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

 

WASTE CHARACTERIZATION INSPECTION REPORT AND APPROVAL 

EPA BASELINE INSPECTION NO. EPA-Hanford-CCP-CH-04.10-8 

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) Checklist 

Attachment A.4 Visual Examination (VE) Checklist 

Attachment A.5 WIPP Waste Data System (WDS) Checklist 

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

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

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

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

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

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

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

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

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

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

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

Attachment B.12 Replicate Testing Results for Container 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 Form, Issue No. Hanford-CCP-CH-WDS-10-

002CR, Final 

Attachment C.3 EPA Inspection Issue Tracking Form, 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 Form, Issue No. Hanford-CCP-CH-VE-10-

005F, Final 

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

006CR, Final 

Attachment D Acceptable Knowledge Source Documents Reviewed 

Attachment E Public Comment on Proposed Baseline Approval 
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 Decontamination 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 Comprehensive 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 System 

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 Protection Agency’s (EPA or the Agency) approval of the 

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

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

54631-54634), proposing approval of the Contact-Handled (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 comment period to seek comment on the proposed 

approval. The comment period ended on October 25, 2010. EPA received initial and follow-up comments 

from a single Commenter1 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 necessary. 

This report discusses EPA’s baseline inspection results 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). This waste is and will be characterized using the HanfordCCP implemented CH TRU waste characterization processes consistent with the conditions and limitations

as described in this report. 

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

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 baseline inspection of 

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

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

technically adequate. 

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

specified in Condition 3 of the Agency’s certification of the WIPP’s compliance with disposal regulations 

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. In addition, since then, the CCP has been disposing of 

CH-TRU waste at WIPP characterized by the now terminated Hanford program2

. EPA had not previously 

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

wastes. 

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

characterization programs for CH TRU debris waste to be disposed of at WIPP. During the inspection, the 

Agency examined the following activities: 

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

• Two nondestructive assay (NDA) systems, the Canberra 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-stored TRU debris waste (S5000) 

 

 

1

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

2

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

approval in mid-2008. 
8

• Visual Examination (VE) for CH retrievably-stored TRU debris waste (S5000) 

• WIPP Waste Data System (WDS) for CH retrievably-stored 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 evaluation of load management from the scope of this 

inspection [see Section 8.1(5)]. 

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

Finding and five concerns. Upon satisfactory resolution of EPA issues, EPA determined that the HanfordCCP waste characterization program for retrievably-stored CH TRU debris waste was technically adequate. 

EPA proposed for approval the Hanford-CCP CH TRU waste characterization program in the configuration 

observed during the baseline inspection and described 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 process3

 used for calculating liquids in container (a) is variable at different 

CCP-serviced sites, (b) is not necessarily a process 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 CH 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 Conversion Chart” to make it better suited to 

match operator’s skill level; 

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

to minimize subjectivity; and 

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

operator qualification, and test results prior to implementation. 

Unless these steps are taken, CBFO and CCP are prohibited 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 approved unit are sufficiently significant (such as 

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

implementation of such RTR-specific T2 change(s) prior 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 including the supporting material and observations EPA made at other CCPserviced CH TRU sites over the past six months. 

 
9

In addition, EPA finalizes the following elements of 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 TRU 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 baseline inspection according to Table 1, below. Reference 

to the specific section of this report where each T1 or T2 change is discussed is included in parentheses 

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

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

potential to impact the site’s waste characterization activities under 40 CFR 194.24 or the documentation 

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

safety, or the Resource Conservation and Recovery Act (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 of tiering). Upon approval, EPA will notify the public of the 

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

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 Processes 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 Changesa

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 changesb 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 equipmentc (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 to EPA upon the following: 

- Modificationc 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 method 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 to 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 report all T2 changes to EPA at the end of each fiscal quarter. Note: EPA 

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

b “Substantive changes” are changes with the potential to impact the site’s waste characterization activities or documentation 

