DOCKET NO: A-98-49; II-A4-193 

EPA eDocket NO: EPA-HQ-OAR-2001-0012-0443 

WASTE CHARACTERIZATION REPORT 

TIER 1 CHANGE EVALUATION: 

VISUAL EXAMINATION OF CONTACT HANDLED TRANSURANIC WASTE 

PERFORMED BY THE CENTRAL CHARACTERIZATION PROJECT 

AT THE OAK RIDGE NATIONAL LABORATORY

August 5–6, 2014 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

November 2014
i 

TABLE OF CONTENTS 

Abbreviations and Acronyms ......................................................................................................... ii

1.0 Introduction ..........................................................................................................................1

2.0 Purpose of Tier 1 Evaluations ..............................................................................................4

3.0 Purpose of This Report ........................................................................................................4

4.0 Scope of Review ..................................................................................................................4

5.0 Evaluation Personnel ...........................................................................................................5

6.0 Technical Evaluation of Visual Examination ......................................................................5

7.0 Conclusions ..........................................................................................................................6

LIST OF TABLES 

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

Implemented by ORNL-CCP ......................................................................................... 2

Table 2. Evaluation Personnel ........................................................................................................ 5

ATTACHMENTS 

Attachment A Approval Summary for ORNL-CCP Contact-Handled Waste Characterization 

Program 

Attachment B Visual Examination for Contact-Handled Waste Checklist 
ii 

ABBREVIATIONS AND ACRONYMS 

AK acceptable knowledge 

AKE Acceptable Knowledge Expert 

AKSR acceptable knowledge summary report 

BDR batch data report 

CBFO Carlsbad Field Office 

CCP Central Characterization Program 

CFR Code of Federal Regulations 

CH contact-handled 

CIS characterization information summary 

DOE U.S. Department of Energy 

DWAS Digital Waste Assay System 

EA Expert Analyst 

EPA U.S. Environmental Protection Agency 

IPAN imaging passive active neutron 

ISOCS In Situ Object Counting System 

ITR Independent Technical Reviewer 

LOQI list of qualified individuals 

MCS Mobile Characterization Services 

MILCC2 Mobile ISOCS Large Container Counter-2 

NCR nonconformance report 

NDA nondestructive assay 

NDE nondestructive examination 

NFS Nuclear Fuel Services 

OJT on-the-job training 

ORNL Oak Ridge National Laboratory 

QA quality assurance 

QAPP Quality Assurance Project Plan 

RH remote-handled 

RTR real-time radiography 

SC&A S. Cohen and Associates (SC&A, Inc.) 

SCG summary category group 
iii 

SGS segmented gamma scanner 

SME subject matter expert 

SPM Site Project Manager 

T1 Tier 1 

T2 Tier 2 

TRU transuranic 

VE visual examination 

VEE visual examination expert 

WDS Waste Data System 

WIPP Waste Isolation Pilot Plant 

WMC waste matrix code 

WMP waste material parameters 

WSPF waste stream profile form 
1 

1.0 INTRODUCTION 

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

(T1) change for the Central Characterization Program (CCP) to resume use of visual examination 

(VE) for characterization of contact-handled (CH) transuranic (TRU) waste at the Oak Ridge 

National Laboratory (ORNL). Specifically, ORNL-CCP is approved to resume VE 

characterization for heterogeneous debris [summary category group (SCG) S5000] and soils 

(SCG S4000). In accordance with Title 40 of the Code of Federal Regulations (40 CFR) 

194.8(b), EPA conducted a baseline inspection of CCP’s waste characterization program for CH 

TRU wastes at the U.S. Department of Energy’s (DOE’s) ORNL in Oak Ridge, TN, in 2008. As 

a result, EPA approved the ORNL-CCP CH TRU waste characterization program (see EPA 

Docket No. A-98-49, II-A4-103). 

On March 24, 2010, EPA granted T1 approval for ORNL-CCP to characterize CH TRU S4000 

and S5000 waste using VE (see EPA Docket No. A-98-49, II-A4-125). ORNL-CCP suspended 

operations for a time and resumed them in 2014. Therefore, on February 4–6, 2014, EPA 

conducted a continued compliance inspection of the ORNL-CCP waste characterization program 

and approved the resumption of the ORNL-CCP CH and remote-handled (RH) TRU waste 

characterization programs (see EPA Docket No. A-98-49, II-A4-186). However, EPA did not 

include the CH VE process in the 2014 continued compliance inspection scope because ORNLCCP was not prepared to use or demonstrate the process. EPA did not observe and review the 

CH VE process during the continued compliance inspection, therefore, EPA identified resumed 

use of the CH VE process as a separate T1 evaluation. EPA’s reviews and approvals of ORNLCCP’s CH waste characterization program are listed in Attachment A. 

