# EPA DOCKET NO. A-98-49, II-A4-138

WASTE CHARACTERIZATION INSPECTION REPORT AND APPROV AL

EPA BASELINE INSPECTION NO. EPA-Hanford-CCP-CH-04.1 0-8

OF THE CENTRAL CHARACTERIZATION PROJECT

WASTE CHARACTERIZATION PROGRAM

AT THE HANFORD SITE

April 27–29, 2010

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air

Center for Waste Management and Regulations

1200 Pennsylvania Avenue, NW

Washington, DC 20460

December 2010

# i 

# TABLE OF CONTENTS

Section Page

Acronyms ..........................................

................................................... .......................................... iii

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

................................................... ........................ 7

2.0 Purpose of Inspections ............................

................................................... ....................... 11

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

................................................... ...................... 12

4.0 Scope of Inspection ...............................

................................................... ......................... 13

5.0 Inspection-Related Definitions ....................

................................................... .................. 14

6.0 Personnel .........................................

................................................... ............................... 14

6.1 EPA Inspection Team ...............................

................................................... ......... 14

6.2 Personnel Contacted................................

................................................... ........... 15

7.0 Performance of the Inspection .....................

................................................... .................. 15

7.1 Site Background and History .......................

................................................... ...... 15

7.2 Inspection Process Overview .......................

................................................... ...... 16

8.0 Technical Waste Characterization Areas ............

................................................... ........... 16

8.1 Acceptable Knowledge (AK) .........................

................................................... .... 17

8.2 Nondestructive Assay (NDA) ........................

................................................... .... 32

8.3 Real-Time Radiography (RTR) .......................

................................................... .. 39

8.4 Visual Examination (VE) ...........................

................................................... ........ 45

8.5 WIPP Waste Data System (WDS) ......................

.................................................. 49

9.0 Response to Comments ..............................

................................................... .................... 53

10.0 Summary of Results ................................

................................................... ....................... 55

10.1 Findings and Concerns .............................

................................................... .......... 55

10.2 Conclusions .......................................

................................................... ................. 55

11.0 References ........................................

................................................... .............................. 58

# ii 

# ATTACHMENTS

Attachment A.1 Acceptable Knowledge (AK) Checklist

Attachment A.2 Nondestructive Assay (NDA) Checklist

, Attachment A.3 Real-Time Radiography (RTR) Checklis t

Attachment A.4 Visual Examination (VE) Checklist

Attachment A.5 WIPP Waste Data System (WDS) Checkli st

Attachment B.1 Replicate Testing Data for Container RL0063023, GEA-A

Attachment B.2 Replicate Testing Results for Conta iner RL0063023, GEA-A

Attachment B.3 Replicate Testing Data for Containe r RL0050614, GEA-A

Attachment B.4 Replicate Testing Results for, Cont ainer RL0050614, GEA-A

Attachment B.5 Replicate Testing Data for Containe r RL0063005, GEA-A

Attachment B.6 Replicate Testing Results for Contai ner RL0063005, GEA-A

Attachment B.7 Replicate Testing Data for Container RL0063034, GEA-B

Attachment B.8 Replicate Testing Results for Contai ner RL0063034, GEA-B

Attachment B.9 Replicate Testing Data for Containe r RL0056338, GEA-B

Attachment B.10 Replicate Testing Results for, Con tainer RL0056338, GEA-B

Attachment B.11 Replicate Testing Data for Containe r RL062952, GEA-B

Attachment B.12 Replicate Testing Results for Conta iner RL062952, GEA-B

Attachment C.1 EPA Inspection Issue Tracking Form , Issue No. Hanford-CCP-CH-RTR-10-

001CR

, Final

Attachment C.2 EPA Inspection Issue Tracking Fo rm

, Issue No. Hanford-CCP-CH-WDS-10-

002CR

, Final

Attachment C.3 EPA Inspection Issue Tracking Fo rm, Issue No. Hanford-CCP-CH-NDA-10-

003CR

, Final

Attachment C.4 EPA Inspection Issue Tracking Form

, Issue No. Hanford-CCP-CH-AK-10-

004CR

, Final

Attachment C.5 EPA Inspection Issue Tracking Fo rm

, Issue No. Hanford-CCP-CH-VE-10-

005F

, Final

Attachment C.6 EPA Inspection Issue Tracking Fo rm, Issue No. Hanford-CCP-CH-VE-10-

006CR

, Final

Attachment D Acceptable Knowledge Source Documents Reviewed

Attachment E Public Comment on Proposed Baseline Ap proval

# iii 

# ACRONYMS

AITR Automated Independent Technical Review

AK acceptable knowledge

AKE Acceptable Knowledge Expert

AKSR AK summary report

Am americium

Ba barium

BDR batch data report

CBFO Carlsbad Area Field Office

CCP Central Characterization Project

Cf californium

CFR Code of Federal Regulations

CH contact-handled

CIS Characterization Information Summary

Cm curium

Co cobalt

CRA Compliance Recertification Application

Cs cesium

D&D decontamination and decommissioning

DA Database Administrator

DOE U.S. Department of Energy

DQO data quality objective

DR discrepancy resolution

EA expert analyst

EPA U.S. Environmental Protection Agency

ES&H environmental safety and health

Eu europium

FR Federal Register

FRAM fixed energy response function analysis with multiple efficiencies

ftp file transfer protocol

g gram or grams

g/cc grams per cubic centimeter

# iv



# GEA Canberra Gamma Energy Analysis

HEHF Emergency Decontamination Facility

HLW high-level waste

IDMS Integrated Document Management System

IPAN Imaging Passive Active Neutron

ITR Independent Technical Reviewer

K potassium

keV kiloelectron volt

kg kilogram or kilograms

LANL Los Alamos National Laboratory

LEGe low-energy germanium

LLD lower limit of detection

LO Lead Operator

LWA Land Withdrawal Act

m 3 

# cubic meters

MGA multi-group analysis

MGA-U MGA Uranium

MPFPD Mixed PFP Debris

MPFPDD Mixed Plutonium Finishing Plant Decontamin ation and Decommissioning

Na sodium

Nb niobium

nCi/g nanocuries per gram

NCR nonconformance report

NDA nondestructive assay

NDE nondestructive examination

Np neptunium

NWPA Nuclear Waste Policy Act

ORIA Office of Radiation and Indoor Air

ORNL Oak Ridge National Laboratory

PDP Performance Demonstration Program

PFP Plutonium Finishing Plant

PTS Program Tracking System

Pu plutonium

# v



# QC quality control

Ra radium

RCRA Resource Conservation and Recovery Act

RLMPFPCD Mixed Plutonium Finishing Plant Comprehe nsive Debris Waste Stream

RTR real-time radiography

SCG Summary Category Group

SEGe standard electrode germanium

SME Subject Matter Expert

SNF spent nuclear fuel

SPM Site Project Manager

Sr strontium

SRS Savannah River Site

SWB standard waste box

SWITS Solidified Waste Information Tracking Syste m

T1 Tier 1

T2 Tier 2

Th thorium

TMU total measurement uncertainty

TRU transuranic

TRUEDMT TRU Electronic Data Management Tool

U uranium

VE visual examination

VEE Visual Examination Expert

VEO Visual Examination Operator

WAC waste acceptance criteria

WAP Waste Analysis Plan

WCA Waste Certification Assistant

WCO Waste Certification Official

WDS WIPP Waste Data System

WG Pu weapons-grade plutonium

WIPP Waste Isolation Pilot Plant

WMC waste matrix code

WMP waste material parameter

# vi



# WRAP Waste Reprocessing and Packaging

WSPF Waste Stream Profile Form

WWIS WIPP Waste Information System

# 7



# 1.0 EXECUTIVE SUMMARY

This report supports the U.S. Environmental Protect ion Agency’s (EPA or the Agency) approval of the

transuranic (TRU) waste characterization program im plemented by the Central Characterization Project

(CCP) at the Hanford site. On September 8, 2010, EP A issued a Federal Register (FR) Notice (75 FR

54631-54634), proposing approval of the Contact-Han dled (CH) TRU waste characterization program at

Hanford and docketed the baseline inspection report (EPA Docket No. A-98-49; II-A4-128) for public

review. In addition, EPA opened a 45-day public com ment period to seek comment on the proposed

approval. The comment period ended on October 25, 2 010. EPA received initial and follow-up comments

from a single Commenter 1 

# which are included in Attachment E of this report. Upon consideration of the

public comments, EPA made appropriate modifications to the proposed tiering changes as discussed in

Section 9.0 of this report and elsewhere as necessa ry.

This report discusses EPA’s baseline inspection res ults and Table 1 of this report identifies tiering

designations, conditions and limitations applicable to the CH TRU waste characterization program

implemented by CCP at Hanford. As a result of this approval, Hanford-CCP may dispose of CH debris

waste at the Waste Isolation Pilot Plant (WIPP). T his waste is and will be characterized using the Ha nfordCCP implemented CH TRU waste characterization proce sses consistent with the conditions and limitations

as described in this report.

In accordance with 40 CFR 194.8(b), the EPA conduct ed Baseline Inspection No. EPA-Hanford-CCP-CH04.10-8 of the waste characterization program for C H TRU waste. This inspection occurred at the Hanfor d

site, April 27 through 29, 2010. In accordance with the provisions of 40 CFR 194.8(b), as issued in a

July 16, 2004, Federal Register (FR) notice (69 FR 42571–42583), EPA conducted a b aseline inspection of

the site’s program to characterize wastes proposed for disposal at the WIPP. As a result of the baseli ne

inspection, EPA determined that the CH TRU waste ch aracterization program of the CCP at Hanford is

technically adequate.

EPA must verify compliance with 40 CFR 194.24 befor e waste may be disposed of at the WIPP, as

specified in Condition 3 of the Agency’s certificat ion of the WIPP’s compliance with disposal regulati ons

for TRU radioactive waste (63 FR 27354, 27405, May 18, 1998). In the Fall of 2009, the CCP took over

TRU waste characterization activities at Hanford. I n addition, since then, the CCP has been disposing of

CH-TRU waste at WIPP characterized by the now termi nated Hanford program 2 

# . EPA had not previously

evaluated waste characterization systems implemente d by the CCP at Hanford for characterizing CH TRU

wastes.

The purpose of the baseline inspection was to evalu ate the technical adequacy of the site’s waste

characterization programs for CH TRU debris waste t o be disposed of at WIPP. During the inspection, th e

Agency examined the following activities:

• Acceptable knowledge (AK) for CH retrievably-stored TRU debris waste (S5000)

• Two nondestructive assay (NDA) systems, the Canberr a Gamma Energy Analysis System Units A

and B (GEA-A and GEA-B) for characterizing debris ( S5000) wastes

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

1 

# The public comments are available in the EPA AIR D OCKET NO. EPA-HQ-OAR-2010-0711

2 

# EPA originally approved Hanford’s TRU waste charac terization program in mid-2002 and gave subsequent baseline

approval in mid-2008.

# 8



# • Visual Examination (VE) for CH retrievably-stored T RU debris waste (S5000)

• WIPP Waste Data System (WDS) for CH retrievably-sto red TRU debris waste (S5000)

During the inspection, Hanford-CCP personnel stated that the Hanford-CCP was not seeking approval to

perform load management, and EPA excluded evaluatio n of load management from the scope of this

inspection [see Section 8.1(5)].

As discussed in the baseline inspection report acco mpanying the proposed approval, EPA identified 1

Finding and five concerns. Upon satisfactory resolu tion of EPA issues, EPA determined that the Hanford

CCP waste characterization program for retrievably- stored CH TRU debris waste was technically adequate

. EPA proposed for approval the Hanford-CCP CH TRU wa ste characterization program in the configuration

observed during the baseline inspection and describ ed in the baseline inspection report cited above.

EPA received public comment and upon considerations of the comments, EPA is making the following two

changes to the proposed approval.

1. EPA concludes that the process 3 

# used for calculating liquids in container (a) is v ariable at different

CCP-serviced sites, (b) is not necessarily a proces s improvement as claimed, and (c) may be

excessive, particularly when liquid volume does not have to be that precise to determine whether

the liquid contents are in excess of the allowable threshold. If CBFO wants to allow CCP to use this

method of calculation of liquid in a container at C H TRU including Hanford, then the following

steps are necessary:

• Maintenance of auditable records when liquids in a container are calculated using mathematical

formulae;

• Revision and simplification of the “Measurement Con version Chart” to make it better suited to

match operator’s skill level;

• Improved on-the-job training of RTR Operators to ma ke it consistent among different operators

to minimize subjectivity; and

• Submission to EPA for evaluation and approval the r evised training material, test questions for

operator qualification, and test results prior to i mplementation.

Unless these steps are taken, CBFO and CCP are proh ibited to use the mathematical formulae for

different liquid shapes to calculate liquid volume in containers.

2. A new RTR unit or modification of an approved unit is a T2 change at other EPA-approved CCP

CH TRU sites. However, if modifications to an appro ved unit are sufficiently significant (such as

those Hanford-CCP intends to make in the coming mon ths), then EPA may evaluate

implementation of such RTR-specific T2 change(s) pr ior to EPA’s concurrence of CBFO’s draft

certification/recertification letter incorporating changes to the certified. CBFO must notify EPA

about the use of a new RTR unit or modification to an approved unit as soon as Hanford-CCP is

ready for CBFO’s certification audit.

3 

# This conclusion is based on the public comment inc luding the supporting material and observations EPAmade at other CCPserviced CH TRU sites over the past six months.

# 9



# In addition, EPA finalizes the following elements o f the Hanford-CCP’s CH TRU waste characterization

program that EPA proposed for approval:

(1) The AK process for CH retrievably-stored TRU debris wastes

(2) The GEA-A and GEA-B system units for assaying CH TR U wastes

(3) The nondestructive examination (NDE) process of RTR for CH TRU debris wastes

(4) The NDE process of VE for CH TRU debris waste

(5) The WDS process for tracking waste contents of CH TRU wastes

Hanford-CCP must report any Tier 1 (T1) or Tier 2 ( T2) changes to their Hanford-CCP waste

characterization activities from the date of the ba seline inspection according to Table 1, below. Refe rence

to the specific section of this report where each T 1 or T2 change is discussed is included in parenthe ses

following the change. Table 1 in this report closel y follows the format used in previous CH baseline

approval reports. Footnote b in Tables 1 and 10 spe cifies that “substantive changes” are changes with the

potential to impact the site’s waste characterizati on activities under 40 CFR 194.24 or the documentat ion

thereof, excluding changes that are solely related to environmental safety and health (ES&H), nuclear

safety, or the Resource Conservation and Recovery A ct (RCRA), or that are editorial in nature.

All T1 changes must be submitted for evaluation and approval by EPA prior to implementation (see

Section 2.0 of this report for a brief discussion o f tiering). Upon approval, EPA will notify the publ ic of the

results of its evaluations by posting the results t o the EPA Web site and by sending e-mails through t he

WIPPNEWS list. Upon completion of its review of the T2 changes submitted at the end of each fiscal

quarter, EPA will post the T2 changes. EPA expects the first report of Hanford-CCP’s T2 changes at the

end of the first quarter following approval.

# 10



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

Based on April 27-29, 2010 Site Baseline Inspection as issued on December 15, 2010

Process Elements Hanford-CCP T1 Changes Needing

EPA Review and Approval Hanford-CCP T2 Changes a



# Acceptable Knowledge

(AK) Implementation of load management (AK

13)

Implementation of AK for wastes other

than retrievably-stored debris

(i.e., retrievably-stored soil/gravel and/or

solids) (AK 1) Notification to EPA upon completion of new versions or

updates/ substantive changes b 

# of the following:

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

4)

- Availability of modifications to the AKSR (AK

5)

- Availability of all final WSPF with related

attachments (AK 9)

- Availability of all AK Accuracy Reports (AK

12)

- Availability of successful training records (AK

10)

- Availability of the AK-NDA memorandum (AK

14)

Non Destructive Assay

(NDA) New equipment or physical modifications

to approved equipment c 

# (NDA 1)

Extension or changes to approved

calibration range for approved equipment

(NDA 2) Notification to EPA upon completion of changes to

software for approved equipment, operating range(s) , and

site procedures that require CBFO approval (NDA 2)

Real-Time Radiography

(RTR) There are no T1 changes at this time Notification t o EPA upon the following:

- Modification c 

# to approved equipment, RTR units

A and B (RTR 2)

- Completion of changes to site RTR procedures

requiring CBFO approvals (RTR 2)

- Addition of new SCG to the RTR processes that

are subject to this approval (RTR 2)

Implementation of a different type of RTR equipment

(RTR 2)

Visual Examination (VE) Performance of VE by any me thod other

than using two trained operators to

perform actual VE at the time of

packaging (VE 1) Notification to EPA upon the following:

- Completion of changes to site VE procedure(s)

requiring CBFO approvals (VE 2)

- Addition of new SCG to the VE processes that

are subject to this approval (VE 2)

Waste Data System (WDS) There are no T1 changes at this time Notification t o EPA upon the following:

- Completion of changes to WDS procedure(s)

requiring CBFO approvals (WDS 2)

- Changes to the Excel spreadsheet titled WDS

Master Template.xls, Revision 2, Addendum #2,

SCO #1065 (WDS 2)

a 

# Upon receiving EPA approval, Hanford-CCP will repor t all T2 changes to EPA at the end of each fiscal q uarter. Note: EPA

may request specific T2 change items before the end of a fiscal quarter.

b 

# “Substantive changes” are changes with the potentia l to impact the site’s waste characterization activ ities or documentation

thereof, excluding changes that are solely related to ES&H, nuclear safety, or RCRA, or that are edito rial in nature.

c 

# Modifications to approved equipment include all cha nges with the potential to affect NDA data relative to waste isolation and

exclude minor changes, such as the addition of safe ty-related equipment.

# 11



# 2.0 PURPOSE OF INSPECTIONS

On May 18, 1998, EPA certified that the WIPP will c omply with the radioactive waste disposal

regulations at 40 CFR Part 191. In this certificati on, EPA also included Condition 3, which states

that “the Secretary shall not allow shipment of any waste from...any waste generator site other

than LANL [Los Alamos National Laboratory] for disp osal at the WIPP until the Agency has

approved the processes for characterizing those was te streams for shipment using the process set

forth in §194.8.” The approval process described a t 40 CFR 194.8 requires DOE to (1) provide

EPA with information on AK 4 

# for waste streams proposed for disposal at the WIP P, and (2)

implement a system of controls used to confirm that the total amount of each waste component

that will be emplaced in the WIPP will not exceed l imits identified in the WIPP Compliance

Certification Application (DOE/CAO 1996-2184, 40 CFR Part 191, Compliance Certification

Application for the Waste Isolation Pilot Plant , 1996).

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

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

program. The purpose of the baseline inspection is to approve the site’s waste characterization

program based on a demonstration that the program’s components, with applicable conditions

and limitations, can adequately characterize TRU wa stes and comply with the regulatory

requirements imposed on TRU wastes destined for dis posal at the WIPP. An EPA team conducts

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

properly implemented. Specifically, the EPA inspect ion team verifies compliance with

40 CFR 194.24 (c)(4), which states the following:

Any compliance application shall: . . . Provide in formation which demonstrates

that a system of controls has been and will continu e to be implemented to confirm

that the total amount of each waste component that will be emplaced in the

disposal system will not exceed the upper limiting value or fall below the lower

limiting value described in the introductory text o f paragraph I of this section. 5



# The system of controls shall include, but shall not be limited to: measurement;

sampling; chain of custody records; record keeping systems; waste loading

schemes used; and other documentation.

In other words, the purpose of the baseline inspect ion is to assess whether DOE sites that

characterize TRU waste prior to disposal at the WIP P are capable of characterizing and tracking

the waste in a manner to demonstrate regulatory com pliance and document that the waste will

not exceed the approved limits. Before approving th e TRU waste characterization systems and

4 

# As of the FR notice of July 16, 2004 (69 FR 42571– 42583), EPA has replaced the term “process knowledg e”

with “acceptable knowledge.” Acceptable knowledge refers to any information about the process used to generate

waste, material inputs to the process, and the time period during which the wastes were generated, as well as data

resulting from the analysis of waste conducted prio r to or separate from the waste certification proce ss authorized by

an EPA certification decision to show compliance wi th Condition 3 of the certification decision.

5 

# The introductory text of 40 CFR 194.24(c) states, “For each waste component identified and assessed p ursuant

to [40 CFR 194.24(b)], the Department shall specify the limiting value (expressed as an upper or lower limit of

mass, volume, curies, concentration, etc.), and the associated uncertainty (i.e., margin of error) for each limiting

value, of the total inventory of such waste propose d for disposal in the disposal system.”

# 12



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

identify and measure waste components (such as plut onium) that must be tracked for

compliance, 6 

# and (2) confirm that the waste in any given contai ner has been properly identified

as belonging to the group of approved waste streams

.

Following EPA’s baseline approval, EPA is authorize d to evaluate and approve, if necessary,

changes to the site’s approved waste characterizati on program by conducting additional

inspections under the authority of 40 CFR 194.24(h) . Under 40 CFR 194.24, EPA has the

authority to conduct continued compliance inspectio ns to verify that the site continues to use

only the approved waste characterization processes to characterize the waste and remains in

compliance with all regulatory requirements. Based on the adequacies of the waste

characterization processes demonstrated during the baseline inspection, including all conditions

and limitations, EPA specifies which subsequent was te characterization program changes or

modifications must undergo further EPA inspection o r approval under 40 CFR 194.24. EPA

accomplishes this by assigning a tier level to each aspect of the characterization program. T1

activities have more stringent reporting requiremen ts and the Agency’s approval prior to

implementing the change is necessary. The EPA-appro ved sites must report T2 activities to EPA

based on the frequency established in the inspectio n report. DOE may choose to characterize and

dispose of materials at its own risk while EPA cons iders the proposed T2 changes. If HanfordCCP contemplates a change that is not identified in this report, EPA recommends that the site, in

consultation with CBFO, discuss the nature of the c hange with EPA. This would minimize the

possibility of EPA not approving the site-assigned tiers. The rule applying to this baseline

inspection can be found in the Federal Register not ice at 69 FR 42571–42583, July 16, 2004.

3.0 PURPOSE OF THIS REPORT

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

Baseline Inspection No. EPA-Hanford-CCP-CH-04.10-8 in terms of findings and concerns.

Specifically, this report does the following:

• Describes the characterization systems evaluated du ring the inspection that are approved

• Provides objective evidence of the approval basis f or all waste characterization systems

• Identifies all relevant system limitations and/or c onditions for each waste characterization

system

• Identifies the applicable T1 and T2 elements

• Provides objective evidence of outstanding findings or concerns, as applicable

6 

# The potential contents of a waste stream or group o f waste streams determine which processes can adequ ately

characterize the waste. For example, if AK informat ion suggests that the waste form is heterogeneous, the site

should select a suitable NDA technique to ensure ad equate measurements. Radiography and VE help to con firm and

quantify waste components, such as cellulosics, rub bers, plastics, and metals. Once the nature of the waste has been

confirmed, the assay techniques then quantify selec ted radionuclides in the waste. In some cases, a TR U waste

generator site may be able to characterize a wide r ange of heterogeneous waste streams or only a few. A site’s stated

limits on the applicability of proposed WC processe s govern EPA’s inspection scope.

# 13



# • Describes any tests or demonstrations completed dur ing the course of the inspection and

their relevance to EPA’s approval decision

The completed checklists (Attachments A.1 through A .5 to this report) reference the documents

that the EPA inspection team reviewed in support of the technical determination. To see or

obtain copies of any items identified in the attach ed checklists, write to the following address:

Quality Assurance Manager

USDOE/Carlsbad Area Field Office

P.O. Box 3090

Carlsbad, NM 88221

EPA’s final approval decision on the Hanford-CCP wa ste characterization program will be

conveyed to DOE separately by letter. More informat ion is also on EPA’s Web site at

http://www.epa.gov/radiation/WIPP/index.html in accordance with 40 CFR 194.8(b)(3).

4.0 SCOPE OF INSPECTION

The scope of EPA Baseline Inspection No. EPA-Hanfor d-CCP-CH-04.10-8 was the evaluation

of the technical adequacy of the waste characteriza tion systems in use at Hanford-CCP to

characterize CH TRU wastes. The EPA inspection team evaluated these systems with respect to

their ability to perform the following functions:

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

# Am, 137 

# Cs,

238 

# Pu, 239 

# Pu, 240 

# Pu, 242 

# Pu, 90 

# Sr, 233 

# U, 234 

# U, and 238 

# U) using a combination of AK and NDA

systems

• Assign waste material parameters (WMPs) correctly u sing RTR for CH retrievably-stored

debris waste

• Perform effective waste information (data) transfer using the WDS

Specifically, these systems consisted of the follow ing components:

• AK processes that support retrievably-stored S5000 debris wastes

• Two NDA systems, GEA-A and GEA-B, for the analysis of S5000 debris wastes

• RTR

• VE

• The WDS for the purpose of compiling TRU waste data by container and tracking of all

waste containers emplaced in the WIPP repository

During its inspection, EPA does not approve or cert ify waste characterization data per se; that

function is the sole responsibility of the site bei ng evaluated—in this case, Hanford-CCP. EPA,

however, evaluated adequacy of the site’s waste cha racterization processes and ability of

personnel and equipment to characterize contents of CH retrievably-stored TRU waste

# 14



# containers. The evaluation consisted of interviewin g 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 obje ctive 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, RTR tapes, and WDS printouts for

specific TRU containers. During this inspection, EP A 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. Bas ed on the evaluation of the waste

characterization processes in conjunction with the sample of objective evidence, EPA determined

the technical adequacy of the waste characterizatio n processes within the inspection’s scope.

5.0 INSPECTION-RELATED DEFINITIONS

During an inspection, EPA inspectors may encounter items or activities that require further

inquiry for their potential to adversely affect was te characterization and/or isolation within the

repository. The two main categories relevant to was te characterization inspections are identified

below:

Finding : A determination that a specific item or activity does not conform to

40 CFR 194.24(c)(4). A finding requires a response from CBFO.

Concern : A judgment that a specific item or activity may o r may not have a negative effect on

compliance and, depending on the magnitude of the i ssue, may or may not require a

response.

Note that DOE does not need to address concerns not requiring a response prior to program

approval. However, EPA recommends that when DOE acc epts the site’s response to an EPA

concern, it should inform EPA at the same time that the site implements the corresponding

corrective action. This process is similar to a T2 change.

6.0 PERSONNEL

6.1 EPA Inspection Team

Table 2 identifies the members of the EPA waste cha racterization inspection team.

Table 2. EPA Inspection Team Members

Inspection Team Member Position Affiliation

Rajani Joglekar Inspection Team Leader U.S. EPA ORIA

Ed Feltcorn Inspector U.S. EPA ORIA

Lindsey Bender Observer U.S. EPA ORIA

Jonathan Walsh Observer U.S. EPA ORIA

Connie Walker Techni cal Inspector, AK S. Cohen & Associates, Inc.

Kira Darlow Inspector

- In

- Training, AK S. Cohen & Associates, Inc

Dorothy Gill Technical Inspector, NDE S. Cohen & Associates, Inc.

Patrick Kelly Technical Inspector, NDA S. Cohen & Associates, Inc

Abe Zeito un Inspector

- In

- Training, NDE S. Cohen & Associates, Inc.

# 15



# 6.2 Personnel Contacted

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

personnel in several disciplines. The personnel con tacted represented only a sample of the CH

TRU waste characterization staff, and they are listed in Table 3, along with their affiliation s and

areas of expertise.

Table 3. Personnel Contacted During Inspection

Personnel Affiliation Area of Expertise/Function

Sherri Nance CCP Acceptable Knowledge Expert (AKE)

Steve Schafer CCP Acceptable Knowledge Expert (AKE)

Joe Harvill CCP NDA, Technical Liason

George Westik AREVA/CCP NDA, Expert Analyst (EA)

Brett Templeton MCS/CCP NDA, Lead Operator (LO)

Ed Gulbransen AREVA NDA, Expert Analyst (EA)

Deborah Zentner CCP Visual Examination Expert (VEE)

Carissa Marquez CCP Visual Examination Operator (VEO)

Yulanda Gates CCP Visual Examination Operator (VEO)

Charles McCants CCP Visual Examination Operator (VEO)

Dale Simpson CCP RTR Subject Matter Expert (SME)

Jeremy Veseley CCP RTR Operator/Independent Technical

Reviewer (ITR)

Larry Porter CCP Site Program Manager (SPM)

Mike Ramirez CCP Waste Certification Official (WCO)



# During the baseline inspection, Hanford-CCP provide d a list of TRU waste characterization

personnel, from which EPA selected a sample of indi viduals to interview. The EPA inspectors

reviewed the qualifications (including waste charac terization experience) and training records of

these individuals to assess their waste characteriz ation capabilities. After resolution of a finding,

EPA has determined that those Hanford-CCP waste cha racterization personnel responsible for

characterizing and certifying TRU waste were qualif ied and had received adequate training to

perform their assigned function. When personnel cha nges occur, EPA may request qualification

and training records of any new individuals identif ied as key waste characterization personnel.

EPA will review these records and may interview the personnel to determine their ability to

produce quality data. This personnel qualification evaluation and review of training records is

similar to EPA’s evaluation during each inspection.

7.0 PERFORMANCE OF THE INSPECTION

7.1 Site Background and History

The DOE’s Hanford site covers a 560-square mile are a on the Columbia River near Richland,

Washington. The Hanford site was established during World War II to produce plutonium for

U.S. nuclear weapons, and the site’s nine productio n reactors created approximately 75% of the

# 16



# plutonium used in the U.S. nuclear arsenal. Peak pl utonium production years were in the 1960s,

and all nuclear material production was halted in l ate 1989. Hanford’s current mission involves

environmental restoration and nuclear material stab ilization and stewardship and Hanford is also

an interim storage facility for TRU-contaminated wa ste, including defense waste. EPA inspected

and approved Hanford’s waste characterization progr am in 2008. In 2009, TRU waste

characterization activities at Hanford were taken o ver by CCP, and the Hanford-CCP TRU waste

characterization program is the subject of this bas eline inspection.

7.2 Inspection Process Overview

EPA Baseline Inspection No. EPA-Hanford-CCP-CH-04.1 0-8 took place April 27-29, 2010.

EPA reviewed additional documents that were provide d after the inspection to complete its

evaluation of several of the technical areas within the inspection’s scope. The inspection was

performed for the purpose of determining Hanford-CC P waste characterization program

compliance with 40 CFR 194.24. The inspection invol ved the following steps:

(1) Preparing draft checklists specific to each technic al area before the inspection

(2) Obtaining and reviewing site procedures, reports, a nd other technical information

related to waste characterization activities at Han ford-CCP in advance of the

inspection

(3) Interacting with CBFO and Hanford-CCP personnel to arrange inspection logistics

(4) Verifying onsite the technical adequacy or qualific ations of waste characterization

personnel, procedures, processes, and equipment by means of interviews, observation,

and demonstrations, and recording the results on ch ecklists

(5) Recording all findings and concerns on EPA Inspecti on Issue Tracking Forms and

providing completed forms to CBFO and site personne l as they were generated

(6) Communicating all pertinent information to CBFO and Hanford-CCP personnel

onsite, as appropriate

(7) Pursuing resolution of all identified issues before completion of the inspection by

discussions with CBFO and Hanford-CCP personnel

(8) Conducting entrance, exit, and daily briefings for CBFO and Hanford-CCP

management personnel, as appropriate

(9) Reviewing additional information provided by Hanfor d-CCP after the inspection

8.0 TECHNICAL WASTE CHARACTERIZATION AREAS

Sections 8.1 through 8.5 of this report detail the five technical areas assessed during this

inspection—AK, NDA, NDE consisting of RTR and VE, a nd the WDS.

# 17



# 8.1 Acceptable Knowledge (AK)

EPA examined the AK process and associated informat ion to determine whether Hanford-CCP

complies with 40 CFR 194.24 and 194.8 requirements for CH retrievably-stored and newlygenerated debris wastes.

Waste Characterization Element Description

Attachment A.1 to this report is a checklist that i dentifies technical elements and objective

evidence reviewed by the EPA inspection team. AK pr ovides information on several aspects of

TRU wastes at Hanford-CCP, including, but not limit ed to, the following:

• Defense waste status

• Spent Nuclear Fuel (SNF), High-Level Waste (HLW) pr esence

• Material parameters

• Waste stream definition

• Radionuclide composition

• Waste matrix codes (WMCs)

EPA examined the following AK technical elements:

• Waste stream identification and definition

• Radionuclide content of waste

• Physical composition of waste

• Overall procedural technical sufficiency and scope and ability to follow the AK waste

characterization process for containers and waste s treams including AK information

assembly, compilation, confirmation, and AK discrep ancy resolution (DR)

• Sufficiency of AK Summary including source document integration and source document

sufficiency

• Drum data traceability

• Defense origin of waste

• SNF and HLW status

• The Waste Stream Profile Form (WSPF)

• Personnel training

• Non Conformance Reports (NCRs)

• AK accuracy

• Load management

• AK-NDA Communication

Documents Reviewed

During the inspection, EPA inspectors examined or a ccepted a variety of documents related to

AK, some provided as paper copy, others in electron ic format. The list of all documents

reviewed or accepted as objective evidence is prese nted in Attachment D. The following BDRs

were examined:

# 18 Drum Number RTR BDR No. NDA BDR No.

0056238 RLRTRB0002 RLGEAA0001

0063057 RLRTRA0001 RLGEAA0002



# Technical Evaluation

Hanford-CCP had completed characterization of one w aste stream that was provided to EPA for

inspection, the Mixed Plutonium Finishing Plan Deco ntamination and Decommissioning

(MPFPDD) waste stream representative of Summary Cat egory Group (SCG) S5000 waste.

Waste stream MPFPDD is composed of newly-generated and retrievably-stored debris waste

generated from production through D&D activities at the Plutonium Finishing Plan (PFP). The

MPFPDD waste stream consists of debris from several sources within the PFP complex as

discussed in Item (1) below.

EPA evaluated the adequacy of AK information specif ic to this CH TRU retrievably-stored and

newly-generated waste stream in the following areas

.

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

The WIPP Waste Acceptance Criteria (2009) defines a waste stream as: “waste material

generated from a single process or from an activity which is similar in material, physical form,

and hazardous constituents.” The MPFPDD waste stre am was evaluated based on this definition.

The MPFPDD waste stream is composed of TRU mixed he terogeneous debris created by various

production, maintenance, cleanout, stabilization, d econtamination, and decommissioning

activities at PFP. The waste stream may contain a n umber of debris materials including metals,

plastics, and cellulosics, as detailed in Item (3), below. MPFPDD waste stream was created by

Hanford-CCP by combining the Mixed PFP Debris (MPFP D) waste stream, and Mixed

Plutonium Finishing Plant Comprehensive Debris (RLM PFPCD) Waste Stream. A total of 4,528

debris containers from the MPFPD waste stream were characterized under the old Hanford waste

characterization program before its termination in August 2009 and have been disposed of at the

WIPP. Several thousand of the MPFPD debris containe rs remain to be characterized which

Hanford-CCP will characterize for WIPP disposal. Pr ior to the termination of its program in

August 2009, Hanford created the RLMPFPCD waste str eam but none of the containers were

approved for WIPP disposal. Hanford-CCP indicated t hat the MPFPD waste stream was a subset

of the larger RLMPFPCD waste stream. Hanford-CCP ha s redefined waste stream, RLMPFPCD,

including MPFPD, to capture three additional facili ties or areas within the PFP complex,

specifically the Waste Treatment and Americium Faci lity (Building 242-Z), Ventilation and

Exhaust shafts (291-Z) and Ancillary cribs/trenches . Between 2001-2008, EPA evaluated the

MPFPD waste stream as part of the original Hanford program inspection to approve debris

(S5000) waste and reevaluated the same during the s ubsequent site inspections, but never

evaluated RLMPFPCD. Therefore, EPA’s analysis inclu des the acceptability of combining the

Hanford-defined and Hanford-CCP-defined waste strea ms and if the new MPFPDD waste stream

has been adequately defined.

# 19



# Hanford-CCP representatives and the AKSR indicate t hat the PFP has been in operation since

1949 and performed weapons fabrication support acti vities through the late 1960s, after which

time operations began shifting to supporting commer cial nuclear reactor activities. Hanford-CCP

representatives indicated that all waste generated prior to 1970 has already been shipped to WIPP

as part of the MPFPD waste stream. As a result, was te containers in inventory and to be shipped

as part of the MPFPDD waste stream were generated a fter 1970. The AKSR estimates that 2,455

containers of waste from this waste stream are in r etrievable storage as standard waste boxes, 55-

gallon drums and 85-gallon drums, most of which wil l be repackaged. Approximately 6,694

cubic meters (m 3 

# ) of TRU waste debris will be generated at PFP duri ng D&D activities that

began in 2009.

The AKSR states that the “combined” MPFPDD waste st ream consists of TRU mixed

heterogeneous debris resulting from production, mai ntenance, cleanout, stabilization, and

decontamination and decommissioning (D&D) at PFP. T he PFP Facility includes several

buildings and areas. These are:

• 232-Z Waste Incinerator Facility Incinerator (e.g., Contaminated Waste Recovery)

• 234-5Z Plutonium Finishing Plant

• 236-Z Plutonium Reclamation Facility Process Cell

• 242-Z Waste Treatment Facility Waste Treatment Faci lity and Americium Facility

• 291-Z Ventilation/Exhaust Air Stack

• PFP Ancillary Areas (2736-Zb Areas PFP Effluent Inf rastructure, 241-Z Treatment and

Storage Tanks, 241-Z-361 Settling Tank, 241-Z-8 Sil ica Slurry Tank, 216-Z-9 Crib, 216-

Z-1A Crib/Tile Field, Ancillary Facilities, 216-Z-1 2 Process Crib, 2904-ZA Monitoring

Station)

Hanford-CCP provided a freeze file change generated two weeks prior to the EPA inspection that

removed all of the PFP Effluent Infrastructure unit s in 2736-Zb Areas from the waste stream,

based on the results of an earlier CBFO audit of th e site. EPA agrees with this determination.