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

c Modifications to approved equipment include all changes with the potential to affect NDA data relative to waste isolation and 

exclude minor changes, such as the addition of safety-related equipment. 
11

2.0 PURPOSE OF INSPECTIONS 

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

regulations at 40 CFR Part 191. In this certification, 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 disposal at the WIPP until the Agency has 

approved the processes for characterizing those waste streams for shipment using the process set 

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

EPA with information on AK4 for waste streams proposed for disposal at the WIPP, 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 limits 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 the 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 wastes and comply with the regulatory 

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

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

properly implemented. Specifically, the EPA inspection team verifies compliance with 

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

Any compliance application shall: . . . Provide information which demonstrates 

that a system of controls has been and will continue 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 of 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 inspection is to assess whether DOE sites that 

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

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

not exceed the approved limits. Before approving the 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 knowledge” 

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 prior to or separate from the waste certification process authorized by 

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

5

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

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 proposed for disposal in the disposal system.” 
12

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

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

compliance,6

 and (2) confirm that the waste in any given container has been properly identified 

as belonging to the group of approved waste streams. 

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

changes to the site’s approved waste characterization 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 inspections to verify that the site continues to use 

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

compliance with all 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 waste characterization program changes or 

modifications must undergo further EPA inspection or 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 requirements and the Agency’s approval prior to 

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

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

dispose of materials at its own risk while EPA considers 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 change 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 notice 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 during the inspection that are approved 

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

• Identifies all relevant system limitations and/or conditions 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 of waste streams determine which processes can adequately 

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

should select a suitable NDA technique to ensure adequate measurements. Radiography and VE help to confirm and 

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

confirmed, the assay techniques then quantify selected radionuclides in the waste. In some cases, a TRU waste 

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

limits on the applicability of proposed WC processes govern EPA’s inspection scope.
13

• Describes any tests or demonstrations completed during 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 attached 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 waste characterization program will be 

conveyed to DOE separately by letter. More information 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-Hanford-CCP-CH-04.10-8 was the evaluation 

of the technical adequacy of the waste characterization 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 (241Am, 137Cs, 

238Pu, 239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U, and 238U) using a combination of AK and NDA 

systems 

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

debris waste 

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

Specifically, these systems consisted of the following 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 certify waste characterization data per se; that 

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

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

personnel and equipment to characterize contents of CH retrievably-stored TRU waste 
14

containers. The evaluation consisted of interviewing personnel, observing equipment operations 

that follow site procedures, and inspecting records related to each of the waste characterization 

processes within the inspection’s scope. 

An important aspect of this evaluation was the objective evidence documenting the effectiveness 

of the waste characterization processes. Objective evidence typically takes the form of batch data 

reports (BDRs), radioassay data sheets, AK accuracy reports, RTR tapes, and WDS printouts for 

specific TRU containers. During this inspection, EPA selected samples of each of these items, 

based on the number and variety of items each waste characterization process produced, 

consistent with standard inspection techniques. Based on the evaluation of the waste 

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

the technical adequacy of the waste characterization 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 waste characterization and/or isolation within the 

repository. The two main categories relevant to waste 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 or may not have a negative effect on 

compliance and, depending on the magnitude of the issue, 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 accepts 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 characterization 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 Technical 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 Zeitoun 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 contacted represented only a sample of the CH 

TRU waste characterization staff, and they are listed in Table 3, along with their affiliations 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 provided a list of TRU waste characterization 

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

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

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

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

characterizing and certifying TRU waste were qualified and had received adequate training to 

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

and training records of any new individuals identified 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 area 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 production reactors created approximately 75% of the 
16

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

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

environmental restoration and nuclear material stabilization and stewardship and Hanford is also 

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

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

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

characterization program is the subject of this baseline inspection. 

7.2 Inspection Process Overview 

EPA Baseline Inspection No. EPA-Hanford-CCP-CH-04.10-8 took place April 27-29, 2010. 

