EPA DOCKET NO. A-98-49, II-A4-142 

 

WASTE CHARACTERIZATION INSPECTION 

CONTINUED COMPLIANCE REPORT 

EPA INSPECTION OF THE CENTRAL CHARACTERIZATION PROJECT 

WASTE CHARACTERIZATION PROGRAM 

AT THE IDAHO NATIONAL LABORATORY 

 

November 16-17, 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 

February 2011 
i 

TABLE OF CONTENTS 

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

2.0 Purpose of Continued Compliance Inspections .................................................................. 1

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

4.0 Scope of This Continued Compliance Inspection ............................................................... 2

5.0 Personnel ............................................................................................................................. 3

5.1 EPA Inspection Team ............................................................................................. 3

5.2 Personnel Contacted................................................................................................ 4

6.0 Technical Evaluation of the Waste Characterization Areas ............................................... 5

6.1 Acceptable Knowledge ........................................................................................... 5

6.1.1 Contact-Handled Waste Streams ................................................................ 5

6.1.2 Remote-Handled Waste Streams .............................................................. 29

6.1.3 Summary of Acceptable Knowledge Results ........................................... 39

6.2 Nondestructive Assay ........................................................................................... 39

6.2.1 Technical Evaluation: Waste Assay Gamma Spectrometer...................... 40

6.2.2 Technical Evaluation: Super High Efficiency Neutron Counter .............. 43

6.2.3 Summary of Nondestructive Assay Results .............................................. 45

6.3 Real-Time Radiography ........................................................................................ 46

6.4 Visual Examination ............................................................................................... 47

7.0 Summary of Results and Conclusions .............................................................................. 48

7.1 Findings and Concerns .......................................................................................... 48

7.2 Tiering Changes .................................................................................................... 48

7.3 Conclusions ........................................................................................................... 49

LIST OF TABLES 

Table 1. EPA Inspection Team Members ....................................................................................... 3

Table 2. Personnel Contacted During Inspection ........................................................................... 4

Table 3. Contact-Handled Batch Data Reports Examined .............................................................. 7

Table 4. Original Lawrence Berkeley National Laboratory Drum Numbers ............................... 20

Table 5. Summary of Accelerated Retrieval Project Drum Traceability Analysis ....................... 20

Table 6. Remote-Handled Batch Data Reports Examined ............................................................ 30

Table 7. Summary of Compliance with Tiering Requirements .................................................... 36
ii 

ATTACHMENTS 

Attachment A Real-Time Radiography Concern No. INL-CCP-CH-RTR-10-01CR 

Attachment B.1 Replicate Testing Data for Drum ARP21969 -WAGS 

Attachment B.2 Replicate Testing Data for Drum ARP22225 - WAGS 

Attachment B.3 Replicate Testing Data for Drum BN10381564 - SuperHENC 

Attachment C.1 Acceptable Knowledge References – Contact-Handled Waste 

Attachment C.2 Acceptable Knowledge References – Remote-Handled Waste 

Attachment C.3 Nondestructive Assay References – Contact-Handled Waste 
iii 

ACRONYMS AND ABBREVIATIONS 

AEC Atomic Energy Commission 

AK Acceptable Knowledge 

AKE Acceptable Knowledge Expert 

AKSR Acceptable Knowledge Summary Report 

Am americium 

AMWTP Advanced Mixed Waste Treatment Project 

ANL-E Argonne National Laboratory-East 

ARP Accelerated Retrieval Project 

ASTM American Society for Testing and Materials 

Ba barium 

BDR batch data report 

CBFO Carlsbad Field Office 

CCP Central Characterization Project 

Cf californium 

CH contact-handled 

CIS characterization information summary 

cps counts per second 

CRR Characterization Reconciliation Report 

Cs cesium 

CWI CH2M-WG Idaho, LLC 

DOE U.S. Department of Energy 

DPS Drum Packaging Stations 

DQO data quality objective 

DR discrepancy resolution 

DU depleted uranium 

EA Expert Analyst 

EPA U. S. Environmental Protection Agency 

FQAO Facility Quality Assurance Officers 

FR Federal Register 

FRAM Fixed-energy Response Function Analysis with Multiple Efficiencies 

FWHM Full Width at Half Maximum 
iv 

g/cm3 grams per cubic centimeter 

GEM Glovebox Excavator Method 

HENC High Efficiency Neutron Counter 

HERL Heavy Elements Research Laboratory 

HEU highly enriched uranium 

HFEF Hot Fuel Examination Facility 

INL Idaho National Laboratory 

INTEC Idaho Nuclear Technology and Engineering Center 

IQT Image Quality Test 

ITR Independent Technical Review 

keV kilo electron volt 

LBNL Lawrence Berkeley National Laboratory 

LLD Lower Limit of Detection 

LO Lead Operator 

LOQI List of Qualified Individuals 

LLNL Lawrence Livermore National Laboratory 

LWA Land Withdrawal Act 

MCS Mobile Characterization Services 

MFP Mixed Fission Products 

MGA multi-group analysis 

mrem/hr millirem per hour 

nCi/g nanocuries per gram 

NCR Nonconformance Report 

NDA Nondestructive Assay 

NDE Nondestructive Evaluation 

NNSS Nevada National Security Site 

Np neptunium 

NRF Naval Reactors Facility 

NTS Nevada Test Site 

NU natural uranium 

NWPA Nuclear Waste Policy Act of 1982 

OJT on the job training 

OM Operations Manager 
v 

ORIA Office of Radiation and Indoor Air 

PCB polychlorinated biphenyl 

PDP Performance Demonstration Program 

PM Project Manager 

PPE personal protective equipment 

PTS Project Tracking System 

Pu plutonium 

QAPD Quality Assurance Program Document 

QC quality control 

R&D Research and Development 

RDS Radioassay Data Sheet 

RFETS Rocky Flats Environmental Technology Site 

RFP Rocky Flats Plant 

RH remote-handled 

RTR Real-Time Radiography 

RWMC Radioactive Waste Management Complex 

SCG Summary Category Group 

SDA Subsurface Disposal Area 

SHENC Super High Efficiency Neutron Counter 

SPC sludge pan container 

SPM Site Project Manager 

 SQS Small Quantity Site 

Sr strontium 

SHENC Super High Efficiency Neutron Counter 

SWB standard waste box 

SWEPP Stored Waste Examination Pilot Plant 

T1 Tier 1 

T2 Tier 2 

TMU total measurement uncertainty 

TRA Test Reactor Area 

TTR Tonopah Test Range 

TTR-HET Tonopah Test Range- Heterogeneous 

TRU transuranic 
vi 

U uranium 

VE Visual Examination 

VEE Visual Examination Expert 

VERB Visual Examination and Repackaging Building 

VET Visual Examination Technique 

VPM Vendor Project Manager 

WAGS Waste Assay Gamma Spectrometer 

WC Waste Characterization 

WCPIP Waste Characterization Program Implementation Plan 

WDS Waste Data System 

WG weapons-grade 

WIPP Waste Isolation Pilot Plant 

WMC Waste Matrix Code 

WMP Waste Material Parameter 

WSPF Waste Stream Profile Form 

WTS Washington TRU Solutions
1 

1.0 EXECUTIVE SUMMARY 

In accordance with 40 CFR 194.24(h), the U.S. Environmental Protection Agency (EPA) 

conducted a continued compliance inspection of the Central Characterization Project (CCP) 

waste characterization program for contact-handled (CH) and remote-handled (RH) transuranic 

(TRU) wastes at the U.S. Department of Energy (DOE) Idaho National Laboratory (INL) in 

Idaho Falls, Idaho. This inspection occurred on November 16-17, 2010. In accordance with the 

provisions of 40 CFR 194.24(h), as issued in a July 16, 2004, Federal Register (FR) notice 

(69 FR 42571–42583), EPA conducted a continued compliance inspection of the site’s program 

to characterize TRU wastes proposed for disposal at the Waste Isolation Pilot Plant (WIPP). As a 

result of this continued compliance inspection, EPA confirmed that the INL-CCP TRU waste 

characterization program continues to characterize CH and RH TRU waste consistent with the 

conditions and limitations that are discussed in the baseline inspection reports (see EPA Docket 

Nos. A-98-49; II-A4-59 and A-98-49; II-A4-72). During this inspection, EPA evaluated samples 

of the following waste characterization activities:

 

• Acceptable knowledge (AK) for CH and RH waste streams 

• Two nondestructive assay (NDA) systems operated by INL-CCP for characterizing CH 

TRU wastes: the Waste Assay Gamma Spectrometer (WAGS) and the Super High 

Efficiency Neutron Counter (SuperHENC) 

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

• Visual Examination (VE) for newly generated CH and RH TRU waste 

EPA maintains its approval of the INL-CCP CH and RH TRU waste characterization programs 

in the configuration observed during this inspection consistent with the limitations described in 

the baseline inspection reports cited above and other subsequent EPA Tier 1 (T1) approvals. The 

T1 and Tier 2 (T2) designations from the baseline inspection and other subsequent EPA T1 

approvals remain applicable and no T1 or T2 tiering changes resulted from this continued 

compliance inspection. 

This report serves as EPA’s public notification of the results of the continued compliance 

inspection. This information will be provided through the EPA website and by sending emails to 

the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3). 

2.0 PURPOSE OF CONTINUED COMPLIANCE INSPECTIONS 

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, FR notice, EPA must 

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

program (Vol. 69, No. 136, pages 42571–42583, July 16, 2004). The purpose of EPA’s 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 comply with the regulatory requirements imposed on TRU wastes 

destined for disposal at the WIPP. 
2 

Following EPA’s baseline approval, EPA has the authority to conduct continued compliance 

inspections to verify that the site continues to use only the approved waste characterization 

processes to characterize the waste and remains in compliance with all the regulatory 

requirements. EPA is also authorized to evaluate and approve changes, if necessary, to the site’s 

approved waste characterization program by conducting additional inspections under the 

authority of 40 CFR 194.24(h). 

3.0 PURPOSE OF THIS REPORT 

This report documents the basis for EPA’s decision to maintain the approval of the INL-CCP 

waste characterization program for CH and RH TRU wastes. Specifically, this report does the 

following: 

• Describes the sample of the INL-CCP waste characterization systems evaluated during 

this inspection 

• Identifies all areas where waste characterization systems have changed relative to what 

was approved during the baseline inspection and other subsequent EPA T1 evaluations, 

and assesses the impact, if any, of those changes 

• Provides objective evidence to support the EPA continued approval basis for all waste 

characterization systems 

• Describes any tests or demonstrations completed during the course of the inspection and 

their relevance to EPA’s approval decision. 

The DOE documents that EPA reviewed for this evaluation are cited in different sections 

throughout the report and are listed in Attachments C.1 through C.3. Any of these documents can 

be requested from the following address: 

Carlsbad Field Office 

Manager, National TRU Program 

P.O. Box 3090 

Carlsbad, NM 88221-3090 

4.0 SCOPE OF THIS CONTINUED COMPLIANCE INSPECTION 

The scope of this continued compliance inspection included the evaluation of selected elements 

of the waste characterization systems in use at INL-CCP to characterize CH and RH TRU wastes 

that were approved during the baseline inspection and subsequent T1 evaluations. The EPA 

inspection team evaluated aspects of these systems with respect to their ability to continue to 

perform the following functions: 

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

(

241Am), cesium-137 (137Cs), plutonium-238 (238Pu), 239Pu, 240Pu, 242Pu, strontium-90 

(

90Sr), uranium-233 (233U), 234U, and 238U] using a combination of AK and NDA systems 
3 

• Assign waste material parameters (WMPs) correctly using RTR and VE for CH and RH 

retrievably stored and newly generated wastes, respectively 

Specifically, these consisted of the following components: 

• AK processes that support CH and RH wastes 

• Two NDA systems, the WAGS and SuperHENC systems 

• RTR for retrievably stored CH wastes 

• VE for newly generated CH and RH wastes 

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 waste characterization processes. Objective evidence 

typically takes the form of batch data reports (BDRs), radioassay data sheets, AK accuracy 

reports and RTR tapes. 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 samples of objective evidence, EPA 

determined the technical adequacy of the waste characterization processes within the 

inspection’s scope. 

5.0 PERSONNEL 

5.1 EPA Inspection Team 

Table 1 identifies the members of the EPA waste characterization inspection team. 

Table 1. EPA Inspection Team Members 

Inspection Team Member Position Affiliation

Ed Feltcorn Inspector-Team Leader U.S. EPA ORIAa

Rajani Joglekar Inspector U.S. EPA ORIA 

Lindsey Bender Inspector U.S. EPA ORIA 

Cathy Economy Observer U.S. EPA ORIA 

Patrick Kelly NDA Inspector SC&A, Inc. 

Dorothy Gill RTR Inspector SC&A, Inc. 

Connie Walker AK Inspector SC&A, Inc. 

Kira Darlow AK Inspector SC&A, Inc. 

Rose Gogliotti NDA Observer SC&A, Inc. 

a

 Office of Radiation and Indoor Air 

 
4 

5.2 Personnel Contacted 

EPA and its support personnel conducted interviews with INL-CCP waste characterization 

personnel in several disciplines. The personnel contacted represented a sample of the CH and RH 

TRU waste characterization staff, and they are listed inError! Reference source not found., 

with their affiliations and areas of expertise or function. 

Table 2. Personnel Contacted During Inspection 

Personnel Affiliation Area of Expertise/Function 

Scott Smith TechSpecs/INL-CCP AKE 

Lisa Frost CWI ICP 

Tom Johnson CWI STR 

Stephanie McElhaney Pajarito SHENC-EA 

Courtland Fesmire CBFO Observer 

Michael Walentine WTS/CCP Project Office PM 

Thomas L. Clements, Jr. CWI ICP 

Irene Quintana WTS/CCP RH PM 

Ted Carlson WTS/INL-CCP VPM 

Greg Smith WTS/INL-CCP VPM 

Tyson Christenson VJ Technologies RTR 

Rick Green Pajarito SHENC 

Howard Budweg CBFO Observer 

Jeffrey Poole WTS/INL-CCP VEE 

Preston Abbott MCS NDA, EA 

Bart Morales MCS NDA-EA 

Bill Verlanic WTS/INL-CCP Site PM 

Bryce Woodbury MCS NDA-EA 

Mark Pearcy WTS/CCP Project Office Certification Manager 

Corey Boland MCS NDA-LO 

Sharon Cummins Pajarito NDA—SuperHENC, Operator

Shane Boudreau Pajarito NDA—SuperHENC, EA

James Rowsell MCS NDA—WAGS, Operator

John Braiser MCS NDA—WAGS, EA

Jerry Bowden VJ Technologies RTR Operator, ITR 

Brett Gyorfy Stoller RTR Operator, ITR 

Vince Medina WTS/INL-CCP SPM 
5 

6.0 TECHNICAL EVALUATION OF THE WASTE CHARACTERIZATION AREAS 

Sections 6.1 through 6.4 of this report detail the four technical areas assessed during this 

inspection: acceptable knowledge (AK); nondestructive assay (NDA); and nondestructive 

examination (NDE), consisting of real-time radiography (RTR) and visual examination (VE). 

6.1 Acceptable Knowledge 

6.1.1 Contact-Handled Waste Streams 

Background Information

EPA examined the AK process and associated information to determine whether INL-CCP 

remained in compliance with 40 CFR 194.8 requirements for CH waste streams. The continued 

compliance inspection scope included all of the Small Quantity Site (SQS) and three Accelerated 

Retrieval Project (ARP) waste streams. Specifically, EPA reviewed the following CH waste 

streams: 

• ID-NTLBL-S3900 

• ID-NTLBL-S5400 

• ID-NTS-TTR-HET 

• ID-SDA-DEBRIS 

• ID-SDA-SLUDGE 

• ID-SDA-SOIL 

Small Quantity Site Waste Streams 

EPA approved the INL-CCP CH baseline program in October 2005 for S3000, S4000, and 

S5000 waste. In 2008, INL-CCP began accepting waste from offsite SQS generators for 

characterization and subsequent shipment to WIPP. Several sites have shipped waste to INL for 

characterization as SQSs— Nevada National Security Site1

 (NNSS) was a main storage area for 

waste from several SQSs including Lawrence Livermore National Laboratory (LLNL), 

Lawrence Berkeley National Laboratory (LBNL), Lynchburg, Industrial Technology Research 

Institute, Rocky Flats Environmental Technology Site (RFETS),2

 the Tonopah Test Range (TTR) 

and related test facilities at or near NNSS. NNSS itself also generated waste [e.g., waste created 

during repackaging at the NNSS Visual Examination and Repackaging Building (VERB) 

facility]. INL-CCP accepts waste directly from Small Quantity Sites (SQS) including LLNL, 

LBNL, and General Electric Vallecitos. EPA examined the SQS characterization process with an 

emphasis on AK data assembly, use, and interpretation to assess whether these wastes have been 

appropriately characterized under INL-CCP’s approved program. 

Accelerated Retrieval Project Waste Streams 

 

1

 The Nevada National Security Site was formerly named the Nevada Test Site. 

2

 The Rocky Flats Environmental Technology Site was formerly known as the Rocky Flats Plant (RFP). 
6 

Over the years, INL received TRU waste from several onsite and offsite DOE locations [e.g., 

Argonne National Laboratory West, and Rocky Flats Plant (RFP)], as well as other generators 

(e.g., Colorado School of Mines, and the United States Geologic Survey). These wastes were 

placed in the subsurface disposal area (SDA). The SDA at INL consists of 58 trenches, 20 pits, 

21 rows of soil vaults, Pad A, and the Acid Pit, where historic waste disposal activities occurred. 

Waste in certain areas of the SDA has been targeted for removal under the ARP, and the areas 

containing the targeted waste are collectively identified as the “retrieval area.” The waste 

removal, drumming, and characterization for WIPP disposal are occurring in a phased manner 

[Phases I (ARP-I) through V (ARP-V)]. The retrieved ARP wastes are divided into three waste 

streams during VE: ID-SDA-DEBRIS, ID-SDA-SLUDGE, and ID-SDA-SOIL. EPA has 

approved these INL-CCP Summary Category Groups (SCGs) for WIPP disposal. 

During this continued compliance inspection, EPA primarily evaluated Revision 9 of the AK 

Summary Report (AKSR), but also included specific sections of Revisions 7 and 8 of the AKSR 

to confirm that INL-CCP continues to comply with the EPA-approved AK processes when 

integrating additional ARP phases into the AK record. 

EPA conducted a continued compliance inspection at INL-CCP during September 2008, and 

later in October-December 2008. EPA’s report, dated March 2009, identified as a T1 change the 

following (see EPA Docket No. A-98-49): “Changes to the targeted waste(s) from what was 

presented in Revision 6 of the AK Summary CCP-AK-INL-001.” CCP-AK-INL-001, 

Revision 7, approved by CBFO on October 27, 2008, revised the targeted waste to incorporate 

the previously non-targeted RFP 742-sludge. This approval occurred while EPA’s continued 

compliance report was in preparation, and was implemented before EPA’s T1 requirement was 

documented. EPA elected to postpone review of the inclusion of 742-sludge until the next 

continued compliance inspection. The analysis is presented in Item (1) below. 

Waste Characterization Element Description

As part of the inspection, EPA reviewed the elements of the AK process listed below: 

• Waste stream definition 

• AK information pertaining to the radiological characteristics of TRU wastes 

• Identification of wastes’ physical form, including waste material parameters (WMPs) and 

prohibited items 

• AK procedural adequacy and implementation, i.e., assembly compilation, interpretation, 

confirmation, and discrepancy resolution 

• Adequacy of the AKSR 

• Drum traceability and the ability to follow the AK waste characterization process 

• Defense origin of TRU wastes 

• Spent Nuclear Fuel (SNF) and High Level Waste (HLW) status relative to the Land 

Withdrawal Act (LWA) 
7 

• Waste Stream Profile Form (WSPF) preparation and completeness 

• Preparation of nonconformance reports (NCRs) 

• AK accuracy 

• Implementation of load management 

• NDA-AK communication. 

Documents, Waste Containers, and Batch Data Reports Reviewed

As part of this continued compliance inspection attachments, source documents, required forms, 

and other data were provided to EPA and were examined, as appropriate. All CH AK 

documentation referenced is listed in Attachment C.1. Some of these documents were provided 

in advance of the inspection, however most were provided to EPA upon arrival at INL-CCP. The 

list of VE and NDA BDRs examined for this evaluation is presented in Table 3. 

Table 3. Contact-Handled Batch Data Reports Examined 

Waste Stream Drum Number NDE BDR Number NDA BDR Number 

ID-NTLBL-S3900 NT080018R INRTRS090049 INNDAS090184 

ID-NTLBL-S5400 NT041489A INRTRS090058 INNDAS09218 

ID-NTS-TTR-HET TTR-21A INRTR5090059 NNDAW090179 

ID-SDA-DEBRIS ARP06227 INARPVE000740 INNDAH080058, INNDAW090184 

ID-SDA-SLUDGE ARP15566 INARPVE001510 INNDAS090352 

ID-SDA-SOIL ARP20413 INARPVE001936 INNDAS100048 

Technical Evaluation

EPA examined three SQS waste streams and three ARP waste streams. Adequacy of 

documentation and identification of the waste streams are addressed below. Throughout the 

review, the three ARP waste streams may be evaluated as one because they are differentiated 

only by their physical characteristics. 

