DOCKET NO: A-98-49; II-A4-74 

WASTE CHARACTERIZATION REPORT FOR TIER 1 CHANGE 

 

EVALUATION OF THE 

WIPP WASTE INFORMATION SYSYTEM (WWIS) FOR REMOTE HANDLED 

TRU WASTE IMPLEMENTED BY THE 

CENTRAL CHARACTERIZATION PROJECT (CCP) at INL and ANL 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center of Federal Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

January 2007
i

TABLE OF CONTENTS 

Section Page

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

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

3.0 Purpose of This Report..................................................................................................... 2

4.0 Scope of Review ................................................................................................................. 2

5.0 Evaluation Team ............................................................................................................... 2

6.0 Performance of the WWIS Review.................................................................................. 3

7.0 Summary of Results .......................................................................................................... 3

7.1 Conclusions ..................................................................................................................... 4

ATTACHMENTS 

Attachment A WIPP Waste Information System (WWIS) Checklist 

Attachment B WWIS Data Requirements 

Attachment C Revised Tiering Table for INL-CCP RH 

Attachment D Revised Tiering Table for ANL-CCP RH
1

1.0 EXECUTIVE SUMMARY 

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

conducted two baseline inspections of waste characterization (WC) programs for remote-handled (RH) 

transuranic (TRU) wastes at the following Department of Energy (DOE) sites: 

• EPA Baseline Inspection No. EPA-INL-CCP-RH-6.06-8 of the Central Characterization 

Project’s (CCP) RH WC program at DOE’s Idaho National Laboratory (INL) in June and 

August 2006, reported in Docket No: A-98-49, II-A4-69; and 

• EPA Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8 of the CCP RH WC program at the 

DOE’s Argonne National Laboratory (ANL) in September 2006, reported in Docket No: A-98-

49, II-A4-70. 

As a result of these two baseline inspections, EPA approved the INL-CCP and ANL-CCP RH TRU 

WC programs based on a demonstration of the sites’ capabilities, with conditions and limitations as 

documented in the INL Baseline Final Inspection Report and the ANL Baseline Final Inspection 

Report, (see EPA Docket Nos: A-98-49; II-A4-72, January 12, 2007 and A-98-49, II-A4-73, January 

16, 2007, respectively). The January 2007 baseline approvals of the CCP programs at INL and ANL 

for RH TRU wastes did not include the WIPP Waste Information System (WWIS). EPA’s proposed 

approval (Federal Register, Volume 71, Number 216, November 8, 2006, Pages 25488 to 25493) 

stated that the WWIS would be evaluated independently and subject to evaluation and review through 

a Tier 1 (T1) change. CBFO subsequently requested a T1 change for WWIS that would apply to both 

sites and this evaluation was performed by EPA’s participation in an interactive demonstration 

organized by CCP on November 21, 2006. 

This report serves as EPA’s evaluation of the WWIS for RH TRU wastes at INL-CCP and ANL-CCP 

as a T1 change. Using the information provided in this report, EPA has determined that the WWIS is 

adequate for tracking RH TRU waste components. This report, in conjunction with the INL Baseline 

Final Inspection Report and the ANL Baseline Final Inspection Reports (see EPA Docket Nos: A-98-

49; II-A4-72, January 12, 2007 and A-98-49, II-A4-73, January 16, 2007, respectively) completes 

EPA’s initial evaluation of INL-CCP and ANL-CCP for RH TRU wastes for the WC systems included 

in the respective inspection reports and allows for the disposal of RH TRU waste at WIPP, contingent 

upon all other approvals that are required for DOE. Note that so far only one RH waste type, debris 

waste (S5000) from INL and ANL, has been evaluated and approved by EPA. Today’s approval will 

allow the disposal of debris waste (S5000) from INL and ANL at WIPP, contingent upon DOE 

receiving all other required approvals. 

Additionally EPA is adding a Tier 2 element for WWIS as a result of this evaluation and is reflected in 

the attached tables for INL-CCP (approved January 12, 2007) and ANL-CCP RH (approved January 

16, 2007). 