Subsequently, EPA examined the information presente d in the AK Summary and supporting

references and supplemental documentation, and ques tioned the inclusion of the incinerator

waste (232-Z) in this waste stream, because informa tion suggested it managed material from

outside the PFP. Hanford-CCP provided supporting in formation that indicated no other facilities

other than PFP provided feed material to the incine rator [see Item (5)], and EPA accepts this

explanation.

EPA examined the AKSR, supporting documents, and in terviewed Hanford-CCP personnel to

ascertain waste and material movement in and throug h the PFP facility and related areas. EPA

determined that material movement and subsequent wa ste generation occurred through each of

these facilities including “back and forth” materia l movement and management, and HanfordCCP AKEs stated that there is no indication that ma jor contributions of materials or wastes from

other site sources were managed at the complex. Rad iological and physical characteristics of the

waste stream are discussed in Items (2) and (3), be low.

# 20



# EPA noted that the MPFPDD waste stream is broad and includes both process and D&D waste

from a number of PFP activities. This suggests that these activities may constitute a multitude of

processes, bringing to question whether these proce sses should have been singled out as separate

waste streams. However, Hanford-CCP personnel state d that in almost all instances, it was

impossible to differentiate “where” in the PFP comp lex the waste was generated, (i.e., 236-X

waste cannot be distinguished from 242-Z waste), so no further segregation into individual waste

streams can be accomplished, based on AK. Additiona lly, data suggest that the waste material

has a general radiological signature supporting the waste stream definition [see Item (2), below].

Based on this information, the waste stream designa tion is appropriate. See Items (2) and (3)

below for radiological and physical waste character ization analyses that support this

determination. Since this waste stream included onl y debris (S5000) waste, characterization of

solids and sludge (S3000) and soil and gravel (S400 0) waste will require a T1 change approval.

(See Table 1 where this is included as a T1 change)

.

(2) AK information pertaining to the radiological chara cteristics of TRU wastes was

examined and found to be adequate.

A primary function of PFP during its early years of operation was the production and fabrication

of plutonium for weapons parts, which included conv ersion of Pu nitrate to metal and

casting/machining operations. Plutonium recovery fr om scrap and waste was also performed. In

the 1960s, the mission began to shift to commercial nuclear support, and hence a change in the

isotopic distribution of the plutonium fabricated o r managed at the PFP. The isotopic distribution

of plutonium within waste reflects this shift in pl utonium production and fabrication activities.

Radiological Characteristics of the MPFPDD Waste St ream

Hanford-CCP examined previous AK reports and data i n the WWIS for the portion of this waste

stream already emplaced in WIPP to determine the ge neral isotopic composition of the waste

stream. The AK Summary states that data from 5,856 drums were evaluated to obtain this

information, which is presented in Table 4, below. The source of this information is entirely the

WWIS, which includes the 4,528 drums emplaced, as w ell as 1,328 certified drums in the WWIS

that were not shipped at the time the data were obt ained from the WWIS. This table shows that

239 

# Pu and 238 

# U are the most prevalent isotopes by mass. This was te stream also contains isotopes

of uranium, americium, neptunium, cesium, and stron tium.

# 21 

# Table 4. Waste Stream MPFPD WWIS Reported Radionuc lides

Isotope Total Radionuclide

Wt% Suspected Present

(Yes/No)

WIPP Required Radionuclides

Am-241 0.63% Yes

Pu-238 0.04% Yes

Pu-239 67.34% Yes

Pu-240 6.19% Yes

Pu-242 0.07% Yes

U-233 0.03% Yes

U-234 Trace 1 

# Yes

U-238 24.65% Yes

Sr-90 Trace Yes

Cs-137 Trace Yes

Additional Radionuclides

Am-243 Trace Yes

Ba-133 Trace Yes

Cf-249 Trace Yes

Cm-243 Trace Yes

Co-60 Trace Yes

Eu-152 Trace Yes

Eu-154 Trace Yes

K-40 0.01% Yes

Na-22 Trace Yes

Nb-94 Trace Yes

Np-237 0.11% Yes

Pu-241 0.22% Yes

Ra-226 Trace Yes

Th-228 Trace Yes

Th-232 0.37% Yes

U-232 Trace Yes

U-235 0.34% Yes

Notes:

1 “Trace” indicates <0.1 wt% for that radionuclide

.



# Hanford-CCP representatives also evaluated the gene ral isotopic distribution of key isotopes

based on historic AK data in various references. Th ese ranges are presented in Table 5, below.

Table 5. Plutonium and Uranium Isotopic Distributi ons

Pu and Associated Distributions Uranium Distributions

Isotope Wt% Distribution Isotope Wt% Distribution

Pu-238 0.01 – 0.05% U-232 Trace

Pu-239 74.78 – 97.77% U-233 Trace

Pu-240 2.13 – 20.72% U-234 0.006 – 0.008%

Pu-241 0.02 – 0.81% U-235 0.57 – 0.97%

Pu-242 0.001 – 0.66% U-236 0.07 – 0.08%

Am-241 0.07 – 2.88% U-238 98.95 – 99.35%

Np-237 0.00 – 0.09%

# 22



# AK data indicate that the initial weapons-grade plu tonium (WG Pu) produced at Hanford

exhibited a 240 

# Pu weight percentage between approximately 0.9 - 7% , and fuel material

processed at Hanford exhibited a 8 - 27% range of 240 

# Pu weight percent for experimental reactor

and other technologies. Hanford-CCP concluded that a range of isotopic distributions would be

expected for this waste stream, as shown in Table 5 , above. The table was generated assuming

241 

# Am is present due to decay of 241 

# Pu, but AK data show that 241 

# Am may also be present in

waste generated from the Waste Treatment complex (2 42-Z). Therefore, the estimated

percentage of americium may be greater than what is presented. Uranium is present as an

impurity as slightly depleted uranium (0.6 percent 235 

# U) and slightly enriched uranium (>1%

235 

# U). Impurities that may be present include 232 

# Th, 249 

# Cf, and trace amounts of other

radionuclides.

Isotopic Distributions for the MPFPDD Waste Stream

Numerous references (e.g., P976) indicate that seve ral isotopic distributions have been developed

and used by Hanford prior to CCP’s involvement, inc luding distributions applicable to PFP. The

Hanford characterization program used these distrib utions when measurement values could not

be obtained, and were used to characterize approxim ately 10% of the containers from the

MPFPD waste stream (which is now included in the MP FPDD waste stream). Hanford

developed these distributions by examining the AK r ecords for 4,655 containers, and

determining the three most frequent percent plutoni um isotopic distributions processed at the

235-5Z complex, based on the percent of 240 

# Pu identified on the drum records. The following

distributions (shown in Tables 6, 7, and 8) were us ed by Hanford personnel, and were also

adopted by Hanford-CCP. Based on review of the AK r ecord, these distributions are reasonable.

Table 6. Default 6 Percent Pu-240 20-Year Aged Mas s Fraction

Isotope Weight Percent Uncertainty (1 σ)

Pu-238 0.0302 0.0030

Pu-239 93.6784 9.3678

Pu-240 6.0503 0.6050

Pu-241 0.2211 0.0221

Pu-242 0.0201 0.0020

Am-241 0.5025 0.0502



# Table 7. Default 12 Percent Pu-240 20-Year Aged Ma ss Fraction

Isotope Weight Percent Uncertainty (1 σ)

Pu-238 0.0815 0.0082

Pu-239 85.5498 8.5550

Pu-240 13.2172 1.3217

Pu-241 1.1210 0.1121

Pu-242 0.0306 0.0031

Am-241 1.7833 0.1783

# 23 

# Table 8. Default 23 Percent Pu-240 20-Year Aged Ma ss Fraction

Isotope Weight Percent Uncertainty (1 σ)

Pu-238 0.0924 0.0092

Pu-239 72.4474 7.2447

Pu-240 24.4844 2.4484

Pu-241 1.6419 0.1642

Pu-242 1.3340 0.1334

Am-241 2.6167 0.2617



# As discussed previously, Hanford-CCP AKEs acquired data for over 5,800 drums from the

original MPFPD waste stream and related AK to evalu ate the general radiological composition

of the portion of the waste stream that is currentl y emplaced at WIPP. The drums evaluated are

assumed to be representative of the waste stream as a whole, but are biased toward waste

contaminated by WG Pu. Hanford-CCP AKEs indicated t hat the values obtained from the WWIS

were almost entirely derived (approximately 90%) fr om actual measurements, and therefore did

not rely heavily on the above default isotopics. To evaluate whether actual measured data were

well represented by the default isotopic values, Ha nford-CCP AKEs developed the isotopic

distribution of the emplaced waste stream that is p rimarily contaminated by WG Pu. The

following weight percent distributions for MPFPD wa stes in the WWIS were obtained: 241 

# Am –

0.86%; 238 

# Pu – 0.05%; 239 

# Pu – 91.18%; 240 

# Pu – 8.39%; 241 

# Pu– 0.29%; 242 

# Pu – 0.09%. These

values adequately correspond with Table 6 above, an d the comparison verified that the default

isotopic distributions used by Hanford-CCP match th e measured values in the WWIS. Based on

this analysis, the potential isotopic composition o f the waste stream is well understood, and the

default isotopics were verified by measurement data

.

(3) Identification of physical form including WMPs and prohibited items was assessed and

found to be adequate.

Waste stream MPFPDD is composed of a variety of deb ris material represented by a host of

activities including plutonium processing, waste tr eatment, incineration, and D&D activities.

MPFPDD is comprised primarily of numerous organic a nd inorganic debris waste items.

Potential debris items that may be present in the w aste include, but are not limited, to metal tools,

metal tanks, metal pipes/pumps, glass, glove box pa nels, hot plates, sample racks stirrers,

burners, slip lid cans, un-tinned cans, torpedo lev els, grease guns, aluminum foil, mask filters,

leaded aprons, leaded gloves, lead tape, lead chrom ate paint, lead seals, fluorescent light bulbs,

scraps from maintenance activities, glass thermomet ers, various glass tubes, vials, beakers,

asbestos pot liners, ceramic kitty litter, vermicul ite, cardboard “ice-cream” cartons, PPE rags,

wood, filter media, various rubber items, plastic i tems, and occasional absorbed or unabsorbed

liquids.

As indicated in Item (1) above, this range of activ ities may be considered separate waste

processes or separate waste streams, but they have been grouped into a single waste stream

because AK cannot differentiate the drums. The phys ical composition of the waste stream is

described generally in site records. However, waste s generated prior to 1970 have already been

disposed of in WIPP as waste stream MPFPD, so the W WIS was reviewed by Hanford-CCP to

develop an accurate picture of the waste streams’ p hysical composition.

# 24



# The AKSR freeze file indicates that 5,856 container s were certified for shipment from Hanford,

but only 4,528 containers were actually shipped as of August 2009. WWIS records were

examined by Hanford-CCP representatives to determin e the physical composition of the waste

stream, noting that this portion of the waste strea m is biased toward process waste, rather than

D&D waste. These data showed that the waste stream is composed of more than 50%

heterogeneous inorganic and organic debris, so a WM C of S5400, Heterogeneous Debris, was

applied to this waste stream.

To estimate the WMPs for waste stream MPFPDD, Hanfo rd-CCP evaluated data for 4,994 of the

5,856 containers in the WWIS and NDE information from AK reference HNF-36515. Based on

this analysis, Hanford-CCP generated the WMP conten ts of the waste that are presented in

Table 9 below. This distribution is expected to cha nge to include an increased percentage of

metal as more D&D waste is included in the waste st ream.

Table 9. Waste Stream MPFPDD Waste Material Parame ters

WMP Description Average Weight Percent Weight Percent Range

Iron-based Metals/Alloys 48% 0 - 100%

Aluminum-based

Metals/Alloys < 1% 0 - 83%

Other Metals 5% 0 - 87%

Other Inorganic Materials 8% 0 - 100%

Cellulosics 12% 0 - 92%

Rubber 9% 0 - 91%

Plastics (waste materials) 18% 0 - 100%

Organic Matrix < 1% --

Inorganic Matrix < 1% --

Soils/gravel < 1% --

TOTAL INORGANIC 61% --

TOTAL ORGANIC 39% --



# Hanford-CCP representatives indicated that physical composition information would be obtained

through NDE of each container, which will also iden tify the presence of prohibited items (i.e.,

liquids). Based on this information, the physical c omposition of the waste stream documented in

the WWIS is expected to agree with the material ant icipated to be present in the waste stream as

a whole.

(4) AK procedural adequacy and implementation was asses sed and found to be adequate

(assembly compilation, interpretation, confirmation , discrepancy resolution).

CCP-TP-005, Revision 18 is Hanford-CCP’s AK procedu re. It includes processes and

procedures for the following activities:

• AK Documentation Management

• Compiling AK Documentation

• Recording AK Documentation

• Review and Submittal of AK Documentation

• Waste Stream Characterization

# 25



# • Determining AK Documentation Accuracy

• Re-evaluating AK Documentation

• Resolving AK Discrepancies

• Updating AK for Additional Waste Stream Containers

• Container Tracking Spreadsheet Development and Main tenance

EPA examined the AK document management process use d to acquire all available AK

references (C, D, DR, M, P, U) pertinent to the was te stream, including new references that were

recently added. EPA found that Hanford-CCP followed the procedure appropriately to record

and review AK documentation. EPA questioned element s of the waste stream identification

process [see Item (5), below], and noted that data limitations are identified for each source

document on the source document summary form. Hanfo rd-CCP provided example DR forms as

well as the container tracking spreadsheet for revi ew.

Several attachments support these activities:

Attachment 1 – Acceptable Knowledge Documentation C hecklists

Attachment 2 – Record of Communication

Attachment 3 – Acceptable Knowledge Source Document Summary

Attachment 4 – Acceptable Knowledge Source Document Reference List

Attachment 5 – Hazardous Constituents

Attachment 6 – Waste Form, Waste Material Parameter s, Prohibited Items, and Packaging

Attachment 7 – Radionuclides

Attachment 8 – Waste Containers List

Attachment 9 – Waste Characterization Data Cross-Re ference

Attachment 10 – Acceptable Knowledge Re-evaluation Checklist

Attachment 11 – Acceptable Knowledge Source Documen t Discrepancy Resolution Form

Attachment 12 – Form and Content Guide for AK Summa ry Reports

Attachment 13 – CCP Waste Stream Characterization C hecklist

Attachment 14 – CCP Acceptable Knowledge Accuracy R eport

Only Attachment 5 is not relevant to EPA’s review. EPA was provided examples of relevant

Attachments (see Attachment D), which demonstrated Hanford-CCP’s ability to prepare these

items. EPA found it difficult to examine the AK Sou rce Document Summaries separate from the

Source Documents (they are usually attached to the source documents), and recommends that

Attachment 3 actually be “attached” to the relevant source document as has been done at all

other CCP sites. EPA determined that Hanford-CCP de monstrated the ability to follow the AK

procedure for the elements examined. Notification o f modification of CCP-TP-005 Revision 18

is a T2 change. (See Table 1 where this is included as a T2 change).

(5) The AK Summary was assessed and found to be adequat e.

The AK Summary was examined to determine whether ma jor technical components were

present, and to ensure that the document adequately justified and described the waste stream.

Hanford-CCP representatives provided a freeze file modification representing changes inprogress; these changes were appropriate and necess ary to clarify the contents of the AKSR,

# 26



# Revision 2. EPA identified several concerns associa ted with the AKSR, and these were discussed

with Hanford-CCP personnel and were incorporated in an EPA Inspection Issue Tracking Form.

These issues are summarized below (see Attachment C .4 for a copy of this form):

EPA Inspection Issue Tracking Form, Hanford-CCP-CH- AK-10-004CR:

• Examine feed and other data for 232-Z Incinerator t o verify its inclusion in the waste

stream.

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

• In Section 4.6.1, modify the discussion pertaining to waste stream definition to include

the lack of ability to correlate drums to specific PFP processes. Also modify Section 5.3

to indicate whether to-be-generated waste will be s egregated upon generation or

packaging.

• Clarify intent of last paragraph p. 30 regarding pl utonium grades and defense waste.

• Add information to Section 5.4.2 pertaining to the 6%, 12%, and 23% plutonium isotopic

distributions as presented in AK Source Documents a nd the AK-NDA memorandum,

including data that support generation of these dis tributions at the PFP, as well as other

pertinent historical data.

• Remove first sentence from the first paragraph in S ection 4.5 regarding intent to

segregate waste during packaging or repackaging, as it contradicts later statements.

• Verify number of HEHF (Emergency Decontamination Fa cility) drums and how it is

included in the PFP drum population.

• Add the total volume (cubic meters) of waste in inv entory.

• In the final paragraph of Section 5.4.2, add the se cond predominant radionuclide by

activity, to be consistent with the previous portio n of the sentence that identifies the two

predominant radionuclides by mass.

Resolution: Hanford-CCP provided a discrepancy resolution (DR 013) documenting the

gathering of information that adequately addressed the first bullet showing that only PFP

material was processed through the incinerator faci lity. Also, Hanford-CCP modified the existing

freeze file to remove or modify language pertaining to material managed in the 232-Z

Incinerator. The remaining issues were addressed th rough modification of the existing freeze file.

Status of Concern: The response is adequate; EPA considers this issu e to be closed.

The AKSR will be updated to include information on the freeze file, which is in the AK Record.

Notification of availability of modifications to th e AKSR is a T2 change. (See Table 1 where this

is included as a T2 change).

(6) Drum traceability and the ability to follow the AK waste characterization process for

containers was assessed and found to be adequate.

# 27



# Drum traceability data for drum Nos. 0056238 and 00 63057 were examined, from initial AK

documentation through Hanford-CCP characterization and drum management. Drum records

examined for each included the following:

• Historic Documentation from the Hanford Site Record s Storage Facility and Integrated

Document Management System (IDMS), including TRU/TR U Mixed Waste Contents

Inventory Sheet, Waste Designation Worksheet, Inspe ction Sheet for Loaded/Sealed

TRU/TRU Mixed Waste Drum, Inspection Sheet for Empt y 55-Gallon Waste Drum, and

Certificate of Conformance

• Solid Waste Information Tracking System (SWITS) dat abase records including the

SWITS Container Listing Report

• TRU Electronic Data Management Tool (TRUEDMT) Datab ase Print Outs

• BDRs (NDA and RTR)

• CCP Program Tracking System (PTS) printout – each c ontainer

These data indicate that historic information perta ining to waste drum content is available.

EPA also requested information about a container th at had not yet undergone Hanford-CCP

waste characterization. The Hanford-CCP AKE provide d drum information for container

0055034. These data included additional information not available for the two Hanford-CCP

D&D containers that had been characterized (0056238 and 0063057), because container 0055034

was generated in 1979 as a process waste. Informati on examined included SWITS database

information, TRUEDMT database, Onsite Radioactive S hipment Records, and Solid Waste

Burial Records. These data indicated that drum No. 0055034 was not composed of S5000 debris

but was instead a “solid sludge” per information on the drum record. EPA inspectors asked for

additional information about this drum, including t he Quickscan RTR that had been performed to

verify the SCG. The Quickscan showed that the drum contained small containers that held some

solidified material, but the small containers const ituted much less than 50% of the drum by

volume, so the overall drum content was composed of debris.

Information examined showed that Hanford-CCP person nel could obtain historic information for

drums within the waste stream, had access to site s creening to verify waste contents, and could

trace information for the container from the AK rec ord through the characterization process.

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

TRU waste streams to be disposed at WIPP must be “d efense” waste. Hanford-CCP states that

based on DOE guidance, a waste is defense in origin if it has been generated “in whole or part by

one of the atomic energy defense activities listed in section 10101(3) of the Nuclear Waste

Policy Act of 1982 (NWPA).” AK data indicate that PFP TRU waste is co ntaminated with

radionuclides generated from energy defense activit ies, including defense nuclear material

processing and fabrication of plutonium for weapons , defense nuclear waste materials byproducts management, and defense research and devel opment. Based on the information

# 28



# provided in the AKSR, supporting references and the DOE’s guidance regarding defense waste,

the waste stream is defense in origin.

(8) Spent Nuclear Fuel and High-Level Waste Status was evaluated and found to be in

compliance with the WIPP Land Withdrawal Act.

The WIPP Land Withdrawal Act (LWA) prohibits the di sposal of SNF and HLW as defined by

the NWPA at WIPP. The NWPA states that SNF is “fuel that has been withdrawn from a nuclear

reactor following irradiation, the constituent elem ents of which have not been separated by

reprocessing. SNF may not include test specimens ir radiated for research and development only

(i.e., these may be classified as waste when it is technically infeasible, cost prohibitive, or would

increase worker exposure.” HLW is defined by the N WPA as “the highly radioactive material

resulting from the reprocessing of spent nuclear fu el, including liquid waste produced directly in

reprocessing and any solid material derived from su ch liquid waste that contains fission products

in sufficient concentrations, and other highly radi oactive material that the Commission,

consistent with existing law, determines by rule re quires permanent isolation.” The AKSR and

Hanford-CCP AKEs indicate that PFP did not reproces s spent nuclear fuel, as waste contains

only unirradiated materials derived from testing an d other sources. Therefore, the waste is not

SNF and because SNF was not reprocessed at PFP, HLW could not have been generated. EPA

concurs that the data provided in the AKSR support this determination.

(9) Waste Stream Profile Form preparation and completen ess was evaluated and found to be

adequate.

A draft Waste Stream Profile Form (WSPF) was provid ed for EPA review to demonstrate

Hanford-CCP’s ability to prepare this required docu ment. The WSPF includes the Profile Form,

Characterization Information Summary (CIS), DQO Rec onciliation Checklist, and Summation of

Aspects of the AK Summary Report: MPFPDD. Comparis on of the WSPF with the AKSR

revealed discrepancies with respect to the exact nu mber of containers in the waste stream

(containers versus drums and SWBs). Also, the WSPF references Revision 1 of the AKSR;

Revision 2 is now in effect. When the final WSPF is prepared, EPA expects that the correct

AKSR will be referenced, and all necessary changes to tables, figures, and section references

will be made as necessary and references will be ad ded to the Supplemental Document listing on

the WSPF. A draft WSPF does demonstrate Hanford-CCP ’s ability to prepare this document and

associated attachments. Notification of availabilit y of all final WSPFs with related attachments is

a T2 change. (See Table 1 where this is included as a T2 change).

(10) Staff training was examined and found to be adequat e.

Training documentation for the following personnel was provided:

The qualification cards were provided for the SPM, Natasha McCants, and two AKEs -- Sherri

Nance and Steve Schafer. These cards indicated that Ms. McCants had been trained to the

appropriate procedures, but there was no indication she had been trained to the specific AK

Documents (e.g., AKSR) associated with the EPA insp ection. The Qualification Cards for Ms.

Nance and Mr. Schaffer were signed in 2004 and 2003 , respectively, and did not indicate training

had been accomplished to the most recent regulatory documents or internal procedures (e.g.,

# 29



# WAP, WAC, CCP-TP-005 and EPA’s CRA). Hanford-CCP pr ovided information to indicate that

Ms. McCants had been trained to the appropriate AKS R, but documentation to indicate that

Hanford-CCP AKEs were trained to the most recent ve rsions of procedures, particularly

CCP-TP-005 Revision 18, was not available. The obje ctive evidence indicates that AKEs are

familiar with the relevant waste characterization p rocedures, but documentation also must be

available to demonstrate that the AKEs have been ap propriately trained to the most recent

versions of these procedures. EPA will verify the p aperwork at future inspections. Notification of

availability of successful training is a T2 change. (See Table 1 where this is included as a T2

change).

(11) Preparation of Nonconformance Reports was evaluated and found to be adequate.

Several Nonconformance Reports (NCRs) have been gen erated for this waste stream. Issues

addressed through the NCR process include identific ation of impenetrable items (i.e., lead lining

or materials obscure RTR examination of drum conten ts), presence of liquids, presence of

prohibited items (i.e., disposable lighter), sealed containers greater than 4 liters, and

measurement less than 100 nCi/g TRU. In all of thes e instances, the example NCRs provided

rejected the drum and returned it to the Host Site for remediation or other disposition. The

examples provided show that Hanford-CCP satisfactor ily documents the NCR process.

(12) AK accuracy was assessed and found to be adequate.

Hanford-CCP provided an Acceptable Knowledge Accura cy report for the MPFPDD Waste

Stream, Lot 1, which included only 10 drums. This r eport noted that the AKSR identified 238 

# U

and 239 

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

# Pu and 240 

# Pu were the most

predominant radionuclides by weight for the 10 cont ainers. The AK Accuracy report concludes

that if this situation is persistent through the wa ste stream, revision of the most prevalent

radionuclides within the AKSR would be warranted, b ut an AK re-evaluation was not performed

at this time. The physical composition of the waste stream agreed with what was presented in the

AKSR. Provision of this report demonstrates Hanford -CCP’s ability to prepare this document

and implement AK accuracy calculations per CCP-TP-0 05 Revision 18. Notification of the

availability of all AK Accuracy Reports is a T2 cha nge. (See Table 1 where this is included as a

T2 change).

(13) Load management was found to be not applicable.

Hanford-CCP AKEs indicated that load management wou ld not be performed on waste under the

Hanford-CCP program. Performance of load management is a T1 change.

(14) NDA-AK communication was assessed and found to be a dequate.

CCP-TP-005 Revision 18, Section 4.4.22 requires the preparation of an NDA memorandum that

evaluates the radionuclide characterization of the waste stream. The memorandum is required to

include a section that shows how NDA personnel will apply AK during assay. The memorandum

addresses limitations associated with AK- based inf ormation, and must also include a description

of the assay methods, and also requires that NDA is sues (for both measured and calculated

# 30



# radionuclides) should be discussed and resolved. Th e NDA memorandum for CCP-AK-RL-101

MPFPDD waste first describes the isotopic informati on based on AK data derived through AK

record examination and through WWIS data collection and analysis. The memorandum also

describes limitations associated with the AK data, and how the AK data will be applied during

assay. Additionally, the memorandum presents how 242 

# Pu, 234 

# U, and 90 

# Sr will be determined, and

discusses potential gamma spectrometry and neutron interferences. The NDA memorandum is an

excellent way to document how AK is used in the NDA process, and serves as an important link

between the two characterization programs by provid ing identical information to both AK and

NDA personnel. Notification of revisions to this ND A memorandum and the availability of any

NDA memorandum is a T2 change. (See Table 1 where t his is included as a T2 change).

(15) Data management was evaluated and found to be adequ ate.

Hanford-CCP AKEs indicated that they could obtain d ata from the site through various sources.

These include:

• SWITS, which presents radiological, physical, and c hemical data on a container basis

• Hanford Site Records Storage Facility (Hard Copy Fi les) and related Integrated

Document Management System (IDMS) that includes sca nned versions of hard-copy files

• TRU Electronic Data Management Tool, which is a Han ford database that documents

drum history up to acceptance by the characterizati on facility (CCP)

Hanford-CCP generates a full list of all containers in the waste stream and presents these drums

on CCP-TP-005 Attachment 8. Hanford-CCP also mainta ins the AK Container Tracking

Spreadsheet per CCP-TP-005 Revision 18, which keeps track of individual drum status including

Container I.D., Waste Stream I.D. Generation Date, Vent Date, Change Reason (for vent date),

New Closure Date, New Vent Date, and Container Type . Hanford-CCP posts the Container

Tracking Spreadsheet to the file transfer protocol (ftp) site and EPA has access to this site. This

spreadsheet (and Attachment 8) is updated as new co ntainers are added to the waste stream.

Hanford-CCP also keeps detailed records of containe r characterization status, including the

presence of NCRs that might have been issued for a container. This is CCP’s PTS (Program

Tracking System), and NCRs are also tracked in the system. Information from the PTS is used to

populate the WWIS.

Based on this information, historical data are avai lable to the Hanford-CCP AKE, and HanfordCCP, as part of the characterization process, uses information from the site. Hanford-CCP tracks

each container from the site systems through its ow n internal system, which in turn provides

information to the WWIS. The data management system observed adequately tracked and

managed evaluated information.

(16) The integration of previous site documents into the Hanford-CCP process was examined

and was found to be satisfactory.

EPA first approved the Hanford Site in September of 2002, with a later baseline approval of the

Hanford Program in 2007. The Hanford Site program w as terminated in 2009, and CCP took

# 31



# over the characterization responsibilities. The Han ford TRU waste characterization program has

a tremendous amount of information in hard copy doc uments, electronic data, and human

intellectual capital available to Hanford-CCP that should serve as a starting point for HanfordCCP’s characterization program. Examination of data available for the first debris waste stream

characterized by Hanford-CCP (MPFPDD) shows that ma ny of the references available with

Hanford TRU program have been integrated into the H anford-CCP documentation system. Also,

waste databases are available to CCP personnel. CCP used the site’s AKSRs for MPFPD and

RLPFPCD waste stream to create the larger CCP-defin ed combined waste stream MPFPDD.

Many of the references and concepts in both reports were rooted in Hanford’s original program.

CCP should rely on this information and examine all references and data to ensure that HanfordCCP defined TRU wastes have complete pedigree and o wnership as “their own” stand-alone

program. Integration of site documents and activiti es is a work in progress, and is expected to

proceed in a satisfactory manner.

Summary of AK Findings and Concerns

The EPA inspection team did not identify any findin gs related to AK during this inspection. EPA

did identify the single concern that is discussed a bove. A copy of the EPA Inspection Issue

Tracking Form documenting this concern is provided in Attachment C.4 to this report. EPA

considers this concern to have been adequately addr essed and there are no open findings or

concerns related to AK resulting from this inspecti on.

Baseline Approval

EPA approves the AK systems evaluated during this b aseline inspection as described in this

report for CH retrievably-stored and newly-generate d TRU debris (S5000). Application of the

AK process described in this report to wastes other than these is a T1 change. (See Table 1 where

this is included as a T1 change).

AK Tiers

Based on the inspection and results discussed above , EPA assigns the following tiers:

T1 AK changes will require EPA review and approval prior to impl ementation and will apply to

any new waste category not evaluated during the bas eline inspection. These include the

following:

• Categories of waste not approved under this baselin e inspection (e.g., S3000 and S4000

wastes)

• Implementation of load management

Hanford-CCP must report and submit documentation on T1 changes when it is ready for EPA

review and approval. Upon initial review, EPA will inform Hanford-CCP and CBFO whether a

site inspection is necessary. EPA may request addit ional information, choose to conduct a

desktop review, and/or confer with Hanford-CCP pers onnel. Upon AK evaluation with or

# 32



# without site inspection, EPA will issue a decision. Only upon receiving EPA written approval

may Hanford-CCP characterize and dispose of the new waste at the WIPP.

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

• Modification of CCP-TP-005 Revision 18

• Availability of modifications to the AKSR

• Availability of all final WSPF with related attachm ents

• Availability of all AK Accuracy Reports

• Availability of successful training records

• Revisions to the NDA memorandum for MPFPDD, and ava ilability of any NDA

memorandum

8.2 Nondestructive Assay (NDA)

Waste Characterization Element Description

During this inspection, EPA inspected two NDA syste ms located at the Waste Reprocessing and

Packaging (WRAP) Facility: the Canberra Gamma Ener gy Analysis System Units A and B

(GEA-A and GEA-B).

Documents Reviewed

The GEA-B Unit was refurbished and recalibrated in March 2006, following which both GEA

systems were equivalent in terms of their measureme nt capability. The checklist in

Attachment A.2, in conjunction with the documents l isted below, comprise the documents that

were examined in assessing GEA Units A and B during this inspection:

• CCP-TP-070, CCP Gamma Energy Assay (GEA) Calibratio n, Confirmation and

Verification Procedure, Revision 0

• CCP-TP-071, CCP Gamma Energy Assay (GEA) Operating Procedure, Revision 0

• CCP-TP-072, CCP Gamma Energy Assay (GEA) Data Revie w, Validation, and

Reporting Procedure, Revision 0

• GEA Units A and B Radionuclide Listing Library, Fil ename: C:\GENIE2K\CAMFILES\CCPWRAP.nlb, generated April 37 , 2010

• ASTM C 1133 – 03, Standard Test Method for Nondestructive Assay of Sp ecial Nuclear

Material in Low-Density Scrap and Waste by Segmente d Passive Gamma-Ray Scanning

• Use of Isotope Correlation Techniques to Determine 242 

# Pu Abundance , R. Gunnink, 1980

• GEA-A 104-ND-06-102A Calibration Verification, Marc h 9, 2010

• CCP-AK-RL-101 MPFPDD DNA Memo, Evaluation of the Ra diological

Characterization of Hanford Site Waste Stream MPFPD D, Revision 2, March 17, 2010

# 33



# • HNF-5148, EDC-05-25965, Calibration Report for the WRAP Facility Gamma Ener gy Analysis (GEA) System , May 16, 2005

• Hanford-CCP List of Qualified Individuals, NDA GEA, April 14, 2010, 11:32 AM

• CCP-RL-GEA-003, Total Measurement Uncertainty (TMU) for the Gamma Energy

Assay Systems

• CCP-RL-GEA_A-001, Revision 0, Gamma Energy Assay (G EA) System Unit A

Calibration, Confirmation and Verification Report

• CCP-RL-GEA_B-001, Revision 0, Gamma Energy Assay (G EA) System Unit B

Calibration, Confirmation and Verification Report

• GEA-A System Notebook RL-NDA-GEA-A-003, Assigned by Susan Keathley, January

5, 2010, Building 2336W, Area 200 W; Users – Brett Templeton, William Williams,

Jeremy Heath, Alan, Shumaker, Mike Maul; Daily Acti vities – Verify CCP-TP-071,

Revision 0; NDA 2K Version 4.0

• GEA-B System Notebook RL-NDA-GEA-B-004, Assigned by Susan Keathley, January

5, 2010, Building 2336W, Area 200 W; Users – Brett Templeton, William Williams,

Jeremy Heath, Alan, Shumaker, Mike Maul; Daily Acti vities – Verify CCP-TP-071,

Revision 0; NDA 2K Version 4.0

• GEA A BDR RLGEAA0001

• GEA A BDR RLGEAA0002

• GEA A BDR RLGEAA0003

• GEA B BDR RLGEAB0001

• GEA B BDR RLGEAB0002

• GEA B BDR RLGEAB0003

Technical Evaluation

Both of these NDA systems had been evaluated and ap proved by EPA as part of the Hanford

TRU program previously in 2003 and 2005 (see Docket Nos. A-98-49, II-A4-41 and A-98-49,

II-A4-58, respectively) at the WRAP facility. The d etailed technical basis for each system’s

operation is described and detailed in the EPA insp ection reports cited above. Since GEA Units

A and B had undergone hardware changes and software upgrade(s), they had been partially

recalibrated and both systems are essentially equiv alent in terms of measurement capability.

Both systems had been operational for WIPP assays p rior to this inspection and both were reevaluated during this inspection. The EPA inspectio n team evaluated the following aspects of

both systems:

• Design and technical capability of the measurement hardware and software to perform

the required analyses

• Adequacy of the assay program’s documents and proce dures to provide technical support

to EPA approval

# 34



# • Knowledge and understanding of the personnel involv ed in the NDA program

Hanford-CCP NDA personnel stated that the GEA-A and GEA-B Units have not changed or

been modified in any significant way since EPA last inspected them during the Hanford baseline

inspection of 2007. The EPA Inspection Team confirm ed this by direct evaluation of both

systems’ technical documentation and other records during this inspection. EPA assessed the

technical elements of the WRAP GEA Units A and B th at are discussed below.

(1) The design, operation and personnel associated with GEA Units A and B were assessed

and were found to be adequate.

The GEA Units A and B (GEA-A and GEA-B) are housed in the WRAP facility. Each system

consists of six gamma detectors: four are Standard Electrode Germanium (SEGe) detectors for

quantitative analysis; and two are Low-Energy Germa nium (LEGe) detectors used for isotopic

analysis based on photons in the 45 to 300 keV rang e in conjunction with Multi Group Analysis

(MGA), MGA Uranium (MGA-U), and FRAM (Fixed-energy Response Function Analysis with

Multiples Efficiencies) software. The choice of sof tware is at the discretion of the NDA Expert

Analyst (EA). AK-based or default isotopics are use d when measured isotopics cannot be

supported and only for waste streams that have an a pproved set of default isotopics. The SEGe

detectors address matrix correction by using four h ighly collimated 152 

# Eu sources located directly

opposite the SEGe detectors and at a right angle (9 0°) to the LEGe detectors. Both systems

operate under the GENIE2000/NDA2000 software and in clude shielded enclosures, drum

elevation and rotation equipment, and ancillary ele ctronics.

The systems have two operational modes, a shielded and unshielded

geometry, and there are

limitations to both modes that are applicable to ac tual waste containers that are discussed in the

calibration report for each system. These modes are used depending on a container’s Pu loadings,

enhanced 241 

# Am levels, or significant count rates from other fi ssion products. The main

difference results in the choice of 239 

# Pu line (129 keV or 414 keV) for quantitative analy sis.

Additionally, there is an option regarding the use of the individual horizontal segments of a

container’s assay or summing all horizontal segment s over the container’s vertical height. These

choices are incorporated in the system’s software, but are routinely evaluated by the NDA AK

during data validation, and the software’s choices can be overridden. The GEA units produce

data for 238 

# Pu, 239 

# Pu, 240 

# Pu, 233 

# U, 235 

# U, and 238 

# U over a mass range from 0.010 g to 345 g of

nominal WG Pu, i.e., 6% 240 

# Pu. Technically based correlations (scaling factors ) are used to

derive values for 234 

# U, 137 

# Cs, and 90 

# Sr; 242 

# Pu is determined using the correlation techniques o f

Gunnink. There are no technical issues associated w ith the design, operation, and personnel

associated with GEA Units A and B. The use of new, unapproved NDA equipment at WRAP or

physical modifications to the WRAP GEA Units A and B observed during this inspection is a T1

change. (See Table 1 where this is included as a T1 change.)