(1) The definition of waste stream was evaluated and found to be adequate. 

Contact-Handled Wastes Streams from Small Quantity Sites: 

As part of this inspection, EPA evaluated three SQS waste streams. These waste streams have 

been characterized and disposed at WIPP and INL-CCP informed EPA of the availability of 

WSPFs as T2 changes in the Q1 2010 Tier Report. EPA reviewed the information provided and 

included the three SQS waste streams listed below in this inspection. 

 

ID-NTLBL-S5400 debris from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) 

The waste stream originated from research and development (R&D) and maintenance activities 

at LBNL. Source documents (References U001, U015, U029, U052, U072, U074, U084, and 

U103) suggest that drums from the waste stream had original closure dates from 1975–1980 and 
8 

were shipped to NNSS between May 1975 and December 1984. The waste stream originally 

consisted of 12 drums, seven of which were overpacked into 85-gallon drums and directly 

shipped to WIPP from NNSS. NNSS repacked the remaining five drums, resulting in one 55-

gallon S5400 drum, one S5400 standard waste box (SWB), and one 55-gallon S3900 drum 

(discussed below as a separate waste stream) (References DR002, P025, U015, U072, U074, 

U084, and U103). 

The AKSR and related source documents indicate that the waste stream was generated primarily 

as part of ongoing actinide chemistry research in the Heavy Elements Research Laboratory 

(HERL) in Building 70A and its predecessor in Building 70 (P098). Source documents (e.g., 

C101) suggest the waste in this waste stream originated from the Pitroom (Building 70). The 

AKSR states that the following divisions were operating during the time of waste generation: 

• Chemistry Division, 1961 through 1963 

• Nuclear Chemistry Division, 1964 through 1974 (P098) 

• Materials and Molecular Research Division, 1975 through 1986 (Reference P098) 

The AKSR implies that wastes generated between 1976 and 1996 from the Nuclear Science 

Division may be present based on the dates of activities. The AKSR also suggests that waste 

generated from 1977 and 1995 by the Earth Sciences Division to support the development of 

nuclear waste repositories, specifically WIPP and Yucca Mountain could also be present in the 

waste (Reference P098). 

INL-CCP stated that any activities performed prior to 1975 may have contributed to this waste 

stream, as 1975 was the date of the first drum closure, not the date of first generation of this 

waste. No waste generated after 1980 would be in the waste stream. INL-CCP indicates that 

waste cannot be differentiated by generator location because wastes were comingled at a single 

collection point. Based on the process description and general information provided by INLCCP, the waste stream is appropriately defined. Physical and radiological characteristics of the 

waste stream are described in Items (2) and (3) below. 

ID-NTLBL-S3900 solid waste from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) 

Waste Stream ID-NTLBL-S3900 originated from R&D and maintenance activities performed at 

LBNL (References U001, U015, U029, U072, and U103). The waste stream is mixed 

homogeneous solids originally generated from 1977 to 1980, which are the closure dates of the 

original NTLBL drums containing solid waste. The waste stream consists primarily of absorbed 

and solidified aqueous liquids. The materials used to absorb/solidify liquids include Aquaset, 

diatomaceous earth, Portland cement, and vermiculite. This waste has the same process origin as 

ID-NTLBL-S5400, but was generated when the original four drums were repackaged and S3900 

waste was segregated into a separate one-drum waste stream. Waste Stream ID-NTLBL-S3900 

consists of a single drum and no additional containers of this waste stream will be generated in 

the future. Based on this information, the waste stream is adequately defined; see Items (2) and 

(3) below for additional information. 
9 

ID-NTS-TTR-HET debris from the Tonopah Test Range/Roller Coaster Project stored at 

Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0) 

The Roller Coaster Project involved storage transportation tests conducted at the Double Tracks 

located at the Nellis Air Force Range and the Clean Slate 1, 2, and 3 sites located on the TTR. 

Conventional explosives were used to detonate nuclear materials and study their distribution. 

These two areas were contaminated with Pu and U and were remediated in 1994–2000, resulting 

in the collection of metal fragments and other debris such as personal protective equipment 

(PPE) (References C1002, C1003, P1017, P1013, and P1025). Two 30-gallon drums of TRU 

debris waste were generated and these were shipped to NNSS for storage at the TRU Pad Cover 

Building in December 1999. Approximately 3,550 grams of hot fragments were collected and are 

in the debris waste, with a measured 241Am activity in excess of 100 nanocuries per gram (nCi/g) 

(References C1002, M1005, P1012, P1013, P1014, P1024, P1025, P1033, P1036, P1099, and 

P1107). The TTR-HET drums were repackaged into a single 55-gallon drum at the VERB in 

2006 (References C1014 and P1016). Based on this information, while the wastes were obtained 

from two separate areas, the processes associated with their creation are similar and their 

commingling during repackaging makes it impossible to distinguish them by production areas. 

The waste stream is adequately defined, see Items (2) and (3) below for additional information. 

In addition to the three SQS waste streams, ARP waste streams were evaluated, as described 

below. 

Contact-Handled Waste Streams from the Accelerated Retrieval Project 

(AKSR CCP-AK-INL-001, Revision 9) 

The targeted waste in all five ARP phases (ARP-I – ARP-V) consists of RFP First-Stage Sludge 

(741-Series), RFP Second-Stage Sludge (742-Series), RFP Organic Setups (743-Series), RFP 

Roaster Oxide, RFP Graphite, and RFP Filters. The pits contained within ARP-III, -IV, and -V 

received waste from RFP during the same time period as the previously approved waste (May 

1964 – September 1968, compared to January 1963 – September 1968), indicating that the 

wastes have the same origin (References ID-P092, ID-U343, ID-U344, ID-U345, INTEC-P002, 

RF-U1306, RF-U1307, and RF-U1308). Waste Stream ID-SDA-DEBRIS is defined as a separate 

waste stream because it contains more than 50% debris. Waste Stream ID-SDA-SLUDGE is 

defined as a separate waste stream from the rest of the ARP waste because it contains more than 

50% sludge. Waste Stream ID-SDA-SOIL is defined as a separate waste stream because it 

contains more than 50% interstitial soil from the retrieval area. Based on this information, the 

waste streams are adequately defined; see Items (2) and (3) below for additional information. 

Evaluation of the Inclusion of Rocky Flats Plant Second-Stage Sludge (742-Series) as 

Targeted Waste from the Accelerated Retrieval Project 

The 741- and 742-series sludges were generated in RFP Building 774, which treated aqueous 

solutions contaminated with highly enriched uranium (HEU), depleted uranium (DU) and Pu 

containing trace amounts of 241Am, neptunium-237 (237Np,) 233U, and curium-244 (244Cm). The 

treatment activities performed in Building 774 used a two-stage precipitation process. The first 

stage contained the bulk of the radioactive constituents and was designated as 741-series sludge. 
10 

The first-stage effluent was collected as feed for the second-stage precipitation process; sludge 

collected from second-stage precipitation was designated a 742-series sludge (second-stage 

sludge) (Reference P562). RFP 741-series inorganic sludges were included in the original 

targeted waste population, but the 742-series sludges were not because targeted wastes were 

limited to those expected to contain a significant portion of the constituents of concern, 

specifically volatile organic compounds, U, and TRU radionuclides, including Pu. INL-CCP 

later determined that the 741- and 742-series sludges are generally physically indistinguishable; 

therefore, INL-CCP decided to include the 742-series sludge in the targeted population because it 

was typically comingled with the excavated targeted waste (References P216, P239). 

EPA examined references to determine the radiological differences between the two sludges. The 

data provided indicates that the 741-series sludge is expected to include the bulk of the actinides 

present in the waste stream, primarily 239Pu, 241Am, and 240Pu by mass, while the 742-series 

sludge is expected to contain far less Pu and other actinides, and more U (References P256, 

U115). 741-series sludge also contains over 63% of the TRU activity, while 742-series sludge 

contains less than 0.2% of the TRU activity (Reference P103). The treatment process may 

preferentially concentrate more soluble radionuclides in the 742-series sludge than in the 741-

series sludge. 

INL-CCP included radiological data for all wastes in the overall radiological envelope expected 

for the SDA waste streams, including non-targeted materials, as discussed in Section 5.5 of the 

AKSR and presented in Table 5-4. INL-CCP also adjusted the AK-NDA memorandum (included 

in Attachment 7 of CCP-TP-005) between Revisions 6 and 9 of the AKSR to include new ARP 

phases; APR-III and -IV include more 742-series sludge by volume and the isotopic data 

presented in the AK-NDA memorandum should reflect this change. Changes to the estimated 

radionuclide mass and activity percents for the waste stream as a whole due to addition of ARPIII and -IV were relatively small. The eventual addition of ARP-V waste to the AK-NDA 

memorandum should not impact the estimated values greatly, due to the relatively low volumes 

of 741- and 742-series sludge expected in ARP-V. EPA also notes that 742-series sludge was 

generated from the same general process as the 741-series sludge, and agrees that while the 

radiological composition of the 742-series sludge is different, the overall composition fits the 

anticipated ARP radiological composition (AKSR Table 5-4), which was developed to include 

all targeted and non-targeted wastes. EPA agrees that the 742-series sludge was included in the 

waste stream because it was indistinguishable from 741-series sludge, and believes this may 

account for the large number of INL-CCP Nonconformance Reports (NCRs) issued due to drums 

exhibiting TRU activity <100 nCi/g. EPA concludes that the 742-series sludge fits the previously 

defined radiological envelope of the ARP wastes, and has been accounted for in recent AK-NDA 

memoranda with the inclusion of ARP-III and ARP-IV waste. 

Modification of the targeted waste population remains a T1 change. 

(2) Acceptable Knowledge information pertaining to the radiological characteristics of 

transuranic wastes was examined and found to be adequate. 

Radiological characteristics of each waste stream were evaluated as described below. 
11 

Contact-Handled Waste Streams from Small Quantity Sites 

ID- NTLBL-S5400 debris from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) 

Experiments and activities conducted at LBNL resulted in wastes containing a wide variety of 

radionuclides. LBNL was not a production facility, so constant isotopic ratios for Pu are not 

expected (References C101, P025, P094, U001, U003, U029, U061, U067, and U085). 

Radionuclides that may be present include the following: 

•

241Am, 243Am 

• Berkelium-249 

• Californium-249, 252 

•

242Cm, 244Cm 

•

237Np 

• Protactinium-231 

•

238Pu, 239Pu, 240Pu, 241Pu, 242Pu 

• Radium-226 

• Thorium-228 

• Mixed fission products, assumed to include 137Cs and 90Sr 

Based on NNSS NDA measurements of the two containers in the waste stream, the predominant 

radionuclides by weight percent are 237Np at 56.61% and 241Am at 18.54%. Greater than 95% of 

the total activity is 241Am and 241Pu. Previous assay data from NNSS show that 234U and 238U are 

not expected (References C142 and U103). This information does not coincide with INL-CCP 

NDA data, which indicates that 239Pu and 241Am are the predominant radionuclides by weight, 

and INL-CCP submitted a freeze file3 change to the AKSR to address this discrepancy. The 

NDA memorandum for this waste stream states that several Pu grades were commonly used at 

LBNL; grades are defined by their percentage composition of 240Pu and 241Am (except for heatgrade Pu). The NDA memorandum provided default isotopic distributions for weapons-grade 

(WG), fuel-grade, reactor-grade, mixed-grade, and americium-enriched plutonium, enriched 

uranium and DU. The NDA memorandum states that if isotopic analysis results are not 

acceptable or available, default isotopics as defined in AK are used. In the case of drum No. 

NT041489A, which was examined as part of this continued compliance inspection, the NDA 

analyses used AK-based default isotopics as defined in the AK-NDA memorandum. See Item 

(11) below for additional information pertaining to AK accuracy and Item (14) below for 

additional information pertaining to AK-NDA communication. Based on data reviewed and INLCCP assay information, the radiological composition of the waste stream is adequately defined. 

ID-NTLBL-S3900 solid waste from Lawrence Berkeley National Laboratory and stored at 

Nevada National Security Site (AKSR CCP-AK-INL-010, Revision 0) 

 

3

As a result of an inspection-related EPA issue, INL-CCP may have to revise a document. INL-CCP makes the 

change(s) and provides the revised document to EPA as a freeze file to serve as objective evidence for the 

inspection. INL-CCP’s document control process then generates an official version of the revised document.
12 

Waste Stream ID-NTLBL-S3900 consists of mixed homogeneous solids generated at LBNL as 

part of R&D and maintenance activities and is composed primarily of absorbed and solidified 

aqueous and organic liquid. Aquaset, diatomaceous earth, Portland cement, and vermiculite were 

used to absorb/solidify liquids. The radionuclide composition of the waste stream was based on 

NDA measurements performed at the NNSS indicating that the predominant radionuclides for 

this waste stream by weight are 239Pu (90%) and 240Pu (6.15%), and that over 95% of the total 

activity is 239Pu, 240Pu, and 241Pu. The NDA memorandum indicates that default isotopics will be 

used in the event that measured values are unacceptable. In the case of the single drum in the 

waste stream, measured isotopics were acceptable. Based on data reviewed and INL-CCP assay 

information, the radiological composition of the waste stream is adequately defined. 

ID-NTS-TTR-HET debris from the Tonopah Test Range/Roller Coaster Project stored at 

Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0) 

Waste Stream ID-NTS-TTR-HET was generated from the remedial investigations and the 

cleanup of Double Tracks and Clean Slate sites. At these sites, high explosives were detonated 

near nuclear weapon assemblies to determine contamination dispersion. The assemblies were 

composed of 238Pu, 239Pu, 240Pu, 241Pu, and DU, and debris associated with the waste contain 

these radionuclides and 241Am, a decay product of 241Pu (References C1002, P1012, P1013, 

P1014, P1017, P1018, P1023, P1032, P1033, P1096, P1107, and P1099). Container TTR-21A 

was radioassayed at NNSS in 2006 and was determined to be TRU, i.e., >100 nCi/g TRU alpha 

activity. Based on the results of this assay, the two predominant radionuclides expected by 

weight percent based on AK are 238U and 239Pu, while 241Pu, 239Pu, and 240Pu comprise over 95% 

of the total activity. This information does not coincide with INL-CCP NDA data which 

indicates that 239Pu and 240Pu are the predominant radionuclides by weight, and INL-CCP 

submitted a freeze file change to the AKSR rectifying this discrepancy. The AK-NDA 

memorandum stated that if measured isotopic results were not available, default isotopics would 

be used. In the case of the single drum, TTR21A, measured isotopics were used. INL-CCP 

measurement data indicate that 239Pu and 241Am are the most prevalent isotopes by weight. See 

Item (11) below for additional information pertaining to AK Accuracy and Item (14) below for 

additional information pertaining to AK-NDA communication. Based on EPA’s analysis, the 

radiological composition of the waste stream was adequately defined. 

Contact-Handled Waste Streams from the Accelerated Retrieval Project 

(AKSR CCP-AK-INL-001, Revision 9)

While each ARP phase contains targeted RFP waste, the proportion and type of targeted and 

non-targeted wastes waste types in each area varies, as do the SQSs that contribute to each ARP. 

The waste retrieval and VE processes attempt to remove as much of the non-targeted waste as 

possible; however, some contamination is inevitable. Therefore, the expected radionuclides in 

ARP waste streams must be updated every time a new ARP phase is added. INL-CCP calculates 

the expected radionuclides based on AK data (Reference ID-U313), and continues to update 

these calculations every time additional ARP phases are added, historically adding one new ARP 

phase per AKSR revision, as evidenced by comparing Tables 5-2, 5-3, and 5-4 in AKSR, 

Revisions 7, 8, and 9. INL-CCP indicates that the most prevalent radionuclide by mass are 238U 

(99.63%), with 235U and 239Pu as the second and third most prevalent by mass in almost equal 
13 

concentrations, while the most prevalent radionuclides by activity are 241Pu (50.56%) and 241Am 

(38.07%). During this continued compliance inspection, EPA noted that the AK-based expected 

radionuclides do not accurately correspond with those measured by NDA. This appears to be 

because INL-CCP is not adequately correcting for the in-growth of 241Am from 241Pu.4 EPA 

recognizes that INL-CCP has not historically been required to update the radiological 

characterization information in the AKSR based on NDA information. Instead, the AK-NDA 

memorandum is expected to reflect accurate, NDA-based information and the AK Accuracy 

Reports are expected to catch inconsistencies between the AKSR and the NDA records. See 

Items (11) and (13) below for further discussion of this issue. Based on the above information, 

the AK information pertaining to the radiological characteristics of TRU wastes is adequate. 

(3) Identification of physical form, including Waste Material Parameters and prohibited 

items, were assessed and found to be adequate. 

Contact-Handled Waste Streams from Small Quantity Sites 

ID- NTLBL-S5400 debris from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) 

Waste Stream ID-NTLBL-S5400 is composed of mixed, heterogeneous decontamination and 

decommissioning and process/maintenance related wastes generated at LBNL, appropriately 

classified as WMP S5400. Specific waste items include organic laboratory debris (cardboard, 

cloth tape, cotton swabs, Kimwipes, paper) and inorganic debris (aluminum, copper, glass, 

graphite, and other scrap metals). The AKSR states that the drum(s) may contain 241Am sources 

with lead shielding, but sources were not found during repackaging. Small amounts of sorbent 

may be present. INL-CCP estimated the WMP based on NNSS RTR and VE of six containers 

shipped directly from NNSS to WIPP (Reference C134). INL-CCP determined that the waste 

stream is composed primarily of inorganic waste, such as metals (79.7%), with the remainder 

composed of organic material, such as cellulosics (20.3%). Comparison of these data with the 

RTR results for drum NT041489A indicates that this drum contains materials that generally 

correspond with those identified in legacy drums. Typical materials include scrap metal, hand 

tools, springs, metal cans, wire, metal funnels, hose clamps, open metal buckets, metal clamps, 

scrap lead, small glass containers, absorbent, light bulbs, labware, wood, plastic bags, scrap 

plastic, and plastic sheeting. Based on the above analysis, the physical composition of the waste 

stream was adequately described. 

ID-NTLBL-S3900 solid waste from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) 

Waste Stream ID-NTLBL-S3900 is composed of homogenous solids generated through 

solidification of liquids associated with LBNL R&D and process/maintenance activities. It is 

composed primarily of absorbed or solidified aqueous liquids generated through mixing with 

Aquaset, diatomaceous earth, Portland cement, and vermiculite. Debris may also be present in 

the waste stream. It is appropriately assigned WMC S3900, Unknown/Other Homogenous Solids 

 

4

 With a half-life of 14.35 years, 241Pu decays to 241Am at a rate of approximately 4.7% per year, i.e., 241Am 

accumulates at a rate of approximately 4.7% per year. 
14 

(References C101, P094, U014, and U103). INL-CCP evaluated pre-screen RTR information 

performed at NNSS to estimate WMP percentages and content information compiled in 

supporting AKSR CCP-AK-NTS-003. Based on this analysis, INL-CCP estimated that the waste 

stream was composed primarily of inorganic (92.54%) and organic materials (7.46%). 

Examination of Attachment 6 and associated memoranda, as well as the container RTR 

performed by INL-CCP, indicates that the drum contains a plastic bag, plastic containers, and 

sludge (percentages were not provided on the RTR form). This description generally conforms 

with AK. The physical composition of the waste stream was adequately described. 

ID-NTS-TTR-HET debris from the Tonopah Test Range/Roller Coaster Project stored at 

Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0) 

Waste Stream ID-NTS-TTR-HET is composed primarily of debris and other site remediationrelated waste, as well as a small amount of soil containing metal fragments. Specific debris items 

include PPE and sampling equipment such as plastic gloves and bags, boot covers, disposable 

coveralls, wipes, foil, respirator cartridges, masking tape, and disposable sampling tools 

(References C1002, C1024, M1005, M1025, P1099, P1107, U1010, and U1011). INL-CCP 

indicated that VE forms were not prepared by NNSS when this waste stream was repackaged and 

consolidated, and the waste generation processes suggested that the waste may contain 

substantially more soil than presented in the AKSR. However, the AK references examined 

verify that the waste stream is composed primarily of debris (80%), with some soil and metal 

(20%). WMC S5400, Heterogeneous Debris, was assigned to the waste stream (References 

C1024, M1025, U1010, and U1011). WMP estimates were obtained based on the assumptions 

that: 

 

• The soil component contains both soil and metal fragments of equal weight 

• The weight percents are 50% metal fragments (iron based metal/alloys), 25% aluminumbased metals/alloys and 25% other metals. 