2.0 PURPOSE OF TIER 1 CHANGE EVALUATIONS 

Certain changes to the WC activities from the date of the site’s baseline inspection must be reported to, 

and, if applicable, approved by EPA according to the tiering requirements set forth in 40 CFR 194.8, 

regulation and incorporated in the INL and ANL Baseline Final Report cited above. 
2

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

must perform a single baseline inspection of a TRU waste generator site’s WC program. (Vol. 69, 

No.136, pages 42571–42583, July 16, 2004). The purpose of the baseline inspection is to evaluate the 

site’s WC program based on the demonstration that the program’s components, with applicable 

conditions and limitations, can adequately characterize TRU wastes and comply with the regulatory 

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

conducts an onsite inspection to verify that the site’s system of controls is technically adequate and

properly implemented. 

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

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

conducting additional inspections under the authority of 40 CFR 194.24(h). Changes requiring EPA 

notification and approval prior to implementation (Tier 1 Change) and those requiring postimplementation (Tier 2) notification are identified in the site-specific baseline inspection reports. EPA 

may conduct a site inspection to observe, first-hand, the implementation of the change or can opt to 

conduct “desktop” review of information provided specific to a change. Under 40 CFR 194.24, EPA 

has the authority to conduct continued compliance inspections (both announced and unannounced) to 

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

those WC processes remain in compliance with all the applicable regulatory requirements. 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of the EPA’s evaluation of a T1 change to the initial baseline approval 

of RH TRU WC programs at INL-CCP and ANL-CCP. Specifically, this report addresses the 

technical area of tracking waste components using the WWIS. The Baseline Final Inspection Reports 

referenced above describe the conditions that EPA has approved and document the basis for EPA’s 

approval decision of the WWIS. 

4.0 SCOPE OF REVIEW

This T1 change review included the evaluation of information supporting the technical area of the 

WWIS. 

5.0 EVALUATION TEAM 

The participants in the interactive demonstration of November 21, 2006, are listed in Table 1. 

Table 1. Interactive WWIS Demonstration Participants

Evalution Team Member Position Affiliation

Mr. Ed Feltcorn Evaluation Team Leader U.S. EPA ORIA 

Ms. Sharon White Observer U.S. EPA ORIA 

Ms. Dorothy Gill Inspector S. Cohen & Associates, Inc. 

Mr. Patrick Kelly Inspector S. Cohen & Associates, Inc. 
3

Mr. J. R. Stroble WCO CCP 

Ms. Creta Kirkes WWIS Data Entry CCP 

Mr. Eric D’Amico SPM CCP 

Mr. Court Fesmire TRU Waste Cert. Work 

Coordinator CBFO 

Mr. Jim Sheutz Observer CTAC 

6.0 PERFORMANCE OF THE WWIS REVIEW

On November 21, 2006, EPA participated in an on-line interactive audio/visual demonstration of the 

WWIS process for RH waste. 

Procedure CCP-TP-530, Revision 3 was used by CCP to enter RH data into WWIS. EPA reviewed the 

procedure and determined that it was complete and technically adequate for this purpose. Note that at 

the time of the demonstration, CCP did not have complete characterization data for any RH container 

and only Dose-to-Curie (DTC) and Visual Examination (VE) data were used. Sufficient and complete 

characterization data were not available, because, in the absence of an EPA baseline approval, a Waste

Stream Profile Form (WSPF) had not yet been approved by CBFO. Therefore, CCP chose to enter 

data into the test instance of the certification module for the demonstration. 

The DTC and VE data for container No. 00789 were entered into WWIS prior to the demonstration. 

EPA was able to review both the Summary spreadsheet and Waste Container Data Form for this 

container. All the required data fields were present in the RH module of WWIS reviewed. Appendix 

H, Remote-handled TRU waste, from the Qualification Cards for one (1) Waste Certification Assistant 

and one (1) Waste Certification Official (WCO) were reviewed and found to be complete. The RH 

training was dated June 6, 2006 for the WCA and October 10, 2006 for the WCO. The enclosed 

inspection checklist provides additional information on EPA’s evaluation of the WWIS. 

7.0 SUMMARY OF RESULTS 

During this desktop evaluation, the EPA did not identify any findings or concerns related to the use of 

the WWIS for entering and tracking waste RH TRU components at INL-CCP or ANL-CCP. 