(2) System calibration and calibration confirmation of the GEA Units A and B had been

performed as required.

The calibration of the GEA Units is documented in C CP-RL-GEA_A-001 (GEA-A) and

CCP-RL-GEA_B-001 (GEA-B). Both GEA units have energ y and peak shape calibrations that

# 35



# had been performed previously as documented in HNF- 5148, both of which were verified and

documented by Hanford-CCP. New multi-curve and tran smission (shielded) efficiency

calibrations were performed for both GEA units usin g six mixed-gamma line sources containing

152 

# Eu/ 137 

# Cs/ 241 

# Am in four 55-gallon (208-liter) matrix drums conta ining foam, soft board,

particle board and sand that spanned a density rang e of 0.011 to 1.56 g/cc. Both systems use tin

shields approximately 1/32” thick on the SEGe detec tors to reduce system dead time resulting

from high 241 

# Am concentrations associated with aged plutonium, a nd the 152 

# Eu transmission

sources are aligned to obtain transmission data on all vertical segments of the SEGe detectors of

each system. Calibration confirmation was performed using Pu sources other than the

152 

# Eu/ 137 

# Cs/ 241 

# Am sources used for calibration, as required. Hanfo rd-CCP NDA personnel

provided objective evidence of the appropriate pedi gree for all WG Pu sources that is

documented in each system’s calibration report. The calibration confirmation sources consisted

of WG Pu sources in a variety of gram values that w ere combined to produce the following

masses: 9.0 g, 130.0 g and 265.0 g. The system pas sed all calibration confirmation criteria

except for the 9.0 WG Pu in the shielded transmissi on corrected mode, due to poor counting

statistics on the Pu lines at 129, 203 and 375 keV. However, this mode would not be used for

routine assays and the multi-curve data that were c ollected simultaneously yielded acceptable

results. With the one exception for the 9.0 g WG Pu standard in the shielded transmission mode

discussed above, all calibration confirmations pass ed the criteria for accuracy and precision.

There are no technical issues with the calibration and calibration confirmation of GEA Units A

and B.

Regarding routine performance testing of the GEA-B, EPA identified a discrepancy in the

documentation of the Summed 239 

# Pu Mass Daily Standard. EPA discussed this concern with

Hanford-CCP NDA personnel and incorporated it in an EPA Inspection Issue Tracking Form.

The issue is summarized below (see Attachment C.3 f or a copy of this form).

EPA Inspection Issue No. Hanford-CCP-CH-NDA-10-003C R: The controls limits for this

parameter were developed on the basis of nine data points using the Student’s T Test (n = 9),

which resulted in fairly tight control limits, as e xpected. When additional data had been

accumulated, the limits were recalculated using the Student’s T Test (n = 31), which resulted in

broader control limits, as expected. However, the n ewer limits were not conveyed to the

appropriate personnel and the newer assays were sub jected to the old limits. This is not a

performance issue, since all assays passed the tigh ter (more restrictive) limits. However, it

indicates a breakdown in communication within the N DA group, as well as a lack of appropriate

control over fundamentally important performance da ta. This affected all GEA-B BDRs that

were generated to date.

Resolution: Hanford-CCP NDA personnel took the GEA-B Unit out of service pending a

complete investigation regarding the cause of this incident and committed to training all NDA

personnel on the correct application of control lim its, including their documentation. All GEA-B

BDRs will be amended and reissued, as required.

Status of Concern: EPA considers this concern to be closed.

# 36



# Extension or changes to approved calibration range for the WRAP GEA Units A and B is a T1

change, (See Table 1 where this is included as a T1 change.) Also, notification to EPA upon

completion of changes to software, operating range( s) and site procedures for the WRAP GEA

Units A and B that require CBFO approval is a T2 ch ange and requires EPA notification.

Consistent with EPA’s authority under 40 CFR 194.24 (h), EPA may request this information if

EPA deems it necessary to ensure continued complian ce with EPA regulations. (See Table 1

where this is included as a T2 change.)

(3) The total measurement uncertainty of assays perform ed on the GEA-A and GEA-B had

been adequately determined and documented.

The determination of the total measurement uncertai nty (TMU) of assays performed on the GEA

Units A and B is documented in CCP-RL-GEA-003, Tota l Measurement Uncertainty (TMU) for

the Gamma Energy Assay Systems. The components of u ncertainty included in the TMU

determination included calibration source uncertain ties, counting statistics, self-absorption

effects, matrix non-homogeneities, non-uniform sour ce distributions, and isotopic measurement

uncertainties. There are no issues with the determi nation and documentation of TMU for GEA-A

and GEA-B.

(4) The lower limit of detection of the GEA-A and GEA-B had been adequately determined

and documented.

The lower limit of detection (LLD) is defined as “t hat level of radioactivity which, if present,

yields a measured value greater than the critical l evel with a 95% probability, where the critical

level is defined as that value which measurements o f the background will exceed with 5%

probability.” The LLD of any given NDA measurement is likely to depend on the type of

measurement, the properties of the waste matrix bei ng assayed, and the environmental

background. For this reason, the LLD will vary from drum to drum and may even vary between

measurements of the same drum.

The GEA-A and GEA-B systems must report an LLD for each of the ten WIPP-tracked

radionuclides. Only measured values that exceed the reported LLD for that measurement will be

reported and used in calculations of derived quanti ties, such as total TRU alpha activity and TRU

alpha activity concentration. The LLD values for al l operational modes (transmission-corrected

and multi-curve) are documented in the calibration report for each system. Both reports provide

data that indicate that the LLDs for both GEA syste ms are below 100 nCi/g for wastes with a net

weight over approximately 11 kg (density about 0.05 5 g/cc). This limit has been incorporated in

the Automated Independent Technical Review (AITR). Both GEA units have the required

sensitivity to make TRU/Non-TRU determinations in a ccordance with the 100 nCi/g TRU

criterion. There are no technical issues with the d etermination and documentation of the LLD for

the GEA-A and GEA-B units.

# 37



# (5) The GEA Units A and B are scheduled to participate in the CBFO-sponsored NDA

Performance Demonstration Program.

Both GEA Units are scheduled to participate in Cycl e 17A (May 2010 distribution) of the

CBFO-sponsored NDA Performance Demonstration Progra m (PDP), by assaying S5000 wastes

containing debris, glass, and sludge. EPA will eval uate the results of these assays when they

become available.

(6) EPA replicate testing of the GEA-A and GEA-B Units was performed and evaluated and

found to be adequate.

The purpose of the replicate testing performed as p art of this inspection is to provide the EPA

with an independent means to verify that the GEA-A and GEA-B Units can provide reproducible

results for the determination of the quantity of te n WIPP-tracked radionuclides ( 241 

# Am, 137 

# Cs,

238 

# Pu, 239 

# Pu, 240 

# Pu, 242 

# Pu, 90 

# Sr, 233 

# U, 234 

# U, and 238 

# U) and the TRU alpha concentration. EPA

selected replicate testing drums from the list of p reviously measured drums on each system. This

is accomplished by reassaying drums previously meas ured on the same system in order to

demonstrate the system’s ability to do the followin g:

• Produce results consistent with the reported TMU by comparing the sample standard

deviation for a number of replicate measurements ta ken over several hours or days to the

reported TMU; and

• Provide reproducible results over longer periods of time, such as weeks or months, by

comparing the results of the replicate measurement( s) to the original reported values.

As part of the inspection to evaluate the GEA units , EPA requested that each GEA unit reassay

three drums that EPA randomly selected from a list of previously assayed drums. EPA chose

container Nos. RL0063023, RL0050614 and RL0063005 f or GEA-A and RL0063034,

RL0056338 and RL062952536-8-37 for GEA-B. All six d rums were reassayed on the respective

GEA unit five times and the data for the five repli cates and the original assay were analyzed

using two statistical tests, a Chi-Squared (χ 2 

# ) Test and a t Test . Data and results of the statistical

analysis for both units are included in Attachments B.1 through B.4.12 and the results are

summarized below.

GEA-A:

• Container No. RL0063023: The five replicate 241 

# Am results for this container had a

tight grouping the average of which was sufficientl y different from the original assay to

trigger a “Significant” flag for the t Test . For 237 

# Np, the five replicates showed four

results that were less than the MDA and one reporta ble (greater than MDA) value, which

triggered the “Significant” flag. The actual diffe rences among these assay values are

small and these results are consistent with what ha s been observed on other NDA

systems. Both issues reflect the inherent weakness of the statistical tests and neither issue

bears further investigation at this time.

• Container No. RL0050614: The 137 

# Cs and 90 

# Sr results showed a “Highly Significant”

flag for the Chi-Squared Test . Since 90 

# Sr is scaled to the measured 137 

# Cs value any flag

# 38



# that is reported should be noted for both radionucl ides. The replicate and original 137 

# Cs

values are low and are subject to considerable vari ations, which triggers the “Highly

Significant” flag. The 241 

# Am and TRU Alpha Activity showed “Highly Significan t” flags

for the t Test . The actual variability occurred for the 241 

# Am value, which is incorporated

in the TRU Alpha Activity. The five replicates were grouped tightly with a mean activity

values that was approximately 60% higher than the o riginal assay, which translated to a

17% increase in TRU Alpha Activity. The 241 

# Am variation appears to be a true difference

although both the original and replicate assays are acceptable by all reported

measurement parameters. There are several possible explanations for this discrepancy,

including positional changes of the 241 

# Am-bearing items within the waste container due to

handling, which could cause elevated readings due t o a better counting geometry. No

further actions are warranted at this time although EPA may choose to revisit this issue

with Hanford-CCP at a later date.

GEA-B:

• Container No. RL0063034: The Chi-Squared Test and t Test

values exhibited variances

that were less than or equal to the limits of both statistical tests.

• Container No. 0056338: The Chi-Squared Test and t Test

values exhibited variances that

were less than or equal to the limits of both stati stical tests.

• Container No. RL062952: The Chi-Squared Test indicated two “Highly Significant”

flags, one for 238 

# Pu and one for 242 

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

# Pu. Due

to the low activity levels for these radionuclides, there was considerable variation in the

isotopic determinations assigned by MGA. This cause d differences in the isotopic

contribution of 240 

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

# Pu, 239 

# Pu

and 242 

# Pu isotopes. We have observed this problem previous ly, especially with low Pu

content drums where MGA runs poorly and a small abs olute difference (4%) produces

what appear to be large differences.

There are no technical issues associated with repli cate testing of GEA Units A and B.

Summary of NDA Findings and Concerns

The EPA inspection team did not identify any findin gs related to NDA during this inspection.

EPA did identify the single concern that is discuss ed above. A copy of the EPA Inspection Issue

Tracking Form documenting this concern is provided in Attachment C.3 to this report. EPA

considers this concern to have been adequately addr essed and there are no open findings or

concerns related to NDA resulting from this inspect ion.

Baseline Approval

EPA approves the NDA systems evaluated during this baseline inspection as described in this

report for CH retrievably-stored and newly-generate d TRU debris (S5000).

# 39



# NDA Tiers

Based on the inspection and results discussed above , EPA assigns the following tiers:

T1 NDA changes will require EPA review and approval prior to impl ementation and will apply

to any NDA system not evaluated during the baseline inspection. These include the following:

• The use of new, unapproved NDA equipment at WRAP or physical modifications to the

WRAP GEA Units A and B observed during this inspect ion

• Extension or changes to approved calibration range for the WRAP GEA Units A and B

Hanford-CCP must report and submit documentation on T1 changes when it is ready for EPA

review. Upon initial review, EPA will inform Hanfor d-CCP and CBFO whether a site inspection

is necessary. EPA may request additional informatio n, choose to conduct a desktop review,

and/or confer with Hanford-CCP personnel. Upon eval uation with or without site inspection,

EPA will issue a decision. Only upon receiving EPA written approval may Hanford-CCP use the

new NDA system for characterization of TRU wastes i ntended for disposal at the WIPP.

T2 NDA change includes notification to EPA upon completion of cha nges to software from

approved equipment, operating range(s), and site pr ocedures that require CBFO approval. These

changes do not require EPA approval before implemen tation. Hanford-CCP must provide

notification to EPA upon completion of these change s associated with the WRAP GEA Units A

and B evaluated during the baseline inspection.

8.3 Real-Time Radiography (RTR)

Waste Characterization Element Description

As part of the inspection of the RTR activities, th e EPA inspection team focused on overall

procedural technical adequacy and implementation, a s well as the identification of WMPs and

prohibited items, in reviewing the following RTR el ements:

• Documentation of RTR activities through use of an a pproved procedure

• Proper execution of RTR activities

• Management oversight and independent review of RTR activities

• Training of RTR personnel

The RTR facility uses radiography to help determine the following aspects of TRU waste

characterization:

• Types and amounts of WMPs

• Confirmation of the WMC

• Presence or absence of prohibited items

• Demonstration of capability testing for operators o n the RTR system using specifically

placed items

# 40



# Documents, BDRs, and Objective Evidence Reviewed

The following documents were among those the EPA in spection team examined to assess

whether all RTR operations follow the appropriate a pproved procedures:

• CCP-TP-053, Revision 7, CCP Standard Real-Time Radi ography (RTR) Inspection

Procedure, October 21, 2009

• CCP-TP-028, Revision 3, Radiography Test and Traini ng Drum Requirements,

January 19, 2006

• CCP-QP-002, Training and Qualification Plan, Revisi on 27, September 30, 2008

• CCP-QP-005, TRU Nonconforming Item Reporting and Co ntrol, Revision 18, August 13,

2009

• Standing Order CCP-SO-RL-01, April 14, 2010

• CCP-QP-008, Records Management, Revision 15, Octobe r 28, 2009

The following is a complete listing of all objectiv e evidence the EPA team evaluated during the

inspection:

• RTR BDRs and audio/visual recording of RTR events f or selected drums contained in

BDRs RLRTRA0001, RLRTRA0002, and RLRTRA0003

• NCR-RL-0642-10

• Written and audio/visual recordings of Capability Demonstration Data Sheet for ContactHandled Waste for various RTR operators

• Qualification card and training records for three R TR operators/ITRs

• CCP NDE Test Drum Inventory Sheet for HAN-NDETEST-0 2, -03, and -04

• List of currently qualified RTR personnel

• Measurement Conversion Chart

Technical Evaluation

During the inspection, the EPA inspection team eval uated the technical elements of the RTR

process using the checklist included as Attachment A.3 to this report. These areas are

summarized as follows:

(1) Overall procedural technical adequacy and implement ation were considered and were

found to be acceptable.

The RTR procedure, documented in CCP-TP-053, Revisi on 7, Standard Real-Time Radiography

(RTR) Inspection Procedure, contained specific info rmation on performing non-intrusive

radiography, including operational setup and checko ut, identification of prohibited items,

# 41



# assignment of WMPs and estimation of weights and vo lumes, confirmation of WMCs, input of

data, issuance of NCRs, and technical review of rad iography results.

(2) Characterization of Waste Material Parameters a nd prohibited items was assessed and

was found to be adequate.

Procedure CCP-TP-053, Revision 7, requires that rad iography audio/visual recording equipment

verification be performed at the beginning of every shift in which drums are subject to

examination. EPA inspectors confirmed adherence to verification requirements through

interviews with RTR operators, observation of an RT R event, and review of written BDRs and

audio/video tapes. There are two RTR units, A and B , at Hanford operated by CCP’s RTR

personnel for characterizing physical contents (i.e ., WMPs) of individual 55-gallon drums and

both of these were included in the scope of this in spection.

At the beginning of a shift, and before examining a ny waste containers, the operator runs a scan

on the lines-pair resolution test gauge to determin e that images are clearly visible. On the day of

the inspection, the operator had performed this che ck before EPA arrived at the facility, but the

inspectors reviewed the image quality check for Bat ch RLRTRA0025. This check was

determined to be acceptable and met Hanford-CCP req uirements. The operator had a copy of the

waste stream description available for review, and was able to answer questions regarding the

WMC assignment.

For each container undergoing examination, the oper ator makes an audio/video recording of the

RTR event. The first notations that the operator ma kes on the audio/video recording are the drum

number and the date and time on the audio/video rec ording before beginning the radiography

process. The examination of the drum begins at the top of the drum where the operator identifies

the seal and vent. The drum rotates through 360 deg rees so that all objects inside a drum are

visible from all sides. The operator can zoom both in and out and increase or decrease the scan

energy in order to compensate for varying densities in the material being examined. During

examination, the operator also “rocks” the drum to determine the presence of free liquids.

The RTR operator identifies WMPs, and a second staf f member enters the data electronically

into the RTR Data Sheet. This second person was an RTR operator in training and performs only

data entry at present. The waste stream being gener ated and processed in the PFP Building is

MPFPDD, which is a debris (S5000) waste stream. The re is a standardized weight table

(Table 3) in the standard operating procedure that provides weights for commonly encountered

waste items. WMP weight estimates are made and reco rded on the data sheet. The tare weight for

containers is obtained from standing order CCP-SO-R L-01.

As part of the inspection, the EPA team observed th e examination of waste container

RL0056204, which formed part of batch RLRTRA0025. T he EPA inspectors also reviewed the

audio/visual recordings of container RL0063057 and the Independent Observation for this

container. EPA determined that the QC performed was appropriate and that information on the

audio/visual recording matched the written RTR reco rd (BDR). During the on-site

demonstration, the operator used an uncontrolled me thod to calculate the volume of liquid found

in the folds of plastic within the drum. EPA discus sed this with Hanford-CCP RTR personnel

# 42



# and generated an EPA Inspection Issue Tracking Form to address this issue. The issue is

summarized below (see Attachment C.3 for a copy of this form):

EPA Inspection Issue No. Hanford-CCP-CH-RTR-10-001C R: The RTR operator used a

“Measurement Conversion Chart” to calculate the vol ume of liquid identified during RTR

examinations and made process decisions based on th e result. This chart is not a controlled

document and the calculation used is incorrect. EPA is concerned regarding the origin and

prevalence of this practice.

Resolution: Hanford-CCP responded that the RTR characterization process to date relies on

operator training, judgment, and experience to esti mate liquid volumes and that this subjectivity

is recognized in the EPA suggested training manual. Hanford-CCP also stated that since the RTR

characterization requirements recognize estimations of liquid volume as sufficient, controlling

common geometric conversions and subsequent arithme tic operations as part of the permanent

record is beyond the scope of the requirement. RTR operators are encouraged to use additional

techniques to better identify free liquids and qual ity controls, including ITR review, are in place

to identify discrepancies in free liquid volumes an d correct any estimation errors. Hanford-CCP

pointed out that as the referenced mis-calculation had not been through the entire review process,

there is no way to know if the operator mistake wou ld have been identified and corrected.

Status of Concern: EPA believes that approximatio n of waste components is adequate;

however, EPA needs to have confidence that the info rmation DOE provides on waste

components is reasonable and can be supported, and is auditable. DOE needs to demonstrate

that its implementation of the system of controls i ncluding processes and equipment used for

waste characterization, and training of personnel c haracterizing waste are credible. In this

instance EPA is verifying the appropriate implement ation of waste characterization processes at

TRU sites.

In the report accompanying the proposed approval, E PA required that when mathematically

estimating volume of liquid in a container, the ope rator must maintain auditable records. These

records can then be used by an ITR or SPM to verify results. EPA received public comment

against this requirement. As discussed in Section 9 .0 of this report, EPA disagrees with the

Commenter and determines that not only the maintena nce of auditable records is necessary but

also the process implemented to calculate liquid co ntents in a container needs to be revised, and

EPA will review implementation of the revised proce dure at CCP-serviced CH TRU sites. Also,

RTR operators need to be trained to the revised pro cedures and tested to determine proper use of

a mathematical formula for calculating liquid in a container. This concern is closed.

RTR performed for any new waste category groups tha t was not evaluated during the baseline

inspection is a T1 change and will require EPA revi ew and approval prior to implementation.

(See Table 1 where this is included as a T1 change)

.

Notification to EPA upon completion of modification s to approved equipment, RTR units A and

B, changes made to RTR procedure(s) that require CB FO approval and the addition of new SCG

to the RTR processes that are subject to this appro val are all T2 changes that require EPA

notification. Consistent with EPA’s authority under 40 CFR 194.24(h), EPA may request this

# 43



# information if EPA deems it necessary to ensure con tinued compliance with EPA regulations.

(See Table 1 where this is included as a T2 change. )

(3) Documentation of radiography activities was exa mined and was found to be adequate.

Simultaneous written and audio/visual recordings ar e made as the waste is examined. The EPA

inspectors observed this during the examination of waste container RL0056204 and further

verified it by review of RTR BDRs and audio/visual recordings. RTR data are entered

electronically into Attachment 2, CCP Radiography D ata Sheet, from procedure CCP-TP-053 as

they are generated.

(4) EPA ascertained that documentation of radiograp hy procedures was adequate.

Radiography procedures are well defined and the doc uments are controlled. During the

inspection, the EPA team reviewed the adequacy and implementation of all radiography-related

procedures. QC examinations were performed as requi red by the procedure. In batch

RLRTRA0001, an independent observation was performe d on container RL0037205 and a

replicate scan was performed on container RL0063057 ; in batch RLRTRA0002, an independent

observation was performed on container RL0058636 an d a replicate scan was performed on

container RL0066836; and in batch RLRTRA0003, an in dependent observation was performed

on container RL0066877 and a replicate scan was per formed on container RL0062953.

Although NCRs were not available for review in BDRs RLRTRA0001, RLRTRA0002, and

RLRTRA0003, the operator interviewed was able to de scribe how NCRs are initiated and

documented. To verify this information, EPA reviewe d NCR-RL-0642-10 issued against

container RL0055166, BDR RLRTRB0018, even though th is NCR had not been through the

required reviews. EPA determined that the NCR was i ssued and processed in accordance with

CCP procedures.

The BDRs the EPA examined had been reviewed at the data generation level (ITR) and project

level (SPM) as required.

(5) Training of radiography personnel was adequate.

During the inspection, the EPA team reviewed docume ntation of the capability demonstration for

selected radiography personnel. The inspectors view ed the audio/visual recording for the latest

capability demonstration drum for the RTR SME and a n RTR operator during the inspection.

The RTR SME is responsible for verification of qual ification for RTR operators. Training

records reviewed indicate that only trained personn el were operating the RTR equipment.

EPA also reviewed the Qualification Cards and train ing records for selected RTR personnel.

Training documentation was complete and was filed c orrectly for purposes of reviewing and

reference.

# 44



# Summary of RTR Findings and Concerns

The EPA team did not identify any findings and iden tified one concern requiring a response for

RTR during the on-site inspection.

Baseline Approval

The baseline conditions that the EPA inspection tea m evaluated during this inspection consisted

of the following:

• Trained personnel, RTR operator/ITR and SME

• Approved and controlled operating procedures CCP-TP -053, Revision 4; CCP-QP-002,

Revision 27; CCP-TP-028, Revision 3

• RTR records and supporting data, CCP-TP-053 and CCP -TP-001 review checklists,

operator Demonstration of Capability records, and B DRs

• RTR Units A and B

This system is suitable for RTR of CH TRU S5000 deb ris wastes

.

RTR Tiers

Based on the inspection and the results discussed a bove, EPA proposes assigning the following

tiers:

T1 RTR changes will require EPA review and approval prior to impl ementation. There are no

T1 changes at this time.

Hanford-CCP must report and submit documentation on T1 changes when they are ready for

EPA review. Upon initial review, EPA will inform Ha nford-CCP and CBFO whether a site

inspection is necessary. EPA may request additional information, choose to conduct a desktop

review, and/or confer with Hanford-CCP personnel. U pon evaluation with or without a site

inspection, EPA will issue a decision. Only upon re ceiving EPA written approval may HanfordCCP implement T1 changes.

T2 RTR changes that do not require EPA approval before implementation b ut require HanfordCCP to report and submit documentation discussing s uch changes include the following:

• Modifications to approved equipment, RTR units A an d B

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

• Addition of new SCG to the RTR processes that are s ubject to this approval

• Use of a different type of RTR unit from what was i ncluded in the baseline approval, e.g.,

a high-energy RTR unit

Every three months from the date of EPA approval, H anford-CCP will provide information

concerning T2 changes. If new RTR equipment is in u se, EPA inspection may be necessary. EPA

# 45



# will evaluate changes and communicate with Hanford- CCP regarding whether the changes raise

any concerns and require Hanford-CCP response, or w hether Hanford-CCP can continue to

implement the changes.

8.4 Visual Examination (VE)

Waste Characterization Element Description

As part of the inspection of the VE activities, the EPA inspection team focused on overall

procedural technical adequacy and implementation, a s well as the identification of WMPs and

prohibited items, in reviewing the following VE ele ments:

• Documentation of VE activities through use of an ap proved procedure

• Proper execution of VE activities

• Management oversight and independent review of VE a ctivities

• Training of VE personnel

The VE process for CH debris (S5000) waste performe d at Hanford uses manual examination to

determine the following aspects of TRU waste charac terization:

• Identification and weight estimate of WMPs

• Confirmation of the WMC

• Confirmation of presence or absence of prohibited i tems

The VE must be performed by two trained and qualifi ed VEOs, as described in procedure

CCP-TP-053.

Documents, BDRs, and Objective Evidence Reviewed

The following documents were among those the EPA re viewed to assess whether VE operations

follow the appropriate approved procedures and meet VE requirements:

• CCP-TP-113, CCP Standard Contact-Handled Waste Visu al Examination, Revision 13,

March 11, 2009

• CCP-QP-002, Training and Qualification Plan, Revisi on 27, September 30, 2008

• CCP-QP-005, TRU Nonconforming Item Reporting and Co ntrol, Revision 18, August 13,

2009

• CCP-AK-RL-101, Revision 2,

• CCP-QP-008, Records Management, Revision 15, Octobe r 28, 2009

Following is a complete list of all objective evide nce that the EPA inspection team evaluated

during the inspection:

• Visual Examination BDRs RLVEPF0022 and RLVEPF0023

# 46



# • List of currently qualified VE personnel, April 14, 2010

• Qualification card and training records for three V E operators and one VE

operator/Visual Examination Expert (VEE)

• Letter appointing the VEE, March 12, 2010

Technical Evaluation

During the inspection, the EPA inspection team eval uated the technical elements of the VE

process using the checklist included as Attachment A.4 to this report. These areas are

summarized as follows:

(1) Overall procedural technical adequacy and implement ation were assessed and found to be

adequate.

The VE procedure, documented in CCP-TP-113, Revisio n 13, contained specific information on

performing VE, including identification of prohibit ed items, assignment of WMPs, and technical

review of VE results. EPA inspectors usually observ e a VE evolution as part of the inspection

process, but this was not possible at Hanford-CCP d ue to safety concerns inside PFP.

Implementation of the VE process was assessed using review of written records and by

interviewing VE personnel.

Any new waste category or VE process that was not e valuated during the baseline inspection is a

T1 change and will require EPA review and approval prior to implementation. Specifically, this

applies to performance of VE by any method other th an using two trained operators to perform

actual VE at the time of packaging (VE of records b y two operators is not included in this

approval). (See Table 1 where this is included as a T1 change).

(2) Characterization of Waste Material Parameters and p rohibited items was evaluated and

was found to be adequate.

EPA interviewed trained VE operators (VEOs) and VEE to determine how VE data are

generated and recorded. EPA inspectors were unable to observe a VE event because of safety

concerns; operators are required to wear full respi rator suits to work in the VE area and EPA

inspectors are not trained for this type of operati on. The waste stream being processed at the time

of the on-site inspection was MPFPDD, which is a de bris (S5000) waste stream. Site personnel

manipulate the waste items while CCP VEOs identify and record them. VE is always performed

by two trained VE operators. Waste items are curren tly being generated from break-down of

glove boxes in PFP. These waste items, such as pipe s, brackets, and saw-blades are taped

together into packages and numerically identified o n the outside of the package. VE data forms

record both the contents of each package and the pa ckaging materials used, such as “plastic bag

and duct tape.” VEOs identify and record WMPs and estimated weights are assigned. The VEOs

do use the standard weights in Table 4 of CCP-TP-11 3, but not all items in this waste stream are

included there. Hanford-CCP VE personnel were able to identify prohibited items and how they

will be processed when located in the waste. Verifi cation that the physical form of the waste

matches the WMC is recorded. VE is performed by two trained VE operators.

# 47



# Upon inspection of VE documentation, EPA identified a discrepancy as a concern. EPA

discussed this concern with Hanford-CCP personnel a nd captured it on an Inspection Issue

Tracking Form (see Attachment C.3 for a copy of thi s form), and is summarized below:

EPA Inspection Issue No. Hanford-CCP-CH-VE-10-006CR : The VEE appointment letter

was dated March 2010, although Hanford-CCP has been performing VE at Hanford since the

summer of 2009.

Resolution: Hanford-CCP provided a VEE appointment letter date d July 2, 2009, which

predates all VE characterization activities as docu mented on the VE BDRs. Additionally,

Hanford-CCP also provided documentation of the reje ction of all VE BDRs completed or started

before April 22, 2010.

Status of Concern: EPA considers this concern to be closed.

T2 VE changes that do not require EPA approval prio r to implementation include the following

changes made to VE procedure(s) that require CBFO a pproval and the addition of new SCG to

the VE processes that are subject to this approval

(3) Documentation of Visual Examination activities was examined and found to be adequate.

EPA inspectors reviewed BDRs RLVEPF0022 and RLVEPF0 023 to verify that the VE data

were documented correctly and completely. Site pers onnel used Attachment 2 from CCP-TP-113

to record these data. The two BDRs had been reviewe d at data generation and project level as

required. No NCRs had been issued during the VE and review processes.

(4) Training for Visual Examination personnel was exami ned and found to be adequate.

Hanford-CCP maintains a list of qualified individua ls, which it uses to ensure that all training is

current. Hanford-CCP documents the personnel who ar e trained for performing VE and data

generation-level data review, and the VEE. As part of the inspection, the EPA team reviewed the

Qualification Cards for VEOs and the VEE and found that they required comprehensive and

adequate training for VE personnel. These training records were completed and available for

review.

The EPA inspectors reviewed the following records:

• Visual Examination BDRs RLVEPF0022 and RLVEPF0023

• List of currently qualified VE personnel, April 14, 2010

• Qualification Card and training records for the VE operators and VEE

• Letter appointing the VEE, dated March 12, 2010

The VEE interviewed was not able to describe EPA re gulations or requirements. EPA discussed

this with Hanford-CCP personnel and EPA captured th is on an Inspection Issue Tracking Form.

The issue is summarized below (see Attachment C.3 f or a copy of this form):

# 48



# EPA Inspection Issue No. Hanford-CCP-CH-VE-10-005F: VE personnel interviewed did not

have any knowledge or understanding of EPA regulati on(s) as required by CCP-PO-002,

Revision 22, Appendix 10, Section 10.2. EPA had ide ntified this issue previously in the waste

characterization programs at both ORNL-CCP and SRS- CCP. EPA requires that VEOs be

trained to Federal Regulations (CFR Part 194.24) be fore the first CH TRU waste shipment is

scheduled from Hanford-CCP.

Resolution: In response to this finding, CBFO provided a docume nt EPA Requirements for

TRU Waste Disposal as Applied to VE and RTR , EPA-01, Revision 0, dated May 11, 2010. EPA

reviewed this document and determined that it adequ ately addressed EPA’s concern.

Status of Concern: EPA considers this issue to be closed.

EPA identified a discrepancy with respect to the da te on which the VEE was appointed. EPA

discussed this with Hanford-CCP VE personnel and ca ptured this on an Inspection Issue

Tracking Form. The issue is summarized below (see A ttachment C.3 for a copy of this form):

EPA Issue No. Hanford-CCP-CH-VE-0006CR: The Hanford-CCP VEE was appointed in

March of 2010, after VE had begun at the site.

Resolution: The Hanford-CCP SPM stated in the inspection clos ing meeting that this was not a

problem because Hanford-CCP had decided to RTR all containers that had previously undergone

VE, except for the containers in BDRs RLVEPF0022 an d RLVEPF0023.

Status of Concern: EPA considers this issue to be closed.

Summary of VE Findings and Concerns

EPA generated one finding and one concern requiring a response during this inspection, as

discussed above.

Baseline Approval

EPA approved the VE process for S5000 debris waste that the EPA inspection team evaluated

during this baseline inspection, consisting of the following elements:

• Trained personnel, specifically VEOs, VEE, and SPM

• Approved and controlled operating procedures, speci fically CCP-TP-113, Revision 13

using 2 trained VEOs; CCP-QP-002, Revision 27

• VE records and supporting data, CCP-TP-113 and CCP- TP-001 review checklists, and

VE BDRs

This approval is limited to execution of VE by two trained operators at the site. This system is

suitable for VE of CH TRU S5000 debris waste.

# 49



# VE Tiers

T1 VE changes will require EPA review and approval prior to impl ementation, and will apply to

any new waste category or process that was not eval uated during the baseline inspection. The

one T1 change identified is performance of VE by an y method other than using two trained

operators to perform actual VE at the time of packa ging (VE of records by two operators is not

included in this approval).

Hanford-CCP must report and submit documentation on T1 changes when they are ready for

EPA review. Upon initial review, EPA will inform Ha nford-CCP and CBFO whether a site

inspection is necessary. EPA may request additional information, choose to conduct a desktop

review, and/or confer with Hanford-CCP personnel. U pon evaluation with or without a site

inspection, EPA will issue a decision. Only upon re ceiving EPA written approval may HanfordCCP implement T1 changes.

T2 VE changes that do not require EPA approval prior to implemen tation, but require HanfordCCP to report and submit documentation, include the following:

• Changes made to VE procedure(s) that require CBFO a pproval

• Addition of new SCG to the VE processes that are su bject to this approval

Hanford-CCP will provide EPA with information conce rning T2 changes on a quarterly basis,

including a brief description of the available info rmation. EPA will evaluate these changes and

communicate with Hanford-CCP as to whether the chan ges raise any concerns and require a

Hanford-CCP response, or whether Hanford-CCP can co ntinue to implement the changes.

Consistent with EPA’s authority under 194.24(h), EP A may request information relative to these

changes if EPA deems the information is necessary t o ensure continued compliance with EPA

regulations.

8.5 WIPP Waste Data System (WDS)

Waste Characterization Element Description

In December of 2009, the data entry system used to certify containers for disposal, previously

WWIS, was changed from an Oracle-based to a web-bas ed system. This new system was named

Waste Data System (WDS) and data entry procedure CC P-TP-030 was revised to include the

necessary changes. The title of this procedure was changed to “CCP CH TRU Waste

Certification and WWIS/WDS Data Entry” and a new Us er’s Manual was issued. The EPA team

determined, through interview, that the differences between WWIS and WDS were minor in

nature and process improvements had been made durin g this change. EPA has previously

inspected the WWIS process and determined that CCP had successfully submitted CH waste

characterization data to the database. At the time of the on-site inspection, the Waste Stream

Profile Form for MPFPDD had not been approved and d ata could not be entered into the WDS

proper to demonstrate that the effectiveness of dat a submission had not been compromised due to

the change from WWIS to WDS. Procedure CCP-TP-030 i s used for submittal of both

characterization and certification CH data to the W DS. Waste Certification Assistants (WCAs)

# 50



# and Waste Certification Officials (WCOs) are based in the CCP office in Carlsbad, New Mexico,

and data transfer is performed electronically

.

Documents, Records, and Objective Evidence Reviewed

The following documents were among those the EPA in spectors reviewed to assess whether

WDS operations follow the appropriate approved proc edures and meet WDS requirements:

• CCP-TP-030, Revision 27, CCP CH TRU Waste Certifica tion and WWIS/WDS Data

Entry, December 14, 2009

• CCP-QP-002, Revision 27, Training and Qualification Plan, September 30, 2008

The EPA inspectors evaluated the following objectiv e evidence during the inspection:

• Waste Container Data Report for containers RL006302 1 and RL0063034

• CCP Correlation of Container Identification Numbers to Batch Data Reports, waste

stream MPFPDD, lot #1

• WDS data entry summary, characterization and certif ication, spreadsheet for containers

RL0062930, RL0063034, RL0063014, RL0063021, RL00630 40

• CCP-QP-022, Software Quality Assurance Plan, Attach ment 3, Software Problem

Reporting and Change Request for WDS Master Templat e, SCO # 1065, versions 1 and 2

• WCO qualification card and training record

• DA e-mail rescinding database access for employee

Technical Evaluation

During the inspection, the EPA inspection team eval uated the technical elements of the WDS

process using the checklist included as Attachment A.5 to this report. These areas are

summarized as follows:

(1) Overall procedural technical adequacy was evaluated and found to be adequate as

observed during the inspection.

CCP has successfully submitted characterization and certification into WWIS and, while this

now takes place in WDS, the process followed is ess entially the same for both data bases. The

WDS procedure documented in CCP-TP-030, RH TRU Wast e Certification and WWIS/WDS

Data Entry, Revision 27, is well defined and contro lled, and contains instructions for entering,

reviewing, and transmission of data. The procedure was revised to allow the use of WDS and

issued on December 12, 2009. The new Microsoft Exce l spreadsheet used for data entry was also

adequate and controlled. WDS incorporates some chan ges to WWIS, for example, WCOs can

now change uploaded data, rather than the Database Administrator. A new user’s manual,

DOE/CBFO-09-3427, Waste Data System User’s Manual w as generated and issued to support

the implementation of this new system. At the time of the on-site inspection, the subject waste

# 51



# stream did not have an approved Waste Stream Profil e Form and so the demonstration provided

only included the test instances of the system. The WCO demonstrated to the EPA inspectors

how data were entered, uploaded, and tracked in the WDS. To ensure that the system is effective

when used for actual certification of containers, L ANL drum LA00000064320 located in SWB

LASB00811, was tracked back from emplacement to the original characterization BDRs. No

issues were identified for the adequacy and impleme ntation of this new system.