Based on the descriptions of PPE and sampling equipment from AK source documents, the 

debris component is estimated to contain by weight 30% cellulosics, 30% plastic, 30% rubber, 

5% iron-based metal/alloys, 3% other metals, and 2% aluminum-based metals/alloys (References 

P1099 and P1107). Examination of RTR data for drum No. TTR21A indicates that it is 

composed of scrap metal, scrap rubber, plastic bags, plastic sheeting, plastic tubing, large open 

plastic containers, and soil, which corresponds to the anticipated waste content determined by 

AK. Based on the above analysis, the physical composition of the waste stream was adequately 

described. 

Contact-Handled Waste Streams from the Accelerated Retrieval Project 

(AKSR CCP-AK-INL-001, Revision 9) 

The three ARP waste streams are debris (ID-SDA-DEBRIS), solid/sludge (ID-SDA-SLUDGE), 

and soil (ID-SDA-SOIL). An ARP waste drum may contain any of these three wastes and these 

materials are delineated into the three waste streams bases on the WMP associated with more 

than 50% of the drum’s contents, as discussed under Item (1), above. 
15 

The AKSR describes the targeted debris waste as graphite and filters. Solid targeted wastes are: 

• 741- and 742-series sludges – inorganic solid matrices derived from treatment of aqueous 

liquids that were solidified through the addition of Portland cement 

• 743-series sludge – an organic solid matrix derived from the treatment of oils and organic 

solvents into a solid by mixing with a synthetic calcium silicate and organic solvents 

• Roaster oxides – pure DU metal machine turnings converted to an oxide in a chemical 

roaster that INL-CCP classifies as a homogenous solid waste 

Soils are not targeted waste, however, many of the targeted debris and sludge wastes are no 

longer (or were never) buried in drums or containers and quantities of the interstitial dirt are 

inadvertently removed from the retrieval area and packaged with the targeted wastes. 

As described in Item (2) above, the volumes of targeted wastes are included in the different ARP 

phases in varying proportions to other targeted and non-targeted wastes. Therefore, INL-CCP 

periodically updates the estimated waste burial volumes and WMP percentages based on 

expected contents of the newly added ARP areas and the VE records of waste packaged from 

ARP-I and -II (References ID-U-329 and ID-U345). While the percentage of targeted waste in 

the entire retrieval area did not change with the addition of ARP-III, -IV, and -V, the proportions 

estimated in the various areas vary widely. The total volume of ARP-I and ARP-II is currently 

estimated at 225,087 ft3

 (85,046 ft3 less than estimated in AKSR, Revision 6), of which 33% is 

targeted waste and 67% is non-targeted waste (10% more and 10% less, respectively, than 

estimated in AKSR, Revision 6). In total, ARP-III, -IV, and -V add a total of 361,159 ft3

, of 

which 17% is targeted waste and 83% is non-targeted waste. Addition of the newer ARP phases 

increased the total waste volume but did not increase the percentage of targeted waste. 

Analysis of the information provided by INL-CCP indicates that the intended physical 

characteristics of the debris, solid, and soil wastes in the new ARP phases and ARP-I and -II 

should be comparable for targeted wastes. Data suggest that there are no major anomalous nontargeted materials. However, 100% VE is performed during waste packaging to verify the 

absence of prohibited items, identify anomalous items, catalogue WMPs, and assign the drum to 

the appropriate waste stream. The physical composition of the waste stream was adequately 

described. 

(4) Acceptable Knowledge procedural adequacy and implementation were assessed and 

found to be adequate (assembly compilation, interpretation, confirmation, discrepancy 

resolution). 

INL-CCP uses procedure CCP-TP-005 for AK data collection, analysis, interpretation, 

confirmation, and discrepancy resolution. INL-CCP has used Revision 18 of this procedure since 

2008, but this procedure was recently updated and the current revision is 20. EPA expected 

revision 20 to include information formerly included in the WCPIP for RH waste (Revision 0D), 

which was removed and placed in procedure CCP-TP-005 during the most recent revision of the 
16 

WCPIP. However, Revision 20 does not include these requirements, which should only impact 

RH waste. EPA reviewed changes to CCP-TP-005, as presented in Revisions 19 and 20: 

• Revision 19: This revision incorporated relatively minor changes identified during 

internal and external audits. Typical revisions include changes to source document titles 

and simplification of attachment references. A notable change is the addition of a 

requirement to return generator site documents to the generator site once INL-CCP no 

longer works at that site, rather than include those references in INL-CCP Records. This 

was apparently due to the number of site documents assembled as part of the AK 

program. EPA understands this simplification, but CBFO must ensure EPA has access to 

these documents regardless of the characterization entity that uses (or used) the 

documents. For example, it is possible that INL-CCP could lose their certification, at 

which point records typically included in INL-CCP’s files would no longer be available 

at INL-CCP Records. EPA expects that all documents will be readily available to EPA 

regardless of storage location. Additionally, INL-CCP revised language to no longer 

require that the Attachment 3 summaries be “attached” to their associated source 

documents. This practice of separating Attachment 3 summaries from the full source 

document proved burdensome at other CCP sites because the Attachment 3 forms were 

assigned the exact same document number as the original source document. If the two 

files were mixed, it would be impossible to tell the original source document from the 

summary. If the Attachment 3 summaries are separated from the original source 

documents, EPA expects that these files will have unique identifiers such that the source 

documents and summaries can be differentiated. 

• Revision 20: This document revision includes minor modifications, the most notable 

being a requirement to submit each AKSR revision to INL-CCP Document Services. 

Revisions 19 and 20 of CCP-TP-005 did not significantly modify the AK process, and are 

acceptable noting the above items. 

Contact-Handled Waste Streams from Small Quantity Sites 

(AKSRs CCP-AK-INL-010, Revision 0 and CCP-AK-INL-014, Revision 0) 

EPA also reviewed the confirmation checklists for the three SQS waste streams to determine if 

any issues requiring a discrepancy resolution (DR) and reevaluation checklist arise during the 

confirmation process. Waste Stream LBNL S3900 did not require AK re-evaluation based on 

characterization data. However, both the TTR-HET and LBNL S5400 waste streams 

reevaluation checklists noted issues that mandated AK reevaluation. 

• For LBNL S5400, 239Pu and 241Am are the most prevalent radionuclides by weight based 

on measurement data, not 237Np and 241Am as indicated by AK. An AK reevaluation was 

requested, and an Attachment 10 (reevaluation checklist) was finalized on November 9, 

2010. This explained the discrepancy, and indicated that the AKSR will be updated to 

recognize this change. The AKSR is dated July 2009, so the next revision of this AKSR 

should include the modification based on the DR and AK re-evaluation. 
17 

• For TTR-HET, 239Pu and 240Pu are the most prevalent radionuclides by weight based on 

measurement data, not 238U and 239Pu as indicated by AK. An AK reevaluation was 

requested, and an Attachment 10 was completed January 7, 2010. This re-evaluation 

resulted in the generation of DR1005. The AKSR is dated June 18, 2009, so the next 

revision of this AKSR should include the modification based on the DR and AK reevaluation. 

Notification of revisions to any SQS AKSR remains a T2 change. 

Contact-Handled Waste Streams from the Accelerated Retrieval Project 

(AKSR CCP-AK-INL-001, Revision 9) 

EPA also reviewed random confirmation checklists for the three ARP waste streams to 

determine if any issues requiring issuance of DRs and/or reevaluation checklists arose during the 

confirmation process. Waste Stream ID-SDA-DEBRIS did not require AK reevaluation. 

However, both the ID-SDA-SLUDGE and ID-SDA-SOIL waste streams have reevaluation 

checklists noting issues associated with tentatively identified compounds that mandated AK 

reevaluation. The reevaluation checklist for the ID-SDA-SLUDGE waste stream was noted 

during a previous continued compliance inspection. The soil reevaluation checklist, completed 

one year later, lists additional compounds but describes the same solution. The AKSR was not 

revised as a result of either discrepancy. Notification of revisions to the AKSR remains a T2 

change. 

(5) The Acceptable Knowledge Summary Report was assessed and found to be adequate. 

AK summaries for each of the waste streams were evaluated, as summarized below. 

Contact-Handled Waste Streams from Small Quantity Sites 

ID- NTLBL-S5400 debris from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) 

Waste Stream ID-NTLBL-S5400 consists of mixed heterogeneous debris generated at LBNL as 

part of R&D and maintenance activities. INL-CCP states that the waste stream is composed of 

organic and inorganic laboratory debris. See Item (3) above for additional detail. AK indicates 

that some drums may contain 241Am sources with lead shielding, but VE did not identify these 

items. Small amounts of homogenous solids may be present, but the vast majority of this waste 

material type was removed during repackaging and placed in the S3900 waste stream. AK 

indicated that the two predominant radionuclides by mass are 237Np and 241Am, while over 95% 

of the total activity is 241Am and 241Pu. However, as indicated in Items (2) and (4) above, INLCCP’s NDA data showed that 240Pu was a predominant radionuclide by mass, so the AKSR must 

be revised to address this discrepancy. Additionally, the AKSR did not adequately address the 

defense determination explanation; see Item (7) below for additional information. As detailed in 

Item (6) below, INL-CCP submitted a freeze file change describing drum traceability elements. 

EPA expects the AKSR to be revised to reflect all of these deficiencies and notification of 

availability of this revision remains a T2 change. 
18 

ID-NTLBL-S3900 solid waste from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) 

Waste Stream ID-NTLBL-S3900 is mixed homogenous waste generated during R&D and 

process/maintenance activities at LBNL. See Item (3) for additional detail. The waste was 

originally comingled with debris generated by the same activities, but was separated into a 

different waste stream during repackaging at NNSS. AK data suggest that the two predominant 

radionuclides by mass are 239Pu and 240Pu, and over 95% of the total activity is 239Pu, 240Pu, and 

241Pu, which was confirmed by NDA. However, as indicated in Item (7) below, the AKSR did 

not adequately address the defense origin of wastes. As detailed in Item (6) below, INL-CCP 

submitted a freeze file change describing drum traceability elements. The AKSR must be revised 

to better justify the defense determination and to address the traceability change and notification 

of availability of this revision remains a T2 change. 

ID-NTS-TTR-HET debris from the Tonopah Test Range/Roller Coaster Project stored at 

Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0) 

Waste Stream ID-NTS-TTR-HET is composed of waste generated through cleanup of two sites 

in Nevada at which U- and Pu-bearing materials were exploded using conventional explosives. 

The waste consists of heterogeneous debris waste with lesser amounts of soil containing metal 

fragments. See Item (2) above for additional detail. The AKSR states that the two predominant 

radionuclides by weight are 238U and 239Pu, while over 95% of the total activity is 239Pu, 240Pu, 

and 241Pu. However, NDA measurements found the two predominant radionuclides by weight to 

be 239Pu and 240Pu. As indicated in Items (2) and (4) above, the AKSR should be revised to 

address this discrepancy. Notification of availability of a revised AKSR remains a T2 change. 

Contact-Handled Waste Streams from the Accelerated Retrieval Project 

(AKSR CCP-AK-INL-001, Revision 9)

These ARP waste streams consist of targeted RFP debris and sludge wastes and may also contain 

interstitial soil. While the historic source of all the targeted waste is RFP, various small 

generators also contributed waste to the ARP. Every time a new ARP area is added, INL-CCP 

continues to adequately update the list of potential waste generators, the expected radionuclides, 

WMP estimates, and the list of AK source documents. For example, in AKSR, Revision 9, INLCCP described three additional INL waste generators relative to ARP-V (Pit 9): CFA-665 – the 

Vehicle Maintenance Terminal and Automotive Repair Shop, the Modular Analytical 

Laboratory, and the Glovebox Excavator Method (GEM) Project. The Modular Analytical 

Laboratory will only contribute wastes (including unaltered sample material) generated during 

analysis of the ARP wastes (References ID-P402, ID-P403, ID-P404, ID-U376, and ID-U377). 

The GEM project tested the methods to be utilized throughout the ARP retrieval area by 

excavating a portion of Pit 9 (now ARP-V); the wastes removed by the GEM project will be 

repackaged and sorted into the three ARP waste streams (References ID-C114, ID-P377, IDP380, ID-P399, ID-U355, and RF-P356). As described in Items (2) and (3) above, INL-CCP 

adequately revised the AKSR, Revision 9 to account for the expansion of the retrieval area to 

include ARP-V. Sufficient source documents were added to the AK record to support inclusion 

of ARP-V. The CCP-TP-005, Attachment 4, AK Summary Document Reference List has not yet 
19 

been updated to include references in the AKSR, Revision 9. EPA assumes that this document 

will be updated in the future. 

(6) Drum traceability and the ability to follow the Acceptable Knowledge waste 

characterization process for containers were evaluated and found to be adequate. 

Contact-Handled Waste Streams from Small Quantity Sites 

Retrievably stored and newly generated containers were evaluated separately. Traceability of 

retrievably stored containers from LBNL to NNSS to INL was examined to verify that a drum’s 

history could be tracked to the place of origin. To streamline the inspection, traceability was 

performed on the LBNL wastes only, although examined references indicate that a similar level 

of traceability is available in the AK record for the TTR-HET waste stream. 

ID- NTLBL-S5400 debris from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0), and ID-NTLBL-S3900 solid 

waste from Lawrence Berkeley National Laboratory stored at Nevada National Security Site 

(AKSR CCP-AK-INL-010, Revision 0) 

Traceability of drums from the two LBNL waste streams was evaluated by interviewing INLCCP representative Scott Smith. Since the containers have a common origin they were evaluated 

in tandem and the results are presented together. The final drums of interest are Nos. 

NT041489A (S5400) and NT080018R (S3900) and were part of 12 that originated from the 

Building 70 Pitroom and were originally loaded between 1975 and 1980. These 12 drums were 

shipped to NNSS, beginning in 1975; seven were directly shipped to WIPP, while five drums 

were retained because they required repackaging. These five drums (Nos. NT280011, 

NT280007, NT280015, NT780025, and NT751050) were repackaged in 2008, resulting in one 

debris drum (No. NT041489A), one debris SWB, and one homogenous solids drum (No. 

NT080018R). It must be noted that the AKSR states four drums, not five, were retained and 

repackaged at NNSS. EPA noted the discrepancy in drum numbers while performing the 

traceability analysis and INL-CCP submitted a freeze file modification to Section 4.5.1 of the 

AKSR. EPA evaluated the freeze file modification and found it acceptable. Notification of 

availability of a revised AKSR that includes this revision remains a T2 change. 

Traceability of LBNL Drum No. NT280011 was examined. This drum was generated at LBNL 

in 1980 and shipped to NNSS. It underwent RTR at NNSS in 2005 upon repackaging it to drum 

“A” in July 2005, and a second repackaging to drum “AA” in October 2005. The drum was then 

assayed in June 2006, and was repackaged again in 2009 placed in a SWB, and shipped to INL. 

References U103, U065, U016, U051 and U001 were among those examined to verify this 

progression. INL-CCP provided the information presented in Table 4 below that identifies 

original LBNL drum numbers: 
20 

Table 4. Original Lawrence Berkeley National Laboratory Drum Numbers 

Waste Stream 

Drum Number 

Shipped to INL 

Feed 

Drum Number 

Interim 

Drum 

Number 

Interim 

Drum 

Number 

Drum Number

Shipped to 

NNSS 

ID-NTLBL-S5400 NT080344R NT280011AA NT280011A NT280011 

 HC-05-065A NT042090A NT042090 NT280007 

 NT980100 NT280015 

 NT780025A NT780025 

 NT041489A NT041489 NT751050 

ID-NTLBL-S3900 NT080018R NT780025A NT780025 

 NT280011A NT280011 

Additionally, INL-CCP provided a list of source documents and identified the pages in those 

source documents that addressed the LBNL waste traceability; source documents U014, U015, 

U051, U061, U065, U067, U084, and U085 were included in this listing. These data indicate that 

traceability could be achieved for the complex history associated with the two S5400 containers 

and single S3900 drum that originated at LBNL. Notification of availability of a revised AKSR 

that includes revisions related to drum repackaging remains a T2 change. 

Contact-Handled Waste Streams from the Accelerated Retrieval Project 

(AKSR CCP-AK-INL-001, Revision 9) 

The three ARP waste streams are composed entirely of newly generated waste; therefore, there is 

no direct link between waste generation at generator site and the drums being characterized by 

INL-CCP. However, through use of the Waste Inventory Location Database at INL and other 

historic waste documentation, INL-CCP is able to identify the specific wastes that were interred 

in the pits by ARP phase. EPA evaluated traceability for the last drum from each ARP waste 

stream that was emplaced in the WIPP facility as of the date of the continued compliance 

inspection. VE and NDA BDRs, relevant NCRs, project tracking system (PTS) screenshots, and 

WDS Container Data Reports were provided for each drum. Each drum was traceable from 

generation during VE through NDA to final emplacement in the WIPP facility, as summarized 

below in Table 5. 

Table 5. Summary of Accelerated Retrieval Project Drum Traceability Analysis 

Drum No. SCG VE BDR, date NDA BDR, date – 

result 

2

nd NDA BDR, date –

result Emplacement Date

ARP06227 S5400 IN-ARP-VE-000740, 

2/11/08 

INNDAH080058, 

2/20/08 – rejected, 

NCR-INL-0159080 

INNDAW090184, 

7/30/09 – reworked, 

then accepted, NCRINL-052610 

11/10/10 

ARP15566 S3900 IN-ARP-VE-001510, 

4/9/09 

INNDAS090352, 

11/23/09 – accepted

N/A 11/12/10 

ARP20413 S4200 IN-ARP-VE-001936, 

3/8/10 

INNDAS100048, 

3/17/10 – accepted 

N/A 11/7/10 
21 

(7) Defense origin of transuranic wastes was examined and found to be adequate. 

Contact-Handled Waste Streams from Small Quantity Sites 

ID- NTLBL-S5400 debris from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) and ID-NTLBL-S3900 solid 

waste from Lawrence Berkeley National Laboratory stored at Nevada National Security Site 

(AKSR CCP-AK-INL-010, Revision 0) 

INL-CCP states that since 1931, LBNL has been involved with TRU research and development, 

including technologies important to the development of the first atomic bombs. From 1947 to 

1975, the Atomic Energy Commission (AEC) was responsible for and funded programs in 

nuclear weapons research, development, production, and testing, as well as projects related to 

radioactive materials and TRU radionuclides. INL-CCP also states that budget documents 

generated from 1957 through 1986 identified numerous programs and projects that can be tied to 

defense activities. 

INL-CCP states that based on guidance from the DOE, a TRU waste is eligible for disposal at 

WIPP 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). INL-CCP 

attempted to demonstrate that the TRU waste destined for disposal at WIPP is associated with 

defense activities by linking TRU waste items to researchers, LBNL divisions, and facilities that 

were associated with defense work that generated the wastes (Reference P098). INL-CCP 

concluded that there was a sufficient correlation of defense activities to those performed at 

LBNL to support a defense determination for waste generated at this facility. CBFO issued an 

approved defense determination for LBNL waste shipped to LLNL in April 2004, and INL-CCP 

stated that this was applicable to the LBNL waste shipped to NNSS since it was within the time 

frame of generation of the LBNL wastes assigned to Waste Streams ID-NTLBL-S5400 and IDNTLBL-S3900 (Reference P098). 

EPA reviewed source documents associated with the LBNL waste streams and noted that the 

defense determination was not supported by some of these references. Specifically, Reference 

C101, which is an interview with operators who performed experiments in the Building 70 

Pitroom during the 1975–1980 time period, states that activities performed at this location were 

non-defense in origin. EPA questioned the INL-CCP AKE about these assertions, and received 

an adequate explanation. Since the wastes originated prior to 1975, DOE contends that this waste 

is likely to be contaminated with defense-related radionuclides. EPA also expects that when the 

AKSR and Reference C101 and other references that discuss the defense determination are 

revised, notification of availability of a revised AKSR and corresponding references is necessary 

and it remains as a T2 change. 

ID-NTS-TTR-HET debris from the Tonopah Test Range/Roller Coaster Project stored at 

Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0) 

Based on guidance from the DOE, a TRU waste is eligible for disposal at WIPP if it has been 

generated in whole or part by one of the atomic energy defense activities listed in Public Law 
22 

102-579, The Waste Isolation Pilot Plant Land Withdrawal Act (as amended), and Section 

10101(3) of the NWPA. INL-CCP concluded that AK indicated the TRU waste generated from 

the Roller Coaster Project is contaminated from activities related to weapons, defense nuclear 

waste and materials by-products management, and defense research and development. EPA 

accepts DOE’s conclusion. 

Contact-Handled Waste Streams from the Accelerated Retrieval Project 

(AKSR CCP-AK-INL-001, Revision 9)

The AKSR, Revision 9 was assessed with respect to the defense origin of these wastes. Targeted 

waste in the additional ARP phases came from RFP and EPA previously established RFP’s 

involvement with weapons-related activities, thus meeting the defense-related criterion. With 

regard to the non-targeted waste, EPA previously determined that the targeted and non-targeted 

wastes within the three waste streams were commingled due to a lack of container integrity 

within the pits. This situation is no different in ARP-III, -IV, or -V than it was in ARP-I and -II. 