Changes to WWIS tiering for RH waste characterization at INL-CCP and ANL-CCP

Tier 2:

The following Tier 2 element is added as a result from this evaluation: 

DOE must report and submit documentation discussing changes include the following: 

• Changes made to WWIS procedure(s) that require CBFO approval 

Both the INL-CCP and ANL-CCP RH WC programs will provide information concerning T2 changes 

to EPA on a quarterly basis. EPA will evaluate the changes and will inform the INL-CCP and ANLCCP RH programs whether the changes raise any concerns and require an INL-CCP and/or ANL-CCP 
4

RH response, or whether the INL-CCP and ANL-CCP RH WC programs can continue to implement 

the proposed changes. 

7.1 Conclusions 

During this T1 evaluation, EPA evaluated the use of the WWIS for tracking RH TRU waste 

components at INL-CCP and ANL-CCP. Based on the demonstration provided by CCP, EPA 

approves the use of WWIS for RH waste for both INL and ANL as a T1 change. This approval allows 

RH waste to be disposed of at WIPP, contingent upon all other approvals that are required for DOE. 

EPA will evaluate the submission of actual/complete RH WC data into the WWIS soon after the first 

shipment of RH waste containers from INL. 

Additionally EPA is adding a T2 element for WWIS as a result of this evaluation which is reflected in 

the attached tables for INL-CCP (approved January 12, 2007) and ANL-CCP RH (approved January 

16, 2007).
Attachment A 

WWIS Checklist 

Attachment B 

WWIS Data Requirements 

Attachment C 

Revised Tiering Table for INL-CCP RH 

Attachment D 

Revised Tiering Table for ANL-CCP RH 
A-1

ATTACHMENT A: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECK

EPA Inspection No.: Inspect

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

WWIS-1: WWIS and Data Entry Personnel must be trained to assess data and properly enter data into the WWIS. 

Y 

CCP-QP-002 

CCP-TP-530, R. 3, s. 2.2.1 

WCO and Data Entry Personnel are trained to assess data and properly enter and transfer all data in the WWIS. Training for Data Entry Personnel and data reviewers/verifiers include the WIPP Waste Information System User’s Manual and the applicable site procedures. Training records are available for review and are complete. 

Y Training requirement

data have been incorpadded to the qualificainspection, there werOfficials (WCO) and Assistants (WCA) quAddendum H – Remsites) contained in thWCO and 1 WCA wdocumentation demo

been appropriately tr

in WWIS. The trainiretrievable. Objective evidence:

Training Qualificatio

WWIS-2: Security measures for ensuring data integrity and accessing WWIS are sufficient. 

Y 

CCP-TP-530, R. 3, s. 4.1 

Access to WWIS is controlled. WWIS access requests are recorded in an access log, however named, that is available for review. 

NA This item was not rev

interactive audio/visuCCP. Procedure CCrequirements for conEPA will verify that later date when data entered in to the prod

WWIS-3: There are adequate 

procedures for entering data into the 

WWIS and transmitting data to WIPP. 

Y 

CCP-TP-530, R. 3, s. 3.0, 4.0 

Employee’s explanation of job duties was consistent with applicable procedures. WWIS and Data Entry Personnel adequately explained how data are assessed, input, and transferred into WWIS. 

Y During the on-line de

by CCP, data entry w

summary sheets for creviewed to ensure thentered. The Waste container was also reradionuclide, Waste to Curie informationsuccessful data entry instance of WWIS. 
A-2

ATTACHMENT A: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECK

EPA Inspection No.: Inspect

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

Objective evidence:

1. Waste Container 

No.00789 

2. Attachment 2, C

data for containe

3. Attachment1, CC

Examination Da00789 

4. WWIS Data Ent

for container No

WWIS-4: Procedures require that only verified and validated data are entered into WWIS. 

Y 

CCP-TP-530, R. 3, s 4.3, Table 1 

Data generation and project level reviews of container data for WWIS entry have been 

performed and review checklists are complete. 

NA During the on-line de

documentation was rdata entry will form pinspection. 

