivalent in terms of their measurement capability . The checklist in Attachment A.2, in conjunction with the documents listed below , comprise the documents that were examined in assessing GEA Units A and B during this inspection:

 CCP - TP - 070, CCP Gamma Energy Assay (GEA) Calibration, Confirmation and Verification Procedure, Revision 0  CCP - TP - 071, CCP Gamma Energy Assay (GEA) Operating Procedure, Revision 0  CCP - TP - 072, CCP Gamma Energy Assay (GEA) Data Review, Validation, and Reporting Procedure, Revision 0  GEA Units A and B Radionuclide Listing Library , Filename: C: \GENIE2K\CAMFILES \CCPWRAP.nlb, generated April 37, 2010  ASTM C 1133

– 0 3, Standard Test Method for Nondestructive Assay of Special Nuclear Material in Low-Density Scrap and Waste by Segmented Passive Gamma -Ray Scanning  Use of Isotope Correlation Techniques to Determine 242

### Pu Abundance , R. Gunnink, 1980  GEA - A 104 -ND - 06 - 102A Calibration Verification, March 9, 2010  CCP - AK- RL - 101 MPFPDD DNA Memo, Evaluation of the Radiological Characterization of Hanford Site Waste Stream MPFPDD, Revision 2, March 17, 2010  HNF - 5148, EDC - 05 - 25965, Calibration Report for the W RAP Facility Gamma Ener gy Analysis (GEA) System , May 16, 200526



###  Hanford - CCP Li st of Qualified Individuals, NDA GEA, April 14, 2010, 11:32 AM  CCP - RL - GEA - 003, Total Measurement Uncertainty (TMU) for the Gamma Energy Assay S ys tems  CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA ) System Unit A Calibration, Confirmation and Verification Report  CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report  GEA - A S ys tem Notebook RL -NDA - GEA - A - 003, Assigned b y Susan Keathley , January 5, 2010, Building 2336W, Area 200 W; Users

– Brett Templeton, William Williams, Jeremy Heath, Alan, Shumaker, Mike Maul; Dail y Activities

– Verify CCP - TP - 071, Revision 0; NDA 2K Version 4.0  GEA - B System Notebook RL -NDA - GEA - B - 004, Assigned b y Susan Ke athley , January 5, 2010, Building 2336W, Area 200 W; Users

– Brett Templeton, William Williams, Jeremy Heath, Alan, Shumaker, Mike Maul; Dail y Activities

– Verify CCP - TP - 071, Revision 0; NDA 2K Version 4.0  GEA A BDR RLGEAA0001  GEA A BDR RLGEAA0002  GEA A BD R RLGEAA0003  GEA B BDR RLGEAB0001  GEA B BDR RLGEAB0002  GEA B BDR RLGEAB0003 Technical Evaluation Both of these NDA s ys tems had been evaluated and approved b y EPA as part of the Hanford TRU program previously in 2003 and 2005 (see Docket Nos. A - 98 - 49, II - A4 - 41 and A - 98 - 49, II A4 - 58, respectivel y) at the WRAP facility . The detailed technical basis for each s ys tem’s operation is described and detailed in the EPA inspection reports cited above. Since GEA Units A and B had undergone hardware changes and sof tware upgrade(s), they

had been partially recalibrated and both s ys tems are essentially equivalent in terms of measurement capability . Both systems had been operational for WIPP assays prior to this inspection and both were re evaluated during this inspection. The EPA inspection team evaluated the following aspects of both systems:

 Design and technical capability of the measurement hardware and software to perform the required anal ys es  Adequacy

of the assay

program’s documents and procedures to provide technical support to EPA approval  Knowledge and understanding of the personnel involved in the NDA program27



### Hanford - CCP NDA personnel stated that the GEA - A and GEA - B Units have not changed or been modified in any significant way since EPA last inspected them during the Hanford baseline inspection of 2007. The EPA Inspection Team confirmed this by direct evaluation of both systems, technical documentation, and other records during this inspection. EPA assessed the technical elements of the WRAP GEA Units A and B that are discussed below. (1) The design, operation and personnel associated with GEA Units A and B were assessed and were found to be adequate. The GEA Units A and B (GEA - A and GEA - B) are housed in the WRAP facility . Each s ys tem consists of six gamm a detectors: four are Standard Electrode Germanium (SEGe) detectors for quantitative anal ys is; and two are Low - Energy Germanium (LEGe) detectors used for isotopic anal ys is based on photons in the 45 to 300 keV range in conjunction with Multi Group Analy si s (MGA), MGA Uranium (MGA - U), and FRAM (Fixed - energy Response Function Analysis with Multiples Efficiencies) software. The choice of software is at the discretion of the NDA Expert Analyst (EA). AK -based or default isotopics are used when measured isotop ics cannot be supported and onl y for waste streams that have an approved set of default isotopics. The SEGe detectors address matrix correction by using four highl y collimated 152 

### Eu sources located directly opposite the SEGe detectors and at a right angle (90°) to the LEGe detectors. Both systems operate under the GENIE2000/NDA2000 software and include shielded enclosures, drum elevation and rotation equipment, and ancillary electronics. The systems have two operational modes, a shielded and unshielded geometry , and there are limitations to both modes that are applicable to actual waste containers that are discussed in the calibration report for each system. These modes are used depending on a container’s Pu loadings, enhanced 241 

### Am levels, or signific ant count rates from other fission products. The main difference results in the choice of 239 

### Pu line (129 keV or 414 keV) for quantitative anal ys is. Additionally , there is an option regarding the use of the individual horizontal segments of a container’s assay

or summing all horizontal segments over the container’s vertical height . These choices are incorporated in the system’s software, but are routinel y evaluated by the NDA AK during data validation, and the software’s choices can be overridden. The GEA units produce data for 238 

### Pu, 239 

### Pu, 240 

### Pu, 233 

### U, 235 

### U, and 238 

### U over a mass range from 0.010 g to 345 g of nominal WG Pu, i.e., 6% 240 

### Pu. Technically based correlations (scaling factors) are used to derive values for 234

### U, 137 

### Cs, and 90 

### Sr; 242 

### Pu is determined using the correlation techniques of Gunnink. There are no technical issues associated with the design, operation, and personnel associated with GEA Units A and B. The use of new, unapproved NDA equipment at WRAP or physical modifications to the WRAP GEA Units A and B observed during this inspection is a T1 change. (See Table 1 where this is included as a T1 change.) (2) System calibration and calibration confirmation of the GEA Units A and B had been performed as required. The calibration of the GEA Units is documented in CCP - RL - GEA_A - 001 (GEA - A) and CCP - RL - GEA_B - 001 (GEA - B). Both GEA units have energy and peak shape calibrations that had been performed previously as documented in HNF - 5148, both of which were verified and documented b y Hanford - CCP . New multi - curve and transmission (shielded) efficiency28



### calibrations were performed for both GEA units using six mixed - gamma line sources containing 152 

### Eu/ 137 

### Cs/241 

### Am in four 55 - gallon (208 - liter) matrix drums containing foam, soft board, particle board and sand that spanned a density range of 0.011 to 1.56 g/cc. Both systems use tin shields approximately

1/32” thick on the SEGe detectors to reduce s ys tem dead time resulting from high 241 

### Am concentrations associated with aged plutonium, and the 152 

### Eu transmission sources are aligned to obtain transmission data on all vertical segments of the SEGe detectors of each s ys tem. Calibration confirmation was performed using Pu sources other than the 152 

### Eu/ 137 

### Cs/241 

### Am sources used for calibration, as required. H anford - CCP NDA personnel provided objective evidence of the appropriate pedigree for all WG Pu sources that is documented in each s ys tem’s calibration report. The calibration confirmation sources consisted of WG Pu sources in a variety of gram values that were combined to produce the following masses: 9.0 g, 130.0 g and 265.0 g. The system passed all calibration confirmation criteria except for the 9.0 WG Pu in the shielded transmission corrected mode, due to poor counting statistics on the Pu lines at 1 29, 203 and 375 keV. However, this mode would not be used for routine assays and the multi - curve data that were collected simultaneously yielded acceptable results. With the one exception for the 9.0 g WG Pu standard in the shielded transmission mode dis cussed above, all calibration confirmations passed the criteria for accuracy and precision. There are no technical issues with the calibration and calibration confirmation of GEA Units A and B. Regarding routine performance testing of the GEA - B, EPA identified a discrepancy in the documentation of the Summed 239 

### Pu Mass Daily Standard. EPA discussed this concern with Hanford - CCP NDA personnel and incorporated it in an EPA Inspection Issue Tracking Form. The issue is summarized below (see Attachment C.3 f or a cop y of this form). EPA Inspection Issue No. Hanford - CCP - CH -NDA- 10 - 003CR: The controls limits for this parameter were developed on the basis of nine data points using the Student’s T Test (n = 9), which resulted in fairly

tight control limits, as expected. When additional data had been accumulated, the limits were recalculated using the Student’s T Test (n = 31), which resulted in broader control limits, as expected. However, the newer limits were not conveyed to the appropriate personnel and the n ewer assays were subjected to the old limits. This is not a performance issue, since all assays passed the tighter (more restrictive) limits. However, it indicates a breakdown in communication within the NDA group, as well as a lack of appropriate contro l over fundamentally important performance data. This affected all GEA - B BDRs that were generated to date. Resolution: Hanford - CCP NDA personnel took the GEA - B Unit out of service pending a complete investigation regarding the cause of this incident and committed to training all NDA personnel on the correct application of control limits, including their documentation. All GEA - B BDRs will be amended and reissued, as required. Status of Concern: EPA considers this concern to be closed. Extension or changes to approved calibration range for the WRAP GEA Units A and B is a T1 change, (See Table 1 where this is included as a T1 change.) Also, notification to EPA upon completion of changes to software, operating range(s) and site procedures for the WRAP GEA29



### Units A and B that require CBFO approval is a T2 change and requires EPA notification. Consistent with EPA’s authority under 40 CFR 194.24(h), EPA may request this information if EPA deems it necessary

to ensure continued compliance with EPA regulations . (See Table 1 where this is included as a T2 change.) (3) The total measurement uncertainty (TMU) of assays performed on the GEA - A and GEA - B had been adequately determined and documented. The determination of the TMU of assays performed on the GEA Units A and B is documented in CCP - RL - GEA - 003, Total Measurement Uncertainty (TMU) for the Gamma Energy Assay Systems. The components of uncertainty included in the TMU determination included calibration source uncertainties, counting statistics, self - absorption effects, matrix non homogeneities, non - uniform source distributions, and isotopic measurement uncertainties. There are no issues with the determination and documentation of TMU for GEA - A and GEA - B. (4) The lower limits of detection (LLD) of the GEA - A and GEA - B had been adequatel y determined and documented. The LLD is defined as “that level of radioactivity which, if present, yields a measured value greater than the critical level with a 95% probability , where the critical level is defined as that value which measurements of the background will exceed with 5% probability .” The LLD of any given NDA measurement is likely to depend on the ty

pe of measurement, the properties of the waste matrix being assayed, and the environmental background. For this reason, th e LLD will vary from drum to drum and may even vary

between measurements of the same drum. The GEA - A and GEA - B systems must report an LLD for each of the ten WIPP - tracked radionuclides. Onl y measured values that exceed the reported LLD for that measurement will be reported and used in calculations of derived quantities, such as total TRU alpha activity and TRU alpha activity

concentration. The LLD values for all operational modes (transmission - corrected and multi - curve) are documented in the calibratio n report for each s ys tem. Both reports provide data that indicate that the LLDs for both GEA s ys tems are below 100 nCi/g for wastes with a net weight over approximately 11 kg (density

about 0.055 g/cc). This limit has been incorporated in the Automated Independent Technical Review (AITR). Both GEA units have the required sensitivity

to make TRU/Non - TRU determinations in accordance with the 100 nCi/g TRU criterion. There are no technical issues with the determination and documentation of the LLD for the GEA - A and GEA - B units. (5) The GEA Units A and B are scheduled to participate in the CBFO - sponsored NDA Performance Demonstration Program (PDP). Both GEA Units are scheduled to participate in Cycle 17A (May 2010 distribution) of the CBFO - sponsored NDA PDP, b y assaying S5000 wastes containing debris, glass, and sludge. EPA will evaluate the results of these assays when they become available.30



### (6) EPA replicate testing of the GEA - A and GEA - B Units was performed and evaluated and found to be adequate. The purpose of the replicate testing performed as part of this inspection is to provide the EPA with an independent means to verify that the GEA - A and GEA - B Units can provide reproducible results for the determination of the quantity of ten 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. EPA selected replicate testing drums from the list of previously measured drums on each s ys tem. This is accomplished b y reassaying drums previously me asured on the same s ystem in order to demonstrate the s ys tem’s ability to do the following:

 Produce results consistent with the reported TMU by comparing the sample standard deviation for a number of replicate measurements taken over several hours or days to the reported TMU; and  Provide reproducible results over longer periods of time, such as weeks or months, by comparing the results of the replicate measurement(s) to the original reported values. As part of the inspection to evaluate the GEA units, EPA requested that each GEA unit reassay three drums that EPA randomly selected from a list of previously assayed drums. EPA chose container Nos. RL0063023, RL 0050614 and RL0063005 for GEA - A and RL0063034, RL0056338 and RL062952536 - 8 - 37 for GEA - B. All six drums were reassayed on the respective GEA unit five times and the data for the five replicates and the original assay were anal yz ed using two statistical tests, a Chi- Squared (χ 2 

### ) Test and a t Test . Data and results of the statistical anal ys is for both units are included in Attachments B.1 through B.4.12 and the results are summarized below. GEA - A:  Container No. RL 0063023: The five replicate 241 

### Am results for this container had a tight grouping the average of which was sufficiently different from the ori ginal assay to trigger a “Significant” flag for the t Test . For 237

### Np, the five replicates showed four results that were less than the MDA and one reportable (greater than MDA) value, which triggered the “Significant” flag. The actual differences amon g these assay values are small and these results are consistent with what has been observed on other NDA systems. Both issues reflect the inherent weakness of the statistical tests and neither issue bears further investigation at this time.

 Container No. RL0050614: The 137 

### Cs and 90 

### Sr results showed a “Highl y Significant” flag for the Chi- Squared Test . Since 90 

### Sr is scaled to the measured 137 

### Cs value any flag that is reported should be noted for both radionuclides. The replicate and original 137 

### Cs values are low and are subject to considerable variations, which triggers the “Highl y Significant” flag. The 241 

### Am and TRU Alpha Activity showed “Highly

Significant” flags for the t Test . The actual variability occurred for the 241 

### Am value, which is incorporated in the TRU Alpha Activity. The five replicates were grouped tightl y with a mean activity values that was approximately 60% higher than the original assay , which translated to a 17% increase in TRU Alpha Activity . The 241 

### Am variation appears to be a tr ue difference although both the original and replicate assays are acceptable by all reported31



### measurement parameters. There are several possible explanations for this discrepancy , including positional changes of the 241 

### Am -bearing items within the waste container due to handling, which could cause elevated readings due to a better counting geometry . No further actions are warranted at this time although EPA may choose to revisit this issue with Hanford - CCP at a later date. GEA - B:  Container No. RL 0063034: The Chi- Squared Test and t Test values exhibited variances that were less than or equal to the limits of both statistical tests.

 Container No. 0056338: The Chi- Squared Test and t Test values exhibited variances that were less than or equal to the limits of both statistical tests.

 Container No. RL 062952: The Chi- Squared Test indicated two “Highl y Significant” flags, one for 238 

### Pu and one for 242 

### Pu, and a “Significant” flag for the t Test for 239 

### Pu. Due to the low activity levels for these radionuclides, there was considerable variation in the isotopic determinations assigned b y MGA. This caused differences in the isotopic contribution of 240 

### Pu (13% versus 17%), which is then propagated through 238 

### Pu, 239 

### Pu and 242 

### Pu isotopes. We have observed this prob lem previously , especiall y with low Pu content drums where MGA runs poorl y and a small absolute difference (4%) produces what appear to be large differences. There are no technical issues associated with replicate testing of GEA Units A and B. Summary of NDA Findings and Concerns The EPA inspection team did not identify any findings related to NDA during this inspection. EPA did identify

the single concern that is discussed above. A copy of the EPA Inspection Issue Tracking Form documenting this concern is provided in Attachment C.3 to this report. EPA considers this concern to have been adequatel y addressed and there are no open findings or concerns related to NDA resulting from this inspection. Proposed Baseline Approval EPA is proposing to approve the NDA s ys tems evaluated during this baseline inspection as described in this report for CH retrievably- stored and newl y- generated TRU debris (S5000). NDA Tiers Based on the inspection and results discussed above, EPA assigns the following tiers: T1 NDA changes will require EPA review and approval prior to implementation and will apply to any NDA s ys tem not evaluated during the baseline inspection. These include the following:

 The use of new, unapproved NDA equipment at WRAP or physical modific ations to the WRAP GEA Units A and B observed during this inspection  Extension or changes to approved calibration range for the WRAP GEA Units A and B32



### Hanford - CCP must report and submit documentation on T1 changes when it is ready for EPA review. Upon initial review, EPA will inform Hanford - CCP and CBFO whether a site inspection is necessary . EPA may

request additional information, choose to conduct a desktop review, and/or confer with Hanford - CCP personnel. Upon evaluation with or without site inspection, EPA will issue a decision. Only upon receiving EPA written approval may Hanford - CCP use the new NDA s ys tem for characterization of TRU wastes intended for disposal at the WIPP. T2 NDA changes do not require EPA approval before implementation but re quire that Hanford CCP provide notification to EPA upon completion of changes to software, operating range(s) and site procedures for the WRAP GEA Units A and B that require CBFO approval. 8.3 Real- Tim e Radiography (RTR) Waste Characterization Element Description As part of the inspection of the RTR activities, the EPA inspection team focused on overall procedural technical adequacy and implementation, as well as the identification of WMPs and prohibited items, in reviewing the following RTR elements:

 Documentation of RTR activities through use of an approved procedure  Proper execution of RTR activities  Management oversight and independent review of RTR activities  Training of RTR personnel The RTR facility

uses radiography to help determine the following a spects of TRU waste characterization:

 Ty pes and amounts of WMPs  Confirmation of the WMC  Presence or absence of prohibited items  Demonstration of capability testing for operators on the RTR system using specificall y placed items Documents, BDRs, and Obj ective Evidence Reviewed The following documents were among those the EPA inspection team examined to assess whether all RTR operations follow the appropriate approved procedures:

 CCP - TP - 053, Revision 7 , CCP Standard Real - Time Radiography (RTR) Inspectio n Procedure, October 21, 2009  CCP - TP - 028, Revision 3, Radiography Test and Training Drum Requirements, January 19, 2006  CCP - QP - 002, Training and Qualification Plan, Revision 27, September 30, 2008  CCP - QP - 005, TRU Nonconforming Item Reporting and Control, Revision 18, August 13, 200933



###  Standing Order CCP - SO - RL - 01, April 14, 2010  CCP - QP - 008, Records Management, Revision 15, October 28, 2009 The following is a complete listing of all objective evidence the EPA team evaluated during the inspection:

 RTR BDRs and a

udio/visual recording of RTR events for selected drums contained in BDRs RLRTRA0001, RLRTRA0002, and RLRTRA0003  NCR- RL - 0642 - 10  Written and audio/visual recordings of Capability Demonstration Data Sheet for Contact Handled Waste for various RTR operators  Qualification card and training records for three RTR operators/ITRs  CCP NDE Test Drum Inventory Sheet for HAN -NDETEST - 02, - 03, and - 04  List of currentl y qualified RTR personnel  Measurement Conversion Chart Technical Evaluation During the inspection, the EPA inspection team evaluated the technical elements of the RTR process using the checklist included as Attachment A.3 to this report . These areas are summarized as follows: (1) Overall procedural technical adequacy and implementation were considered and wer e found to be acceptable. The RTR procedure, documented in CCP - TP - 053, Revision 7 , Standard Real - Time Radiography (RTR) Inspection Procedure , contained specific information on performing non - intrusive radiography, including operational setup and checkout, identification of prohibited items, assignment of WMPs and estimation of weights and volumes, confirmation of WMCs, input of data, issuance of NCRs, and technical review of radiography results. (2) Characterization of WMPs and prohibited items was asses sed and was found to be adequate. Procedure CCP - TP - 053, Revision 7 , require s that radiography audio/visual recording equipment verification be performed at the beginning of every shift in which drums are subject to examination. EPA inspectors confirmed adherence to verification requirements through interviews with RTR operators, observation of an RTR event, and review of written BDRs and audio/video tapes . There are two RTR units, A and B, at Hanford operated by CCP’s RTR personnel for characterizing phys ical contents (i.e., WMPs) of individual 55 - gallon drums and both of these were included in the scope of this inspection.34



### At the beginning of a shift , and before examining any waste containers, the operator runs a scan on the lines -pair resolution test gauge to determine that images are clearl y visible. On the day of the inspection, the operator had performed this check before EPA arrived at the facility , but the inspectors reviewed the image quality check for Batch RLRTRA0025 . This check was determin ed to be acceptable and met Hanford- CCP requirements. The operator had a cop y of the waste stream description available for review , and was able to answer questions regarding the WMC assignment. For each container undergoing examination, the operator makes an audio/video recording of the RTR event. The first notations that the operator makes on the audio/video recording are the drum number and the date and time on the audio/video recording before beginning the radiography process. The examination of the drum begins at the top of the drum where the operator identifies the seal and vent. The drum rotates through 360 degrees so that all objects inside a drum are visible from all sides. The operator can zoom both in and out and increase or decrease the scan energy

in order to compensate for varying densities in the material being examined. During examination, the operator also “rocks” the drum to determine the presence of free liquids. The RTR operator identifies WMPs, and a second staff member enters t he data electronicall y into the RTR Data Sheet. This second person was an RTR operator in training and performs only data entry at present . The waste stream being generated and processed in the PFP Building is MPFPDD, which is a debris (S5000) waste stre am. There is a standardized weight table (Table 3) in the standard operating procedure that provides weights for commonly encountered waste items. WMP weight estimates are made and recorded on the data sheet. The tare weight for containers is obtained f rom standing order CCP - SO - RL - 01. As part of the inspection, the EPA team observed the examination of waste container RL0056204, which formed part of batch RLRTRA0025. The EPA inspectors also reviewed the audio/visual recordings of c ontainer RL 0063057 and the Independent Observation for this container. EPA determined that the QC performed was appropriate and that information on the audio/visual recording matched the written RTR record (BDR). During the on - site demonstration, the operator used an uncontro lled method to calculate the volume of liquid found in the folds of plastic within the drum. EPA discussed this with Hanford- CCP RTR personnel and generated an EPA Inspection Issue Tracking Form to address this issue. The issue is summarized below (see Attachment C.3 for a copy of this form): EPA Inspection Issue No. Hanford - CCP - CH - RTR- 10 - 001CR: The RTR operator used a “Measurement Conversion Chart” to calculate the volume of liquid identified during RTR examinations and made process decisions based on the result. This chart is not a controlled document and the calculation used is incorrect. EPA is concerned regarding the origin and prevalence of this practice. Resolution: Hanford - CCP responded that the RTR characterization process to date relies on operator training, judgment, and experience to estimate liquid volumes and that this subjectivity is recognized in the EPA suggested training manual. Hanford- CCP also stated that since the RTR characterization requirements recognize estimations of liquid volume as sufficient,35



### controlling common geometric conversions and subsequent arithmetic operations as part of the permanent record is beyond the scope of the requirement. RTR operators are encouraged to use additional techniques to better identify free l iquids and quality

controls, including ITR review, are in place to identify

discrepancies in free liquid volumes and correct any estimation errors. Hanford - CCP pointed out that as the referenced mis - calculation had not been through the entire review proce ss, there is no way to know if the operator mistake would have been identified and corrected. On the basis of discussions between CBFO and EPA following the onsite inspection, this concern was addressed. EPA requires that when es timating observable, free liquid in a CH container, if a mathematical equation is used to calculate the quantities of liquid, the calculation must be documented so it can be verified b y another RTR operator, an independent technical reviewer, or a technical auditor and/or Federal inspector. CBFO understands and accepts EPA’s requirement for RTR. Status of Concern: EPA considers this concern to be closed. RTR performed for any new waste category groups or equipment ty pe(s) that w as not evaluated during the baseline inspection is a T1 change and will require EPA review and approval prior to implementation. A specific example is the use of a high - energy RTR unit different from those that are included in the baseline approval. See Table 1 where this is included as a T1 change.) No tification to EPA upon completion of modifications to approved equipment , RTR units A and B , changes made to RTR procedure(s) that require CBFO approval and the addition of new SCG to the RTR processes that are subject to this approval are all T2 changes that require EPA notification. Consistent with EPA’s authority under 40 CFR 194.24(h), EPA may request this information if EPA deems it necessary to ensure continued compliance with EPA regulations. (See Table 1 where this is included as a T2 change.) (3 ) Documentation of radiography activities was examined and was found to be adequate. Simultaneous written and audio/vi sual recordings are made as the waste is examined. The EPA inspectors observed this during the examination of waste container RL 0056204 and further verified it b y review of RTR BDRs and audio/visual recordings . RTR data are entered electronically

into Attachment 2, CCP Radiography Data Sheet, from procedure CCP - TP - 053 as they are generated.36



### (4) EPA ascertained that documentation of radio graphy procedures was adequate. Radiography procedures are well defined and the documents are controlled. During the inspection, the EPA team reviewed the adequacy and implementation of all radiography- related procedures. QC examinations were performed as required b y the procedure. In b atch RLRTRA0001 , an independent observation was performed on c ontainer RL0037205 and a replicate scan was performed on c ontainer RL 0063057; in b atch RLRTRA0002 , an independent observation was performed on c ontainer RL 0058 636 and a replicate scan was performed on c ontainer RL 0066836; and in b atch RLRTRA0003 , an independent observation was performed on c ontainer RL 0066877 and a replicate scan was performed on c ontainer RL0062953 . Although NCRs were not available for revie w in BDRs RLRTRA0001, RLRTRA0002, and RLRTRA0003, the operator interviewed was able to describe how NCRs are initiated and documented. To verify

this information, EPA reviewed NCR- RL - 0642 - 10 issued against container RL0055166, BDR RLRTRB0018, even though this NCR had not been through the required reviews. EPA determined that the NCR was issued and processed in accordance with CCP procedures. The BDRs the EPA examined had been reviewed at the data generation level (ITR) and project level (SPM) as required . (5) Training of radiography personnel was adequate. During the inspection, the EPA team reviewed documentation of the capability demonstration for selected radiography personnel. The inspectors viewed the audio/visual recording for the latest capability demonstration drum for the RTR SME and an RTR operator during the inspection. The RTR SME is responsible for verification of qualification for RTR operators . Training records reviewed indicate that only trained personnel were operating the RTR equipment . EPA also reviewed the Qualification C ards and training records for selected RTR personnel. Training documentation was complete and was filed correctl y for purposes of reviewing and reference. Summary of RTR Findings and Concerns The EPA team did not identify any findings and identified one concern requiring a response for RTR during the on - site inspection. Proposed Baseline Approval The baseline conditions that the EPA inspection team evaluated during this inspection consisted of the following:

 Trained personnel , RTR operator/ITR and SME  Approved and controlled operating procedures CCP - TP - 053, Revision 4; CCP - QP - 002, Revision 27; CCP - TP - 028, Revision 337



###  RTR records and supporting data, CCP - TP - 053 and CCP - TP - 001 review checklists, operator Demonstration of Capability records, and BDRs  RTR Units A and B This system is suitable for RTR of CH TRU S5000 debris wastes . RTR Tiers Based on the inspection and the results discussed above, EPA proposes assigning the following tiers: T1 RTR changes will require EPA review and approval prior to implementation, and will apply to any new waste category groups or equipment type that w as not evaluated during the baseline inspection. The one T1 change identified was using a different type, for example high - energy , of RTR unit to those included in the baseline approval. Hanford - CCP must report and submit documentation on T1 changes when they are ready for EPA review. Upon initial review, EPA will inform Hanford - CCP and CBFO whether a site inspection is necessary . EPA may request additional information, choose to conduct a desktop review, and/or confer with Hanford - CCP personnel. Upon evaluation with or without a site inspection, EPA will issue a decision. Only upon receiving EPA written approval may Hanford CCP implement T1 changes. T 2 RTR changes that do not require EPA approval before implementation but require Hanford CCP to report and submit documentation discussing such changes include the following:

 Modifications to approved equipment , RTR units A and B  Changes made to RTR procedure(s) that require CBFO approval  Addition of new SCG to the RTR processes that are subject to this approval Every three months from the date of EPA approval, Hanford - CCP will provide information concerning T2 changes. If new RTR equipment is in use, EPA inspection may be necessary . EPA will evaluate changes and communicate with Hanford - CCP regarding whether the changes raise any concerns and require Hanford- CCP response, or whether Hanford - CCP can continue to implement the changes. 8.4 Visual Examination (VE) Waste Characterization Element Description As part of the inspection of the VE activities, the EPA inspection team focused on overall procedural technical adequacy and implementation, as well as the identification of WMPs and prohibited items, in reviewing the following VE elements:

 Documentation of VE activities through use of an approved procedure  Proper execution of VE activities38



###  Management oversight and independent review of VE activities  Training of VE personnel The VE process for CH debris (S5000) waste performed at Hanford uses manual examination to determine the following aspects of TRU waste characterization:

 Id entification and weight estimate of WMPs  Confirmation of the WMC  Confirmation of presence or absence of prohibited items The VE must be performed by two trained and qualified VEOs, as described in procedure CCP - TP - 053. Documents, BDRs, and Objective Evidence Reviewed The following documents were among those the EPA reviewed to assess whether VE operations follow the appropriate approved procedures and meet VE requirements:

 CCP - TP - 113, CCP Standard Contact - Handled Waste Visual Examination, Revision 13, March 11, 2009  CCP - QP - 002, Training and Qualification Plan, Revision 27, September 30, 2008  CCP - QP - 005, TRU Nonconforming Item Reporting and Control, Revision 18, August 13, 2009  CCP - AK- RL - 101, Revision 2,  CCP - QP - 008, Records Management, Revision 15, October 28, 2009 Following is a complete list of all objective evidence that the EPA inspection team evaluated during the inspection:

 Visual Examination BDRs RLVEPF0022 and RLVEPF0023  List of currentl y qualified VE personnel, April 14, 2010  Qualification card and training records for three VE operators and one VE operator/Visual Examination Expert (VEE )  Letter appointing the VEE, March 12, 2010 Technical Evaluation During the inspection, the EPA inspection team evaluated the technical elements of the VE process using the checklist included as Attachment A.4 to this report . These areas are summarized as follows:39



### (1) Overall procedural technical adequacy and implementation were assessed and found to be adequate. The VE procedure, documented in CCP - TP - 113, Revision 13, contained specific information on performing VE, including identification of prohibited items, assignment of WMPs, and technical review of VE results. EPA inspectors usuall y observe a VE evolution as part of the inspection process, but this was not possible at Hanford - CCP due to safety concerns inside PFP. Implementation of the VE process wa s assessed using review of written records and b y interviewing VE personnel. Any new waste category

or VE process that was not evaluated during the baseline inspection is a T1 change and will require EPA review and approval prior to implementation. Speci ficall y, this applies to performance of VE b y any method other than using two trained operators to perform actual VE at the time of packaging (VE of records by two operators is not included in this approval). (See Table 1 where this is included as a T1 ch ange). (2) Characterization of WMPs and prohibited items was evaluated and was found to be adequate. EPA interviewed trained VE operators (VEOs) and VEE to determine how VE data are generated and recorded. EPA inspectors were unable to observe a VE event b ecause of safety concerns; operators are required to wear full respirator suits to work in the VE area and EPA inspectors are not trained for this ty pe of operation. The waste stream being processed at the time of the on - site inspection was MPFPDD, which is a debris (S5000) waste stream. Site personnel manipulate the waste items while CCP VEOs identify and record them. VE is always performed b y two trained VE operators. Waste items are currentl y being generated from breakdown of glove boxes in PFP. Th ese waste items, such as pipes, brackets, and saw -blades are taped together into packages and numerically identified on the outside of the package. VE data forms record both the contents of each package and the packaging materials used, such as “plastic b ag and duct tape.” VEOs identify and record WMPs and estimated weights are assigned. The VEOs do use the standard weights in Table 4 of CCP - TP - 113, but not all items in this waste stream are included there. Hanford- CCP VE personnel were able to identify prohibited items and how they will be processed when located in the waste. Verification that the physical form of the waste matches the WMC is recorded. VE is performed by two trained VE operators. Upon inspection of VE documentation, EPA identified a discrepancy as a concern. EPA discussed this concern with Hanford - CCP personnel and captured it on an Inspection Issue Tracking Form (see Attachment C.3 for a cop y of this form), and is summarized below: EPA Inspection Issue No. Hanford - CCP - CH -VE - 10 - 006C R : The VEE appointment letter was dated March 2010, although Hanford- CCP has been performing VE at Hanford since the summer of 2009.40



### Re solution: Hanford - CCP provided a VEE appointment letter dated July 2, 2009, which predates all VE characterization activities as documented on the VE BDRs. Additionally , Hanford - CCP also provided documentation of the rejection of all VE BDRs completed or started before April 22, 2010. Status of Concern: EPA considers this concern to be closed. T2 VE changes that do no t require EPA approval prior to implementation include the following changes made to VE procedure(s) that require CBFO approval and the addition of new SCG to the VE processes that are subject to this approval (3) Documentation of VE activities was examined and found to be adequate. EPA inspectors reviewed BDRs RLVEPF0022 and RLVEPF0023 to verify that the VE data were documented correctly and completel y. Site personnel used Attachment 2 from CCP - TP - 113 to record these data. The two BDRs had been reviewed at data generation and project level as required. No NCRs had been issued during the VE and review processes. (4) Training for VE personnel was examined and found to be adequate. Hanford - CCP maintains a list of qualified individuals, which it uses to ensure t hat all training is current. Hanford - CCP documents the personnel who are trained for performing VE and data generation - level data review, and the VEE. As part of the inspection, the EPA team reviewed the Qualification Cards for VEOs and the VEE and found that they require d comprehensive and adequate training for VE personnel. These training records were completed and available for review. The EPA inspectors reviewed the following records:

 Visual Examination BDRs RLVEPF0022 and RLVEPF0023  List of currently

qualified VE personnel, April 14, 2010  Qualification Card and training records for the VE operators and VEE  Letter appointing the VEE, dated March 12, 2010 The VEE interviewed was not able to describe EPA regulations or requirements. EPA discussed this with Hanford - CCP personnel and EPA captured this on an Inspection Issue Tracking Form. The issue is summarized below (see Attachment C.3 for a cop y of this form): EPA Inspection Issue No. Hanford - CCP - CH -VE - 10 - 005F : VE personnel interviewed did not have any knowledge or understanding of EPA regulation(s) as required b y CCP - PO - 002, Revision 22, Appendix 10, Section 10.2. EPA had identified this issue previously in the waste characterization programs at both ORNL - CCP and SRS - CCP. EPA requires that VEOs be trained to Federal Regulations (CFR Part 194.24) before the first CH TRU waste shipment is scheduled from Hanford - CCP.41



### Resolution: Inresponse to this finding, CBFO provided a document EPA Requirements for TRU W aste Disposal as Applied to VE and RTR , EPA - 01, Revision 0, dated May 11, 2010. EPA reviewed this document and determined that it adequatel y addressed EPA’s concern. Status of Concern: EPA considers this issue to be closed. EPA identified a discrepancy with respect to the date on which the VEE was appointed. EPA discussed this with Hanford - CCP VE personnel and captured this on an Inspection Issue Tracking Form. The issue is summarized below (see Attachment C.3 for a copy of this form): EPA Issue No. Hanford - CCP - CH - VE - 0006CR: The Hanford - CCP VEE was appointed in March of 2010, after VE had begun at the site. Resolution: The Hanford - CCP SPM stated in the inspection closing meeting that this was not a problem because Hanford - CCP had decided to RTR all containers that had previously undergo ne VE, except for the containers in BDRs RLVEPF0022 and RLVEPF0023. Status of Concern : EPA considers this issue to be closed. Summary of VE Findings and Concerns EPA generated one finding and one concern requiring a response during this inspection, as discussed above. Proposed Baseline Approval EPA is proposing to approve the VE process for S5000 debris waste that the EPA inspection team evaluated during this baseline inspection, consisting of the following elements:

 Trained personnel, specifically VEOs, VEE, and SPM  Approved and controlled operating procedures, specificall y CCP - TP - 113 , Revision 13 using 2 trained VEOs ; CCP - QP - 002, Revision 2 7  VE records and supporting data, CCP - TP - 113 and CCP - TP - 001 review checklists, and VE BDRs This proposed approval is limited to ex ecution of VE by two trained operators at the site . This system is suitable for VE of C H TRU S5000 debris waste. VE Tiers T1 VE changes will require EPA review and approval prior to implementation, and will apply to any new waste category

or process that was not evaluated during the baseline inspection. The one T1 change identified is performance of VE b y any method other than using two trained operators to perform actual VE at the time of packaging (VE of records by two operators is not included in this approval).42



### Hanford - CCP must report and submit documentation on T1 changes when they are ready for EPA review. Upon initial review, EPA will inform Hanford - CCP and CBFO whether a site inspection is necessary . EPA may request additional information, choose to conduct a desktop review, and/or confer with Hanford - CCP personnel. Upon evaluation with or without a site inspection, EPA will issue a decision. Only upon receiving EPA written approval may Hanford CCP implement T1 changes. T2 VE changes that do not require EPA approval prior to implementation, but require Hanford CCP to report and submit documentation, include the following:

 Changes made to VE procedure(s) that require CBFO approval  Addition of new SCG to the VE processes that are subject to this approval Hanford - CCP will provide EPA with information concerning T2 changes on a quarterly basis, including a brief description of the available information. EPA will evaluate these changes and communicate with Hanford - CCP as to whether the changes raise any concerns and require a Hanford - CCP response, or whether Hanford - CCP can continue to implement the changes. Consistent with EPA’s authority under 194.24(h), EPA may request information relative to these changes if EPA deems the information is necessary to ensure continued compliance with EPA regulations. 8.5 WIPP Waste Data System (WDS) W aste C haracterization Element Description In December of 2009, the data entry s ys tem used to certify

containers for disposal, previously WWI S , was changed from an Oracle -based to a web -based s ys tem. This new s ys tem was named Waste Data System (WDS) and data entry procedure CCP - TP - 030 was revised to include the necessary changes. The title of this procedure was changed to “CCP CH TRU Waste Certification and WWI S/WDS Data Entry” and a new User’s Manual was issued. The EPA team determined, through interview, that the differences between WWI S and WDS were minor in nature and process improvements had been made during this change. EPA has previous ly inspected the WWI S process and determined that CCP had successfully submitted CH waste characterization data to the database. At the time of the on - site inspection, the Waste Stream Profile Form for MPFPDD had not been approved and data could not be entered into the WDS proper to demonstrate that the effectiveness of data submission had not been compromised due to the change from WWI S to WDS. Procedure CCP - TP - 0 30 is used for submittal of both characterization and certification C H data to the WDS . Wast e Certification Assistants (WCAs) and Waste Certification Officials (WCOs) are based in the CCP office in Carlsbad, New Mexico, and data transfer is performed electronicall y. Documents, Records, and Objective Evidence Reviewed The following documents were among those the EPA inspectors reviewed to assess whether WDS operations follow the appropriate approved procedures and meet WDS requirements:43



###  CCP - TP - 0 30, Revision 27 , CCP C H TRU Waste Certification and WWI S /WDS Data Entry , December 14, 2009  CCP - QP - 002, Revision 2 7 , Training and Qualification Plan, September 30, 2008 The EPA inspectors evaluated the following objective evidence during the inspection:

 Waste Container Data Report for containers RL0063021 and RL 0063034  CCP Correlation of Container Identi fication Numbers to Batch Data Reports, waste stream MPFPDD, lot #1  WDS data entry summary , characterization and certification , spreadsheet for containers RL0062930, RL0063034, RL 0063014, RL0063021, RL 0063040  CCP - QP - 022, Software Quality Assurance Plan, Attachment 3, Software Problem Reporting and Change Request for WDS Master Template, SCO # 1065, versions 1 and 2  WCO qualification card and training record  DA e - mail rescinding database access for employee Technical Evaluation During the inspection, the E PA inspection team evaluated the technical elements of the WDS process using the checklist included as Attachment A. 5 to this report . These areas are summarized as follows: (1) Overall procedural technical adequacy was evaluated and found to be adequate as observed during the inspection. CCP has successfully

submitted characterization and certification into WWI S and, while this now takes place in WDS, the process followed is essentially the same for both data bases. The WDS procedure documented in CCP - TP - 0 3 0, RH TRU Waste Certification and WWI S /WDS Data Entry , Revision 27 , is well defined and controlled, and contains instructions for entering, reviewing, and transmission of data. The procedure was revised to allow the use of WDS and issued on December 12, 2 009. The new Microsoft Excel spreadsheet used for data entry was also adequate and controlled. WDS incorporates some changes to WWI S, for example, WCOs can now change uploaded data, rather than the Database Administrator. A new user’s manual, DOE/CBFO - 0 9 - 3427, Waste Data S ys tem User’s Manual was generated and issued to support the implementation of this new system. At the time of the on - site inspection, the subject waste stream did not have an approved Waste Stream Profile Form and so the demonstration provided only included the test instances of the s ys tem. The WCO demonstrated to the EPA inspectors how data were entered, uploaded, and tracked in the WDS. To ensure that the sy stem is effective when used for actual certification of containers, LANL drum LA00000064320 located in SWB LAS B00811, was tracked back from emplacement to the original characterization BDRs. No issues were identified for the adequacy and implementation of this new system.44



### EPA identified a discrepancy with respect to documentatio n of the WDS. EPA discussed this with Hanford - CCP personnel and captured this on an Inspection Issue Tracking Form. The issue is summarized below (see Attachment C.3 for a copy of this form): EPA Inspection Issue No. Hanford - CCP - CH -WDS - 10 - 00 2 CR : CCP training procedure CCP - QP - 002, Revision 27, Section [C.3] requires WCOs to demonstrate proficiency in WWI S as part of training. However, WDS is not specifically identified in the training procedure, although this is the only

User’s Manual listed in the reference section of CCP - TP - 030. The Hanford - CCP Project Manager indicated that the procedure(s) associated with data entry are being revised at this time. Response: Hanford - CCP personnel indicated that CCP training procedure CCP - QP - 002, Revision 27, Sectio n [C.3] lists the requirement for WCOs to demonstrate proficiency in WWI S as part of training as an example of the ty pes of activities that may

be performed after completion of a “core” qualification card. At the time of the Hanford - CCP baseline inspectio n, CCP - QP - 002 was in revision to remove the list of sample activities that may be performed after completion of a “core” qualification card because inclusion of such a list is not a requirement. Deletion of this list removes any confusing references to WW IS /WDS in CCP - QP - 002. Hanford - CCP also pointed to language in the User’s Manual (DOE/CBFO - 09 - 3427) that defines WWI S database as a subsystem of the WDS. Status of Concern: EPA considers this issue to be closed. (2) Implementation and documentation of WDS activities were examined and found to be adequate. Hanford - CCP did not have an approved WSPF for waste stream MPFPDD at the time of the on site inspection and consequently had not generated any

official records for EPA ’s review. A qualified Hanford - CC P WCO demonstrated the characterization and certification process b y uploading CH data into the test instance of WDS. However, the usual records (e - mails, signed data spreadsheet, etc.) were not available for review. After the characterization data hav e been through every level of review and approval, they are entered into a controlled Excel spreadsheet b y a WCA. A review of the spreadsheet is made b y a second WCA to verify

correct data entry . The WCO reviews the data to ensure that they are WIPP - comp liant and signs the spreadsheet to accept the data. Closure of associated NCRs is verified b y the SPM. EPA inspectors verified validation of Versions 1 and 2 of the WDS Excel spreadsheet. The WCO was able to demonstrate data entry into the test instance of WDS. WDS data entry summaries and the Waste Container Data Report were retrieved when requested by EPA. To verify that data entered into WDS proper could be retrieved, a randomly chosen LANL container was traced back from emplacement to the original characterization BDRs. Although EPA was not able to challenge WDS with data from waste stream MPFPDD, the WCO demonstrated sufficient information about the data system to enable EPA to conclude that the WDS was adequate for container certification.45



### T2 WDS changes include changes to WDS procedure(s) that require CBFO approval and changes to the Excel spreadsheet titled WDS Master Template.xls, Revision 2, Addendum #2, SCO #1065. (3) Training of WDS personnel was reviewed and was found to be adequate. The E PA inspectors observed limited job performance of a WCO to verify personnel training and qualification. Inspectors also reviewed the qualification card and training records for the WC O providing the on - site demonstration. The training procedure CCP - QP - 00 2 requires WCOs to demonstrate proficiency in WWI S, but does not include WDS. EPA generated Concern No. Hanford - CCP - CH - WDS - 10 - 002CR to address this issue Summary of WDS Findings and Concerns The EPA inspection team did not identify any findings related to WDS . EPA did identify one concern requiring a response discussed above. Proposed Baseline Approval EPA is proposing to approve the WDS container certification s ys tem that the EPA evaluated during this baseline inspection, consisting of the following elements:

 Trained WDS , WCA , and WCO  Approved and controlled operating procedures CCP - TP - 030, Revision 27 and CCP - QP - 002, Revision 27  Approved and controlled data entry Excel spreadsheet titled WDS Master Template.xls, Revision 2, Addendum #2, SCO #1065 WDS Tiers T1 WDS changes will require EPA review and approval prior to implementation, and will apply to any new waste category

or process that was not evaluated during the baseline inspection. There are no T1 changes at this time. T2 WDS changes that do not require EPA approval prior to implementation, but require Hanford - CCP to report and submit documentation, include the following:

 Changes to WDS procedure(s) that require CBFO approval  Changes to the Excel spreadsheet titled WDS Master Template.xls , Revision 2, Addendum #2, SCO #106546



### Hanford - CCP will provide EPA with information concerning T2 changes on a quarterly basis, including a brief description of the available information. EPA will evaluate these changes and communicate with Hanford- CCP wh ether the changes raise any concerns and require a Hanford CCP response, or whether Hanford- CCP can continue to implement the changes. Consistent with EPA’s authority

under 194.24(h), EPA may request information relative to these changes , if EPA deems the information is necessary to ensure continued compliance with EPA regulations. 9.0 RESPONSE TO COMMENTS This section is reserved for pu b lic comments. 10.0 SUMMARY OF RESULTS 10.1 Findings and Concerns The finding and concerns identified during the inspection, as we ll as Hanford - CCP responses, are discussed in the preceding sections of this report. Attachment C includes copies of the EPA Inspection Issue Tracking Forms that capture these issues. Hanford - CCP responded to the one EPA finding and five EPA concerns sub sequent to the inspection. The EPA inspection team members evaluated all responses for completeness and adequacy and concluded that each EPA issue requiring a response had been resolved satisfactoril y. No EPA issues related to the baseline inspection of Hanford - CCP remain open at this time. 10.2 Conclusions The EPA inspection team determined that the Hanford- CCP waste characterization program activities were technically adequate. EPA is proposing to approve the Hanford- CCP waste characterization program in the configuration observed during this inspection and described in this report and the attached checklists (Attachments A.1 through A.5). This proposed baseline compliance decision is based on EPA’s inspection completed April 27 - 29, 2010. This proposed a pproval includes the following: (1) The AK process for retrievabl y- stored CH TRU debris wastes (2) The GEA - A and GEA - B systems for assaying CH TRU wastes (3) The NDE process of RTR for CH TRU debris wastes (4) The NDE process of VE for CH TRU debris wastes (5) The WDS proce ss for tracking of waste contents of CH TRU wastes This proposed baseline approval of Hanford - CPP does not include load management. Table 10 below closely

follows the format used in the previous CH baseline approval reports. The table identifies applic able T1 and T2 changes that may be necessary

in the future to the EPA - approved CH TRU waste characterization baseline program. Hanford - CCP must report and47



### receive EPA approval of any T1 changes to the Hanford - CCP waste characterization activities from the date of the baseline inspection. This approval must be sought prior to the implementation of each of the T1 changes identified in Table 10. Additionally , Hanford - CCP must notify

EPA regarding T2 changes according to Table 10, below. (See Section 2.0 of this report for a brief discussion of tiering.) Upon approval of the T1 changes, EPA will post the results of the evaluations to the EPA Web site and by sending e - mails to the WIPPNEWS list, as described above. Upon completion of its review and concurrence of the T2 changes submitted at the end of each fiscal quarter, EPA will post the T2 changes. EPA expects the first report of Hanford - CCP’s T2 changes at the end of the first quarter following approval.48 

### Table 1 0 . Tiering of TRU Waste Characterizatio n Processes Implemented by Hanford - CCP

Based on April 27 - 29, 2010 Site Baseline Inspection Process Elements Hanford - CCP T1 Changes Hanford - CCP T2 Changes a Acceptable Knowledge (AK) Im plementation of load management Im plementation of AK for wastes other than retrievably stored debris (i.e., retrievably - stored soil/gravel and/or solids) Notification to EPA upon completion of new versions or updates/ substantive changes b of

the following:

- Modification of CCP - TP - 005, Revision 18

- Availability of modifications to the AKSR

- Availability of all final WSPF with related attachments

- Availability of all AK Accuracy Reports

- Availability of successful training records

- Availability of the AK -NDA memorandum Non Destructive Assay (NDA) New equipment or physical modifications to approved equipmentc Extension or changes to approved calibration range for approved equipment Notification to EPA upon completion of c hanges to software for approved equipment, operating range(s), and site procedures that require CBFO approval Real - Time Radiography (RTR) Im plementation of a different type of RTR equipment Notification to EPA upon the following:

- Modificationc to approved equipment, RTR units A and B

- Com pletion of c hanges to site RTR procedures requiring CBFO approvals

- Addition of new SCG to the RTR processes that are subject to this approval Visual Examination (VE) P erformance of VE by any method other than using two trained operators to perform actual VE at the time of packaging Notification to EPA upon the following:

- Com pletion of c hanges to site VE procedure(s) requiring CBFO approvals

- Addition of new SCG to the VE processes that are subject to this approval Waste Data System (WDS) There are no T1 changes at this time Notification to EPA upon the following:

- Com pletion of change s to WDS procedure(s) requiring CBFO approvals

- Changes to the Excel spreadsheet titled WDS Master Template.xls, Revision 2, Addendum #2, SCO #1065 a Upon receiving EPA approval, Hanford - CCP will report all T2 changes to EPA at the end of each fiscal quarter. b “ Substantive changes” are changes with the potential to impact the site’s waste characterization activities or documentation thereof, excluding changes that are solely related to ES&H, nuclear safety, or RCRA, or that are editorial in nature. c Modif ications to approved equipment include all changes with the potential to affect NDA data relative to waste isolation and exclude minor changes, such as the addition of safety - related equipment.49



### 11.0 REFERENCES New Mexico Environment Department, Waste Isolatio n Pilot Plant Hazardous Waste Facility Permit (WAP), NM48901 139088 - TSDF, Santa Fe, New Mexico, 1989. U.S. Code of Federal Regulations , Title 40, Protection of Environment , Part 191, “Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High - Level and Transuranic Radioactive Wastes.” U.S. Code of Federal Regulations , Title 40, Protection of Environment, Part 194, “Criteria for the Certification and Re - Certification of the Waste Isolation Pilot Plant’s Compliance with the 40 CFR Part 191 Disposal Regulations.” U.S. Department of Energy , “40 CFR Part 191, Compliance Certification Application for the Waste I solation Pilot Plant,” DOE/CAO 1996 - 2184, Carlsbad, New Mexico, 1996. U.S. Department of Energy , “40 CFR Part 191, Subparts C and D, Compliance Recertification Application 2004,” DOE/WIPP/2004 - 3231, 2004. U.S. Department of Energy , “Transuranic Waste Baseline Inventory Report,” Revision 0, DOE/TRU - 2206 - 3344. U.S. Department of Energy , Carlsbad Area Field Office , “Contact - Handled Transuranic Waste Acceptance Criteria for the Waste I solation Pilot Plant (CH - WAC),” Revision 3, DOE/WIPP - 02 - 3122, Carlsbad, New Mexico, April 25, 2005. U.S. Department of Energy , Carlsbad Area Field Office, “Quality Assurance Program D escription (QAPD),” DOE/CBFO - 94 - 1012, Revision 7, Carlsbad, New Mexico, July 2005. U.S. Environmental Protection Agency , “Criteria for the Certification and Recertification of the Waste I solation Pilot Plant’s Compliance with the Disposal Regulations: Certification Decision; Final Rule,” Federal Register , Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405. U.S. Environmental Protection Agency , “ EPA Replicate Testing for WIPP Nondestructive Assay (NDA) S ys tems ,” Revision 2, June 2002. U.S. Nuclear Regulatory Commission, “Contact - Handled Transuranic Waste Authorized Methods for Payload Control.A - 1 

### ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH AK Checklist Inspection Date: April 27 - 29, 201 0

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Examples of Objective Evidence GENERAL AK- 1 : Is the waste TRU by definition as presented in the LWA? (P.L.102 - 579) CCP - TP - 005, Revision 18; Section 4.4.31; CH - WAC Revis ion 6.4; P.L. 102 - 579 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance Draft WSPF for Stream MPFPDD. Data examined indicates waste is TRU waste by definition, NDA BDRs RLGEAA0001, 0002. AK- 2 : Do the presented volumes comport with LWA capacity restrictions? (P.L.102 - 579) CCP - TP - 005, Revision 18; CH - WAC Revision 6.4; P.L. 102 - 579 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance WSPF for Stream MPFPDD; AKSR MPFPDD, CCP - TP - 005 Attachment 6. No data exami ned identified any issues with respect to waste volume. AK- 3 : Are any wastes considered (or previously considered) high - level wastes (HLW)? HLW are prohibited. (P.L.102 - 579) CH - WAC Revision 6.4; P.L. 102 - 579 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance AKSR MPFPDD, Section 4.3.2. No data examined indicated that the waste stream evaluated during inspection were by definition SNF or HLW. AK- 4: Are any wastes considered (or previously considered) Spent Nuclear Fuel? SNF i s prohibited. (P.L.102 - 579) CH - WAC Revision 6.4; P.L. 102 - 579 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance AKSR MPFPDD, Section 4.3.2. No data examined indicated that the waste stream evaluated during inspection were by defi nition SNF or HLW. AK- 5: Are these defense wastes? Waste must be defense in origin. (P.L.102 - 579) CCP - TP - 005, Revision 18, Section 4.4.1; CH - WAC Revision 6.4; P.L. 102 - 579 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance AKSR M PFPDD, Section 4.3.1. Data examined during the inspection indicated that the waste stream is or was commingled with waste that was defense in origin. AK- 6 : What is the scope of authorization sought (i.e., SCG, other site - specific breakdow ns?) CCP - TP - 005 , Revision 18; CH - WAC Revision 6.4; P.L. 102 - 579, CRA 2009 EPA Scope Letter: CH Debris AKSR MPFPDD, WSFP for Stream MPFPDD. Scope of the approval was contact handled debris (S5000), retrievably stored and newly generated. Categories of waste not approve d under this baseline inspection (e.g., S3000 and S4000 wa stes). AK- 7: Is AK being used that was assembled prior to an EPA approved QA program? If so, what qualification process is used? Is this waste undergoing confirmation as per the CCA/CRA (100% s ampling)? [194.24(c)(2) - (5), 194.22(a)] CCP - TP - 005, Revision 18; CH - WAC Revision 6.4; P.L. 102 - 579 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance RLRTRB0002, RLGEAA0001, RLRTRA0001, RLGEAA0002. 100% NDE and 100% NDA to confirm AK.A - 2 

### ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH AK Checklist Inspection Date: April 27 - 29, 201 0

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Examples of Objective Evidence AK- 8: Is AK being assembled as waste is generated after EPA approval of the QA program? Is this waste undergoing confirmation as per the CCA/CRA (100% sampling)? [194.24(c)(2) - (5)] CCP - TP - 005, Revision 18; CH - WAC Revision 6.4; P.L. 102 - 579 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance RLRTRB0002, RLGEAA0001, RLRTRA0001, RLGEAA0002AKSR AKSR MPFPDD, Section 5.4.1.2. All waste generated during D&D activities will undergo 100% NDE and 100% NDA. AK- 9 : Procedures require staff to be qualified to assemble, compile, and confirm AK data, including, but not limited to: a. Identification of required reading list and successful completion of all required reading including, but not limited to:  Applicable portions of the WIPP WAP and TSDF WAC  WIPP Compliance Certification Decision Conditions 2 and 3  State and Federal RCRA regulations associated with solid and hazardous waste characterization  Discrepancy resolution and reporting processes  Site - specific procedures associated with waste characterization using acceptable knowledge b. Successful completion of testing to demonstrate understanding of required reading list c. Completion of internal and/or external training programs pertinent to AK d. Participation in internal audits to ass ess AK program e. Other methodologies for demonstrating AK proficiency as developed on a site - specific basis (WAP B4, B4 - 3a) CCP - TP - 005, Revision 18, Section 2.2; CCP - QP - 002, Section 4.2 Interview of Steve Schafer Natasha McCants, and Sheri Nance AKE Qualif ication Cards for Sheri Nance, Steve Schafer, Natasha McCants. Also presented training roster for most recent Hanford AKSR MPFPDD. CCP representative stated that they do not have required reading for the most updated procedure versions

– they are require d to verify they are using the most updated procedure as presented on the FTP site. It is clear that the individuals were aware of the content of the most recent AK procedure, but EPA recommends that documentation of updated reading be included in the training records. Further, the documentation did not include any indication that individuals have been trained to EPA requirements. All individuals had participated in various internal audits.