Therefore, the defense arguments posed by INL-CCP continue to be acceptable to EPA and 

supported by available documentation. 

(8) The absence of Spent Nuclear Fuel and High Level Waste Status in these waste streams 

was evaluated and found to be in compliance with the Land Withdrawal Act. 

The AKSRs for all evaluated waste streams indicate the following: “The Public Law 102-579, 

[WIPP LWA] prohibits the disposal of spent nuclear fuel and high-level waste as defined by the 

[Nuclear Waste Policy Act (NWPA)]... at WIPP.” According to the NWPA, spent nuclear fuel 

(SNF) is “fuel that has been withdrawn from a nuclear reactor following irradiation, the 

constituent elements of which have not been separated by reprocessing.” DOE Order 435.1, 

Radioactive Waste Management (Reference 16) expands on this definition to clarify that “test 

specimens of fissionable material irradiated for research and development only, and not 

production of power or plutonium, may be classified as waste, and managed in accordance with 

the requirements of this Order when it is technically infeasible, cost prohibitive, or would 

increase worker exposure to separate the remaining test specimens from other contaminated 

material.” High-level waste (HLW) is defined by the NWPA as “the highly 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 highly radioactive material that the commission, consistent 

with existing law, determines by rule requires permanent isolation.” 

The waste stream contents and descriptions were evaluated against these definitions to determine 

whether the waste streams contained SNF or HLW. 

Contact-Handled Waste Streams from Small Quantity Sites 

ID- NTLBL-S5400 debris from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) 
23 

ID-NTLBL-S3900 solid waste from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) 

The NTLBL-S5400 and NTLBL-S3900 waste streams consist of debris and homogeneous waste 

"contaminated with radioactive material from R&D, maintenance, and repackaging operations." 

INL-CCP indicates that these operations did not include any separation or reprocessing of reactor 

fuel, and the wastes themselves do not contain irradiated fuel elements from a reactor; spent fuel 

pieces or particles also are not included in the waste. INL-CCP concludes, and EPA agrees, that 

the three containers in the subject waste streams do not include SNF and are not HLW 

(Reference P098). 

ID-NTS-TTR-HET debris from the Tonopah Test Range/Roller Coaster Project stored at 

Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0) 

Operation Roller Coaster and remediation of the Roller Coaster test sites and Roller Coaster 

RADSAFE Area involved the dispersion of nuclear material through detonation of conventional 

chemical explosives. References provided to EPA did not indicate that the Pu and U sources used 

were "spent nuclear fuel." The waste stream does not include HLW as defined by the NWPA 

(References P1008, P1016, and P1022). 

Contact-Handled Waste Streams from the Accelerated Retrieval Project 

(AKSR CCP-AK-INL-001, Revision 9)

As evaluated in the last continued compliance inspection at INL, the AKSR, Revision 9 

adequately explains that Waste Streams ID-SDA-DEBRIS, ID-SDA-SLUDGE, and ID-SDASOIL do not contain SNF or HLW. The AKSR states that SNF may have been buried in Pit 4, 

but not in the retrieval area, and that if SNF is found it will be segregated and not packaged. No 

NCRs have been generated since 2006 due to the presence of intact fuel rods. The AKSR also 

states that while HLW (acidic liquids) were produced in one of the small waste-contributing 

generators (CCP-601), it was sent to a different facility and not buried in the retrieval area. EPA 

continues to accept INL-CCP’s position that ARP waste streams do not contain SNF or HLW. 

(9) Waste Stream Profile Form preparation and completeness were evaluated and found to be 

adequate. 

The WSPFs for each of the waste streams were examined for completeness. Note that none of 

the WSPFs examined had a change request form indicating that modifications were requested 

after initial approval. 

Contact-Handled Waste Streams from Small Quantity Sites 

ID-NTLBL-S5400 debris from Lawrence Berkeley National Laboratory and stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) 

Michael Walentine approved the WSPF on October 23, 2009; the Characterization Information 

Summary (CIS) was attached, including the AK Summation of Aspects. The approved WSPF 

was complete. 
24 

ID-NTLBL-S3900 solid waste from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) 

Michael Walentine approved the WSPF on October 23, 2009; the CIS was attached, including 

the AK Summation of Aspects. The approved WSPF was complete. 

ID-NTS-TTR-HET debris from the Tonopah Test Range/Roller Coaster Project stored at 

Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0) 

Michael Walentine approved the WSPF on November 18, 2009; the CIS was attached, including 

the AK Summation of Aspects. The approved WSPF was complete. 

Contact-Handled Waste Streams from the Accelerated Retrieval Project (Acceptable 

Knowledge Summary Report CCP-AK-INL-001, Revision 9)

Barbara Broomfield approved the ID-SDA-DEBRIS WSPF on February 21, 2007; the CIS is 

attached, including the AK Summation of Aspects. The approved WSPF is complete. 

Barbara Broomfield approved the ID-SDA-SLUDGE WSPF on February 25, 2007; the CIS is 

attached, including the AK Summation of Aspects. The approved WSPF is complete. 

Barbara Broomfield initially approved the ID-SDA-SOIL WSPF on June 17, 2008; the CIS was 

attached, including the AK Summation of Aspects. However, the AK Summation of Aspects 

appeared to be missing the first two pages. Other than the missing pages, the approved WSPF 

was complete. In 2009, the WSPF was revised in response to New Mexico Environment 

Department comments. Michael Walentine approved the ID-SDA-SOIL WSPF, Revision 1, on 

October 7, 2009 by; the CIS is attached, including all pages of the AK Summation of Aspects. 

The approved revised WSPF is complete. 

(10) Preparation of nonconformance reports was evaluated and found to be adequate. 

Contact-Handled Waste Streams from Small Quantity Sites 

(AKSRs CCP-AK-INL-010, Revision 0 and CCP-AK-INL-014, Revision 0) 

INL-CCP provided a spreadsheet that identified the NCRs issued at INL since 2006. Based on 

this spreadsheet and the BDRs provided for Waste Streams NTLBL-S5400, NTLBL-S3900, and 

TTR-HET, NCRs were not prepared for any drums examined within these waste streams. 

Contact-Handled Waste Streams from the Accelerated Retrieval Project 

(AKSR CCP-AK-INL-001, Revision 9)

EPA has evaluated INL-CCP’s ability to produce compliant NCRs several times. As a spot 

check, EPA reviewed the two NCRs associated with drum traceability data for S5400 drum No. 

ARP06227. INL-CCP generated NCR-INL-0159080 because this drum assayed at less than 100 

nCi/g of TRU and was returned to INL. A year later, NCR-INL-052610 was generated during a 
25 

second NDA analysis of this drum because of an issue with the 238Pu activity. This drum 

underwent review by the NDA expert analyst (EA), the Independent Technical Reviewer (ITR) 

and Site Project Manager (SPM), and finally was accepted for disposal at WIPP. These two 

NCRs indicate that INL-CCP continues to produce NCRs according to EPA-approved 

procedures. 

(11) Acceptable Knowledge accuracy was assessed and found to be adequate. 

Contact-Handled Waste Streams from Small Quantity Sites 

ID- NTLBL-S5400 debris from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) 

EPA reviewed the AK accuracy report for Waste Stream NTLBL-S5400, and found that it 

contained typographical errors. EPA also found that the predominant radionuclides identified by 

AKSR and NDA did not correspond, but the AK accuracy report did not reflect this discrepancy. 

Instead, the AK accuracy report stated that NDA and AK data were in agreement, with 100% 

accuracy. INL-CCP representatives explained that at the time the AK accuracy report was 

prepared, a freeze-file change was in place that updated the AKSR by revising the predominant 

radionuclides to correspond to those identified through INL-CCP NDA. 

The NDA results and AK information in place at the time of AK accuracy report preparation, 

including the AKSR, must be compared to determine radiological accuracy. The freeze file 

change was in place prior to the NDA-AK comparison. In the future, AK accuracy reports must 

state whether a pending freeze file or other documentation was reviewed in addition to the 

AKSR. If a freeze file change or other documentation was not in place at the time of the review 

to explain differences between NDA and the AKSR, then INL-CCP must evaluate NDA-AKSR 

discrepancies as radiological inaccuracies. INL-CCP provided a revised AK accuracy report, 

approved on January 7, 2010, that rectified the typographical errors, but this version did not state 

that the AK accuracy review included AKSR freeze-files. EPA also believes that INL-CCP 

should consider both radionuclide weight percent and activity percent when evaluating AK 

accuracy and will revisit this issue in the future. Providing AK accuracy reports for this waste 

stream remains a T2 change. 

ID-NTLBL-S3900 solid waste from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) 

EPA reviewed the AK accuracy report for Waste Stream NTLBL-S3900 that states that 239Pu and 

240Pu are the two most prevalent radionuclides, which was verified by NDA performed by INLCCP. No Attachment 10s were prepared for this waste stream (AK-reevaluation). The AK 

accuracy report concluded that the accuracy for this waste stream was 100% because there was 

no reassignment of WMC and no addition of new hazardous waste numbers, and because the 

radionuclide composition determined by measurement is consistent with AK. This appears 

reasonable since the radionuclide content assigned by AK was verified by INL-CCP’s NDA 

measurements. As stated previously, EPA believes that INL-CCP should consider both 
26 

radionuclide weight percent and activity percent when evaluating AK accuracy and will revisit 

this issue in the future. 

ID-NTS-TTR-HET debris sourced from the Tonopah Test Range/Roller Coaster Project stored 

at Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0) 

EPA reviewed the AK Accuracy Report for Waste Stream NTS-TTR-HET, and questioned how 

CCP-TP-005, Attachment 10 was addressed. INL-CCP representatives adequately explained the 

discrepancy. EPA also found that the AKSR and NDA-identified predominant radionuclides did 

not correspond, but the AK accuracy report did not reflect this discrepancy and instead stated 

that NDA and AK data were in agreement, with 100% accuracy. INL-CCP representatives 

explained that at the time the AK accuracy report was prepared, a freeze-file change was in place 

that updated the AKSR by revising the predominant radionuclides to correspond to those 

identified through CCP-INL NDA. However, the freeze file was prepared on January 10, 2011, 

and was not in place at the time the AK accuracy report was prepared and INL-CCP did not 

provide information to support their contention that AK reviewed at the time of AK Accuracy 

Report preparation supported NDA results. 

The NDA results and AK information in place at the time of AK accuracy report preparation, 

including the AKSR, must be compared to assess accuracy. AK accuracy reports must state 

whether a pending freeze file or other documentation was reviewed in addition to the AKSR. If a 

freeze file change or other documentation was not in place at the time of the review to explain 

differences between NDA and the AKSR, then INL-CCP must evaluate NDA-AKSR 

discrepancies as radiological inaccuracies. As stated previously, EPA also believes that INLCCP should consider both radionuclide weight percent and activity percent when evaluating AK 

accuracy and will revisit this issue in the future. INL-CCP must revise the AK accuracy report 

for Waste Stream ID-NTS-TTR-HET to accurately reflect the AK data in the record at the time 

of report preparation. Providing AK accuracy reports for this waste stream remains a T2 change. 

Contact-Handled Waste Streams from the Accelerated Retrieval Project 

(AKSR CCP-AK-INL-001, Revision 9)

INL-CCP provided AK Accuracy Reports for ID-SDA-DEBRIS Lots 1-28, ID-SDA-SLUDGE 

Lots 1-185, and ID-SDA-SOIL Lots 1-37. None of the AK accuracy reports identified any issues 

with respect to WMPs or radionuclides and all three reports indicate that the most prevalent 

radionuclides by mass are 238U and 239Pu, consistent with AK. However, since actual weight 

percentages are not given, it is impossible to compare the predicted and actual values. All three 

reports state that no drums were rejected due to radionuclide-related concerns. As mentioned in 

Item (2) above and Item (13) below, the AK record does not include the in-growth of 241Am from 

241Pu, but this discrepancy between expected and NDA-measured values is not reflected in the 

AK accuracy report. EPA determined that this is because the discrepancy is apparent when 

comparing radionuclide activity percentages, which the AK accuracy report does not evaluate. 

As stated previously, EPA believes that INL-CCP should consider both radionuclide weight 

percent and activity percent when evaluating AK Accuracy and will revisit this issue in the 

future. 
27 

EPA also notes one minor typographical error in the Soil AK accuracy report (one of the section 

headings references incorrectly ID-SDA-DEBRIS” instead of “ID-SDA-SOIL”), and assumes 

that this will be corrected before the next version is available. Providing AK accuracy reports for 

the ID-SDA-SOIL, ID-SDA-SLUDGE, and ID-SDA-DEBRIS waste streams remains a T2 

change. 

(12) Load management was examined and found to be not applicable. 

Contact-Handled Waste Streams from Small Quantity Sites 

ID- NTLBL-S5400 debris from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) 

ID-NTLBL-S3900 solid waste from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) 

 ID-NTS-TTR-HET debris from the Tonopah Test Range/Roller Coaster Project stored at 

Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0) 

The WSPFs for these three waste streams state that load management will not be employed for 

these waste streams. Implementation of load management remains a T1 change. 

Contact-Handled Waste Streams from the Accelerated Retrieval Project 

(AKSR CCP-AK-INL-001, Revision 9)

INL-CCP has previously indicated, and EPA has previously observed, that load management is 

not being performed. During this continued compliance inspection, INL-CCP stated that load 

management had not been implemented. Implementation of load management continues to be a 

T1 change. 

(13) NDA-AK communication was assessed and found to be adequate. 

Contact-Handled Waste Streams from Small Quantity Sites 

ID-NTLBL-S5400 debris from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) 

ID-NTLBL-S3900 solid waste from Lawrence Berkeley National Laboratory stored at Nevada 

National Security Site (AKSR CCP-AK-INL-010, Revision 0) 

INL-CCP issued the same AK-NDA memorandum for the NTLBL-S3900 and NTLBL-S5400 

waste streams on June 25, 2009. Jim Shoen prepared the memorandum which states, “The 

purpose of this memorandum is to satisfy the requirement of CCP-TP-005, INL-CCP Acceptable 

Knowledge Documentation, for evaluating the radionuclide characterization of LBNL TRU 

mixed waste streams ID-NTLBLS5400: Heterogeneous Debris and ID-NTLBL-S3900: 

Solidified Inorganics and Organics.” 
28 

The AK-NDA memorandum stated that INL-CCP expected that the isotopic codes MGA or 

FRAM5

 provide reasonable estimates of the isotopic distribution. However, if acceptable 

isotopics are not provided during assay, the NDA EA compares the measured and AK-based 

values and derives technically appropriate isotopic values. If this process does not provide valid 

isotopic values, the drum is rejected. The report included default isotopic values for WG, default 

reactor-grade, mixed and 241Am-enriched Pu, as well as for natural uranium (NU) and DU. None 

of this information was included in the AKSR, but is apparently available in references and 

literature. Examination of NDA data for both the S3900 and S5400 drums from LBNL indicates 

that default isotopics were used for the S5400 drum No. NT041489A, and measured values were 

used for S3900 drum No. NT080018R. Based on the above information, development and 

implementation of the AK-NDA memorandum were adequate. 

ID-NTS-TTR-HET debris from the Tonopah Test Range/Roller Coaster Project stored at 

Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0) 

John Kleckner prepared the AK-NDA memorandum that was issued August 14, 2009. The 

document states, “[in] most cases experience has shown that the isotopic codes MGA or FRAM 

will provide a reasonable estimate of the waste isotopic distribution.” However, in those 

instances when the measurement does not yield a reasonable isotopic distribution, the NDA EA 

compares the measured and AK-based values and derives technically appropriate isotopic values. 

If this process does not provide isotopic values, the drum is rejected. The report provides default 

isotopic values for WG Pu and DU, Tables 3 and 4, respectively. The single drum in this waste 

stream did not require use of default isotopics. Based on the information reviewed, development 

and implementation of the AK-NDA memorandum were adequate. 

Contact-Handled Waste Streams from the Accelerated Retrieval Project 

(AKSR CCP-AK-INL-001, Revision 9)

A single AK-NDA memorandum has been issued that applies to all three ARP waste streams and 

is included with Attachment 7 of CCP-TP-005, Revision 18, prepared for each stream. The most 

recent memorandum is dated June 7, 2010 and does not include reference to ARP-V, which was 

added in AKSR, Revision 9, dated September 8, 2010. It is assumed that the AK-NDA 

memorandum will eventually be updated to include ARP-V. The AK-NDA memorandum states 

that the soil, sludge, and debris waste streams are actually conglomerations of several waste 

streams mixed during retrieval, and it is not possible to predict a radiological distribution when 

the waste streams are expected to contain undetermined and varying amounts of the parent waste 

streams. Tables 1 and 2 in the AK-NDA memorandum present the mass and activity fractions by 

target waste type, with overall waste radiological distribution provided in Table 3. This 

memorandum states that if NDA does not yield valid isotopic results, default isotopics based on 

RFP WG Pu, HEU, and DU will be used, as detailed in Tables 4 – 6; 242Pu will be determined by 

correlation techniques and 234U will be scaled to 235U and/or 238U, as appropriate. 

As in the AKSR, Revision 9, the predicted radionuclide distributions have not been corrected for 

decay or in-growth, and a footnote has been included to bring this to the reader’s attention. EPA 

 

5

 MGA is Multi Group Analysis. FRAM is Fixed-energy Response function Analysis with Multiple efficiencies. 
29 

raised this issue with INL-CCP, who responded that they did not want to correct all of the 

radionuclides for decay/in-growth and so were not correcting any of the radionuclides, and that it 

did not matter because the measurements of record are observed values from NDA. However, 

there are times when NDA data are not usable and the declared isotopics become part of the 

measurement of record. In such situations, 241Am may be underreported. It is EPA’s position that 

there is no need to correct all radionuclides in the AK-NDA memorandum. However, 

quantification of the 10 WIPP-tracked radionuclides and their uncertainty is required and this 

includes 241Am. The calculation of 241Am in-growth from its progenitor 241Pu (half-life 

approximately 14.2 years) is relatively simple and can change significantly over the time frames 

relevant to characterization of TRU waste for WIPP. EPA expects that the AK-NDA 

memorandum contain the most accurate information practicable regarding the 10 WIPP-tracked 

radionuclides. Accordingly, if information regarding the in-growth of 241Am is available for a 

specific group of wastes, waste containers or waste stream(s), it should be integrated in the AKNDA memorandum, as appropriate. EPA expects information addressing the in-growth of 241Am 

to be included in the AK record. 

No further response is required at this time. Revision of the AK-NDA memoranda applicable to 

the ID-SDA-SOIL, ID-SDA-SLUDGE, and ID-SDA-DEBRIS waste streams, or preparation of 

new, separate memoranda, remains a T2 change. 

Summary of Contact Handled Acceptable Knowledge Results

Acceptable Knowledge Findings or Concerns 

The EPA Inspection Team did not identify any AK findings or concerns related to AK for CH 

wastes as a result of this continued compliance inspection. 

Changes to Acceptable Knowledge Tiering 

There are no changes to the T1 or T2 designations to INL-CCP’s CH waste characterization 

programs as a result of this continued compliance inspection. 

Acceptable Knowledge Conclusions 

Based on the results of this evaluation and the data examined, EPA determines that INL-CCP 

demonstrated continued AK characterization compliance for CH waste streams. 

6.1.2 Remote-Handled Waste Streams 

This report includes only the new information EPA evaluated for the RH waste streams approved 

as T1 changes in 2009 -2010. The review did not include examination of AKSRs with respect to 

waste stream determination and other types of data, because EPA recently reviewed and 

approved this information as part of the T1 review process. 
30 

Background Information

EPA’s INL-CCP continued compliance inspection scope included all RH streams approved since 

2009. These waste streams included: 

• ID-ANLE-S5000 [Argonne National Laboratory-East (ANLE6), additional drums] 

• ID-HFEF-S5400-RH [Hot Fuel Examination Facility (HFEF), Lots 1a and 1b 

• ID-MFC-S5400-RH (MFC) 

• IN-ID-NRF-153 [Naval Reactors Facility (NRF)] 

• ID-INTEC-RH [Idaho Nuclear Technology and Engineering Center (INTEC)] 

• ID-RTC-S3000 [Test Reactor Area (TRA)] 

T1 requests for the NRF and TRA waste streams were recently approved by EPA and the ANLE 

waste stream change involved only a few drums, so these waste streams were not included in 

EPA’s continued compliance inspection. The continued compliance inspection focused on the 

MFC, HFEF, and INTEC RH waste streams. 