WWIS-5: Procedures include 

instructions for entering characterization data into the Characterization Data System (CDS) WCO Review Form and data discrepancy resolution 

Y 

CCP-TP-530, R. 3, s 4.4, Table 1 

WCA uses Table 1 to identify and enter required data into the CDS Second WCA reviews data, initials and dates If data discrepancies cannot be resolved the form is sent to WCO or SPM for resolution 

NA At the time of the on

entered into the test iThere was no opportdata and resolution oon-line demonstratioinclude the productioaspect of the WWIS future EPA inspectio

WWIS-6: Containers are not submitted to WWIS if there are open 

NCR/CARs 

Y 

CCP-TP-530, R. 3, s 4.3.10, 4.5.16 

WCA request SPQAO to confirm that there are no open NCR/CARs for the containers entered into the CDS 

NA The verification that 

is required by proceddemonstrated providinclude this aspect of inspect this aspect of date. At present all dmanually and not thr

WWIS-7: Procedures provide instructions for WCO review of 

Y 

CCP-TP-530, The WCO verifies: NA Table 1 of the proced

used for WWIS requ
A-3

ATTACHMENT A: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECK

EPA Inspection No.: Inspect

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

characterization and certification to WWIS 

R. 3, s 4.5 • TRU alpha activity is > 100 nCi/g for each 

payload container 

• Confirm WWIS Data Spreadsheet or CDS 

WCO Review Form is information accurate and complete 

• TRUCON Code (waste is not incompatible) 

• WSPF number 

• If methane concentration is “U” flagged, 

calculates concentration from hydrogen concentration 

• Calculates flammable analytes if sample was 

composited 

• IF the container is to be overpacked, at least 

1 TRU isotope >LLD 

• Site-specific identifier precedes container # 

• Assess GGT requirements 

procedurally required 

the summary spreadsspreadsheet for contaduring the on-line deCCP was unable to pspreadsheet as the decertification instance that the WCO signs tcontainer at a future 

WWIS-8: WMP weights for each SCG are entered into WWIS in accordance with the procedure. 

Y CCP-TP-530, R. 3, s 4.5.7– 4.5.12 

S5000 Wastes: If calculated CPR weight is = or < net weight of container, enter the net weight of the container as“plastic” If calculated CPR weight is = or > than net weight of container, enter maximum weight of CPR as “plastic” S4000 Wastes: If container does not contain any debris material, 

assign net weight of container as WMP “soil” If container does contain any debris material, enter estimated weight of debris as “plastic” and the remaining net weight as “soil” S3000 Wastes: If container does not contain any debris material, assign net weight of container as appropriate 

Y An S5000 debris dru

used for the on-line dspreadsheet and the Wshowed that the wast

been entered into the 

WWIS as plastic as iobserve any waste inS3000 containers. Objective evidence:

Waste Container Dat00789 Attachment1, CCP-TData Form for contaiWWIS Data Entry Sucontainer No. 00789 
A-4

ATTACHMENT A: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECK

EPA Inspection No.: Inspect

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

WMP, e.g., cement, solidified organic If container does contain any debris material, enter estimated weight of debris as “plastic” and the remaining net weight as appropriate WMP 

WWIS-9: Reviewed data are entered into WWIS 

Y CCP-TP-530, R. 1, s 4.5.18-4.5.21 

WCO signs and dates CDS or WWIS Data spreadsheet WCO or WCA submits data to WWIS (certification module if WSPF approved, characterization module if WSPF not approved) WWIS Administrator accepts/rejects data via email 

NA At the time of the on

entering RH data into demonstrated data fotest instance of the ce

Waste Stream Profile approved. Even if thcan be entered into thcharacterization moddemonstrate this. CCevidence of acceptan

because to date no R

the production instanObjective evidence oacceptance will be obinspection when CCP 

production instance o

WWIS-10: Resolution of data deficiencies 

Y CCP-TP-530, R. 3, s 4.5.20- 4.5.22

Hold 

NCR 

NA Procedure CCP-TP-5

resolution of data def

provide objective evi

time of the on-line dethis process at a futurobjective evidence thwith requirements. 

WWIS-11: Container selection for RH-TRU Waste canister/Load Management Containers using WWIS 

Y CCP-TP-530, R. 1, s 4.6 

After submission, the Waste Container Data Report is printed, signed and dated Copies of data, radiological survey, filter information, signed Waste Container Data Report, correspondence sent to CCP records custodian 

NA At this time RH load 

by WIPP. 