EPA identified a discrepancy with respect to docume ntation of the WDS. EPA discussed this

with Hanford-CCP personnel and captured this on an Inspection Issue Tracking Form. The issue

is summarized below (see Attachment C.3 for a copy of this form):

EPA Inspection Issue No. Hanford-CCP-CH-WDS-10-002C R: CCP training procedure

CCP-QP-002, Revision 27, Section [C.3] requires WCO s to demonstrate proficiency in WWIS

as part of training. However, WDS is not specifical ly identified in the training procedure,

although this is the only User’s Manual listed in t he reference section of CCP-TP-030. The

Hanford-CCP Project Manager indicated that the proc edure(s) associated with data entry are

being revised at this time.

Response: Hanford-CCP personnel indicated that CCP training procedure CCP -QP-002,

Revision 27, Section [C.3] lists the requirement fo r WCOs to demonstrate proficiency in WWIS

as part of training as an example of the types of a ctivities that may be performed after

completion of a “core” qualification card. At the t ime of the Hanford-CCP baseline inspection,

CCP-QP-002 was in revision to remove the list of sa mple activities that may be performed after

completion of a “core” qualification card because i nclusion of such a list is not a requirement.

Deletion of this list removes any confusing referen ces to WWIS/WDS in CCP-QP-002. HanfordCCP also pointed to language in the User’s Manual ( DOE/CBFO-09-3427) that defines WWIS

database as a subsystem of the WDS.

Status of Concern: EPA considers this issue to be closed.

(2) Implementation and documentation of WDS activit ies were examined and found to be

adequate.

Hanford-CCP did not have an approved WSPF for waste stream MPFPDD at the time of the onsite inspection and consequently had not generated any official records for EPA’s review. A

qualified Hanford-CCP WCO demonstrated the characte rization and certification process by

uploading CH data into the test instance of WDS. Ho wever, the usual records (e-mails, signed

data spreadsheet, etc.) were not available for revi ew.

After the characterization data have been through e very level of review and approval, they are

entered into a controlled Excel spreadsheet by a WC A. A review of the spreadsheet is made by a

second WCA to verify correct data entry. The WCO re views the data to ensure that they are

WIPP-compliant and signs the spreadsheet to accept the data. Closure of associated NCRs is

verified by the SPM. EPA inspectors verified valida tion of Versions 1 and 2 of the WDS Excel

spreadsheet.

# 52



# The WCO was able to demonstrate data entry into the test instance of WDS. WDS data entry

summaries and the Waste Container Data Report were retrieved when requested by EPA. To

verify that data entered into WDS proper could be r etrieved, a randomly chosen LANL container

was traced back from emplacement to the original ch aracterization BDRs. Although EPA was

not able to challenge WDS with data from waste stre am MPFPDD, the WCO demonstrated

sufficient information about the data system to ena ble EPA to conclude that the WDS was

adequate for container certification.

T2 WDS changes include changes to WDS procedure(s) that require CBFO approval and

changes to the Excel spreadsheet titled WDS Master Template.xls, Revision 2, Addendum #2,

SCO #1065.

(3) Training of WDS personnel was reviewed and was foun d to be adequate.

The EPA inspectors observed limited job performance of a WCO to verify personnel training and

qualification. Inspectors also reviewed the qualifi cation card and training records for the WCO

providing the on-site demonstration.

The training procedure CCP-QP-002 requires WCOs to demonstrate proficiency in WWIS, but

does not include WDS. EPA generated Concern No. Han ford-CCP-CH-WDS-10-002CR to

address this issue.

Summary of WDS Findings and Concerns

The EPA inspection team did not identify any findin gs related to WDS. EPA did identify one

concern requiring a response discussed above.

Baseline Approval

EPA approves the WDS container certification system that the EPA evaluated during this

baseline inspection, consisting of the following el ements:

• Trained WDS, WCA, and WCO

• Approved and controlled operating procedures CCP-TP -030, Revision 27 and

CCP-QP-002, Revision 27

• Approved and controlled data entry Excel spreadshee t titled WDS Master Template.xls,

Revision 2, Addendum #2, SCO #1065

WDS Tiers

T1 WDS changes will require EPA review and approval prior to impl ementation, and will apply

to any new waste category or process that was not e valuated during the baseline inspection.

There are no T1 changes at this time.

# 53



# Hanford-CCP must report and submit documentation on T1 changes when they are ready for

EPA review. Upon initial review, EPA will inform Ha nford-CCP and CBFO whether a site

inspection is necessary. EPA may request additional information, choose to conduct a desktop

review, and/or confer with Hanford-CCP personnel. U pon evaluation with or without a site

inspection, EPA will issue a decision. Only upon re ceiving EPA written approval may HanfordCCP implement T1 changes.

T2 WDS changes that do not require EPA approval prior to implemen tation, but require

Hanford-CCP to report and submit documentation, inc lude the following:

• Changes to WDS procedure(s) that require CBFO appro val

• Changes to the Excel spreadsheet titled WDS Master Template.xls, Revision 2,

Addendum #2, SCO #1065

Hanford-CCP will provide EPA with information conce rning T2 changes on a quarterly basis,

including a brief description of the available info rmation. EPA will evaluate these changes and

communicate with Hanford-CCP whether the changes ra ise any concerns and require a HanfordCCP response, or whether Hanford-CCP can continue t o implement the changes. Consistent with

EPA’s authority under 194.24(h), EPA may request in formation relative to these changes, if EPA

deems the information is necessary to ensure contin ued compliance with EPA regulations.

9.0 RESPONSE TO COMMENTS

On October 6, 2010, EPA received initial comments f rom one Commenter on the following two

issues: (1) estimating the liquid contents of a dr um using a mathematical equation(s); and (2)

evaluation of High Energy RTR equipment as a T1 cha nge. (See EPA Air Docket EPA-HQOAR-2010-0711 for complete comments). Both issues a re discussed below. EPA requested

additional explanation specific to the first issue, and the Commenter provided follow-up

information on October 25, 2010. The initial and fo llow-up comments, a listing of the follow-up

documentation, and EPA response to the public comme nts are included in Attachment E of this

report. Below is EPA’s response.

EPA Response to Comment No. 1: Estimating the liqui d contents of a drum using a

mathematical equation: EPA reviewed the additional information the comment er provided in

response to the proposed requirement which is inclu ded as Attachment E of this report. The

Commenter states “The RTR operator used a “Measurem ent Conversion Chart” to calculate the

volume of liquid identified during RTR examinations . This chart is not a controlled document

and the calculation used is incorrect. EPA is conce rned regarding the origin and prevalence of

this practice.” EPA believes that volumes estimated using the calculations observed, will lead to

an unwarranted assumption of confidence in the accu racy of the estimate. Also, the calculated

liquid volumes as currently done may lead to a grea ter expectation of accuracy, and requiring

these as auditable records is justified. As discuss ed below, EPA disagrees with Commenter’s

contention that using mathematical formulae to calc ulate liquid volumes is a “process

improvement.” This disagreement is based on the poo r implementation of the process that EPA

# 54



# inspectors observed at Hanford and at two other CCP -serviced TRU sites (Idaho National

Laboratory and Savannah River Site).

Information provided as response to EPA’s proposed approval (included as Attachment E of this

report) included RTR training material and attendan ce sheets for RTR personnel. The training

modules provided in the Commenter’s response did no t address significant figures or a technique

for rounding values. The training material is compr ehensive and concluded with an examination;

however, the examination results were not provided to EPA for review. The calculation for an

irregular prism is incorrect in both training modul es. When calculating liquid volume more

precision and accuracy is implied, though it is sti ll just an estimate; if incorrect, then it is a poo r

estimate. EPA does not concur with CCP or CBFO’s in sistence to calculate a precise quantity of

liquid when the estimation method can provide the d esired precision.

In addition, the Commenter’s response in Attachment E stated that volume calculations are not

required to be part of the written record because o f possible bias during ITR review. Commenter

did not sufficiently elaborate on how availing such calculations as auditable records could bias a

reviewer’s decision. It is unclear to EPA why the Commenter’s concern of bias is limited to

liquid volume calculations. ITR review has always i ncluded estimated WMP weights, which are

critical to the repository’s performance, without a ppearing to trigger bias.

In summary, EPA concludes that the CCP process for calculation of liquid volumes during RTR

is neither adequately developed for its use by RTR operators nor effectively and consistently

implemented throughout the CCP complex, as evidence by the issues identified at Hanford in

April 2010, and elsewhere since then.

If CCP continues to use this method of calculation of liquid volume of containers around the

Complex including Hanford, CCP must do the followin g:

• Maintain auditable records of calculated liquid vol ume in a container;

• Revise the “Measurement Conversion Chart” to make i t better suited to operator’s

skill level;

• Improve training of RTR Operators and make it consi stent so that subjectivity is

minimized; and

• Provide EPA with the revised training material, tes t questions for operator

qualification, and test results.

Unless these steps are taken, the CCP is prohibited to use the current mathematical estimation

method for different shapes to calculate liquid vol ume in containers.

EPA Response to Comment No. 2: Use of High Energy R TR equipment as a Tier 1 change:

EPA agrees that new RTR unit or modification to an approved unit has been identified as a Tier

2 change in the past at all CCP-serviced TRU sites. Therefore, EPA identifies CCP’s

implementation of the High Energy RTR unit at Hanfo rd as a T2 change. The text and the tiering

table in this report have been changed accordingly.

# 55



# A new RTR unit or modification of an approved unit is a T2 change at other EPA-approved CCP

TRU sites. However, if modifications to an approved unit are sufficiently significant (such as

those Hanford-CCP intends to make in the coming mon ths), then EPA may evaluate

implementation of such RTR-specific T2 change(s) pr ior to EPA’s concurrence of CBFO’s draft

certification/recertification letter incorporating changes to the certified RTR equipment. CBFO

must notify EPA about the use of a new RTR unit or modification to an approved unit as soon as

Hanford-CCP is ready for CBFO’s certification audit

.

10.0 SUMMARY OF RESULTS

10.1 Findings and Concerns

The finding and concerns identified during the insp ection, as well as Hanford-CCP responses,

are discussed in the preceding sections of this rep ort. Attachment C includes copies of the EPA

Inspection Issue Tracking Forms that capture these issues.

Hanford-CCP responded to the one EPA finding and fi ve EPA concerns subsequent to the

inspection. The EPA inspection team members evaluat ed all responses for completeness and

adequacy and concluded that each EPA issue requirin g a response had been resolved

satisfactorily. No EPA issues related to the baseli ne inspection of Hanford-CCP remain open at

this time.

10.2 Conclusions

The EPA inspection team determined that the Hanford -CCP waste characterization program

activities were technically adequate. EPA approves the Hanford-CCP waste characterization

program in the configuration observed during the ba seline inspection and described in this report

and the attached checklists (Attachments A.1 throug h A.5). This baseline compliance decision is

based on EPA’s inspection completed April 27-29, 20 10, and in consideration of the public

comment received on the proposed baseline approval. This approval includes the following:

(1) The AK process for retrievably-stored CH TRU debris wastes

(2) The GEA-A and GEA-B systems for assaying CH TRU was tes

(3) The NDE process of RTR for CH TRU debris wastes

(4) The NDE process of VE for CH TRU debris wastes

(5) The WDS process for tracking of waste contents of C H TRU wastes

This baseline approval of Hanford-CPP does not incl ude load management. Also, this approval

prohibits Hanford-CCP from a process currently impl emented for mathematically calculating

container liquid contents during RTR. If CBFO wants to allow CCP to use this method of

calculation of liquid in a container at CH TRU incl uding Hanford, then the following steps are

necessary:

• Maintenance of auditable records when liquids in a container are calculated using

mathematical formulae;

# 56



# • Revision and simplification of the “Measurement Con version Chart” to make it better

suited to match operator’s skill level;

• Improved on-the-job training of RTR Operators to ma ke it consistent among different

operators to minimize subjectivity; and

• Submission to EPA for evaluation and approval the r evised training material, test

questions for operator qualification, and test resu lts prior to implementation.

Unless these steps are taken, the CCP is prohibited to use the mathematical formulae for different

liquid shapes to calculate liquid volume in contain ers.

A new RTR unit or modification of an approved unit is a T2 change at other EPA-approved CCP

CH TRU sites. However, if modifications to an appro ved unit are sufficiently significant (such as

those Hanford-CCP intends to make in the coming mon ths), then EPA may evaluate

implementation of such RTR-specific T2 change(s) pr ior to EPA’s concurrence of CBFO’s draft

certification/recertification letter incorporating changes to the certified. CBFO must notify EPA

about the use of a new RTR unit or modification to an approved unit as soon as Hanford-CCP is

ready for CBFO’s certification audit.

Table 10 below closely follows the format used in t he previous CH baseline approval reports.

The table identifies applicable T1 and T2 changes t hat may be necessary in the future to the

EPA-approved CH TRU waste characterization baseline program. Hanford-CCP must report and

receive EPA approval of any T1 changes to the Hanfo rd-CCP waste characterization activities

from the date of the baseline inspection. This appr oval must be sought prior to the

implementation of each of the T1 changes identified in Table 10. Additionally, Hanford-CCP

must notify EPA regarding T2 changes according to T able 10, below. (See Section 2.0 of this

report for a brief discussion of tiering.) Upon ap proval of the T1 changes, EPA will post the

results of the evaluations to the EPA Web site and by sending e-mails to the WIPPNEWS list, as

described above. Upon completion of its review and concurrence of the T2 changes submitted at

the end of each fiscal quarter, EPA will post the T 2 changes. EPA expects the first report of

Hanford-CCP’s T2 changes at the end of the first qu arter following approval.

# 57



# Table 10. Tiering of TRU Waste Characterization Pr ocesses Implemented by Hanford-CCP

Based on April 27-29, 2010 Site Baseline Inspection

Process Elements Hanford-CCP T1 Changes Hanford-CCP T2 Changes a



# Acceptable Knowledge

(AK) Implementation of load management

Implementation of AK for wastes other

than retrievably-stored debris

(i.e., retrievably-stored soil/gravel and/or

solids) Notification to EPA upon completion of new versions or

updates/ substantive changes b 

# of the following:

- Modification of CCP-TP-005, Revision 18

- Availability of modifications to the AKSR

- Availability of all final WSPF with related

attachments

- Availability of all AK Accuracy Reports

- Availability of successful training records

- Availability of the AK-NDA memorandum

Non Destructive Assay

(NDA) New equipment or physical

modifications to approved equipment c



# Extension or changes to approved

calibration range for approved equipment Notification to EPA upon completion of changes to

software for approved equipment, operating range(s)

, and site procedures that require CBFO approval

Real-Time Radiography

(RTR) There are no T1 changes at this time Notification t o EPA upon the following:

- Modification c 

# to approved equipment, RTR

units A and B

- Completion of changes to site RTR procedures

requiring CBFO approvals

- Addition of new SCG to the RTR processes that

are subject to this approval

Implementation of a different type of RTR equipment

Visual Examination (VE) Performance of VE by any me thod other

than using two trained operators to

perform actual VE at the time of

packaging Notification to EPA upon the following:

- Completion of changes to site VE procedure(s)

requiring CBFO approvals

- Addition of new SCG to the VE processes that

are subject to this approval

Waste Data System

(WDS) There are no T1 changes at this time Notification t o EPA upon the following:

- Completion of changes to WDS procedure(s)

requiring CBFO approvals

- Changes to the Excel spreadsheet titled WDS

Master Template.xls, Revision 2, Addendum

#2, SCO #1065

a 

# Upon receiving EPA approval, Hanford-CCP will repor t all T2 changes to EPA at the end of each fiscal q uarter. Note: EPA

may request specific T2 change items before the end of a fiscal quarter.

b 

# “Substantive changes” are changes with the potentia l to impact the site’s waste characterization activ ities or documentation

thereof, excluding changes that are solely related to ES&H, nuclear safety, or RCRA, or that are edito rial in nature.

c 

# Modifications to approved equipment include all cha nges with the potential to affect NDA data relative to waste isolation and

exclude minor changes, such as the addition of safe ty-related equipment.

# 58



# 11.0 REFERENCES

New Mexico Environment Department, Waste Isolation Pilot Plant Hazardous Waste Facility

Permit (WAP), NM48901 139088-TSDF, Santa Fe, New Me xico, 1989.

U.S. Code of Federal Regulations , Title 40, Protection of Environment, Part 191,

“Environmental Radiation Protection Standards for M anagement and Disposal of Spent Nuclear

Fuel, High-Level and Transuranic Radioactive Wastes .”

U.S. Code of Federal Regulations , Title 40, Protection of Environment , Part 194, “Criteria for

the Certification and Re-Certification of the Waste Isolation Pilot Plant’s Compliance with the

40 CFR Part 191 Disposal Regulations.”

U.S. Department of Energy, “40 CFR Part 191, Compli ance Certification Application for the

Waste Isolation Pilot Plant,” DOE/CAO 1996-2184, Ca rlsbad, New Mexico, 1996.

U.S. Department of Energy, “40 CFR Part 191, Subpar ts C and D, Compliance Recertification

Application 2004,” DOE/WIPP/2004-3231, 2004.

U.S. Department of Energy, “Transuranic Waste Basel ine Inventory Report,” Revision 0,

DOE/TRU-2206-3344.

U.S. Department of Energy, Carlsbad Area Field Offi ce, “Contact-Handled Transuranic Waste

Acceptance Criteria for the Waste Isolation Pilot P lant (CH-WAC),” Revision 3, DOE/WIPP-02-

3122, Carlsbad, New Mexico, April 25, 2005.

U.S. Department of Energy, Carlsbad Area Field Offi ce, “Quality Assurance Program

Description (QAPD),” DOE/CBFO-94-1012, Revision 7, Carlsbad, New Mexico, July 2005.

U.S. Environmental Protection Agency, “Criteria for the Certification and Recertification of the

Waste Isolation Pilot Plant’s Compliance with the D isposal Regulations: Certification Decision;

Final Rule,” Federal Register , Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405.

U.S. Environmental Protection Agency, “EPA Replicat e Testing for WIPP Nondestructive Assay

(NDA) Systems,” Revision 2, June 2002.

U.S. Nuclear Regulatory Commission, “Contact-Handle d Transuranic Waste Authorized