On May 30, 2014, the Carlsbad Field Office (CBFO) requested a T1 change to add VE for SCG 

S4000 and S5000 CH TRU waste. EPA evaluated the proposed T1 change by reviewing ORNLCCP documents and conducting an onsite inspection of VE at ORNL on August 5–6, 2014. EPA 

determined that the VE process is technically adequate for characterizing S4000 and S5000 CH 

TRU waste. 

Based on the results of this T1 evaluation, EPA revised the VE T1 designation to reflect EPA’s 

approval of VE for SCG S4000 and S5000 CH TRU waste and state explicitly that any use of VE 

to characterize CH TRU homogenous solid (SCG S3000) is a T1 change. Table 1 shows the T1 

change in bold text. T1 and Tier 2 (T2) changes that were initiated during the CH baseline and as 

modified as a result of subsequent T1 and continued compliance approvals remain in effect. The 

language in Table 1 regarding AK documentation applies to all ORNL-CCP waste streams. 

EPA did not identify any findings or concerns during this T1 evaluation. 

This report serves as EPA’s public notification of the results of the proposed T1 change and its 

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

WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3). 
2 

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

(Based on November 13–15, 2007, Baseline Inspection and Subsequent Inspections and Evaluations, Upd

Process Elements ORNL-CCP CH Waste Characterization Process – T1 Changes ORNL-CCP CH Waste Characteriz

Acceptable Knowledge, 

including Load Management 

Any new waste category other than retrievably stored debris, soils/gravel and solids (i.e., any type of newly generated waste) 

Load management 

Submission of a list of active ORNL-CCP Notification to EPA upon completion of o

• AK accuracy reports (annually, at a mi

• AK-AK and AK-NDA/NDE Discrepan

• WSPFs and related attachments (e.g., C

streams, including change notices 

• AKSRs (new and updated versions) 

• CCP-TP-005, Attachments 4, 6, 7 and 

including “Add Container” memorand

• Site AK procedures requiring CBFO a

Nondestructive Assay New equipment or substantive physical modifications** to approved 

equipment

Extension of or changes to approved calibration range for approved equipment Relocation of MILCC2 onsite or other activities that require system recalibration Addition of new measurement configurations or container types 

Submission of a list of ORNL-CCP NDA performed work during the previous quartNotification to EPA upon substantive mod

• Software for approved equipment 

• Operating ranges upon CBFO approva• Site NDA procedures requiring CBFO 

Notification to EPA upon successful calibfollowing on-site relocation or other equip

Real-Time Radiography None Submission of a list of ORNL-CCP RTR o

work during the previous quarter Notification to EPA upon: 

• New equipment or substantive physica

equipment 

• Substantive modification** to site RTR 

approval 

Visual Examination and 

Visual Examination Technique 

Use of VE to characterize homogenous solid CH TRU waste 

(SCG 3000) 

Submission of a list of ORNL-CCP VE opperformed work during the previous quart

WIPP Waste Data System Load management Notification to EPA upon substantive mod

procedures requiring CBFO approval 

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

* ORNL-CCP will report all T2 changes to EPA every three months. 
3 

** “Substantive modification” refers to a change with the potential to affect ORNL-CCP’s CH waste characterization processes or documentat

that are solely related to the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act, or that are editoriaaddress administrative concerns. EPA may request copies of new references that DOE adds during a document revision. 
4 

2.0 PURPOSE OF TIER 1 EVALUATIONS 

Certain changes to the waste characterization activities from the date of the site’s baseline 

inspection must be reported to and, if applicable, approved by EPA according to the tiering 

requirements set forth in 40 CFR 194.8 regulations and incorporated into the ORNL-CCP 

baseline final report (see EPA Docket No. A-98-49, II-A4-103). 

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

(Vol. 69, No. 136, pages 42571–42583), EPA must perform a single baseline inspection of a 

TRU waste generator site’s waste characterization program. The purpose of EPA’s baseline 

inspection is to approve the site’s waste characterization program, based on the demonstration 

that the program’s components, with applicable conditions and limitations, can adequately 

characterize TRU wastes and comply with the regulatory requirements imposed on TRU wastes 

destined for disposal at the WIPP. 