AK- 10: a. Are procedures adequate to encompass the spectrum o f wa stes for which authorization is sought? CCP - TP - 005, Revision 18; CCP - TP - 066 Revie w of objective evidence and interview of Steve Schafer and Sheri RLRTRB0002, RLGEAA0001, RLRTRA0001, RLGEAA0002, VE BDRS RLVEPF0001 - 0004,0008 - 0013A - 3 

### ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH AK Checklist Inspection Date: April 27 - 29, 201 0

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Examples of Objective Evidence b. Are there different procedures for newly generated vs. retrievably stored waste? Are there different procedures for solid, debris, or soil waste? Should there be? c. For newly generated waste, have adequate procedures been developed and implemented to characterize waste using acceptable knowledge prior to packaging? (WAP B4, B4 - 3b) Nance CCP - TP - 005, Rev. 18. Procedure is common to retrievably stored and newly generated waste. RTR, NDA used to collect confirmatory data for each container. Data and procedures indicate that NDA and RTR may be used to characterize waste, all of which activities are governed by procedure addressed in other checklist sections. Newly generated waste may undergo VE in the future. Modification of CCP - TP - 005, Revision 18 is a Tier 2 change. ASSEMBLING AK INFORM ATION AND COMPILING AK DOCUMENTATION INT O AN AUDITABLE RECORD AK- 11: What is the breakdown of the types and quantities of TRU waste generated/stored at the site? (WAP B4, B4 - 2a) CCP - TP - 005, Revision 18, Sections 4.4.8, 4.4.9, and Attachment 1 PR6 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance WSPF MPFPDD, AK Tracking Spreadsheet, PTS, AKSR MPFPDD (example: Table 5 - 2, mixed stream), HNF - 6489, HNF - 36515, CCP - TP - 005, Attachment 6 (and associated memo). The MPFPDD waste stream is essentially a combination of the Hanford MPFPD and RLMPFPCD waste streams. The MPFPD is a subset of the RLMPFPCD stream, with the later containing wastes from Building 242 - Z - Waste Treatment Facility, 291 - Z - Ventilation/Exhaust Air Stack Building, and PFP Ancillary Facilities. AK- 12: Do procedures call for AK information to be collected for: a. 241 Am, 238 Pu, 239 Pu, 240 Pu, 242 Pu, 233 U, 234U, 238 U, 90 Sr, 137 Cs + unexpected radionuclides b. Ferrous metals (in containers) c. Cellulosics , plastics, rubber d. Nonferrous metals (in containers) (CRA/CCA Ch 4 and Attachments/Appendices) CCP - TP - 005, Revision 18, Sections 4.4.21, 4.4.22, 4.4.24 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance P976, P1084, AKSR MPFPDD (e.g. Table 5 - 4) CCP - TP - 005 Attachment 7 and related NDA Memo, reference C200, Attachment 6; RLRTRB0002, RLGEAA0001, RLRTRA0001, RLGEAA0002, VE BDRs RLVEPF0001 - 0004,0008 - 0013. AK data shows that 239 Pu and 238 U are the most prevalent isotopes by mass. Wa ste also contains uranium, americium, neptunium, cesium, and strontium. Waste stream MPFPDD is composed of a variety of debris material represented by a host of activities including plutonium processing, waste treatment, incineration, and D&D activities. Modification of the NDA memo is a Tier 2 change.A - 4 

### ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH AK Checklist Inspection Date: April 27 - 29, 201 0

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Examples of Objective Evidence AK- 13: Do procedures require documentation of radionuclide process origin? Are the facility and TRU waste management operations correlated to specific waste stream information? (WAP B4; WAC Appendix A. 2.2) CCP - TP - 005, Revision 18, Section 4.4, Attachment 1 WS4, PR7 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance AKSR Section 4.0, HNF - 6489 HNF - 36515, C100, C104, , M047, P052, Waste stream includes material from the followi ng buildings: • 232 - Z, Waste Incinerator Facility (now demolished) • 234 - 5Z, Plutonium Process and Storage Building • 236 - Z, Plutonium Reclamation Facility • 242 - Z, Waste Treatment Facility • 2736 - ZB, Product Shipping and Receiving Facility • 291 - Z, Venti lation/Exhaust Air Stack Building • PFP Ancillary Facilities CCP demonstrated that all but the PFP Ancillary Facilities are within the same waste stream based on common physical, radiological, and material composition except for the Ancillary facilities. C CP removed the ancillary facilities from the wa ste stream in a freeze file modification. AK- 14: Are correlations between waste streams, with regard to time of generation, waste generating processes, and site - specific facilities clearly described? For newly generated wastes, the rate and quantity of waste to be generated shall be defined. (WAP B4, B4 - 3c) CCP - TP - 005, Revision 18, Section 4.4, Attachment 1 PR7 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance AKSR MPFPDD Sections 4.2.2, 5.2, Example references: C117, P130, P191, and P239 P194, P071 and P153 Historic time outlines, processes, facilities: AKSR 4.2.2 Future volume, location new generation: AKSR 5.2 AK- 15: a. Are waste streams appropriately identified and are wa stes characterized on a waste stream basis? b. Are wastes grouped on a waste stream basis using Acceptable Knowledge? (WAP B4, Section B - 1a) CCP - TP - 005, Revision 18, Sections 4.4, 4.2.3, 4.2.4 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance MPFPDD WSPF, AKSR MPFPDD, Solid Waste Information and Tracking System (SWITS) Waste Container Report and Container Listing Reports, Drum Packaging Data Sheets drums RL0056238, RL0063057 The MPFPDD waste stream is composed of TRU mixed heterogeneous deb ris created by various production, maintenance, cleanout, stabilization, decontamination, and decommissioning activities at the Plutonium Finishing Plant (PFP). Wastes from different buildings with common overall PFP support processes and with common phys ical and radiological form were apparently assembled with no distinguishing assignment to different sourceA - 5 

### ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH AK Checklist Inspection Date: April 27 - 29, 201 0

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Examples of Objective Evidence areas in PFP. CCP representatives stated that because it is not possible to discern where the drums came from other than PFP, all the drums must be assigned to the same waste stream. AK- 16: Do procedures demonstrate a logical progression from general facility information to more detailed waste stream - specific information? CCP - TP - 005, Revision 18, Section 4.4 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance MCPFPDD WSPF, AKSR MCPFPD; Source Documents (C,DR,P, M, U), and related drum data including PTS Print Outs, and data from IDMS, SWITS, TRU DMT AK- 17: Does the process include review of AK information to evaluate and document AK- AK information discrepancies? (WAC Section A.2.2.3, WAP B4, Section B4 - 3) CCP - TP - 005, Revision 18, Sections 4.7, 4.8, 4.9 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance Discrepancy Resolutions, including DR010, DR01 3

AK- 18: Do procedures require collection of information regarding how waste is tracked and managed at the generator site (including historical and current operations)? (WAC Section A.2; WAP B4 Section B4 - 2a) CCP - TP - 005, Revision 18, Section 4.4, Attachment 1 PR4 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance . SWITS database information, TRUEDMT database, Onsite Radioactive Shipment Records, and Solid Waste Burial Records, CCP PTS/CTS, AK Tracking Spreadsheet, CCP - TP - 005 Atta chment 8, WWIS (emplaced historic containers). Data examined demonstrated that historic waste tracking and management can be ascertained as well as current drum status and location. AK- 19: Is AK information compiled in an auditable record, including a road map for all applicable information? CCP - TP - 005, Revision 18, Attachments 1, 4 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance CCP - TP - 005, Attachments 1 and 4

AK- 20: Has a reference list been provided that identifies documents, databases, Quality Assurance protocols, and other sources of information that support AK information? (WAP B4, Section B4 - 3c) CCP - TP - 005, Revision 18, Attachment 4 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance CCP - TP - 005 Attachment 4; AKSR MPFPDD Reference list

AK- 21: Have the following mandatory information requirements been identified?  Map of the site that identifies the areas and facilities CCP - TP - 005, Revision 18, Section 4.4.31, Attachment 1 Revie w of objective evidence and interview of Steve Schafer and Sheri AKSR MPF PDD, Sections 4.2 - 5.3, related figures, AK -NDA Memo for MPFPDD, CCP Freeze File, Figures 1 - 3A - 6 

### ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH AK Checklist Inspection Date: April 27 - 29, 201 0

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Examples of Objective Evidence involved in TRU waste generation, treatment, and storage  Facility mission desc ription related to TRU waste generation and management  Description of the operations that generate TRU waste at the site and process information, including:

- Area(s) or building(s) from which the waste stream wa s or is generated

- Estimated waste stream volume and time period of generation

- Waste generating process description for each building or area

- Process flow

diagrams, if appropriate

- Generalized material inputs or other information that identifies the radionuclide content of the waste stream and the physical waste form

- Ty pes and quantities of TRU waste generated, including historical generation through future projections  Physical/chemical waste composition that could affect isotopic distribution (i.e., processes to remove ingrown 2 41 Am)  Statement of all numerical adjustments applied to derive the material’s isotopic distribution, e.g., scaling factors, decay/ingrowth corrections and secular equilibrium considerations  Specification of isotopic ratios for the 10 WIPP - tracked radionucl ides and, if applicable, the radionuclides that comprise 95% of the hazard (WAC Section A.2.2; WAP B4, B4 - 2a, B4 - 2b) Nance AK data indicate that the initial weapons grade Pu produced at Hanford exhibited a 240 Pu weight percentage between approximately 0.9 - 7%. Fuel material processe d at Hanford exhibited a 240 Pu weight percent of 8 - 27% for experimental reactor technology as well as other technologies. CCP Hanford concluded that this spectrum of values indicated a range of isotopic distributions would likely be appropriate for this waste stream . The NDA memo indicated that 233 Pa may cause interference with 239 Pu assay; other radionuclides that may interfere with transmission include those associated with 152 Eu. Also, alpha particles can interact with low - Z nuclei releasing neutrons that can interfere with neutron counting. Beryllium, boron, fluorine, carbon sodium, magnesium and aluminum may contribute.

AK- 22: Does the site have procedures for the collection of supporting information? Examples of supplemental CCP - TP - 005, Revision 18, Section 4.2.5, Attachment 1 Revie w of objective evidence and interview of Steve Schafer and Sheri Numerous examples, including but not limited to C043, C053, C074, DR010, DR013, M026, M040,A - 7 

### ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH AK Checklist Inspection Date: April 27 - 29, 201 0

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Examples of Objective Evidence information, from WAC, include:  Safeguards and security and other material control systems/programs  Reports of nuclear safety or criticality  Accidents involving SNM waste packaging and waste disposal  Building or nuclear material management area logs or inventory records  Site databases that provide SNM or nuclear material information test plans  Research project reports, or laboratory notebooks that describe the radionuclide content of materials used in experiments  Information from site personnel  Historical analytical data relevant to isotopic distribution in the waste stream (WAC Section A.2.2.2; WAP B4 Section B4 - 2c) Nance M044, M305, P203,P228,P179, P202, P203, P976, U202

AK- 23: Is all necessary supporting information assembled and has it been appropriately used? (WAP B4 Section B4 - 2c) CCP - TP - 005, Revision 18, Section 4.2.5 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance Numerous examples, including but not limited to C043, C053, C074, DR010, DR013, M026, M040, M044, M305, P203,P228,P179, P202, P203, P976, U202Also, CCP prepared additional freeze file changes addressing EPA concerns as well as DR013. AK- 24: a. Are waste categorization schemes presented and are they appropriate? b. Are waste identification/categorization schemes relevant to the isotopic composition of waste? (Attachment B4 Section B4 - 1, WAC Appendix A.2) CCP - TP - 005, Revision 18, Section 4.4 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance AKSR MPFPDD, NDA Memo, CCP - TP Attachment 7; DR010, Waste defined by processes associated with PFP and includes isotopic distribution applied to the stream as a whole.

AK- 25: Have data uses and limitations been assembled CCP - TP - 005, Revision 18, Revie w of objective evidence and interview of CC - TP - 005 Rev 18 Attachment 3; all AK source document summaries. Note that CCP separatedA - 8 

### ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH AK Checklist Inspection Date: April 27 - 29, 201 0

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Examples of Objective Evidence and are they technically adequate? (CRA/CCA; WAC Appendix A, Section A.2.2.3) Section 4.3, Attachment 3 Steve Schafer and Sheri Nance the Attachment 3s from the original source documents, which as not been practiced at any CC P location until Hanford. This proved cumbersome as the Source Document Summaries and related Source Documents had the same file names, thus leading to loss of data and the need to rename documents. In the future, CCP has determined this approach is not appropriate and will attach Source Document Summaries to the actual Source Documents. AK- 26: Site documents/procedures require the facility to prepare an AK summary document that summarizes all information collected, including the basis for all waste stream designations. Is the AK Summary of sufficient scope and detail? (WAC Appendix A Section A.2.2; WAP Attachment B4 Sections B4 - 2b, B - 3d) CCP - TP - 005, Revision 18, Section 4.4 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance AKSR MPFPDD. EPA identified several issues associated with the AKSR that required mo dification and which were addressed through freeze file changes including:

- Examine feed and other data for 232 - Z Incinerator to verify its inclusion in the waste stream.

- Examine the use of “offsite sources” throughout the document.

- In Section 4.6.1, modify the discussion pertaining to waste stream definition to include the lack of ability to correlate drums to specific PFP processes. Also modify Section 5.3 to indicate whether to -be - generated waste will be segregated upon generation or packaging.

- Clarify intent of last paragraph p.30 regarding plutonium grades and defense waste.

- Add information to Section 5.4.2 pertaining to the 6%, 12%, and 23% plutonium isotopic di stributions as presented in AK Source Documents and the AK-NDA memo, including data that supports generation of these distributions at the PFP as well as other pertinent historical data.

- Remove first sentence from the first paragraph in Section 4.5 regarding intent to segregate wasteA - 9 

### ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH AK Checklist Inspection Date: April 27 - 29, 201 0

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Examples of Objective Evidence during packaging or repackaging, as it contradicts later statements.

- Verify number of HEHF (Emergency Decontamination Facility) drums and how it is included in the PFP drum population.

- Add the total volume (cubic meters) of wa ste in inventory.

- In the final paragraph of Section 5.4.2, add the second predominant radionuclide by activity, to be consistent with the previous portion of the sentence that identifies the two predominant radionuclides by mass. CCP submitted a freez e file modification that adequately addressed these concerns. Modifications to the AKSR are a Tier 2 change. AK- 27: Are conclusions and interpretations presented in the AK Summary technically sound and supported by referenced mandatory and supplemental information? CCP - TP - 005, Revision 18 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance See Item AK - 26; Example references include Source documents C, DR, M, P, and U. AK- 28: If AK data discrepancy is identified, site will evaluate the source of the discrepancy to determine if discrepant information is credible. Information that is not credible will be identified as such and reasons for dismissing will be justified in writing. Limitations concerning information will be documented in the AK record and summarized in the AK report. If a discrepancy cannot be resolved, the site will perform direct measurements for the impacted population. (WAC Appendix A.2, Section A.2.2.3) CCP - TP - 005, Revision 18, section 4.9 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance DR005, DR006 DR013, DR010

AK- 29: Has the use of load management been proposed? Does the AK Summary include the following from the WAC, Revision 3, Appendix E?  Each TRU waste stream selected for payload CCP - TP - 005, Revision 18, Section 4.4.31 Revie w of obje ctive evidence and interview of Steve Schafer and Sheri Nance AKSR MPFPDD, AK Accuracy Report, Lot 1. Modification of AK Accuracy reports is a Tier 2 change. CCP Hanford AKEs indicated that load management would not be performed on waste under the CCP Hanford program. Performance ofA - 10 

### ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH AK Checklist Inspection Date: April 27 - 29, 201 0

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Examples of Objective Evidence management must include in its acceptable knowledge summary report an estimate of the total waste volume and the percentage of the waste volume that is above and below

100 nCi/g. (It should be noted that this information, although based on the best available AK information, is preliminary and subject to the performance of WIPP - certified NDA measurements and cannot and will not be used as a measure of AK accuracy.) (Reference E3) (WAC, Appendix E) load management is a Tier 1 change.

AK- 30: Are nonconforming wastes segregated? Are NCRs dispositioned in an appropriate and technically defensible manner? (WAP B4, Section B4 - 3b, Attachment B3, Section B3 - 13) CCP - TP - 00 5, Revision 18, Section 4.9 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance NCR - RL - 001 - 10,; NCR RL - 0600 - 10 - 0617 - 20; NCR 1201 - 1203. Example NCRs primarily due to presence of various prohibited items (i.e. liquids in prohibited quantities), LLW, Identified adequately through NCR preparation. AK- 31: Do site procedures require that additional information be collected before waste may be shipped if the required AK information is not available for a waste stream or if available AK is poor or unacceptable? (WAP B4 ) CCP - TP - 005, Revision 18, Sections 4.4.2, 4.4.3 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance CCP indicated that there have been no examples where additional information had to be collected be cause of poor AK. EPA notes that CCP often access historic site data including RTR, VE, and NDA data acquired from the previous Hanford program. AK- 32: Do these procedures facilitate the mandatory traceability analysis performed for each Summary Waste C ategory Group examined during the audit, noting that EPA will determine whether the available waste streams adequately demonstrate the full characterization process for the proposed scope? (WAP B4, Section B4 - 2) CCP - TP - 005, Revision 18, Section 4.4 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance AKSD MCPFPDD; HNF - 6489 HNF - 36515, Source Documents IINSERT EXAMPLES); BDRs (RTR, VE, NDA) for Drums 0056238, 0063057, 0055034; Historic Documentation from site records, PTS/CTS, WWIS print - outs for the above containers. All of the above were examined from initial AK documentation through CCP Hanford characterization and drum management. Drum records examined for each included the following:

- Historic Documentation from the Hanford Site Records Storage Facility and Integrated Document Management system (IDMS), including TRU/TRU Mixed Waste Contents Inventory Sheet, Waste Designation worksheet, Inspection Sheet forA - 11 

### ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH AK Checklist Inspection Date: April 27 - 29, 201 0

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Examples of Objective Evidence Loaded/Sealed TRUITRU Mixed Waste Drum, Inspection Sheet for Empty 55 - Gal lon Waste Drum, and Certificate of Conformance

- Solid Waste Information Tracking System (SWITS) database records including the SWITS Container Listing Report

- TRU Electronic Data Management Tool (TRUEDMT) database Print Outs

- BDRs (NDA and RTR)

- CCP Program Tracking Sheet (PTS) printout - each container These data indicate that historic information pertaining to waste drum content is available. AK- 33: If AK was used (i.e., data collected prior to QA program), what method was employed to qualify the inf ormation? Approved methods or peer review , corroborating data, confirmatory testing, and QA program equivalency? If confirmatory testing is used, has the following been considered (from WAC)?*  At a minimum, to confirm existing AK data, it is necessary to com

pare ratios of the two most prevalent radionuclides in the isotopic mix *I f the WAC requirements are not followed, identify how the specific radionuclides are characterized via AK, and how these data are used by NDA. (40 CFR 149.22(b), WAC, Appendix A , Section A.2.1) CCP - TP - 005, Revision 18 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance AKSR MPFPDD, CCP - TP - 005 Attachment 7 and NDA Memo; P976; data were confirmed by 100% confirmatory testing using NDA. The NDA memo describes how

AK is used by NDA. It must be noted that the WAC Appendix A is typically not followed because the nature of the waste at sites is not amenable to the approach. CCP Hanford evaluated radiological characteristics of the waste stream based on WWIS d ata, which represents the MCPFPD component of the waste stream. Data from 5856 drums were evaluated (4528 drums emplaced, 1328 certified drums in the WWIS that were not shipped). 239 Pu and 238 U most prevalent isotopes by mass. An isotopic distribution was established for Pu and U isotopes that will be used by NDA personnel when assay results are not acceptable. Distribution indicates that initial weapons grade Pu produced at Hanford exhibited a 240 Pu weight percentage between approximately 0.9 - 7%. Fuel material processed at Hanford exhibited a 240 Pu weight percent of 8 - 27% for experimental reactor technology as well as other technologies. 241 Am is present due to decay of 241 Pu or from the Waste Treatment complex (242 - Z). CCP uses default isotopics based on theA - 12 

### ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH AK Checklist Inspection Date: April 27 - 29, 201 0

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Examples of Objective Evidence percent 240 Pu (6%, 12%, 23%) and assigns the defaults based on 240 Pu identified on the drum records. These distributions appear reasonable based on available data. Comparison of default isotopics with measured data in the WWIS indicated good agree me nt assuming the material in the WWIS was represented by weapons grade Pu. AK- 34: Are radioassay and NDE results compared to the AK to verify implementation of the characterization program? (194.24 (c)(3); 194.22(b)) CCP - TP - 005, Revision 18, Section 4. 5.3, Attachment 13 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance AK Accuracy Report, CCP - TP - Attachment 13. An example characterization checklist demonstrated that data examined based on the WSPF and BDRs indicates that result s thus far have compared well to AK. AK- 35: This procedure requires a reevaluation of AK if NDE identifies it to be a different waste matrix code. This procedure describes how the waste must be reassigned, based on the AK reevaluation. (WAP B4, Section B4 - 3e) CCP - TP - 005, Revision 18, Section 4.9, Attachment 10 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance CCP - TP - 005 Revision 18, Attachment 10, C037. No Attachment 10s were yet prepared for the audited waste streams although CCP had demonstrated the ability to create these Attachments as warranted by the data. An example of a LANL Attachment 10 was provided. AK- 36: Does the generator site have written procedures for newly generated waste to document the confirmation of acceptable knowledge information with visual examination prior to or during waste packaging? Do these procedures address the required elements in B4 - 3e? (WAP B4, Section B4 - 3e) CCP - TP - 005, Revision 18, CCP - TP - 001, CCP - TP113. Revie w of objective evidence and interview of Steve Schafer and Sheri Nance VE BDRs RLVEPF0001 - 0004, 0008 - 0013. Data indicate that confirmation occurs; no characterization/confirmation checklist was provided for review . AK- 37: Procedures require the following steps to be followed if wastes are reassigned to a different waste matrix code based on NDE:  Revie w existing information based on the container identification number and document all differences  Reassess and document all analytical data associated with the waste  Reevaluate waste material parameter determinations and document any changes CCP - TP - 005, Revision 18, Section 4.8, Attachment 10 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance CCP did not provide an example of an AT Re Evaluation Checklist Attachment 10 pertinent to this waste stream because no checklist had been required up to the date of the inspection. However, an example for LANL was provided.A - 13 

### ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH AK Checklist Inspection Date: April 27 - 29, 201 0

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Examples of Objective Evidence  Reevaluate the radionuclide content and document any changes  Verify and document that the reassigned waste matrix code was generated within the specified time period, area and buildings, waste generating process, and that the process material inputs are consistent with the waste material parameters identified during radiography or visual examination  Record all changes to acceptable knowledge records  If discrepancies exist in the acceptable knowledge information for the reassigned waste matrix code, complete a nonconformance report, document the segregation of this container, and define the corrective actions necessary to fully characterize the waste (WAP B4, Section B4 - 3e) AK- 38: Has the site project manager calculated the percent changes in waste matrix code based on AK and NDE/VE? Were accuracy evaluations assigned? Are these accep table? (WAP B3, Section B3 - 9; WAC Appendix A, Section A.6.5) CCP - TP - 005, Revision 18, Section 4.6, Attachment 14 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance AK Accuracy Report, March 2010. No containers were identified by C CP Acceptable Knowledge as having radionuclides outside the expected ranges for MPFPDD. The AK Accuracy report indicated that while the two most prevalent radionuclides are current, 239 Pu and 240 Pu, AK indicates that 239 Pu and 238 U should be the two mo st prevalent based on weight. CCP said there isn’t enough data to conclude that there is a major shift in expected AK, so they didn’t identify this as an AK Accuracy issue yet. There was no reassignment of WMS, nor was there reassignment based on HWN assignment. CCP concluded that based on these criteria, the accuracy for the waste stream is 100%. AK- 39: Are the following items addressed with respect to AK -NDA communication and the use of AK data by NDA personnel?  Do procedures require the identification of AK data CCP - TP - 005, Revision 18, Section 4.4.22 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance P976, P1084, NDA Memo. CCP NDA and AK Personnel prepared and reviewed the AK NDA memo which addresses AK based was te stream descriptions and radionuclide distributions, prevalent radionuclides based on AK, and AK dataA - 14 

### ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH AK Checklist Inspection Date: April 27 - 29, 201 0

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Examples of Objective Evidence limitations?  Are AK data and associated limitations communicated to NDA personnel and is this required by procedure?  How is AK used by NDA personnel?  Do AK and NDA personnel communicate and agree about the use of AK?  Is this agreement procedural ized? (WAC, Appendix A) limitations. It also addresses, specifically, how the data will be used during NDA, s tating that AK based default isotopics will be used if NDA does no t yield adequate results. Assay interferences are also addressed.

AK- 40: Have internal AK audits been performed? (WAP B4, Section B4 - 3d, g) CCP - TP - 005, Revision 18, Section 4.5.1 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance WTS Quality Assurance Audit I09 - 06, August 2009. The Audit only addressed AK records, and did not address the actual AK process. CCP indicated that an audit addressing the AK more comprehensively was in progress, but results were not available for EPA ’s inspection. AK- 41: If data consistently indicate discrepancies with acceptable knowledge information, the site increases sampling, reassesses the materials and processes that generate the waste, and resubmits waste stream profile information. (WAP B4, Sections B4 - 3b, B4 - 33) CCP - TP - 005, Revision 18, Attachment 10 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance MPFPDD WSPF, CCP - TP - 005 Attachment 10 (not available for this inspection). CCP indicated that thus far, consistent discrepancies with respect to AK information have not been observed.