Waste Characterization Element Description 

Because many elements related to these waste streams were previously covered by EPA’s T1 

approvals, EPA's continued compliance inspection addressed the following: 

• WSPF and Characterization Reconciliation Report (CRR) adequacy 

• New NCRs and AK DRs 

• AK accuracy 

• AK data traceability related to characterization/confirmation activities 

• Adequacy of T1 review result requirements, including revision of documents to address 

T1 review results 

Documents, Waste Containers, and Batch Data Reports Reviewed

Several attachments, source documents, required forms, and other data were provided to EPA as 

part of the continued compliance inspection. The listing of RH AK source documents examined 

is presented in Attachment C.2. BDRs examined as part of the RH continued compliance 

inspection are presented below. All available BDRs for the HFEF waste stream were provided to 

EPA, but the three presented below include two of the most recent drums emplaced in the WIPP 

facility (October 1, 2010). Table 6 below lists the BDRs that were provided for the HFEF drums 

as well as the two INTEC and eight MFC waste drums. 

Table 6. Remote-Handled Batch Data Reports Examined

Waste Stream Drum Number NDE BDR Number DTC BDR Number 

ID-INTEC-RH IDIC000000460 RHINLVE090001 INLRHDTC09004 

ID-INTEC-RH IDIC000000427 RHINLVE090001 INLRHDTC10002 

 

6

 ANLE is now called simply ANL but many existing record use the old name. 
31 

Table 6. Remote-Handled Batch Data Reports Examined

Waste Stream Drum Number NDE BDR Number DTC BDR Number 

ID-HFEF-S5400-RH SN152A 

SN152B INLRHRTR10009 INLRHDTC10012 

ID-HFEF-S5400-RH IDAWANL780204A INLRHRTR09006 INLRHDTC09006 

ID-MFC-S5400-RH 

IDAWANL880065A 

DAWANL880065B 

IDAWANL880068A 

IDAWANL880068B 

IDAWANL880134A 

IDAWANL880134B 

INLRHRTR09009 INLRHDTC09009 

ID-MFC-S5400-RH IDAWANL880064A 

IDAWANL880064B RHINLVE090003 INLRHDTC09009 

Technical Evaluation

(1) The Waste Stream Profile Form and related change requests, as well as new/updated 

Characterization Reconciliation Reports, were evaluated and found to be adequate. 

Remote-Handled Waste Stream ID-INTEC-RH 

The WSPF provided to EPA during this inspection was approved on September 15, 2010. The 

waste stream is described as debris that may include combustibles and noncombustibles, as well 

as solidified sludge of acid-dissolved fuel, absorbed with diatomaceous earth. The WSPF states 

that the waste stream consists of two 30-gallon lead-lined drums, Nos. IDIC000000460 and 

IDIC000000427. The WSPF includes the CRR for the waste stream. No change requests were 

provided for the waste stream, and the drums have been emplaced in the WIPP. 

Remote-Handled Waste Stream ID-HFEF-S5400-RH 

The WSPF provided to EPA during the inspection was approved on February 10, 2010. This 

WSPF said the waste stream was composed of organic and inorganic debris derived through the 

examination of irradiated fuel pins. The waste stream consists of 91 waste canisters, and the 

WDS indicates about 75 individual drums or containers have been emplaced in the WIPP since 

the waste was first shipped on March 11, 2010. No change requests were provided for the waste 

stream. The CRR attached to the WSPF addressed nine of the initial drums included in the 

shipment; no additional CRRs were provided to EPA. 

Remote-Handled Waste Stream ID-MFC-S5400-RH 

The WSPF provided to EPA during the inspection was approved on June 24, 2010. The waste 

stream is described as glassware, paper, poly, and miscellaneous hardware generated during 

analytical chemistry laboratory hot cell operations. The WSPF states that the waste stream 

consists of eight 55-gallon drums packaged into three RH canisters. The WSPF includes the 

CRR for the waste stream. No change requests were provided for the waste stream, and the 

drums have been emplaced in the WIPP. 
32 

Based on the information above, INL-CCP continues to adequately prepare WSPFs and related 

attachments. 

(2) New Non Conformance Reports and AK discrepancy resolutions were reviewed and 

found to be adequate. 

Remote-Handled Waste Stream ID-INTEC-RH 

DR001, dated October 13, 2009, was provided to EPA as part of the original T1 review. DR002 

was listed on the new AKSR reference list and although RCRA-related, was provided to EPA as 

part of this inspection. No new DRs relevant to EPA’s characterization program were generated. 

EPA approved the T1 request for this waste stream in August 2010. NCR Nos. NCR-RHINL0501-10, NCR-RHINL-D502-10, NCR-RHINL-0504-09, NCR-RHINL-0507-09, and NCRRHINL-0512-09 were prepared prior to EPA’s approval. EPA reviewed the NCR process as part 

of the T1 review and no new NCRs were issued for this waste stream after EPA approval. 

Remote-Handled Waste Stream ID-HFEF-S5400-RH 

DR003, dated August 27, 2009, was provided to EPA as part of the original T1 review. DR004 is 

a new DR generated post-EPA approval that addresses liquids in HFEF cans and was provided to 

EPA upon request. No other DRs were provided. EPA approved the T1 request for Lot 1a in 

February 2010 and Lot 1b in August 2010. INL-CCP provided four example NCRs pertaining to 

this waste stream that were issued after EPA’s approval of Lot 1a: 

• NCR-RHINL-0500-10, issued February 10, 2010, indicated that the surface dose rate for 

Drum No. IDAWANL870105A measured 70 millirem per hour (mrem/hr), not the 

required >200 mrem/hr. The disposition for this drum was to return it to the host site. 

• NCR-RHINL-0507-10, issued May 25, 2010, dealt with addition of containers to the AK 

tracking spreadsheet. The information was added to the AK tracking spreadsheet, and no 

final disposition was identified. 

• NCR-RHINL-0514-10, issued October 18, 2010, dealt with the identification of negative 

container weight on a waste conversion record. The final disposition was not identified, 

although the issue did not impact AK. 

• NCR-RHINL-0515-10, issued November 2, 2010, stated that drum Nos. N154B, N153A 

and SN151A did not meet the decay heat limits specified in approved RH-TRUCON 

codes. The final disposition was not identified, although the issue did not impact AK. 

Remote-Handled Waste Stream ID-MFC-S5400-RH 

DR002, dated September 23, 2008, was provided to EPA as part of the original T1 review. 

DR003 is a new DR generated post-EPA approval that addresses the size of the waste-containing 

paint cans within the eight drums and was provided to EPA upon request. No other DRs relevant 

to the MFC waste stream have been generated. EPA approved the T1 request for this waste 

stream in June 2010. INL-CCP had not prepared any NCRs pertaining to this waste stream prior 

to EPA approval and had issued one NCR pertaining to this waste stream after EPA’s approval. 
33 

NCR-RHINL-0509-10, issued July 20, 2010, indicated that the ITR did not properly review the 

Audio/Video for drum No. IDAWANL880065A. The disposition was to rework the RTR BDR 

and resubmit the document to records. 

Based on the information presented above, EPA concludes that INL-CCP continues to prepare 

DRs and NCRs as required. 

(3) Acceptable Knowledge accuracy was reviewed and found to be adequate. 

Remote-Handled Waste Stream ID-INTEC-RH 

The AK accuracy report was approved and finalized on November 5, 2010. While the subject of 

the report was the INL Waste Stream ID-INTEC-RH, Lot 1, the text addressed Waste Stream 

SR-BCLPD.004.002. INL-CCP agreed that the report was in error and indicated that a revision 

was in process. Notification of availability of a revised final INTEC AK accuracy report remains 

a T2 change. 

Remote-Handled Waste Stream ID-HFEF-S5400-RH 

A draft AK accuracy report, dated October 12, 2009, was provided to EPA that indicated Lots 1-

9 exhibited 100% AK accuracy, because no waste was reassigned to a different SCG or waste 

stream, and the radiological parameters were accurate with respect to AK. Verification of 

accuracy was accomplished through achievement of AK-based data quality objectives (DQOs). 

Although not explicitly stated, presentation of the DQOs in this manner shows that the SCG 

assignment was not modified, the drums were not placed in a different waste stream, and some of 

the general radiological parameters (i.e., TRU and RH determination) were met through 

implementation of the WCPIP and comparison to the AK Record. It is expected that the final 

report will include all lots characterized through 2010. Notification of availability of a final AK 

accuracy report for this waste stream remains a T2 change. 

Remote-Handled Waste Stream ID-MFC-S5400-RH 

EPA evaluated a draft AK accuracy report, dated April 15, 2010 and found it to be adequate 

during the T1 review. The AK accuracy report indicated that all eight drums exhibited 100% AK 

accuracy, because no waste was reassigned to a different SCG or waste stream, and the 

radiological parameters were accurate with respect to AK. A final AK accuracy report is not yet 

available. Notification of availability of the final MFC AK Accuracy report remains a T2 change. 

(4) Acceptable Knowledge data traceability as it related to characterization/confirmation 

activities was reviewed and found to be adequate. 

The same traceability information was provided for the INTEC, HFEF, and MFC waste streams, 

so all were evaluated together. Data were provided to evaluate tracking of information for all 

three wastes streams, from the NDA/NDE phase through shipment, to emplacement in the WIPP. 

INL-CCP provided the following documents for each waste stream: 
34 

• CCP-TP-005, Revision 18, Attachment 8, which is a drum list showing drum status as of 

the date of list generation (i.e., repackaging status). This attachment is not necessarily a 

complete list of all containers in the waste stream. 

o INTEC: November 12, 2009 

o HFEF: November 12, 2009 

o MFC: February 2, 2010 

• The AK tracking spreadsheet was also provided, which is a drum list that is current as of 

the date of report generation (September 27, 2010). There is one AK tracking spreadsheet 

for each site, so the same document was provided in reference to each of the three 

evaluated here. 

• Several BDRs were provided (DTC, RTR, and VE); a subset of these BDRs is included 

in the WSPF CRR. 

• INL-CCP provided a WDS spreadsheet that includes shipment, emplacement and other 

data. Once the WSPF is approved and shipment begins, INL-CCP tracks and has access 

to WDS information. 

• PTS screen shots show tracking data maintained by INL-CCP, including NCR 

identification and status. 

These mechanisms show that drum data are recorded throughout the characterization and 

emplacement process. 

To verify traceability of data, drum Nos. IDWWAL780204A and IDAWANL880068A were 

tracked through the various characterization data sheets, databases, and ultimate emplacement of 

the waste in WIPP to verify that the same information was transferred throughout the process. 

Data examined included BDRs and WDS and PTS information; data in these examples were 

found to be traceable. In summary, the information provided shows that INL-CCP has access to 

information about each container throughout the characterization, shipment, and emplacement 

processes, and this traceability is adequate. 

(5) Compliance with tiering requirements, including revision of documents to address Tier 1 

review results, was evaluated and found to be adequate. 

EPA examined key documents identified in EPA’s T1 and T2 requirements to determine whether 

the most recent revision of these documents is available, whether EPA was properly notified of 

the documents’ availability, and to determine the status of document reviews and revisions. EPA 

examined the tiering elements and associated documents and activities as a status check to 

determine whether the ongoing characterization process incorporated these elements. The results 

of this examination are presented in Table 7 below. 

Based on the information in Table 7 below, EPA determined that, for the most part, data are 

available to evaluate the T1 compliance issues; the HFEF waste stream’s AKSR does not yet 

include the changes necessary to address issues identified during EPA’s T1 evaluation. EPA was 

also provided updated information about the documents associated with each of the T2 elements. 
35 

EPA determined that the quarterly T2 notification reports continue to include revised or newly 

issued documents as required under 40 CFR 194.8. 
36 

Table 7. Summary of Compliance with Tiering Requirements 

Tier Tiering Requirements1 INTEC HFEF T1 Addition of containers to approved waste 

streams if new or different radionuclide-scaling factors or a different radiological characterization process are required 

The INTEC waste stream is of finite size and has been emplaced in WIPP, so no addition of containers is anticipated. 

INL-CCP indicated that new “lots” may be added to the waste stream in the future that require different scaling factors, but CCP-AK-INL-581, Revision 1 was updated to include the Lot 1b scaling factors, but no additional new scaling factors. 

The size WIis a

T1 Any new RH waste streams not approved to 

date 

EPA was not informed of new RH waste streams as part of the inspection, and under

in forthcoming T1 change requests. 

T1 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 

The INTEC waste stream is of finite size and has been emplaced in WIPP, so no substantive modifications are expected. 

Substantive modifications may occur in the future; however, the most recent version of these documents was 

provided during this inspection and 

such modifications have not been made. 

The size WIthe stredocinclthat fort

T1 Load management for any RH waste stream EPA did not find that load management was being performed for these waste streamT2 Notification to EPA when updates to AK 

Summary Reports (AKSRs), Radiological Characterization Reports, and Confirmation Test Plans (e.g., CCP-AK-INL-500, CCP-AKINL-501, and CCP-AK-INL-502) are approved 

by CBFO 

The most updated versions of these documents were provided to EPA during the inspection. CCP-AKINL-550, Revision 1 was approved 

by CBFO on March 10, 2010, and 

EPA was notified of this change via the CBFO FY2010 2nd quarter T2 

reporting. This revision includes the changes necessary to address concerns identified during EPA’s T1 evaluation. 

The most updated versions of these documents were provided to EPA during the inspection. EPA was notified of the availability of CCPAK-INL-580, Revision 2, CCP-AKINL-581, Revision 1, and CCP-AKINL-582, Revision 1 via the CBFO FY2010 3rd quarter T2 reporting. 

Revision 2 of the AKSR does not include the Lot 1b freeze file changes generated as a result of EPA’s Tiering review. EPA expects that Revision 3 will address these changes. 

The docdurINL

by 

Thinecidenevanotmad

qua

T2 Notification to EPA when changes to AK 

documentation as a result of Waste Characterization Program Implementation Plan (WCPIP) revisions have been made [e.g., Characterization Reconciliation Reports (CRRs)] 

The new WCPIP was only recently approved, so EPA determined that none of the ex

documentation (e.g., CCP-TP-005) would be available at this inspection. 
37 

Table 7. Summary of Compliance with Tiering Requirements 

Tier Tiering Requirements1 INTEC HFEF T2 Notification to EPA when a Correlation or 

Surrogate Summary Form is completed for each of the RH containers in this waste stream identified as contact-handled (CH), based upon measured dose rates that present nondestructive assay (NDA) results for assayed containers 

CSSFs were not provided to EPA during the inspection, so it is assumed that none are available. 

CSSFs were not provided to EPA during the inspection, so it is assumed that none are available. 

CSdurassu

T2 Notification to EPA once waste stream data 

package for debris waste stream and any 

modifications to the Waste Stream Profile Form (WSPF), including the CRR and AKSR, are completed 

See Item (1), above. Notification of the availability of the final WSPF was provided to EPA via the CBFO FY2010 4th quarter T2 reporting. 

See Item (1), above. Notification of the availability of the final WSPF was 

provided to EPA via the CBFO 

FY2010 2nd quarter T2 reporting. 

See the was FY

T2 Notification to EPA that the final dose-to-curie

(DTC) determination is complete for RH containers 728 through 737, as identified in AK Reference P030 

The requirement is not applicable to these waste streams. This information was not p

and EPA expects it would be included, as available, in T2 request quarterly response

T2 AK accuracy reports (prepared annually, at a 

minimum) 

See Item (3), above. The final AK accuracy report is dated November 5, 2010, and therefore EPA expects that notification of availability should occur via the CBFO FY2011 1st quarter T2 reporting. 

See Item (3), above. EPA has not received notification of the availability of an AK accuracy report. 

See recavarep

T2 Notification to EPA when additional containers 

are added to RH TRU debris or sludge waste streams that have been approved to date and the containers were characterized using the same radionuclide-scaling factors 

The INTEC waste stream is of finite size and has been emplaced in WIPP, so no addition of containers is anticipated. 

The HFEF waste stream, as approved 

by EPA, is expected to add containers 

as waste is generated. EPA expects that notification will be provided as outlined in the HFEF Lot 1b T1 approval report. 

The size WIis a

T2 Notification to EPA of availability of a revised

AKSR and source documents supporting the addition of containers to the approved waste streams 

The INTEC waste stream is of finite size and has been emplaced in WIPP, so no addition of containers is anticipated. 

See Item (1) above. EPA requested copies of new source documents and received that information during the continued compliance inspection. 

The size WIis a
38 

Table 7. Summary of Compliance with Tiering Requirements 

Tier Tiering Requirements1 INTEC HFEF T2 Notification to EPA when Attachment 4 of 

CCP-TP-005 is generated to reflect the updated AKSR Source Document Reference List 

A revised Attachment 4 was 

provided. EPA did not receive 

notification of the availability of the revised Attachment 4; however, this T2 requirement was put in place after the most recent AKSR revision and it is assumed that Attachment 4 is only updated upon CBFO’s approval of an AKSR revision. 

A revised Attachment 4 was provided. EPA did not receive notification of the availability of the revised Attachment 4; however, this T2 requirement was 

put in place after the most recent 

AKSR revision and it is assumed that Attachment 4 is only updated upon CBFO’s approval of an AKSR revision. 

A r

pro

notrevassuupdan AwhiFY

Thenotrev

plac

qua

1 These are the tiering requirements as published in the most recent INL-CCP T1 approval report (approval of TRA sludge waste, A-98-49, II-A
39 

Summary of Remote Handled Acceptable Knowledge Results

Acceptable Knowledge Findings or Concerns 

The EPA Inspection Team did not identify any AK findings or concerns as a result of the RH 

portion of the continued compliance inspection. 

Changes to Acceptable Knowledge Tiering 

There are no changes to the T1 or T2 designations for INL-CCP’s RH waste characterization 

program as a result of this continued compliance inspection. 

Acceptable Knowledge Conclusions 

Based on the results of this evaluation and the data examined, EPA determines that INL-CCP 

demonstrated continued AK characterization compliance for RH waste streams. 

6.1.3 Summary of Acceptable Knowledge Results 

Acceptable Knowledge Findings or Concerns 

The EPA Inspection Team did not identify any AK findings or concerns for INL-CCP’s CH or 

RH waste characterization programs as a result of this continued compliance inspection. 

Changes to Acceptable Knowledge Tiering 

There are no changes to the T1 or T2 designations to INL-CCP’s CH or RH waste 

characterization programs as a result of this continued compliance inspection. 

Acceptable Knowledge Conclusions 

Based on the results of this evaluation and the data examined, EPA determines that INL-CCP 

demonstrated continued waste characterization compliance for all evaluated CH and RH waste 

streams. 

6.2 Nondestructive Assay 

EPA had approved the SuperHENC and the WAGS NDA systems initially during the baseline 

inspection and two subsequent continued compliance inspections in 2008 and 2009. The 

systems’ abilities to perform the required analyses had been demonstrated during the baseline 

and confirmed in the two continued compliance inspections. Accordingly, this inspection 

focused on the following: 

 

• Confirming that the design and technical capabilities of both NDA systems’ hardware 

and software had not changed since EPA’s last inspection 

• Adequacy of the current revisions of the INL-CCP NDA procedures and documents 
40 

• Operational and maintenance history of the NDA systems since the last EPA inspection 

• Knowledge, understanding and training status of INL-CCP NDA personnel 

The documents that EPA examined in assessing the WAGS and SuperHENC systems during this 

inspection are listed in Appendix C.3. 

6.2.1 Technical Evaluation: Waste Assay Gamma Spectrometer 

The following aspects of the WAGS were evaluated during this inspection: 

(1) The Waste Assay Gamma Spectrometer Nondestructive Assay system is the same system 

that was approved previously. 

The WAGS system is located at INL in the facility formerly called the SWEPP,7

 Building 

WMF-610. The EPA inspection team verified that there have been no substantive hardware or 

software changes to this system except for the detector replacement that is discussed under 

Item (3) below. 

(2) The design and operational range of the Waste Assay Gamma Spectrometer were 

assessed and were found to be unchanged from the last inspection and were adequate for 

the wastes currently being assayed. 

The WAGS assays retrievably stored (legacy) wastes and newly generated wastes from the ARP 

at INL. ARP wastes include sludge, debris and soils, most of which originated at RFP and are 

primarily WG Pu covered under AK Memorandum 19. Additional wastes are from the SQS 

program and include wastes from LLNL, which are not typically WG Pu wastes. These wastes 

contain fuel-grade, reactor-grade and mixed isotopics-grade Pu, as documented in AK 

Memorandum 18. Between January 2010 and November 16, 2010, the WAGS assayed 1,617 

drums that were compiled in 191 BDRs. The EPA Inspectors observed the assay of drum No. 

10348288, a legacy waste sludge that had a density of 0.0920 kilograms/liter and approximately 

0.5 g 239Pu upon assay. All daily performance measurements were observed, appropriately 

recorded and were in control. Specifically, background, daily performance check, Full Width at 

Half Maximum (FWHM), energy calibration (gain) and barium-133 (133Ba) transmission source 

checks were evaluated, as evidenced in the WAGS daily operational logbook and BDRs. 