Following EPA’s baseline approval, EPA is 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). Changes requiring EPA notification and 

approval prior to implementation (T1) and those requiring post-implementation notification (T2) 

are identified in the site-specific baseline inspection reports and subsequent T1 evaluation 

reports. When evaluating proposed T1 changes for approval, EPA may conduct a site inspection 

to observe implementation of the change or can opt to conduct a desktop review of information 

provided specific to a change. DOE may choose to characterize and dispose of any previously 

approved TRU waste using processes, procedures or equipment implemented as T2 changes at 

risk of subsequent EPA disapproval. 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of EPA’s evaluation of a T1 change to allow ORNL-CCP to 

resume use of VE for characterization of SCG S4000 and S5000 CH TRU waste. This report 

documents the basis for EPA’s approval decision and explains the results of the technical 

evaluation of the process, including any limitations. EPA’s approval decision regarding resumed 

use of VE has been conveyed to DOE separately by letter. EPA will also announce the decision 

on its website at www.epa.gov/radiation/wipp, in accordance with 40 CFR 194.8(b)(3). 

Documents provided by CBFO for this evaluation and listed in Section 6.2 of this report can be 

requested from CBFO at the following address: 

U.S. Department of Energy 

Carlsbad Field Office 

TRU Sites and Transportation Division 

P.O. Box 3090 

Carlsbad, NM 88221-3090 

4.0 SCOPE OF REVIEW 

The scope of EPA’s T1 evaluation is the VE process used to characterize CH TRU SCG S4000 

and S5000 waste. EPA evaluated this proposed change request in accordance with 40 CFR 
5 

194.8(b) to assess the technical adequacy, implementation and effectiveness of ORNL-CCP’s 

VE process to characterize CH TRU S4000 and S5000 waste. EPA evaluated personnel 

qualifications and training, and operating procedures to assess the technical adequacy of the VE 

process for CH TRU waste. 

5.0 EVALUATION PERSONNEL 

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

affiliations and T1 evaluation functions. 

Table 2. Evaluation Personnel 

6.0 TECHNICAL EVALUATION OF VISUAL EXAMINATION 

On August 5–6, 2014, EPA evaluated the CH VE operations at ORNL-CCP. The evaluation 

included review of documents and records, observation of VE operations and interviews with 

ORNL-CCP VE personnel. 

Records and Documentation Reviewed 

Prior to and during the on-site visit, the EPA inspectors reviewed the following documents and 

other VE-related records: 

• CCP-TP-113, CCP Standard Contact-Handled Waste Visual Examination, Revision 18, 

September 25, 2013. 

• CCP-PO-001, CCP Transuranic Waste Characterization Quality Assurance Project Plan, 

Revision 21, May 31, 2013. 

• CCP-QP-002, CCP Training and Qualification Plan, Revision 38, August 7, 2014. 

• CCP-QP-005, CCP TRU Nonconforming Item Reporting and Control, Revision 24, July 29, 

2014 

• CCP-TP-001, CCP Project Level Data Validation and Verification, Revision 21, June 6, 

2013. 

• CCP-AK-ORNL-002, Acceptable Knowledge Report for Waste Stream OR-REDC-CH—

HET, Revision 3, April 29, 2014. 

• Qualification Cards for selected VE operators. 

Name Affiliation & Function 

Ed Feltcorn Lead Inspector, U.S. EPA 

Dorothy Gill Technical Evaluator – Visual Examination, SC&A 

Anthony Harley CCP, Visual Examination Expert 

Shelley Martinez CCP, Cognizant Engineer 

Chuck (David) Wallace CCP, Visual Examination Operator/Independent Technical Reviewer 

Jason Cofer CCP, Visual Examination Operator/Independent Technical Reviewer 

Irene Joo URS, RH Program Manager 
6 

• Qualification Card for VE Expert (VEE). 

• VEE appointment letter dated October 14, 2013. 

• List of Applicable Waste Streams Qualified, dated October 14, 2013, for VEE. 

• LOQI for VE personnel dated July 9, 2014. 

• ORNL NDE Personnel Waste Streams Qualified List dated July 9, 2014. 

• CH VE Batch Data Report (BDR) Nos. ORVECH0101, ORVECH0102, ORVECH0106, 

ORVECH0107, ORVECH0109. 

• Completed Attachment 2, CCP Waste Visual Examination Data Form, for container 

X10C0402896F. 

• Nonconformance report (NCR) No. NCR-ORNL-0159-14. 