AK- 42: Are acceptable knowledge processes consistently applied among all generator sites, and does each generator site comply with the following data quality requirements for acceptable knowledge documentation: a. Precision - Precision is not applicable to AK (see Attachment B4) b. Accuracy - Accuracy is the degree of agreement between an observed sample result and the true value. The percentage of waste containers which require reassignment to a new waste matrix code is based on the reevaluation of acceptable knowledge and sampling and analysis data will be reported as a measure of acceptable knowledge accuracy. Accuracy based on CCP - TP - 005, Revision 18 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance AK Accuracy Report, March 2010, Semi - annual Trend Report, March 2010, Training Records, Steve Schafer, Sheri Nance. Data limitations addressed in Attachment 3s and DRs. Trend Report provides a summary of relevant CCP work including results of assessments, significant issues, trend analysis results, performance assessments of Quality Control (QC) data, and performance assessments against QA Objectives. The AK Records co ntain the required information.A - 15 

### ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH AK Checklist Inspection Date: April 27 - 29, 201 0

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Examples of Objective Evidence radionuclide content is typically assessed by comparing measured results with AK data. c. Com pleteness - Com

pleteness is an assessment of the number of waste streams or number of samples collected to the number of samples determined to be useable through the data validation process. The a cceptable knowledge record must contain 100 percent of the information specified in Section B4 - 2. The usability of the acceptable knowledge information will be assessed for completeness during audits. d. Com parability - Data are consi dered comparable w hen one set of data can be compared to another set of data. Com parability is ensured through sites meeting the training requirements and complying with the minimum standards outlined for procedures that are used to im plement the acceptabl e knowledge process. WAC Section A.6.5: Additionally, comparison of measured data with AK - derived or -based values, as applicable, provides a means to assess comparability on a waste stream basis. e. Representativeness - Representativeness expresses the degree to w

hich sample data accurately and precisely represent characteristics of a population. Representativeness is a qualitative parameter that will be satisfied by ensuring that the process of obtaining, evaluating, and documenting acceptable knowledge information is performed in accordance with the minimum standards established in Section B3. Sites also must assess and document the limitations of the acceptable knowledge information used to assign waste parameters. (WAP B3, Section B3 - 9) AK- 43: Does the generator site address quality control by tracking its performance with regard to the use of acceptable knowledge by: (1) assessing the frequency of inconsistencies among information, and (2) documenting the results of acceptable knowledge confirmation through CCP - TP - 005, Revision 18, CCP - QP - 019 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance Semi - annual Trend Report, March 2010. CCP QP - 019 identifies items to be addressed in the report: It identified the number of certification audits that were performed during that time period, the NCRs identified, significant QA or QCA - 16 

### ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH AK Checklist Inspection Date: April 27 - 29, 201 0

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Examples of Objective Evidence radiography or visual examination? In addition, the acceptable knowledge process and waste stream documentation must be evaluated through internal assessments by quality ass urance organizations and assessments by auditors or observers external to the organization (i.e., CBFO, NMED, EPA). (WAP B3, Section B3 - 9) problems (CARs), PDP results, results of audits and surveillances, etc. It was noted that CCP used NDA equipment at INL that were not yet certified by EPA, and the assayed drums were entered in the WWIS. The drums were removed from the WWIS, and the Trend Report states that this caused no adverse trends. The report also indicated that 264 Trend Code Ls dealing with AK were issued in 2008 and 2009. This means that AK was the primary source of error as reported in this document with respect to all other Trend Codes. However, no AK CARS were issued. AK - 44: Did the generator site implement, or does it currently implement, process controls to ensure that prohibited items are documented and managed in accordance with site - specific certification plans? What process controls are in place to assess prohibited items and other waste characteristics (i.e. is fast scan used, and, if so, by whom)? (WAP B4, Section B4 - 3b) CCP - TP - 005, Revision 18, Section 4.4, Attachment 1 PR8, Attachment 6 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance Fast Scan (RTR); also CCP Hanford personnel indicated a non - certified type of quick VE may also be performed, as may an NDA scan to detected containers that are not TRU. Further, historic NDE and NDA data may be a ccessed.

AK- 45: Does the generator site document, justify, and consistently delineate waste streams based on site - specific permit requirements or state - enforced agreements? How do these agreements impact waste characterization? (WAP B4, Section B4 - 3e ) CCP - TP - 005, Revision 18, Attachment 1 O16 Revie w of objective evidence and interview of Steve Schafer and Sheri Nance AKSR MPFPDD; P143, P144, P145. Site clean up being performed in accordance with the Tri - Party agreement. D&D/clean up dictated by programs outside of CCP.Revisio n No.: Site specific checklist A - 17 

### Attachment A.2 Non -Destructive Assay (NDA) Checklist EPA Inspection No.: EPA- HANFORD - CCP - 10.05 - 8 NDA System: Ga mma Energy Analysis Units A & B (GEA -A & GEA- B) Inspection Date: April 27 – 29, 2010 Required Technical Eleme nts Y/N Location Verification of Activity Y/N Objective Evidence 

### System Description Identify the NDA systems by name, location and number, as appropriate. Y General system information The GEA units identified as follows: GEA - A 104 -ND - 06 - 102A; GEA - B 104 -ND - 06 - 102B. - Observation of the two GEA units at WRAP Facility during the inspection. Describe the system’s operational history including deployment at other DOE sites. Y General system information Both units were previously used for WIPP - related TRU ass ays at Hanford and had been approved for this use by EPA several times, most recently during EPA baseline inspection of Hanford (Non - CCP) in 2008 . - EPA Air Docket Nos. A - 98 - 49, II - A4 - 41 and A - 98 - 49, II - A4 - 58

For systems that have been deployed at multipl e DOE sites document pertinent aspects of each system’s development, e.g., installation of new or different detectors, software or other relevant features. Y General system information Both GEA systems are essentially unchanged with respect to hardware. Mi nor software changes have been made. - Observation of the two GEA units at WRAP Facility during the inspection. 

### System Performance Identify the period of performance relevant to this inspection and if this NDA system has prior EPA approval(s). Y General system information The GEA units became operation for WIPP assays on March 2, 2010. - GEA - A System Notebook RL NDA - GEA - A - 003, a ssigned by Susan Keathley, January 5, 2010, Building 2336W, Area 200 W; GEA - B System Notebook RL NDA - GEA - B - 004, a ssigned by Susan Keathley, January 5, 2010, Building 2336W, Area 200 W Identify the number of waste containers this system assayed during the period of performance. Of these, indicate how many Batch Data Reports (BDRs) were assembled. And how many BDRs have been promote d through Project Level Review and are available for EPA’s evaluation. Y General system information A total of 237 containers assayed for both GEA units as of 4 - 21 - 10; 30 BDRs; 13 BDRs promoted through data generation level review; 12 BDRs through Site Pro ject Manager review; 6 BDRs (3 from GEA - A and 3 from GEA - B) were provided for EPA review - GEAA BDRs RLGEAA0001, RLGEAA0002 & RLGEAA0003; GEAB BDRs RLGEAB0001, RLGEAB0002 & RLGEAB0003Revisio n No.: Site specific checklist A - 18 

### Attachment A.2 Non -Destructive Assay (NDA) Checklist EPA Inspection No.: EPA- HANFORD - CCP - 10.05 - 8 NDA System: Ga mma Energy Analysis Units A & B (GEA -A & GEA- B) Inspection Date: April 27 – 29, 2010 Required Technical Eleme nts Y/N Location Verification of Activity Y/N Objective Evidence 

### General Reporting Requirements Assay systems must report quantitative values and uncertainties for 238 Pu, 239 Pu, 240 Pu, 242 Pu, 241 Am, 233 U, 234U, 238 U, 90 Sr, and 137 Cs. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Both GEA units report quantitative values and uncertainties for 238 Pu, 239 Pu, 240 Pu, 242 Pu, 241 Am, 23 3 U, 234U, 238 U, 90 Sr, and 137 Cs. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report Each container characterized and intended for disposal at WIPP must contain TRU waste. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Containers assayed on both GEA units meet criteria for TRU waste or they are removed via NCRs. Y GEAA BDRs RLGEAA0001, RLGEAA0002 & RLGEAA0003; GEAB BDRs RLGEAB0001, RLGEAB0002 & RLGEAB0003 NDA instruments and procedures must be appropriate for the waste streams being assayed. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Both GEA units are appropriate for the waste streams they are currently assaying. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report NDA instruments and procedures result in unbiased values for the cumulative activity of the WIPP radionuclide inventory. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 GEA radionuclide values are acceptable for calculating the cumulative activity of the WIPP radionuclide inventory. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy As say (GEA) System Unit B Calibration, Confirmation and Verification Report; GEAA BDRs RLGEAA0001, RLGEAA0002 & RLGEAA0003; GEAB BDRs RLGEAB0001, RLGEAB0002 & RLGEAB0003Revisio n No.: Site specific checklist A - 19 

### Attachment A.2 Non -Destructive Assay (NDA) Checklist EPA Inspection No.: EPA- HANFORD - CCP - 10.05 - 8 NDA System: Ga mma Energy Analysis Units A & B (GEA -A & GEA- B) Inspection Date: April 27 – 29, 2010 Required Technical Eleme nts Y/N Location Verification of Activity Y/N Objective Evidence Some radionuclides are derived by the application of scaling factors or correlation tec hniques. Identify all radionuclides that are quantified in this manner. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Scaling factors are used to quantify 234U and 90 Sr based on correlations with 235 U/238 U and 137 Cs, respectively. MGA and MGA - U are used and both software programs key on specific photons lines and use them to infer other radionuclides. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revisio n 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report Assess the technical adequacy of the calculations involving the application of scaling factors and/or correlation techniques. Y CCP - PO - 002, CCP Waste Certificati on Plan, Revision 24 Scaling factors used to quantify 234U and 90 Sr based on correlations with 235 U/238 U and 137 Cs are technically adequate. Y CCP - TP - 072, Revision 0 Identify the procedures that govern this function and where the results of these calculations are documented. Y The procedure that governs the application of scaling factors is CCP - TP - 072, Revision 0 and the results are documented in the NDA BDRs. CCP - TP - 072, Revision 0; GEAA BDRs RLGEAA0001, RLGEAA0002 & RLGEAA0003; GEAB BDRs RLGEAB0001, RL GEAB0002 & RLGEAB0003 

### Acceptable Knowledge (AK) If isotopic ratios based on AK are used the values must be qualified by confirmatory testing. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Isotopic ratios are used in quantifying radionuclides fo r waste streams that have approved AKbased data. Y CCP - TP - 072, Revision 0 Do NDA personnel use AK derived isotopic values to calculate radionuclide values? If so, is this function performed according to a formal procedure? Assess the technical adequacy of this process(s). Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 NDA personnel using AK - derived isotopic values to calculate radionuclide values use a formal CCP technical procedure. Y CCP - TP - 072, Revision 0; GEAA BDRs RLGEAA0001, RLGEAA0002 & RLGEAA0003; GEAB BDRs RLGEAB0001, RLGEAB0002 & RLGEAB0003 Identify the procedure and where the results of these calculations are documented. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 The procedure for AK related calculations is CCP - TP - 072, Revision 0 and results of these calculations are recorded in the NDA BDRs. Y CCP - TP - 072, Revision 0; GEAA BDRs RLGEAA0001, RLGEAA0002 & RLGEAA0003; GEAB BDRs RLGEAB0001, RLGEAB0002 & RLGEAB0003Revisio n No.: Site specific checklist A - 20 

### Attachment A.2 Non -Destructive Assay (NDA) Checklist EPA Inspection No.: EPA- HANFORD - CCP - 10.05 - 8 NDA System: Ga mma Energy Analysis Units A & B (GEA -A & GEA- B) Inspection Date: April 27 – 29, 2010 Required Technical Eleme nts Y/N Location Verification of Activity Y/N Objective Evidence 

### Isotopic Determination Identify the radionuclides that are me asured directly and the specific radiation type that is measured. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 The radionuclides that are measured directly are all gamma (photon) emitters. Y GEA Units A and B Radionuclide Listing Library, Filename: C: \GENIE2K\CAMFILES \CCPW RAP.nlb, generated April 37, 2010 Identify the method(s) used to derive the isotopic contribution for the unmeasured radionuclides, e.g., MGA, FRAM or other technique. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 The isotopic contributions for the unmeasured radionuclides are derived using MGA, MGAU and FRAM, as needed. Y CCP - TP - 072, Revision 0; Use of Isotope Correlation Techniques to Determine 242

Pu Abundance , R. Gunnink, 1980 

### Low er Level of Detection (LLD) The LLD for each NDA system must be determined. For multi modal systems this may require a separate determination for each mo de, i.e., active neutron, passive neutron and gamma. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 The LLDs for both GEA units have been determined and documented. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report Site - specific environmental backgrounds and container - specific interferences must be accounted for in LLD determinations. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Site - specific backgrounds are taken in account for both GEA units. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report NDA instruments performing TRU/Non TRU waste discrimination measurements are required to have a LLD no greater than 100 nCi/g. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Both GEA unit are used to discriminate TRU and Non - TRU wa stes and each sys tem has the required sensitivity, i.e., an LLD < 100 nCi/g. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit BRevisio n No.: Site specific checklist A - 21 

### Attachment A.2 Non -Destructive Assay (NDA) Checklist EPA Inspection No.: EPA- HANFORD - CCP - 10.05 - 8 NDA System: Ga mma Energy Analysis Units A & B (GEA -A & GEA- B) Inspection Date: April 27 – 29, 2010 Required Technical Eleme nts Y/N Location Verification of Activity Y/N Objective Evidence Calib ration, Confirmation and Verification Report The technical basis and derivation for LLDs must be technically adequate and appropriately documented. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 The technical basis and derivation for LLDs for both GEA units are technically adequate and appropriately documented. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report For radionuclides that are not determined primarily by measurement an LLD analog, i.e., a reporting threshold must be used when it is technically feasible. Identify all instances when this occurs and the form of the documentation of these activities. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 The radionuclides that are not determined primarily by measurement an LLD analog, i.e., a reporting threshold is used when it is technically feasible. All instances when this occurs are documented appropriately. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Cal ibration, Confirmation and Verification Report Identify any/all instances where an LLD value for a non - measured radionuclide is not provided basis on a lack of technical feasibility. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Any/all instance s where an LLD value for a non - measured radionuclide is not provided basis on a lack of technical feasibility are documented. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA

_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report Are LLD values container/assay event specific or are typical LLD values applied to a class or type of wastes, i.e., those with similar attribute s? If LLD values are not container/assay event specific identify the attributes or characteristics whereby waste Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 LLD values have been determined for classes of wastes by density to demonstrate adequate sensitivity over the operational range, however, each assay event produces a unique LLD. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit BRevisio n No.: Site specific checklist A - 22 

### Attachment A.2 Non -Destructive Assay (NDA) Checklist EPA Inspection No.: EPA- HANFORD - CCP - 10.05 - 8 NDA System: Ga mma Energy Analysis Units A & B (GEA -A & GEA- B) Inspection Date: April 27 – 29, 2010 Required Technical Eleme nts Y/N Location Verification of Activity Y/N Objective Evidence containers are grouped. Calibration, Confirmation and Verification Report 

### Total Measurement Uncertainty (TMU) The method used to calculate the TMU for all required quantities must be documented and technically justified. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 The method used to calculate the TMU for all required quantities is documented and technically justified. Y CCP - RL - GEA - 003, Total Measurement Uncertainty (TMU) for the Gamma Energy Assay Systems TMU determination accounts for all sources of uncertainty, specifically  Random errors  Calibration  Isotopic determination  Matrix inhomogeneity  Difference between calibration assumptions and actual waste  Non uniform source distribution  End effects  Self absorption  Transmission source  Self shielding  Neutron multiplication Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 The TMU determination accounts for all sources of uncertainty, specifically:  Random errors  Calibration  Isotopic determination  Matrix inhomogeneity  Difference between calibration assumptions and actual waste  Non uniform source distribution  End effects  Self absorption  Transmission source  Self shielding  Neutron multiplication Y CCP - RL - GEA - 003, Total Measurement Uncertainty (TMU) for the Gamma Energy Assay Systems

Methods to determine TMU must be documented, reviewed and approved by CBFO for each NDA instrument. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 The TMU report for both GEA units wa s approved by CBFO. CCP - RL - GEA - 003, Total Measurement Uncertainty (TMU) for the Gamma Energy Assay SystemsRevisio n No.: Site specific checklist A - 23 

### Attachment A.2 Non -Destructive Assay (NDA) Checklist EPA Inspection No.: EPA- HANFORD - CCP - 10.05 - 8 NDA System: Ga mma Energy Analysis Units A & B (GEA -A & GEA- B) Inspection Date: April 27 – 29, 2010 Required Technical Eleme nts Y/N Location Verification of Activity Y/N Objective Evidence 

### System Calibration Each NDA instrument must be calibrated before its initial use. Determine the date of the system’s calibration of record and where this is documented. Y CCP - PO - 002, CCP Waste C ertification Plan, Revision 24 The energy calibrations for both GEA units that were established by Hanford outside of CCP are the calibrations of record. Both GEA units had new efficiency calibrations performed by CCP. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report The range of applicability of the system’s calibration(s) must be specified in site procedures or other formal documentation. Identify the manner in which the range is expressed, i.e., curies or Pu/SNM mass for activity and salient physical characteristics for matrix. Y CCP - PO - 002, CCP Waste Certificati on Plan, Revision 24 The ranges of both GEA units are expressed in terms of nuclear material content (grams of WG Pu) and matrix (material density in g/cm 3 ). Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report Any matrix/source surrogate waste combinations must be representative of the activity ranges and relevant waste matrix characteristics currently in use or planned for use by the system. The system must be calibrated to 100% recovery. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Matrix/source surrogate waste combinations used are representative of the ac tivity ranges and relevant physical characteristics of the matrices currently measured or planned for use by the system. The system is calibrated to 100% recovery. Y CCP - TP - 070, Revision 0, CCP Gamma Energy Assay (GEA) Calibration, Confirmation and Verifi cation Procedure; CCP - RL GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report The use of consensus standards for calibration is required, when such standards exist. If consensus standards do not exist, the calibration technique must be approved by CBFO. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 ASTM C - 1133 - 03 is th e consensus standard that was used for calibration of both GEA units. Y CCP - TP - 070, Revision 0, CCP Gamma Energy Assay (GEA) Calibration, Confirmation and Verification ProcedureRevisio n No.: Site specific checklist A - 24 

### Attachment A.2 Non -Destructive Assay (NDA) Checklist EPA Inspection No.: EPA- HANFORD - CCP - 10.05 - 8 NDA System: Ga mma Energy Analysis Units A & B (GEA -A & GEA- B) Inspection Date: April 27 – 29, 2010 Required Technical Eleme nts Y/N Location Verification of Activity Y/N Objective Evidence Identify the specific consensus standards that were used for the system calibration or, in their absence, the alternate calibration technique. Evaluate the CBFO approval of the alternate technique. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 See answer to previous checklist item. Y See answer to previous checklist ite m. Primary standards must be obtained from suppliers maintaining a nationally accredited measurement program. Identify the nationally accredited measurement program. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Primary gamma standards have been obtained from LANL (WG Pu standards) and North American Scientific (mixed gamma sources). Both suppliers maintain a nationally accredited measurement program that has been identified and appropriately documented. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report List the standards used for calibration and verify the pedigree of each standard. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 The calibration standards are listed in the calibration reports and the pedigree of each has been verified. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report 

### Calibration Verification & Confirmation Verification of an NDA instrument’s c alibration must be performed after any of the following occurrences: major system repairs and/or modifications, replacement of the system’s components, significant changes to the system’s software, and relocation of the system. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 The calibration of both GEA units has been verified performed and documented as required. Y CCP - TP - 070, Revision 0, CCP Gamma Energy Assay (GEA) Calibration, Confirmation and Verification Procedure; CCP - RL GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification ReportRevisio n No.: Site specific checklist A - 25 

### Attachment A.2 Non -Destructive Assay (NDA) Checklist EPA Inspection No.: EPA- HANFORD - CCP - 10.05 - 8 NDA System: Ga mma Energy Analysis Units A & B (GEA -A & GEA- B) Inspection Date: April 27 – 29, 2010 Required Technical Eleme nts Y/N Location Verification of Activity Y/N Objective Evidence Recalibration of the system must occur if the calibration verification demonstrates that the system’s response has significantly changed. NA CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Not applicable, theses systems have not been relocated. NA NA The system calibration must be confirmed by performing replicate measurements of a non interfering matrix. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 The system calibration has been confirmed by performing replicate measurements of a non - interfering matrix. Y CCP - TP - 070, Revision 0; CC P RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report Replicate measurements must be performed with containers of the same nominal size and according to the same procedures used for actual waste assays. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Replicate measurements have been performed with containers of the same nominal size and according to the same procedures as those used for actual waste assays. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report Replicate measurements must be performed using nationally recognized standards or standards derived from nationally recognized standards that span the range of use of the instrument with respect to disintegration rate and/or matrix effects. Identify all standards that were used and indicate their application (verification or confirmation). Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Replicate measurements have been p erformed using nationally recognized standards or standards derived from nationally recognized standards that span the range of use of the instrument with respect to disintegration rate and/or matrix effects. All standards that were used have been identifi ed and their application documented. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report Identify the nationally accredited measurement program. List the standards used for verification/confirmation and verify the pedigree of each standard. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 The nationally accredite d measurement program has been identified and the pedigree of the gamma and WG Pu standards used for verification and/or confirmation Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001,Revisio n No.: Site specific checklist A - 26 

### Attachment A.2 Non -Destructive Assay (NDA) Checklist EPA Inspection No.: EPA- HANFORD - CCP - 10.05 - 8 NDA System: Ga mma Energy Analysis Units A & B (GEA -A & GEA- B) Inspection Date: April 27 – 29, 2010 Required Technical Eleme nts Y/N Location Verification of Activity Y/N Objective Evidence has been verified. Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report The standards used for calibration confirmation must not be the same sources as those used for the system’s calibrati on of record. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 The WG Pu standards used for calibration confirmation are not the same as the gamma sources used for the system’s calibration of record. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report Requirements for accuracy, expressed as %R, and precision, expressed as %RSD, must be met as specified in DOE/WIPP - 02 - 3122, Appendix A, Table A - 3.2 for precision and  30% for accuracy. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Requirements for accuracy and precision have been met as specified in DOE/WIPP - 02 - 3122, Appendix A, Table A - 3.2 for precision and  30% for accuracy. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report 

### Quality Control All radioassay and data validation must be performed by appropriately trained and qualified personnel. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 All radioassay and data validation has been performed by appropriately trained and qualified personnel. Y GEAA BDRs RLGEAA0001, RLGEAA0002 & RLGEAA0003; GEAB BDRs RLGEAB0001, RLGEAB0002 & RLGEAB0003 Identify the name, title and function of all personnel performing NDA data vali dation. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 The name, title and function of all personnel performing NDA data validation are documented. Y GEAA BDRs RLGEAA0001, RLGEAA0002 & RLGEAA0003; GEAB BDRs RLGEAB0001, RLGEAB0002 & RLGEAB0003 Requalification of personnel must be based on evidence of continued satisfactory performance and must be performed at least Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Requalification of personnel is based on evidence of continued satisfactory performance and is Y Hanford - CCP List of Qualified Individuals, NDA GEA, April 14, 2010, 11:32 AMRevisio n No.: Site specific checklist A - 27 

### Attachment A.2 Non -Destructive Assay (NDA) Checklist EPA Inspection No.: EPA- HANFORD - CCP - 10.05 - 8 NDA System: Ga mma Energy Analysis Units A & B (GEA -A & GEA- B) Inspection Date: April 27 – 29, 2010 Required Technical Eleme nts Y/N Location Verification of Activity Y/N Objective Evidence every two years. current. All computer programs, including spreadsheets used for data reduction or analysis, must meet the applicable requirements in the CBFO Q APD. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Not assessed during this inspection. NA Not assessed during this inspection. The site must participate in relevant measurement comparison programs sponsored or approved by CBFO, including the ND A PDP. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Hanford - CCP participated in the CBFO - sponsored NDA PDP, Cycle 17A (May 2010 distribution) by assaying S5000 wastes containing debris, glass, and sludge . Y 

### Background and Performance Checks A ssay system background measurements must be taken daily, unless otherwise approved by CBFO. Determine the form of CBFO approval documentation of the alternate approach to backgrounds, if applicable. Contributions to backgrounds from nearby radiation sourc es must be carefully controlled, or more frequent backgrounds must be measured. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Daily background measurements have been taken and recorded daily. Contributions to backgrounds from nearby radiation so urces (i.e., other wa ste drums stored or staged inWRAP) have been carefully controlled. Y GEAA BDRs RLGEAA0001, RLGEAA0002 & RLGEAA0003; GEAB BDRs RLGEAB0001, RLGEAB0002 & RLGEAB0003

Assess how often background radiation was problematic to the extent that measurement personnel had to make adjustments. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Background records document the performance of both GEA units over time. Y GEAA BDRs RLGEAA0001, RLGEAA0002 & RLGEAA0003; GEAB BDRs RLGEAB0001, RLGEAB00 02 & RLGEAB0003 Identify the criteria used to evaluate instrument backgrounds and assess the technical adequacy of this criterion, i.e., statistical or administrative. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Backgrounds have been evaluated against a technically appropriate acceptance criterion and the nature and results of these evaluations have been documented. Y GEAA BDRs RLGEAA0001, RLGEAA0002 & RLGEAA0003; GEAB BDRs RLGEAB0001, RLGEAB0002 & RLGEAB0003 Identify the number of data points required to derive the initial control limit. At what interval(s) will ne w limits be calculated? Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 The number of data points required to derive the initial control limit and the interval(s) at which will new limits be calculated are documented. Y CCP - TP - 072, Revision 0Revisio n No.: Site specific checklist A - 28 

### Attachment A.2 Non -Destructive Assay (NDA) Checklist EPA Inspection No.: EPA- HANFORD - CCP - 10.05 - 8 NDA System: Ga mma Energy Analysis Units A & B (GEA -A & GEA- B) Inspection Date: April 27 – 29, 2010 Required Technical Eleme nts Y/N Location Verification of Activity Y/N Objective Evidence System performance checks must be performed at least once per operational day. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Performance checks have been performed at least once per operational day and all checks have been documented. Y GEAA BDRs RLGEAA0001, RLGEAA0002 & RLGEAA0003; GEAB BDRs RLGEAB0001, RLGEAB0002 & RLGEAB0003 System performance checks must include, as applicable, efficiency, matrix correction checks, and sys tems peak position and resolution for spectrometric systems. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Performance checks include efficiency, matrix correction checks, and peak position and resolution checks. Y GEAA BDRs RLGEAA0001, RLGEAA000 2 & RLGEAA0003; GEAB BDRs RLGEAB0001, RLGEAB0002 & RLGEAB0003 At a minimum of once per operational week an interfering matrix must be assayed to assess the long term stability of the NDA instrument and its matrix corrections and how this performance is do cumented. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 An interfering matrix is used to assess the long term stability of the GEA units and their matrix corrections at least once per operational week. This activity is appropriately documented. Y CCP - RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report Interfering surrogate waste matrices must be constructed in a way that the salient matrix characteristics do not change over time. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Interfering surrogate waste matrices have been constructed such that the salient matrix characteristics do not change over time. Y CCP - TP - 072, Revision 0; CCP RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report The radionuclide sources used for performance checks must be long - lived and of sufficient strength (activity) to provide statistically sufficient results over a short measurement time. Y CCP - PO - 002, C CP Waste Certification Plan, Revision 24 The WG Pu and gamma sources used for performance checks are long - lived and are of sufficient activity to provide statistically sufficient results over a short measurement time. Y CCP - TP - 072, Revision 0; CCP RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit BRevisio n No.: Site specific checklist A - 29 

### Attachment A.2 Non -Destructive Assay (NDA) Checklist EPA Inspection No.: EPA- HANFORD - CCP - 10.05 - 8 NDA System: Ga mma Energy Analysis Units A & B (GEA -A & GEA- B) Inspection Date: April 27 – 29, 2010 Required Technical Eleme nts Y/N Location Verification of Activity Y/N Objective Evidence Calibration, Confirmation and Verification Report Radioactive sources are decay corrected as a function of their physical half life, as appropriate, specifically 133 Ba, 252 Cf, 137 Cs, 75 Se and 109 Cd. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Radioactive sources are decay corrected as a function of their physical half lif

e, as appropriate. Y CCP - TP - 072, Revision 0; CCP RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report Performance checks must be quantitative and based on 2 and 3 sigma limits. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Performance checks are quantitative and based on 2 and 3 sigma limits. Y CCP - TP - 072, Revision 0; CCP RL - GEA_A - 001, Revision 0, Gamma Energy Assay (GEA) System Unit A Calibration, Confirmation and Verification Report; CCP - RL - GEA_B - 001, Revision 0, Gamma Energy Assay (GEA) System Unit B Calibration, Confirmation and Verification Report 

### Data Management All radioassay data must be reviewed and approved by qualified personnel before being reported to WWIS. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 All radioassay data have been reviewed and approved by qualified personnel before being reported to WWIS. Y CCP - TP - 072, Revision 0; GEAA BDRs RLGEAA0001, RLGEAA0002 & RLGEAA0003; GEAB BDRs RLGEAB0001, RLGEAB0002 & RLGEAB0003 Identify the name, title and function of the individual(s) performing technical review and approval of NDA BRDs. Y CCP - PO - 00 2, CCP Waste Certification Plan, Revision 24 The name, title and function of the individual(s) performing technical review and approval of NDA BRDs are documented on the LOQI and in CCP training records. Y CCP - TP - 072, Revision 0; Hanford - CCP List of Qualif ied Individuals, NDA GEA, April 14, 2010, 11:32 AMRevisio n No.: Site specific checklist A - 30 

### Attachment A.2 Non -Destructive Assay (NDA) Checklist EPA Inspection No.: EPA- HANFORD - CCP - 10.05 - 8 NDA System: Ga mma Energy Analysis Units A & B (GEA -A & GEA- B) Inspection Date: April 27 – 29, 2010 Required Technical Eleme nts Y/N Location Verification of Activity Y/N Objective Evidence Radioassay BDRs must consist of the following elements:  Testing facility name, testing batch number, container numbers, and signature of the Site Project Officer (SPO) or designee(s)  Table of Contents  Bac kground and performance check data or control charts for the relevant time period.  Data validation per the QAPD and site procedures  Separate testing report sheets for each container. Y CCP - PO - 002, CCP Waste Certification Plan, Revision 24 Radioassay BRDs c onsist of the following elements:  Testing facility name, testing batch number, container numbers, and signature of the Site Project Officer (SPO) or designee(s)  Table of Contents  Background and performance check data or control charts for the relevant time period.  Data validation per the QAPD and site procedures  Separate testing report sheets for each container. Y GEAA BDRs RLGEAA0001, RLGEAA0002 & RLGEAA0003; GEAB BDRs RLGEAB0001, RLGEAB0002 & RLGEAB0003