WWIS-12: Records retention Y 

CCP-TP-530, R. 1, s 5.0 

QA/Lifetime records: WWIS Data SS or CDS WCO Review Forms Waste Container Data Report WWIS Data Approval/Rejection Reports Correspondence 

Y EPA reviewed the da

Container Data Repothe time of the demodata manually and wfor uploading electro
A-5

ATTACHMENT A: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECK

EPA Inspection No.: Inspect

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

QA/Nonpermanent Records: CDS Database (electronic) 

EPA will obtain objeacceptance/rejection Objective evidence:

Waste Container DatWWIS Data Entry Sucontainer No. 00789 
B-1

ATTACHMENT B: WWIS DATA REQUIREMENTS 

Certification Module Data Fields, Selected Items 

The table below was completed from the objective evidence obtained during the on-line 

demonstration provided by CCP on November 21, 2006. CCP personnel used the test instance of 

the certification module for the demonstration. The spreadsheet used for data entry is titled INL 

RH Template.xls Ver.1 WWIS Data Entry Summary – Charz and Cert” and it contains all of the 

required fields for both the characterization and certification modules. All items marked Yes in 

the table below were provided as required. 

Specific Information – Was It Provided? Specific Information – Was It Provided? 

Container ID – Yes TRU Alpha Activity Concentration – Yes 

Generator EPA ID – Yes TRU Alpha Activity Concentration Uncertainty – Yes 

Site ID – Yes Pu-239 Equivalent Activity - Yes 

Waste Stream Profile Number – Yes Pu-239 Fissile Gram Equivalent – Yes 

Waste Matrix Code - Yes Pu-239 FGE Uncertainty – Yes 

Waste Type Code – Yes Radionuclide Name – Yes 

Waste Material Weight – Yes Radionuclide Activity - Yes 

Waste Material Parameter – Yes Radionuclide Activity Uncertainty – Yes 

Container Type – Yes Radionuclide Mass –Yes 

Container Weight – Yes Radionuclide Mass Uncertainty –Yes 

Layers of Packaging – Yes Alpha surface Concentration – Yes 

Liner Exists – Yes Beta/Gamma Surface concentration –Yes 

Liner Punctured – Yes Neutron Dose Rate – Yes 

Filter Model – Yes Beta/Gamma Dose Rate – Yes 

Number of Filters Installed – Yes Headspace Gas Results – Yes 

Decay Heat – Yes Prohibited Item Requirements Met – Yes 

Decay Heat Uncertainty – Yes Container Certification Date - Yes 

TRU Alpha Activity - Yes Container Closure Date - Yes 

TRU Alpha Activity Uncertainty - Yes 
ATTACHMENT C: Revised Tiering Table for INL-CCP RH 

C-1

Tiering of RH TRU WC Processes Implemented by INL-CCP 

 Revised January 17, 2007

RH WC Process Elements INL-CCP RH WC Process - T1 Changes INL-CCP RH W

Acceptable Knowledge (AK) Modification of the approved waste stream ID-ANLE-S5000 to 

include additional containers, i.e., K Cell or other debris wastes; AK (1) and AK (5) Any new waste streams not approved under this baseline; AK (1) and 

AK (7)

Substantive modification(s)*** that have the potential to affect the characterization process: CCP-AK-INL-500, CCP-AK-INL-501, or CCP-AK-INL-502; AK (6) and AK (7) Load management for any RH waste stream; AK (16) 

Notification to EPA whe

CCP-INL-AK-501, and 

by CBFO; AK (4) Notification to EPA whe

as a result of WCPIP revCRR); AK (7) and AK (

Notification to EPA whe

Summary Form is compcontainers in this waste upon measured dose rateassayed containers; AK 

Notification to EPA onc

debris waste stream, and including the CRR and AAK (14) 

Notification to EPA that 

complete for RH containidentified in AK Referenreports prepared annuall

Radiological Characterization, including Dose-to-Curie (DTC) 

Application of new scaling factors for isotopic determination other than those documented in CCP-AK-INL-501; RC (8.2.2 and 8.2.3) Use of any alternate radiological characterization procedure other than DTC with established scaling factors as documented in CCP-TP-504 

or substantive modification of the DTC procedure***; RC (8.2.2 and 8.2.3) Any new waste stream not approved under this baseline or addition of containers to Waste Stream ID-ANLE-S5000 that requires changing 

the established radionuclide scaling factors; RC (8.2.3)