EPA reviewed additional documents that were provided 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-CCP waste characterization program 

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

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

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

related to waste characterization activities at Hanford-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 qualifications of waste characterization 

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

and demonstrations, and recording the results on checklists 

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

providing completed forms to CBFO and site personnel 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 Hanford-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, and the WDS. 
17

8.1 Acceptable Knowledge (AK) 

EPA examined the AK process and associated information 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 identifies technical elements and objective 

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

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

• Defense waste status 

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

• 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 streams including AK information 

assembly, compilation, confirmation, and AK discrepancy 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 accepted a variety of documents related to 

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

reviewed or accepted as objective evidence is presented 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 waste stream that was provided to EPA for 

inspection, the Mixed Plutonium Finishing Plan Decontamination and Decommissioning 

(MPFPDD) waste stream representative of Summary Category 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 specific to this CH TRU retrievably-stored and 

newly-generated waste stream in the following areas. 

 

(1) The definition of waste stream was evaluated and found 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 stream was evaluated based on this definition. 

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

production, maintenance, cleanout, stabilization, decontamination, and decommissioning 

activities at PFP. The waste stream may contain a number 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 (MPFPD) waste stream, and Mixed 

Plutonium Finishing Plant Comprehensive Debris (RLMPFPCD) 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 containers remain to be characterized which 

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

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

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

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

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

specifically the Waste Treatment and Americium Facility (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 subsequent site inspections, but never 

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

Hanford-defined and Hanford-CCP-defined waste streams and if the new MPFPDD waste stream 

has been adequately defined. 
19

Hanford-CCP representatives and the AKSR indicate that the PFP has been in operation since 

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

time operations began shifting to supporting commercial 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, waste containers in inventory and to be shipped 

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

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

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

cubic meters (m3) of TRU waste debris will be generated at PFP during D&D activities that 

began in 2009. 

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

heterogeneous debris resulting from production, maintenance, cleanout, stabilization, and 

decontamination and decommissioning (D&D) at PFP. The 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 Facility and Americium Facility 

• 291-Z Ventilation/Exhaust Air Stack 

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

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

Z-1A Crib/Tile Field, Ancillary Facilities, 216-Z-12 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 units in 2736-Zb Areas from the waste stream, 

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

Subsequently, EPA examined the information presented in the AK Summary and supporting 

references and supplemental documentation, and questioned the inclusion of the incinerator 

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

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

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

explanation. 

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

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

determined that material movement and subsequent waste generation occurred through each of 

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

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

waste stream are discussed in Items (2) and (3), below. 
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 processes should have been singled out as separate 

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

impossible to differentiate “where” in the PFP complex 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. Additionally, 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 designation is appropriate. See Items (2) and (3) 

below for radiological and physical waste characterization analyses that support this 

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

solids and sludge (S3000) and soil and gravel (S4000) 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 characteristics 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 conversion of Pu nitrate to metal and 

casting/machining operations. Plutonium recovery from 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 or managed at the PFP. The isotopic distribution 

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

 

Radiological Characteristics of the MPFPDD Waste Stream 

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

stream already emplaced in WIPP to determine the general 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 well as 1,328 certified drums in the WWIS 

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

239Pu and 238U are the most prevalent isotopes by mass. This waste stream also contains isotopes 

of uranium, americium, neptunium, cesium, and strontium. 
21

Table 4. Waste Stream MPFPD WWIS Reported Radionuclides 

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 Trace1 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 general isotopic distribution of key isotopes 

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

Table 5. Plutonium and Uranium Isotopic Distributions 

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 plutonium (WG Pu) produced at Hanford 

exhibited a 240Pu weight percentage between approximately 0.9 - 7%, and fuel material 

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

241Am is present due to decay of 241Pu, but AK data show that 241Am may also be present in 

waste generated from the Waste Treatment complex (242-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% 

235U). Impurities that may be present include 232Th, 249Cf, and trace amounts of other 

radionuclides. 