Radioassay data sheets must include:  Title “Radioa ssay Data Sheet”  Method/procedure used  Date of radioassay  Activities and associated TMU for individual radionuclides  TRU alpha concentration and its associated TMU  Operator signature  Revie wer signature Y CCP - PO - 002, CCP Waste Certification Plan, Revision 2 4 Radioassay data sheets include:  Title “Radioassay Data Sheet”  Method/procedure used  Date of radioassay  Activities and associated TMU for individual radionuclides  TRU alpha concentration and its associated TMU  Operator signature  Revie wer signature Y GEAA BDRs RLGEAA0001, RLGEAA0002 & RLGEAA0003; GEAB BDRs RLGEAB0001, RLGEAB0002 & RLGEAB0003

The following nonpermanent records must be maintained at the radioassay - testing facility or forwarded to the site project office:  Testing batch reports NA NA Not assessed during this inspection. NA NARevisio n No.: Site specific checklist A - 31 

### Attachment A.2 Non -Destructive Assay (NDA) Checklist EPA Inspection No.: EPA- HANFORD - CCP - 10.05 - 8 NDA System: Ga mma Energy Analysis Units A & B (GEA -A & GEA- B) Inspection Date: April 27 – 29, 2010 Required Technical Eleme nts Y/N Location Verification of Activity Y/N Objective Evidence  All raw data, including instrument readouts, calculation records, and radioassay QC results  All applicable instrument calibration reportsRevisio n No.: Site specific checklist A - 32 

### ATTACHMENT A.3 REAL - TIME RADIOGRAPHY (RT R) CHECKLIST EPA Inspection No.: EPA- H anford - CCP - CH - 04.10 - 8 Hanford CCP CH RTR Checklist Inspection Date: April 27 - 29, 2010 Establishment of Required Technical Elements in Procedures Y/N Location Execution of Procedures Objective Evidence/Comments RTR- 1: Site procedures identify required training and qualifications for RTR personnel. CCP - TP - 028, Revision 3 CCP - QP - 002, Revision 27 Operator training was consistent with

applicable procedures. Operator certification is current. OJT was documented for each operator. Operators are re - qualifie d every two years. RTR operators passed a training drum test that includes items common to the waste streams examined at the site (biannually). RTR operators receive training on the waste matrix parameters and typical packaging configurations expected in e ach waste stream. Current LOQI. The EPA inspectors reviewed training records and current demonstration of capability recordings to ensure that RTR operators were adequately trained and that training records were complete. Operators use the LOQI to ensure that only qualified operators performed RTR examinations. Objective evidence: 1. RTR BDRs and audio/visual recording of RTR events for selected drums contained in BDRs RLRTRA0001, RLRTRA0002, and RLRTRA0003 2. Written and audio/visual recordings of Capability De mo nstration Data Sheet for Contact - Handled Waste for various RTR operators 3. Qualification card and training records for three RTR operators/ITRs 4. CCP NDE Test Drum Inventory Sheet for HAN NDETEST - 02, - 03, and - 04 5. List of currently qualified RTR personnel RT R- 2: Site procedure(s) provide complete instructions for operators to perform the RTR examination and completion of the associated documentation. CCP - TP - 053, Revision 7 RTR operator adequately explained the

process followed for examining a drum and entering data into data forms (whether hard copy or electronic data entry is used). Prior to observing the RTR event for container RL0056204, EPA interviewed an RTR operator to ensure that they were knowledgeable about how RTR was performed and what records were generated. The operator wa s able answer all questions correctly. Objective evidence: 1. RTR BDRs and audio/visual recording of RTR events for selected drums contained in BDRs RLRTRA0001, RLRTRA0002, and RLRTRA0003 2. SOP CCP - TP - 053, Attachment 1 & 2, Table 3 3. L ist of currently qualified RTR personnel RTR- 3: The RTR procedure(s) require an image quality check to be performed. CCP - TP - 053, Revision 7, Section 4.3 Operator adequately explained how the acceptability of an image is determined. Image quality ( IQI ) c heck is performed once per day. Performance of the image quality check is documented and recorded. EPA inspectors confirmed adherence to recording quality verification requirements through intervie ws with RTR operators, observation of a RTR event, and revi ew of written BDRs and audio/video tapes. EPA was able to review the IQI for batch RLRTRA0025 (batch that observed drum was part of). Objective evidence: 1. RTR BDRs and audio/visual recording of RTR eventsRevisio n No.: Site specific checklist A - 33 

### ATTACHMENT A.3 REAL - TIME RADIOGRAPHY (RT R) CHECKLIST EPA Inspection No.: EPA- H anford - CCP - CH - 04.10 - 8 Hanford CCP CH RTR Checklist Inspection Date: April 27 - 29, 2010 Establishment of Required Technical Elements in Procedures Y/N Location Execution of Procedures Objective Evidence/Comments for selected drums contained in BDRs RLRTRA0001, RL RTRA0002, and RLRTRA0003 RTR- 4: The procedure allows the operator to adjust the RTR to accommodate the physical properties of the waste and waste containers likely to be encountered at the site. CCP - TP - 053, Revision 7, Section 4.4 Operator could identif y applicable policies and procedures governing the operation of RTR equipment. The RTR system could be adjusted. High - density material was examined with the X - ray device set on the maximum voltage and low density material at a lower voltage. Operator adequately explained what is done if an image is unacceptable (e.g., the waste is solidified or the container is lead - lined). EPA inspectors observed the RTR examination of container RL0056204 on RTR unit A and reviewed 3 completed BDRs to ensure that examinati ons were complete and adequately recorded. During the examination, the RTR operator adjusted the X - ray voltage to ensure identification of all waste items. The operator wa s able to explain disposition of containers if an im penetrable image is observed. O bjective evidence: 1. RTR BDRs and audio/visual recording of RTR events for selected drums contained in BDRs RLRTRA0001, RLRTRA0002, and RLRTRA0003 2. List of currently qualified RTR personnel RTR- 5: CCP - TP - 053, Revision 7, Section 4.3 RTR tape is high qual ity, the sound track is

audible, and the required information is contained on the audible portion of the tape. The RTR tape is consistent with the data package for the same drum. EPA inspectors confirmed adherence to recording quality verification requirements through intervie ws with RTR operators, observation of a RTR event, and review of written BDRs and audio/video tapes. Objective evidence: 1. RTR BDRs and audio/visual recording of RTR events for selected drums contained in BDRs RLRTRA0001, RLRTRA0002, and RLRTRA0003 RTR- 6: There is a procedure for determining whether the waste matches the waste stream description and Waste Matrix Code, and for determining Waste Material Parameters and weights. CCP - TP - 053, Revision 7, Section 4.4, Table 3, Attachment 2 The procedure is adequately implemented.

Operators verify that the waste matches the wa ste stream description. Waste Matrix Code is verified. If not, corrective action is taken. WMP weights are estimated by compiling an inventory of waste items and residual/packaging materials. Does the RTR operator use a standard weight lookup table to provide an estimate of WMP weights? If so, has the table been updated to reflect additional information gained through EP A inspectors observed the RTR evolution for container RL0056204 on RTR unit A and reviewed 3 com pleted BDRs to ensure that examinations were complete and adequately recorded. Attachment 2 from CCP - TP - 053 wa s used to record data and other required information. WMP weights were estimated or taken from the standard weight table provided in the RTR SOP. Container weights were obtained from Standing Order CCP - SO - RL 01. Objective evidence: 1. RTR BDRs and audio/visual recording of RTR events for selected drums contained in BDRs RLRTRA0001, RLRTRA0002, and RLRTRA0003Revisio n No.: Site specific checklist A - 34 

### ATTACHMENT A.3 REAL - TIME RADIOGRAPHY (RT R) CHECKLIST EPA Inspection No.: EPA- H anford - CCP - CH - 04.10 - 8 Hanford CCP CH RTR Checklist Inspection Date: April 27 - 29, 2010 Establishment of Required Technical Elements in Procedures Y/N Location Execution of Procedures Objective Evidence/Comments

previous RTR/VE exams or updated AK information? 2. SOP CCP - TP - 053, Attachment 1 & 2, Table 3 3. List of currently qualified RTR personnel RTR- 7: The RTR procedure provides instructions for identifying prohibited items and for processing drums containing prohibited items. CCP - TP - 053, Revision 7, Section 4.4, Table 1, Attachment 2 Operator could name prohibited items.

Operator adequately explained how the presence of free liquids is determined. Operator’s explanation of required actions if prohibited items were encountered was consistent with procedure. Corrective actions are taken when necessary. EPA inspectors observed the RTR evolution for container RL0056204 on RTR unit A. The examination was performed in accordance with CCP - TP - 053 except that an unco ntrolled and incorrect liquid volume calculation was used by the operator. This calculation was noted on a piece of scrap paper and did not appear to be part of the official record. EPA Concern Hanford - CCP - CH - RTR- 10 - 001CR was generated to address this is sue. The RTR operator, w

ho performed the on - site demonstration, was able to describe prohibited items and what actions would be taken if identified in a container during RTR examination. Although no NCRs had been initiated for validated batches, EPA revie wed NCR - RL - 0642 - 10 to ensure that NCRs were documented correctly. EPA determined that the RTR operators understood the NCR process. Objective evidence: 1. RTR BDRs and audio/visual recording of RTR events for selected drums contained in BDRs RLRTRA0001, RLRT RA0002, and RLRTRA0003 2. NCR - RL - 0642 - 10 3. List of currently qualified RTR personnel 4. Measurement Conversion Chart (uncontrolled) RTR- 8: RTR procedures include the required QC examinations, evaluation accuracy and reproducibility of the RTR process CCP - TP - 053, Revision 7, Section 4.5, 4.6 An independent replicate scan is performed

on one waste container per day or on one container per testing batch (whichever is less frequent). An independent observation of one scan (not the replicate) is performed, by a qualif ied RTR operator (anyone but the initial RTR operator). EPA reviewed 3 BDRs and determined that all required QC was performed for these batches. Objective evidence: 1. RTR BDRs and audio/visual recording of RTR events for selected drums contained in BDRs RLRT RA0001, RLRTRA0002, and RLRTRA0003 RTR- 9: Procedure(s) contain standardized forms for recording CCP - TP - 053, Revision 7, Attachments 1 RTR operator adequately explained the

process followed for examining a drum and entering data into data forms (whether hard A qualified RTR operator performs the examination and a second person electronically enters the data generated. This second person is not required to be a qualified RTRRevisio n No.: Site specific checklist A - 35 

### ATTACHMENT A.3 REAL - TIME RADIOGRAPHY (RT R) CHECKLIST EPA Inspection No.: EPA- H anford - CCP - CH - 04.10 - 8 Hanford CCP CH RTR Checklist Inspection Date: April 27 - 29, 2010 Establishment of Required Technical Elements in Procedures Y/N Location Execution of Procedures Objective Evidence/Comments RTR data and 2 copy or electronic data entry is used). Direct data entry into an electronic form is done by the RTR operator using a computer while the operator is still in the RTR booth. The electronic data file undergoes the same quality control (QC ) checks used for hand written data entries. operator. WMP weights were estimated or taken from the standard weight table provided in the RTR SOP. Container weights were obtained from Standing Order CCP - SO - RL 01. Objective evidence: 1. RTR BDRs and audio/visual recording of RTR events for selected drums contained in BDRs RLRTRA0001, RLRTRA000 2, and RLRTRA0003 2. SOP CCP - TP - 053, Revision 7 3. Standing Order CCP - SO - RL - 01, April 14, 2010 RTR- 10: Site procedures require review of Batch Data Reports (BDRs) at the data generation and project level CCP - TP - 053, Revision 7, Attachment 3 CCP - TP - 001, Revisio n 17, Attachment 2 Data generation level reviews are performed

and documented (ITR). Project level reviews are performed and documented (SPM). EPA verified that the 3 BDRs examined during the inspection had been reviewed at both data generation and project level. Objective evidence: 1. BDRs RLRTRA0001, RLRTRA0002, and RLRTRA0003Revision No.: Site specific checklist A - 36 

### ATTACHMENT A.4 VISUAL EXAMINATION (VE) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH VE Checklist Inspection Dat e: April 27 - 29, 2010 Establishment of Required Technical Elements in Procedures Location Execution of Procedures Objective Evidence/Comment VE - 1: Site procedures identify required training and qualifications for VE personnel. CCP - QP - 002, Revision 27 Vi sual Examination Expert’s (VEE)

explanation of job duties was consistent with applicable procedures. VE personnel’s training was consistent with applicable procedures. VE personnel’s certification is current. VE personnel are re - qualified every two years. VE personnel received training on specific wa ste generating processes, typical packaging configurations, WMPs expected to be found in each Waste Matrix Code. EPA reviewed training records to ensure that they were complete and current. EPA interviewed operators and a VEE to verify that they had received training about EPA’s regulation and CFR Part 194. The VEE did not have any knowledge of these subjects and EPA issued Finding Hanford - CCP - CH - VE - 10 - 005F to address lack of training. The VEE was appointed in March of 2010, after VE had begun at the site. EPA issued Concern Hanford - CCP - CH - VE - 0006CR to address this issue. The CCP Site Project Manager stated in the inspection closing meeting that this was a problem as CCP had decided to RTR all VE’d containers (except those contained in BDRs RLVEPF0022 and RLVEPF0023). Objective evidence: 1. Visual Examination BDRs RLVEPF0022 and RLVEPF0023 2. List of currently qualified VE personnel, April 14, 2010 3. Qualification card and training records for three VE operators and one VE operator/Visual Examination Expert (VEE) 4. Letter appointing the VEE, March 12, 2010 5. CCP - TP - 113, CCP Standard Contact - Handled Waste Visual Examination, Revision 13, March 11, 2009 VE - 2: Procedures and technical guidance documents provide complete in structions for performing VE. CCP - TP - 113, Revision 13 The site uses AK to identify the waste

matrix code category and to estimate waste material parameters present. Procedures are sufficiently detailed to enable the operator to determine if a waste container meets the criteria of '194.24 with regard to identifying applicable parameters with waste limits. Establish standard nomenclature, based on current site practice, so that all staff recognize waste by the same descriptors. SOP CCP - TP - 113 is a well - established procedure and contains all instructions necessary to perform VE. Table 4 of the SOP provides standard weights for common waste items. Objective evidence: 1. Visual Examination BDRs RLVEPF0022 and RLVEPF0023 2. List of currently qualified VE personnel, A pril 14, 2010 3. Qualification card and training records for three VE operators and one VE operator/Visual Examination Expert (VEE) 4. CCP - TP - 113, CCP Standard Contact - Handled Waste Visual Examination, Revision 13, March 11, 2009 VE - 3: Procedure requires an audio/visual recording of the VE event to be made. CCP - TP - 113, Revision 13 VEE is responsible for overall VE activities.

VEE/operator’s explanation of how to operate the data recording system was The EPA team interviewed this projects qualified VEE and 3 qualified VEO/ITRs and reviewed 2 BDRs to determine if the process was im plemented as written.Revision No.: Site specific checklist A - 37 

### ATTACHMENT A.4 VISUAL EXAMINATION (VE) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH VE Checklist Inspection Dat e: April 27 - 29, 2010 Establishment of Required Technical Elements in Procedures Location Execution of Procedures Objective Evidence/Comment consistent with applicable procedures. The video camera was f

ocused prior to the start of VE. An audio/videotape is made of the waste container exam and maintained as a nonpermanent record. Data on the audio/visual recording is consistent with documentation. No audio/visual recording is made of the examination because 2 qualified VEOs perform VE. Objective evidence: 1. Visual Examination BDRs RLVEPF0022 and RLVEPF0 023 2. List of currently qualified VE personnel, April 14, 2010 3. Qualification card and training records for three VE operators and one VE operator/Visual Examination Expert (VEE) 4. Letter appointing the VEE, March 12, 2010 5. CCP - TP - 113, CCP Standard Contact - Handl ed Waste Visual Examination, Revision 13, March 11, 2009 VE - 4: There is a procedure for handling instances when the VE Expert is unable to see through the inner plastic bags/ packages/ containers of waste. CCP - TP - 113, Revision 13 The VEE has decision making criteria for

assessing the need to open the bags/packages in order to identify all of their contents. If the bags are not opened, a brief w ritten description of the contents of the bags is prepared with estimates of the amount of each waste type in the bags. The VEE is not necessarily in the operations room during all VE events. The VEOs can contact the VEE at any time to discuss assignment of WMPs and any other issue encountered. The waste being Ve’d and containerized comes from dismantling of 3 story high glove boxes in the PFP Building and consequently most of the waste processed is easily recognizable. Objective evidence: 1. Visual Examination BDRs RLVEPF0022 and RLVEPF0023 2. List of currently qualified VE personnel, April 14, 2010 3. Qualification card and training records for three VE operators and one VE operator/Visual Examination Expert (VEE) 4. Letter appointing the VEE, March 12, 2010 5. CCP - TP - 113, CCP Standard Contact - Handled Waste Visual Examination, Revision 13, March 11, 2009 VE - 5: The VE procedure requires verification of Waste Matrix Code and WMP weights. CCP - TP - 113, Revision 13 If an automated data entry system is used,

data entry VE personnel could navigate through the various screens. A VE data form is used to document the wa ste matrix cod e and estimated WMP weights of the waste. VE staff have access to standardized charts or tables to aid in the consistent estimation/assignment of weights, waste material parameters, and waste matrix codes. Raw data is collected during VE and transferred onto the final data sheets outside of the VE area. This variation in the usual VE process is due to the sa fety concerns associated with the work area and the need to wear full respirator suits. The BDRs reviewed were complete. AT previous baseline inspections, the EPA inspectors have observed the VE event for a selected container. Because of the safety concerns described above, EPA’s inspection of VE was limited to review of documents and records, and interview of the VE operators and VEE. Objective evidence: 1. Visual Examination BDRs RLVEPF0022 and RLVEPF0023 2. List of currently qualified VE personnel, April 14, 2010Revision No.: Site specific checklist A - 38 

### ATTACHMENT A.4 VISUAL EXAMINATION (VE) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH VE Checklist Inspection Dat e: April 27 - 29, 2010 Establishment of Required Technical Elements in Procedures Location Execution of Procedures Objective Evidence/Comment The estimated or weighed WMP weights are determine d by

com piling an inventory of waste items, residual materials and packaging materials. The items on the inventory list are sorted by WMP and combined with a standard weight look- up table to provide an estimate of WMP weights. References tables are updated as site gains information from VE. VEE verifies Waste Matrix Code and recommends changes as needed. 3. Qualification card and training records for three VE operators and one VE operator/Visual Examination Expert (VEE) 4. Letter appointing the VEE, March 12, 2010 5. CCP - TP - 113, CCP Standard Contact - Handled Waste Visual Examination, Revision 13, March 11, 200 9

VE - 6: Procedure provides instructions for processing of containers with prohibited items. CCP - TP - 113, Revision 13 VE operator/expert’s explanation of

required actions if prohibited items were encountered was consistent with procedure. The VE operator describes any liquids found, including a description of their location in the container and estimated volume. Other prohibited items, including sealed containers are identified and segregated. Waste items are broken dow n by specialize site personnel so that the VEOs can verify that no prohibited items are present in the waste. The VE procedure provides instructions for disposition of prohibited items if they are found. Objective evidence: 1. Visual Examination BDRs RLVEPF0022 and RLVEPF0023 2. List of currently qualified VE personnel, April 14, 2010 3. Qualification card and training records for three VE operators and one VE operator/Visual Examination Expert (VEE) 4. Letter appointing the VEE, March 12, 2010 5. CCP - TP - 113, CCP Standard Contact - Handled Waste Visual Examination, Revision 13, March 11, 2009 VE - 7: Personnel can describe how an NCR is initiated. Revie w of training records and interview with the VE personnel enabled the EPA inspectors to determine that NCRS are initiated as necessary. Objective evidence: 1. Visual Examination BDRs RLVEPF0022 and RLVEPF0023 2. List of currently qualified VE personnel, April 14, 2010 3. Qualification card and training records for three VE operators and one VE operator/Visual Examination Expert (VEE) 4. Letter appointing the VEE, March 1 2, 2010Revision No.: Site specific checklist A - 39 

### ATTACHMENT A.4 VISUAL EXAMINATION (VE) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH VE Checklist Inspection Dat e: April 27 - 29, 2010 Establishment of Required Technical Elements in Procedures Location Execution of Procedures Objective Evidence/Comment 5. CCP - TP - 113, CCP Standard Contact - Handled Waste Visual Examination, Revision 13, March 11, 2009

VE - 8: CCP - TP - 113, Revision 13 The gross weight of the waste container

(container plus contents) is recorded on the VE data form. Volume utilization of the container is documented. Attachment 2, CCP Waste Visual Examination Data Form, of CCP TP - 113 requires operators to record volume utilization. EPA verified this by review of 2 BDRs. Gross weight of the container is determined after conclusion of VE and hence was not reviewed. Objective evidence: 1. Visual Examination BDRs RLVEPF0022 and RLVEPF0023 2. List of currently qualified VE personnel, April 14, 2010 3. CCP - TP - 113, CCP Standard Contact - Handled Waste Visual Examination, Revision 13, March 11, 2009 VE - 9: C CP - TP - 113, Revision 13 CCP - QP - 005, Revision 18 The procedure is adequately implemented.

Corrective actions are taken when necessary. EPA determined by review of completed BDRs that the procedure wa s implemented as written. Objective evidence: 1. Visual Examination BDRs RLVEPF0022 and RLVEPF0023 2. List of currently qualified VE personnel, April 14, 2010 3. CCP - TP - 113, CCP Standard Contact - Handled Waste Visual Examination, Revision 13, March 11, 2009 VE - 10: Site procedure(s) require data generation and project leve l reviews of Batch Data Reports (BDRs). CCP - TP - 113, Revision 13 CCP - TP - 001, Revision 17, Attachment 1 BDRs contain all required information.

Data generation and project level reviews are complete. EPA inspectors reviewed 2 VE BDRs to ensure that all required information was recorded and that the BDRs had been reviewed at both data generation and project level. EPA did not identify any problems with the BDRs. Objective evidence: 1. Visual Examination BDRs RLVEPF0022 and RLVEPF0023 2. List of currently qualified VE personnel, April 14, 2010 3. CCP - TP - 113, CCP Standard Contact - Handled Waste Visual Examination, Revision 13, March 11, 2009Revision No.: Site specific checklist A - 40 

### ATTACHMENT A.5 WIPP WASTE DATA SYSTEM (WDS) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH WDS C hecklist Inspection Date: April 27 - 29, 20108 Establishment of Required Technical Elements in Procedures Location Execution of Procedures Objective Evidence/Comment WDS - 1: WDS and Data Entry Personnel must be trained to assess data and properly enter data into the Waste Data System (WDS) . CCP - QP - 002, Revision 27 CCP - TP - 030, Revision 27 WCO and Data Entry Personnel are trained

to assess data and properly enter and transfer all data in the WDS. Training for Data Entry Personnel and data reviewers/verifiers include the WIPP Waste Information System User’s Manual and the applicable site procedures. Training records are available for review and are complete. The EPA inspections reviewed the qualification card and training records for the WCO who provided the on - site demonstration. The training records were found to be complete except for training on the new WDS User’s Manual. Hanford - CCP - CH - WDS - 10 - 002CR CCP training procedure CCP - QP - 002, Revision 27, Section [C.3] requires Waste Certification Officials (WCOs) to demonstrate proficiency in WWIS as part of training. However, WDS is not specifically identified in the training procedure although this is the only User’s Manual listed in the reference section of CCP - TP - 030. The Hanford CCP Project Manager indicated that the procedure(s) associated with data entry are being revised at this time. Objective evidence: 1. CCP - TP - 030, Revision 27 2. WCO qualification card and training record WDS - 2: Security measures for ensuring data integrity and accessing WDS are sufficient . Y CCP - TP - 030, Revision 27, Section 4.1 Access to WDS is controlled. WDS access

requests are recorded in an access log, however named, that is available for review . The Data Administrator is required to grant access to WDS, the request from CCP and DA re sponse take s place as email communications. This type of communication is also used to rescind access as necessary. EPA reviewed a previous email from the DA eliminating a person’s access. Objective evidence: 1. CCP - TP - 030, Revision 27 2. WCO qualification card and training record 3. DA email rescinding database access WDS - 3: Y CCP - TP - 030, Revision 27, Sections 3.0, 4.0 Em

ployee’s explanation of job duties was consistent with applicable procedures. WCO and WCA adequately explained how data are assessed, input, and transferred into WDS. The EPA team interviewed an experienced (5 years) WCO during the on - site inspection. The WCO identified minor changes between WDS and WWIS, for example, the ability of the WCO to change data in WDS. From the WCO’s information about WDS and EPA observing a WDS demonstration, EPA determined that WDS was suitable for uploading and retrieving characterization and certification data. 1. CCP - TP - 030, Revision 27Revision No.: Site specific checklist A - 41 

### ATTACHMENT A.5 WIPP WASTE DATA SYSTEM (WDS) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH WDS C hecklist Inspection Date: April 27 - 29, 20108 Establishment of Required Technical Elements in Procedures Location Execution of Procedures Objective Evidence/Comment 2. Waste Container Data Report for container RL0063021 and RL0063034 3. CCP Correlation of Container Identification Numbers to Batch Data Reports, waste stream MPFPDD, lot #1 4. WDS data entry summary, characterization and certification, spreadsheet for container s RL0062930, RL0063034, RL0063014, RL0063021, RL0063040 WDS - 4: Procedure s require that only verified and validated data are entered into WDS. Y CCP - TP - 030, Revision 27, Section 4.3, Table 1 Data generation and project level reviews of

container data for WDS entry have been performed and review checklists are complete. Only co mp lete and validated BDR data are entered into WDS. The EPA inspectors traced a randomly chosen LANL container (LA00000064320 in SWB LASB00811) from em placement back to the original characterization BDRs, to verify upload of compliant data and the ability of WDS to retrieve certification data. 1. CCP - TP - 030, Revision 27 2. Waste Container Data Report for container RL0063021 and RL0063034 3. CCP Correlation of Container Identification Numbers to Batch Data Reports, waste stream MPFPDD, lot #1 4. WDS data entry summary , characterization and certification, spreadsheet for container RL0062930, RL0063034, RL0063014, RL0063021, RL0063040 WDS - 5: Y CCP - TP - 030, Revision 27, Section 4.4, Table 1 Table 1 used to identify and enter required

data by WCA . Second WCA reviews d ata, initials and dates . If data discrepancies cannot be resolved , the form is sent to WCO or SPM for resolution . The new WDS template Excel spreadsheet requires the same data entry and revie w as WWIS. WCOs review data before uploading data. 1. CCP - TP - 030, Revision 27 2. WDS data entry summary, characterization and certification, spreadsheet for container s RL0062930, RL0063034, RL0063014, RL0063021, RL0063040 3. CCP - QP - 022, Software Quality Assurance Plan, Attachment 3, Software Problem Reporting and Change Request for WDS Master Template, SCO # 1065, version 1 and 2 4. WCO qualification WDS - 6: Y CCP - TP - 030, Revision 27, Verify that there are no unresolved NCRs

for containers . Verified by email from the SPM . 1. CCP - TP - 030, Revision 27Revision No.: Site specific checklist A - 42 

### ATTACHMENT A.5 WIPP WASTE DATA SYSTEM (WDS) CHECKLIST EPA Inspection No.: EPA- Hanford - CCP - CH - 04.10 - 8 Hanford CCP CH WDS C hecklist Inspection Date: April 27 - 29, 20108 Establishment of Required Technical Elements in Procedures Location Execution of Procedures Objective Evidence/Comment Section 4.4.4 2. Waste Container Data Report for container s RL0063021 and RL0063034 3. CCP Correlation of Container Identification Numbers to Batch Data Reports, waste stream MPFPDD, lot #1 4. WDS data entry summary, characterization and certification, spreadsheet for container s RL0062930, RL0063 034, RL0063014, RL0063021, RL0063040 WDS - 7: Resolution of data deficiencies Y CCP - TP - 030, Revision 27, Section 4.5.5 WDS Administrator rejects data via email .