Revisions of CCP-AK-INrequire CBFO approval; 

Visual Examination of audio/video media (VE) 

Implementation of VE following this baseline approval; if INL-CCP 

decides to use VE in the future, EPA approval is necessary 
ATTACHMENT C: Revised Tiering Table for INL-CCP RH 

C-2

Tiering of RH TRU WC Processes Implemented by INL-CCP 

 Revised January 17, 2007

RH WC Process Elements INL-CCP RH WC Process - T1 Changes INL-CCP RH W

Real-Time Radiography (RTR) Any use of RTR requires EPA approval WIPP Waste Information System (WWIS) None Changes made to WWIS 

approval 

* INL-CCP will report all T2 changes to EPA every three months. ** Excluding changes that are editorial in nature or are required to address administrative concerns.

*** Substantive modification refers to a change with the potential to affect INL-CCP’s RH WC process, e.g., the use of an inherently 

measurement instrument or the use of the high-range probe as described in CCP-TP-504. 
ATTACHMENT D Revised Tiering Table for ANL-CCP RH

D-1

Tiering of RH TRU WC Processes Implemented by ANL-CCP

Revised January 17, 2007 

RH WC Process Elements ANL-CCP RH WC Process - T1 Changes ANL-CCP RH W

Acceptable Knowledge (AK) Any new waste streams not approved under this baseline; AK (1) 

Modification of the approved waste stream AERHDM to include additional 

containers beyond the approximately 45 included in CCP-AK-ANLE-500, 

Revision 1. The 20 additional containers identified in the AK summary as 

being present are not included in this waste stream approval; AK (1) 

Substantive modification(s)*** that have the potential to affect the 

characterization process to CCP-AK-ANLE-500, CCP-AK-ANLE-501 or CCP-AK-ANLE-502; AK (8) Implementation of load management for any RH waste stream; AK (16) 

Notification to EPA that 

complete for RH containstream; AK (3) 

Notification to EPA whe

documentation as a resu

Notification that updates 

following documents: 

• All future revision

CCP-ANLE-AK-5

• Listing of the refer

assembly of fuel pAK (5) 

• All future revision

AK (8) 

• CCP-AK-ANLE-5

address freeze file 

Notification to EPA that 

waste stream is completeto the WSPF including tAK (9), and AK (14) 

Notification to EPA whe

completed, prepared ann

Radiological Characterization, including Dose-To-Curie (DTC) 

Use of any alternate radiological characterization procedure other than DTC with established scaling factors as documented in CCP-TP-504 and 

CCP-AK-ANLE-501, Revision 0, respectively, or substantive modification thereof***; RC (8.2.2 and 8.2.3) Any new waste stream not approved under this baseline or addition of 

containers to waste stream AERHDM that require changing the established radionuclide scaling factors; RC (8.2.3) 

Notification to EPA that 

501 or CCP-TP-504 that complete; RC (8.2.2 and 
ATTACHMENT D Revised Tiering Table for ANL-CCP RH

D-2

Tiering of RH TRU WC Processes Implemented by ANL-CCP

Revised January 17, 2007 

RH WC Process Elements ANL-CCP RH WC Process - T1 Changes ANL-CCP RH W

Application of new scaling factors for isotopic determination other than those documented in CCP-AK-ANLE-501; RC (8.2.2 and 8.2.3) 

Visual Examination (VE) VE by reviewing existing audio/visual recordings for Summary waste 

category not covered by this approval; VE (1) & VE (3) VE by any new process for S5000 debris wastes; VE (1) and VE (3) 

Notification to EPA that 

that require CBFO approVE (3) Addition of new S5000 

Real Time Radiography (RTR) Any use of RTR requires EPA approval WIPP Waste Information System (WWIS) 

None Changes made to WWIS 

approval 

* ANL-CCP will report all T2 changes to EPA every three months. ** Excluding changes that are editorial in nature or are required to address administrative concerns. New references that are includ

revision may be requested by EPA. 

*** Substantive modification refers to a change with the potential to affect ANL’s RH WC process, e.g., the use of an inherently diff

instrument or the use of the high range probe as described for CCP-TP-504 for radiological characterization.