### 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 W ASTE
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 2014i 

### 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 Was te 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 Checklistii 

### 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 groupiii



### 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 form1



### 1.0 INTRODUCTION

This report supports the U.S. Environmental Protect ion Agency’s (EPA’s) approval of a Tier 1 (T1) change for the Central Characterization Progra m (CCP) to resume use of visual examination (VE) for characterization of contact-handled (CH) t ransuranic (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 Cod e of Federal Regulations (40 CFR) 194.8(b), EPA conducted a baseline inspection of CC P’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 ch aracterization 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-98-4 9, II-A4-125). ORNL-CCP suspended operations for a time and resumed them in 2014. The refore, 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 com pliance inspection scope because ORNLCCP was not prepared to use or demonstrate the proc ess. EPA did not observe and review the CH VE process during the continued compliance inspe ction, therefore, EPA identified resumed use of the CH VE process as a separate T1 evaluatio n. 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) r equested a T1 change to add VE for SCG S4000 and S5000 CH TRU waste. EPA evaluated the pro posed T1 change by reviewing ORNLCCP documents and conducting an onsite inspection o f VE at ORNL on August 5–6, 2014. EPA determined that the VE process is technically adequ ate for characterizing S4000 and S5000 CH

TRU waste.

Based on the results of this T1 evaluation, EPA rev ised 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 tha t 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 appl ies to all ORNL-CCP waste streams.

EPA did not identify any findings or concerns durin g 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 throu gh the EPA website and by emails to the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3 ).2Table 1. Tiering of Contact-Handled Transuranic Waste Characterization Processes Implemented by ORNL-CCP(Based on November 13–15, 2007, Baseline Inspectionand Subsequent Inspections and Evaluations, Updated October 2014)Process ElementsORNL-CCP CH Waste Characterization Process – T1 ChangesORNL-CCP CH Waste Characterization Process – T2 Changes*Acceptable Knowledge,including LoadManagementAny new waste category other than retrievably stored debris,soils/gravel and solids (i.e., any type of newly generated waste)Load managementSubmission of a list of active ORNL-CCP CH AKEs andSPMsNotification to EPA upon completion of or substantive modification** to:•AK accuracy reports (annually, at a minimum)•AK-AK and AK-NDA/NDE Discrepancy Resolution Reports•WSPFs and related attachments (e.g., CIS) for all new or modified wastestreams, including change notices•AKSRs (new and updated versions)•CCP-TP-005, Attachments 4, 6, 7 and 8 and/or associated memoranda,including “Add Container” memoranda•Site AK procedures requiring CBFO approvalNondestructive Assay New equipment or substantive physical modifications** to approvedequipmentExtension of or changes to approved calibration range for approvedequipmentRelocation of MILCC2 onsite or other activities that require systemrecalibrationAddition of new measurement configurations or container typesSubmission of a list of ORNL-CCP NDA operators, EAsand ITRs thatperformed work during the previous quarterNotification to EPA upon substantive modification**to:•Software for approved equipment•Operating ranges upon CBFO approval•Site NDA procedures requiring CBFO approvalNotification to EPA upon successful calibration verification of MILCC2following on-site relocation or other equipment changesReal-Time Radiography NoneSubmission of a list of ORNL-CCP RTR operators andITRs that performedwork during the previous quarterNotification to EPA upon:•New equipment or substantive physical modifications** to approvedequipment•Substantive modification** to site RTR procedures requiring CBFOapprovalVisual Examination andVisual ExaminationTechniqueUse of VE to characterize homogenous solid CH TRU waste(SCG 3000)Submission of a list of ORNL-CCP VE operators, VE Experts and ITRs thatperformed work during the previous quarterWIPP Waste Data System Load managementNotification to EPA upon substantive modification**to site WDSprocedures requiring CBFO approvalNew T1s, T2s and significant modifications to existing T1s or T2s are inboldtext; T1s or T2s that were only revised for styleare not shown in bold.* ORNL-CCP will report all T2 changes to EPA everythree months.3** “Substantive modification” refers to a change with the potential to affect ORNL-CCP’s CH waste characterization processes or documentation of them, excluding changesthat are solely related to the environment, safetyand health; nuclear safety; or the Resource Conservation and Recovery Act, or that are editorial in nature or are required toaddress 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 activ ities 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 th e July 16, 2004, Federal Register notice (Vol. 69, No. 136, pages 42571–42583), EPA must per form a single baseline inspection of a TRU waste generator site’s waste characterization p rogram. The purpose of EPA’s baseline inspection is to approve the site’s waste character ization program, based on the demonstration that the program’s components, with applicable cond itions and limitations, can adequately characterize TRU wastes and comply with the regulat ory requirements imposed on TRU wastes destined for disposal at the WIPP.