Isotopic Distributions for the MPFPDD Waste Stream 

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

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

Hanford characterization program used these distributions when measurement values could not 

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

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

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

determining the three most frequent percent plutonium isotopic distributions processed at the 

235-5Z complex, based on the percent of 240Pu identified on the drum records. The following 

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

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

Table 6. Default 6 Percent Pu-240 20-Year Aged Mass 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 Mass 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 Mass 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 evaluate the general radiological composition 

of the portion of the waste stream that is currently 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 that the values obtained from the WWIS 

were almost entirely derived (approximately 90%) from 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, Hanford-CCP AKEs developed the isotopic 

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

following weight percent distributions for MPFPD wastes in the WWIS were obtained: 241Am – 

0.86%; 238Pu – 0.05%; 239Pu – 91.18%; 240Pu – 8.39%; 241Pu– 0.29%; 242Pu – 0.09%. These 

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

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

this analysis, the potential isotopic composition of 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 debris material represented by a host of 

activities including plutonium processing, waste treatment, incineration, and D&D activities. 

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

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

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

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

leaded aprons, leaded gloves, lead tape, lead chromate paint, lead seals, fluorescent light bulbs, 

scraps from maintenance activities, glass thermometers, various glass tubes, vials, beakers, 

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

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

liquids. 

As indicated in Item (1) above, this range of activities 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 physical composition of the waste stream is 

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

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

develop an accurate picture of the waste streams’ physical composition. 
24

The AKSR freeze file indicates that 5,856 containers 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 determine the physical composition of the waste 

stream, noting that this portion of the waste stream 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 WMC of S5400, Heterogeneous Debris, was 

applied to this waste stream. 

To estimate the WMPs for waste stream MPFPDD, Hanford-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 contents of the waste that are presented in 

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

metal as more D&D waste is included in the waste stream. 

Table 9. Waste Stream MPFPDD Waste Material Parameters 

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 identify the presence of prohibited items (i.e., 

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

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

a whole. 

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

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

CCP-TP-005, Revision 18 is Hanford-CCP’s AK procedure. 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 Maintenance 

EPA examined the AK document management process used to acquire all available AK 

references (C, D, DR, M, P, U) pertinent to the waste 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 elements 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. Hanford-CCP provided example DR forms as 

well as the container tracking spreadsheet for review. 

Several attachments support these activities: 

 

Attachment 1 – Acceptable Knowledge Documentation Checklists 

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 Parameters, Prohibited Items, and Packaging 

Attachment 7 – Radionuclides 

Attachment 8 – Waste Containers List 

Attachment 9 – Waste Characterization Data Cross-Reference 

Attachment 10 – Acceptable Knowledge Re-evaluation Checklist 

Attachment 11 – Acceptable Knowledge Source Document Discrepancy Resolution Form 

Attachment 12 – Form and Content Guide for AK Summary Reports 

Attachment 13 – CCP Waste Stream Characterization Checklist 

Attachment 14 – CCP Acceptable Knowledge Accuracy Report 

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 Source 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 demonstrated the ability to follow the AK 

procedure for the elements examined. Notification of 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 adequate. 

The AK Summary was examined to determine whether major 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 necessary to clarify the contents of the AKSR, 
26

Revision 2. EPA identified several concerns associated 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 to 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 segregated upon generation or 

packaging. 

• Clarify intent of last paragraph p. 30 regarding plutonium 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 and the AK-NDA memorandum, 

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

pertinent historical data. 

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

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

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

included in the PFP drum population. 

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

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

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

predominant radionuclides by mass. 

Resolution: Hanford-CCP provided a discrepancy resolution (DR013) documenting the 

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

material was processed through the incinerator facility. 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 through modification of the existing freeze file. 