Methods for Payload Control.A-1ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH AK Checklist Inspection Date: April 27-29, 2010Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective EvidenceGENERALAK-1:Is the waste TRU by definition as presented in theLWA?(P.L.102-579)CCP-TP-005, Revision 18;Section 4.4.31; CH-WACRevision 6.4; P.L. 102-579Review of objectiveevidence and interview ofSteve Schafer and SheriNanceDraft WSPF for Waste Stream MPFPDD. Dataexamined indicates waste is TRU waste bydefinition, NDA BDRs RLGEAA0001, 0002.AK-2:Do the presented volumes comport with LWAcapacity restrictions?(P.L.102-579)CCP-TP-005, Revision 18;CH-WAC Revision 6.4;P.L. 102-579Review of objectiveevidence and interview ofSteve Schafer and SheriNanceWSPF for Waste Stream MPFPDD; AKSRMPFPDD, CCP-TP-005 Attachment 6. No dataexamined identified any issues with respect towaste volume.AK-3:Are any wastes considered (or previouslyconsidered) high-level wastes (HLW)? HLW areprohibited.(P.L.102-579)CH-WAC Revision 6.4;P.L. 102-579Review of objectiveevidence and interview ofSteve Schafer and SheriNanceAKSR MPFPDD, Section 4.3.2. No data examinedindicated that the waste stream evaluated duringinspection were by definition SNF or HLW.AK-4:Are any wastes considered (or previouslyconsidered) Spent Nuclear Fuel? SNF is prohibited.(P.L.102-579)CH-WAC Revision 6.4;P.L. 102-579Review of objectiveevidence and interview ofSteve Schafer and SheriNanceAKSR MPFPDD, Section 4.3.2. No data examinedindicated that the waste stream evaluated duringinspection were by definition SNF or HLW.AK-5:Are these defense wastes? Waste must be defensein origin.(P.L.102-579)CCP-TP-005, Revision 18,Section 4.4.1; CH-WACRevision 6.4; P.L. 102-579Review of objectiveevidence and interview ofSteve Schafer and SheriNanceAKSR MPFPDD, Section 4.3.1. Data examinedduring the inspection indicated that the wastestream is or was commingled with waste that wasdefense in origin.AK-6:What is the scope of authorization sought (i.e.,SCG, other site-specific breakdowns?)CCP-TP-005, Revision 18;CH-WAC Revision 6.4;P.L. 102-579, CRA 2009EPA Scope Letter: CHDebrisAKSR MPFPDD, WSFP for Waste StreamMPFPDD. Scope of the approval was contacthandled debris (S5000), retrievably stored andnewly generated. Categories of waste not approvedunder this baseline inspection (e.g., S3000 andS4000 wastes).AK-7:Is AK being used that was assembled prior to anEPA approved QA program? If so, what qualificationprocess is used? Is this waste undergoing confirmation asper the CCA/CRA (100% sampling)?[194.24(c)(2)-(5), 194.22(a)]CCP-TP-005, Revision 18;CH-WAC Revision 6.4;P.L. 102-579Review of objectiveevidence and interview ofSteve Schafer and SheriNanceRLRTRB0002, RLGEAA0001, RLRTRA0001,RLGEAA0002. 100% NDE and 100% NDA toconfirm AK.A-2ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH AK Checklist Inspection Date: April 27-29, 2010Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective EvidenceAK-8:Is AK being assembled as waste is generated afterEPA approval of the QA program? Is this wasteundergoing confirmation as per the CCA/CRA (100%sampling)?[194.24(c)(2)-(5)]CCP-TP-005, Revision 18;CH-WAC Revision 6.4;P.L. 102-579Review of objectiveevidence and interview ofSteve Schafer and SheriNanceRLRTRB0002, RLGEAA0001, RLRTRA0001,RLGEAA0002AKSR AKSR MPFPDD, Section5.4.1.2. All waste generated during D&D activitieswill undergo 100% NDE and 100% NDA.AK-9:Procedures require staff to be qualified toassemble, compile, and confirm AK data, including,butnot limited to:a. Identification of required reading list and successfulcompletion of all required reading including, but notlimited to:•Applicable portions of the WIPP WAP and TSDFWAC•WIPP Compliance Certification Decision Conditions2 and 3•State and Federal RCRA regulations associated withsolid and hazardous waste characterization•Discrepancy resolution and reporting processes•Site-specific procedures associated with wastecharacterization using acceptable knowledgeb. Successful completion of testing to demonstrateunderstanding of required reading listc. Completion of internal and/or external trainingprograms pertinent to AKd.Participation in internal audits to assess AK programe.Other methodologies for demonstrating AKproficiency as developed on a site-specific basis(WAP B4, B4-3a)CCP-TP-005, Revision 18,Section 2.2; CCP-QP-002,Section 4.2Interview of Steve SchaferNatasha McCants, andSheri NanceAKE Qualification Cards for Sheri Nance, SteveSchafer, Natasha McCants. Also presented trainingroster for most recent Hanford AKSR MPFPDD.CCP representative stated that they do not haverequired reading for the most updated procedureversions – they are required to verify they areusing the most updated procedure as presented onthe FTP site. It is clear that the individuals wereaware of the content of the most recent AKprocedure, but EPA recommends thatdocumentation of updated reading be included inthe training records. Further, the documentationdid not include any indication that individuals havebeen trained to EPA requirements. All individualshad participated in various internal audits.AK-10:a. Are procedures adequate to encompass the spectrum ofwastes for which authorization is sought?CCP-TP-005, Revision 18;CCP-TP-066Review of objectiveevidence and interview ofSteve Schafer and SheriRLRTRB0002, RLGEAA0001, RLRTRA0001,RLGEAA0002, VE BDRS RLVEPF0001-0004,0008-0013A-3ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH AK Checklist Inspection Date: April 27-29, 2010Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidenceb. Are there different procedures for newly generated vs.retrievably stored waste? Are there differentprocedures for solid, debris, or soil waste? Shouldthere be?c. For newly generated waste, have adequate proceduresbeen developed and implemented to characterize wasteusing acceptable knowledge prior to packaging?(WAP B4, B4-3b)Nance CCP-TP-005, Rev. 18. Procedure is common toretrievably stored and newly generated waste.RTR, NDA used to collect confirmatory data foreach container. Data and procedures indicate thatNDA and RTR may be used to characterize waste,all of which activities are governed by procedureaddressed in other checklist sections. Newlygenerated waste may undergo VE in the future.Modification of CCP-TP-005, Revision 18 is aTier 2 change.ASSEMBLING AK INFORMATION AND COMPILING AK DOCUMENTATION INTO AN AUDITABLE RECORDAK-11:What is the breakdown of the types andquantities of TRU waste generated/stored at the site?(WAP B4, B4-2a)CCP-TP-005, Revision 18,Sections 4.4.8, 4.4.9, andAttachment 1 PR6Review of objectiveevidence and interview ofSteve Schafer and SheriNanceWSPF MPFPDD, AK Tracking Spreadsheet, PTS,AKSR MPFPDD (example: Table 5-2, mixedwaste stream), HNF-6489, HNF-36515, CCP-TP005, Attachment 6 (and associated memo). TheMPFPDD waste stream is essentially acombination of the Hanford MPFPD andRLMPFPCD waste streams. The MPFPD is asubset of the RLMPFPCD waste stream, with thelater containing wastes from Building 242-ZWaste Treatment Facility, 291-ZVentilation/Exhaust Air Stack Building, and PFPAncillary Facilities.AK-12:Do procedures call for AK information to becollected for:a.241Am,238Pu,239Pu,240Pu,242Pu,233U,234U,238U,90Sr,137Cs + unexpected radionuclidesb. Ferrous metals (in containers)c. Cellulosics, plastics, rubberd. Nonferrous metals (in containers)(CRA/CCA Ch 4 and Attachments/Appendices)CCP-TP-005, Revision 18,Sections 4.4.21, 4.4.22,4.4.24Review of objectiveevidence and interview ofSteve Schafer and SheriNanceP976, P1084, AKSR MPFPDD (e.g. Table 5-4)CCP-TP-005 Attachment 7 and related NDAMemo, reference C200, Attachment 6;RLRTRB0002, RLGEAA0001, RLRTRA0001,RLGEAA0002, VE BDRs RLVEPF0001-0004,0008-0013. AK data shows that239Pu and238U are the most prevalent isotopes by mass.Waste also contains uranium, americium,neptunium, cesium, and strontium. Waste streamMPFPDD is composed of a variety of debrismaterial represented by a host of activitiesincluding plutonium processing, waste treatment,incineration, and D&D activities. Modification ofthe NDA memo is a Tier 2 change.A-4ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH AK Checklist Inspection Date: April 27-29, 2010Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective EvidenceAK-13:Do procedures require documentation ofradionuclide process origin?Are the facility and TRU waste management operationscorrelated to specific waste stream information?(WAP B4; WAC Appendix A.2.2)CCP-TP-005, Revision 18,Section 4.4, Attachment 1WS4, PR7Review of objectiveevidence and interview ofSteve Schafer and SheriNanceAKSR Section 4.0, HNF-6489 HNF-36515, C100,C104, , M047, P052, Waste stream includesmaterial from the following buildings:• 232-Z, Waste Incinerator Facility (nowdemolished)• 234-5Z, Plutonium Process and Storage Building• 236-Z, Plutonium Reclamation Facility• 242-Z, Waste Treatment Facility• 2736-ZB, Product Shipping and ReceivingFacility• 291-Z, Ventilation/Exhaust Air Stack Building• PFP Ancillary FacilitiesCCP demonstrated that all but the PFP AncillaryFacilities are within the same waste stream basedon common physical, radiological, and materialcomposition except for the Ancillary facilities.CCP removed the ancillary facilities from thewaste stream in a freeze file modification.AK-14:Are correlations between waste streams, withregard to time of generation, waste generating processes,and site-specific facilities clearly described? For newlygenerated wastes, the rate and quantity of waste tobegenerated shall be defined.(WAP B4, B4-3c)CCP-TP-005, Revision 18,Section 4.4, Attachment 1PR7Review of objectiveevidence and interview ofSteve Schafer and SheriNanceAKSR MPFPDD Sections 4.2.2, 5.2, Examplereferences: C117, P130, P191, and P239 P194,P071 and P153Historic time outlines, processes, facilities: AKSR4.2.2 Future volume, location new generation:AKSR 5.2AK-15:a.Are waste streams appropriately identified and arewastes characterized on a waste stream basis?b.Are wastes grouped on a waste stream basis usingAcceptable Knowledge?(WAP B4, Section B-1a)CCP-TP-005, Revision 18,Sections 4.4, 4.2.3, 4.2.4Review of objectiveevidence and interview ofSteve Schafer and SheriNanceMPFPDD WSPF, AKSR MPFPDD, Solid WasteInformation and Tracking System (SWITS) WasteContainer Report and Container Listing Reports,Drum Packaging Data Sheets drums RL0056238,RL0063057The MPFPDD waste stream is composed of TRUmixed heterogeneous debris created by variousproduction, maintenance, cleanout, stabilization,decontamination, and decommissioning activitiesat the Plutonium Finishing Plant (PFP). Wastesfrom different buildings with common overall PFPsupport processes and with common physical andradiological form were apparently assembled withno distinguishing assignment to different sourceA-5ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH AK Checklist Inspection Date: April 27-29, 2010Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidenceareas in PFP. CCP representatives stated thatbecause it is not possible to discern where thedrums came from other than PFP, all the drumsmust be assigned to the same waste stream.AK-16:Do procedures demonstrate a logical progressionfrom general facility information to more detailedwastestream-specific information?CCP-TP-005, Revision 18,Section 4.4Review of objectiveevidence and interview ofSteve Schafer and SheriNanceMCPFPDD WSPF, AKSR MCPFPD; SourceDocuments (C,DR,P, M, U), and related drum dataincluding PTS Print Outs, and data from IDMS,SWITS, TRU DMTAK-17:Does the process include review of AKinformation to evaluate and document AK-AKinformation discrepancies?(WAC Section A.2.2.3, WAP B4, Section B4-3)CCP-TP-005, Revision 18,Sections 4.7, 4.8, 4.9Review of objectiveevidence and interview ofSteve Schafer and SheriNanceDiscrepancy Resolutions, including DR010,DR013AK-18:Do procedures require collection of informationregarding how waste is tracked and managed at thegenerator site (including historical and currentoperations)?(WAC Section A.2; WAP B4 Section B4-2a)CCP-TP-005, Revision 18,Section 4.4, Attachment 1PR4Review of objectiveevidence and interview ofSteve Schafer and SheriNance .SWITS database information, TRUEDMTdatabase, Onsite Radioactive Shipment Records,and Solid Waste Burial Records, CCP PTS/CTS,AK Tracking Spreadsheet, CCP-TP-005Attachment 8, WWIS (emplaced historiccontainers). Data examined demonstrated thathistoric waste tracking and management can beascertained as well as current drum status andlocation.AK-19:Is AK information compiled in an auditablerecord, including a road map for all applicableinformation?CCP-TP-005, Revision 18,Attachments 1, 4Review of objectiveevidence and interview ofSteve Schafer and SheriNanceCCP-TP-005, Attachments 1 and 4AK-20:Has a reference list been provided that identifiesdocuments, databases, Quality Assurance protocols,andother sources of information that support AKinformation?(WAP B4, Section B4-3c)CCP-TP-005, Revision 18,Attachment 4Review of objectiveevidence and interview ofSteve Schafer and SheriNanceCCP-TP-005 Attachment 4; AKSR MPFPDDReference listAK-21:Have the following mandatory informationrequirements been identified?•Map of the site that identifies the areas and facilitiesCCP-TP-005, Revision 18,Section 4.4.31, Attachment1Review of objectiveevidence and interview ofSteve Schafer and SheriAKSR MPFPDD, Sections 4.2-5.3, related figures,AK-NDA Memo for MPFPDD, CCP Freeze File,Figures 1-3A-6ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH AK Checklist Inspection Date: April 27-29, 2010Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidenceinvolved in TRU waste generation, treatment, andstorage•Facility mission description related to TRU wastegeneration and management•Description of the operations that generate TRU wasteat the site and process information, including:- Area(s) or building(s) from which the waste streamwas or is generated- Estimated waste stream volume and time period ofgeneration- Waste generating process description for eachbuilding or area- Process flow diagrams, if appropriate- Generalized material inputs or other information thatidentifies the radionuclide content of the wastestream and the physical waste form- Types and quantities of TRU waste generated,including historical generation through futureprojections•Physical/chemical waste composition that could affectisotopic distribution (i.e., processes to remove ingrown241Am)•Statement of all numerical adjustments applied toderive the material’s isotopic distribution, e.g.,scalingfactors, decay/ingrowth corrections and secularequilibrium considerations•Specification of isotopic ratios for the 10 WIPP-trackedradionuclides and, if applicable, the radionuclidesthatcomprise 95% of the hazard(WAC Section A.2.2; WAP B4, B4-2a, B4-2b)Nance AK data indicate that the initial weapons grade Puproduced at Hanford exhibited a240Pu weightpercentage between approximately 0.9-7%. Fuelmaterial processed at Hanford exhibited a240Puweight percent of 8-27% for experimental reactortechnology as well as other technologies. CCPHanford concluded that this spectrum of valuesindicated a range of isotopic distributions wouldlikely be appropriate for this waste stream.The NDA memo indicated that233Pa may causeinterference with239Puassay; other radionuclidesthat may interfere with transmission include thoseassociated with152Eu. Also, alpha particles caninteract with low-Z nuclei releasing neutrons thatcan interfere with neutron counting. Beryllium,boron, fluorine, carbon sodium, magnesium andaluminum may contribute.AK-22:Does the site have procedures for the collectionof supporting information? Examples of supplementalCCP-TP-005, Revision 18,Section 4.2.5, Attachment 1Review of objectiveevidence and interview ofSteve Schafer and SheriNumerous examples, including but not limited toC043, C053, C074, DR010, DR013, M026, M040,A-7ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH AK Checklist Inspection Date: April 27-29, 2010Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidenceinformation, from WAC, include:•Safeguards and security and other material controlsystems/programs•Reports of nuclear safety or criticality•Accidents involving SNM waste packaging and wastedisposal•Building or nuclear material management area logs orinventory records•Site databases that provide SNM or nuclear materialinformation test plans•Research project reports, or laboratory notebooks thatdescribe the radionuclide content of materials usedinexperiments•Information from site personnel•Historical analytical data relevant to isotopicdistribution in the waste stream(WAC Section A.2.2.2; WAP B4 Section B4-2c)NanceM044, M305, P203,P228,P179, P202, P203, P976,U202AK-23:Is all necessary supporting informationassembled and has it been appropriately used?(WAP B4 Section B4-2c)CCP-TP-005, Revision 18,Section 4.2.5Review of objectiveevidence and interview ofSteve Schafer and SheriNanceNumerous examples, including but not limited toC043, C053, C074, DR010, DR013, M026, M040,M044, M305, P203,P228,P179, P202, P203, P976,U202Also, CCP prepared additional freeze filechanges addressing EPA concerns as well asDR013.AK-24:a. Are waste categorization schemes presented and arethey appropriate?b. Are waste identification/categorization schemesrelevant to the isotopic composition of waste?(Attachment B4 Section B4-1, WAC Appendix A.2)CCP-TP-005, Revision 18,Section 4.4Review of objectiveevidence and interview ofSteve Schafer and SheriNanceAKSR MPFPDD, NDA Memo, CCP-TPAttachment 7; DR010, Waste defined by processesassociated with PFP and includes isotopicdistribution applied to the waste stream as a whole.A-8ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH AK Checklist Inspection Date: April 27-29, 2010Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective EvidenceAK-25:Have data uses and limitations been assembledand are they technically adequate?(CRA/CCA; WAC Appendix A, Section A.2.2.3)CCP-TP-005, Revision 18,Section 4.3, Attachment 3Review of objectiveevidence and interview ofSteve Schafer and SheriNanceCC-TP-005 Rev 18 Attachment 3; all AK sourcedocument summaries. Note that CCP separated theAttachment 3s from the original source documents,which as not been practiced at any CCP locationuntil Hanford. This proved cumbersome as theSource Document Summaries and related SourceDocuments had the same file names, thus leadingto loss of data and the need to rename documents.In the future, CCP has determined this approach isnot appropriate and will attach Source DocumentSummaries to the actual Source Documents.AK-26:Site documents/procedures require the facility toprepare an AK summary document that summarizes allinformation collected, including the basis for allwastestream designations. Is the AK Summary of sufficientscope and detail?(WAC Appendix A Section A.2.2; WAP Attachment B4Sections B4-2b, B-3d)CCP-TP-005, Revision 18,Section 4.4Review of objectiveevidence and interview ofSteve Schafer and SheriNanceAKSR MPFPDD. EPA identified several issuesassociated with the AKSR that requiredmodification and which were addressed throughfreeze file changes including:-Examine feed and other data for 232-Z Incineratorto verify its inclusion in the waste stream.-Examine the use of “offsite sources” throughoutthe document.-In Section 4.6.1, modify the discussion pertainingto waste stream definition to include the lack ofability to correlate drums to specific PFPprocesses. Also modify Section 5.3 to indicatewhether to-be-generated waste will be segregatedupon generation or packaging.-Clarify intent of last paragraph p.30 regardingplutonium grades and defense waste.-Add information to Section 5.4.2 pertaining to the6%, 12%, and 23% plutonium isotopicdistributions as presented in AK SourceDocuments and the AK-NDA memo, includingdata that supports generation of these distributionsat the PFP as well as other pertinent historical data.-Remove first sentence from the first paragraph inA-9ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH AK Checklist Inspection Date: April 27-29, 2010Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective EvidenceSection 4.5 regarding intent to segregate wasteduring packaging or repackaging, as it contradictslater statements.-Verify number of HEHF (EmergencyDecontamination Facility) drums and how it isincluded in the PFP drum population.-Add the total volume (cubic meters) of waste ininventory.-In the final paragraph of Section 5.4.2, add thesecond predominant radionuclide by activity, to beconsistent with the previous portion of the sentencethat identifies the two predominant radionuclidesby mass.CCP submitted a freeze file modification thatadequately addressed these concerns.Modifications to the AKSR are a Tier 2 change.AK-27:Are conclusions and interpretations presented inthe AK Summary technically sound and supported byreferenced mandatory and supplemental information?CCP-TP-005, Revision 18 Review of objectiveevidence and interview ofSteve Schafer and SheriNanceSee Item AK-26; Example references includeSource documents C, DR, M, P, and U.AK-28:If AK data discrepancy is identified, site willevaluate the source of the discrepancy to determineifdiscrepant information is credible. Information that is notcredible will be identified as such and reasons fordismissing will be justified in writing. Limitationsconcerning information will be documented in the AKrecord and summarized in the AK report. If a discrepancycannot be resolved, the site will perform directmeasurements for the impacted population.(WAC Appendix A.2, Section A.2.2.3)CCP-TP-005, Revision 18,section 4.9Review of objectiveevidence and interview ofSteve Schafer and SheriNanceDR005, DR006 DR013, DR010AK-29:Has the use of load management been proposed?Does the AK Summary include the following from theWAC, Revision 3, Appendix E?CCP-TP-005, Revision 18,Section 4.4.31Review of objectiveevidence and interview ofSteve Schafer and SheriAKSR MPFPDD, AK Accuracy Report, Lot 1.Modification of AK Accuracy reports is a Tier 2change. CCP Hanford AKEs indicated that loadmanagement would not be performed on wasteA-10ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH AK Checklist Inspection Date: April 27-29, 2010Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidence•Each TRU waste stream selected for payloadmanagement must include in its acceptable knowledgesummary report an estimate of the total waste volumeand the percentage of the waste volume that is aboveand below 100 nCi/g. (It should be noted that thisinformation, although based on the best available AKinformation, is preliminary and subject to theperformance of WIPP-certified NDA measurementsand cannot and will not be used as a measure of AKaccuracy.) (Reference E3)(WAC, Appendix E)Nance under the CCP Hanford program. Performance ofload management is a Tier 1 change.AK-30:Are nonconforming wastes segregated? AreNCRs dispositioned in an appropriate and technicallydefensible manner?(WAP B4, Section B4-3b, Attachment B3, Section B3-13)CCP-TP-005, Revision 18,Section 4.9Review of objectiveevidence and interview ofSteve Schafer and SheriNanceNCR-RL-001-10,; NCR RL-0600-10-0617-20;NCR 1201-1203. Example NCRs primarily due topresence of various prohibited items (i.e. liquidsinprohibited quantities), LLW, Identified adequatelythrough NCR preparation.AK-31:Do site procedures require that additionalinformation be collected before waste may be shipped ifthe required AK information is not available for awastestream or if available AK is poor or unacceptable?(WAP B4 )CCP-TP-005, Revision 18,Sections 4.4.2, 4.4.3Review of objectiveevidence and interview ofSteve Schafer and SheriNanceCCP indicated that there have been no exampleswhere additional information had to be collectedbecause of poor AK. EPA notes that CCP oftenaccess historic site data including RTR, VE, andNDA data acquired from the previous Hanfordprogram.AK-32:Do these procedures facilitate the mandatorytraceability analysis performed for each Summary WasteCategory Group examined during the audit, noting thatEPA will determine whether the available waste streamsadequately demonstrate the full characterization processfor the proposed scope?(WAP B4, Section B4-2)CCP-TP-005, Revision 18,Section 4.4Review of objectiveevidence and interview ofSteve Schafer and SheriNanceAKSD MCPFPDD; HNF-6489 HNF-36515,Source Documents IINSERT EXAMPLES); BDRs(RTR, VE, NDA) for Drums 0056238, 0063057,0055034; Historic Documentation from siterecords, PTS/CTS, WWIS print-outs for the abovecontainers. All of the above were examined frominitial AK documentation through CCP Hanfordcharacterization and drum management. Drumrecords examined for each included the following:-Historic Documentation from the Hanford SiteRecords Storage Facility and Integrated DocumentManagement system (IDMS), including TRU/TRUMixed Waste Contents Inventory Sheet, WasteA-11ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH AK Checklist Inspection Date: April 27-29, 2010Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective EvidenceDesignation worksheet, Inspection Sheet forLoaded/Sealed TRUITRU Mixed Waste Drum,Inspection Sheet for Empty 55-Gallon WasteDrum, and Certificate of Conformance-Solid Waste Information Tracking System(SWITS) database records including the SWITSContainer Listing Report-TRU Electronic Data Management Tool(TRUEDMT) database Print Outs-BDRs (NDA and RTR)-CCP Program Tracking Sheet (PTS) printout-eachcontainerThese data indicate that historic informationpertaining to waste drum content is available.AK-33:If AK was used (i.e., data collected prior to QAprogram), what method was employed to qualify theinformation? Approved methods or peer review,corroborating data, confirmatory testing, and QA programequivalency? If confirmatory testing is used, hasthefollowing been considered (from WAC)?*•At a minimum, to confirm existing AK data, it isnecessary to compare ratios of the two most prevalentradionuclides in the isotopic mix*If the WAC requirements are not followed, identifyhowthe specific radionuclides are characterized via AK, andhow these data are used by NDA.(40 CFR 149.22(b), WAC, Appendix A, Section A.2.1)CCP-TP-005, Revision 18 Review of objectiveevidence and interview ofSteve Schafer and SheriNanceAKSR MPFPDD, CCP-TP-005 Attachment 7 andNDA Memo; P976; data were confirmed by 100%confirmatory testing using NDA. The NDA memodescribes how AK is used by NDA. It must benoted that the WAC Appendix A is typically notfollowed because the nature of the waste at sites isnot amenable to the approach.CCP Hanford evaluated radiological characteristicsof the waste stream based on WWIS data, whichrepresents the MCPFPD component of the wastestream. Data from 5856 drums were evaluated(4528 drums emplaced, 1328 certified drums in theWWIS that were not shipped).239Pu and238U mostprevalent isotopes by mass. An isotopicdistribution was established for Pu and U isotopesthat will be used by NDA personnel when assayresults are not acceptable. Distribution indicatesthat initial weapons grade Pu produced at Hanfordexhibited a240Pu weight percentage betweenapproximately 0.9-7%. Fuel material processed atHanford exhibited a240Pu weight percent of 8-27%for experimental reactor technology as well asother technologies.241Am is present due to decayof241Pu or from the Waste Treatment complexA-12ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH AK Checklist Inspection Date: April 27-29, 2010Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidence(242-Z). CCP uses default isotopics based on thepercent 240 Pu (6%, 12%, 23%) and assigns thedefaults based on240Pu identified on the drumrecords. These distributions appear reasonablebased on available data. Comparison of defaultisotopics with measured data in the WWISindicated good agreement assuming the material inthe WWIS was represented by weapons grade Pu.AK-34:Are radioassay and NDE results compared to theAK to verify implementation of the characterizationprogram?(194.24 (c)(3); 194.22(b))CCP-TP-005, Revision 18,Section 4.5.3, Attachment13Review of objectiveevidence and interview ofSteve Schafer and SheriNanceAK Accuracy Report, CCP-TP-Attachment 13. Anexample characterization checklist demonstratedthat data examined based on the WSPF and BDRsindicates that results thus far have compared wellto AK.AK-35:This procedure requires a reevaluation of AK ifNDE identifies it to be a different waste matrix code. Thisprocedure describes how the waste must be reassigned,based on the AK reevaluation.(WAP B4, Section B4-3e)CCP-TP-005, Revision 18,Section 4.9, Attachment 10Review of objectiveevidence and interview ofSteve Schafer and SheriNanceCCP-TP-005 Revision 18, Attachment 10, C037.No Attachment 10s were yet prepared for theaudited waste streams although CCP haddemonstrated the ability to create theseAttachments as warranted by the data. An exampleof a LANL Attachment 10 was provided.AK-36:Does the generator site have written proceduresfor newly generated waste to document the confirmationof acceptable knowledge information with visualexamination prior to or during waste packaging? Dothese procedures address the required elements in B4-3e?(WAP B4, Section B4-3e)CCP-TP-005, Revision 18,CCP-TP-001, CCP-TP113.Review of objectiveevidence and interview ofSteve Schafer and SheriNanceVE BDRs RLVEPF0001-0004, 0008-0013. Dataindicate that confirmation occurs; nocharacterization/confirmation checklist wasprovided for review.AK-37:Procedures require the following steps to befollowed if wastes are reassigned to a different wastematrix code based on NDE:•Review existing information based on the containeridentification number and document all differences•Reassess and document all analytical data associatedwith the waste•Reevaluate waste material parameter determinationsCCP-TP-005, Revision 18,Section 4.8, Attachment 10Review of objectiveevidence and interview ofSteve Schafer and SheriNanceCCP did not provide an example of an AT ReEvaluation Checklist Attachment 10 pertinent tothis waste stream because no checklist had beenrequired up to the date of the inspection. However,an example for LANL was provided.A-13ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH AK Checklist Inspection Date: April 27-29, 2010Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidenceand document any changes•Reevaluate the radionuclide content and document anychanges•Verify and document that the reassigned waste matrixcode was generated within the specified time period,area and buildings, waste generating process, and thatthe process material inputs are consistent with thewastematerial parameters identified during radiography orvisual examination•Record all changes to acceptable knowledge records•If discrepancies exist in the acceptable knowledgeinformation for the reassigned waste matrix code,complete a nonconformance report, document thesegregation of this container, and define the correctiveactions necessary to fully characterize the waste(WAP B4, Section B4-3e)AK-38:Has the site project manager calculated thepercent changes in waste matrix code based on AK andNDE/VE? Were accuracy evaluations assigned? Arethese acceptable?(WAP B3, Section B3-9; WAC Appendix A, SectionA.6.5)CCP-TP-005, Revision 18,Section 4.6, Attachment 14Review of objectiveevidence and interview ofSteve Schafer and SheriNanceAK Accuracy Report, March 2010.No containers were identified by CCP AcceptableKnowledge as having radionuclides outside theexpected ranges for MPFPDD. The AK Accuracyreport indicated that while the two most prevalentradionuclides are current,239Pu and240Pu, AKindicates that239Pu and238U should be the twomost prevalent based on weight. CCP said thereisn’t enough data to conclude that there is a majorshift in expected AK, so they didn’t identify thisasan AK Accuracy issue yet. There was noreassignment of WMS, nor was there reassignmentbased on HWN assignment. CCP concluded thatbased on these criteria, the accuracy for the wastestream is 100%.AK-39:Are the following items addressed with respectto AK-NDA communication and the use of AK data byNDA personnel?CCP-TP-005, Revision 18,Section 4.4.22Review of objectiveevidence and interview ofSteve Schafer and SheriP976, P1084, NDA Memo. CCP NDA and AKPersonnel prepared and reviewed the AK NDAmemo which addresses AK based waste streamA-14ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH AK Checklist Inspection Date: April 27-29, 2010Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidence•Do procedures require the identification of AK datalimitations?•Are AK data and associated limitations communicatedto NDA personnel and is this required by procedure?•How is AK used by NDA personnel?•Do AK and NDA personnel communicate and agreeabout the use of AK?•Is this agreement proceduralized?(WAC, Appendix A)Nancedescriptions and radionuclide distributions,prevalent radionuclides based on AK, and AK datalimitations. It also addresses, specifically, how thedata will be used during NDA, stating that AKbased default isotopics will be used if NDA doesnot yield adequate results. Assay interferences arealso addressed.AK-40:Have internal AK audits been performed?(WAP B4, Section B4-3d, g)CCP-TP-005, Revision 18,Section 4.5.1Review of objectiveevidence and interview ofSteve Schafer and SheriNanceWTS Quality Assurance Audit I09-06, August2009. The Audit only addressed AK records, anddid not address the actual AK process. CCPindicated that an audit addressing the AK morecomprehensively was in progress, but results werenot available for EPA’s inspection.AK-41:If data consistently indicate discrepancies withacceptable knowledge information, the site increasessampling, reassesses the materials and processes thatgenerate the waste, and resubmits waste stream profileinformation.(WAP B4, Sections B4-3b, B4-33)CCP-TP-005, Revision 18,Attachment 10Review of objectiveevidence and interview ofSteve Schafer and SheriNanceMPFPDD WSPF, CCP-TP-005 Attachment 10(not available for this inspection). CCP indicatedthat thus far, consistent discrepancies with respectto AK information have not been observed.AK-42:Are acceptable knowledge processesconsistently applied among all generator sites, anddoeseach generator site comply with the following dataqualityrequirements for acceptable knowledge documentation:a. Precision - Precision is not applicable to AK (seeAttachment B4)b. Accuracy - Accuracy is the degree of agreementbetween an observed sample result and the true value.The percentage of waste containers which requirereassignment to a new waste matrix code is based onthe reevaluation of acceptable knowledge and samplingand analysis data will be reported as a measure ofCCP-TP-005, Revision 18 Review of objectiveevidence and interview ofSteve Schafer and SheriNanceAK Accuracy Report, March 2010, Semi-annualTrend Report, March 2010, Training Records,Steve Schafer, Sheri Nance. Data limitationsaddressed in Attachment 3s and DRs. TrendReport provides a summary of relevant CCP workincluding results of assessments, significant issues,trend analysis results, performance assessments ofQuality Control (QC) data, and performanceassessments against QA Objectives. The AKRecords contain the required information.A-15ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH AK Checklist Inspection Date: April 27-29, 2010Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidenceacceptable knowledge accuracy. Accuracy based onradionuclide content is typically assessed by comparingmeasured results with AK data.c. Completeness - Completeness is an assessment ofthenumber of waste streams or number of samplescollected to the number of samples determined to beuseable through the data validation process. Theacceptable knowledge record must contain 100 percentof the information specified in Section B4-2. Theusability of the acceptable knowledge information willbe assessed for completeness during audits.d. Comparability - Data are considered comparable whenone set of data can be compared to another set of data.Comparability is ensured through sites meeting thetraining requirements and complying with the minimumstandards outlined for procedures that are used toimplement the acceptable knowledge process. WACSection A.6.5: Additionally, comparison of measureddata with AK-derived or -based values, as applicable,provides a means to assess comparability on a wastestream basis.e. Representativeness - Representativeness expresses thedegree to which sample data accurately and preciselyrepresent characteristics of a population.Representativeness is a qualitative parameter thatwillbe satisfied by ensuring that the process of obtaining,evaluating, and documenting acceptable knowledgeinformation is performed in accordance with theminimum standards established in Section B3. Sitesalso must assess and document the limitations of theacceptable knowledge information used to assign wasteparameters.(WAP B3, Section B3-9)AK-43:Does the generator site address quality controlby tracking its performance with regard to the useofacceptable knowledge by: (1) assessing the frequency ofinconsistencies among information, and (2) documentingCCP-TP-005, Revision 18,CCP-QP-019Review of objectiveevidence and interview ofSteve Schafer and SheriSemi-annual Trend Report, March 2010. CCP-QP019 identifies items to be addressed in the report:It identified the number of certification audits thatwere performed during that time period, the NCRsA-16ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH AK Checklist Inspection Date: April 27-29, 2010Required Technical ElementsProcedure Location/AdequacyVerification of ActivityExamples of Objective Evidencethe results of acceptable knowledge confirmation throughradiography or visual examination? In addition, theacceptable knowledge process and waste streamdocumentation must be evaluated through internalassessments by quality assurance organizations andassessments by auditors or observers external to theorganization (i.e., CBFO, NMED, EPA).(WAP B3, Section B3-9)Nanceidentified, significant QA or QC problems (CARs),PDP results, results of audits and surveillances,etc. It was noted that CCP used NDA equipment atINL that were not yet certified by EPA, and theassayed drums were entered in the WWIS. Thedrums were removed from the WWIS, and theTrend Report states that this caused no adversetrends. The report also indicated that 264 TrendCode Ls dealing with AK were issued in 2008 and2009. This means that AK was the primary sourceof error as reported in this document with respectto all other Trend Codes. However, no AK CARSwere issued.AK-44: Did the generator site implement, ordoes it currently implement, process controls toensure that prohibited items are documented andmanaged in accordance with site-specificcertification plans? What process controls are inplace to assess prohibited items and other wastecharacteristics (i.e. is fast scan used, and, if so,by whom)?(WAP B4, Section B4-3b)CCP-TP-005, Revision 18,Section 4.4, Attachment 1PR8, Attachment 6Review of objectiveevidence and interview ofSteve Schafer and SheriNanceFast Scan (RTR); also CCP Hanford personnelindicated a non-certified type of quick VE mayalso be performed, as may an NDA scan todetected containers that are not TRU. Further,historic NDE and NDA data may be accessed.AK-45:Does the generator site document, justify, andconsistently delineate waste streams based on site-specificpermit requirements or state-enforced agreements?Howdo these agreements impact waste characterization?(WAP B4, Section B4-3e)CCP-TP-005, Revision 18,Attachment 1 O16Review of objectiveevidence and interview ofSteve Schafer and SheriNanceAKSR MPFPDD; P143, P144, P145. Site clean upbeing performed in accordance with the Tri-Partyagreement. D&D/clean up dictated by programsoutside of CCP.Revision No.: Site specific checklistA-17Attachment A.2 Non-Destructive Assay (NDA) ChecklistEPA Inspection No.: EPA-HANFORD-CCP-10.05-8NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B)Inspection Date: April 27 – 29, 2010Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceSystem DescriptionIdentify the NDA systems by name, locationand number, as appropriate.Y General system information The GEA units identified asfollows: GEA-A 104-ND-06-102A;GEA-B 104-ND-06-102B.- Observation of the two GEA unitsat WRAP Facility during theinspection.Describe the system’s operational historyincluding deployment at other DOE sites.Y General system information Both units were previously used forWIPP-related TRU assays atHanford and had been approved forthis use by EPA several times, mostrecently during EPA baselineinspection of Hanford (Non-CCP) in2008.- EPA Air Docket Nos. A-98-49,II-A4-41 and A-98-49, II-A4-58For systems that have been deployed atmultiple DOE sites document pertinentaspects of each system’s development, e.g.,installation of new or different detectors,software or other relevant features.Y General system information Both GEA systems are essentiallyunchanged with respect tohardware. Minor software changeshave been made.- Observation of the two GEA unitsat WRAP Facility during theinspection.System PerformanceIdentify the period of performance relevant tothis inspection and if this NDA system hasprior EPA approval(s).Y General system information The GEA units became operationfor WIPP assays on March 2, 2010.-GEA-A System Notebook RLNDA-GEA-A-003, assigned bySusan Keathley, January 5, 2010,Building 2336W, Area 200 W;GEA-B System Notebook RLNDA-GEA-B-004, assigned bySusan Keathley, January 5, 2010,Building 2336W, Area 200 WIdentify the number of waste containers thissystem assayed during the period ofperformance. Of these, indicate how manyBatch Data Reports (BDRs) were assembled.And how many BDRs have been promotedthrough Project Level Review and areavailable for EPA’s evaluation.Y General system information A total of 237 containers assayedfor both GEA units as of 4-21-10;30 BDRs; 13 BDRs promotedthrough data generation levelreview; 12 BDRs through SiteProject Manager review; 6 BDRs (3from GEA-A and 3 from GEA-B)were provided for EPA review-GEAA BDRs RLGEAA0001,RLGEAA0002 & RLGEAA0003;GEAB BDRs RLGEAB0001,RLGEAB0002 & RLGEAB0003Revision No.: Site specific checklistA-18Attachment A.2 Non-Destructive Assay (NDA) ChecklistEPA Inspection No.: EPA-HANFORD-CCP-10.05-8NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B)Inspection Date: April 27 – 29, 2010Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceGeneral Reporting RequirementsAssay systems must report quantitativevalues and uncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr, and137Cs.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Both GEA units report quantitativevalues and uncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr, and137Cs.Y CCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportEach container characterized and intended fordisposal at WIPP must contain TRU waste.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Containers assayed on both GEAunits meet criteria for TRU waste orthey are removed via NCRs.YGEAA BDRs RLGEAA0001,RLGEAA0002 & RLGEAA0003;GEAB BDRs RLGEAB0001,RLGEAB0002 & RLGEAB0003NDA instruments and procedures must beappropriate for the waste streams beingassayed.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Both GEA units are appropriate forthe waste streams they are currentlyassaying.Y CCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportNDA instruments and procedures result inunbiased values for the cumulative activity ofthe WIPP radionuclide inventory.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24GEA radionuclide values areacceptable for calculating thecumulative activity of the WIPPradionuclide inventory.Y CCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification Report; GEAA BDRsRLGEAA0001, RLGEAA0002 &RLGEAA0003; GEAB BDRsRLGEAB0001, RLGEAB0002 &RLGEAB0003Revision No.: Site specific checklistA-19Attachment A.2 Non-Destructive Assay (NDA) ChecklistEPA Inspection No.: EPA-HANFORD-CCP-10.05-8NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B)Inspection Date: April 27 – 29, 2010Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceSome radionuclides are derived by theapplication of scaling factors or correlationtechniques. Identify all radionuclides that arequantified in this manner.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Scaling factors are used to quantify234U and90Sr based on correlationswith235U/238U and137Cs,respectively. MGA and MGA-U areused and both software programskey on specific photons lines anduse them to infer otherradionuclides.Y CCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportAssess the technical adequacy of thecalculations involving the application ofscaling factors and/or correlation techniques.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Scaling factors used to quantify234Uand90Sr based on correlations with235U/238U and137Cs are technicallyadequate.Y CCP-TP-072, Revision 0Identify the procedures that govern thisfunction and where the results of thesecalculations are documented.Y The procedure that governs theapplication of scaling factors isCCP-TP-072, Revision 0 and theresults are documented in the NDABDRs.CCP-TP-072, Revision 0; GEAABDRs RLGEAA0001,RLGEAA0002 & RLGEAA0003;GEAB BDRs RLGEAB0001,RLGEAB0002 & RLGEAB0003Acceptable Knowledge (AK)If isotopic ratios based on AK are used thevalues must be qualified by confirmatorytesting.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Isotopic ratios are used inquantifying radionuclides for wastestreams that have approved AKbased data.Y CCP-TP-072, Revision 0Do NDA personnel use AK derived isotopicvalues to calculate radionuclide values? Ifso, is this function performed according to aformal procedure? Assess the technicaladequacy of this process(s).Y CCP-PO-002, CCP WasteCertification Plan, Revision 24NDA personnel using AK-derivedisotopic values to calculateradionuclide values use a formalCCP technical procedure.Y CCP-TP-072, Revision 0; GEAABDRs RLGEAA0001,RLGEAA0002 & RLGEAA0003;GEAB BDRs RLGEAB0001,RLGEAB0002 & RLGEAB0003Identify the procedure and where the resultsof these calculations are documented.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The procedure for AK relatedcalculations is CCP-TP-072,Revision 0 and results of thesecalculations are recorded in theNDA BDRs.Y CCP-TP-072, Revision 0; GEAABDRs RLGEAA0001,RLGEAA0002 & RLGEAA0003;GEAB BDRs RLGEAB0001,RLGEAB0002 & RLGEAB0003Revision No.: Site specific checklistA-20Attachment A.2 Non-Destructive Assay (NDA) ChecklistEPA Inspection No.: EPA-HANFORD-CCP-10.05-8NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B)Inspection Date: April 27 – 29, 2010Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceIsotopic DeterminationIdentify the radionuclides that are measureddirectly and the specific radiation type that ismeasured.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The radionuclides that are measureddirectly are all gamma (photon)emitters.YGEA Units A and B RadionuclideListing Library, Filename:C:\GENIE2K\CAMFILES\CCPWRAP.nlb, generated April 37,2010Identify the method(s) used to derive theisotopic contribution for the unmeasuredradionuclides, e.g., MGA, FRAM or othertechnique.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The isotopic contributions for theunmeasured radionuclides arederived using MGA, MGAU andFRAM, as needed.YCCP-TP-072, Revision 0;Use ofIsotope Correlation Techniques toDetermine242Pu Abundance, R.Gunnink, 1980Lower Level of Detection (LLD)The LLD for each NDA system must bedetermined. For multi modal systems thismay require a separate determination for eachmode, i.e., active neutron, passive neutronand gamma.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The LLDs for both GEA units havebeen determined and documented.Y CCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportSite-specific environmental backgrounds andcontainer-specific interferences must beaccounted for in LLD determinations.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Site-specific backgrounds are takenin account for both GEA units.YCCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportNDA instruments performing TRU/NonTRU waste discrimination measurements arerequired to have a LLD no greater than 100nCi/g.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Both GEA unit are used todiscriminate TRU and Non-TRUwastes and each system has therequired sensitivity, i.e., an LLD <100 nCi/g.Y CCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BRevision No.: Site specific checklistA-21Attachment A.2 Non-Destructive Assay (NDA) ChecklistEPA Inspection No.: EPA-HANFORD-CCP-10.05-8NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B)Inspection Date: April 27 – 29, 2010Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceCalibration, Confirmation andVerification ReportThe technical basis and derivation for LLDsmust be technically adequate andappropriately documented.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The technical basis and derivationfor LLDs for both GEA units aretechnically adequate andappropriately documented.Y CCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportFor radionuclides that are not determinedprimarily by measurement an LLD analog,i.e., a reporting threshold must be used whenit is technically feasible. Identify all instanceswhen this occurs and the form of thedocumentation of these activities.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The radionuclides that are notdetermined primarily bymeasurement an LLD analog, i.e., areporting threshold is used when itis technically feasible. All instanceswhen this occurs are documentedappropriately.Y CCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportIdentify any/all instances where an LLDvalue for anon-measuredradionuclide is notprovided basis on a lack of technicalfeasibility.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Any/all instances where an LLDvalue for anon-measuredradionuclide is not provided basison a lack of technical feasibility aredocumented.Y CCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportAre LLD values container/assay eventspecific or are typical LLD values applied toa class or type of wastes, i.e., those withsimilar attributes? If LLD values are notcontainer/assay event specific identify theattributes or characteristics whereby wasteY CCP-PO-002, CCP WasteCertification Plan, Revision 24LLD values have been determinedfor classes of wastes by density todemonstrate adequate sensitivityover the operational range, however,each assay event produces a uniqueLLD.Y CCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BRevision No.: Site specific checklistA-22Attachment A.2 Non-Destructive Assay (NDA) ChecklistEPA Inspection No.: EPA-HANFORD-CCP-10.05-8NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B)Inspection Date: April 27 – 29, 2010Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidencecontainers are grouped.Calibration, Confirmation andVerification ReportTotal Measurement Uncertainty (TMU)The method used to calculate the TMU for allrequired quantities must be documented andtechnically justified.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The method used to calculate theTMU for all required quantities isdocumented and technicallyjustified.Y CCP-RL-GEA-003, TotalMeasurement Uncertainty (TMU)for the Gamma Energy AssaySystemsTMU determination accounts for all sourcesof uncertainty, specifically•Random errors•Calibration•Isotopic determination•Matrix inhomogeneity•Difference between calibrationassumptions and actual waste•Non uniform source distribution•End effects•Self absorption•Transmission source•Self shielding•Neutron multiplicationYCCP-PO-002, CCP WasteCertification Plan, Revision 24The TMU determination accountsfor all sources of uncertainty,specifically:•Random errors•Calibration•Isotopic determination•Matrix inhomogeneity•Difference between calibrationassumptions and actual waste•Non uniform source distribution•End effects•Self absorption•Transmission source•Self shielding•Neutron multiplicationYCCP-RL-GEA-003, TotalMeasurement Uncertainty (TMU)for the Gamma Energy AssaySystemsMethods to determine TMU must bedocumented, reviewed and approved byCBFO for each NDA instrument.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The TMU report for both GEA unitswas approved by CBFO.CCP-RL-GEA-003, TotalMeasurement Uncertainty (TMU)for the Gamma Energy AssaySystemsRevision No.: Site specific checklistA-23Attachment A.2 Non-Destructive Assay (NDA) ChecklistEPA Inspection No.: EPA-HANFORD-CCP-10.05-8NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B)Inspection Date: April 27 – 29, 2010Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceSystem CalibrationEach NDA instrument must be calibratedbefore its initial use. Determine the date ofthe system’s calibration of record and wherethis is documented.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The energy calibrations for bothGEA units that were established byHanford outside of CCP are thecalibrations of record. Both GEAunits had new efficiencycalibrations performed by CCP.YCCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportThe range of applicability of the system’scalibration(s) must be specified in siteprocedures or other formal documentation.Identify the manner in which the range isexpressed, i.e., curies or Pu/SNM mass foractivity and salient physical characteristicsfor matrix.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The ranges of both GEA units areexpressed in terms of nuclearmaterial content (grams of WG Pu)and matrix (material density ing/cm3).YCCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportAny matrix/source surrogate wastecombinations must be representative of theactivity ranges and relevant waste matrixcharacteristics currently in use or planned foruse by the system. The system must becalibrated to 100% recovery.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Matrix/source surrogate wastecombinations used arerepresentative of the activity rangesand relevant physical characteristicsof the matrices currently measuredor planned for use by the system.The system is calibrated to 100%recovery.YCCP-TP-070, Revision 0, CCPGamma Energy Assay (GEA)Calibration, Confirmation andVerification Procedure; CCP-RLGEA_A-001, Revision 0, GammaEnergy Assay (GEA) System UnitA Calibration, Confirmation andVerification Report; CCP-RLGEA_B-001, Revision 0, GammaEnergy Assay (GEA) System UnitB Calibration, Confirmation andVerification ReportThe use of consensus standards forcalibration is required, when such standardsexist. If consensus standards do not exist, thecalibration technique must be approved byCBFO.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24ASTM C-1133-03 is the consensusstandard that was used forcalibration of both GEA units.YCCP-TP-070, Revision 0, CCPGamma Energy Assay (GEA)Calibration, Confirmation andVerification ProcedureRevision No.: Site specific checklistA-24Attachment A.2 Non-Destructive Assay (NDA) ChecklistEPA Inspection No.: EPA-HANFORD-CCP-10.05-8NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B)Inspection Date: April 27 – 29, 2010Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceIdentify the specific consensus standards thatwere used for the system calibration or, intheir absence, the alternate calibrationtechnique. Evaluate the CBFO approval ofthe alternate technique.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24See answer to previous checklistitem.Y See answer to previous checklistitem.Primary standards must be obtained fromsuppliers maintaining a nationally accreditedmeasurement program. Identify thenationally accredited measurement program.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Primary gamma standards havebeen obtained from LANL (WG Pustandards) and North AmericanScientific (mixed gamma sources).Both suppliers maintain a nationallyaccredited measurement programthat has been identified andappropriately documented.Y CCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportList the standards used for calibration andverify the pedigree of each standard.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The calibration standards are listedin the calibration reports and thepedigree of each has been verified.Y CCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportCalibration Verification & ConfirmationVerification of an NDA instrument’scalibration must be performed after any ofthe following occurrences: major systemrepairs and/or modifications, replacement ofthe system’s components, significant changesto the system’s software, and relocation ofthe system.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The calibration of both GEA unitshas been verified performed anddocumented as required.YCCP-TP-070, Revision 0, CCPGamma Energy Assay (GEA)Calibration, Confirmation andVerification Procedure; CCP-RLGEA_A-001, Revision 0, GammaEnergy Assay (GEA) System UnitA Calibration, Confirmation andVerification Report; CCP-RLGEA_B-001, Revision 0, GammaEnergy Assay (GEA) System UnitB Calibration, Confirmation andVerification ReportRevision No.: Site specific checklistA-25Attachment A.2 Non-Destructive Assay (NDA) ChecklistEPA Inspection No.: EPA-HANFORD-CCP-10.05-8NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B)Inspection Date: April 27 – 29, 2010Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceRecalibration of the system must occur if thecalibration verification demonstrates that thesystem’s response has significantly changed.NA CCP-PO-002, CCP WasteCertification Plan, Revision 24Not applicable, theses systems havenot been relocated.NA NAThe system calibration must be confirmed byperforming replicate measurements of a noninterfering matrix.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The system calibration has beenconfirmed by performing replicatemeasurements of a non-interferingmatrix.YCCP-TP-070, Revision 0; CCPRL-GEA_A-001, Revision 0,Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportReplicate measurements must be performedwith containers of the same nominal size andaccording to the same procedures used foractual waste assays.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Replicate measurements have beenperformed with containers of thesame nominal size and according tothe same procedures as those usedfor actual waste assays.YCCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportReplicate measurements must be performedusing nationally recognized standards orstandards derived from nationally recognizedstandards that span the range of use of theinstrument with respect to disintegration rateand/or matrix effects. Identify all standardsthat were used and indicate their application(verification or confirmation).Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Replicate measurements have beenperformed using nationallyrecognized standards or standardsderived from nationally recognizedstandards that span the range of useof the instrument with respect todisintegration rate and/or matrixeffects. All standards that were usedhave been identified and theirapplication documented.Y CCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportIdentify the nationally accreditedmeasurement program. List the standardsused for verification/confirmation and verifyY CCP-PO-002, CCP WasteCertification Plan, Revision 24The nationally accreditedmeasurement program has beenidentified and the pedigree of thegamma and WG Pu standards usedY CCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationRevision No.: Site specific checklistA-26Attachment A.2 Non-Destructive Assay (NDA) ChecklistEPA Inspection No.: EPA-HANFORD-CCP-10.05-8NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B)Inspection Date: April 27 – 29, 2010Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidencethe pedigree of each standard.for verification and/or confirmationhas been verified.Report; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportThe standards used for calibrationconfirmation must not be the same sources asthose used for the system’s calibration ofrecord.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The WG Pu standards used forcalibration confirmation are not thesame as the gamma sources used forthe system’s calibration of record.Y CCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportRequirements for accuracy, expressed as %R,and precision, expressed as %RSD, must bemet as specified in DOE/WIPP-02-3122,Appendix A, Table A-3.2 for precision and±30% for accuracy.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Requirements for accuracy andprecision have been met as specifiedin DOE/WIPP-02-3122, AppendixA, Table A-3.2 for precision and±30% for accuracy.Y CCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportQuality ControlAll radioassay and data validation must beperformed by appropriately trained andqualified personnel.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24All radioassay and data validationhas been performed byappropriately trained and qualifiedpersonnel.YGEAA BDRs RLGEAA0001,RLGEAA0002 & RLGEAA0003;GEAB BDRs RLGEAB0001,RLGEAB0002 & RLGEAB0003Identify the name, title and function of allpersonnel performing NDA data validation.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The name, title and function of allpersonnel performing NDA datavalidation are documented.YGEAA BDRs RLGEAA0001,RLGEAA0002 & RLGEAA0003;GEAB BDRs RLGEAB0001,RLGEAB0002 & RLGEAB0003Requalification of personnel must be basedon evidence of continued satisfactoryY CCP-PO-002, CCP WasteCertification Plan, Revision 24Requalification of personnel isbased on evidence of continuedY Hanford-CCP List of QualifiedIndividuals, NDA GEA, April 14,Revision No.: Site specific checklistA-27Attachment A.2 Non-Destructive Assay (NDA) ChecklistEPA Inspection No.: EPA-HANFORD-CCP-10.05-8NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B)Inspection Date: April 27 – 29, 2010Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidenceperformance and must be performed at leastevery two years.satisfactory performance and iscurrent.2010, 11:32 AMAll computer programs, includingspreadsheets used for data reduction oranalysis, must meet the applicablerequirements in the CBFO QAPD.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Not assessed during this inspection. NA Not assessed during thisinspection.The site must participate in relevantmeasurement comparison programssponsored or approved by CBFO, includingthe NDA PDP.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Hanford-CCP participated in theCBFO-sponsored NDA PDP, Cycle17A (May 2010 distribution) byassaying S5000 wastes containingdebris, glass, and sludge.YBackground and Performance ChecksAssay system background measurementsmust be taken daily, unless otherwiseapproved by CBFO. Determine the form ofCBFO approval documentation of thealternate approach to backgrounds, ifapplicable. Contributions to backgroundsfrom nearby radiation sources must becarefully controlled, or more frequentbackgrounds must be measured.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Daily background measurementshave been taken and recorded daily.Contributions to backgrounds fromnearby radiation sources (i.e., otherwaste drums stored or stagedinWRAP) have been carefullycontrolled.YGEAA BDRs RLGEAA0001,RLGEAA0002 & RLGEAA0003;GEAB BDRs RLGEAB0001,RLGEAB0002 & RLGEAB0003Assess how often background radiation wasproblematic to the extent that measurementpersonnel had to make adjustments.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Background records document theperformance of both GEA unitsover time.Y GEAA BDRs RLGEAA0001,RLGEAA0002 & RLGEAA0003;GEAB BDRs RLGEAB0001,RLGEAB0002 & RLGEAB0003Identify the criteria used to evaluateinstrument backgrounds and assess thetechnical adequacy of this criterion, i.e.,statistical or administrative.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Backgrounds have been evaluatedagainst a technically appropriateacceptance criterion and the natureand results of these evaluations havebeen documented.Y GEAA BDRs RLGEAA0001,RLGEAA0002 & RLGEAA0003;GEAB BDRs RLGEAB0001,RLGEAB0002 & RLGEAB0003Identify the number of data points required toderive the initial control limit. At whatinterval(s) will new limits be calculated?Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The number of data points requiredto derive the initial control limit andthe interval(s) at which will newlimits be calculated are documented.Y CCP-TP-072, Revision 0Revision No.: Site specific checklistA-28Attachment A.2 Non-Destructive Assay (NDA) ChecklistEPA Inspection No.: EPA-HANFORD-CCP-10.05-8NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B)Inspection Date: April 27 – 29, 2010Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceSystem performance checks must beperformed at least once per operational day.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Performance checks have beenperformed at least once peroperational day and all checks havebeen documented.Y GEAA BDRs RLGEAA0001,RLGEAA0002 & RLGEAA0003;GEAB BDRs RLGEAB0001,RLGEAB0002 & RLGEAB0003System performance checks must include, asapplicable, efficiency, matrix correctionchecks, and systems peak position andresolution for spectrometric systems.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Performance checks includeefficiency, matrix correction checks,and peak position and resolutionchecks.Y GEAA BDRs RLGEAA0001,RLGEAA0002 & RLGEAA0003;GEAB BDRs RLGEAB0001,RLGEAB0002 & RLGEAB0003At a minimum of once per operational weekan interfering matrix must be assayed toassess the long term stability of the NDAinstrument and its matrix corrections andhow this performance is documented.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24An interfering matrix is used toassess the long term stability of theGEA units and their matrixcorrections at least once peroperational week. This activity isappropriately documented.Y CCP-RL-GEA_A-001, Revision0, Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportInterfering surrogate waste matrices must beconstructed in a way that the salient matrixcharacteristics do not change over time.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Interfering surrogate waste matriceshave been constructed such that thesalient matrix characteristics do notchange over time.Y CCP-TP-072, Revision 0; CCPRL-GEA_A-001, Revision 0,Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportThe radionuclide sources used forperformance checks must be long-lived andof sufficient strength (activity) to providestatistically sufficient results over a shortmeasurement time.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The WG Pu and gamma sourcesused for performance checks arelong-lived and are of sufficientactivity to provide statisticallysufficient results over a shortmeasurement time.Y CCP-TP-072, Revision 0; CCPRL-GEA_A-001, Revision 0,Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BRevision No.: Site specific checklistA-29Attachment A.2 Non-Destructive Assay (NDA) ChecklistEPA Inspection No.: EPA-HANFORD-CCP-10.05-8NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B)Inspection Date: April 27 – 29, 2010Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceCalibration, Confirmation andVerification ReportRadioactive sources are decay corrected as afunction of their physical half life, asappropriate, specifically133Ba,252Cf,137Cs,75Se and109Cd.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Radioactive sources are decaycorrected as a function of theirphysical half life, as appropriate.Y CCP-TP-072, Revision 0; CCPRL-GEA_A-001, Revision 0,Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportPerformance checks must be quantitative andbased on 2 and 3 sigma limits.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Performance checks are quantitativeand based on 2 and 3 sigma limits.Y CCP-TP-072, Revision 0; CCPRL-GEA_A-001, Revision 0,Gamma Energy Assay (GEA)System Unit A Calibration,Confirmation and VerificationReport; CCP-RL-GEA_B-001,Revision 0, Gamma Energy Assay(GEA) System Unit BCalibration, Confirmation andVerification ReportData ManagementAll radioassay data must be reviewed andapproved by qualified personnel before beingreported to WWIS.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24All radioassay data have beenreviewed and approved by qualifiedpersonnel before being reported toWWIS.YCCP-TP-072, Revision 0; GEAABDRs RLGEAA0001,RLGEAA0002 & RLGEAA0003;GEAB BDRs RLGEAB0001,RLGEAB0002 & RLGEAB0003Identify the name, title and function of theindividual(s) performing technical reviewand approval of NDA BRDs.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24The name, title and function of theindividual(s) performing technicalreview and approval of NDA BRDsare documented on the LOQI and inCCP training records.YCCP-TP-072, Revision 0;Hanford-CCP List of QualifiedIndividuals, NDA GEA, April 14,2010, 11:32 AMRevision No.: Site specific checklistA-30Attachment A.2 Non-Destructive Assay (NDA) ChecklistEPA Inspection No.: EPA-HANFORD-CCP-10.05-8NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B)Inspection Date: April 27 – 29, 2010Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceRadioassay BDRs must consist of thefollowing elements:•Testing facility name, testing batchnumber, container numbers, andsignature of the Site Project Officer(SPO) or designee(s)•Table of Contents•Background and performance check dataor control charts for the relevant timeperiod.•Data validation per the QAPD and siteprocedures•Separate testing report sheets for eachcontainer.Y CCP-PO-002, CCP WasteCertification Plan, Revision 24Radioassay BRDs consist of thefollowing elements:•Testing facility name, testingbatch number, containernumbers, and signature of theSite Project Officer (SPO) ordesignee(s)•Table of Contents•Background and performancecheck data or control charts forthe relevant time period.•Data validation per the QAPDand site procedures•Separate testing report sheetsfor each container.YGEAA BDRs RLGEAA0001,RLGEAA0002 & RLGEAA0003;GEAB BDRs RLGEAB0001,RLGEAB0002 & RLGEAB0003Radioassay data sheets must include:•Title “Radioassay Data Sheet”•Method/procedure used•Date of radioassay•Activities and associated TMU forindividual radionuclides•TRU alpha concentration and itsassociated TMU•Operator signature•Reviewer signatureY CCP-PO-002, CCP WasteCertification Plan, Revision 24Radioassay data sheets include:•Title “Radioassay Data Sheet”•Method/procedure used•Date of radioassay•Activities and associated TMUfor individual radionuclides•TRU alpha concentration andits associated TMU•Operator signature•Reviewer signatureYGEAA BDRs RLGEAA0001,RLGEAA0002 & RLGEAA0003;GEAB BDRs RLGEAB0001,RLGEAB0002 & RLGEAB0003The following nonpermanent records must bemaintained at the radioassay-testing facilityor forwarded to the site project office:•Testing batch reportsNA NA Not assessed during thisinspection.NA NARevision No.: Site specific checklistA-31Attachment A.2 Non-Destructive Assay (NDA) ChecklistEPA Inspection No.: EPA-HANFORD-CCP-10.05-8NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B)Inspection Date: April 27 – 29, 2010Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidence•All raw data, including instrumentreadouts, calculation records, andradioassay QC results•All applicable instrument calibrationreportsRevision No.: Site specific checklistA-32ATTACHMENT A.3 REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH RTR ChecklistInspection Date: April 27-29, 2010Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresObjective Evidence/CommentsRTR-1:Site procedures identifyrequired training and qualificationsfor RTR personnel.CCP-TP-028,Revision 3CCP-QP-002,Revision 27Operator training was consistent withapplicable procedures.Operator certification is current.OJT was documented for each operator.Operators are re-qualified every two years.RTR operators passed a training drum testthat includes items common to the wastestreams examined at the site (biannually).RTR operators receive training on the wastematrix parameters and typical packagingconfigurations expected in each waste stream.Current LOQI.The EPA inspectors reviewed training records and currentdemonstration of capability recordings to ensure that RTRoperators were adequately trained and that trainingrecordswere complete. Operators use the LOQI to ensure thatonly qualified operators performed RTR examinations.Objective evidence:1.RTR BDRs and audio/visual recording of RTR eventsfor selected drums contained in BDRs RLRTRA0001,RLRTRA0002, and RLRTRA00032.Written and audio/visual recordings of CapabilityDemonstration Data Sheet for Contact-HandledWaste for various RTR operators3.Qualification card and training records for three RTRoperators/ITRs4.CCP NDE Test Drum Inventory Sheet for HANNDETEST-02, -03, and -045.List of currently qualified RTR personnelRTR-2:Site procedure(s) providecomplete instructions for operators toperform the RTR examination andcompletion of the associateddocumentation.CCP-TP-053,Revision 7RTR operator adequately explained theprocess followed for examining a drum andentering data into data forms (whether hardcopy or electronic data entry is used).Prior to observing the RTR event for containerRL0056204, EPA interviewed an RTR operator to ensurethat they were knowledgeable about how RTR wasperformed and what records were generated. The operatorwas able answer all questions correctly.Objective evidence:1.RTR BDRs and audio/visual recording of RTR eventsfor selected drums contained in BDRs RLRTRA0001,RLRTRA0002, and RLRTRA00032.SOP CCP-TP-053, Attachment 1 & 2, Table 33.List of currently qualified RTR personnelRTR-3:The RTR procedure(s)require an image quality check to beperformed.CCP-TP-053,Revision 7,Section 4.3Operator adequately explained how theacceptability of an image is determined.Image quality (IQI) check is performed onceper day.Performance of the image quality check isdocumented and recorded.EPA inspectors confirmed adherence to recording qualityverification requirements through interviews with RTRoperators, observation of a RTR event, and review ofwritten BDRs and audio/video tapes. EPA was able toreview the IQI for batch RLRTRA0025 (batch thatobserved drum was part of).Objective evidence:1.RTR BDRs and audio/visual recording of RTR eventsRevision No.: Site specific checklistA-33ATTACHMENT A.3 REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH RTR ChecklistInspection Date: April 27-29, 2010Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresObjective Evidence/Commentsfor selected drums contained in BDRs RLRTRA0001,RLRTRA0002, and RLRTRA0003RTR-4:The procedure allows theoperator to adjust the RTR toaccommodate the physical propertiesof the waste and waste containerslikely to be encountered at the site.CCP-TP-053,Revision 7,Section 4.4Operator could identify applicable policiesand procedures governing the operation ofRTR equipment.The RTR system could be adjusted.High-density material was examined with theX-ray device set on the maximum voltage andlow density material at a lower voltage.Operator adequately explained what is done ifan image is unacceptable (e.g., the waste issolidified or the container is lead-lined).EPA inspectors observed the RTR examination ofcontainer RL0056204 on RTR unit A and reviewed 3completed BDRs to ensure that examinations werecomplete and adequately recorded. During theexamination, the RTR operator adjusted the X-ray voltageto ensure identification of all waste items. The operatorwas able to explain disposition of containers if animpenetrable image is observed.Objective evidence:1.RTR BDRs and audio/visual recording of RTR eventsfor selected drums contained in BDRs RLRTRA0001,RLRTRA0002, and RLRTRA00032.List of currently qualified RTR personnelRTR-5:CCP-TP-053,Revision 7,Section 4.3RTR tape is high quality, the sound track isaudible, and the required information iscontained on the audible portion of the tape.The RTR tape is consistent with the datapackage for the same drum.EPA inspectors confirmed adherence to recording qualityverification requirements through interviews with RTRoperators, observation of a RTR event, and review ofwritten BDRs and audio/video tapes.Objective evidence:1.RTR BDRs and audio/visual recording of RTR eventsfor selected drums contained in BDRs RLRTRA0001,RLRTRA0002, and RLRTRA0003RTR-6:There is a procedure fordetermining whether the wastematches the waste stream descriptionand Waste Matrix Code, and fordetermining Waste MaterialParameters and weights.CCP-TP-053,Revision 7,Section 4.4,Table 3,Attachment 2The procedure is adequately implemented.Operators verify that the waste matches thewaste stream description.Waste Matrix Code is verified. If not,corrective action is taken.WMP weights are estimated by compiling aninventory of waste items andresidual/packaging materials.Does the RTR operator use a standard weightlookup table to provide an estimate of WMPweights? If so, has the table been updated toreflect additional information gained throughEPA inspectors observed the RTR evolution for containerRL0056204 on RTR unit A and reviewed 3 completedBDRs to ensure that examinations were complete andadequately recorded. Attachment 2 from CCP-TP-053 wasused to record data and other required information.WMP weights were estimated or taken from the standardweight table provided in the RTR SOP. Container weightswere obtained from Standing Order CCP-SO-RL-01.Objective evidence:1.RTR BDRs and audio/visual recording of RTR eventsfor selected drums contained in BDRs RLRTRA0001,RLRTRA0002, and RLRTRA00032.SOP CCP-TP-053, Attachment 1 & 2, Table 3Revision No.: Site specific checklistA-34ATTACHMENT A.3 REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH RTR ChecklistInspection Date: April 27-29, 2010Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresObjective Evidence/Commentsprevious RTR/VE exams or updated AKinformation?3.List of currently qualified RTR personnelRTR-7:The RTR procedureprovides instructions for identifyingprohibited items and for processingdrums containing prohibited items.CCP-TP-053,Revision 7,Section 4.4,Table 1,Attachment 2Operator could name prohibited items.Operator adequately explained how thepresence of free liquids is determined.Operator’s explanation of required actions ifprohibited items were encountered wasconsistent with procedure.Corrective actions are taken when necessary.EPA inspectors observed the RTR evolution for containerRL0056204 on RTR unit A. The examination wasperformed in accordance with CCP-TP-053 except thatanuncontrolled and incorrect liquid volume calculation wasused by the operator. This calculation was noted onapiece of scrap paper and did not appear to be partof theofficial record. EPA Concern Hanford-CCP-CH-RTR-10-001CR was generated to address this issue.The RTR operator, who performed the on-sitedemonstration, was able to describe prohibited items andwhat actions would be taken if identified in a containerduring RTR examination.Although no NCRs had been initiated for validatedbatches, EPA reviewed NCR-RL-0642-10 to ensure thatNCRs were documented correctly. EPA determined thatthe RTR operators understood the NCR process.Objective evidence:1.RTR BDRs and audio/visual recording of RTR eventsfor selected drums contained in BDRs RLRTRA0001,RLRTRA0002, and RLRTRA00032.NCR-RL-0642-103.List of currently qualified RTR personnel4.Measurement Conversion Chart (uncontrolled)RTR-8:RTR procedures include therequired QC examinations, evaluationaccuracy and reproducibility of theRTR processCCP-TP-053,Revision 7,Section 4.5, 4.6An independent replicate scan is performedon one waste container per day or on onecontainer per testing batch (whichever is lessfrequent).An independent observation of one scan (notthe replicate) is performed, by a qualifiedRTR operator (anyone but the initial RTRoperator).EPA reviewed 3 BDRs and determined that all requiredQC was performed for these batches.Objective evidence:1.RTR BDRs and audio/visual recording of RTR eventsfor selected drums contained in BDRs RLRTRA0001,RLRTRA0002, and RLRTRA0003RTR-9:Procedure(s) containstandardized forms for recordingCCP-TP-053,Revision 7,Attachments 1RTR operator adequately explained theprocess followed for examining a drum andentering data into data forms (whether hardA qualified RTR operator performs the examination and asecond person electronically enters the data generated.This second person is not required to be a qualified RTRRevision No.: Site specific checklistA-35ATTACHMENT A.3 REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH RTR ChecklistInspection Date: April 27-29, 2010Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresObjective Evidence/CommentsRTR data and 2 copy or electronic data entry is used).Direct data entry into an electronic form isdone by the RTR operator using a computerwhile the operator is still in the RTR booth.The electronic data file undergoes the samequality control (QC) checks used for handwritten data entries.operator.WMP weights were estimated or taken from the standardweight table provided in the RTR SOP. Container weightswere obtained from Standing Order CCP-SO-RL-01.Objective evidence:1.RTR BDRs and audio/visual recording of RTR eventsfor selected drums contained in BDRs RLRTRA0001,RLRTRA0002, and RLRTRA00032.SOP CCP-TP-053, Revision 73.Standing Order CCP-SO-RL-01, April 14, 2010RTR-10:Site procedures requirereview of Batch Data Reports (BDRs)at the data generation and projectlevelCCP-TP-053,Revision 7,Attachment 3CCP-TP-001,Revision 17,Attachment 2Data generation level reviews are performedand documented (ITR).Project level reviews are performed anddocumented (SPM).EPA verified that the 3 BDRs examined during theinspection had been reviewed at both data generation andproject level.Objective evidence:1.BDRs RLRTRA0001, RLRTRA0002, andRLRTRA0003Revision No.: Site specific checklistA-36ATTACHMENT A.4 VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH VE Checklist Inspection Date: April 27-29, 2010Establishment of RequiredTechnical Elements inProceduresLocationExecution of ProceduresObjective Evidence/CommentVE-1:Site procedures identifyrequired training andqualifications for VE personnel.CCP-QP-002,Revision 27Visual Examination Expert’s (VEE)explanation of job duties was consistentwith applicable procedures.VE personnel’s training was consistent withapplicable procedures.VE personnel’s certification is current.VE personnel are re-qualified every twoyears.VE personnel received training on specificwaste generating processes, typicalpackaging configurations, WMPs expectedto be found in each Waste Matrix Code.EPA reviewed training records to ensure that they were complete andcurrent. EPA interviewed operators and a VEE to verify that they hadreceived training about EPA’s regulation and CFR Part 194. The VEEdid not have any knowledge of these subjects and EPA issued FindingHanford-CCP-CH-VE-10-005F to address lack of training.The VEE was appointed in March of 2010, after VE had begun at thesite. EPA issued Concern Hanford-CCP-CH-VE-0006CR to addressthis issue. The CCP Site Project Manager stated inthe inspectionclosing meeting that this was a problem as CCP haddecided to RTRall VE’d containers (except those contained in BDRsRLVEPF0022and RLVEPF0023).Objective evidence:1.Visual Examination BDRs RLVEPF0022 and RLVEPF00232.List of currently qualified VE personnel, April 14,20103.Qualification card and training records for three VE operators andone VE operator/Visual Examination Expert (VEE)4.Letter appointing the VEE, March 12, 20105.CCP-TP-113, CCP Standard Contact-Handled Waste VisualExamination, Revision 13, March 11, 2009VE-2:Procedures and technicalguidance documents providecomplete instructions forperforming VE.CCP-TP-113,Revision 13The site uses AK to identify the wastematrix code category and to estimate wastematerial parameters present.Procedures are sufficiently detailed toenable the operator to determine if a wastecontainer meets the criteria of '194.24 withregard to identifying applicable parameterswith waste limits.Establish standard nomenclature, based oncurrent site practice, so that all staffrecognize waste by the same descriptors.SOP CCP-TP-113 is a well-established procedure andcontains allinstructions necessary to perform VE. Table 4 of the SOP providesstandard weights for common waste items.Objective evidence:1.Visual Examination BDRs RLVEPF0022 and RLVEPF00232.List of currently qualified VE personnel, April 14,20103.Qualification card and training records for three VE operators andone VE operator/Visual Examination Expert (VEE)4.CCP-TP-113, CCP Standard Contact-Handled Waste VisualExamination, Revision 13, March 11, 2009VE-3:Procedure requires anaudio/visual recording of the VEevent to be made.CCP-TP-113,Revision 13VEE is responsible for overall VE activities.VEE/operator’s explanation of how tooperate the data recording system wasThe EPA team interviewed this projects qualified VEE and 3 qualifiedVEO/ITRs and reviewed 2 BDRs to determine if the process wasimplemented as written.Revision No.: Site specific checklistA-37ATTACHMENT A.4 VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH VE Checklist Inspection Date: April 27-29, 2010Establishment of RequiredTechnical Elements inProceduresLocationExecution of ProceduresObjective Evidence/Commentconsistent with applicable procedures.The video camera was focused prior to thestart of VE.An audio/videotape is made of the wastecontainer exam and maintained as anonpermanent record.Data on the audio/visual recording isconsistent with documentation.No audio/visual recording is made of the examination because 2qualified VEOs perform VE.Objective evidence:1.Visual Examination BDRs RLVEPF0022 and RLVEPF00232.List of currently qualified VE personnel, April 14,20103.Qualification card and training records for three VE operators andone VE operator/Visual Examination Expert (VEE)4.Letter appointing the VEE, March 12, 20105.CCP-TP-113, CCP Standard Contact-Handled Waste VisualExamination, Revision 13, March 11, 2009VE-4:There is a procedure forhandling instances when the VEExpert is unable to see throughthe inner plastic bags/ packages/containers of waste.CCP-TP-113,Revision 13The VEE has decision making criteria forassessing the need to open thebags/packages in order to identify all oftheir contents.If the bags are not opened, a brief writtendescription of the contents of the bags isprepared with estimates of the amount ofeach waste type in the bags.The VEE is not necessarily in the operations room during all VEevents. The VEOs can contact the VEE at any time todiscussassignment of WMPs and any other issue encountered.The wastebeing Ve’d and containerized comes from dismantlingof 3 story highglove boxes in the PFP Building and consequently most of the wasteprocessed is easily recognizable.Objective evidence:1.Visual Examination BDRs RLVEPF0022 and RLVEPF00232.List of currently qualified VE personnel, April 14,20103.Qualification card and training records for three VE operators andone VE operator/Visual Examination Expert (VEE)4.Letter appointing the VEE, March 12, 20105.CCP-TP-113, CCP Standard Contact-Handled Waste VisualExamination, Revision 13, March 11, 2009VE-5:The VE procedurerequires verification of WasteMatrix Code and WMP weights.CCP-TP-113,Revision 13If an automated data entry system is used,data entry VE personnel could navigatethrough the various screens.A VE data form is used to document thewaste matrix code and estimated WMPweights of the waste.VE staff have access to standardized chartsor tables to aid in the consistentestimation/assignment of weights, wastematerial parameters, and waste matrixcodes.Raw data is collected during VE and transferred onto the final datasheets outside of the VE area. This variation in the usual VE process isdue to the safety concerns associated with the workarea and the needto wear full respirator suits. The BDRs reviewed were complete.AT previous baseline inspections, the EPA inspectors have observedthe VE event for a selected container. Because of the safety concernsdescribed above, EPA’s inspection of VE was limitedto review ofdocuments and records, and interview of the VE operators and VEE.Objective evidence:1.Visual Examination BDRs RLVEPF0022 and RLVEPF00232.List of currently qualified VE personnel, April 14,2010Revision No.: Site specific checklistA-38ATTACHMENT A.4 VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH VE Checklist Inspection Date: April 27-29, 2010Establishment of RequiredTechnical Elements inProceduresLocationExecution of ProceduresObjective Evidence/CommentThe estimated or weighed WMP weightsare determined by compiling an inventoryof waste items, residual materials andpackaging materials.The items on the inventory list are sorted byWMP and combined with a standard weightlook-up table to provide an estimate ofWMP weights.References tables are updated as site gainsinformation from VE.VEE verifies Waste Matrix Code andrecommends changes as needed.3.Qualification card and training records for three VE operators andone VE operator/Visual Examination Expert (VEE)4.Letter appointing the VEE, March 12, 20105.CCP-TP-113, CCP Standard Contact-Handled Waste VisualExamination, Revision 13, March 11, 2009VE-6:Procedure providesinstructions for processing ofcontainers with prohibited items.CCP-TP-113,Revision 13VE operator/expert’s explanation ofrequired actions if prohibited items wereencountered was consistent with procedure.The VE operator describes any liquidsfound, including a description of theirlocation in the container and estimatedvolume.Other prohibited items, including sealedcontainers are identified and segregated.Waste items are broken down by specialize site personnel so that theVEOs can verify that no prohibited items are present in the waste. TheVE procedure provides instructions for dispositionof prohibited itemsif they are found.Objective evidence:1.Visual Examination BDRs RLVEPF0022 and RLVEPF00232.List of currently qualified VE personnel, April 14,20103.Qualification card and training records for three VE operators andone VE operator/Visual Examination Expert (VEE)4.Letter appointing the VEE, March 12, 20105.CCP-TP-113, CCP Standard Contact-Handled Waste VisualExamination, Revision 13, March 11, 2009VE-7:Personnel can describe how an NCR isinitiated.Review of training records and interview with the VE personnelenabled the EPA inspectors to determine that NCRS are initiated asnecessary.Objective evidence:1.Visual Examination BDRs RLVEPF0022 and RLVEPF00232.List of currently qualified VE personnel, April 14,20103.Qualification card and training records for three VE operators andone VE operator/Visual Examination Expert (VEE)4.Letter appointing the VEE, March 12, 2010Revision No.: Site specific checklistA-39ATTACHMENT A.4 VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH VE Checklist Inspection Date: April 27-29, 2010Establishment of RequiredTechnical Elements inProceduresLocationExecution of ProceduresObjective Evidence/Comment5.CCP-TP-113, CCP Standard Contact-Handled Waste VisualExamination, Revision 13, March 11, 2009VE-8:CCP-TP-113,Revision 13The gross weight of the waste container(container plus contents) is recorded on theVE data form.Volume utilization of the container isdocumented.Attachment 2, CCP Waste Visual Examination Data Form, of CCPTP-113 requires operators to record volume utilization. EPA verifiedthis by review of 2 BDRs.Gross weight of the container is determined after conclusion of VEand hence was not reviewed.Objective evidence:1.Visual Examination BDRs RLVEPF0022 and RLVEPF00232.List of currently qualified VE personnel, April 14,20103.CCP-TP-113, CCP Standard Contact-Handled Waste VisualExamination, Revision 13, March 11, 2009VE-9:CCP-TP-113,Revision 13CCP-QP-005,Revision 18The procedure is adequately implemented.Corrective actions are taken whennecessary.EPA determined by review of completed BDRs that theprocedurewas implemented as written.Objective evidence:1.Visual Examination BDRs RLVEPF0022 and RLVEPF00232.List of currently qualified VE personnel, April 14,20103.CCP-TP-113, CCP Standard Contact-Handled Waste VisualExamination, Revision 13, March 11, 2009VE-10:Site procedure(s)require data generation andproject level reviews of BatchData Reports (BDRs).CCP-TP-113,Revision 13CCP-TP-001,Revision 17,Attachment 1BDRs contain all required information.Data generation and project level reviewsare complete.EPA inspectors reviewed 2 VE BDRs to ensure that all requiredinformation was recorded and that the BDRs had beenreviewed atboth data generation and project level. EPA did notidentify anyproblems with the BDRs.Objective evidence:1.Visual Examination BDRs RLVEPF0022 and RLVEPF00232.List of currently qualified VE personnel, April 14,20103.CCP-TP-113, CCP Standard Contact-Handled Waste VisualExamination, Revision 13, March 11, 2009Revision No.: Site specific checklistA-40ATTACHMENT A.5 WIPP WASTE DATA SYSTEM (WDS) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH WDS Checklist Inspection Date: April 27-29, 20108Establishment of RequiredTechnical Elements in ProceduresLocationExecution of ProceduresObjective Evidence/CommentWDS-1:WDS and Data EntryPersonnel must be trained to assessdata and properly enter data into theWaste Data System (WDS).CCP-QP-002,Revision 27CCP-TP-030,Revision 27WCO and Data Entry Personnel are trainedto assess data and properly enter and transferall data in the WDS.Training for Data Entry Personnel and datareviewers/verifiers include the WIPP WasteInformation System User’s Manual and theapplicable site procedures.Training records are available for review andare complete.The EPA inspections reviewed the qualification cardandtraining records for the WCO who provided the on-sitedemonstration. The training records were found to be completeexcept for training on the new WDS User’s Manual.Hanford-CCP-CH-WDS-10-002CRCCP training procedure CCP-QP-002, Revision 27, Section[C.3] requires Waste Certification Officials (WCOs)todemonstrate proficiency in WWIS as part of training.However, WDS is not specifically identified in thetrainingprocedure although this is the only User’s Manual listed in thereference section of CCP-TP-030. The Hanford-CCP ProjectManager indicated that the procedure(s) associatedwith dataentry are being revised at this time.Objective evidence:1.CCP-TP-030, Revision 272.WCO qualification card and training recordWDS-2:Security measures forensuring data integrity and accessingWDS are sufficient.YCCP-TP-030,Revision 27,Section 4.1Access to WDS is controlled. WDS accessrequests are recorded in an access log,however named, that is available for review.The Data Administrator is required to grant accessto WDS,the request from CCP and DA response takes place asemailcommunications. This type of communication is alsoused torescind access as necessary. EPA reviewed a previous emailfrom the DA eliminating a person’s access.Objective evidence:1.CCP-TP-030, Revision 272.WCO qualification card and training record3.DA email rescinding database accessWDS-3:YCCP-TP-030,Revision 27,Sections 3.0,4.0Employee’s explanation of job duties wasconsistent with applicable procedures. WCOand WCA adequately explained how dataare assessed, input, and transferred intoWDS.The EPA team interviewed an experienced (5 years) WCOduring the on-site inspection. The WCO identified minorchanges between WDS and WWIS, for example, the ability ofthe WCO to change data in WDS. From the WCO’sinformation about WDS and EPA observing a WDSdemonstration, EPA determined that WDS was suitableforuploading and retrieving characterization and certificationdata.Revision No.: Site specific checklistA-41ATTACHMENT A.5 WIPP WASTE DATA SYSTEM (WDS) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH WDS Checklist Inspection Date: April 27-29, 20108Establishment of RequiredTechnical Elements in ProceduresLocationExecution of ProceduresObjective Evidence/Comment1.CCP-TP-030, Revision 272.Waste Container Data Report for container RL0063021and RL00630343.CCP Correlation of Container Identification NumberstoBatch Data Reports, waste stream MPFPDD, lot #14.WDS data entry summary, characterization andcertification, spreadsheet for containers RL0062930,RL0063034, RL0063014, RL0063021, RL0063040WDS-4:Procedures require that onlyverified and validated data are enteredinto WDS.YCCP-TP-030,Revision 27,Section 4.3,Table 1Data generation and project level reviews ofcontainer data for WDS entry have beenperformed and review checklists arecomplete.Only complete and validated BDR data are entered into WDS.The EPA inspectors traced a randomly chosen LANLcontainer (LA00000064320 in SWB LASB00811) fromemplacement back to the original characterization BDRs, toverify upload of compliant data and the ability ofWDS toretrieve certification data.1.CCP-TP-030, Revision 272.Waste Container Data Report for container RL0063021and RL00630343.CCP Correlation of Container Identification NumberstoBatch Data Reports, waste stream MPFPDD, lot #14.WDS data entry summary, characterization andcertification, spreadsheet for container RL0062930,RL0063034, RL0063014, RL0063021, RL0063040WDS-5:YCCP-TP-030,Revision 27,Section 4.4,Table 1Table 1 used to identify and enter requireddata by WCA.Second WCA reviews data, initials anddates.If data discrepancies cannot be resolved, theform is sent to WCO or SPM for resolution.The new WDS template Excel spreadsheet requires thesamedata entry and review as WWIS. WCOs review data beforeuploading data.1.CCP-TP-030, Revision 272.WDS data entry summary, characterization andcertification, spreadsheet for containers RL0062930,RL0063034, RL0063014, RL0063021, RL00630403.CCP-QP-022, Software Quality Assurance Plan,Attachment 3, Software Problem Reporting and ChangeRequest for WDS Master Template, SCO # 1065, version1 and 24.WCO qualificationWDS-6:YVerify that there are no unresolved NCRs Verified by email from the SPM.Revision No.: Site specific checklistA-42ATTACHMENT A.5 WIPP WASTE DATA SYSTEM (WDS) CHECKLISTEPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8Hanford-CCP CH WDS Checklist Inspection Date: April 27-29, 20108Establishment of RequiredTechnical Elements in ProceduresLocationExecution of ProceduresObjective Evidence/CommentCCP-TP-030,Revision 27,Section 4.4.4for containers. 1.CCP-TP-030, Revision 272.Waste Container Data Report for containers RL0063021and RL00630343.CCP Correlation of Container Identification NumberstoBatch Data Reports, waste stream MPFPDD, lot #14.WDS data entry summary, characterization andcertification, spreadsheet for containers RL0062930,RL0063034, RL0063014, RL0063021, RL0063040WDS-7:Resolution of datadeficienciesYCCP-TP-030,Revision 27,Section 4.5.5WDS Administrator rejects data via email.NCRThe WDS processes are similar to those of WWIS, andstillhave the internal checks that can prevent upload ofnoncompliant data.1.CCP-TP-030, Revision 272.Waste Container Data Report for containers RL0063021and RL00630343.WDS data entry summary, characterization andcertification, spreadsheet for containers RL0062930,RL0063034, RL0063014, RL0063021, RL0063040WDS-8:Records retentionYCCP-TP-030,Revision 27,Section 5.0CCP-QP-008,Revision 15QA/Lifetime records:WDS Master TemplateCorrespondence, including containerrejection emailsQA/Nonpermanent:CDS Database (electronic)Only the template could be verified during the on-siteinspection because of the limited access to the database (due tolack of an approved WSPF).1.CCP-TP-030, Revision 272.CCP-QP-022, Software Quality Assurance Plan,Attachment 3, Software Problem Reporting and ChangeRequest for WDS Master Template, SCO # 1065, version1 and 2Revision No.: Site specific checklistA-43B-1ATTACHMENT B.1 REPLICATE TESTING DATA FOR CONTAINER RL0063023, GEA-AQuantity ofInterestOriginal MeasurementReplicate No. 1Replicate No. 2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 2.60E-02 7.38E-03 2.84E-012.43E-02 6.78E-03 2.79E-012.74E-02 7.44E-03 2.72E-01239Pu Activity (Ci) 2.68E-01 6.67E-02 2.49E-012.87E-01 7.15E-02 2.49E-012.73E-01 6.78E-02 2.48E-01240Pu Activity (Ci) 8.97E-02 2.27E-02 2.53E-016.77E-02 1.72E-02 2.54E-016.53E-02 1.65E-02 2.53E-01242Pu Activity (Ci) 7.82E-06 2.16E-06 2.76E-015.56E-06 1.54E-06 2.77E-015.40E-06 1.49E-06 2.76E-01241Am Activity (Ci) 3.23E-02 8.50E-03 2.63E-015.43E-02 1.44E-02 2.65E-014.18E-02 1.08E-02 2.58E-0190Sr Activity (Ci) 1.09E-07 2.96E-08 2.72E-010.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00137Cs Activity (Ci) 9.94E-08 2.69E-08 2.71E-010.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 5.80E+03 9.93E+02 1.71E-016.04E+03 1.05E+03 1.74E-015.67E+03 9.90E+02 1.75E-01232U Activity (Ci) 3.58E-08 2.05E-08 5.73E-010.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00237Np Activity (Ci) 4.71E-07 1.25E-07 2.65E-010.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00Quantity ofInterestReplicate No. 3Replicate No. 4Replicate No. 5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 1.67E-02 5.20E-03 3.11E-012.35E-02 6.56E-03 2.79E-011.59E-02 4.85E-03 3.05E-01239Pu Activity (Ci) 2.74E-01 6.83E-02 2.49E-012.74E-01 6.82E-02 2.49E-012.66E-01 6.62E-02 2.49E-01240Pu Activity (Ci) 4.57E-02 1.19E-02 2.60E-016.55E-02 1.66E-02 2.53E-016.56E-02 1.66E-02 2.53E-01242Pu Activity (Ci) 3.29E-06 9.74E-07 2.96E-015.29E-06 1.46E-06 2.76E-015.39E-06 1.49E-06 2.76E-01241Am Activity (Ci) 5.08E-02 1.34E-02 2.64E-014.61E-02 1.21E-02 2.62E-015.08E-02 1.34E-02 2.64E-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 5.40E+03 9.86E+02 1.83E-015.70E+03 9.96E+02 1.75E-015.55E+03 9.71E+02 1.75E-01232U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00237Np Activity (Ci) 0.00E+00 N/A 0.00E+002.11E-07 5.67E-08 2.69E-010.00E+00 N/A 0.00E+00B-2ATTACHMENT B.2 REPLICATE TESTING RESULTS FOR CONTAINER RL0063023, GEA-AQuantity ofInterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|