Following EPA’s baseline approval, EPA is authorize d to evaluate and approve changes, if necessary, to the site’s approved waste characteriz ation 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 req uiring post-implementation notification (T2) are identified in the site-specific baseline inspec tion reports and subsequent T1 evaluation reports. When evaluating proposed T1 changes for ap proval, 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 ch aracterize and dispose of any previously approved TRU waste using processes, procedures or e quipment implemented as T2 changes at risk of subsequent EPA disapproval.

3.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluatio n 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 limitation s. EPA’s approval decision regarding resumed use of VE has been conveyed to DOE separately by le tter. 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 CFR5



### 194.8(b) to assess the technical adequacy, implemen tation and effectiveness of ORNL-CCP’s VE process to characterize CH TRU S4000 and S5000 w aste. EPA evaluated personnel qualifications and training, and operating procedur es 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 eva luation, 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 operat ions at ORNL-CCP. The evaluation included review of documents and records, observati on of VE operations and interviews with ORNL-CCP VE personnel.

Records and Documentation Reviewed

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

other VE-related records:

• CCP-TP-113, CCP Standard Contact-Handled Waste Visu al 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, Re vision 38, August 7, 2014.

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

2014

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

2013.

• CCP-AK-ORNL-002, Acceptable Knowledge Report for Wa ste 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 Examinati on, SC&A Anthony Harley CCP, Visual Examination Expert Shelley Martinez CCP, Cognizant Engineer Chuck (David) Wallace CCP, Visual Examination Opera tor/Independent Technical Reviewer Jason Cofer CCP, Visual Examination Operator/Indepe ndent Technical Reviewer Irene Joo URS, RH Program Manager6



### • Qualification Card for VE Expert (VEE).

• VEE appointment letter dated October 14, 2013.

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

• LOQI for VE personnel dated July 9, 2014.

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

• CH VE Batch Data Report (BDR) Nos. ORVECH0101, ORVE CH0102, ORVECH0106,

ORVECH0107, ORVECH0109.

• Completed Attachment 2, CCP Waste Visual Examinatio n 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 prev ious inspections. EPA determined that the procedures continue to provide adequate, a ppropriate and complete instructions for performance of applicable VE processes and operatio ns. 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 O RNL Transuranic Waste Processing

Center. The VE event used container No. X10C0402896 F from SCG S5000 Waste Stream ORREDC-CH-HET. ORNL site personnel performed the actu al handling of the waste in a glovebox under the direction of ORNL-CCP VE personnel. T he ORNL-CCP personnel examined the waste, identified each waste item as required and r ecorded the process. Upon completion of the VE inspection, ORNL placed the waste in a new 55-ga llon drum, output container No.