Status of Concern: The response is adequate; EPA considers this issue 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 the 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 0063057 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 Records Storage Facility and Integrated 

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

Inventory Sheet, Waste Designation Worksheet, Inspection Sheet for Loaded/Sealed 

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

Certificate of Conformance 

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

SWITS Container Listing Report 

• TRU Electronic Data Management Tool (TRUEDMT) Database Print Outs 

• BDRs (NDA and RTR) 

• CCP Program Tracking System (PTS) printout – each container 

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

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

waste characterization. The Hanford-CCP AKE provided 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. Information examined included SWITS database 

information, TRUEDMT database, Onsite Radioactive Shipment 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 the 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 constituted much less than 50% of the drum by 

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

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

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

trace information for the container from the AK record 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 “defense” 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 contaminated with 

radionuclides generated from energy defense activities, including defense nuclear material 

processing and fabrication of plutonium for weapons, defense nuclear waste materials byproducts management, and defense research and development. 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 disposal 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 elements of which have not been separated by 

reprocessing. SNF may not include test specimens irradiated 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 NWPA as “the highly radioactive material 

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

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

in sufficient concentrations, and other highly radioactive material that the Commission, 

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

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

only unirradiated materials derived from testing and 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 completeness was evaluated and found to be 

adequate. 

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

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

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

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

revealed discrepancies with respect to the exact number 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 added 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 availability 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 adequate. 

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 inspection. 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 provided information to indicate that 

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

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

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

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

available to demonstrate that the AKEs have been appropriately trained to the most recent 

versions of these procedures. EPA will verify the paperwork 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 generated for this waste stream. Issues 

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

or materials obscure RTR examination of drum contents), 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 these 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 satisfactorily documents the NCR process. 

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

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

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

and 239Pu as the most predominant radionuclides by weight, but 239Pu and 240Pu were the most 

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

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

radionuclides within the AKSR would be warranted, but 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-005 Revision 18. Notification of the 

availability of all AK Accuracy Reports is a T2 change. (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 would 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 adequate. 

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 information, and must also include a description 

of the assay methods, and also requires that NDA issues (for both measured and calculated 
30

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

MPFPDD waste first describes the isotopic information 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 242Pu, 234U, and 90Sr 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 providing identical information to both AK and 

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

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

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

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

These include: 

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

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

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

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

drum history up to acceptance by the characterization 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 maintains 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 containers are added to the waste stream. 

Hanford-CCP also keeps detailed records of container 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 available 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 own 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 was terminated in 2009, and CCP took 
31

over the characterization responsibilities. The Hanford TRU waste characterization program has 

a tremendous amount of information in hard copy documents, 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 many of the references available with 

Hanford TRU program have been integrated into the Hanford-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-defined 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 ownership as “their own” stand-alone 

program. Integration of site documents and activities 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 findings related to AK during this inspection. EPA 

did identify the single concern that is discussed above. 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 addressed and there are no open findings or 

concerns related to AK resulting from this inspection. 

Baseline Approval 

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

report for CH retrievably-stored and newly-generated 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 implementation and will apply to 

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

following: 

• Categories of waste not approved under this baseline 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 additional information, choose to conduct a 

desktop review, and/or confer with Hanford-CCP personnel. 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 attachments 

• Availability of all AK Accuracy Reports 

• Availability of successful training records 

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

memorandum 

8.2 Nondestructive Assay (NDA) 

Waste Characterization Element Description

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

Packaging (WRAP) Facility: the Canberra Gamma Energy 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 measurement capability. The checklist in 

Attachment A.2, in conjunction with the documents listed 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) Calibration, 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 Review, Validation, and 

Reporting Procedure, Revision 0 

• GEA Units A and B Radionuclide Listing Library, Filename: 

C:\GENIE2K\CAMFILES\CCPWRAP.nlb, generated April 37, 2010 

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

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

• Use of Isotope Correlation Techniques to Determine 242Pu Abundance, R. Gunnink, 1980 

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

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

Characterization of Hanford Site Waste Stream MPFPDD, Revision 2, March 17, 2010 
33

• HNF-5148, EDC-05-25965, Calibration Report for the WRAP Facility Gamma Energy 

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 (GEA) System Unit A 

Calibration, Confirmation and Verification Report 

• CCP-RL-GEA_B-001, Revision 0, Gamma Energy Assay (GEA) 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 Activities – 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 Activities – 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 approved 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 detailed technical basis for each system’s 

operation is described and detailed in the EPA inspection 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 equivalent in terms of measurement capability. 