Warning and Control Limits [2 and 3 sigma (σ) limits] for all parameters had been established 

and documented, as appropriate, and background [~40 counts per second (cps), full spectrum], 

FWHM and gain were controlled by boundary limits. Decay correction of the 133Ba transmission 

source was performed in the software. Typical assay times for debris drums were ~32 minutes 

and ~26 minutes for sludge drums. EPA Inspection personnel observed that WAGS personnel 

had available and were using the current revisions of the WAGS operating procedure. All 

operational aspects of the WAGS operation were acceptable. 

 

7

 SWEPP is the Stored Waste Examination Pilot Plant.
41 

(3) System calibration and calibration confirmation of the Waste Assay Gamma 

Spectrometer Nondestructive Assay system had been performed and documented as 

required. 

The EPA inspection team verified that the system’s original calibration was unchanged. One 

calibration verification had been performed since the last EPA inspection, when a gamma 

detector was replaced. This was documented in CCP-INL-WAGS-10-005; all aspects of the 

calibration verification were technically acceptable and appropriately documented. 

(4) The total measurement uncertainty of assays performed on the Waste Assay Gamma 

Spectrometer Nondestructive Assay system had been determined and documented, as 

required. 

CCP-INL-WAGS-002, Total Measurement Uncertainty for the WAGS System adequately 

documents all pertinent aspects of the system’s total measurement uncertainty (TMU). The EPA 

inspection team verified that this document was unchanged from EPA’s last inspection. 

(5) The lower limit of detection, including the minimum detectable concentration of the 

Waste Assay Gamma Spectrometer, had been determined and documented, as required. 

CCP-INL-WAGS-001, Revision 1, April 2008, adequately documents the technical basis for the 

system’s lower limit of detection (LLD), including reporting thresholds for specific nonmeasured radionuclides 242Pu and 90Sr. The EPA inspection team verified that this document was 

unchanged from EPA’s last inspection. 

(6) The Waste Assay Gamma Spectrometer had successfully participated in Drum Cycle 17A 

and Box Cycle 9A of the CBFO-sponsored Performance Demonstration Program (PDP), 

as required. 

(7) Personnel training was assessed and found to be adequate. 

All NDA personnel associated with the calibration, operation and data review and approval of 

the WAGS had current training in the applicable areas as evidenced by the List of Qualified 

Individuals (LOQI) provided during the inspection. 

(8) EPA replicate testing of the Waste Assay Gamma Spectrometer unit was performed and 

evaluated, and was found to comply with the criteria for the Environmental Protection 

Agency Replicate Testing Protocol. 

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

an independent means to verify that the WAGS can provide reproducible results for the 

determination of the quantity of 10 WIPP-tracked radionuclides (241Am, 137Cs, 238Pu, 239Pu, 

240Pu, 242Pu, 90Sr, 233U, 234U, and 238U) and the TRU alpha concentration.8

 This is accomplished 

 

8

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

and data evaluation. 
42 

by the WAGS reassaying drums it previously measured to demonstrate the system’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 

• 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 with all statistical evaluations, there are limitations inherent in this protocol. The usefulness 

of the results depends in large part on the degree to which the conditions encountered are 

consistent with the assumptions upon which the tests are predicated. EPA’s experience to date 

indicates that containers chosen at random do not always provide information best suited for the 

application of these statistical protocols. For example: 

• An NDA system may have been recalibrated in the time period between the original 

assay and the reassay performed during an inspection, and the new calibration may have 

different values for some of the calibration algorithm’s terms. 

• The containers chosen at random for replicate analysis may lack sufficient nuclear 

material content to provide useable data for some or all of the WIPP-tracked 

radionuclides. 

• High precision for the five replicate assays may yield an average value that differs 

slightly from the original assay value, but produces results that the statistical analysis 

indicates are Significant or Highly Significant. However, these differences may be small 

variations that are more a function of the statistical protocols and do not indicate true 

measurement trends or problems, as discussed below.

• Since some radionuclides are quantified based on the measurement of another 

radionuclide, a Significant or Highly Significant indicator for one measured entity will be 

reflected in the other three, indicating a larger potential measurement trend or problem 

than actually exists. Examples include: values for 238Pu and 240Pu, which are derived by 

applying an isotopic ratio to a measured 239Pu value; and 137Cs and 90Sr that are 

quantified based on a directly measured 241Am value, an inferred 137Cs value, and a 

scaling factor for 90Sr, as discussed below. 

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

or Highly Significant results may not, in fact, be representative of true measurement issues, as 

discussed below for drum No. ARP22225. 

As part of this inspection, EPA requested that INL-CCP reassay two drums that EPA randomly 

selected from a list of drums previously assayed on the WAGS. Drum Nos. ARP21969, and 

ARP22225 were reassayed five times and the results were compared to the original assay data. 

Two statistical tests, a chi-squared (χ2

) test and a t test, were performed. Data and results of the 

statistical analysis are included in Attachments B.1and B.2. For drum Nos. ARP21969 and 

ARP22225, the χ2 test showed that the observed variances in the replicate measurements are less 
43 

than or equal to the reported uncertainties within the statistical limits of the test. For drum No. 

ARP21969, the t test showed no statistically significant differences between the original assay 

values and the average of the five replicate measurements. 

The t test for drum No. ARP22225 showed a statistically Highly Significant difference between 

the original assay value and the average of the five replicate measurements for 238Pu, 240 Pu and 

242Pu. The test also indentified a statistically Significant difference between the original assay 

value and the average of the five replicate measurements for 237Np. This indicates that the 

variances in the replicate measurements for these items were greater than the reported 

uncertainties for all values relative to the limits of the test. The 242Pu values that were found to be 

Highly Significant, was expected based on the manner in which this radionuclide is measured. 

There are several possible reasons for the Highly Significant differences for 238Pu and 240 Pu 

replicate versus original—actual changes in the physical configuration of the drum’s contents 

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

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

aspect that this test is designed to query. Although the software identified these variances as 

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

additional attention at this time. Further inspection of the five replicate measurements found a 

small standard deviation in value. The original measurement values were sufficiently similar to 

replicates that despite its classification as Highly Significant by the t test, there is no reason to 

question the instrument’s performance. 

6.2.2 Technical Evaluation: Super High Efficiency Neutron Counter 

The following aspects of the SuperHENC were evaluated during this inspection: 

(1) The Super High Efficiency Neutron Counter Nondestructive Assay system is the same 

system that was approved previously. 

The SuperHENC system is located at INL in the facility formerly called the SWEPP, Building 

WMF-610, South Bay, and is officially designated as NDA SHENC-01. The EPA inspection 

team verified that there have been no substantive hardware or software changes to this system 

since the last EPA inspection. 

(2) The design and operational range of the Super High Efficiency Neutron Counter were 

assessed and were found to be unchanged from the last inspection and were adequate for 

the wastes currently being assayed. 

The SuperHENC assays a variety of configurations: 55-gallon drums of dry combustibles; SWBs 

containing debris; 100-gallon drums containing pucks

9

; one SWB containing two puck drums; 

and, one SWB containing four 55-gallon drums of sludge. Two interfering matrix baseline tests 

were performed and documented for the SuperHENC, one for a 55-gallon drum of dry 

combustibles and one for 2-pucks of light metals in an SWB. Approved waste streams include 

BN550 (from AMWTP), as documented in RPT-TRUW-07, the AK document for 

 

9 Pucks are 55-gallon drums of TRU waste that have been compacted into smaller disks by crushing, the pucks

are then over-packed in 100-gallon drums which are referred to as pucked drums. 
44 

supercompacted waste from RFETS and DOE’s Mound Site, consisting of mixtures of 12% and 

23% 240Pu wastes. The EPA Inspectors observed that daily performance measurements were 

appropriately recorded and were in control. Specifically, neutron and gamma backgrounds, daily 

gamma source check, and californium-252 normalizations were performed, as evidenced in the 

SuperHENC daily operational logbook and BDR No. INNDA BO9016. Warning and Control 

Limits (2 and 3 σ limits) for all parameters had been established and documented, as appropriate. 

Background limits were established as an upper limit, i.e., three times the average gamma and 

neutron backgrounds observed during the system’s initial calibration. All operational aspects of 

the SuperHENC were acceptable. 

(3) System calibration and calibration confirmation of the Super High Efficiency Neutron 

Counter had been performed and documented as required. 

The EPA inspection team verified that the system’s original calibrations for all previously 

approved assay configurations were unchanged. No calibration verifications had been performed 

since the last EPA inspection. 

(4) The total measurement uncertainty of assays performed on the Super High Efficiency 

Neutron Counter had been determined and documented, as required. 

The EPA inspection team verified that the system’s original determination of TMU for all 

previously approved assay configurations were unchanged since the last EPA inspection. 

(5) The lower limit of detection, including the minimum detectable concentration of the 

Super High Efficiency Neutron Counter, had been determined and documented, as 

required. 

The EPA inspection team verified that the system’s original determination of LLDs for all 

previously approved assay configurations were unchanged since the last EPA inspection. 

(6) The Super High Efficiency Neutron Counter had successfully participated in Drum Cycle 

17A (combustibles and metals matrices) and Box Cycle 9A (combustibles and metals 

matrices) of the CBFO-sponsored PDP, as required. Additionally, INL-CCP submitted 

data for Box Cycle 10A on October 10, 2010, but had not received results at the time of 

the inspection. 

(7) Personnel training was assessed and found to be adequate. 

All NDA personnel associated with the calibration, operation and data review and approval of 

the SuperHENC had current training in the applicable areas as evidenced by the LOQI provided 

during the inspection. 

(8) EPA replicate testing of the Super High Efficiency Neutron Counter was performed and 

evaluated, and was found to comply with the criteria for the Environmental Protection 

Agency Replicate Testing Protocol. 
45 

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

an independent means to verify that the SuperHENC can provide reproducible results for the 

determination of the quantity of 10 WIPP-tracked radionuclides (241Am, 137Cs, 238Pu, 239Pu, 

240Pu, 242Pu, 90Sr, 233U, 234U, and 238U) and the TRU alpha concentration.10 This is accomplished 

by the SuperHENC reassaying drums it previously measured to demonstrate the system’s ability 

to provide the following: 

• 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 

• 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 

EPA requested that INL-CCP reassay one waste drum that EPA randomly selected from a list of 

drums previously assayed on the SuperHENC. EPA chose Drum No. BN10381564. The 

previously assayed drum was reassayed five times on the SuperHENC for this inspection. Two 

statistical tests, χ2

 test and a t test, were performed on the replicate analyses of the drum. 

Analytical data for each assay event and results of the statistical analysis are included in 

Attachments B.3 

For both drums, the t test showed no statistically significant differences between the original 

measurement assay value and the average of the five replicate measurements for all measurement 

parameters. The χ2 test for these drums showed that the observed variances in the replicate 

measurements were less than or equal to the reported uncertainties for all values within the 

statistical limits of the test. There are no outstanding issues with either statistical test for this 

drum. 

6.2.3 Summary of Nondestructive Assay Results 

Summary of Nondestructive Assay Findings and Concerns 

The EPA inspection team did not identify any findings or concerns related to the WAGS or 

SuperHENC NDA systems during this continued compliance inspection. 

Changes to Nondestructive Assay Tiering 

There are no changes to the T1 or T2 designations for NDA as a result of this continued 

compliance inspection. 

Nondestructive Assay Conclusion

Based on the results of this evaluation and the data examined, EPA determines that INL-CCP 

demonstrated continued NDA compliance for all evaluated systems. 

 

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

and data evaluation. 
46 

6.3 Real-Time Radiography 

EPA evaluated INL-CCP’s continued compliance with EPA-approved RTR procedures for 

retrievably stored (legacy) CH waste and found compliance to be adequate. 

Technical Evaluation 

EPA interviewed operators/ITRs and reviewed BDRs and training records to verify ongoing 

RTR operations and training. 

Operations were verified by review of BDR Nos. INRTR51000768, INRTR5100070, and 

INRTR5100076, generated in October and November of 2010 for CH drums. All BDRs 

contained an acceptable Measurement Control Report and a CCP Attachment 2, Radiography 

Data Sheet, had been completed for each drum. All attachments had been signed as required by 

procedure CCP-TP-053, Standard RTR Inspection Procedure. Required quality control (QC) 

samples, Independent Observation and Replicate Scan, had been successfully completed and 

included in each BDR. Correct generation, recording and processing of NCRs were investigated 

by reviewing the following NCRs: 

• NCR-INL-0661-10, NCR-INL-0662-10 (BDR No. INRTR5100068) 

• NCR-INL-0665-10, NCR-INL-0666-10 (BDR No. INRTR5100070) 

• NCR-INL-0677-10, NCR-INL-0678-10, NCR-INL-0550-10 (BDR No. INRTR5100076) 

BDR Nos. INRTR5100068 and INRTR5100070 had been reviewed at both data generation 

(ITR) and project level (SPM). At the time of the onsite inspection, INRTR5100076 had been 

reviewed at the ITR level only. 

EPA reviewed the written and audio/visual record for drum No.10229559, which contained a 

large amount of liquid (17 pints). The operator responsible for this examination was interviewed 

to determine how the volume of this liquid, and that in other drums, was calculated. The 

information received from a second operator interviewed was different than that from the first, 

and EPA generated Concern INL-CCP-CH-RTR-10-01CR, Revision 1 to address this issue. The 

concern was discussed with INL-CCP RTR personnel and is summarized below. 

EPA Inspection Issue Tracking Form, Concern No. INL-CCP-CH-RTR-10-01CR, 

Revision 1: There were two aspects to this concern, as follows: 

• RTR operators that EPA interviewed did not describe a consistent method of volume 

calculation. For example, one operator always used a rectangular formula and another 

tried to use the closest standard shape formula. EPA is concerned that use of calculation 

formulae has the potential for inconsistent reporting of liquid volumes.

• RTR operators stated that they have not been provided any guidance for rounding and 

number of significant figures for reporting calculated liquid volumes.
47 

Resolution: EPA has determined that this method of estimating liquid contents of containers was 

implemented solely to comply with recent hazardous waste permit requirements. Continued use 

of this method does not adversely affect compliance with EPA requirements to reasonably 

estimate the quantity of liquid emplaced in the WIPP repository. 

Status of Concern: EPA considers this issue closed. 

EPA inspectors interviewed RTR operators/ITRs and reviewed records to verify ongoing training 

and expertise. INL-CCP contracts with VJ Technologies to provide training, including 

calculation of volumes, to RTR operators for CH waste. Personnel performing RH RTR are 

employed by CH2M-WG Idaho, LLC (CWI) but INL-CCP provides oversight for the operations 

and examinations. CWI employees perform test drum examinations, which are scored by INLCCP personnel and are subject to CCP training requirements. Operators were able to describe 

how data sheets are completed and how NCRs are initiated. Waste Stream AMWTP ID-RFS3114 was being processed by INL-CCP at the time of the on-site inspection, which does contain 

free liquid. The free liquid is considered as PCB (polychlorinated biphenyl) liquid and these 

drums are returned to the Advanced Mixed Waste Treatment Project for reprocessing. 

Test Drum records were reviewed and found to be complete. Operators are required to 

successfully examine a test drum every six months to remain qualified. INL-CCP has developed 

separate test drums for CH and RH wastes and for each summary category group. 

EPA did not identify any concerns with regard to training of RTR operators. 

Summary of Real-Time Radiography Findings and Concerns 

The EPA inspection team did not identify any findings and did identify one concern related to 

RTR as performed by INL-CCP described above (see Attachment A for a copy of this concern) 

during this continued compliance inspection. 

Changes to Real-Time Radiography Tiering 

There are no changes to the T1 or T2 designations to RTR as a result of this continued 

compliance inspection. 

Real-Time Radiography Conclusion

Based on the results of this evaluation and the data examined, EPA determines that INL-CCP 

demonstrated continued RTR compliance. 

6.4 Visual Examination 

EPA evaluated INL-CCP’s continued compliance with EPA-approved VE procedures for newly 

generated CH and RH waste and found compliance to be adequate for both waste types. 
48 

Technical Evaluation 

The EPA inspectors reviewed BDRs, interviewed personnel and observed packaging operations 

to verify that VE continues to be performed by INL-CCP in accordance with approved 

procedures. 

INL-CCP performs CH VE at the Radioactive Waste Management Complex (RWMC) ARP and 

RH VE at INTEC. EPA determined that CH BDR Nos. IN-ARP-VE-002226 and IN-ARP-VE002227 were generated in accordance with approved procedure CCP-TP-006, Visual 

Examination Technique for INL Newly Generated TRU Waste Retrieved from Pits. Data were 

recorded on the electronic data sheet Attachment 1 – CCP Waste Visual Examination Technique 

Data Form SCO# 798 Addendum 4, Windows XP 2002 MS Excel 2003. The data sheets were 

signed and dated by two operators and a Visual Examination Expert (VEE). No NCRs were 

generated for these two BDRs. VE operators and VEE interviewed were able to provide answers 

to all EPA’s questions and were knowledgeable with regard to VE operations. 

EPA determined that VE at CCP-INL continues to be performed by trained personnel and in 

accordance with approved procedures. 

Summary of Visual Examination Findings and Concerns

The EPA inspection team did not identify any findings or concerns related to VE during this 

continued compliance inspection. 

Changes to Visual Examination Tiering 

There are no changes to the T1 or T2 designations to VE as a result of this continued compliance 

inspection. 

Visual Examination Conclusion

Based on the results of this evaluation and the data examined, EPA determines that INL-CCP 

demonstrated continued VE compliance. 

7.0 SUMMARY OF RESULTS AND CONCLUSIONS 

7.1 Findings and Concerns 

There were no findings identified during this continued compliance inspection. The EPA 

inspection team identified one concern related to RTR as performed by INL-CCP which is 

discussed above and is provided in Attachment A. 

7.2 Tiering Changes 

There are no changes to the T1 or T2 designations in any waste characterization area as a result 

of this inspection. 
49 

7.3 Conclusions 

The EPA inspection team determined that the INL-CCP waste characterization program 

activities continue to be technically adequate. EPA is not proposing any changes to the INL-CCP 

waste characterization program in the configuration at this time. The scope of the compliance 

decision is based on EPA’s inspection completed November 16–17, 2010.
A-1 

ATTACHMENT A 

Real-Time Radiography Concern No. INL-CCP-CH-RTR-10-01CR 

Inspection No. EPA-INL-CCP-CH-11.10-24 Issue Number: INL-CCP-CH-RTR-10-01CR 

Date: November 16, 2010, Revision 1 

Inspector: Dorothy E. Gill 

Attachments? YES NO 

Sample Size: 1 

Population size (if known): Unknown 

Description of Issue: 

A. Operators interviewed did not describe to EPA a consistent method of calculation of 

liquid volume. For example, one operator always used a rectangular formula and 

another attempted to use the closest standard shape formula. EPA is concerned that use 

of the calculation formulae has the potential for inconsistent reporting of liquid 

volumes. 

B. Operators stated that they have not been provided any guidance for rounding and 

number of significant figures to use for reporting calculated liquid volumes. 

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable 

D. Discussed with: Mike Walentine, Bill Verlanic, Mark Pearcy 

E. Additional Comments: EPA recognizes that the results of these calculations are estimates 

and a high degree of precision is not expected.