NCR The WDS processes are similar to those of WWIS, and still have the internal checks that can prevent upload of non compliant data. 1. CCP - TP - 030, Revision 27 2. Waste Container Data Report for container s RL0063021 and RL0063034 3. WDS data entry summary, characterization and certification, spreadsheet for container s RL0062930, RL0063034, RL0063014, RL 0063021, RL0063040 WDS - 8: Records retention Y CCP - TP - 030, Revision 27, Section 5.0 CCP - QP - 008, Revision 15 QA/Lifetime records:

WDS Master Template Correspondence, including container rejection emails QA/Nonpermanent: CDS Database (electronic) Only th e template could be verified during the on - site inspection because of the limited access to the database (due to lack of an approved WSPF). 1. CCP - TP - 030, Revision 27 2. CCP - QP - 022, Software Quality Assurance Plan, Attachment 3, Software Problem Reporting and Change Request for WDS Master Template, SCO # 1065, version 1 and 2B - 1 

### ATTACHMENT B.1 REPLICATE TESTING DA TA FOR CONTAINER RL0 063023, GEA- A Quantity of Interest Original Measurem ent Replicate No. 1 Replicate No. 2 Reported Value Absolute

Uncertain ty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 Pu Activity (Ci) 2.60E - 02 7.38E - 03 2.84E - 01 2.43E - 02 6.78E - 03 2.79E - 01 2.74E - 02 7.44E - 03 2.72E - 01 239 Pu Activity (Ci) 2.68E - 01 6.67E - 02 2.49E - 01 2.87E - 01 7.15E - 02 2.49E - 01 2.73E - 01 6.78E - 02 2.48E - 01 240 Pu Activity (Ci) 8.97E - 02 2.27E - 02 2.53E - 01 6.77E - 02 1.72E - 02 2.54E - 01 6.53E - 02 1.65E - 02 2.53E - 01 242 Pu Activity (Ci) 7.82E - 06 2.16E - 06 2.76E - 01 5.56E - 06 1.54E - 06 2.77E - 01 5.40E - 06 1.49E - 06 2.76E - 01 241 Am Activity (Ci) 3.23E - 02 8.50E - 03 2.63E - 01 5.43E - 02 1.44E - 02 2.65E - 01 4.18E - 02 1.08E - 02 2.58E - 01 90 Sr Activity (Ci) 1.09E - 07 2.96E - 08 2.72E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137 Cs Activity (Ci) 9.94E - 08 2.69E - 08 2.71E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 5.80E+03 9.93E+02 1.71E - 01 6.04E+03 1.05E+03 1.74E - 01 5.67E+03 9.90E+02 1.75E - 01 232U Activity (Ci) 3.58E - 08 2.05E - 08 5.73E - 01 0.00E+00 N/A 0.00E+00 0.00E +00 N/A 0.00E+00 237Np Activity (Ci) 4.71E - 07 1.25E - 07 2.65E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 Quantity of Interest Replicate No. 3 Replicate No. 4 Replicate No. 5 Reported Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 Pu Activity (Ci) 1.67E - 02 5.20E - 03 3.11E - 01 2.35E - 02 6.56E - 03 2.79E - 01 1.59E - 02 4.85E - 03 3.05E - 01 239 Pu Activity (Ci) 2.74E - 01 6.83E - 02 2.49E - 01 2.74E - 01 6.82E - 02 2.49E - 01 2.66E - 01 6.62E - 02 2.49E - 01 240 Pu Activity (Ci) 4.57E - 02 1.19E - 02 2.60E - 01 6.55E - 02 1.66E - 02 2.53E - 01 6.56E - 02 1.66E - 02 2.53E - 01 242 Pu Activity (Ci) 3.29E - 06 9.74E - 07 2.96E - 01 5.29E - 06 1.46E - 06 2.76E - 01 5.39E - 06 1.49E - 06 2.76E - 01 241 Am Activity (Ci) 5.08E - 02 1.34E - 02 2.64E - 01 4.61E - 02 1.21E - 02 2.62E - 01 5.08E - 02 1.34E - 02 2.64E - 01 90 Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137 Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0 0 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 5.40E+03 9.86E+02 1.83E - 01 5.70E+03 9.96E+02 1.75E - 01 5.55E+03 9.71E+02 1.75E - 01 232U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 237Np Activity (Ci) 0.00E+00 N/A 0.00 E+00 2.11E - 07 5.67E - 08 2.69E - 01 0.00E+00 N/A 0.00E+00B - 2 

### ATTACHMENT B.2 REPLICATE TESTING RE SULTS FOR CONTAINER RL0063023, GEA-A Quantity of Interest Original Measurem ent Sample Me an Sample

Standard Deviation Relative

Standard Deviation  2

 Pr( x <|  2 | ) Reported Value Absolute

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238 Pu Activity (Ci) 2.60E - 02 7.38E - 03 2.16E - 02 5.03E - 03 2.33E - 01 1.86E+00 7.62E - 01 239 Pu Activity (Ci) 2.68E - 01 6.67E - 02 2.75E - 01 7.60E - 03 2.76E - 02 5.19E - 02 1.00E+00 240 Pu Activity (Ci) 8.97E - 02 2.27E - 02 6.20E - 02 9.14E - 03 1.48E - 01 6.49E - 0 1 9.58E - 01 242 Pu Activity (Ci) 7.82E - 06 2.16E - 06 4.99E - 06 9.53E - 07 1.91E - 01 7.79E - 01 9.41E - 01 241 Am Activity (Ci) 3.23E - 02 8.50E - 03 4.88E - 02 4.86E - 03 9.97E - 02 1.31E+00 8.60E - 01 90 Sr Activity (Ci) 1.09E - 07 2.96E - 08 0.00E+00 0.00E+00 N/A 0.00E+00 1.00E+00 137 Cs Activity (Ci) 9.94E - 08 2.69E - 08 0.00E+00 0.00E+00 N/A 0.00E+00 1.00E+00 TRU Alpha Conc. (nCi/g) 5.80E+03 9.93E+02 5.67E+03 2.37E+02 4.18E - 02 2.28E - 01 9.94E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 232U Activity (Ci) 3.58E - 08 2.05E - 08 0.00E+00 0.00E+00 N/A 0.00E+00 1.00E+00 237Np Activity (Ci) 4.71E - 07 1.25E - 07 4.22E - 08 9.44E - 08 2.24E+00 2.28E+00 6.85E - 01 Quantity of Interest T Pr( x <| t |)

  2 Test t Test 233 U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A #VALUE! Not Applicable 238 U Activity (Ci) N/A N/A #VALUE! Not Applicable 238 Pu Activity (Ci) 8.06E - 01 4.65E - 01 Not Significant Not Significant 239 Pu Activity (Ci) - 8.17E - 01 4.60E - 01 Not Significant Not Significant 240 Pu Activity (Ci) 2.77E+00 5.03E - 02 Not Significant Not Significant 242 Pu Activity (Ci) 2.71E+00 5.33E - 02 Not Significant Not Significant 241 Am Activity (Ci) - 3.09E+00 3.65E - 02 Not Significant Significant 90 Sr Activity (Ci) N/A N/A Not Significant Not Applicable 137 Cs Activity (Ci) N/A N/A Not Significant Not Applicable TRU Alpha Conc. (nCi/g) 4.93E - 01 6.48E - 01 Not Significant Not Significant N/A N/A #VALUE! Not Applicable 232U Activity (Ci) N/A N/A Not Significant Not Applicable 237Np Activity (Ci) 4.15E+00 1.43E - 02 Not Significant SignificantB - 3 

### ATTACHMENT B.3 REPLICATE TESTING DA TA FOR CONTAINER RL0 050614, GEA- A Quantity of Interest Original Measurem ent Replicate No. 1 Replicate No. 2 Reported Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 1.01E - 05 2.69E - 06 2.66E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 U Activity (Ci) 5.05E - 06 1.34E - 06 2.65E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 Pu Activity (Ci) 4.81E - 02 1.94E - 02 4.03E - 01 1.20E - 01 2.68E - 02 2.23E - 01 1.30E - 01 2.80E - 02 2.15E - 01 239 Pu Activity (Ci) 1.60E+00 3.09E - 01 1.93E - 01 1.74E+00 3.36E - 01 1.93E - 01 1.66E+00 3.22E - 01 1.94E - 01 240 Pu Activity (Ci) 4.05E - 01 8.16E - 02 2.01E - 01 4.43E - 01 8.68E - 02 1.96E - 01 4.14E - 01 8.11E - 0 2 1.96E - 01 242 Pu Activity (Ci) 4.44E - 05 1.01E - 05 2.27E - 01 4.33E - 05 9.64E - 06 2.23E - 01 3.96E - 05 8.82E - 06 2.23E - 01 241 Am Activity (Ci) 3.82E - 01 7.47E - 02 1.96E - 01 6.58E - 01 1.28E - 01 1.95E - 01 5.97E - 01 1.16E - 01 1.94E - 01 90 Sr Activity (Ci) 6.86E - 07 1.41E - 07 2.0 6E - 01 1.81E - 06 3.56E - 07 1.97E - 01 1.06E - 06 2.09E - 07 1.97E - 01 137 Cs Activity (Ci) 6.23E - 07 1.29E - 07 2.07E - 01 1.65E - 06 3.24E - 07 1.96E - 01 9.65E - 07 1.90E - 07 1.97E - 01 TRU Alpha Conc. (nCi/g) 5.29E+04 7.15E+03 1.35E - 01 6.43E+04 8.07E+03 1.26E - 01 6.09E+04 7.68E+ 03 1.26E - 01 237Np Activity (Ci) 5.13E - 06 1.01E - 06 1.97E - 01 4.67E - 06 9.13E - 07 1.96E - 01 5.24E - 06 1.03E - 06 1.97E - 01 243 Am Activity (Ci) 4.50E - 05 1.27E - 05 2.82E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 Quantity of Interest Replicate No. 3 Replicate No. 4 Replicate No. 5 Reported Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 Pu Activity (Ci) 7.78E - 02 1.91E - 02 2.46E - 01 1.34E - 01 2.88E - 02 2.15E - 01 1.15E - 01 2.52E - 02 2.19E - 01 239 Pu Activity (Ci) 1.68E+00 3.25E - 01 1.93E - 01 1.68E+00 3.25E - 01 1.93E - 01 1.68E+00 3.26E - 01 1.94E - 01 240 Pu Activity (Ci) 4.52E - 01 8.83E - 02 1.95E - 01 3.88E - 01 7.61E - 02 1.96E - 01 4.56E - 01 8.92E - 02 1.96E - 0 1 242 Pu Activity (Ci) 4.25E - 05 9.47E - 06 2.23E - 01 3.63E - 05 8.09E - 06 2.23E - 01 4.35E - 05 9.68E - 06 2.23E - 01 241 Am Activity (Ci) 6.06E - 01 1.18E - 01 1.95E - 01 5.56E - 01 1.08E - 01 1.94E - 01 6.21E - 01 1.21E - 01 1.95E - 01 90 Sr Activity (Ci) 8.35E - 07 1.65E - 07 1.98E - 01 7.0 6E - 07 1.40E - 07 1.98E - 01 1.89E - 07 3.87E - 08 2.05E - 01 137 Cs Activity (Ci) 7.59E - 07 1.50E - 07 1.98E - 01 6.42E - 07 1.27E - 07 1.98E - 01 1.72E - 07 3.52E - 08 2.05E - 01 TRU Alpha Conc. (nCi/g) 6.12E+04 7.77E+03 1.27E - 01 5.99E+04 7.65E+03 1.28E - 01 6.25E+04 7.82E+03 1.25E - 01 237Np Activity (Ci) 5.39E - 06 1.06E - 06 1.97E - 01 4.70E - 06 9.55E - 07 2.03E - 01 5.53E - 06 1.08E - 06 1.95E - 01 243 Am Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00B - 4 

### A TTACHMENT B.4 REPLICATE TESTING RE SULTS FOR, CONTAINER RL005061 4, GEA-A Quantity of Interest Original Measurem ent Sample Me an Sample

Standard Deviation Relative

Standard Deviation  2

 Pr( x <|  2 | ) Reported Value Absolute

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 234U Activity (Ci) 1.01E - 05 2.69E - 06 0.00E+00 0.00E+00 N/A 0.00E+00 1.00E+00 238 U Activity (Ci) 5.05E - 06 1.34E - 06 0.00E+00 0. 00E+00 N/A 0.00E+00 1.00E+00 238 Pu Activity (Ci) 4.81E - 02 1.94E - 02 1.15E - 01 2.23E - 02 1.94E - 01 5.30E+00 2.58E - 01 239 Pu Activity (Ci) 1.60E+00 3.09E - 01 1.69E+00 3.03E - 02 1.80E - 02 3.85E - 02 1.00E+00 240 Pu Activity (Ci) 4.05E - 01 8.16E - 02 4.31E - 01 2.89E - 02 6. 72E - 02 5.03E - 01 9.73E - 01 242 Pu Activity (Ci) 4.44E - 05 1.01E - 05 4.10E - 05 3.08E - 06 7.49E - 02 3.71E - 01 9.85E - 01 241 Am Activity (Ci) 3.82E - 01 7.47E - 02 6.08E - 01 3.71E - 02 6.10E - 02 9.85E - 01 9.12E - 01 90 Sr Activity (Ci) 6.86E - 07 1.41E - 07 9.20E - 07 5.91E - 07 6.43E - 0 1 7.04E+01 1.89E - 14 137 Cs Activity (Ci) 6.23E - 07 1.29E - 07 8.38E - 07 5.39E - 07 6.44E - 01 6.99E+01 2.35E - 14 TRU Alpha Conc. (nCi/g) 5.29E+04 7.15E+03 6.18E+04 1.70E+03 2.75E - 02 2.25E - 01 9.94E - 01 237Np Activity (Ci) 5.13E - 06 1.01E - 06 5.11E - 06 3.98E - 0 7 7.79E - 02 6.21E - 01 9.61E - 01 243 Am Activity (Ci) 4.50E - 05 1.27E - 05 0.00E+00 0.00E+00 N/A 0.00E+00 1.00E+00 Quantity of Interest T Pr( x <| t |)

  2 Test t Test 233 U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A Not Significant Not Applicable 238 U Activity (Ci) N/A N/A Not Significant Not Applicable 238 Pu Activity (Ci) - 2.75E+00 5.14E - 02 Not Significant Not Significant 239 Pu Activity (Ci) - 2.65E+00 5.71E - 02 Not Significant Not Significant 240 Pu Activity (Ci) - 8.08E - 01 4.64E - 01 Not Significant Not Significant 242 Pu Activity (Ci) 9.97E - 01 3.75E - 01 Not Significant Not Significant 241 Am Activity (Ci) - 5.5 6E+00 5.14E - 03 Not Significant Highly Significant 90 Sr Activity (Ci) - 3.61E - 01 7.36E - 01 Highly Significant Not Significant 137 Cs Activity (Ci) - 3.63E - 01 7.35E - 01 Highly Significant Not Significant TRU Alpha Conc. (nCi/g) - 4.77E+00 8.86E - 03 Not Significant Highly Significant 237Np Activity (Ci) 5.51E - 02 9.59E - 01 Not Significant Not Significant 243 Am Activity (Ci) N/A N/A Not Significant Not ApplicableB - 5 

### ATTACHMENT B.5 REPLICATE TESTING DA TA FOR CONTAINER RL0 063005, GEA- A Quantity of Interest Original Measurem ent Replicate No. 1 Replicate No. 2 Reported Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 Pu Activity

(Ci) 3.53E - 02 7.64E - 03 2.16E - 01 3.51E - 02 7.62E - 03 2.17E - 01 3.22E - 02 7.09E - 03 2.20E - 01 239 Pu Activity (Ci) 1.38E - 01 2.63E - 02 1.91E - 01 1.37E - 01 2.62E - 02 1.91E - 01 1.37E - 01 2.62E - 02 1.91E - 01 240 Pu Activity (Ci) 6.82E - 02 1.36E - 02 1.99E - 01 6.33E - 02 1.27E - 0 2 2.01E - 01 5.75E - 02 1.15E - 02 2.00E - 01 242 Pu Activity (Ci) 1.61E - 05 3.56E - 06 2.21E - 01 1.55E - 05 3.42E - 06 2.21E - 01 1.36E - 05 3.00E - 06 2.21E - 01 241 Am Activity (Ci) 1.03E - 01 2.05E - 02 1.99E - 01 1.34E - 01 2.61E - 02 1.95E - 01 1.19E - 01 2.31E - 02 1.94E - 01 90 Sr Activity (Ci) 1.10E - 07 3.19E - 08 2.90E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137 Cs Activity (Ci) 1.00E - 07 2.90E - 08 2.90E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 9.09E+03 9.70E+02 1.07E - 01 9.76E+03 1.05E+03 1.08E - 01 9.12E+03 9.88E+02 1.08E - 01 152 Eu Activity (Ci) 1.27E - 07 3.92E - 08 3.09E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 237Np Activity (Ci) 1.08E - 06 2.11E - 07 1.95E - 01 5.96E - 07 1.23E - 07 2.06E - 01 7.35E - 07 1.44E - 07 1.96E - 01 232U Activity (Ci) 5.56E - 08 1.9 5E - 08 3.51E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 Quantity of Interest Replicate No. 3 Replicate No. 4 Replicate No. 5 Reported Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 U Activity (Ci) 0.00E+00 N/A 0.0 0E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 Pu Activity (Ci) 3.53E - 02 7.52E - 03 2.13E - 01 3.88E - 02 8.31E - 03 2.14E - 01 3.61E - 02 7.61E - 03 2.11E - 01 239 Pu Activity (Ci) 1.37E - 01 2.62E - 02 1.91E - 01 1.34E - 01 2.55E - 02 1.90E - 01 1.33E - 01 2.54E - 02 1.91E - 01 2 40 Pu Activity (Ci) 5.46E - 02 1.09E - 02 2.00E - 01 6.70E - 02 1.34E - 02 2.00E - 01 5.24E - 02 1.05E - 02 2.00E - 01 242 Pu Activity (Ci) 1.41E - 05 3.11E - 06 2.21E - 01 1.72E - 05 3.87E - 06 2.25E - 01 1.40E - 05 3.08E - 06 2.20E - 01 241 Am Activity (Ci) 1.19E - 01 2.30E - 02 1.93E - 01 1.40E - 01 2.72E - 02 1.94E - 01 1.14E - 01 2.20E - 02 1.93E - 01 90 Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137 Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 9.13E+03 9 .84E+02 1.08E - 01 1.00E+04 1.07E+03 1.07E - 01 8.85E+03 9.51E+02 1.07E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 152 Eu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 237Np Activity (Ci) 6.16E - 07 1.29E - 07 2.09E - 01 7.58E - 07 1.48E - 07 1.95E - 01 7.51E - 07 1.54E - 07 2.05E - 01 232U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00B - 6 

### ATTACHMENT B.6 REPLICATE TESTING RES ULTS FOR CONTAINER RL0063005, GEA-A Quantity of Intere st Original Measurem ent Sample Me an Sample

Standard Deviation Relative

Standard Deviation  2

 Pr( x <|  2 | ) Reported Value Absolute

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 234U Activity (Ci) 0.00E+00 N/A 0.00 E+00 0.00E+00 N/A #VALUE! #VALUE! 238 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238 Pu Activity (Ci) 3.53E - 02 7.64E - 03 3.55E - 02 2.36E - 03 6.66E - 02 3.83E - 01 9.84E - 01 239 Pu Activity (Ci) 1.38E - 01 2.63E - 02 1.36E - 01 1.95E - 03 1.44E - 02 2 .20E - 02 1.00E+00 240 Pu Activity (Ci) 6.82E - 02 1.36E - 02 5.90E - 02 6.08E - 03 1.03E - 01 7.98E - 01 9.39E - 01 242 Pu Activity (Ci) 1.61E - 05 3.56E - 06 1.49E - 05 1.48E - 06 9.96E - 02 6.93E - 01 9.52E - 01 241 Am Activity (Ci) 1.03E - 01 2.05E - 02 1.25E - 01 1.12E - 02 8.92E - 02 1.19E +00 8.80E - 01 90 Sr Activity (Ci) 1.10E - 07 3.19E - 08 0.00E+00 0.00E+00 N/A 0.00E+00 1.00E+00 137 Cs Activity (Ci) 1.00E - 07 2.90E - 08 0.00E+00 0.00E+00 N/A 0.00E+00 1.00E+00 TRU Alpha Conc. (nCi/g) 9.09E+03 9.70E+02 9.37E+03 4.85E+02 5.17E - 02 9.98E - 01 9.10E - 0 1 152 Eu Activity (Ci) 1.27E - 07 3.92E - 08 0.00E+00 0.00E+00 N/A 0.00E+00 1.00E+00 237Np Activity (Ci) 1.08E - 06 2.11E - 07 6.91E - 07 7.85E - 08 1.14E - 01 5.54E - 01 9.68E - 01 232U Activity (Ci) 5.56E - 08 1.95E - 08 0.00E+00 0.00E+00 N/A 0.00E+00 1.00E+00 Quantity of Interest t Pr( x <| t |)

  2 Test t Test 233 U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A #VALUE! Not Applicable 238 U Activity (Ci) N/A N/A #VALUE! Not Applicable 238 Pu Activity (Ci) - 7.73E - 02 9.42E - 01 Not Significant Not Significant 239 Pu Activity (Ci) 1.12E+00 3.24E - 01 Not Significant Not Significant 240 Pu Activity (Ci) 1.39E+00 2.37E - 01 Not Significant Not Significant 242 Pu Activity (Ci) 7.51E - 01 4.94E - 01 Not Significant Not Significant 2 41 Am Activity (Ci) - 1.81E+00 1.44E - 01 Not Significant Not Significant 90 Sr Activity (Ci) N/A N/A Not Significant Not Applicable 137 Cs Activity (Ci) N/A N/A Not Significant Not Applicable TRU Alpha Conc. (nCi/g) - 5.31E - 01 6.23E - 01 Not Significant N ot Significant 152 Eu Activity (Ci) N/A N/A Not Significant Not Applicable 237Np Activity (Ci) 4.52E+00 1.07E - 02 Not Significant Significant 232U Activity (Ci) N/A N/A Not Significant Not ApplicableB - 7 

### ATTACHMENT B.7 REPL ICATE TESTING DATA FOR CONTAINER RL0063034, GEA- B Quantity of Interest Original Measurem ent Replicate No. 1 Replicate No. 2 Reported Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0 .00E+00 0.00E+00 N/A 0.00E+00 238 Pu Activity (Ci) 1.34E - 02 4.88E - 03 3.64E - 01 1.54E - 02 5.46E - 03 3.55E - 01 3.53E - 03 3.35E - 03 9.49E - 01 239 Pu Activity (Ci) 1.94E - 01 5.48E - 02 2.82E - 01 2.00E - 01 5.66E - 02 2.83E - 01 1.95E - 01 5.51E - 02 2.83E - 01 240 Pu Activity (Ci) 5 .09E - 02 1.48E - 02 2.91E - 01 4.07E - 02 1.20E - 02 2.95E - 01 4.64E - 02 1.37E - 02 2.95E - 01 242 Pu Activity (Ci) 4.05E - 06 1.28E - 06 3.16E - 01 3.12E - 06 1.00E - 06 3.21E - 01 3.55E - 06 1.14E - 06 3.21E - 01 241 Am Activity (Ci) 3.43E - 02 9.85E - 03 2.87E - 01 3.25E - 02 9.35E - 03 2.88E - 01 3.05E - 02 8.80E - 03 2.89E - 01 90 Sr Activity (Ci) 3.38E - 08 1.31E - 08 3.88E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137 Cs Activity (Ci) 3.08E - 08 1.20E - 08 3.90E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 4.86E+03 9.62E+02 1. 98E - 01 4.80E+03 9.79E+02 2.04E - 01 4.57E+03 9.57E+02 2.09E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 237Np Activity (Ci) 8.91E - 08 3.57E - 08 4.01E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 Quantity of Interest Replicate No. 3 Replicate No. 4 Replicate No. 5 Reported Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertain ty Relative

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E +00 0.00E+00 N/A 0.00E+00 238 Pu Activity (Ci) 1.50E - 02 5.51E - 03 3.67E - 01 1.06E - 02 4.34E - 03 4.09E - 01 1.23E - 02 4.58E - 03 3.72E - 01 239 Pu Activity (Ci) 1.98E - 01 5.61E - 02 2.83E - 01 1.88E - 01 5.32E - 02 2.83E - 01 1.88E - 01 5.32E - 02 2.83E - 01 240 Pu Activity (Ci) 4.78E - 02 1.41E - 02 2.95E - 01 4.49E - 02 1.32E - 02 2.94E - 01 4.01E - 02 1.18E - 02 2.94E - 01 242 Pu Activity (Ci) 3.79E - 06 1.22E - 06 3.22E - 01 3.61E - 06 1.16E - 06 3.21E - 01 3.21E - 06 1.03E - 06 3.21E - 01 241 Am Activity (Ci) 3.40E - 02 9.80E - 03 2.88E - 01 3.45E - 02 9.93E - 03 2.88E - 01 3.2 1E - 02 9.23E - 03 2.88E - 01 90 Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137 Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 4.91E+03 9.80E+02 2.00E - 01 4.62E+0 3 9.30E+02 2.01E - 01 4.53E+03 9.22E+02 2.04E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 237Np Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+ 00 N/A 0.00E+00B - 8 

### ATTACHMENT B.8 REPLICATE TESTING RE SULTS FOR CONTAINER RL0063034, GEA- B Quantity of Interest Original Measurem ent Sample Me an Sample

Standard Deviation Relative

Standard Deviation  2

 Pr( x <|  2 | ) Reported Value Absolute

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238 Pu Activity (Ci) 1.34E - 02 4.88E - 03 1.14E - 02 4.80E - 03 4.23E - 01 3.88E+00 4.23E - 01 239 Pu Activity (Ci) 1.94E - 01 5.48E - 02 1.94E - 01 5.59E - 03 2.88E - 02 4.16E - 02 1.00E+00 240 Pu Activity (Ci) 5.09E - 02 1.48E - 02 4.40E - 02 3.43E - 03 7.80E - 02 2.15E - 0 1 9.95E - 01 242 Pu Activity (Ci) 4.05E - 06 1.28E - 06 3.46E - 06 2.82E - 07 8.15E - 02 1.94E - 01 9.96E - 01 241 Am Activity (Ci) 3.43E - 02 9.85E - 03 3.27E - 02 1.59E - 03 4.87E - 02 1.05E - 01 9.99E - 01 90 Sr Activity (Ci) 3.38E - 08 1.31E - 08 0.00E+00 0.00E+00 N/A 0.00E+00 1.00E+00 137 Cs Activity (Ci) 3.08E - 08 1.20E - 08 0.00E+00 0.00E+00 N/A 0.00E+00 1.00E+00 TRU Alpha Conc. (nCi/g) 4.86E+03 9.62E+02 4.69E+03 1.62E+02 3.46E - 02 1.14E - 01 9.98E - 01 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 237Np Activity (Ci) 8.91E - 08 3.57E - 08 0.00E+00 0.00E+00 N/A 0.00E+00 1.00E+00 Quantity of Interest t Pr( x <| t |)

  2 Test t Test 233 U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A #VALUE! Not Applicable 238 U Activity (Ci) N/A N/A #VALUE! Not Applicable 238 Pu Activity (Ci) 3.86E - 01 7.19E - 01 Not Significant Not Significant 239 Pu Activity (Ci) 3.27E - 02 9.75E - 01 Not Significant Not Significant 240 Pu Activity (Ci) 1.84E+00 1.39E - 01 Not Significant Not Significant 242 Pu Activity (Ci) 1.92E+00 1.27E - 01 Not Significant Not Significant 241 Am Activity (Ci) 9.05E - 01 4.17E - 01 Not S ignificant Not Significant 90 Sr Activity (Ci) N/A N/A Not Significant Not Applicable 137 Cs Activity (Ci) N/A N/A Not Significant Not Applicable TRU Alpha Conc. (nCi/g) 9.79E - 01 3.83E - 01 Not Significant Not Significant N/A N/A #VALUE! Not Appl icable N/A N/A #VALUE! Not Applicable 237Np Activity (Ci) N/A N/A Not Significant Not ApplicableB - 9 