Both systems had been operational for WIPP assays prior to this inspection and both were reevaluated during this inspection. The EPA inspection 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 procedures to provide technical support 

to EPA approval 
34

• Knowledge and understanding of the personnel involved 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 confirmed 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 that 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 Germanium (LEGe) detectors used for isotopic 

analysis based on photons in the 45 to 300 keV range 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 software is at the discretion of the NDA Expert 

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

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

detectors address matrix correction by using four highly collimated 152Eu sources located directly 

opposite the SEGe detectors and at a right angle (90°) to the LEGe detectors. Both systems 

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

elevation and rotation equipment, and ancillary electronics. 

The systems have two operational modes, a shielded and unshielded geometry, and there are 

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

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

enhanced 241Am levels, or significant count rates from other fission products. The main 

difference results in the choice of 239Pu line (129 keV or 414 keV) for quantitative analysis. 

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

container’s assay or summing all horizontal segments 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 238Pu, 239Pu, 240Pu, 233U, 235U, and 238U over a mass range from 0.010 g to 345 g of 

nominal WG Pu, i.e., 6% 240Pu. Technically based correlations (scaling factors) are used to 

derive values for 234U, 137Cs, and 90Sr; 242Pu is determined using the correlation techniques of 

Gunnink. There are no technical issues associated with 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 CCP-RL-GEA_A-001 (GEA-A) and 

CCP-RL-GEA_B-001 (GEA-B). Both GEA units have energy 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 transmission (shielded) efficiency 

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

152Eu/137Cs/241Am in four 55-gallon (208-liter) matrix drums containing foam, soft board, 

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

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

from high 241Am concentrations associated with aged plutonium, and the 152Eu 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 

152Eu/137Cs/241Am sources used for calibration, as required. Hanford-CCP NDA personnel 

provided objective evidence of the appropriate pedigree 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 were combined to produce the following 

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

except for the 9.0 WG Pu in the shielded transmission 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 collected 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 passed 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 239Pu 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 for a copy of this form). 

EPA Inspection Issue No. Hanford-CCP-CH-NDA-10-003CR: 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 expected. 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 newer limits were not conveyed to the 

appropriate personnel and the newer assays were subjected to the old limits. This is not a 

performance issue, since all assays passed the tighter (more restrictive) limits. However, it 

indicates a breakdown in communication within the NDA group, as well as a lack of appropriate 

control over fundamentally important performance data. 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 limits, 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 change 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 compliance with EPA regulations. (See Table 1 

where this is included as a T2 change.) 

(3) The total measurement uncertainty of assays performed on the GEA-A and GEA-B had 

been adequately determined and documented. 

The determination of the total measurement uncertainty (TMU) of assays performed on the GEA 

Units A and B is documented in CCP-RL-GEA-003, Total Measurement Uncertainty (TMU) for 

the Gamma Energy Assay Systems. The components of uncertainty included in the TMU 

determination included calibration source uncertainties, counting statistics, self-absorption 

effects, matrix non-homogeneities, non-uniform source distributions, and isotopic measurement 

uncertainties. There are no issues with the determination 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 “that level of radioactivity which, if present, 

yields a measured value greater than the critical level with a 95% probability, where the critical 

level is defined as that value which measurements of 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 being 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 quantities, such as total TRU alpha activity and TRU 

alpha activity concentration. The LLD values for all 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 systems are below 100 nCi/g for wastes with a net 

weight over approximately 11 kg (density about 0.055 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 accordance with the 100 nCi/g TRU 

criterion. There are no technical issues with the determination 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 Cycle 17A (May 2010 distribution) of the 