F. Site Response Information: 

 Site Response Required? YES NO 

Site Response Due Date: December 7, 2010 
B-1 

ATTACHMENT B.1: REPLICATE TESTING DATA FOR DRUM ARP21969 – WAG

Instrument: WAGS Drum: ARP21969 

Quantity of Interest 

Original Measurement Replicate #1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) 2.39E-05 1.44E-05 6.03E-01 2.23E-05 1.35E-05 6.05E-01 1.93E-05 238U Activity (Ci) 9.92E-06 3.52E-06 3.55E-01 7.21E-06 2.68E-06 3.72E-01 8.46E-06 238Pu Activity (Ci) 2.54E-03 1.28E-03 5.04E-01 2.25E-03 1.15E-03 5.11E-01 5.14E-03 239Pu Activity (Ci) 8.49E-02 2.89E-02 3.40E-01 8.01E-02 2.73E-02 3.41E-01 8.07E-02 240Pu Activity (Ci) 1.71E-02 5.90E-03 3.45E-01 1.78E-02 6.24E-03 3.51E-01 1.83E-02 242Pu Activity (Ci) 3.12E-06 1.12E-06 3.59E-01 2.31E-06 1.42E-06 6.15E-01 3.20E-06 241Am Activity (Ci) 7.99E-02 2.73E-02 3.42E-01 7.33E-02 2.51E-02 3.42E-01 8.87E-02 90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 1.50E+03 3.27E+02 2.18E-01 1.41E+03 3.06E+02 2.17E-01 1.57E+03 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) 2.10E-05 1.27E-05 6.05E-01 1.64E-05 9.92E-06 6.05E-01 2.15E-05 238U Activity (Ci) 7.60E-06 2.84E-06 3.74E-01 8.53E-06 3.13E-06 3.67E-01 8.26E-06 238Pu Activity (Ci) 4.70E-03 1.89E-03 4.02E-01 2.35E-03 1.21E-03 5.15E-01 2.30E-03 239Pu Activity (Ci) 8.48E-02 2.89E-02 3.41E-01 8.24E-02 2.81E-02 3.41E-01 8.30E-02 240Pu Activity (Ci) 1.91E-02 6.59E-03 3.45E-01 1.85E-02 6.37E-03 3.44E-01 1.80E-02 242Pu Activity (Ci) 3.31E-06 1.19E-06 3.60E-01 3.17E-06 1.13E-06 3.57E-01 3.29E-06 241Am Activity (Ci) 7.62E-02 2.61E-02 3.43E-01 8.17E-02 2.80E-02 3.43E-01 7.85E-02 90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 1.50E+03 3.21E+02 2.14E-01 1.50E+03 3.27E+02 2.18E-01 1.48E+03 
B-2 

ATTACHMENT B.1: REPLICATE TESTING RESULTS FOR DRUM ARP21969 – WA

Instrument: WAGS Drum: ARP21969 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation x 2 Pr(x <|c2|) Reported Value Absolute Uncertainty 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A 234U Activity (Ci) 2.39E-05 1.44E-05 2.01E-05 2.34E-06 1.17E-01 1.06E-01 9.99E-01 238U Activity (Ci) 9.92E-06 3.52E-06 8.01E-06 5.80E-07 7.23E-02 1.08E-01 9.99E-01 238Pu Activity (Ci) 2.54E-03 1.28E-03 3.35E-03 1.44E-03 4.31E-01 5.09E+00 2.78E-01 239Pu Activity (Ci) 8.49E-02 2.89E-02 8.22E-02 1.88E-03 2.28E-02 1.69E-02 1.00E+00 240Pu Activity (Ci) 1.71E-02 5.90E-03 1.83E-02 5.03E-04 2.74E-02 2.91E-02 1.00E+00 242Pu Activity (Ci) 3.12E-06 1.12E-06 3.06E-06 4.21E-07 1.38E-01 5.66E-01 9.67E-01 241Am Activity (Ci) 7.99E-02 2.73E-02 7.97E-02 5.91E-03 7.42E-02 1.87E-01 9.96E-01 90Sr Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A 137Cs Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 1.50E+03 3.27E+02 1.49E+03 5.72E+01 3.83E-02 1.22E-01 9.98E-01 

Quantity of Interest t Pr(x <|t|) x 2 Test t Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable 234U Activity (Ci) 1.48E+00 2.13E-01 Not Significant Not Significant 238U Activity (Ci) 3.01E+00 3.97E-02 Not Significant Significant 238Pu Activity (Ci) -5.11E-01 6.36E-01 Not Significant Not Significant 239Pu Activity (Ci) 1.31E+00 2.60E-01 Not Significant Not Significant 240Pu Activity (Ci) -2.25E+00 8.76E-02 Not Significant Not Significant 242Pu Activity (Ci) 1.39E-01 8.96E-01 Not Significant Not Significant 241Am Activity (Ci) 3.40E-02 9.75E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A Not Applicable Not Applicable 137Cs Activity (Ci) N/A N/A Not Applicable Not Applicable TRU Alpha Conc. (nCi/g) 1.28E-01 9.05E-01 Not Significant Not Significant 
B-3 

ATTACHMENT B.2: REPLICATE TESTING DATA FOR DRUM ARP22225 – WAG

Instrument: WAGS Drum: ARP22225 

Quantity of Interest 

Original Measurement Replicate #1 R

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

A

Un

233U Activity (Ci) N/A N/A 234U Activity (Ci) 5.74E-05 3.51E-05 6.12E-01 5.38E-05 3.29E-05 6.12E-01 5.91E-05 3238U Activity (Ci) 6.27E-05 2.23E-05 3.56E-01 6.11E-05 2.17E-05 3.55E-01 6.04E-05 2238Pu Activity (Ci) 4.06E-03 2.17E-03 5.35E-01 1.89E-03 9.82E-04 5.20E-01 1.76E-03 9239Pu Activity (Ci) 6.46E-02 2.29E-02 3.55E-01 6.72E-02 2.38E-02 3.54E-01 6.25E-02 2240Pu Activity (Ci) 1.80E-02 6.52E-03 3.62E-01 1.49E-02 5.43E-03 3.64E-01 1.39E-02 5242Pu Activity (Ci) 6.12E-06 2.27E-06 3.71E-01 1.94E-06 1.21E-06 6.24E-01 1.80E-06 1241Am Activity (Ci) 1.66E-01 5.89E-02 3.55E-01 1.60E-01 5.67E-02 3.54E-01 1.57E-01 590Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 1.62E+03 4.08E+02 2.52E-01 1.56E+03 3.96E+02 2.54E-01 1.51E+03 3

Quantity of Interest 

Replicate #3 Replicate #4 Re

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

A

Un

233U Activity (Ci) N/A N/A 234U Activity (Ci) 5.51E-05 3.37E-05 6.12E-01 5.46E-05 3.34E-05 6.12E-01 5.15E-05 3.238U Activity (Ci) 6.37E-05 2.26E-05 3.55E-01 6.63E-05 2.35E-05 3.54E-01 6.40E-05 2.238Pu Activity (Ci) 1.75E-03 9.12E-04 5.21E-01 1.77E-03 9.21E-04 5.20E-01 1.85E-03 9.239Pu Activity (Ci) 6.23E-02 2.21E-02 3.55E-01 6.30E-02 2.23E-02 3.54E-01 6.58E-02 2.240Pu Activity (Ci) 1.38E-02 5.05E-03 3.66E-01 1.40E-02 5.09E-03 3.64E-01 1.46E-02 5.242Pu Activity (Ci) 1.80E-06 1.12E-06 6.22E-01 1.82E-06 1.13E-06 6.21E-01 1.90E-06 1.241Am Activity (Ci) 1.68E-01 5.94E-02 3.54E-01 1.64E-01 5.84E-02 3.56E-01 1.80E-01 6.90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 1.57E+03 4.08E+02 2.60E-01 1.56E+03 4.02E+02 2.58E-01 1.68E+03 4.
B-4 

ATTACHMENT B.2: REPLICATE TESTING RESULTS FOR DRUM ARP22225 – WA

Instrument: WAGS Drum: ARP22225 

Quantity of Interest 

Original Measurement Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation 

x

 2 Pr(x <|c2 Reported 

Value 

Absolute 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A 234U Activity (Ci) 5.74E-05 3.51E-05 5.48E-05 2.76E-06 5.04E-02 2.48E-02 1.00E+0238U Activity (Ci) 6.27E-05 2.23E-05 6.31E-05 2.38E-06 3.78E-02 4.56E-02 1.00E+0238Pu Activity (Ci) 4.06E-03 2.17E-03 1.80E-03 6.23E-05 3.45E-02 3.30E-03 1.00E+0239Pu Activity (Ci) 6.46E-02 2.29E-02 6.42E-02 2.21E-03 3.44E-02 3.72E-02 1.00E+0240Pu Activity (Ci) 1.80E-02 6.52E-03 1.42E-02 4.83E-04 3.39E-02 2.19E-02 1.00E+0242Pu Activity (Ci) 6.12E-06 2.27E-06 1.85E-06 6.42E-08 3.47E-02 3.20E-03 1.00E+0241Am Activity (Ci) 1.66E-01 5.89E-02 1.66E-01 8.96E-03 5.40E-02 9.25E-02 9.99E-090Sr Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A 137Cs Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 1.62E+03 4.08E+02 1.58E+03 6.27E+01 3.98E-02 9.44E-02 9.99E-0

Quantity of Interest t Pr(x <|t|) x 2 Test t Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable 

234U Activity (Ci) 8.53E-01 4.42E-01 Not Significant Not Significant 238U Activity (Ci) -1.53E-01 8.86E-01 Not Significant Not Significant 238Pu Activity (Ci) 3.31E+01 4.99E-06 Not Significant Highly Significant 239Pu Activity (Ci) 1.82E-01 8.64E-01 Not Significant Not Significant 240Pu Activity (Ci) 7.11E+00 2.07E-03 Not Significant Highly Significant 242Pu Activity (Ci) 6.07E+01 4.41E-07 Not Significant Highly Significant 241Am Activity (Ci) 2.04E-02 9.85E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A Not Applicable Not Applicable 137Cs Activity (Ci) N/A N/A Not Applicable Not Applicable TRU Alpha Conc. (nCi/g) 6.41E-01 5.57E-01 Not Significant Not Significant 
B-5 

ATTACHMENT B.3: REPLICATE TESTING DATA FOR DRUM BN10381564 – SUPERH

Instrument: SuperHENC Drum: BN10381564 

Quantity of Interest 

Original Measurement Replicate #1 Repli

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Abso

Uncer

233U Activity (Ci) N/A N/A N/234U Activity (Ci) N/A N/A N/238U Activity (Ci) N/A N/A N/238Pu Activity (Ci) 1.40E-02 5.64E-03 4.02E-01 1.37E-02 5.50E-03 4.01E-01 1.55E-02 6.24E239Pu Activity (Ci) 4.58E-01 4.61E-02 1.01E-01 4.46E-01 4.43E-02 9.92E-02 5.06E-01 5.08E240Pu Activity (Ci) 1.02E-01 5.88E-03 5.78E-02 9.93E-02 5.45E-03 5.49E-02 1.13E-01 6.41E242Pu Activity (Ci) 1.32E-05 6.80E-06 5.15E-01 1.29E-05 6.63E-06 5.15E-01 1.46E-05 7.53E241Am Activity (Ci) 9.39E-02 2.19E-02 2.34E-01 9.02E-02 2.56E-02 2.84E-01 1.02E-01 2.91E90Sr Activity (Ci) N/A N/A N/137Cs Activity (Ci) N/A N/A N/TRU Alpha Conc. (nCi/g) 1.82E+03 1.93E+02 1.06E-01 1.77E+03 1.90E+02 1.07E-01 2.01E+03 2.17E

Quantity of Interest 

Replicate #3 Replicate #4 Repli

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Abso

Uncer

233U Activity (Ci) N/A N/A 234U Activity (Ci) N/A N/A 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 1.49E-02 6.00E-03 4.02E-01 1.47E-02 5.94E-03 4.04E-01 1.42E-02 5.6239Pu Activity (Ci) 4.86E-01 5.04E-02 1.04E-01 4.79E-01 5.28E-02 1.10E-01 4.62E-01 4.5240Pu Activity (Ci) 1.08E-01 6.76E-03 6.26E-02 1.06E-01 7.78E-03 7.31E-02 1.03E-01 5.4242Pu Activity (Ci) 1.40E-05 7.23E-06 5.16E-01 1.38E-05 7.15E-06 5.17E-01 1.33E-05 6.8241Am Activity (Ci) 9.82E-02 2.81E-02 2.86E-01 9.68E-02 2.79E-02 2.88E-01 9.33E-02 2.690Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 1.93E+03 2.15E+02 1.11E-01 1.90E+03 2.23E+02 1.17E-01 1.84E+03 1.9
B-6 

ATTACHMENT B.3: REPLICATE TESTING RESULTS FOR DRUM BN10381564 – SUPE

Instrument: SuperHENC Drum: BN10381564 

Quantity of Interest 

Original Measurement Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation 

x

 2 Pr(x <|c2 Reported |) 

Value 

Absolute 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A 234U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A 238U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A 238Pu Activity (Ci) 1.40E-02 5.64E-03 1.46E-02 7.06E-04 4.83E-02 6.27E-02 1.00E+00 239Pu Activity (Ci) 4.58E-01 4.61E-02 4.76E-01 2.30E-02 4.83E-02 9.94E-01 9.11E-01 240Pu Activity (Ci) 1.02E-01 5.88E-03 1.06E-01 5.11E-03 4.83E-02 3.03E+00 5.53E-01 242Pu Activity (Ci) 1.32E-05 6.80E-06 1.37E-05 6.63E-07 4.83E-02 3.81E-02 1.00E+00 241Am Activity (Ci) 9.39E-02 2.19E-02 9.62E-02 4.65E-03 4.83E-02 1.79E-01 9.96E-01 90Sr Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A 137Cs Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 1.82E+03 1.93E+02 1.89E+03 9.15E+01 4.83E-02 8.94E-01 9.25E-01 

Quantity of Interest t Pr(x <|t|) x 2 Test t Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable 234U Activity (Ci) N/A N/A Not Applicable Not Applicable 238U Activity (Ci) N/A N/A Not Applicable Not Applicable 238Pu Activity (Ci) -7.27E-01 5.08E-01 Not Significant Not Significant 239Pu Activity (Ci) -7.27E-01 5.08E-01 Not Significant Not Significant 240Pu Activity (Ci) -7.27E-01 5.07E-01 Not Significant Not Significant 242Pu Activity (Ci) -7.27E-01 5.08E-01 Not Significant Not Significant 241Am Activity (Ci) -4.47E-01 6.78E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A Not Applicable Not Applicable 137Cs Activity (Ci) N/A N/A Not Applicable Not Applicable TRU Alpha Conc. (nCi/g) -6.88E-01 5.30E-01 Not Significant Not Significant 
C.1-1 

ATTACHMENT C.1 

Acceptable Knowledge References – Contact-Handled Waste 

CCP-TP-005, CCP Acceptable Knowledge Documentation, Carlsbad, New Mexico, Washington 

TRU Solutions, LLC., Revisions 18, 19 and 20, November 16, 2006, July 6, 2010, and November 1, 

2010 

ID-NTS-TTR-HET

Acceptable Knowledge Accuracy Report, Waste Stream ID-NTS-TTR-HET, Lot 1, June 30, 2010 

CCP-AK-INL-009, CCP Acceptable Knowledge Summary Report for Idaho National Laboratory 

Nevada Test Site Lawrence Livermore National Laboratory Waste, Carlsbad, New Mexico, 

Washington TRU Solutions, LLC, Revision 1, May 19, 2009 

CCP-AK-INL-014, Central Characterization Project Acceptable Knowledge Summary Report for 

Idaho National Laboratory Tonopah Test Range/Roller Coaster Project Contact-Handled Transuranic 

Waste, Waste Stream: ID-NTS-TTR-HET, Revision 0, July 15, 2009 

CCP-PK-NTS-007, Central Characterization Project Process Knowledge Summary Report for 

Nevada Test Site Tonopah Test Range/Roller Coaster Project Contact-Handled Transuranic Waste, 

Carlsbad, New Mexico, Washington TRU Solutions, LLC, April 9, 2009 

CCP-TP-005 Attachment 1, Documentation Checklist, July 23, 2009 

CCP-TP-005 Attachment 4, Source Document Reference List, July 23, 2009 

CCP-TP-005 Attachment 7, Radiological Data INL-NTS-TTR-HET, and associated AK-NDA 

Memorandum, August 14, 2009 

CCP-TP-005 Attachment 10, AK Re-Evaluation Checklist, INL-NTS-TTR-HET, January 7, 2010 

CCP AK Waste Stream Characterization Checklist, October 14, 2009 

INL NTS AK Tracking Spreadsheet, October 1, 2010 

List of BDRs, INL NTS-TTR-HET, dated November 8, 2010 

PTS Screen Shot Drum TTR-21A, provided November 17, 2010 

Waste Stream Profile Form, Waste Stream ID-NTS-TTR-HET, December 30, 2009 
C.1-2 

C1002, Letter to E.F. Di Sanza, Director Subject Contract No. DE-AC08-96NV11718 Notification 

for Placement of Clean Slate Fragments in TRU Pad Cover Building, 1300-SL-00-0061, December 

20, 1999 

C1003, Letter to E.F. Di Sanza, Director Subject Contract,No. DE-AC-08-96NV11718 Concurrence 

for placement of corrective action unit (CAU) 407 Roller Coaster transuranic (TRU) waste in TRU 

Pad Cover Building (TPCB), 1300-SL-01-0095, February 27, 2001 

C1014, Interview with Lou Gregory Regarding NTS TRU Waste Management, October 1, 2008 

C1024, Email from Lou Gregory to John Kleckner, re: Questions., November 5, 2008 

DR005, Discrepancy Resolution re: Predominant Isotopes for Waste Stream ID-NTS-TTR-HET, 

John Kleckner, January 7, 2010 

M1005, Incoming Radioactive Material Checklist, 99130R, December 6, 1999 

M1025, TRU Inventory Scorecard, undated 

P1012, Corrective Action Decision Document for Corrective Action, Unit 407: Roller Coaster 

RADSAFE Area, Tonopah Test Range, Nevada, CAU 407 Waste Characterization and Disposal, 

DOE/NV-567, September, 1999 and July, 2000 

P1013, Level 1 - Waste Characterization Waste Stream Number: LRY5LLNTSCS06 Double Tracks 

Soil MEF. NO. 00437, undated 

P1014, Waste Characterization Summary Waste Stream Number: LRY5LLFY00010 CAU 407, TTR 

Solid Soil, MEF No. F00011, undated 

P1016, Corrective Action Investigation Plan for Corrective Action Unit 486: Double Tracks Radsafe 

Area Nellis Air Force Range, Nevada, DOE/NV-523, October 1998 

P1018, In Situ Radiological Surveying at the Double Tracks Site, DOE/NV/11718-013, April 1996 

P1023, Clean Slate 1, Corrective Action Decision Document, Corrective Action Unit No. 412, 

DOE/NV-472, April 1997 

P1024, Clean Slate 1 Closure Report (Nevada Environmental Restoration Project), DOE/NV/11718-

159, November 1997 

P1025, Closure Report for Corrective Action Unit 407; Roller Coaster RADSAFE Area; Tonopah 

Test Range, Nevada, DOE/NV-694-Rev, December 12, 2001 

P1032, Radiological Dose Assessment for Residual Radioactive Material in Soil at the Clean Slate 

Sites 1, 2, and 3, Tonopah Test Range, DOE/NV-482, UC-700, June 1997 
C.1-3 

P1033, Double Tracks Test Site Characterization Report, DOE/NV-484, UC-700, May 1996 

P1036, Nevada Environmental Restoration Project Double Tracks Closure Report, DOE/NV-11718-

113, UC-802, June 1997 

P1088, Operation Roller Coaster, Project Officers Report – Project 2.6d, Special Particulate Analysis 

(Soil), POR-2509 (WT-2509), May 26, 1966 

P1096, Nevada Environmental Restoration Project, Clean Slate 1 Corrective Action Plan, 

DOE/NV/11718-100 (UC-700), April 1997 

P1099, Nevada Environmental Restoration Project, Double Tracks Interim Corrective Action Plan, 

DOE/NV/11718-112, June 1996 

P1107, Clean Slate Corrective Action Investigation Plan, DOE/NV-456, May 1996 

U1010, WEF Supervisor Logbook Excerpt, February 23, 2006 

U1011, WEF Visual Examination Expert Logbook Excerpt, February 23, 2006 

ID-NTLBL-S5400 and ID-NTLBL-S3900 

Acceptable Knowledge Accuracy Report, Waste Stream ID-NTLBL-S5400, Lot 1, November 10, 

2010 

Acceptable Knowledge Accuracy Report: Idaho National Laboratory Waste Stream ID-NTLBLS3900, Lot 1, May 25, 2010 

CCP-AK-INL-009, Central Characterization Project Acceptable Knowledge Summary Report for 

Idaho National Laboratory Nevada Test Site Lawrence Livermore National Laboratory Waste, 

Carlsbad, New Mexico, Washington TRU Solutions, LLC, Revision 1, May 19, 2009 

CCP-AK-INL-010, Central Characterization Project Acceptable Knowledge Summary Report for 

Idaho National Laboratory Nevada Test Site Lawrence Berkeley National Laboratory Waste, Waste 

Streams:ID-NTLBL-S5400, ID-NTLBL-S3900, Revision 0, June 18, 2009 

CCP-AK-NTS-3, Central Characterization Project Acceptable Knowledge Summary Report for 

Nevada Test Site Lawrence Berkeley Laboratory Waste, Carlsbad, New Mexico, Washington TRU 

Solutions, LLC, Revision 4, December 7, 2005 

CCP-PK-NTS-003, Central Characterization Project Process Knowledge Summary Report for 

Nevada Test Site Lawrence Berkeley National Laboratory Waste, Carlsbad, New Mexico, 

Washington TRU Solutions, LLC, Revision 8, November 6, 2008 

CCP-TP-005 Attachment 1, Documentation Checklist, ID-NTLBL-S3900, July 15, 2009 
C.1-4 

CCP-TP-005 Attachment 1, Documentation Checklist, ID-NTLBL-S5400, July 15, 2009 

CCP-TP-005 Attachment 4, Source Document Reference List, ID-NTLBL-S3900, July 15, 2009 

CCP-TP-005 Attachment 4, Source Document Reference List, ID-NTLBL-S5400, July 15, 2009 

CCP-TP-005 Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, Packaging, 

Waste Stream ID-NTLBL-S3900, June 11, 2009 

CCP-TP-005 Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, Packaging, 

Waste Stream ID-NTLBL-S5400, June 11, 2009 

CCP-TP-005 Attachment 7, Radiological Data ID-NTLBL-S3900, and associated AK-NDA 

Memorandum, June 25, 2009 

CCP-TP-005 Attachment 7, Radiological Data I ID-NTLBL-S5400, and associated AK-NDA 