### ATTACHMENT B.9 REPLICATE TESTING DA TA FOR CONTAINER RL0 056338, GEA- B Quantity of Interest Original Measurem ent Replicate No. 1 Replicate No. 2 Reported Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.0 0E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 Pu Activity (Ci) 9.75E - 03 3.25E - 03 3.33E - 01 7.46E - 03 3.45E - 03 4.62E - 01 5.4 5E - 03 2.77E - 03 5.08E - 01 239 Pu Activity (Ci) 1.13E - 01 2.30E - 02 2.04E - 01 1.15E - 01 2.33E - 02 2.03E - 01 1.11E - 01 2.27E - 02 2.05E - 01 240 Pu Activity (Ci) 3.04E - 02 6.80E - 03 2.24E - 01 2.89E - 02 7.31E - 03 2.53E - 01 2.75E - 02 6.24E - 03 2.27E - 01 242 Pu Activity (Ci) 2.72E - 0 6 6.88E - 07 2.53E - 01 2.74E - 06 8.23E - 07 3.00E - 01 2.60E - 06 6.76E - 07 2.60E - 01 241 Am Activity (Ci) 4.56E - 04 1.27E - 04 2.79E - 01 4.52E - 04 1.26E - 04 2.79E - 01 4.56E - 04 1.27E - 04 2.79E - 01 90 Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.0 0E+00 137 Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 3.33E+03 5.24E+02 1.57E - 01 3.28E+03 5.35E+02 1.63E - 01 3.13E+03 5.13E+02 1.64E - 01 Quantity of Interest Replicate No. 3 Replicate No. 4 Replicate No. 5 Reported Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00 E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 Pu Activity (Ci) 4.69E - 03 2.48E - 03 5.29E - 01 4.12E - 03 2.67E - 03 6.48E - 01 2.44E - 03 2.34E - 03 9.59E - 01 239 Pu Activity (Ci) 1.14E - 01 2.32E - 02 2.04E - 01 1.11E - 01 2.37E - 02 2.14E - 01 1.12E - 01 2.27E - 02 2.03E - 01 240 Pu Activity (Ci) 2.99E - 02 6.65E - 03 2.22E - 01 3.67E - 02 8.44E - 03 2.30E - 01 2.70E - 02 6.12E - 03 2.27E - 01 242 Pu Activity (Ci) 2.63E - 06 6.65E - 07 2.53E - 01 3.24E - 06 8.47E - 07 2.61E - 01 2.45E - 06 6.33E - 07 2.58E - 01 241 Am Activity (Ci) 4.51E - 04 1.26E - 04 2.79E - 01 4.49E - 04 1.25E - 04 2.78E - 01 4.64E - 04 1.30E - 04 2.80E - 01 90 Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00 E+00 N/A 0.00E+00 137 Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 3.23E+03 5.26E+02 1.63E - 01 3.29E+03 5.48E+02 1.67E - 01 3.06E+03 5.12E+02 1.67E - 01B - 10 

### ATTACHMENT B.10 REPLICATE TESTING RE SULTS FOR CONTAINER RL 0056338, GEA- B Quantity of Interest Original Measurem ent Sample Me an Sample

Standard Deviation Relative

Standard Deviation  2

 Pr( x <|  2 | ) Reported Value Absolute

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238 Pu Activity (Ci) 9.75E - 03 3.25E - 03 4.83E - 03 1.84E - 03 3.81E - 01 1.28E+00 8.64E - 01 239 Pu Activity (Ci) 1.13E - 01 2.30E - 02 1.13E - 01 1.82E - 03 1.61E - 02 2.50E - 02 1.00E+00 240 Pu Activity (Ci) 3.04E - 02 6.80E - 03 3.00E - 02 3.92E - 03 1.31E - 01 1.33E+0 0 8.57E - 01 242 Pu Activity (Ci) 2.72E - 06 6.88E - 07 2.73E - 06 3.02E - 07 1.11E - 01 7.72E - 01 9.42E - 01 241 Am Activity (Ci) 4.56E - 04 1.27E - 04 4.54E - 04 6.16E - 06 1.36E - 02 9.40E - 03 1.00E+00 90 Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 137 Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! TRU Alpha Conc. (nCi/g) 3.33E+03 5.24E+02 3.20E+03 9.98E+01 3.12E - 02 1.45E - 01 9.97E - 01 Quantity of Interest t Pr( x <| t |)

  2 Test t Test 233 U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A #VALUE! Not Applicable 238 U Activity (Ci) N/A N/A #VALUE! Not Applicable 238 Pu Activity (Ci) 2.44E+00 7.12E - 02 Not Significant Not Significant 239 Pu Activity (Ci) 2.01E - 01 8.51E - 01 Not Significant Not Signi ficant 240 Pu Activity (Ci) 9.32E - 02 9.30E - 01 Not Significant Not Significant 242 Pu Activity (Ci) - 3.62E - 02 9.73E - 01 Not Significant Not Significant 241 Am Activity (Ci) 2.52E - 01 8.13E - 01 Not Significant Not Significant 90 Sr Activity (Ci) N/A N/A #VALUE! Not Applicable 137 Cs Activity (Ci) N/A N/A #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) 1.21E+00 2.94E - 01 Not Significant Not SignificantB - 11 

### ATTACHMENT B.11 REPLICATE TESTING DA TA FOR CONTAINER RL0 62952, GEA- B Quantity of Interest O riginal Measurem ent Replicate No. 1 Replicate No. 2 Reported Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 Pu Activity (Ci) 3.77E - 03 1.01E - 03 2.68E - 01 2.26E - 03 3.03E - 03 1.34E+00 1.57E - 02 6.88E - 03 4.38E - 01 239 Pu Activity (Ci) 4.85E - 02 1.11E - 02 2.29E - 01 3.91E - 02 7.15E - 03 1.83E - 01 4.23E - 02 7.70E - 03 1.82E - 01 240 Pu Activity (Ci) 1.14E - 02 3.07E - 03 2.69E - 01 1.84E - 02 4.98E - 03 2.71E - 01 1.63E - 02 6.54E - 03 4.01E - 01 242 Pu Activity (Ci) 6.57E - 07 1.76E - 07 2.68E - 01 2.19E - 06 8.11E - 07 3.70E - 01 5.70E - 06 1.92E - 06 3.37E - 01 241 Am Activity (Ci) 6.98E - 04 2.03E - 04 2.91E - 01 7.01E - 04 2.05E - 04 2.92E - 01 6.93E - 04 2.02E - 04 2.91E - 01 90 Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 137 Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 2.15E+03 3.85E+02 1.79E - 01 2.02E+03 3.09E+02 1.53E - 01 2.51E+03 4.09E+02 1.63E - 01 Quantity of Interest Replicate No. 3 Replicate No. 4 Replicate No. 5 Reported Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty Reported

Value Absolute

Uncertainty Relative

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 238 Pu Activity ( Ci) 8.11E - 03 4.43E - 03 5.46E - 01 3.12E - 03 3.21E - 03 1.03E+00 1.33E - 02 7.34E - 03 5.52E - 01 239 Pu Activity (Ci) 4.50E - 02 8.25E - 03 1.83E - 01 4.07E - 02 7.31E - 03 1.80E - 01 4.07E - 02 7.45E - 03 1.83E - 01 240 Pu Activity (Ci) 2.38E - 02 6.85E - 03 2.88E - 01 1.92E - 02 5.20E - 03 2.7 1E - 01 1.56E - 02 6.84E - 03 4.38E - 01 242 Pu Activity (Ci) 4.25E - 06 1.39E - 06 3.27E - 01 2.67E - 06 9.38E - 07 3.51E - 01 5.21E - 06 1.93E - 06 3.70E - 01 241 Am Activity (Ci) 7.09E - 04 2.08E - 04 2.93E - 01 6.96E - 04 2.02E - 04 2.90E - 01 7.19E - 04 2.11E - 04 2.93E - 01 90 Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A 137 Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A TRU Alpha Conc. (nCi/g) 2.59E+03 3.88E+02 1.50E - 01 2.13E+03 3.19E+02 1.50E - 01 2.35E+03 4.18E+02 1.78E - 01B - 12 

### ATTACHMENT B.12 REPLICATE TESTING RE SULTS FOR CONTAINER RL062952, GEA- B Quantity of Interest Original Measurem ent Sample Me an Sample

Standard Deviation Relative

Standard Deviation  2

 Pr( x <|  2 | ) Reported Value Absolute

Uncertainty 233 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238 U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238 Pu Activity (Ci) 3.77E - 03 1.01E - 03 8.50E - 03 5.98E - 03 7.03E - 01 1.40E+02 2.69E - 29 239 Pu Activity (Ci) 4.85E - 02 1.11E - 02 4.16E - 02 2.23E - 03 5.37E - 02 1.62E - 01 9.97E - 01 240 Pu Activity (Ci) 1.14E - 02 3.07E - 03 1.87E - 02 3.23E - 03 1.73E - 01 4.43E+0 0 3.51E - 01 242 Pu Activity (Ci) 6.57E - 07 1.76E - 07 4.00E - 06 1.54E - 06 3.84E - 01 3.05E+02 7.24E - 65 241 Am Activity (Ci) 6.98E - 04 2.03E - 04 7.04E - 04 1.05E - 05 1.50E - 02 1.08E - 02 1.00E+00 90 Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 137 Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! TRU Alpha Conc. (nCi/g) 2.15E+03 3.85E+02 2.32E+03 2.43E+02 1.05E - 01 1.59E+00 8.10E - 01 Quantity of Interest t Pr( x <| t |)

  2 Test t Test 233 U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A #VALUE! Not Applicable 238 U Activity (Ci) N/A N/A #VALUE! Not Applicable 238 Pu Activity (Ci) - 7.22E - 01 5.10E - 01 Highly Significant Not Significant 239 Pu Activity (Ci) 2.84E+00 4.69E - 02 Not Significant Signi ficant 240 Pu Activity (Ci) - 2.05E+00 1.09E - 01 Not Significant Not Significant 242 Pu Activity (Ci) - 1.99E+00 1.18E - 01 Highly Significant Not Significant 241 Am Activity (Ci) - 4.86E - 01 6.53E - 01 Not Significant Not Significant 90 Sr Activity (Ci) N/A N/A #VALUE! Not Applicable 137 Cs Activity (Ci) N/A N/A #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) - 6.39E - 01 5.58E - 01 Not Significant Not SignificantC - 1 

### ATTACHMENT C.1 EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. HANFORD - CCP - CH - RTR- 10 - 0 01CR, FINAL Inspection No. EPA - Hanford - CCP - CH - 04.10 - 8 Issue Number: Hanford - CCP - CH - RTR- 10 - 001CR Date: April 27, 2010 Inspector: Dorothy E. Gill Attachments? YES NO Sample Size: 1 Population size (if known): Unknown Description of Issue: The RTR operator used a “Measurement Conversion Chart” to calculate the volume of liquid identified during RTR examinations and made process decisions based on the result. This chart is not a controlled document and the calculation used is incorrect. EPA is concerned regarding the origin and prevalence of this practice. B. Regulatory Reference: 40 CFR 194.24(c) C. Site requirement(s): Not applicable D. Discussed with: Dale Simpson, Jeremy Vesely E. Additional Comments: None F. Site Response Information: Site Response Required? YES NO Site Response Due Date: May 13, 2010C - 2 

### ATTACHMENT C.2 EPA INSPECTION ISSUE TRACKING FORM , ISSUE NO. HANFORD - CCP - CH -WDS - 10 - 002CR, FINAL Inspection No. EPA - Hanford - CCP - CH - 04.10 - 8 Issue Number: Hanford - CCP - CH - WDS - 10 - 002CR Date: April 28, 2010 Inspector: Dorothy E. Gill Attachments? YES NO Sample Size: 1 Population size (if known): 1 Description of Issue: CCP training procedure CCP - QP - 002, Revision 27, Section [C.3] requires Waste Certification Officials (WCOs) to demonstrate proficiency in WWI S as part of training. However, WDS is not specificall y identified in the training procedure although this is the only User’s Manual listed in the reference section of CCP - TP - 030. The Hanford CCP Project Manager indicated that the procedure(s) associated with data entry are being revised at this time. B. Regulatory Reference: 40 CFR 194 .24(c) C. Site requirement(s): Not applicable D. Discussed with: Mike Ramirez, Larry Porter E. Additional Comments: None F. Site Response Information: Site Response Required? YES NO Site Response Due Date: May 14, 2010C - 3 

### ATTACHMENT C.3 EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. HANFORD - CCP - CH -NDA - 10 - 003CR, FINAL Inspection No. EPA - HANFORD - CCP - CH 04.10 - 8 Issue Number: HANFORD - CCP -NDA - 10 - 003CR Date: April 28 , 2010 Inspector: P. Kel ly Attachments? YES NO Sample Size: Three GEA - A BDRs Population size (if known): Three GEA - A BDRs Description of Issue: All of the Batch Data Reports (BDRs) for GEA - A contained control limits for the transmission 23 9 

### Pu mass daily standard that were incorrect. The control limits had been recalculated on March 10, 2010 but the control limits stated in the BDRs were different from what was documented in the calibration verification report. There is no concern regardin g the technical adequacy of the performance check data, this concern is focused on the records that document the performance checks. Additionally , the GEA - A log book did not contain any entry regarding the incorporation of the new limits. B. Regulat ory Reference: 40 CFR 194.24(c) C. Site requirement(s): D. Discussed with: J. Harvill, E. Gulbransen, Bret Templeton E. Additional Comments: F. Site Response Information: Site Response Required? YES NO Site Response Due Date: May 13, 2010C - 4 

### ATTACHMENT C.4 EPA INSPECTION ISSUE TRACKING FORM , ISSUE NO. HANFORD - CCP - CH -AK- 10 - 004CR, FINAL Inspection No. EPA - Hanford - CCP - CH - 04.10 - 8 Issue Number: Hanford - CCP - CH - AK- 10 - 004CR Date: April 29, 2010 Inspector: C. Walker Attachments? YES NO Sample Size: Waste Stream MPFPDD Population size (if known): Entire Stream Description of Issue: The AK Summary requires revision to address technical issues and e lements identified during the inspection. These modifications are required to ensure adequate representation of the waste stream and its radiological and physical characteristics. The following must be addressed:  Examine feed and other data for 232 - Z Inc inerator to verify its inclusion in the waste stream.  Examine the use of “offsite sources” throughout the document.  In Section 4.6.1, modify the discussion pertaining to waste stream definition to include the lack of ability to correlate drums to specific PFP processes. Also modify Section 5.3 to indicate whether to -be - generated waste will be segregated upon generation or packaging.  Clarify

intent of last paragraph p.30 regarding plutonium grades and defense waste.  Add information to Section 5.4.2 pertaining to the 6%, 12%, and 23% 240 

### Pu isotopic distributions as presented in AK Source Documents and the AK-NDA memo, including data that support generation of these distributions at PFP as well as other pertinent historical data.  Remove first sentence from th e first paragraph in Section 4.5 regarding intent to segregate waste during packaging or repackaging, as it contradicts later statements.  Verify

number of HEHF (Emergency Decontamination Facility) drums and how they are included in the PFP drum population .  Add the total volume (cubic meters) of waste in inventory .  In the final paragraph of Section 5.4.2, add the second predominant radionuclide by activity , to be consistent with the previous portion of the sentence that identifies the two predominant radio nuclides b y mass. Revise the AK Summary as appropriate to address the above; amendment of existing freeze file modification is acceptable. B. Regulatory Reference: 40 CFR 194.24(c) C. Site requirement(s): D. Discussed with: S. Schaf er, S. Nance E. Additional Comments: F. Site Response Information: Site Response Required? YES NO Site Response Due Date: May 13 , 2010C - 5 

### ATTACHMENT C.5 EPA INSPECTION ISSUE TRACKING FORM , IS SUE NO. HANFORD - CCP - CH -VE - 10 - 005F, FINAL Inspection No. EPA - Hanford - CCP - CH - 04.10 - 8 Issue Number: Hanford - CCP - CH - VE - 10 - 005F Date: April 28, 2010 Inspector: Dorothy E. Gill Attachments? YES NO Sample Size: 1 Populati on size (if known): 1 Description of Issue: The VE personnel interviewed did not have any knowledge or understanding of EPA regulation(s) as required by CCP - PO - 002, Revision 22, Appendix 10, Section 10.2. This NDE issue was previously

identified b y EPA at both ORNL - CCP and SRS - CCP. EPA requires that VE operators be trained to Federal Regulations (CFR Part 194.24) before the first CH TRU waste shipment is scheduled from Hanford CCP. B. Regulatory Reference: 40 CFR 194.24(c) C. Site requiremen t(s): Not applicable D. Discussed with: Deborah Zenter, Larry Porter E. Additional Comments: None F. Site Response Information: Site Response Required? YES NO Site Response Due Date: See Description of Issue section aboveC - 6 

### ATTACHMENT C.6 EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. HANFORD - CCP - CH -VE - 10 - 006CR, FINAL Inspection No. EPA - Hanford - CCP - CH - 04.10 - 8 Issue Number: Hanford - CCP - CH - VE - 10 - 006CR Date: April 28, 2010 Inspector: Dorothy E. Gill Attachments? YES NO Sample Size: 1 Population size (if known): 1 Description of Issue: The VEE appointment letter was dated March 2010 although Hanford- CCP has been performing VE at Hanford since the summer of 2009. B. Regulatory Reference: 40 CFR 194.24(c) C. Site requirement(s): Not applicable D. Discussed with: Deborah Zenter, Larry Porter E. Additional Comments: None F. Site Response Information: Site Response Required? YES NO Site Response Due Date: May 14, 2010D - 1 

### ATTACHMENT D ACCEPTABLE KNOWLEDGE SOURCE DOCUMENTS REVIEWED Hanford CCP CH Baseline Reference List AKE Qualification Card for Steve Schafer, 2003 through March 22, 2 010. AKE Qualification Card for Sheri Nance, 2004 through March 22, 2010. CCP - AK- RL - 101, Central Characterization Project Acceptable Knowledge Summary Report For Hanford Plutonium Finishing Plant (PFP) Contact - Handled Transuranic Debris Waste From Deco ntamination and Decommission , Waste Stream: MPFPDD , Revision 1, January 15, 2010 . CCP - AK- RL - 101 Central Characterization Project Acceptable Knowledge Summary Report For Hanford Plutonium Finishing Plant (PFP) Contact - Handled Transuranic Debris Waste, Wast e Stream: MPFPDD , Revision 2 March 30, 2010 . CCP - AK- RL - 101, from Sheri Nance to CCP Central Records, MPFPDD NDA Memo, Evaluation of the Radiological Characterization of Hanford Site Waste Stream MPFPDD , Revision 2, March 17, 2010. CCP - AK- RL - 101, from Mar k Doherty

to CCP Central Records, MPFPDD NDA Memo, Evaluation of the Radiological Characterization of Hanford Site Waste Stream MPFPDD, Revision 3, April 7, 2010 . CCP AK Tracking Spread Sheet, W aste S tream MPFPDD, dated April 2 7, 2010 . CCP - PO - 001, CCP Transuranic Waste Characterization Quality Assurance Project Plan . CCP - PO - 003, CCP Transuranic Authorized Methods for Payload Control . CCP - TP - 005, Revision 18, CCP Acceptable Knowledge Documentation, Effective date November 15, 2006 ; and example Attachment s 1, 4, 5, 6, 7, 8, 10, provided April 27, 2010. CCP - TP - 113, CCP Standard Contact Handled Waste Visual Examination , Carlsbad, New Mexico, Washington TRU Solutions, LLC. C013 Interview of Michael Wesselman by Richard Clinton concerning Sr - 90/Cs - 137, Ratio Determination. R. Clinton , March 28, 2002. C014 E - mail from Bisping to Rollosson re: Heat - Sealed Bag Question and Clarification, S.W. Bisping , July

25 , 2002. C018 Email Response from Elizabeth Curfman to Richard Clinton regarding Inquiry from Caroline Sutter concerning PFP Laboratory History , E. Curfman , January 10, 2000.D - 2



### C019 Record of Communication for Interview of Ted Venetz Regarding Plutonium Finishing Plant Wastes , P.H. Wicks, M.E. L akes, and R.J. Swan , April 26, 2007. C020 Memo to Abramowski re : Determination of PCB Concentration in Hydraulic Oils 65452 - 82 - 159 S. G. Metcalf

, August 25, 1982. C021 Interview with Jose Aranda , R. Clinton , August 28, 1998. C022 Interview with R. Gregory , R. Clinton , August 28, 1998. C023 Questionnaire , G. Backlund. C024 E - mail re: 224 - T Wastes , J. D. Anderson , July 7, 2007. C025 E - mail from Aranda to Clinton re: Question about Heat Sealing , J. L . Aranda , August 7, 1996. C026 PFP Soil Record of Communication with Jose Mejia , M.E. Lakes and P.H. Wicks , December 19, 2006. C027 PFP Soil Record of Communication with J. Aranda , M.E. Lakes and P.H. Wicks , December 6, 2006. C028 E - Mail Response from Jose Aranda re: PFP W aste Question , Jose Aranda , September 13, 1999. C029 E - mail from Fazzsari re: PFP Waste Question , D. Fazzari , September 13, 1999. C030 Final Low - Pressure Reactor Fuel Processing Campaign - PUREX Plant Contract AT (45 - ) - 1 20 ARH - 2440 , R.P. Corlew , April 7, 1972. C031 Email f

rom Karl Husted re: Two most prevalent isotopes in RLMPFPCD waste originating in 242 - Z, K. I. Husted , December 19, 2007. C032 Memo from D. C. DeRosa, dated February 7, 2003, Subject: NPFPD and MPFPD Waste Streams M4T00 - DCD - 03 - 029 D.C. DeRosa February 7, 2003. C034 Fax from Manthos to Hamilton re: Values used for WIPP Waste Calcul ations at PFP 16300 - AC90 - 041 E , J. Manthos , October 8, 1990. C035 Email from Fred Riedel, F . Riedel February 9, 2000. C036 Record of Communication with Ted Venetz, R. E. Bolls June 30, 2005. C037 Memorandum from R. Clinton to P.J. Crane concerning Trans mittal of AK Re - eval checklist for Waste Stream NPFPD 3T000 - PJC - 01 - 043 R. Clinton March 21, 2001.D - 3



### C039 Interview of Gregg Krehl by Richard Clinton regarding Stanley Works Torpedo Levels, R. Clinton August 15, 2001. C040 Interview of Customer Representative of Shell Chemical Company by Richard Clinton regarding Shell Sol 140, R. Clinton August 15, 2001. C041 Email from Richard Clinton to Gregg Krehel regarding and inquiry of the Chemical Make - up of Fluid in Stanley Works Torpedo Levels. R. Clinton July 1 8, 2001. C042 Disclosure of Information Concerning the Waste Designation of a Level Recorded in TRU - WRP - 01NCR- 100 for Drum RHZ - 220 - A21300 3T000 - PJC - 01 - 158 R. Clinton. C043 Record of Communication with D. A. Marsh R. J. Swan. C044 L etter from P. J. Crane, R. Clinton October 1, 1998. C045 Interview of J. Estey M. Watson October 3, 2000. C046 Interview of J. A. Mortenson re: Heat Sealed Packages. M. Watson September 19, 2000. C047 Interview of R. D. William re: PFP Heat Sealed Packaged. M. Watson Sep tember 14, 2000. C048 Interview of R. E. Allenby re: PFP Heat Sealed Packages. M. Watson September 14, 2000. C049 Interview of R. Lehrschall re: Heat Sealed Packages. M. Watson September 27, 2000. C051 Sr- 90 To Cs - 137 Ratio for Appendix E of Hanford Sit eTransuranic Waste Certification Plan for NDA M4T00 - PJC - 02 - 076 R. Clinton April 11, 2002. C052 Disclosure of Miscertification Information and Visual Examination Selection for Fiscal ye ar 2002 3T000 - PJC - 01 - 156 R. Clinton October 9, 2001. C053 Email from Lincoln P. Djang to David C. DeRosa and Paul J. Crane Concerning U - 234 and Sr- 90 in Characterization Data from the Tank Farms Database, TWINS, L. Djang February

27, 2002. C054 Memorandum to L . F. Perkins re: TRU Site Project Office Transmittal for Notification of Possible Target Analy te Additions 3T000 - PJC - 00 - 172 P. J. Crane September 8, 2000. C055 Memorandum to L . F. Perkins re: TRU Site Project Office Transmittal for Notification of Possible Target Anal yt e Additions 3T000 - PJC - 00 - 203 P. J. Crane October 2 6, 2000.D - 4



### C056 Contract no. DE - AC06 - 96RL 13200

– DOE Approval for Termination of Safeguards on Specific Attractiveness D Mixed Oxide Scrap at the Plutonium Finishing Plant 0205389 M. H. Schlender November 15, 2002. C057 Contract No. DE - AC06 - 96RL 13200

– DOE Approval for Termination of Safeguards on Specific Attractiveness D Mixed Oxide Scrap at the PFP 00301319A K. A. Klein March 20, 2003. C058 Interview with Thurman Cooper. R. Clinton August 28, 1998. C059 Coffins from PFP

– Mtg Notes E. M Greager Augus t 2, 2006. C060 Record of Communication with Karl Husted 10/12/07 re: Adding U - 232 as a trace radionuclide to MPUREXD and MPFPD AK, M.I. Rollosson October 12, 2007. C062 E - Mail Response to Questionnaire sent b y MS Watson to Several Former Workers at PFP Regarding the Use of Heat Sealed Bags Generating Heat Sealed Packages, R. Trainer September 6, 2000. C063 Internal Memo to E. T. Abramowski re: PCB Determination Results in Contaminated Hydraulic Oils 65452 - 82 - 114 S. G. Metcalf May 19, 1982. C071 Memorandum from N.M. Abdurrahman to P.J. Crane concerning Calculations of Hanford Sr- 90 I sotopic Ratio Based on its Isotopic Ratio to Cs - 137 02 -NMA - 006 N.M. Abdurrahman August 14, 2002. C074 PFP Debris Waste Designation , J. Bolles March 31, 2004. C076 Designation of TRU Drums Containing Heat Sealed Inner Package L. J. Estey May 7, 1990. C077 Transmittal of AK Confirmation Checklist for 19 Waste Containers from Waste Stream MPFPD 3T000 - PJC - 01 - 090 R. Clinton June 7, 2001. C082 Internal Memo to L Dayley re: Results of Sand, Slag, and Crucible Testing for Cementation Process 15F00 - 96 - 068 S. A. Jones and J. L . Winstead August 7, 1996. C083 Debris Classification for Sand, Slag, and Crucible Waste FH - 0003830 E.S. Aromi and P.J. Crane. C084 Proposed Waste Designation of Carbon Tetrachloride Used at the Plutonium Finishing Plant 3T000 - PJC - 00 - 045 R. Clinton April 10, 2000. C100 U - 234 to U - 235 and U - 238 Ratios for Appendix E of Hanford Site Transuranic Waste Certification Plan for NDA M4T00 - PJC - 02 - 077 R. Clinton April 11, 2002.D - 5



### C104 241 - Z - 361 Sludge Characterization Sampling and Anal ys is Plan HNF - 4371 F.R. Crawford July 29, 1999. C105 Communication to R. Clinton re: Occurrence of Cs - 137 and K - 40 in Transuranic Waste, M. G. Cantaloub February 20, 2001. C106 Internal memo to R. L . Granberg re: Solvent Waste Designations 80132 - 89 - 069 R. J. Landon May

15, 1989. C107 Plutonium Purification and Fabrication of Technical Manual HW - 29200. C108 Slurping Vacuum System and Analy tical Laboratory

Room 146 Repackaging Process, N. Sequin September 22, 1999. C109 Disposal request for Downloaded. CCL4

– TBP Waste

– PFP - 94 - 000189 15540 - 094 - RJM - 029 E. J. Manthos February 23, 1994. C110 Memorandum to P. J. Crane re: Anal ys is of TI Cs with Respect to Possible Addition to Target Analy

t e List 8F000 - SLF - 00 - 23 S. L. Fitzgerald September 13, 2000. C113 Internal Memo to E. G. Backlund re: Corrosivity Test on Cemented Sand, Slag, an Crucible Items 19F0096 - 06+2 M. L. Winstead July 10, 1996. C114 E - mail to M. I . Rollosson re: Use of the Term Soil in Past Practice, S. W. Bisping June 28, 2006. C115 WRP Strategy

for Managing Chlorinated Biphenyl’s Under TSCA NA L . E. Strickling January 30, 2008. C116 Proposal to Delay

Assignment of TSCA Status to Retrievably Stored Low - Level Waste F9000 - 07 - 019 J. E. Hyatt June 26, 2007. C117 PFP Building Numbers NA D.R. Corriell May 20, 2009. C200, Memorandum from Sheri Nance to CCP Records, Waste Material Parameter Anal ys is for Waste Stream MPFPDD, March 15, 2010 . C205 Addendum to TSD Record D. R. Corriel l May 20, 2009. C353 Memo to P. J. Crane re: Calculations of Hanford Strontium I sotopic Abundances Based on Isotopic Ratios 02 -NMA - 005, 02 -NMA - 006, 04 -NMA - 007 N. M. Abdurrahman July 14, 2004. C364, Record of Interview, Waste Stream Numbers: MPFPDD, Interviewers: Steve Schafer and Sheri Nance, Interviewee: Rhonda J (Roni) Swan, Melvin E (Mel) Lakes, Subject: Feed to the Building 232 - Z Incinerator, May 4, 2010 .D - 6