X10C0402896F1. EPA reviewed the completed data sheets for the demonstration con tainer and determined that they contained all required informa tion. 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 perform ed 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 rev ised 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 Densit y 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 Novembe r 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 2 1, 2014 A-98-49; II-A4-192B-1ATTACHMENT BVISUAL EXAMINATION FOR CONTACT-HANDLED WASTE CHECKLISTEPA Inspection No.: CCP-ORNL-T1-2014Inspection Date: August 5-6, 2014Establishment of RequiredTechnical Elements inProceduresExecution of ProceduresObjective Evidence and Additional CommentsCHVE-1Site procedures identifyrequired training andqualifications for CHVEpersonnel.CCP-QP-002, Revision 38Formal training elements include:project requirements, containeridentification and labeling, applicablestate andfederalregulationsSite-specific training program:OJT,identification of summary categorygroups, WMPs, packagingconfigurations, residual liquidsEPA has reviewed the CCP training procedure on numerous occasions and determinedit to be comprehensive and fully implemented. The training program for VE personnelincludes the required elements of examination, OJT,and formal training.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 VEEdated October 14, 2013.4.LOQI for VE personnel dated July 9, 2014.5.ORNL NDE Personnel Waste Streams Qualified List dated July 9. 2014.CHVE-2Operator qualification and requalificationrequirements aredescribed.CCP-QP-002, Revision 38, s.4.3.6, 44.4.1To become qualified, the CHVEoperator must pass a comprehensivewritten test with an 80 percent or bettergrade that addresses VE operations,documentation, characterization,formal training elements, andprocedural elements. VE Operatorsmust demonstrate capability in thepresence of the site VEE during OJT.However, the formal and OJT trainingis conducted by a qualified SME.EPA reviewed the Qualification Cards for several VEoperators and determined that theoperators were correctly trained and the training records were complete.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 VEEdated October 14, 2013.4.LOQI for VE personnel dated July 9, 2014.5.ORNL NDE Personnel Waste Streams Qualified List dated July 9, 2014.CHVE-3Each site has a designatedVEE.CCP-QP-002, Revision 38, s.4.4.1CCP-PO-001, QAPP, Revision21VEE designation is documentedVEE has knowledge of the CH TRUwaste being characterizedResponsible for overall direction andimplementation of VE at the facilityCertification Planspecifies theselection, qualification, and trainingrequirements of VEEThe VEE is available on-site but is not necessarilypresent for all VE events. The VEEis knowledgeable with regard to the VE processes employed and the waste streamsexamined.Objective evidence:1.Qualification Card for VEE.2.VEE appointment letter dated October 14, 2013.3.List of Applicable Waste Streams Qualified for VEEdated October 14, 2013.4.LOQI for VE personnel dated July 9, 2014.5.ORNL NDE Personnel Waste Streams Qualified List dated July 9, 2014.B-2Establishment of RequiredTechnical Elements inProceduresExecution of ProceduresObjective Evidence and Additional CommentsCHVE-4Procedures and technicalguidance documents providecomplete instructions forperforming CHVE.CCP-TP-113, Revision 18,section 4.0•100% of containers will be subjectto VE at the time of packaging•Waste Stream Description andWMC verified•Presence/absence of prohibiteditems confirmed•Two operators used even ifaudio/visual recording of VE isgeneratedEPA observed the VE event for S5400 container No. X10C0402896F (output containerX10C0402896F1) from Waste Stream OR-REDC-CH-HET. ORNL-CCP operatorsperformed the VE processes in accordance with CCP-TP-113 and recorded all requiredVE data.Objective evidence:1.Completed Attachment 2, CCP Waste Visual Examination Data Form, forcontainer No. X10C0402896F.2.Qualification Cards for VE operators performing theVE demonstration.3.VEE appointment letter dated October 14, 2013.4.List of Applicable Waste Streams Qualified, dated October 14, 2013, for VEE.5.LOQI for VE personnel dated July 9, 2014.6.ORNL NDE Personnel Waste Streams Qualified List dated July 9, 2014.7.BDR Nos. ORVECH0101, ORVECH0102, ORVECH0106, ORVECH0107,ORVECH0109.CHVE-5Corrective actions are takenwhen necessary.CCP-QP-005, Revision 24Operators were able to describe howthey initiate a corrective actionEPA reviewed NCR Nos. NCR-ORNL-0159-14 and NCR-ORNL-0702-14 that wereinitiated for containers in BDR No. ORVECH0101. These NCRs were initiated,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, ORVECH0106, ORVECH0107,ORVECH0109.CHVE-6Site procedure(s) require datageneration and project levelreviews of BDRs.CCP-TP-001, Revision 21•ITR review Attachment 2•SPM review Attachment 3EPA verified that the required reviews were performed for the BDRs listed below. TheITR and SPM reviews had been completed and signed by the applicable personnel.Objective evidence:1.Completed Attachment 2, CCP Waste Visual Examination Data Form, forcontainer No. X10C0402896F.2.BDR Nos. ORVECH0101, ORVECH0102, ORVECH0106, ORVECH0107,ORVECH0109.B-3Establishment of RequiredTechnical Elements inProceduresExecution of ProceduresObjective Evidence and Additional CommentsCHVE-7Records are available forreview.Lifetime/QA records – Attachments 1-5, Copy of NCRsQA/nonpermanent records – VHS tapeor DVD (primary and backup)ORNL-CCP was able to provide all documents and records requested by EPA.Objective evidence:1.Completed Attachment 2, CCP Waste Visual Examination Data Form, forcontainer No. X10C0402896F.2.Qualification Cards for VE operators performing theVE demonstration.3.VEE appointment letter dated October 14, 2013.4.List of Applicable Waste Streams Qualified for VEE,dated October 14, 2013.5.LOQI for VE personnel dated July 9, 2014.6.ORNL NDE Personnel Waste Streams Qualified List dated July 9, 2014.7.BDR Nos. ORVECH0101, ORVECH0102, ORVECH0106, ORVECH0107,ORVECH0109.