• Nonconformance report (NCR) No. NCR-ORNL-0702-14.

EPA has reviewed ORNL-CCP VE documents on many previous inspections. EPA determined 

that the procedures continue to provide adequate, appropriate and complete instructions for 

performance of applicable VE processes and operations. There were no concerns regarding the 

adequacy of the VE documents. 

Observation of CH VE Operations 

EPA observed the VE event in Building 7880 at the ORNL Transuranic Waste Processing 

Center. The VE event used container No. X10C0402896F from SCG S5000 Waste Stream ORREDC-CH-HET. ORNL site personnel performed the actual handling of the waste in a glovebox under the direction of ORNL-CCP VE personnel. The ORNL-CCP personnel examined the 

waste, identified each waste item as required and recorded the process. Upon completion of the 

VE inspection, ORNL placed the waste in a new 55-gallon drum, output container No. 

X10C0402896F1. EPA reviewed the completed data sheets for the demonstration container and 

determined that they contained all required information. There were no concerns regarding 

ORNL-CCP’s performance and documentation of VE for CH TRU wastes. 

ORNL-CCP CH VE operations and processes are performed and recorded in accordance with 

applicable requirements of 40 CFR Part 194 and ORNL-CCP procedures. 

7.0 CONCLUSIONS 

Changes to Tiering 

Based on the results of this T1 evaluation, EPA revised the VE T1 designation to reflect EPA’s 

approval of VE for SCG S4000 and S5000 CH TRU waste to state explicitly that any use of VE 

to characterize CH TRU homogenous solid (SCG S3000) is a T1 change (see Table 1). 
7 

Approval 

During this T1 change evaluation, EPA examined the use of the VE process to characterize SCG 

S4000 and S5000 CH TRU waste. Based on the results of this evaluation, EPA approves this T1 

change consistent with the limitations specified in this report. 
A-1 

ATTACHMENT A 

APPROVAL SUMMARY FOR ORNL-CCP CONTACT-HANDLED WASTE

CHARACTERIZATION PROGRAM 

Approved Activity EPA Inspection Number, 

Approval Dates EPA Docket Number 

ORNL-CCP CH Baseline Approval EPA-ORNL-CCP-CH-11.07-8, 

August 21, 2008 A-98-49, II-A4-103 

T1 Change – Extension of the Calibration and Density 

Ranges for the SGS NDA System October 8, 2008 A-98-49; II-A4-108 

T1 Change – Extension of the Passive Mode 

Calibration Range for the DWAS/IPAN SGS January 8, 2009 A-98-49, II-A4-109 

T1 Change – Addition of SCG S4000 October 7, 2009 A-98-49, II-A4-117 

Unannounced Continued Compliance Inspection November 23, 2009 A-98-49, II-A4-121 

T1 Change – Addition of the MCS IQ3 NDA System 

and Visual Examination March 30, 2010 A-98-49, II-A4-125 

T1 Change – Addition of NFS Trench B Soils to 

Waste Stream OR-NFS-CH-SOIL March 23, 2011 A-98-49; II-A4-144 

Continued Compliance Inspection June 18, 2014 A-98-49; II-A4-186 

T1 Change – Addition of MILCC2 NDA System October 21, 2014 A-98-49; II-A4-192 
B-1 

ATTACHMENT B 

VISUAL EXAMINATION FOR CONTACT-HANDLED WASTE CHECKLIST 

EPA Inspection No.: CCP-ORNL-T1-2014 Inspec

Establishment of Required 

Technical Elements in 

Procedures 

Execution of Procedures Objective Evidence and Additional C

CHVE-1 Site procedures identify required training and qualifications for CHVE personnel. CCP-QP-002, Revision 38

Formal training elements include: project requirements, container identification and labeling, applicable state and federal regulations Site-specific training program: OJT, identification of summary category groups, WMPs, packaging configurations, residual liquids 

EPA has reviewed the CCP training procedure on numerous 

it to be comprehensive and fully implemented. The training includes the required elements of examination, OJT, and fo

Objective evidence:

1. Qualification Cards for selected VE operators. 

2. VEE appointment letter dated October 14, 2013. 3. List of Applicable Waste Streams Qualified for VEE d

4. LOQI for VE personnel dated July 9, 2014. 5. ORNL NDE Personnel Waste Streams Qualified List d

CHVE-2 Operator qualification and requalification requirements are 

described. CCP-QP-002, Revision 38, s. 4.3.6, 44.4.1

To become qualified, the CHVE operator must pass a comprehensive written test with an 80 percent or better grade that addresses VE operations, documentation, characterization, formal training elements, and procedural elements. VE Operators must demonstrate capability in the presence of the site VEE during OJT. However, the formal and OJT training is conducted by a qualified SME. 