# χ2|)ReportedValueAbsoluteUncertainty233U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!234U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!238U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!238Pu Activity (Ci) 2.60E-02 7.38E-032.16E-02 5.03E-03 2.33E-011.86E+007.62E-01239Pu Activity (Ci) 2.68E-01 6.67E-022.75E-01 7.60E-03 2.76E-025.19E-021.00E+00240Pu Activity (Ci) 8.97E-02 2.27E-026.20E-02 9.14E-03 1.48E-016.49E-019.58E-01242Pu Activity (Ci) 7.82E-06 2.16E-064.99E-06 9.53E-07 1.91E-017.79E-019.41E-01241Am Activity (Ci) 3.23E-02 8.50E-034.88E-02 4.86E-03 9.97E-021.31E+008.60E-0190Sr Activity (Ci) 1.09E-07 2.96E-080.00E+00 0.00E+00 N/A0.00E+001.00E+00137Cs Activity (Ci) 9.94E-08 2.69E-080.00E+00 0.00E+00 N/A0.00E+001.00E+00TRU Alpha Conc. (nCi/g) 5.80E+03 9.93E+025.67E+03 2.37E+02 4.18E-022.28E-019.94E-010.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!232U Activity (Ci) 3.58E-08 2.05E-080.00E+00 0.00E+00 N/A0.00E+001.00E+00237Np Activity (Ci) 4.71E-07 1.25E-074.22E-08 9.44E-08 2.24E+002.28E+006.85E-01Quantity ofInterestTPr(x<|t|)χ2Testt Test233U Activity (Ci) N/A N/A #VALUE! Not Applicable234U Activity (Ci) N/A N/A #VALUE! Not Applicable238U Activity (Ci) N/A N/A #VALUE! Not Applicable238Pu Activity (Ci) 8.06E-01 4.65E-01 Not SignificantNot Significant239Pu Activity (Ci) -8.17E-01 4.60E-01Not Significant Not Significant240Pu Activity (Ci) 2.77E+00 5.03E-02Not Significant Not Significant242Pu Activity (Ci) 2.71E+00 5.33E-02Not Significant Not Significant241Am Activity (Ci) -3.09E+00 3.65E-02Not SignificantSignificant90Sr Activity (Ci) N/A N/ANot SignificantNot Applicable137Cs Activity (Ci) N/A N/ANot SignificantNot ApplicableTRU Alpha Conc. (nCi/g) 4.93E-01 6.48E-01Not Significant Not SignificantN/A N/A #VALUE! Not Applicable232U Activity (Ci) N/A N/ANot SignificantNot Applicable237Np Activity (Ci) 4.15E+00 1.43E-02Not SignificantSignificantB-3ATTACHMENT B.3 REPLICATE TESTING DATA FOR CONTAINER RL0050614, GEA-AQuantity ofInterestOriginal MeasurementReplicate No. 1Replicate No. 2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 1.01E-05 2.69E-06 2.66E-010.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 5.05E-06 1.34E-06 2.65E-010.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 4.81E-02 1.94E-02 4.03E-011.20E-01 2.68E-02 2.23E-011.30E-01 2.80E-02 2.15E-01239Pu Activity (Ci) 1.60E+00 3.09E-01 1.93E-011.74E+00 3.36E-01 1.93E-011.66E+00 3.22E-01 1.94E-01240Pu Activity (Ci) 4.05E-01 8.16E-02 2.01E-014.43E-01 8.68E-02 1.96E-014.14E-01 8.11E-02 1.96E-01242Pu Activity (Ci) 4.44E-05 1.01E-05 2.27E-014.33E-05 9.64E-06 2.23E-013.96E-05 8.82E-06 2.23E-01241Am Activity (Ci) 3.82E-01 7.47E-02 1.96E-016.58E-01 1.28E-01 1.95E-015.97E-01 1.16E-01 1.94E-0190Sr Activity (Ci) 6.86E-07 1.41E-07 2.06E-011.81E-06 3.56E-07 1.97E-011.06E-06 2.09E-07 1.97E-01137Cs Activity (Ci) 6.23E-07 1.29E-07 2.07E-011.65E-06 3.24E-07 1.96E-019.65E-07 1.90E-07 1.97E-01TRU Alpha Conc. (nCi/g) 5.29E+04 7.15E+03 1.35E-016.43E+04 8.07E+03 1.26E-016.09E+04 7.68E+03 1.26E-01237Np Activity (Ci) 5.13E-06 1.01E-06 1.97E-014.67E-06 9.13E-07 1.96E-015.24E-06 1.03E-06 1.97E-01243Am Activity (Ci) 4.50E-05 1.27E-05 2.82E-010.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00Quantity ofInterestReplicate No. 3Replicate No. 4Replicate No. 5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 7.78E-02 1.91E-02 2.46E-011.34E-01 2.88E-02 2.15E-011.15E-01 2.52E-02 2.19E-01239Pu Activity (Ci) 1.68E+00 3.25E-01 1.93E-011.68E+00 3.25E-01 1.93E-011.68E+00 3.26E-01 1.94E-01240Pu Activity (Ci) 4.52E-01 8.83E-02 1.95E-013.88E-01 7.61E-02 1.96E-014.56E-01 8.92E-02 1.96E-01242Pu Activity (Ci) 4.25E-05 9.47E-06 2.23E-013.63E-05 8.09E-06 2.23E-014.35E-05 9.68E-06 2.23E-01241Am Activity (Ci) 6.06E-01 1.18E-01 1.95E-015.56E-01 1.08E-01 1.94E-016.21E-01 1.21E-01 1.95E-0190Sr Activity (Ci) 8.35E-07 1.65E-07 1.98E-017.06E-07 1.40E-07 1.98E-011.89E-07 3.87E-08 2.05E-01137Cs Activity (Ci) 7.59E-07 1.50E-07 1.98E-016.42E-07 1.27E-07 1.98E-011.72E-07 3.52E-08 2.05E-01TRU Alpha Conc. (nCi/g) 6.12E+04 7.77E+03 1.27E-015.99E+04 7.65E+03 1.28E-016.25E+04 7.82E+03 1.25E-01237Np Activity (Ci) 5.39E-06 1.06E-06 1.97E-014.70E-06 9.55E-07 2.03E-015.53E-06 1.08E-06 1.95E-01243Am Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00B-4ATTACHMENT B.4 REPLICATE TESTING RESULTS FOR, CONTAINER RL0050614, GEA-AQuantity ofInterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|