### DOE/WIPP - 02 - 3122, Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant , C arlsbad, New Mexico, U.S. Department of Energy . Draft Waste Stream Profile Form, Hanford Waste Stream MPFPDD, Prepared by CCP, March 10, 2010 . DR005 AK Source Document Discrepancy R. Clinton May 20, 1999 . DR006 NaI Discrepancy R. Clinton July 15, 19 99 . DR010, Acceptable Knowledge source document Discrepancy Resolution waste stream MPFPDD, TRU - Mixed heterogeneous debris resulting from production, maintenance, cleanout, stabilization and decontamination and decommissioning (D&D) at the Hanford Plutonium Finishing Plant (PFP), Steve Schafer provided April 27 , 2010 . DR013, Acceptable Knowledge Source Document Discrepancy Resolution, Waste Stream Number MPFPDD, T RU mixed heterogeneous debris resulting from production, maintenance, cleanout, stabilizatio n, and decontamination and decommissioning (D&D) at the Hanford Plutonium Finishing Plant (PFP) . Discrepancy

Resolution for Incinerator Feed (Building 232 - Z) . Engineering Data Transmittal , EDT 125236, to Distribution from WRAP Project Engineer, Prelimin ary Safety Evaluation, W - 026 Waste Receiving and Processing Facility Module 1, December 9, 1994 . Freeze File Changes, prepared b y Steve Schafer, Changes to CCP - AK- RL - 101, R. 2 (and attachments) identified and agreed to during the April 5 - 7, 2010 CBFO/NM ED audit, provided Apri l 27, 2010 . Freeze File Modification of CCP - AK- RL - 101Central Characterization Project Acceptable Knowledge Summary

Report For Hanford Plutonium Finishing Plant (PFP)Contact - Handled Transuranic Debris Waste, Waste Stream: MPFPDD, REV IS ION 3, MARKUPSN Provided May 13, 2010 . HNF - 6489, Rev ision 1, Acceptable Knowledge (AK) Document for Plutonium Finishing Plant Mixed Debris Waste Stream MPFPD, September 15, 2006 . HNF - 36515 Revision 1, Acceptable Knowledge Document for the Richland Mixe d Plutonium Finishing Plant Comprehensive Debris Waste Stream, RLMPFPCD June 5, 2009 . HNF - 15502, Plutonium Finishing Plant Deactivation and Decommissioning Technical Safety Requirements , Administrative Control 5.20 and Specific Administrative Controls 5. 24 .D - 7



### Inter- Office Correspondence, Washington TRU Solutions LLC, from J.E. Hoff to Distribution, Transmittal and Closure of WTS Quality Assurance Audit IO - 06, Central Characterization Project Quality

Assurance Program, August 5, 2009 . Inter- Office Correspondence , March 31, 2010, from V. M. Waldram T o : N. R. McCants, RE: Acceptable Knowledge Accuracy Report, Waste Stream Number MPFPDD, L ot 1. M024 Hanford Site Battery Book

– “HEHF MSDS’s from Soft Reporting which Pertain to Alkaline Batteries”, T. C. Hughes. M025 Burial Records. M026 MSDS for Dry

Chemical Fire Extinguisher Powder (Ammonium Phosphate) 051938, August 31, 2000. M033 Waste Designation Worksheet for PFP - DES - 07 - 00 P. Wicks. M034 Waste Designation Worksheet for PFP - DES - 08 - 00 P. Wicks. M035 PFP Complex Effluent TRU Waste Stream Designation 216Z12DES01 to 04, 241Z8DES 01 - 00 M. Watson. M036 Waste Designation Worksheet for Designation # PFP - DES - 03 - 00 PFP - DES - 03 - 00 P. Wicks February

20, 2007. M037 Waste Designation Worksheet for Designati on # PFP - DES - 04 - 00 PFP - DES - 04 - 00 M. Lakes February

5, 2007. M038 Waste Designation Worksheet for Designation # PFP - DES - 05 - 00 PFP - DES - 05 - 00 P. Wicks February

5, 2007. M039 Solid Waste Storage/Disposal Records. M040 RMI S Solid Waste Record List for NPFPD and MPFPD , May 30, 2001. M041 Burial Records for RLMPFPCD , M Rollosson. M042 Low Level/TRU Waste Located at CWC, S. G alstad. M043 MSDS Number 7653 - 2, SHELLSOL D60, Shell Chemical Company . M044 Solid Waste Burial Records

– Addendum for 218 - W - 3A, July 23 , 1980. M046 Radioactive Waste Storage/Disposal Anal ys is Record 14 - 1D - 8LM - 0401 M. F. Pascual , September 16, 1995. M047 MPFPD I sotopes Data from SWITS R. Clinton June 7, 2001.D - 8



### M048 Addendum to TSD Record (Canned Ash) J. Stamm. M049 Addendum to TSD Records (SS&C) J. Stamm. M050 Addendum to TSD Record. M051 Reevaluation of RLMPDT.001 Change Notice # 3 M. I. Rollosson February 22, 2007. M052 Reevaluation MPFPD Organic Matrix to Other Inorganic Matrix Material, M. I. Rollosson. M054 PFP PCB Debris Designation PFP - DES - 02 - 00 M. lakes October 11, 2006. M056 Review of PFP Complex Effluents AK/Designation and Applicability of WAC 173 - 303 - 090(7) and 40 CFR 261.23, J.P. Evans April 3, 2008. M058 MSDS for Fryquel 200 Hydraulic Fluid 014029, April 24, 2007. M062 Shell Chemical Company- Solvents Technical Support - American Region - Fax On Demand System, Shell Chemical Company September 22, 2000. M063 Fax to R. Clinton re: Waste Material to be Disposed of E. G. Backlund February 17, 2000. M102 Waste Inf

ormation Data System General Summary Report for 232 - Z Waste Incineration Facility Site Code: 232 - Z. M105 Waste Container Projected Procurements for the Lifecycle of the PFP D&D Project, 2009. M106 NDA Data for Containers from Hanford Waste Stream RLMPDT. 001, WWI S May 21, 2009. M124 MSDS for RADPRO 061823A. M280 TRU Waste Drum Container Contents reports. M305 TRU Waste Volume Inventory Estimate. New Mexico, Washington TRU Solutions, LLC.DOE/TRU - 2008 - 3425, Annual Transuranic Waste Inventory

Report

– 20 08, NCR- RL - 0001; NCR- RL - 600 - 617; NCR 1201 - 1203; Waste Stream MPFPDD, various dates . P041 Past Practices Technical Characterization Study- 300 Area - Hanford Site WHC - MR- 0388 M.S. Gerber December, 1992.D - 9



### P051 Hanford Site Solid Waste Acceptance Criteria HNF - EP - 0063, May 1, 2003. P052 Hanford Site Transuranic Waste Management Program Acceptable Knowledge Documentation for Retrievabl y Stored Contact - Handled Waste HNF - 3461, Revision 7 R. Clinton. P070 Hanford Site TRU Certification Plan HNF - 2600. P071 History and Stabilization of the PFP Complex, Hanford Site HNF - EP - 0924 M.S. Gerber March, 1997. P072 Hanford Site TRU QAPjP HNF - 2599. P075 CCP NCR and CAR logs for 2003 and 2004 DR 009 M. M. Anderson. P098 Determining Whether Transuanic Waste is Defense Wast e D. P. Detwiler. P100 Secrecy

Vs. Openness: Finding a Balance at the DOE, Proceedings of a Workshop, J. Weeks November 29, 1999. P101 Addendum to I sotopics per Can for Mark IA and Mark IV Fuel WHC88 - 00032, Add 1, July 19, 1988. P113 A History

of Soli d Waste Packaging at the Hanford Site WHC - SA - 2772 - FP D. R. Duncal, et al February

1, 1995. P114 PFP Final Safety Analysis Report WHC - SD - CP - SAR- 021 J. E. Shapley . P115 Process Flowsheet Document, Remote Mechanical C (RMC) Line, PFP PFD - Z - 190 - 00002 M. Stubbs, J. F. Durnil June 10, 1993. P116 Stabilization of Polycubes Engineering Study Historical Use and Fabrication and Treatment Schemes WHC - SC - CP - TI - 204 W.S. Lewis. P117 Safety

Assessment Document

– Z Plant RMA Oxide line RHO - CD - 454 D. L . Cahow, K. O. F ein, G. L. Hanson September 1, 1979. P120 Z Plant RMA Oxide Line Campaign Process Control Plan RHO - CD - 644 R. L . Walser, R. E. Van der Cook. P121 Z Plant RMA Oxide Line Flowsheet Addendum - Filtrate Concentration RHO - CD - 616, ADD R.L . Walser and R.E. Van der Cook. P122 Plutonium Finish Plant Environmental Operations, Recan Plutonium Metal ZO - 200 - 504, June 27, 1994.D - 10



### P123 Criticality

Prevention Specification, Incinerator Burning Hood Characterization and Disassembly

Activities CPS - Z - 165 - 80625, May 8, 1995. P 124 Criticality

Prevention Specification, Glovebox Clean - up Operations CPS - Z - 165 - 80012. May 8, 1995. P125 Plutonium Finishing Plant Process Flow Document k- Sand, Slag and Crucible Cementation Process Flow Document PFD - Z - 190 - 00004 G. R. Wittman October 1, 1994. P126 Thermal Stabilization Process Flowsheet Room 230A, 234 - 5 Building. PFD - Z - 190 - 00004, Revision A - 0 G.R. Wittman October, 1994. P127 Plant Operating Procedure, Oxidize Plutonium Metal in Glovebox HC - 21 - C and HA - 21 - I ZO - 160 - 033, Revision A - 7 Rockw ell Hanford Operations. P128 Stabilize Reactive Scrap (Operate HC - 21C Muffle Furnace) ZO - 160 - 032 , August 26, 1982. P129 Criticality

Prevention Specification: Plutonium Finishing Plant/Plutonium Metal Production CPS - Z - 165 - 80350. January 9, 1990. P130 Engineering Evaluation/Cost Analysis for the Plutonium Finishing Plant Above - Grade Structures DOE/RL - 2004 - 05, Revision 1. P131 PFP Historical Facts DOE - 0254. P132 242 - Z Waste Treatment Facility , D. C. Lini. P133 Fabrication Oil Disposal ARH - CD - 239 D. A. D odd. P134 PFP Liquid Organic Disposal as 20 Year Retrievable TRU Waste HNF - 26402 M.W. Gibson and L .H. Rodgers. P135 PFP Impure Plutonium Oxide: Characterization of Items with Greater than 30 & less than 85 Weight Percent Plutonium HNF - 10638 D. C. Lini, L . H. Rodgers. P137 Existing Data on the 216 - Z Liquid Waste Sites RHO - LD - 114 K. W. Owens. P138 Data Quality

Objectives Process for Disposition of Sand, Slag, and Crucible Materials Stored at the Plutonium Finishing Plant HNF - 9734, Revision 2 A.M. Hopkins December, 2003. P139 216 - Z - 9 Crib at the PFP D. Lini, J. Teal February 27, 2004. P140 242 - Z Waste Treatment Facility D.C. Lini December 29, 2003. P141 Handling of Pu Contaminated, Acid Soaked Rags in Hood 5 ZO - 160 - 031.D - 11



### P143 Decommissioning of Divi sion of Military Application Equipment at Richland Operations Office: Quarterly

Report ARH - R- 215, 1Q. P144 Decommissioning of Division of Military Application Equipment at Richland Operations Office: Quarterly Report ARH - R- 215, 2Q. P145 Decommissioning of Division of Military Application at Richland Operations office: Quarterl y Report ARH - R - 215, 3Q. P146 Decommissioning of Division of Military Application (DMA) Equipment at Hanford - Summary

Report: June 1977 ARH - ST - 141 M.N. Raile June, 1977. P147 Handle Pu Contaminated, Acid Soaked Rags ZO - 160 - 030. P148 Critical Mass Specification, Waste Treatment Facility , Buildings 241 - Z and 242 - Z HW - 82632 R.J. Sloat. P149 Process Design Basis for Fabrication Oil Storage and Sampling Facility , 234 - 5 Building. HW - 76399 D.D. Wodrich February 13, 1963. P150 Recovery

of Plutonium from Fabrication Oil HW - 74350 R.S. Kingsley August 1, 1962. P151 The Plutonium Production Story at the Hanford Site: Processes and Facilities History WHC - MR- 0521 M. S. Gerber. P152 Histori cal Report on the Retrievabl y Stored Division of Military Application Equipment at the Hanford Site WHC - IP - 0791 J.A. Demiter, D.R. Duncan, and W.E. Meeuwsen December 11, 1991. P153 WST History

of the Plutonium Production Facilities at the Hanford Site His toric District 1943 - 1990 DOE/RL - 97 - 1047 T.E. Marceau, D.W. Harvey , et. al. June, 2002. P154 Stabilize Material Handling ZO - 160 - 034, Revision B - 0, D - 1, February 22, 1995. P155 Operating Specifications for Plutonium Finishing Plant: Thermal Stabilization G lovebox HC - 21C OSD - Z - 184 - 00006 M.W. Gibson July 14, 1994. P156 Z - Plant RMA Oxide Line Flowsheet PFD - Z - 190 - 0001 S.L . Yarbo. P157 PFP Process Control Engineering PFD - Z - 190 - 0004 M. Gibson. P158 Estimation and Characterization of D&D Solid Waste Expected from PFP WHC - EP - 0829, Revision 0 J.S. Miller, J.A. Pottmeyer, T.J. Stratton, and D.R. Duncan January , 1995.D - 12



### P159 Scrap Stabilization and Calcination Glovebox 4, Room 41, 236 - Z Building CPS - Z - 165 - 82090, Revision C - 0 PFP May 4,1987. P162 Glovebox MT - 5: Dis solving and Leaching CPS - Z - 165 - 80715, Revision A - 3 PFP. P163 Glovebox MT 6: Solution Clarification CPS - Z - 165 - 80716, Revision C - 1 PFP. P164 Access Glovebox: 2nd Floor East CPS - Z - 165 - 80709. P165 Access Glovebox: 1st Floor West CPS - Z - 165 - 80708. P166 Acce ss Glovebox: 1st Floor East CPS - Z - 165 - 80707. P167 Process Cell CPS - 165 - 80701, Revision A - 1 PFP January 12, 1995. P168 Slag and Crucible Processing Gloveboxes CPS - Z - 165 - 80731, Revision A - 0. PFP September 19, 1989. P169 Operate Glovebox 60 ZO - 160 - 040 C. M. Kronvall 1981, 1987. P170 Handling of Plutonium Contaminated Acid and Water Soaked Rags ZO - 170 - 005. P171 Investigation of Chemical Explosion of an Ion Exchange Resin Column and Resulting Americium Contamination of Personnel in the 242 - Z Building. P 172 Sample Plutonium Bearing Powders for the International Atomic Energy Agency (IAEA) ZO - 300 - 110, Revision A - 2 PFP August 21, 1995. P173 Recan Plutonium - Bearing Recoverable Material ZO - 200 - 505, Revision J - 2 E.P. Bonadie September 11, 1996. P174 Handle P FP Reactive Material ZO - 170 - 014, Revision D - 0, E - 2 C. Barr and G.B. Chronister 1993, 1996. P175 Sorting Glove Box CPS - Z - 165 - 80290 September 12, 1983. P176 Dismantle HEPA Filters ZO - 170 - 823, July 7, 1994. P177 Repackage 55 - Gallon Waste Drums ZO - 170 - 040, April 3, 1989. P178 Seal Out ZO - 170 - 0299 G. Barr, et all. P179 Handle and Package TRU Solid Waste in 55 Gallon Drums ZO - 170 - 015 PFP.D - 13



### P180 Solid Waste Repackaging and Disposal ZL - 100 - 323, September 18, 1998. P181 PFP Analy

tical Laboratory

Organic Wast e Loadout ZL - 100 - 326 January 14, 1998. P182 The I sotopic Content and Specific Activity of Pile Produced Plutonium HW - 23487 G. J. Alkire, H. R. Schmidt, E. M. Kinderman February 25, 1952. P183 Methods and Models of the Hanford Internal Dosimetry Program PNL - MA - 860 E.H. Carbaugh January

31, 2003. P184 Spent Fuel I sotopic Inventory counted b y Fuel Elements UNI - 1983 E. H. Carbaugh January 31, 2003. P185 26% Pu - 240n Production Data ARH - 1164 R. C. Black, et all February 22, 1982. P186 PFP Operations Overview (1949 - 2004): Contamination Events and Plutonium I sotope Distributions of L egacy

holdup Material in Process Systems HNF - 22064 R. C. Hoy

t, J. A. Teal. P187 PFP L aboratory

Safety Anal ys is Report SD - HS - SAR- 011 G. L . Jones March 1, 1984. P188 Radiological Hi story of the Plutonium Finishing Plant (1954 - 1997) FSP - PFP - IP - 003 A. L. Ehlert April 1, 1999. P189 Plutonium Process Support L aboratories , D. Lini June 21, 2004. P191 Engineering Evaluation/Cost Analysis for the Plutonium Finishing Plant Sub - Grade Structures and Installations HNF - 30862 L. Oates, J.A. Teal, A.M. Hopkins, A.R. Sherwood, and D.C. Lini August 2006. P192 FY 1988 Remote Mechanical C Line , Campaign Blend Plan WHC - 88 - 245 J. F. Durnil, E. V. Weiss June 24, 1988. P194 D&D Assessment for the Waste Incineration Facility (Building 232 - Z) Hanford Site, Washington DOE/RL - 93 - 104 L .N. Dean February 1994. P196 241 - Z - 361 Sludge Characterization Sampling and Anal ys is Plan HNF - 4371, Revision 1 F.R. Crawford July

29, 1999. P197 Clarification on PFP L ead Lin ed Gloves. C. Simiele. P198 T - Plant Operating Procedure Package Transuranic Waste DO - 100 - 039 C, Martin. P199 Plutonium Finishing Plant Stabilization Operations Technical Procedure - Pipe -N - Go Operations ZO - 160 - 080, Revision C - 17 May 3, 2006.D - 14



### P200 Remot e Mechanical C (RMC) Line Material Balance and Lead Summary

– June 27, 1985 to December 11, 1985 RHO - SS - SR- 183 - 85 - 1 D. L. Bouse, J. V. Matkevich, R. C. Martinson January 30, 1986. P202 Nuclear Material Transfer and Control FSP - PFP - 5 - 8, Vol. 1, Chapter 4.5 , Revision 8 PFP June 8, 1998. P203 Nuclear Material Control General Requirements FSP - PFP - 5 - 8, Vol. 2, Chapter 4.3, Revision 5 PFP. P204 Contaminated Process Equipment Removal for the D&D of 232 - Z Contaminated Waste Recovery Process Facility

at the Pluto nium Finishing Plant HNF - 32534 - FP, Revision 0 M.J. Minette, et al. January , 2007. P205 Organic Waste Loadout ZL - 100 - 326 J. M. Hieb April 12, 1996. P207 Tank 241 - Z - 361 Waste Characterization Data Quality Objective: Headspace an Tank Structure FDH - 9855079R 1, HNF - 2176 L. J. Olguin, A. M. Hopkins, D. L. Banning. P208 Recent Site - Wide Transport Modeling Related to the Carbon Tetrachloride Plume at the Hanford Site M. P. Bergeron, C. R. Cole September 1, 2004. P209 Final Environmental Statement, Waste Management Operations, Hanford Reservation, Richland, Washington ERDA - 1538 J.L . Liverman. P210 Z Plant Aggregate Area Management Study Technical Baseline Report BHI - 00175 D.H. DeFord. P211 216 - Z - 12 Transuranic Crib Characterization: Operational History and D istribution of Plutonium and Americium RHO - ST - 44 R. B. Kasper. P212 Chemical and Radioactive Material Spill Clean Up ZL - 191 - 322. P213 Seal Out - PPSLGlove Boxes ZP - 100 - 001 W. S. L ewis. P215 RCRA/SUPERFUND/OUST Hotline Monthly Report Question October 1992 . October 1, 1992. P216 RCRA/SUPERFUND/OUST Hotline Monthly Report Question and Answers May 1, 1991. P218 Nuclear Material Control

– Physical Inventory FSP - PFP - 5 - 8, Chap 4.4. May 19, 1988. P219 Receiving, Handling, and Disposal of Routine Laboratory Samples ZL - 090 - 304. P220 Seal In and Seal Out of Material from Glove Box by Plastic bag or Sphincter ZL 161 - 302.D - 15



### P221 Interim Plutonium Stabilization Engineering Study PNL - 10507 P. J. Sevigny, et al . August 1, 1995. P222 Technical Basis for Characterizati on of Plutonium for PFP WHC - SD - CP - TI - 190 R. D. Crow, R. W. Szempruch. P225 Listing Background Document, EPA. P226 Hanford Tank Chemical and Radionuclide Inventories: HDW model LA - UR- 96 - 3860 , S. Agnew. P227 Hanford Defined Waste Models Limitations and Improvements HNF - 3273 R. W. Harmsen, et al. P228 Criticality

Safety May

1, 1998. P230 Process Flowsheet Document, Remote Mechanical C (RMC) Line, PFP PFD - Z - 190 - 00002 G. T. Tassoti. P231 PRF Solvent Extraction Depletion Flowsheet - High Uranium/High Fluoride Feed PFD - Z - 180 - 00001, June 20, 1988. P232 PRF Engineering Training Manual RHO - MA - 246 J. E. Ludowise. P233 Hydrol ys is and Dissolution Flowsheet PFD - Z - 180 - 00003 M. A. McNamar. P234 Waste Minimization Plan PFP WHC - WM - EV - 023 E. G. Backlund. P235 A - Button Line Terminal Process Clean Out RHO - CD - 982 J. F. Durnil, J. D. Ludowise. P236 Tank 241 - Z - 361, Cores 263 and 264 Analy tical Results for the Final Report NA R. A. Esch May 1, 2000. P237 Final Report for the Hydraulic Oil Samples Received from PFP, 234 - 5Z HA - 23S, October 2007. G. P. Ritenour November 29, 2007. P238 Solid Waste Management History of the Hanford Site WHC - ED - 0845 D. R. Duncan March 1, 1995. P239 PFP Final Safety Analysis Report WHC - SD - CP - SAR- 021, Revision 0 J.E. Shapely . P244 Transmittal of the Waste Stream - Specific Documents for the AK Document Management Program for PFP Non - Mixed and Mixed Debris Waste Streams. M4T00 - DCD - 02 - 159 S. W. Bisping June 12, 2003.D - 16



### P245 Plutonium Finishing Plant Operations Overview (1949 - 2004): Contamination Events and Plutonium I sotope Distributions of L egacy Holdup Material in Process S ys tems HNF - 22064 R. C. Hoy t, J. A. Teal. P246 Transmittal of the Waste Stream - Specific Document SS&C01 Revision 5, for the Acceptable Knowledge Documentation Management Program for PFP Sand, Slag, and Crucible Waste. M4T00 - TRU - 04 - 472 S.W. Bisping June 17, 2004. P247 Deactivation and Cleanout of the 308 Fuels Laboratory and the 232 - Z In cinerator at the Hanford Site. Ms Gerber October 22, 1999. P250 Work Plan For Removal of Division of Military Application Equipment 234 - 5ZBuilding ARH - 3079 H.E. Johnson April 26, 1974. P251 The History

of the 200 Area Burial Ground Facilities WHC - EP - 0912 J.D. Anderson September, 1996. P252 I sotopic Composition and Specific Activity of Chalk River Plutonium HW - 53433 F. P. Brauer. P253 Nuclear Weapons Frequently Asked Questions, Chapter 8.0 The First Nuclear Weapons C. Sublette April 18, 2007. P254 Room 27: Maintenance Glovebox CPS - Z - 165 - 80727, Revision A - 0 PFP. P258 WRAP Module 1 Sampling Strategy and Waste Characterization Alternatives Study WHC WD - W026 - ES - 013 C. LBergeson, R. A. Hy re, et al September 1, 1994. P277 PFP Standard Practices, Seal In ZO - 170 - 301 June 21, 1994. P278 Experimental I sotopic Anal ys is of Point Exposure Data in Hanford Prod uction Reactor DUN - 72443 RD H. Toffer and A.F. Kupinski September 8, 1970. P279 Contact Handled TRU Solid Waste Disposal OSD - Z - 184 - 00020. P403 Characterization of Past and Present Solid Waste Streams from the Plutonium - Uranium Extraction Plant WHC - EP - 06 46 H. Toffer, A. F. Kupinski September 8, 1970. P405 Characterization of Past and Present Solid Waste Streams from the Plutonium PFP WHC EP - 0621 D.R. Duncan and B.A. Mayancsik. P406 PFP Plutonium - Uranium Oxide: Characterization of Items with <30 Weight P ercent Plutonium HNF - 10919 D. C. Lini, L. H. Rodgers March 1, 2002. P414 Retrieval Process Description HNF - 5597, Revision 3. March 31, 2004.D - 17



### P415 TRU Waste Phase I Retrieval Plan HNF - 4781, Revision 1 K. McDonald September 26, 2000. P416 Waste Receiving and Processing Facility final Safety Anal ys is Report HNF - SD - W026 - SAR- 002, R2. April 25, 2000. P506 Load Standard Waste Box (SWB) Storage Containers with TRU Waste ZO - 170 - 044, Revision F, Change 26 PFP August 25, 2004. P507 Visual Examination Technique for PFP Debris Waste ZO - 170 - 057, Revision C, Change 11 PFP November 4, 2008. P508 WIPP Procedures - TRU Waste Visual Examination WMP - 400, Revision 12 March 24, 2009. P509 Handle TRU/TRU Mixed Waste in 55 - Gallon Drums ZO - 170 - 015, Revision P, Change 3 PFP November 25, 2008. P510 Package TRU/TRU Mixed Waste ZP - 170 - 0061 April 28, 2008. P511 PFP Debris Draft AK Report HNF - 36515. P512 Procedure for Equipment Removal from the PRF West Gallery Gloveboxes 2Z - 08 - 7986. P513 RadPro Chemical Decontamination of E quipment/Gloveboxes and Hoods Containing Plutonium ZDD - 1 - 002, Revision B, Change 2 PFP April 29, 2009. P514 Technical Data: Plutonium Finishing Plant Chemical Hazard Assessment HNF - SD - CP - TI 219 G. R. Witman, E. V. Weiss September 26, 1997. P525 Waste Inf

ormation Data System General Summary Report (216 - Z Crib) July 21, 2005. P976, Engineering Change Notice 602871, J.P. Joyce, Radioisotopic Characterization of Retrievabl y Stored Transuranic Waste Containers at the Hanford site, WHC - SD - WM - TI - 517, Revision 0, November 12, 1993 P1038 Drum Waste Processing DO - 100 - 058, Rev B, Change 26 June 17, 2009. P1039 Overpacked Drum Waste Processing DO - 100 - 061, Rev A, Change 20. June 17, 2009. P1040 TRU Entry

Glovebox Operation WRP1 - OP - 0724 December 22, 2008. P1079 Hanford Facility

Fact Sheet, 234 - 5Z .D - 18



### P1081 Safety

Evaluation Report for Stabilization Processing of High Chloride Bearing Plutonium Materials at the Plutonium Finishing Plant 03 - ABD - 0071 A.J. Colburn, PJ Garcia, SJ Olinger April 14, 2003. P1082 CHPRC M onthly

Performance Report RL - 0011 D. Del Vecchio September, 2009. P1084, R.L . Gunnick, undated, Use of Isotope Correlation Techniques to Determine 242Pu Abundance, 19 80 P1088 TRU Sorting Glovebox WRP1 - OP - 0725, June 24, 2009. P1089 TRU Loadout Glovebox Operation WRP1 - OP - 0726, July 2, 2009. U201 Hanford Site Plutonium Finishing Plant Residues/L egacy Holdup. U202 Waste Certification Summary

– Radionuclides Reported in SWITS. URS, Washington TRU Solutions LLC, March 3, 2010, to Ms. A. L . Holland Quality A ssurance Manager, Subject: Semiannual report on the central characterization project quality assurance program: second half of calendar year 2009 (July 1, 2009 through December 31, 2009). Waste Stream Profile Form for Hanford Site, Waste Stream Profile Fo rm Number RLMPDT.001, Approved, misdated.19