EPA reviewed the Qualification Cards for several VE opera

operators were correctly trained and the training records weObjective evidence: 

1. Qualification Cards for selected VE operators. 

2. VEE appointment letter dated October 14, 2013. 3. List of Applicable Waste Streams Qualified for VEE d

4. LOQI for VE personnel dated July 9, 2014. 5. ORNL NDE Personnel Waste Streams Qualified List d

CHVE-3 Each site has a designated VEE. CCP-QP-002, Revision 38, s. 4.4.1 CCP-PO-001, QAPP, Revision 21 

VEE designation is documented VEE has knowledge of the CH TRU waste being characterized Responsible for overall direction and implementation of VE at the facility Certification Plan specifies the selection, qualification, and training requirements of VEE 

The VEE is available on-site but is not necessarily present f

is knowledgeable with regard to the VE processes employeexamined. Objective evidence: 

1. Qualification Card for VEE. 

2. VEE appointment letter dated October 14, 2013. 3. List of Applicable Waste Streams Qualified for VEE d

4. LOQI for VE personnel dated July 9, 2014. 5. ORNL NDE Personnel Waste Streams Qualified List d
B-2 

Establishment of Required 

Technical Elements in 

Procedures 

Execution of Procedures Objective Evidence and Additional C

CHVE-4 Procedures and technical guidance documents provide complete instructions for performing CHVE. CCP-TP-113, Revision 18, section 4.0 

• 100% of containers will be subject 

to VE at the time of packaging 

• Waste Stream Description and 

WMC verified 

• Presence/absence of prohibited 

items confirmed 

• Two operators used even if 

audio/visual recording of VE is generated 

EPA observed the VE event for S5400 container No. X10CX10C0402896F1) from Waste Stream OR-REDC-CH-HETperformed the VE processes in accordance with CCP-TP-1VE data. Objective evidence: 

1. Completed Attachment 2, CCP Waste Visual Examina

container No. X10C0402896F. 

2. Qualification Cards for VE operators performing the V

3. VEE appointment letter dated October 14, 2013. 

4. List of Applicable Waste Streams Qualified, dated Oct

5. LOQI for VE personnel dated July 9, 2014. 

6. ORNL NDE Personnel Waste Streams Qualified List d

7. BDR Nos. ORVECH0101, ORVECH0102, ORVECH0

ORVECH0109. 

CHVE-5 Corrective actions are taken when necessary. CCP-QP-005, Revision 24

Operators were able to describe how they initiate a corrective action 

EPA reviewed NCR Nos. NCR-ORNL-0159-14 and NCR-initiated for containers in BDR No. ORVECH0101. These processed and closed in accordance with CCP procedures. Objective evidence: 

1. NCR-ORNL-0159-14. 

2. NCR-ORNL-0702-14. 

3. BDR Nos. ORVECH0101, ORVECH0102, ORVECH0

ORVECH0109. 

CHVE-6 Site procedure(s) require data generation and project level reviews of BDRs. CCP-TP-001, Revision 21

• ITR review Attachment 2 

• SPM review Attachment 3 

EPA verified that the required reviews were performed for ITR and SPM reviews had been completed and signed by thObjective evidence: 

1. Completed Attachment 2, CCP Waste Visual Examinat

container No. X10C0402896F. 

2. BDR Nos. ORVECH0101, ORVECH0102, ORVECH0

ORVECH0109. 
B-3 

Establishment of Required 

Technical Elements in 

Procedures 

Execution of Procedures Objective Evidence and Additional C

CHVE-7 Records are available for review. 

Lifetime/QA records – Attachments 1-5, Copy of NCRs QA/nonpermanent records – VHS tape or DVD (primary and backup) 

ORNL-CCP was able to provide all documents and records 

Objective evidence: 

1. Completed Attachment 2, CCP Waste Visual Examina

container No. X10C0402896F. 

2. Qualification Cards for VE operators performing the V

3. VEE appointment letter dated October 14, 2013. 

4. List of Applicable Waste Streams Qualified for VEE, d

5. LOQI for VE personnel dated July 9, 2014. 

6. ORNL NDE Personnel Waste Streams Qualified List d

7. BDR Nos. ORVECH0101, ORVECH0102, ORVECH0

ORVECH0109.