# χ2|)ReportedValueAbsoluteUncertainty233U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!234U Activity (Ci) 1.01E-05 2.69E-060.00E+00 0.00E+00 N/A0.00E+001.00E+00238U Activity (Ci) 5.05E-06 1.34E-060.00E+00 0.00E+00 N/A0.00E+001.00E+00238Pu Activity (Ci) 4.81E-02 1.94E-021.15E-01 2.23E-02 1.94E-015.30E+002.58E-01239Pu Activity (Ci) 1.60E+00 3.09E-011.69E+00 3.03E-02 1.80E-023.85E-021.00E+00240Pu Activity (Ci) 4.05E-01 8.16E-024.31E-01 2.89E-02 6.72E-025.03E-019.73E-01242Pu Activity (Ci) 4.44E-05 1.01E-054.10E-05 3.08E-06 7.49E-023.71E-019.85E-01241Am Activity (Ci) 3.82E-01 7.47E-026.08E-01 3.71E-02 6.10E-029.85E-019.12E-0190Sr Activity (Ci) 6.86E-07 1.41E-079.20E-07 5.91E-07 6.43E-017.04E+011.89E-14137Cs Activity (Ci) 6.23E-07 1.29E-078.38E-07 5.39E-07 6.44E-016.99E+012.35E-14TRU Alpha Conc. (nCi/g) 5.29E+04 7.15E+036.18E+04 1.70E+03 2.75E-022.25E-019.94E-01237Np Activity (Ci) 5.13E-06 1.01E-065.11E-06 3.98E-07 7.79E-026.21E-019.61E-01243Am Activity (Ci) 4.50E-05 1.27E-050.00E+00 0.00E+00 N/A0.00E+001.00E+00Quantity ofInterestTPr(x<|t|)χ2Testt Test233U Activity (Ci) N/A N/A #VALUE! Not Applicable234U Activity (Ci) N/A N/A Not Significant Not Applicable238U Activity (Ci) N/A N/A Not Significant Not Applicable238Pu Activity (Ci) -2.75E+00 5.14E-02 Not SignificantNot Significant239Pu Activity (Ci) -2.65E+00 5.71E-02Not Significant Not Significant240Pu Activity (Ci) -8.08E-01 4.64E-01Not Significant Not Significant242Pu Activity (Ci) 9.97E-01 3.75E-01Not Significant Not Significant241Am Activity (Ci) -5.56E+00 5.14E-03Not SignificantHighly Significant90Sr Activity (Ci) -3.61E-01 7.36E-01Highly SignificantNot Significant137Cs Activity (Ci) -3.63E-01 7.35E-01Highly SignificantNot SignificantTRU Alpha Conc. (nCi/g) -4.77E+00 8.86E-03Not SignificantHighly Significant237Np Activity (Ci) 5.51E-02 9.59E-01Not Significant Not Significant243Am Activity (Ci) N/A N/ANot SignificantNot ApplicableB-5ATTACHMENT B.5 REPLICATE TESTING DATA FOR CONTAINER RL0063005, GEA-AQuantity ofInterestOriginal MeasurementReplicate No. 1Replicate No. 2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 3.53E-02 7.64E-03 2.16E-013.51E-02 7.62E-03 2.17E-013.22E-02 7.09E-03 2.20E-01239Pu Activity (Ci) 1.38E-01 2.63E-02 1.91E-011.37E-01 2.62E-02 1.91E-011.37E-01 2.62E-02 1.91E-01240Pu Activity (Ci) 6.82E-02 1.36E-02 1.99E-016.33E-02 1.27E-02 2.01E-015.75E-02 1.15E-02 2.00E-01242Pu Activity (Ci) 1.61E-05 3.56E-06 2.21E-011.55E-05 3.42E-06 2.21E-011.36E-05 3.00E-06 2.21E-01241Am Activity (Ci) 1.03E-01 2.05E-02 1.99E-011.34E-01 2.61E-02 1.95E-011.19E-01 2.31E-02 1.94E-0190Sr Activity (Ci) 1.10E-07 3.19E-08 2.90E-010.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00137Cs Activity (Ci) 1.00E-07 2.90E-08 2.90E-010.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 9.09E+03 9.70E+02 1.07E-019.76E+03 1.05E+03 1.08E-019.12E+03 9.88E+02 1.08E-01152Eu Activity (Ci) 1.27E-07 3.92E-08 3.09E-010.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00237Np Activity (Ci) 1.08E-06 2.11E-07 1.95E-015.96E-07 1.23E-07 2.06E-017.35E-07 1.44E-07 1.96E-01232U Activity (Ci) 5.56E-08 1.95E-08 3.51E-010.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00Quantity ofInterestReplicate No. 3Replicate No. 4Replicate No. 5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 3.53E-02 7.52E-03 2.13E-013.88E-02 8.31E-03 2.14E-013.61E-02 7.61E-03 2.11E-01239Pu Activity (Ci) 1.37E-01 2.62E-02 1.91E-011.34E-01 2.55E-02 1.90E-011.33E-01 2.54E-02 1.91E-01240Pu Activity (Ci) 5.46E-02 1.09E-02 2.00E-016.70E-02 1.34E-02 2.00E-015.24E-02 1.05E-02 2.00E-01242Pu Activity (Ci) 1.41E-05 3.11E-06 2.21E-011.72E-05 3.87E-06 2.25E-011.40E-05 3.08E-06 2.20E-01241Am Activity (Ci) 1.19E-01 2.30E-02 1.93E-011.40E-01 2.72E-02 1.94E-011.14E-01 2.20E-02 1.93E-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 9.13E+03 9.84E+02 1.08E-011.00E+04 1.07E+03 1.07E-018.85E+03 9.51E+02 1.07E-010.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00152Eu Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00237Np Activity (Ci) 6.16E-07 1.29E-07 2.09E-017.58E-07 1.48E-07 1.95E-017.51E-07 1.54E-07 2.05E-01232U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00B-6ATTACHMENT B.6 REPLICATE TESTING RESULTS FOR CONTAINER RL0063005, GEA-AQuantity ofInterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|



# χ2|)ReportedValueAbsoluteUncertainty233U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!234U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!238U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!238Pu Activity (Ci) 3.53E-02 7.64E-033.55E-02 2.36E-03 6.66E-023.83E-019.84E-01239Pu Activity (Ci) 1.38E-01 2.63E-021.36E-01 1.95E-03 1.44E-022.20E-021.00E+00240Pu Activity (Ci) 6.82E-02 1.36E-025.90E-02 6.08E-03 1.03E-017.98E-019.39E-01242Pu Activity (Ci) 1.61E-05 3.56E-061.49E-05 1.48E-06 9.96E-026.93E-019.52E-01241Am Activity (Ci) 1.03E-01 2.05E-021.25E-01 1.12E-02 8.92E-021.19E+008.80E-0190Sr Activity (Ci) 1.10E-07 3.19E-080.00E+00 0.00E+00 N/A0.00E+001.00E+00137Cs Activity (Ci) 1.00E-07 2.90E-080.00E+00 0.00E+00 N/A0.00E+001.00E+00TRU Alpha Conc. (nCi/g) 9.09E+03 9.70E+029.37E+03 4.85E+02 5.17E-029.98E-019.10E-01152Eu Activity (Ci) 1.27E-07 3.92E-080.00E+00 0.00E+00 N/A0.00E+001.00E+00237Np Activity (Ci) 1.08E-06 2.11E-076.91E-07 7.85E-08 1.14E-015.54E-019.68E-01232U Activity (Ci) 5.56E-08 1.95E-080.00E+00 0.00E+00 N/A0.00E+001.00E+00Quantity ofInteresttPr(x<|t|)χ2Testt Test233U Activity (Ci) N/A N/A #VALUE! Not Applicable234U Activity (Ci) N/A N/A #VALUE! Not Applicable238U Activity (Ci) N/A N/A #VALUE! Not Applicable238Pu Activity (Ci) -7.73E-02 9.42E-01 Not SignificantNot Significant239Pu Activity (Ci) 1.12E+00 3.24E-01Not Significant Not Significant240Pu Activity (Ci) 1.39E+00 2.37E-01Not Significant Not Significant242Pu Activity (Ci) 7.51E-01 4.94E-01Not Significant Not Significant241Am Activity (Ci) -1.81E+00 1.44E-01Not Significant Not Significant90Sr Activity (Ci) N/A N/ANot SignificantNot Applicable137Cs Activity (Ci) N/A N/ANot SignificantNot ApplicableTRU Alpha Conc. (nCi/g) -5.31E-01 6.23E-01Not Significant Not Significant152Eu Activity (Ci) N/A N/ANot SignificantNot Applicable237Np Activity (Ci) 4.52E+00 1.07E-02Not SignificantSignificant232U Activity (Ci) N/A N/ANot SignificantNot ApplicableB-7ATTACHMENT B.7 REPLICATE TESTING DATA FOR CONTAINER RL0063034, GEA-BQuantity ofInterestOriginal MeasurementReplicate No. 1Replicate No. 2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 1.34E-02 4.88E-03 3.64E-011.54E-02 5.46E-03 3.55E-013.53E-03 3.35E-03 9.49E-01239Pu Activity (Ci) 1.94E-01 5.48E-02 2.82E-012.00E-01 5.66E-02 2.83E-011.95E-01 5.51E-02 2.83E-01240Pu Activity (Ci) 5.09E-02 1.48E-02 2.91E-014.07E-02 1.20E-02 2.95E-014.64E-02 1.37E-02 2.95E-01242Pu Activity (Ci) 4.05E-06 1.28E-06 3.16E-013.12E-06 1.00E-06 3.21E-013.55E-06 1.14E-06 3.21E-01241Am Activity (Ci) 3.43E-02 9.85E-03 2.87E-013.25E-02 9.35E-03 2.88E-013.05E-02 8.80E-03 2.89E-0190Sr Activity (Ci) 3.38E-08 1.31E-08 3.88E-010.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00137Cs Activity (Ci) 3.08E-08 1.20E-08 3.90E-010.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 4.86E+03 9.62E+02 1.98E-014.80E+03 9.79E+02 2.04E-014.57E+03 9.57E+02 2.09E-010.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00237Np Activity (Ci) 8.91E-08 3.57E-08 4.01E-010.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00Quantity ofInterestReplicate No. 3Replicate No. 4Replicate No. 5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 1.50E-02 5.51E-03 3.67E-011.06E-02 4.34E-03 4.09E-011.23E-02 4.58E-03 3.72E-01239Pu Activity (Ci) 1.98E-01 5.61E-02 2.83E-011.88E-01 5.32E-02 2.83E-011.88E-01 5.32E-02 2.83E-01240Pu Activity (Ci) 4.78E-02 1.41E-02 2.95E-014.49E-02 1.32E-02 2.94E-014.01E-02 1.18E-02 2.94E-01242Pu Activity (Ci) 3.79E-06 1.22E-06 3.22E-013.61E-06 1.16E-06 3.21E-013.21E-06 1.03E-06 3.21E-01241Am Activity (Ci) 3.40E-02 9.80E-03 2.88E-013.45E-02 9.93E-03 2.88E-013.21E-02 9.23E-03 2.88E-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 4.91E+03 9.80E+02 2.00E-014.62E+03 9.30E+02 2.01E-014.53E+03 9.22E+02 2.04E-010.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00237Np Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00B-8ATTACHMENT B.8 REPLICATE TESTING RESULTS FOR CONTAINER RL0063034, GEA-BQuantity ofInterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|



# χ2|)ReportedValueAbsoluteUncertainty233U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!234U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!238U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!238Pu Activity (Ci) 1.34E-02 4.88E-031.14E-02 4.80E-03 4.23E-013.88E+004.23E-01239Pu Activity (Ci) 1.94E-01 5.48E-021.94E-01 5.59E-03 2.88E-024.16E-021.00E+00240Pu Activity (Ci) 5.09E-02 1.48E-024.40E-02 3.43E-03 7.80E-022.15E-019.95E-01242Pu Activity (Ci) 4.05E-06 1.28E-063.46E-06 2.82E-07 8.15E-021.94E-019.96E-01241Am Activity (Ci) 3.43E-02 9.85E-033.27E-02 1.59E-03 4.87E-021.05E-019.99E-0190Sr Activity (Ci) 3.38E-08 1.31E-080.00E+00 0.00E+00 N/A0.00E+001.00E+00137Cs Activity (Ci) 3.08E-08 1.20E-080.00E+00 0.00E+00 N/A0.00E+001.00E+00TRU Alpha Conc. (nCi/g) 4.86E+03 9.62E+024.69E+03 1.62E+02 3.46E-021.14E-019.98E-010.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!237Np Activity (Ci) 8.91E-08 3.57E-080.00E+00 0.00E+00 N/A0.00E+001.00E+00Quantity ofInteresttPr(x<|t|)χ2Testt Test233U Activity (Ci) N/A N/A #VALUE! Not Applicable234U Activity (Ci) N/A N/A #VALUE! Not Applicable238U Activity (Ci) N/A N/A #VALUE! Not Applicable238Pu Activity (Ci) 3.86E-01 7.19E-01 Not SignificantNot Significant239Pu Activity (Ci) 3.27E-02 9.75E-01Not Significant Not Significant240Pu Activity (Ci) 1.84E+00 1.39E-01Not Significant Not Significant242Pu Activity (Ci) 1.92E+00 1.27E-01Not Significant Not Significant241Am Activity (Ci) 9.05E-01 4.17E-01Not Significant Not Significant90Sr Activity (Ci) N/A N/ANot SignificantNot Applicable137Cs Activity (Ci) N/A N/ANot SignificantNot ApplicableTRU Alpha Conc. (nCi/g) 9.79E-01 3.83E-01Not Significant Not SignificantN/A N/A #VALUE! Not ApplicableN/A N/A #VALUE! Not Applicable237Np Activity (Ci) N/A N/ANot SignificantNot ApplicableB-9ATTACHMENT B.9 REPLICATE TESTING DATA FOR CONTAINER RL0056338, GEA-BQuantity ofInterestOriginal MeasurementReplicate No. 1Replicate No. 2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 9.75E-03 3.25E-03 3.33E-017.46E-03 3.45E-03 4.62E-015.45E-03 2.77E-03 5.08E-01239Pu Activity (Ci) 1.13E-01 2.30E-02 2.04E-011.15E-01 2.33E-02 2.03E-011.11E-01 2.27E-02 2.05E-01240Pu Activity (Ci) 3.04E-02 6.80E-03 2.24E-012.89E-02 7.31E-03 2.53E-012.75E-02 6.24E-03 2.27E-01242Pu Activity (Ci) 2.72E-06 6.88E-07 2.53E-012.74E-06 8.23E-07 3.00E-012.60E-06 6.76E-07 2.60E-01241Am Activity (Ci) 4.56E-04 1.27E-04 2.79E-014.52E-04 1.26E-04 2.79E-014.56E-04 1.27E-04 2.79E-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 3.33E+03 5.24E+02 1.57E-013.28E+03 5.35E+02 1.63E-013.13E+03 5.13E+02 1.64E-01Quantity ofInterestReplicate No. 3Replicate No. 4Replicate No. 5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 4.69E-03 2.48E-03 5.29E-014.12E-03 2.67E-03 6.48E-012.44E-03 2.34E-03 9.59E-01239Pu Activity (Ci) 1.14E-01 2.32E-02 2.04E-011.11E-01 2.37E-02 2.14E-011.12E-01 2.27E-02 2.03E-01240Pu Activity (Ci) 2.99E-02 6.65E-03 2.22E-013.67E-02 8.44E-03 2.30E-012.70E-02 6.12E-03 2.27E-01242Pu Activity (Ci) 2.63E-06 6.65E-07 2.53E-013.24E-06 8.47E-07 2.61E-012.45E-06 6.33E-07 2.58E-01241Am Activity (Ci) 4.51E-04 1.26E-04 2.79E-014.49E-04 1.25E-04 2.78E-014.64E-04 1.30E-04 2.80E-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 3.23E+03 5.26E+02 1.63E-013.29E+03 5.48E+02 1.67E-013.06E+03 5.12E+02 1.67E-01B-10ATTACHMENT B.10 REPLICATE TESTING RESULTS FOR CONTAINER RL0056338, GEA-BQuantity ofInterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|



# χ2|)ReportedValueAbsoluteUncertainty233U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!234U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!238U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!238Pu Activity (Ci) 9.75E-03 3.25E-034.83E-03 1.84E-03 3.81E-011.28E+008.64E-01239Pu Activity (Ci) 1.13E-01 2.30E-021.13E-01 1.82E-03 1.61E-022.50E-021.00E+00240Pu Activity (Ci) 3.04E-02 6.80E-033.00E-02 3.92E-03 1.31E-011.33E+008.57E-01242Pu Activity (Ci) 2.72E-06 6.88E-072.73E-06 3.02E-07 1.11E-017.72E-019.42E-01241Am Activity (Ci) 4.56E-04 1.27E-044.54E-04 6.16E-06 1.36E-029.40E-031.00E+0090Sr Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!137Cs Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!TRU Alpha Conc. (nCi/g) 3.33E+03 5.24E+023.20E+03 9.98E+01 3.12E-021.45E-019.97E-01Quantity ofInteresttPr(x<|t|)χ2Testt Test233U Activity (Ci) N/A N/A #VALUE! Not Applicable234U Activity (Ci) N/A N/A #VALUE! Not Applicable238U Activity (Ci) N/A N/A #VALUE! Not Applicable238Pu Activity (Ci) 2.44E+00 7.12E-02 Not SignificantNot Significant239Pu Activity (Ci) 2.01E-01 8.51E-01Not Significant Not Significant240Pu Activity (Ci) 9.32E-02 9.30E-01Not Significant Not Significant242Pu Activity (Ci) -3.62E-02 9.73E-01Not Significant Not Significant241Am Activity (Ci) 2.52E-01 8.13E-01Not Significant Not Significant90Sr Activity (Ci) N/A N/A #VALUE! Not Applicable137Cs Activity (Ci) N/A N/A #VALUE! Not ApplicableTRU Alpha Conc. (nCi/g) 1.21E+00 2.94E-01Not Significant Not SignificantB-11ATTACHMENT B.11 REPLICATE TESTING DATA FOR CONTAINER RL062952, GEA-BQuantity ofInterestOriginal MeasurementReplicate No. 1Replicate No. 2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 3.77E-03 1.01E-03 2.68E-012.26E-03 3.03E-03 1.34E+001.57E-02 6.88E-03 4.38E-01239Pu Activity (Ci) 4.85E-02 1.11E-02 2.29E-013.91E-02 7.15E-03 1.83E-014.23E-02 7.70E-03 1.82E-01240Pu Activity (Ci) 1.14E-02 3.07E-03 2.69E-011.84E-02 4.98E-03 2.71E-011.63E-02 6.54E-03 4.01E-01242Pu Activity (Ci) 6.57E-07 1.76E-07 2.68E-012.19E-06 8.11E-07 3.70E-015.70E-06 1.92E-06 3.37E-01241Am Activity (Ci) 6.98E-04 2.03E-04 2.91E-017.01E-04 2.05E-04 2.92E-016.93E-04 2.02E-04 2.91E-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00137Cs Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00TRU Alpha Conc. (nCi/g) 2.15E+03 3.85E+02 1.79E-012.02E+03 3.09E+02 1.53E-012.51E+03 4.09E+02 1.63E-01Quantity ofInterestReplicate No. 3Replicate No. 4Replicate No. 5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00234U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238U Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+00238Pu Activity (Ci) 8.11E-03 4.43E-03 5.46E-013.12E-03 3.21E-03 1.03E+001.33E-02 7.34E-03 5.52E-01239Pu Activity (Ci) 4.50E-02 8.25E-03 1.83E-014.07E-02 7.31E-03 1.80E-014.07E-02 7.45E-03 1.83E-01240Pu Activity (Ci) 2.38E-02 6.85E-03 2.88E-011.92E-02 5.20E-03 2.71E-011.56E-02 6.84E-03 4.38E-01242Pu Activity (Ci) 4.25E-06 1.39E-06 3.27E-012.67E-06 9.38E-07 3.51E-015.21E-06 1.93E-06 3.70E-01241Am Activity (Ci) 7.09E-04 2.08E-04 2.93E-016.96E-04 2.02E-04 2.90E-017.19E-04 2.11E-04 2.93E-0190Sr Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A N/A137Cs Activity (Ci) 0.00E+00 N/A 0.00E+000.00E+00 N/A 0.00E+000.00E+00 N/A N/ATRU Alpha Conc. (nCi/g) 2.59E+03 3.88E+02 1.50E-012.13E+03 3.19E+02 1.50E-012.35E+03 4.18E+02 1.78E-01B-12ATTACHMENT B.12 REPLICATE TESTING RESULTS FOR CONTAINER RL062952, GEA-BQuantity ofInterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|



# χ2|)ReportedValueAbsoluteUncertainty233U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!234U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!238U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!238Pu Activity (Ci) 3.77E-03 1.01E-038.50E-03 5.98E-03 7.03E-011.40E+022.69E-29239Pu Activity (Ci) 4.85E-02 1.11E-024.16E-02 2.23E-03 5.37E-021.62E-019.97E-01240Pu Activity (Ci) 1.14E-02 3.07E-031.87E-02 3.23E-03 1.73E-014.43E+003.51E-01242Pu Activity (Ci) 6.57E-07 1.76E-074.00E-06 1.54E-06 3.84E-013.05E+027.24E-65241Am Activity (Ci) 6.98E-04 2.03E-047.04E-04 1.05E-05 1.50E-021.08E-021.00E+0090Sr Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!137Cs Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE!#VALUE!TRU Alpha Conc. (nCi/g) 2.15E+03 3.85E+022.32E+03 2.43E+02 1.05E-011.59E+008.10E-01Quantity ofInteresttPr(x<|t|)χ2Testt Test233U Activity (Ci) N/A N/A #VALUE! Not Applicable234U Activity (Ci) N/A N/A #VALUE! Not Applicable238U Activity (Ci) N/A N/A #VALUE! Not Applicable238Pu Activity (Ci) -7.22E-01 5.10E-01HighlySignificant Not Significant239Pu Activity (Ci) 2.84E+00 4.69E-02Not SignificantSignificant240Pu Activity (Ci) -2.05E+00 1.09E-01Not Significant Not Significant242Pu Activity (Ci) -1.99E+00 1.18E-01HighlySignificantNot Significant241Am Activity (Ci) -4.86E-01 6.53E-01Not Significant Not Significant90Sr Activity (Ci) N/A N/A #VALUE! Not Applicable137Cs Activity (Ci) N/A N/A #VALUE! Not ApplicableTRU Alpha Conc. (nCi/g) -6.39E-01 5.58E-01Not Significant Not Significant

# C-1 

# ATTACHMENT C.1

EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. HANFO RD-CCP-CH-RTR-10-001CR,

FINAL

Inspection No. EPA-Hanford-CCP-CH-04.10-8 Issue Number: Hanford-CCP-CH-RTR-10-001CR

Date: April 27, 2010

Inspector: Dorothy E. Gill

Attachments? YES NO Sample Size: 1

Population size (if known): Unknown

Description of Issue: The RTR operator used a “Measurement Conversion Chart” to calculate the volume

of liquid identified during RTR examinations and ma de process decisions based on the result. This char t is

not a controlled document and the calculation used is incorrect. EPA is concerned regarding the origin and

prevalence of this practice.

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable

D. Discussed with: Dale Simpson, Jeremy Vesely

E. Additi onal Comments: None

F. Site Response Information:

Site Response Required? YES NO

Site Response Due Date: May 13, 2010

# C-2 

# ATTACHMENT C.2

EPA INSPECTION ISSUE TRACKING FORM

, ISSUE NO. HANFORD-CCP-CH-WDS-10-002CR,

FINAL

Inspection No. EPA-Hanford-CCP-CH-04.10-8 Issue Number: Hanford-CCP-CH-WDS-10-002CR

Date: April 28, 2010

Inspector: Dorothy E. Gill

Attachments? YES NO Sample Size: 1

Population size (if known): 1

D escription of Issue: CCP training procedure CCP-QP-002, Revision 27, S ection [C.3] requires Waste

Certification Officials (WCOs) to demonstrate profi ciency in WWIS as part of training. However, WDS is

not specifically identified in the training procedu re although this is the only User’s Manual listed i n the

reference section of CCP-TP-030. The Hanford-CCP Pr oject Manager indicated that the procedure(s)

associated with data entry are being revised at thi s time.

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable

D. Discussed with: Mike Ramirez, Larry Porter

E. Additional Comments: None

F. Site Response Information:

Site Response Required? YES NO

Site Response Due Date: May 14, 2010

# C-3 

# ATTACHMENT C.3

EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. HANFO RD-CCP-CH-NDA-10-003CR,

FINAL

Inspection No. EPA-HANFORD-CCP-CH04.10-8 Issue Number: HANFORD-CCP-NDA-10-003CR

Date: April 28, 2010

Inspector: P. Kelly

Attachments? YES NO Sample Size: Three GEA-A BDRs

Population size (if known): Three GEA-A BDRs

Description of Issue: All of the Batch Data Reports (BDRs) for GEA-A con tained control limits for the

transmission 239 

# Pu mass daily standard that were incorrect. The con trol limits had been recalculated on

March 10, 2010 but the control limits stated in the BDRs were different from what was documented in th e

calibration verification report. There is no concer n regarding the technical adequacy of the performan ce

check data, this concern is focused on the records that document the performance checks.

Additionally, the GEA-A log book did not contain an y entry regarding the incorporation of the new limi ts.

B. Regulatory Re ference: 40 CFR 194.24(c)

C. Site requirement(s):

D. Discussed with: J. Harvill, E. Gulbransen, Bret Templeton

E. Additional Comments:

F. Site Response Information:

Site Response Required? YES NO

Site Response Due Date: May 13, 2010

# C-4 

# ATTACHMENT C.4

EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. HANFO RD-CCP-CH-AK-10-004CR,

FINAL

Inspection No. EPA-Hanford-CCP-CH-04.10-8 Issue Number: Hanford-CCP-CH-AK-10-004CR

Date: April 29, 2010

Inspector: C. Walker

Attachments? YES NO Sample Size: Waste Stream MPFPDD

Population size (if known): Entire Waste Stream

Description of Issue: The AK Summary requires revision to address techni cal issues and elements

identified during the inspection. These modificatio ns are required to ensure adequate representation o f the

waste stream and its radiological and physical char acteristics. The following must be addressed:

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

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

• In Section 4.6.1, modify the discussion pertaining to waste stream definition to include the lack

of ability to correlate drums to specific PFP proce sses. Also modify Section 5.3 to indicate

whether to-be-generated waste will be segregated up on generation or packaging.

• Clarify intent of last paragraph p.30 regarding plu tonium grades and defense waste.

• Add information to Section 5.4.2 pertaining to the 6%, 12%, and 23% 240 

# Pu isotopic

distributions as presented in AK Source Documents a nd the AK-NDA memo, including data that

support generation of these distributions at PFP as well as other pertinent historical data.

• Remove first sentence from the first paragraph in S ection 4.5 regarding intent to segregate waste

during packaging or repackaging, as it contradicts later statements.

• Verify number of HEHF (Emergency Decontamination Fa cility) drums and how they are

included in the PFP drum population.

• Add the total volume (cubic meters) of waste in inv entory.

• In the final paragraph of Section 5.4.2, add the se cond predominant radionuclide by activity, to

be consistent with the previous portion of the sent ence that identifies the two predominant

radionuclides by mass.

Revise the AK Summary as appropriate to address the above; amendment of existing freeze file

modification is acceptable.

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s):

D. Discussed with: S. Schafer, S. Nance

E. Additional Comments:

F. Site Response Information:

Site Response Required? YES NO

Site Response Due Date: May 13, 2010

# C-5 

# ATTACHMENT C.5

EPA INSPECTION ISSUE TRACKING FORM

, ISSUE NO. HANFORD-CCP-CH-VE-10-005F,

FINAL

Inspection No. EPA-Hanford-CCP-CH-04.10-8 Issue Number: Hanford-CCP-CH-VE-10-005F

Date: April 28, 2010

Inspector: Dorothy E. Gill

Attachments? YES NO Sample Size: 1

Population size (if known): 1

Description of Issue: The VE personnel interviewed did not have any kno wledge or understanding of EPA

regulation(s) as required by CCP-PO-002, Revision 2 2, Appendix 10, Section 10.2. This NDE issue was

previously identified by EPA at both ORNL-CCP and S RS-CCP. EPA requires that VE operators be trained

to Federal Regulations (CFR Part 194.24) before the first CH TRU waste shipment is scheduled from

Hanford-CCP.

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable

D. Discussed with: Deborah Zenter, Larry Porter

E. Additional Comments: None

F. Site Response Information:

Site Response Required? YES NO

Site Response Due Date: See Description of Issue section above

# C-6 

# ATTACHMENT C.6

EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. HANFO RD-CCP-CH-VE-10-006CR,

FINAL

Inspection No. EPA-Hanford-CCP-CH-04.10-8 Issue Number: Hanford-CCP-CH-VE-10-006CR

Date: April 28, 2010

Inspector: Dorothy E. Gill

Attachments? YES NO Sample Size: 1

Population size (if known): 1

Description of Issue: The VEE appointment letter was dated March 2010 al though Hanford-CCP has been

performing VE at Hanford since the summer of 2009.

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable

D. Discussed with: Deborah Zenter, Larry Porter

E. Additional Comments: None

F. Site Response Information:

Site Response Required? YES NO

Site Response Due Date: May 14, 2010

# D-1 

# ATTACHMENT D

ACCEPTABLE KNOWLEDGE SOURCE DOCUMENTS REVIEWED

Hanford-CCP CH Baseline Reference List

AKE Qualification Card for Steve Schafer, 2003 thro ugh March 22, 2010.

AKE Qualification Card for Sheri Nance, 2004 throug h March 22, 2010.

CCP-AK-RL-101, Central Characterization Project Acc eptable Knowledge Summary Report For

Hanford Plutonium Finishing Plant (PFP) Contact-Han dled Transuranic Debris Waste From

Decontamination and Decommission, Waste Stream: MPF PDD, Revision 1, January 15, 2010.

CCP-AK-RL-101 Central Characterization Project Acce ptable Knowledge Summary Report For

Hanford Plutonium Finishing Plant (PFP) Contact-Han dled Transuranic Debris Waste, Waste

Stream: MPFPDD, Revision 2 March 30, 2010.

CCP-AK-RL-101, from Sheri Nance to CCP Central Reco rds, MPFPDD NDA Memo,

Evaluation of the Radiological Characterization of Hanford Site Waste Stream MPFPDD,

Revision 2, March 17, 2010.

CCP-AK-RL-101, from Mark Doherty to CCP Central Rec ords, MPFPDD NDA Memo,

Evaluation of the Radiological Characterization of Hanford Site Waste Stream MPFPDD,

Revision 3, April 7, 2010.

CCP AK Tracking Spread Sheet, Waste Stream MPFPDD, dated April 27, 2010.

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

CCP-PO-003, CCP Transuranic Authorized Methods for Payload Control.

CCP-TP-005, Revision 18, CCP Acceptable Knowledge D ocumentation, Effective date

November 15, 2006; and example Attachments 1, 4, 5, 6, 7, 8, 10, provided April 27, 2010.

CCP-TP-113, CCP Standard Contact Handled Waste Visu al Examination, Carlsbad, New

Mexico, Washington TRU Solutions, LLC.

C013 Interview of Michael Wesselman by Richard Clin ton concerning Sr-90/Cs-137, Ratio

Determination. R. Clinton, March 28, 2002.

C014 E-mail from Bisping to Rollosson re: Heat-Seal ed Bag Question and Clarification, S.W.

Bisping, July 25, 2002.

C018 Email Response from Elizabeth Curfman to Richa rd Clinton regarding Inquiry from

Caroline Sutter concerning PFP Laboratory History, E. Curfman, January 10, 2000.

# D-2



# C019 Record of Communication for Interview of Ted V enetz Regarding Plutonium Finishing

Plant Wastes, P.H. Wicks, M.E. Lakes, and R.J. Swan , April 26, 2007.

C020 Memo to Abramowski re: Determination of PCB C oncentration in Hydraulic Oils 65452-

82-159, S. G. Metcalf, August 25, 1982.

C021 Interview with Jose Aranda, R. Clinton, August 28, 1998.

C022 Interview with R. Gregory, R. Clinton, August 28, 1998.

C023 Questionnaire, G. Backlund.

C024 E-mail re: 224-T Wastes, J. D. Anderson, July 7, 2007.

C025 E-mail from Aranda to Clinton re: Question abo ut Heat Sealing, J. L. Aranda, August 7,

1996.

C026 PFP Soil Record of Communication with Jose Mej ia, M.E. Lakes and P.H. Wicks,

December 19, 2006.

C027 PFP Soil Record of Communication with J. Arand a, M.E. Lakes and P.H. Wicks,

December 6, 2006.

C028 E-Mail Response from Jose Aranda re: PFP Waste Question, Jose Aranda, September 13,

1999.

C029 E-mail from Fazzsari re: PFP Waste Question, D . Fazzari, September 13, 1999.

C030 Final Low-Pressure Reactor Fuel Processing Cam paign - PUREX Plant Contract AT (45-)-

1 20 ARH-2440, R.P. Corlew, April 7, 1972.

C031 Email from Karl Husted re: Two most prevalent isotopes in RLMPFPCD waste originating

in 242-Z, K.I. Husted, December 19, 2007.

C032 Memo from D. C. DeRosa, dated February 7, 2003 , Subject: NPFPD and

MPFPD Waste Streams M4T00-DCD-03-029, D.C. DeRosa F ebruary 7, 2003.

C034 Fax from Manthos to Hamilton re: Values used f or WIPP Waste Calculations at PFP

16300-AC90-041 E. J. Manthos, October 8, 1990.

C035 Email from Fred Riedel, F. Riedel, February 9, 2000.

C036 Record of Communication with Ted Venetz, R. E. Bolls, June 30, 2005.