Memorandum, June 25, 2009 

CCP-TP-005 Attachment 8, Drum List Waste Stream ID-NTLBL-S3900, June 11, 2009 

CCP-TP-005 Attachment 8, Drum List Waste Stream ID-NTLBL-S5400, June 11, 2009 

CCP Waste Stream Characterization Checklist, ID-NTLBL-S3900/S5400, September 25, 2009 

CCP-TP-005 Attachment 10, AK Re-Evaluation Checklist, ID-NTLBL-S5400, November 9, 2010 

CCP Waste Stream Characterization Checklist, ID-NTLBL-S5400, September 25, 2009 

INL NTS AK Tracking Spreadsheet, October 1, 2010 

LBNL-C-13, Lawrence Berkley Laboratory Defense Determination, July 8, 2003 

List of BDRs, ID-NTLBL-S5400 and S3900, dated November 8, 2010 

Waste Stream Profile Form, Waste Stream ID-NTLBL-S3900, March 25, 2010 

Waste Stream Profile Form, Waste Stream ID-NTLBL-S5400, March 25, 2010 

C101, Telecon between Jeff Harrison and Jim Haley/Harry Jelonic, LLNL - TRU Waste Generated at 

Lawrence Berkeley Laboratory, (LBL), March 24, 1998

C142, Calculation of Individual and Total Radionuclide Masses and Activities for Waste Stream 

ID-NTLBL-S5400, May 15, 2009 

DR002, Discrepancy Resolution – Additional Physical Form, February 20, 2005 
C.1-5 

P025, NTS TRU Waste Inventory Database, November 18, 1997 

P094, Acceptable Knowledge Document for NTS-Stored Transuranic Waste - Lawrence Berkeley 

Laboratory Waste, B-2151/00.03, August 2000 

P095, Bechtel Nevada TRU Waste Examination, Segregation, and Repacking Procedure, 

OP-2151.402, Revision 2, June 25, 2001 

P098, Central Characterization Project Acceptable Knowledge Summary Report for Ernest Orlando, 

Lawrence Berkeley National Laboratory Contact-Handled TRU Waste, Waste Stream 

BLCHDN.001 CCP-AK-LBNL-001, Revision 0, June 30, 2004 

U001, Assessment of Transuranic Waste Inventory Stored at the Nevada Test Site, April 18, 1991 

U003, Databases Used for the Inventory Assessments of the TRU Drums Stored at DOE’s Nevada 

Test Site (1974-1990), March 13, 1991 

U014, Uncontrolled NTS TRU Waste Inventory Details, March 1998 

U015, Uncontrolled NTS TRU Waste Inventory Details, March 1998 

U016, Excerpts from Nevada Test Site Shipping Records, 1974-1986 

U029, Building 612 Radioactive Waste Logbooks, 1974-1985 

U051, TRU Waste Packing Log, November 18, 2004 

U052, TRU_DS Database Information and TRU_DS User's Guide, OI-2151.401, Version 5.0, 

September 2000 

U061, Radiological Analysis for Waste Streams NTLBL-S5400 and NTLBL-S3900, January 2005 

U062, CCP-AK-LBNL-001 Shoebox and Liquid Treatment Chemical Data, January 2005 

U065, Real Time Radiography (RTR) and Radiography of LBL Containers at the Nevada Test Site, 

March 9, 2005, March 10, 2005, February 14, 2005, February 15, 2005 

U067, CCP NDA Radiological Re-Evaluation for the NTLBL-S5400 Waste Stream, September 2005 

U072, Container Spreadsheet (Scorecard), September 24, 2008 

U074, Visual Examination Expert Logbook (select entries from 7/11 – 7/23), April 7, 2005 through 

August 11, 2005 

U084, Holding Container Inventory Log, October 9, 2008 
C.1-6 

U085, Combined NDA Radiological Datasheets, various dates 

U103, Container Documentation and Prescreen Data for Waste Streams ID-NTLBL-S5400 and 

ID-NTLBL-S3900, various dates 

ID-SDA-DEBRIS, ID-SDA-SLUDGE, and ID-SDA-SOIL

Acceptable Knowledge Accuracy Report, Waste Stream ID-SDA-DEBRIS, Lots 1-28, April 15, 2010 

Acceptable Knowledge Accuracy Report, Waste Stream ID-SDA-SLUDGE, Lots 1-185, April 27, 

2010 

Acceptable Knowledge Accuracy Report, Waste Stream ID-SDA-SOIL, Lots 1-37, April 15, 2010 

CCP-AK-INL-001, Central Characterization Project Acceptable Knowledge Summary Report for 

Waste Retrieved from Designated Areas within the Subsurface Disposal Area at the Idaho National 

Laboratory Transuranic Waste Streams ID-SDA-DEBRIS, ID-SDA-SLUDGE, ID-SDA-SOIL, 

Revisions 6, 7, 8, and 9, February 7, 2008, October 27, 2008, September 8, 2009, and September 8, 

2010 

CCP-TP-005 Attachment 1, Documentation Checklist, Waste Stream: ID-SDA-DEBRIS, June 3, 

2010 

CCP-TP-005 Attachment 1, Documentation Checklist, Waste Stream: ID-SDA-SLUDGE, June 3, 

2010 

CCP-TP-005 Attachment 1, Documentation Checklist, Waste Stream: ID-SDA-SOIL, June 3, 2010 

CCP-TP-005 Attachment 4, Source Document Reference List, June 3, 2010 

CCP-TP-005 Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, Packaging, 

Waste Stream ID-SDA-DEBRIS, June 19, 2009 

CCP-TP-005 Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, Packaging, 

Waste Stream ID-SDA-SLUDGE, June 19, 2009 

CCP-TP-005 Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, Packaging, 

Waste Stream ID-SDA-SOIL, June 19, 2009 

CCP-TP-005 Attachment 7, Radiological Data ID-SDA-DEBRIS, ID-SDA-SLUDGE, ID-SDASOIL, and associated AK-NDA Memorandum, August 14, 2009 

CCP-TP-005 Attachment 10, AK Re-Evaluation Checklist, ID-SDA-SLUDGE, October 30, 2008 

CCP-TP-005 Attachment 10, AK Re-Evaluation Checklist, ID-SDA-SOIL, October 12, 2009 
C.1-7 

CCP AK Waste Stream Characterization Checklists, ID-SDA-DEBRIS, various lots, various dates 

CCP AK Waste Stream Characterization Checklists, ID-SDA-SLUDGE, various lots, various dates 

CCP AK Waste Stream Characterization Checklists, ID-SDA-SOIL, various lots, various dates 

INL AK ARP Tracking Spreadsheet, October 29, 2010 

PTS Screen Shot Drum ARP06227, provided November 17, 2010 

PTS Screen Shot Drum ARP15566, provided November 17, 2010 

PTS Screen Shot Drum ARP20413, provided November 17, 2010 

Waste Isolation Pilot Plant Container Data Report, Drum ARP06227, November 16, 2010 

Waste Isolation Pilot Plant Container Data Report, Drum ARP15566, November 16, 2010 

Waste Isolation Pilot Plant Container Data Report, Drum ARP20413, November 16, 2010 

Waste Stream Profile Form, Waste Stream ID-SDA-DEBRIS, February 21, 2007 

Waste Stream Profile Form, Waste Stream ID-SDA- SLUDGE, September 25, 2007 

Waste Stream Profile Form, Waste Stream ID-SDA-SOIL, Revision 1, October 7, 2009 

ID-C114, Email from Lisa Frost to Scott Smith and Carrie Johnson, Pit 9 & GEM & Lab Waste, 

March 11, 2010 

ID-P092, History of Buried Transuranic Waste at INEL, WPM 77-3, March 1, 1977 

ID-P377, Waste Management Plan for the OU 7-10 Glovebox Excavator Method Project, 

INEEL/EXT-02-00767, Revision 1, September 2003 

ID-P380, Health and Safety Plan for OU 7-10 Glovebox Excavator Method Project Operations, 

INEEL/EXT-02-01117, Revision 7, March 2004 

ID-P399, Idaho Completion Project’s Accelerated Retrieval Project Overview Of The Pit 4 NonTime Critical Removal Action, ICP/CON-04-00598 Preprint, February 27-March 3, 2005 

ID-P402, CH2M-WG Idaho Process Knowledge Summary Report for CH TRU Waste and Mixed 

Low-Level Waste Generated at INTEC and RWMC Analytical Laboratories in Support of AMWTP 

Sampling Activities, Waste Matrix Codes S5490 and S3900, RPT-670, Revision 2, January 2010 

 

ID-P403, Waste Disposition Plan for ICP Laboratory Activities, PLN-3007, Revision 0, February 23, 

2009 
C.1-8 

ID-P404, Analytical Laboratory Waste Management, ACLP-0.040, Revision 9, August 24, 2009 

ID-U313, Radioactive Waste Management Complex Map, G10-2355-07, not dated 

ID-U329, Visual Examination Data for ARP-I, December 11, 2006 

ID-U343, Non-Rocky Flats Shipping Records ARP-III (P06P01), July 31, 2008 

ID-U344, Non-Rocky Flats Shipping Records ARP-IV (P05P01), December 4, 1964 to December 13, 

1966 

ID-U345, Non-Rocky Flats Shipping Records ARP-V (P09P03-P09P04), November 13, 1967 to 

September 11, 1968 

ID-U355, GEM Assay Data and Drum Descriptions, July 2, 2008 

ID-U376, CERCLA Storage/Staging Area, RWMC- TRAILER 14-CARGO-A, CSA_1539N, July 

20, 2010 

ID-U377, Waste Determination & Disposition Form (WDDF), Sample Residue and Analytical Debris 

from ARP Samples, WDDF Number: RWMC10012.R1, July 22, 2010 

INTEC-P002, A History of the Radioactive Waste Management Complex at the Idaho National 

Engineering Laboratory, WM-F1-81-003, Revision 3, July 1, 1985 

RF-P356, Field Sampling Plan for the OU-7-10 Glovebox Excavator Method Project, INEEL/EXT02-00542, Revision 2, October 2, 2003 

RF-U1306, Rocky Flats shipping records for ARP-III (P06P01) in the RWMC SDA, February 12, 

1968 to September 3, 1968 

RF-U1307, Rocky Flats shipping records for ARP-IV (P05P01) in the TWMC SDA, July 22, 1964 to 

November 18, 1966 

RF-U1308, Rocky Flats shipping records for ARP- V (P09P03, P09P04) in the RWMC SDA, 

February 9, 1968 to September 24, 1968 
C.2-1 

ATTACHMENT C.2 

Acceptable Knowledge References – Remote-Handled Waste 

DOE/WIPP-02-3214, Remote-Handled TRU Waste Characterization Program Implementation Plan, 

Carlsbad, New Mexico, U.S. DOE Carlsbad, Revision 0d, October 30, 2003 

CCP-TP-506, CCP Preparation of the Remote-Handled Transuranic Waste Acceptable Knowledge 

Characterization Reconciliation Report, Revision 2, June 8, 2006 

RH INL AK Tracking Spreadsheet, September 27, 2010 

ID-HFEF-S5400-RH

CCP-AK-ANLE-501, Central Characterization Project Remote-Handled Transuranic Radiological 

Characterization Technical Report for Remote-Handled Transuranic Debris Waste From Argonne 

National Laboratory-East, Revision 2, May 10, 2010 

CCP-AK-INL-580, Central Characterization Project Acceptable Knowledge Summary Report 

For Remote-Handled Transuranic Debris Waste from Materials and Fuels Complex Hot Fuel 

Examination Facility at the Idaho National Laboratory Waste Stream ID-HFEF-S5400-RH, Revision 

2, June 1, 2010 

CCP-AK-INL-581, Central Characterization Project Remote-Handled Transuranic Radiological 

Characterization Technical Report For Remote-Handled Transuranic Debris Waste from the Hot Fuel 

Examination Facility (HFEF) at the Idaho National Laboratory, Revision 1, April 30, 2010 

CCP-AK-INL-582, Central Characterization Project RH TRU Waste Certification Plan for 40 CFR 

Part 194 Compliance and Confirmation Test Plan for INL RH Waste Stream: ID-HFEF-S5400-RH, 

Revision 1, May 27, 2010 

CCP-TP-005 Attachment 1, Documentation Checklist, ID-HFEF-S5400-RH, July 15, 2009 

CCP-TP-005 Attachment 4, Source Document Reference List, ID-HFEF-S5400-RH, November 10, 

2010 

CCP-TP-005 Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, Packaging, 

Waste Stream ID-HFEF-S5400-RH, November 12, 2009 

CCP-TP-005 Attachment 8, Drum List Waste Stream ID-HFEF-S5400-RH, November 12, 2009 

Draft Acceptable Knowledge Accuracy Report, Waste Stream ID-HFEF-S5400-RH, Lots 1-9, 

October 12, 2009 
C.2-2 

NCR-RHINL-0500-10, Surface Dose Rate for Container IDAWANL870105A measured 70 mrem/hr, 

not the required 200 mrem/hr, February 10, 2010 

NCR-RHINL-0507-10, Addition of containers to the AK tracking spreadsheet, May 25, 2010 

NCR-RHINL-0514-10, Identification of negative container weight on a waste conversion record, 

October 18, 2010 

NCR-RHINL-0515-10, Drums N154B, N153A and SN151A did not meet the decay heat limits 

specified in approved RH-TRUCON codes, November 2, 2010 

PTS screen shots for waste drum SN152A, provided November 16, 2010 

Waste Stream Profile Form for Waste Stream ID-HFEF-S5400-RH, February 12, 2010 

WDS Print-out 133 HFEF Drums, Drum SN152A, as of November 13, 2010 

ID-INTEC-RH

Acceptable Knowledge Accuracy Report: Idaho National Laboratories Waste Stream Number IDINTEC-RH, Lot 1, November 5, 2010 

CCP-AK-INL-550, Central Characterization Project Acceptable Knowledge Summary Report for 

Stored Remote-Handled Transuranic Debris from the Idaho Nuclear Technology and Engineering 

Center at the Idaho National Laboratory Waste Stream ID-INTEC-RH, Revision 1, March 22, 2010 

CCP-AK-INL-551, Central Characterization Project Radiological Characterization Technical Report 

for the Idaho Nuclear Technology and Engineering Center (INTEC) Remote-Handled Transuranic 

Debris Waste, Revision 0, October 20, 2009 

CCP-AK-INL-552, Central Characterization Project RH TRU Waste Certification Plan for 40 CFR 

Part 194 Compliance and Confirmation Test Plan for INL Waste Stream: ID-INTEC-RH, Revision 0, 

April 2, 2009 

CCP-AK-INL-555, Central Characterization Project Sampling and Analysis Plan, for Stored RemoteHandled Transuranic Debris from the Idaho Nuclear Technology and Engineering Center at the Idaho 

National Laboratory, Revision 0, March 9, 2009 

CCP-TP-005 Attachment 1, Documentation Checklist, ID-INTEC-RH, December 16, 2009 

CCP-TP-005 Attachment 4, Source Document Reference List, ID-INTEC-RH, November 10, 2010 

CCP-TP-005, Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, Packaging, 

Waste Stream ID-INTEC-RH, November 12, 2009 

CCP-TP-005, Attachment 8, Drum List Waste Stream ID-INTEC-RH, November 12, 2009 
C.2-3 

NCR-RHINL-0501-10, Container IDICOOOO00427 was sampled for radiochemistry analysis to 

develop the scaling factors. The analytical laboratory has sample residues to be placed back into the 

drum. The dose is too high on the sample residues to dispose as laboratory waste, March 16, 2010 

NCR-RHINL-D502-10, New Sample Measurement and Conversion Record, March 16, 2010 

NCR-RHINL-0504-09, The amount of organic waste by volume was not recorded for the containers 

listed in box 3, June 1, 2009 

NCR-RHINL-0507-09, Misidentification of Smear Sample as Solid Sample, September 9, 2009 

NCR-RHINL-0512-09, The scaling factors used to calculated the results in BDR INLRHDTC09004 

for the containers listed in Block 3 were incorrect, December 8, 2009 

PTS Screen Shots Containers IDIC000000427 and 460, November 8, 2010 

Waste Stream Profile Form, ID-INTEC-RH, September 15, 2010 

WDS Screen Shots, INTEC Stream, November 9, 2010 

ID-MFC-S5400-RH

CCP-AK-INL-540, Central Characterization Project Acceptable Knowledge Summary Report for 

Remote-Handled Transuranic Waste from the Materials and Fuels Complex at the Idaho National 

Laboratory Waste Streams ID-MFC-S5400-RH and ID-MFC-SOLID-RH, Revision 2, November 8, 

2010 

CCP-AK-INL-541, Central Characterization Project Radiological Characterization Technical Report 

for Remote-Handled Transuranic Debris Waste from the Materials and Fuels Complex at the Idaho 

National Laboratory, Revision 1, December 2, 2009 

CCP-AK-INL-542, Central Characterization Project RH TRU Waste Certification Plan for 40 CFR 

Part 194 Compliance and Confirmation Test Plan for INL Waste Stream: ID-MFC-S5400-RH, 

Revision 0, July 28, 2008 

CCP-TP-005 Attachment 1, Documentation Checklist, ID-MFC-S5400-RH, May 25, 2010 

CCP-TP-005 Attachment 4, Source Document Reference List, ID-MFC-S5400-RH, June 10, 2010 

CCP-TP-005, Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, Packaging, 

Waste Stream ID-MFC-S5400-RH, June 10, 2010 

CCP-TP-005, Attachment 8, Drum List Waste Stream ID-MFC-S5400-RH, February 2, 2010 

Draft Acceptable Knowledge Accuracy Report: Idaho National Laboratories Waste Stream Number 

ID-MFC-S5400-RH, April 15, 2010 
C.2-4 

NCR-RHINL-0509-10, The ITR did not properly review the Audio/Video for container 

IDAWANL880065A. The RTR operator called out the wrong date and the ITR did not resolve this 

with the RTR operator, July 20, 2010 

PTS Screen Shots Containers IDAWANL880064A, 64B, 65A, 65B, 68A, 68B, 134A, and 134B, 

November 8, 2010 

Waste Stream Profile Form, ID-MFC-S5400-RH, June 24, 2010 

WDS Shipping Information Spreadsheet, ID-MFC-S5400, November 9, 2010 
C.3-1 

ATTACHMENT C.3 

Nondestructive Assay References 

Audit Information summarizing numbers of containers and specific configurations assayed each year 

2007 through 2010, prepared for inspection by Stephanie McElhaney 

CCP WAGS Procedure: CCP-TP-010, Revision 3 

CCP-Idaho National Laboratory List of Qualified Individuals, 11/15/1010, 3:21:27 PM, 14 pages, 

prepared at request of EPA Inspectors 

CCP-INL-WAGS-08-002, WAGS Multi-Curve Efficiency Calibration Extension Addendum, 

Revision 0, April 10, 2008; 16 pages 

CCP-INL-WAGS-10-005, September 20. 2010, Calibration Verification of the WAGS System after 

Detector Replacement and Energy Calibration 

CCP-SHENC-10-002, Revision 0, INL SuperHENC 2-Puck SWB Interfering Matrix Measurements, 

May 10, 2010 

CCP-SHENC-10-003, Revision 0, INL SuperHENC 55-Gallon Combustible Interfering Matrix 

Measurements, May 10, 2010 

CCP-SHENC-10-004, Revision 0, INL SuperHENC Weekly Interfering Matrix Measurements, 

September 27, 2010 

CCP-TP-109, Revision 6; CCP Data Reviewing, Validating and Reporting Procedure 

CCP-TP-146, Revision 7; CCP SuperHENC Operating Procedure 

CCP-TP-148, Revision 5; CCP SuperHENC Data Reviewing, Validating and Reporting Procedure 

CCP-TP-170, Revision 2; CCP SuperHENC Calibration Procedure 

Operator Aid posted in WAGS Control Area: CCP-INL-174, WAGS Pulser Parameter Data, Peak 

Centroid Limits, dated December 21, 2009 

Standing Order posted in WAGS Control Area: CCP-INL-06-007, Pulser Monitoring, dated June 7, 

2006 

Standing Orders posted in WAGS Control Area: CCP-INL-005-003; CCP-INL-150; CCP-INL-009 

Summary of Drums Assayed on SGRS, WAGS and HENC, January 2010 to November 16, 2010, 

prepared for inspection by Preston Abbott 
C.3-2 

SuperHENC BDR No. INNDA BO9016 

SuperHENC Calibration Report: BII-5221-CVR-001, Revision 0 

SuperHENC Operational Logbook, page 40, corresponding to day of EPA inspection 

WAGS Batch Data Report INNDAW0090241, consisting of two drums, ARP10173 and ARP10403 

WAGS Operational Logbook, page 133, corresponding to day of EPA inspection