C037 Memorandum from R. Clinton to P.J. Crane conce rning Transmittal of AK

Re-eval checklist for Waste Stream NPFPD 3T000-PJC- 01-043, R. Clinton, March 21, 2001.

# D-3



# C039 Interview of Gregg Krehl by Richard Clinton re garding Stanley Works Torpedo Levels, R.

Clinton, August 15, 2001.

C040 Interview of Customer Representative of Shell Chemical Company by Richard Clinton

regarding Shell Sol 140, R. Clinton, August 15, 200 1.

C041 Email from Richard Clinton to Gregg Krehel reg arding and inquiry of the Chemical Makeup of Fluid in Stanley Works Torpedo Levels, R. Cli nton, July 18, 2001.

C042 Disclosure of Information Concerning the Waste Designation of a Level Recorded in

TRU-WRP-01NCR-100 for Drum RHZ-220-A21300 3T000-PJC -01-158, R. Clinton.

C043 Record of Communication with D. A. Marsh, R. J . Swan.

C044 Letter from P. J. Crane, R. Clinton October 1, 1998.

C045 Interview of J. Estey, M. Watson, October 3, 2 000.

C046 Interview of J. A. Mortenson re: Heat Sealed P ackages, M. Watson, September 19, 2000.

C047 Interview of R. D. William re: PFP Heat Sealed Packages, M. Watson, September 14,

2000.

C048 Interview of R. E. Allenby re: PFP Heat Sealed Packages, M. Watson, September 14,

2000.

C049 Interview of R. Lehrschall re: Heat Sealed Pac kages, M. Watson, September 27, 2000.

C051 Sr-90 To Cs-137 Ratio for Appendix E of Hanfor d Site Transuranic Waste Certification

Plan for NDA, M4T00-PJC-02-076, R. Clinton, April 1 1, 2002.

C052 Disclosure of Miscertification Information and Visual Examination Selection for Fiscal

Year 2002, 3T000-PJC-01-156, R. Clinton, October 9, 2001.

C053 Email from Lincoln P. Djang to David C. DeRosa and Paul J. Crane Concerning U-234

and Sr-90 in Characterization Data from the Tank Fa rms Database, TWINS, L. Djang, February

27, 2002.

C054 Memorandum to L. F. Perkins re: TRU Site Proje ct Office Transmittal for Notification of

Possible Target Analyte Additions, 3T000-PJC-00-172 , P. J. Crane, September 8, 2000.

C055 Memorandum to L. F. Perkins re: TRU Site Proje ct Office Transmittal for Notification of

Possible Target Analyte Additions, 3T000-PJC-00-203 , P. J. Crane, October 26, 2000.

# D-4



# C056 Contract no. DE-AC06-96RL13200 – DOE Approval for Termination of Safeguards on

Specific Attractiveness D Mixed Oxide Scrap at the Plutonium Finishing Plant, 0205389, M. H.

Schlender, November 15, 2002.

C057 Contract No. DE-AC06-96RL13200 – DOE Approval for Termination of Safeguards on

Specific Attractiveness D Mixed Oxide Scrap at the PFP, 00301319A, K. A. Klein, March 20,

2003.

C058 Interview with Thurman Cooper, R. Clinton, Aug ust 28, 1998.

C059 Coffins from PFP – Mtg Notes, E. M Greager, Au gust 2, 2006.

C060 Record of Communication with Karl Husted 10/12 /07 re: Adding U-232 as a trace

radionuclide to MPUREXD and MPFPD AK, M.I. Rollosso n, October 12, 2007.

C062 E-Mail Response to Questionnaire sent by MS Wa tson to Several Former Workers at PFP

Regarding the Use of Heat Sealed Bags Generating He at Sealed Packages, R. Trainer, September

6, 2000.

C063 Internal Memo to E. T. Abramowski re: PCB Dete rmination Results in Contaminated

Hydraulic Oils, 65452-82-114, S. G. Metcalf, May 19 , 1982.

C071 Memorandum from N.M. Abdurrahman to P.J. Crane Concerning Calculations of Hanford

Sr-90 Isotopic Ratio Based on its Isotopic Ratio to Cs-137, 02-NMA-006, N.M. Abdurrahman,

August 14, 2002.

C074 PFP Debris Waste Designation, J. Bolles, March 31, 2004.

C076 Designation of TRU Drums Containing Heat Seale d Inner Package, L. J. Estey, May 7,

1990.

C077 Transmittal of AK Confirmation Checklist for 1 9 Waste Containers from Waste Stream

MPFPD, 3T000-PJC-01-090, R. Clinton, June 7, 2001.

C082 Internal Memo to L Dayley re: Results of Sand, Slag, and Crucible Testing for

Cementation Process, 15F00-96-068, S. A. Jones and J. L. Winstead, August 7, 1996.

C083 Debris Classification for Sand, Slag, and Cruc ible Waste, FH-0003830, E.S. Aromi and

P.J. Crane.

C084 Proposed Waste Designation of Carbon Tetrachlo ride Used at the Plutonium Finishing

Plant, 3T000-PJC-00-045, R. Clinton, April 10, 2000

.

C100 U-234 to U-235 and U-238 Ratios for Appendix E of Hanford Site Transuranic Waste

Certification Plan for NDA, M4T00-PJC-02-07,7 R. Cl inton, April 11, 2002.

# D-5



# C104 241-Z-361 Sludge Characterization Sampling and Analysis Plan HNF-4371, F.R.

Crawford, July 29, 1999.

C105 Communication to R. Clinton re: Occurrence of Cs-137 and K-40 in

Transuranic Waste, M. G. Cantaloub, February 20, 20 01.

C106 Internal memo to R. L. Granberg re: Solvent Wa ste Designations 80132-89-069, R. J.

Landon, May 15, 1989.

C107 Plutonium Purification and Fabrication of Tech nical Manual HW-29200.

C108 Slurping Vacuum System and Analytical Laborato ry Room 146 Repackaging Process, N.

Sequin, September 22, 1999.

C109 Disposal Request for CCL4 – TBP Waste – PFP-94 -000189 15540-094-RJM-029, E. J.

Manthos, February 23, 1994.

C110 Memorandum to P. J. Crane re: Analysis of TICs with Respect to Possible Addition to

Target Analyte List 8F000-SLF-00-23, S. L. Fitzgera ld, September 13, 2000.

C113 Internal Memo to E. G. Backlund re: Corrosivit y Test on Cemented Sand, Slag and

Crucible Items, 19F0096-06+2, M. L. Winstead , July 10, 1996.

C114 E-mail to M. I. Rollosson re: Use of the Term Soil in Past Practice, S. W. Bisping, June 28,

2006.

C115 WRP Strategy for Managing Chlorinated Biphenyl ’s Under TSCA NA, L. E. Strickling,

January 30, 2008.

C116 Proposal to Delay Assignment of TSCA Status to Retrievably Stored Low-Level Waste,

F9000-07-019, J. E. Hyatt, June 26, 2007.

C117 PFP Building Numbers NA D.R., Corriell, May 20 , 2009.

C200, Memorandum from Sheri Nance to CCP Records, W aste Material Parameter Analysis for

Waste Stream MPFPDD, March 15, 2010.

C205 Addendum to TSD Record, D. R. Corriell, May 20 , 2009.

C353 Memo to P. J. Crane re: Calculations of Hanfor d Strontium Isotopic Abundances Based on

Isotopic Ratios 02-NMA-005, 02-NMA- 006, 04-NMA-007 N. M. Abdurrahman July 14, 2004.

C364, Record of Interview, Waste Stream Numbers: MP FPDD, Interviewers: Steve Schafer and

Sheri Nance, Interviewee: Rhonda J (Roni) Swan, Mel vin E (Mel) Lakes, Subject: Feed to the

Building 232-Z Incinerator, May 4, 2010.

# D-6



# DOE/WIPP-02-3122, Transuranic Waste Acceptance Crit eria for the Waste Isolation Pilot Plant,

Carlsbad, New Mexico, U.S. Department of Energy.

Draft Waste Stream Profile Form, Hanford Waste Stre am MPFPDD, Prepared by CCP, March

10, 2010.

DR005 AK Source Document Discrepancy, R. Clinton, M ay 20, 1999.

DR006 NaI Discrepancy, R. Clinton, July 15, 1999.

DR010 Acceptable Knowledge source document Discrepa ncy Resolution waste stream

MPFPDD, TRU-Mixed heterogeneous debris resulting fr om production, maintenance, cleanout,

stabilization and decontamination and decommissioni ng (D&D) at the Hanford Plutonium

Finishing Plant (PFP), S. Schafer, provided April 2 7, 2010.

DR013 Acceptable Knowledge Source Document Discrepa ncy Resolution, Waste Stream

Number MPFPDD, TRU mixed heterogeneous debris resul ting from production, maintenance,

cleanout, stabilization, and decontamination and de commissioning (D&D) at the Hanford

Plutonium Finishing Plant (PFP).

Discrepancy Resolution for Incinerator Feed (Buildi ng 232-Z).

Engineering Data Transmittal, EDT 125236, to Distri bution from WRAP Project Engineer,

Preliminary Safety Evaluation, W-026 Waste Receivin g and Processing Facility Module 1,

December 9, 1994.

Freeze File Changes, prepared by Steve Schafer, Cha nges to CCP-AK-RL-101, R. 2 (and

attachments) identified and agreed to during the Ap ril 5 - 7, 2010 CBFO/NMED audit, provided

April 27, 2010.

Freeze File Modification of CCP-AK-RL-101Central Ch aracterization Project Acceptable

Knowledge Summary Report For Hanford Plutonium Fini shing Plant (PFP) Contact-Handled

Transuranic Debris Waste, Waste Stream: MPFPDD, Revision 3, MARKUPSN, Provide d May

13, 2010.

HNF-6489 Revision 1, Acceptable Knowledge (AK) Docu ment for Plutonium Finishing Plant

Mixed Debris Waste Stream MPFPD, September 15, 2006

.

HNF-36515 Revision 1 Acceptable Knowledge Document for the Richland Mixed Plutonium

Finishing Plant Comprehensive Debris Waste Stream, RLMPFPCD June 5, 2009.

HNF-15502, Plutonium Finishing Plant Deactivation a nd Decommissioning Technical Safety

Requirements, Administrative Control 5.20 and Speci fic Administrative Controls 5.24.

# D-7



# Inter-Office Correspondence, Washington TRU Solutio ns LLC, from J.E. Hoff to Distribution,

Transmittal and Closure of WTS Quality Assurance Au dit IO-06, Central Characterization

Project Quality Assurance Program, August 5, 2009.

Inter-Office Correspondence, March 31, 2010, from V . M. Waldram To: N. R. McCants, RE:

Acceptable Knowledge Accuracy Report, Waste Stream Number MPFPDD, Lot 1.

M024 Hanford Site Battery Book – “HEHF MSDS’s from Soft Reporting which Pertain to

Alkaline Batteries”, T. C. Hughes.

M025 Burial Records.

M026 MSDS for Dry Chemical Fire Extinguisher Powder (Ammonium Phosphate) 051938,

August 31, 2000.

M033 Waste Designation Worksheet for PFP-DES-07-00, P. Wicks.

M034 Waste Designation Worksheet for PFP-DES-08-00, P. Wicks.

M035 PFP Complex Effluent TRU Waste Stream Designat ion 216Z12DES01 to 04, 241Z8DES01-00, M. Watson.

M036 Waste Designation Worksheet for Designation # PFP-DES-03-00 PFP-DES-03-00, P.

Wicks, February 20, 2007.

M037 Waste Designation Worksheet for Designation # PFP-DES-04-00 PFP-DES-04-00, M.

Lakes February 5, 2007.

M038 Waste Designation Worksheet for Designation # PFP-DES-05-00 PFP-DES-05-00, P.

Wicks February 5, 2007.

M039 Solid Waste Storage/Disposal Records.

M040 RMIS Solid Waste Record List for NPFPD and MPF PD, May 30, 2001.

M041 Burial Records for RLMPFPCD, M Rollosson.

M042 Low Level/TRU Waste Located at CWC, S. Galstad

.

M043 MSDS Number 7653-2, SHELLSOL D60, Shell Chemic al Company.

M044 Solid Waste Burial Records – Addendum for 218- W-3A, July 23, 1980.

M046 Radioactive Waste Storage/Disposal Analysis Re cord 14-1D-8LM-0401, M. F. Pascual,

September 16, 1995.

M047 MPFPD Isotopes Data from SWITS, R. Clinton, Ju ne 7, 2001.

# D-8



# M048 Addendum to TSD Record (Canned Ash), J. Stamm.

M049 Addendum to TSD Record (SS&C), J. Stamm.

M050 Addendum to TSD Record.

M051 Reevaluation of RLMPDT.001 Change Notice # 3, M. I. Rollosson, February 22, 2007.

M052 Reevaluation MPFPD Organic Matrix to Other Ino rganic Matrix Material, M. I.

Rollosson.

M054 PFP PCB Debris Designation PFP-DES-02-00, M. L akes, October 11, 2006.

M056 Review of PFP Complex Effluents AK/Designation and Applicability of WAC 173-303-

090(7) and 40 CFR 261.23, J.P. Evans, April 3, 2008

.

M058 MSDS for Fryquel 200 Hydraulic Fluid 014029, A pril 24, 2007.

M062 Shell Chemical Company-Solvents Technical Supp ort-American Region-Fax On Demand

System, Shell Chemical Company, September 22, 2000.

M063 Fax to R. Clinton re: Waste Material to be Dis posed of, E. G. Backlund, February 17,

2000.

M102 Waste Information Data System General Summary Report for 232-Z Waste Incineration

Facility Site Code: 232-Z.

M105 Waste Container Projected Procurements for the Lifecycle of the PFP D&D Project, 2009.

M106 NDA Data for Containers from Hanford Waste Str eam RLMPDT.001, WWIS May 21,

2009.

M124 MSDS for RADPRO 061823A.

M280 TRU Waste Drum Container Contents Reports.

M305 TRU Waste Volume Inventory Estimate.

New Mexico, Washington TRU Solutions, LLC.DOE/TRU-2 008-3425, Annual Transuranic

Waste Inventory Report – 2008.

NCR-RL-0001; NCR-RL-600-617; NCR 1201-1203; Waste S tream MPFPDD, various dates.

P041 Past Practices Technical Characterization Stud y-300 Area- Hanford Site WHC-MR-0388,

M.S. Gerber, December 1992.

# D-9



# P051 Hanford Site Solid Waste Acceptance Criteria H NF-EP-0063, May 1, 2003.

P052 Hanford Site Transuranic Waste Management Prog ram Acceptable Knowledge

Documentation for Retrievably Stored Contact-Handle d Waste HNF-3461, Revision 7, R.

Clinton.

P070 Hanford Site TRU Certification Plan HNF-2600.

P071 History and Stabilization of the PFP Complex, Hanford Site HNF-EP-0924, M.S. Gerber,

March, 1997.

P072 Hanford Site TRU QAPjP, HNF-2599.

P075 CCP NCR and CAR logs for 2003 and 2004 DR 009, M. M. Anderson.

P098 Determining Whether Transuanic Waste is Defens e Waste, D. P. Detwiler.

P100 Secrecy Vs. Openness: Finding a Balance at the DOE, Proceedings of a Workshop, J.

Weeks November 29, 1999.

P101 Addendum to Isotopics per Can for Mark IA and Mark IV Fuel WHC88-00032, Add 1,

July 19, 1988.

P113 A History of Solid Waste Packaging at the Hanf ord Site WHC-SA-2772-FP, D. R. Duncal,

et al, February 1, 1995.

P114 PFP Final Safety Analysis Report WHC-SD-CP-SAR -021, J. E. Shapley.

P115 Process Flowsheet Document, Remote Mechanical C (RMC) Line, PFP PFD-Z-190-00002,

M. Stubbs, J. F. Durnil, June 10, 1993.

P116 Stabilization of Polycubes Engineering Study H istorical Use and Fabrication and

Treatment Schemes, WHC-SC-CP-TI-204, W.S. Lewis.

P117 Safety Assessment Document – Z Plant RMA Oxide line RHO-CD-454, D. L. Cahow, K.

O. Fein, G. L. Hanson, September 1, 1979.

P120 Z Plant RMA Oxide Line Campaign Process Contro l Plan RHO-CD-644, R. L. Walser, R.

E. Van der Cook.

P121 Z Plant RMA Oxide Line Flowsheet Addendum-Filt rate Concentration, RHO-CD-616,

ADD R.L. Walser and R.E. Van der Cook.

P122 Plutonium Finish Plant Environmental Operation s, Recan Plutonium Metal, ZO-200-504,

June 27, 1994.

# D-10



# P123 Criticality Prevention Specification, Incinera tor Burning Hood Characterization and

Disassembly Activities, CPS-Z-165-80625, May 8, 199 5.

P124 Criticality Prevention Specification, Glovebox Clean-up Operations, CPS-Z-165-80012,

May 8, 1995.

P125 Plutonium Finishing Plant Process Flow Documen t K-Sand, Slag and Crucible

Cementation Process Flow Document, PFD-Z-190-00004, G. R. Wittman, October 1, 1994.

P126 Thermal Stabilization Process Flowsheet Room 2 30A, 234-5 Building.

PFD-Z-190-00004, Revision A-0, G.R. Wittman, Octobe r 1994.

P127 Plant Operating Procedure, Oxidize Plutonium M etal in Glovebox HC-21-C and HA-21-I

ZO-160-033, Revision A-7, Rockwell Hanford Operatio ns.

P128 Stabilize Reactive Scrap (Operate HC-21C Muffl e Furnace) ZO-160-032, August 26, 1982.

P129 Criticality Prevention Specification: Plutoniu m Finishing Plant/Plutonium Metal

Production, CPS-Z-165-80350, January 9, 1990.

P130 Engineering Evaluation/Cost Analysis for the P lutonium Finishing Plant

Above-Grade Structures, DOE/RL-2004-05, Revision 1.

P131 PFP Historical Facts, DOE-0254.

P132 242-Z Waste Treatment Facility, D. C. Lini.

P133 Fabrication Oil Disposal, ARH-CD-239, D. A. Do dd.

P134 PFP Liquid Organic Disposal as 20 Year Retriev able TRU Waste, HNF-26402, M.W.

Gibson and L.H. Rodgers.

P135 PFP Impure Plutonium Oxide: Characterization o f Items with Greater

than 30 & less than 85 Weight Percent Plutonium, HN F-10638, D. C. Lini, L. H. Rodgers.

P137 Existing Data on the 216-Z Liquid Waste Sites, RHO-LD-114, K. W. Owens.

P138 Data Quality Objectives Process for Dispositio n of Sand, Slag, and Crucible Materials

Stored at the Plutonium Finishing Plant HNF-9734, R evision 2, A.M. Hopkins December, 2003.

P139 216-Z-9 Crib at the PFP, D. Lini, J. Teal, Feb ruary 27, 2004.

P140 242-Z Waste Treatment Facility, D.C. Lini, Dec ember 29, 2003.

P141 Handling of Pu Contaminated, Acid Soaked Rags in Hood, 5 ZO-160-031.

# D-11



# P143 Decommissioning of Division of Military Applic ation Equipment at Richland Operations

Office: Quarterly Report, ARH-R-215, 1Q.

P144 Decommissioning of Division of Military Applic ation Equipment at Richland

Operations Office: Quarterly Report, ARH-R-215, 2Q.

P145 Decommissioning of Division of Military Applic ation at Richland Operations Office:

Quarterly Report, ARH-R-215, 3Q.

P146 Decommissioning of Division of Military Applic ation (DMA) Equipment at

Hanford - Summary Report: June 1977 ARH-ST-141, M.N . Raile, June, 1977.

P147 Handle Pu Contaminated Acid Soaked Rags, ZO-16 0-030.

P148 Critical Mass Specification, Waste Treatment F acility, Buildings 241-Z and 242-Z,

HW-82632, R.J. Sloat.

P149 Process Design Basis for Fabrication Oil Stora ge and Sampling Facility, 234-5 Building,

HW-76399, D. Woodrich, February 13, 1963.

P150 Recovery of Plutonium from Fabrication Oil, HW -74350, R.S. Kingsley, August 1, 1962.

P151 The Plutonium Production Story at the Hanford Site: Processes and Facilities History

WHC-MR-0521, M. Gerber.

P152 Historical Report on the Retrievably Stored Di vision of Military Application Equipment at

the Hanford Site, WHC-IP-0791, J.A. Demiter, D.R. D uncan, and W.E. Meeuwsen, December

11, 1991.

P153 WST History of the Plutonium Production Facili ties at the Hanford Site Historic District

1943-1990, DOE/RL-97-1047, T.E. Marceau, D.W. Harve y, et al, June, 2002.

P154 Stabilize Material Handling, ZO-160-034, Revis ion B-0, D-1, February 22, 1995.

P155 Operating Specifications for Plutonium Finishi ng Plant: Thermal Stabilization Glovebox,

HC-21C OSD-Z-184-00006, M.W. Gibson, July 14, 1994.

P156 Z-Plant RMA Oxide Line Flowsheet, PFD-Z-190-00 01, S. Yarbo.

P157 PFP Process Control Engineering, PFD-Z-190-000 4, M. Gibson.

P158 Estimation and Characterization of D&D Solid W aste Expected from PFP, WHC-EP-0829,

Revision 0, J.S. Miller, J.A. Pottmeyer, T.J. Strat ton, and D.R. Duncan, January, 1995.

P159 Scrap Stabilization and Calcination Glovebox 4 , Room 41, 236-Z Building, CPS-Z-165-

82090, Revision C-0, PFP, May 4,1987.

# D-12



# P162 Glovebox MT-5: Dissolving and Leaching, CPS-Z- 165-80715, Revision A-3, PFP.

P163 Glovebox MT 6: Solution Clarification, CPS-Z-1 65-80716, Revision C-1, PFP.

P164 Access Glovebox: 2nd Floor East, CPS-Z-165-807 09.

P165 Access Glovebox: 1st Floor West, CPS-Z-165-807 08.

P166 Access Glovebox: 1st Floor East, CPS-Z-165-807 07.

P167 Process Cell CPS-165-80701, Revision A-1, PFP, January 12, 1995.

P168 Slag and Crucible Processing Gloveboxes, CPS-Z -165-80731, Revision A-0, PFP,

September 19, 1989.

P169 Operate Glovebox, 60 ZO-160-040, C. M. Kronval l, 1987.

P170 Handling of Plutonium Contaminated Acid and Wa ter Soaked Rags, ZO-170-005.

P171 Investigation of Chemical Explosion of an Ion Exchange Resin Column and Resulting

Americium Contamination of Personnel in the 242-Z B uilding.

P172 Sample Plutonium Bearing Powders for the Inter national Atomic Energy Agency (IAEA),

ZO-300-110, Revision A-2, PFP, August 21, 1995.

P173 Recan Plutonium-Bearing Recoverable Material, ZO-200-505, Revision J-2, E.P. Bonadie,

September 11, 1996.

P174 Handle PFP Reactive Material, ZO-170-014, Revi sion D-0, E-2 C, Barr and G.B.

Chronister 1993, 1996.

P175 Sorting Glove Box CPS-Z-165-80290, September 1 2, 1983.

P176 Dismantle HEPA Filters, ZO-170-823, July 7, 19 94.

P177 Repackage 55-Gallon Waste Drums, ZO-170-040, A pril 3, 1989.

P178 Seal Out, ZO-170-0299, G. Barr, et al.

P179 Handle and Package TRU Solid Waste in 55-Gallo n Drums, ZO-170-015, PFP.

P180 Solid Waste Repackaging and Disposal, ZL-100-3 23, September 18, 1998.

P181 PFP Analytical Laboratory Organic Waste Loadou t, ZL-100-326, January 14, 1998.

# D-13



# P182 The Isotopic Content and Specific Activity of Pile Produced Plutonium, HW-23487, G. J.

Alkire, H. R. Schmidt, E. M. Kinderman, February 25 , 1952.

P183 Methods and Models of the Hanford Internal Dos imetry Program, PNL-MA-860, E.H.

Carbaugh, January 31, 2003.

P184 Spent Fuel Isotopic Inventory Counted by Fuel Elements, UNI-1983, E. Carbaugh, January

31, 2003.

P185 26% Pu-240 Production Data, ARH-1164, R. C. Bl ack, et al, February 22, 1982.

P186 PFP Operations Overview (1949-2004): Contamina tion Events and Plutonium Isotope

Distributions of Legacy Holdup Material in Process Systems, HNF-22064, R. C. Hoyt, J. Teal.

P187 PFP Laboratory Safety Analysis Report SD-HS-SA R-011, G. L. Jones, March 1, 1984.

P188 Radiological History of the Plutonium Finishin g Plant (1954-1997), FSP-PFP-IP-003, A.

L. Ehlert, April 1, 1999.

P189 Plutonium Process Support Laboratories, D. Lin i, June 21, 2004.

P191 Engineering Evaluation/Cost Analysis for the P lutonium Finishing Plant Sub-Grade

Structures and Installations, HNF-30862, L. Oates, J. Teal, A.M. Hopkins, A.R. Sherwood, and

D.C. Lini, August 2006.

P192 FY 1988 Remote Mechanical C Line, Campaign Ble nd Plan WHC-88-245, J. F. Durnil, E.

V. Weiss, June 24, 1988.

P194 D&D Assessment for the Waste Incineration Faci lity (Building 232-Z) Hanford Site

Washington, DOE/RL-93-104, L.N. Dean, February 1994

.

P196 241-Z-361 Sludge Characterization Sampling and Analysis Plan HNF-4371, Revision 1,

F.R. Crawford, July 29, 1999.

P197 Clarification on PFP Lead Lined Gloves, C. Sim iele.

P198 T-Plant Operating Procedure Package Transurani c Waste, DO-100-039 C, Martin.

P199 Plutonium Finishing Plant Stabilization Operat ions Technical Procedure - Pipe-N-Go

Operations ZO-160-080, Revision C-17, May 3, 2006.

P200 Remote Mechanical C (RMC) Line Material Balanc e and Lead Summary – June 27, 1985

to December 11, 1985, RHO-SS-SR-183-85-1, D. L. Bou se, J. V. Matkevich, R. C. Martinson,

January 30, 1986.

# D-14



# P202 Nuclear Material Transfer and Control FSP-PFP- 5-8, Volume 1, Chapter 4.5, Revision 8,

PFP, June 8, 1998.

P203 Nuclear Material Control General Requirements FSP-PFP-5-8, Volume 2, Chapter 4.3,

Revision 5, PFP.

P204 Contaminated Process Equipment Removal for the D&D of 232-Z Contaminated Waste

Recovery Process Facility at the Plutonium Finishin g Plant, HNF-32534-FP, Revision 0, M.J.

Minette, et al., January, 2007.

P205 Organic Waste Loadout, ZL-100-326, J. M. Hieb, April 12, 1996.

P207 Tank 241-Z-361 Waste Characterization Data Qua lity Objective: Headspace and Tank

Structure, FDH-9855079R1, HNF- 2176, L. J. Olguin, A. M. Hopkins, D. L. Banning.

P208 Recent Site-Wide Transport Modeling Related to the Carbon Tetrachloride Plume at the

Hanford Site, M. P. Bergeron, C. R. Cole, September 1, 2004.

P209 Final Environmental Statement, Waste Managemen t Operations, Hanford Reservation,

Richland, Washington, ERDA-1538, J.L. Liverman.

P210 Z Plant Aggregate Area Management Study Techni cal Baseline Report, BHI-00175, D.H.

DeFord.

P211 216-Z-12 Transuranic Crib Characterization: Op erational History and Distribution of

Plutonium and Americium, RHO-ST-44, R. B. Kasper.

P212 Chemical and Radioactive Material Spill Clean Up, ZL-191-322.

P213 Seal Out-PPSL Glove Boxes, ZP-100-001, W. S. L ewis.

P215 RCRA/SUPERFUND/OUST Hotline Monthly Report Que stion October 1992, October 1,

1992.

P216 RCRA/SUPERFUND/OUST Hotline Monthly Report Que stion and Answers, May 1,

1991.

P218 Nuclear Material Control – Physical Inventory FSP-PFP-5-8, Chapter 4.4, May 19, 1988.

P219 Receiving, Handling, and Disposal of Routine L aboratory Samples, ZL-090-304.

P220 Seal In and Seal Out of Material from Glove Bo x by Plastic Bag or Sphincter, ZL161-302.

P221 Interim Plutonium Stabilization Engineering St udy, PNL-10507, P. J. Sevigny, et al,

August 1, 1995.

# D-15



# P222 Technical Basis for Characterization of Pluton ium for PFP, WHC-SD-CP-TI-190, R.

Crow, R. W. Szempruch.

P225 Listing Background Document, EPA.

P226 Hanford Tank Chemical and Radionuclide Invento ries: HDW Model LA-UR-96-3860,

S. Agnew.

P227 Hanford Defined Waste Models Limitations and I mprovements, HNF-3273, R. Harmsen,

et al.

P228 Criticality Safety, May 1, 1998.

P230 Process Flowsheet Document, Remote Mechanical C (RMC) Line, PFP PFD-Z-190-00002,

G. T. Tassoti.

P231 PRF Solvent Extraction Depletion Flowsheet-Hig h Uranium/High Fluoride Feed, PFD-Z180-00001, June 20, 1988.

P232 PRF Engineering Training Manual, RHO-MA-246, J . E. Ludowise.

P233 Hydrolysis and Dissolution Flowsheet, PFD-Z-18 0-00003, M. A. McNamar.

P234 Waste Minimization Plan PFP, WHC-WM-EV-023, E. G. Backlund.

P235 A-Button Line Terminal Process Clean Out, RHO- CD-982, J. F. Durnil, J. D. Ludowise.

P236 Tank 241-Z-361, Cores 263 and 264 Analytical R esults for the Final Report, R. A. Esch,

May 1, 2000.

P237 Final Report for the Hydraulic Oil Samples Rec eived from PFP, 234-5Z HA-23S, October

2007, G. P. Ritenour, November 29, 2007.

P238 Solid Waste Management History of the Hanford Site WHC-ED-0845, D. R. Duncan

March 1, 1995.

P239 PFP Final Safety Analysis Report, WHC-SD-CP-SA R-021, Revision 0, J.E. Shapely.

P244 Transmittal of the Waste Stream-Specific Docum ents for the AK Document

Management Program for PFP Non-Mixed and Mixed Debr is Waste Streams M4T00-DCD-02-

159, S. W. Bisping, June 12, 2003.

P245 Plutonium Finishing Plant Operations Overview (1949-2004): Contamination Events and

Plutonium Isotope Distributions of Legacy Holdup Ma terial in Process Systems, HNF-22064, R.

C. Hoyt, J. Teal.

# D-16



# P246 Transmittal of the Waste Stream-Specific Docum ent SS&C01, Revision 5, for the

Acceptable Knowledge Documentation Management Progr am for PFP Sand, Slag, and Crucible

Waste, M4T00-TRU-04-472, S.W. Bisping, June 17, 200 4.

P247 Deactivation and Cleanout of the 308 Fuels Lab oratory and the 232-Z Incinerator at the

Hanford Site, M. Gerber, October 22, 1999.

P250 Work Plan For Removal of Division of Military Application Equipment 234-5Z Building,

ARH-3079, H.E. Johnson, April 26, 1974.

P251 The History of the 200 Area Burial Ground Faci lities, WHC-EP-0912, J.D. Anderson

September 1996.

P252 Isotopic Composition and Specific Activity of Chalk River Plutonium, HW-53433, F. P.

Brauer.

P253 Nuclear Weapons Frequently Asked Questions, Ch apter 8.0, The First Nuclear Weapons,

C. Sublette, April 18, 2007.

P254 Room 27: Maintenance Glovebox, CPS-Z-165-80727 , Revision A-0, PFP.

P258 WRAP Module 1 Sampling Strategy and Waste Char acterization Alternatives Study WHCWD-W026-ES-013 C. L Bergeson, R. A. Hyre, et al, Se ptember 1, 1994.

P277 PFP Standard Practices, Seal In, ZO-170-301, J une 21, 1994.

P278 Experimental Isotopic Analysis of Point Exposu re Data in Hanford Production Reactor,

DUN-72443, RD H. Toffer and A.F. Kupinski, Septembe r 8, 1970.

P279 Contact Handled TRU Solid Waste Disposal OSD-Z -184-00020.

P403 Characterization of Past and Present Solid Was te Streams from the Plutonium-Uranium

Extraction Plant, WHC-EP-0646, H. Toffer, A. F. Kup inski, September 8, 1970.

P405 Characterization of Past and Present Solid Was te Streams from the Plutonium PFP, WHCEP-0621, D.R. Duncan and B.A. Mayancsik.

P406 PFP Plutonium-Uranium Oxide: Characterization of Items with <30 Weight

Percent Plutonium, HNF-10919, D. C. Lini, L. H. Rod gers, March 1, 2002.

P414 Retrieval Process Description, HNF-5597, Revis ion 3, March 31, 2004.

P415 TRU Waste Phase I Retrieval Plan HNF-4781, Rev ision 1, K. McDonald, September 26,

2000.

P416 Waste Receiving and Processing Facility Final Safety Analysis Report

# D-17



# HNF-SD-W026-SAR-002, R2, April 25, 2000.

P506 Load Standard Waste Box (SWB) Storage Containe rs with TRU Waste ZO-170-044,

Revision F, Change 26, PFP, August 25, 2004.

P507 Visual Examination Technique for PFP Debris Wa ste ZO-170-057, Revision C, Change

11, PFP, November 4, 2008.

P508 WIPP Procedures - TRU Waste Visual Examination WMP-400, Revision 12, March 24,

2009.

P509 Handle TRU/TRU Mixed Waste in 55-Gallon Drums ZO-170-015, Revision P, Change 3,

PFP, November 25, 2008.

P510 Package TRU/TRU Mixed Waste, ZP-170-0061, Apri l 28, 2008.

P511 PFP Debris Draft AK Report, HNF-36515.

P512 Procedure for Equipment Removal from the PRF W est Gallery Gloveboxes, 2Z-08-7986.

P513 RadPro Chemical Decontamination of Equipment/G loveboxes and Hoods Containing

Plutonium ZDD-1-002, Revision B, Change 2 PFP April 29, 2009.

P514 Technical Data: Plutonium Finishing Plant Chem ical Hazard Assessment HNF-SD-CP-TI219, G. Witman, E.Weiss, September 26, 1997.

P525 Waste Information Data System General Summary Report (216-Z Crib), July 21, 2005.

P976, Engineering Change Notice 602871, J.P. Joyce, Radioisotopic Characterization of

Retrievably Stored Transuranic Waste Containers at the Hanford site, WHC-SD-WM-TI-517,

Revision 0, November 12, 1993.

P1038 Drum Waste Processing DO-100-058, Revision B, Change 26, June 17, 2009.

P1039 Overpacked Drum Waste Processing, DO-100-061, Revision A, Change 20, June 17,

2009.

P1040 TRU Entry Glovebox Operation, WRP1-OP-0724, D ecember 22, 2008.

P1079 Hanford Facility Fact Sheet, 234-5Z.

P1081 Safety Evaluation Report for Stabilization Pr ocessing of High Chloride Bearing

Plutonium Materials at the Plutonium Finishing Plan t, 03-ABD-0071, A.J. Colburn, P.J. Garcia,

S.J. Olinger, April 14, 2003.

P1082 CHPRC Monthly Performance Report RL-0011, D. Del Vecchio, September 2009.

# D-18



# P1084, R.L. Gunnick, Use of Isotope Correlation Tec hniques to Determine 242 

# Pu Abundance,

1980.

P1088 TRU Sorting Glovebox, WRP1-OP-0725, June 24, 2009.

P1089 TRU Loadout Glovebox Operation, WRP1-OP-0726, July 2, 2009.

U201 Hanford Site Plutonium Finishing Plant Residue s/Legacy Holdup.

U202 Waste Certification Summary – Radionuclides Re ported in SWITS.

URS, Washington TRU Solutions LLC, March 3, 2010, t o Ms. A. Holland, Quality Assurance

Manager, Subject: Semiannual report on the central characterization project quality assurance

program: second half of calendar year 2009 (July 1, 2009 through December 31, 2009).

Waste Stream Profile Form for Hanford Site, Waste S tream Profile Form Number

RLMPDT.001, approved, misdated.

# E-1 ATTACHMENT E

PUBLIC COMMENT ON THE PROPOSED APPROVAL

Public comments received in response to the propose d approval are available in the EPA Air

Docket at EPA-HQ-OAR-2010-0711. On October 6, 2010, EPA received comments from one

Commenter (see Attachment E-1) on the issue of esti mating the liquid contents of a drum using

mathematical equation(s), EPA Issue Hanford-CCP-CH- RTR-10-001CR 001. On October 19,

2010, EPA requested an additional explanation speci fic to this issue, which the Commenter

provided on October 25, 2010 (see Attachment E-1) a nd additional documents listed below:

1) PDF file documenting an 80-page PowerPoint cours e presentation on Real-Time

Radiography Training – Liquid Volume Calculation.

(RTR_TRAINING_Liquids_4-09_(3)_.pdf)

2) PDF file documenting a 63-page PowerPoint cours e presentation on Real-Time

Radiography Training – Determination of Residual Li quids.

(RTR_TRAINING_Liquids_Prohibited_Items_10-09_.pdf)

3) PDF file documenting the CCP Attendance Sheets f or: the RTR Training Summit

conducted April 27-30, 2009; the RTR Training Summi t conducted June 12 – 16, 2009;

and the RTR Training Summit — Part II conducted Jun e 8-10, 2009.

(RTR_Attendance_Sheets.pdf)

4) PDF file documenting the RTR Training Examinatio n.

(LANL_Volumes_Test_11-09.pdf)

# E-2 ATTACHMENT E-1

# E-3

# E-4