CBFO-sponsored NDA Performance Demonstration Program (PDP), by assaying S5000 wastes 

containing debris, glass, and sludge. EPA will evaluate 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 part 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 ten WIPP-tracked radionuclides (241Am, 137Cs, 

238Pu, 239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U, and 238U) and the TRU alpha concentration. EPA 

selected replicate testing drums from the list of previously measured drums on each system. This 

is accomplished by reassaying drums previously measured on the same system in order to 

demonstrate the system’s ability to do the following: 

• Produce results consistent with the reported TMU by comparing the sample standard 

deviation for a number of replicate measurements taken over several hours or days to the 

reported TMU; 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 for GEA-A and RL0063034, 

RL0056338 and RL062952536-8-37 for GEA-B. All six drums were reassayed on the respective 

GEA unit five times and the data for the five replicates and the original assay were analyzed 

using two statistical tests, a Chi-Squared (χ2

) 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 241Am results for this container had a 

tight grouping the average of which was sufficiently different from the original assay to 

trigger a “Significant” flag for the t Test. For 237Np, the five replicates showed four 

results that were less than the MDA and one reportable (greater than MDA) value, which 

triggered the “Significant” flag. The actual differences among these assay values are 

small and these results are consistent with what has 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 137Cs and 90Sr results showed a “Highly Significant” 

flag for the Chi-Squared Test. Since 90Sr is scaled to the measured 137Cs value any flag 
38

that is reported should be noted for both radionuclides. The replicate and original 137Cs 

values are low and are subject to considerable variations, which triggers the “Highly 

Significant” flag. The 241Am and TRU Alpha Activity showed “Highly Significant” flags 

for the t Test. The actual variability occurred for the 241Am 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 original assay, which translated to a 

17% increase in TRU Alpha Activity. The 241Am 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 241Am-bearing items within the waste container due to 

handling, which could cause elevated readings due to 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 statistical tests. 

• Container No. RL062952: The Chi-Squared Test indicated two “Highly Significant” 

flags, one for 238Pu and one for 242Pu, and a “Significant” flag for the t Test for 239Pu. Due 

to the low activity levels for these radionuclides, there was considerable variation in the 

isotopic determinations assigned by MGA. This caused differences in the isotopic 

contribution of 240Pu (13% versus 17%), which is then propagated through 238Pu, 239Pu 

and 242Pu isotopes. We have observed this problem previously, especially with low Pu 

content drums where MGA runs poorly and a small absolute difference (4%) produces 

what appear to be large differences. 

There are no technical issues associated with replicate testing of GEA Units A and B. 

Summary of NDA Findings and Concerns 

The EPA inspection team did not identify any findings related to NDA during this inspection. 

EPA did identify the single concern that is discussed 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 addressed and there are no open findings or 

concerns related to NDA resulting from this inspection. 

Baseline Approval 

EPA approves the NDA systems evaluated during this baseline inspection as described in this 

report for CH retrievably-stored and newly-generated 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 implementation 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 inspection 

• 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 Hanford-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. Upon evaluation 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 intended for disposal at the WIPP. 

T2 NDA change includes notification to EPA upon completion of changes to software from 

approved equipment, operating range(s), and site procedures that require CBFO approval. These 

changes do not require EPA approval before implementation. Hanford-CCP must provide 

notification to EPA upon completion of these changes 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, the EPA inspection team focused on overall 

procedural technical adequacy and implementation, as well as the identification of WMPs and 

prohibited items, in reviewing the following RTR elements: 

• Documentation of RTR activities through use of an approved 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 on the RTR system using specifically 

placed items 
40

Documents, BDRs, and Objective Evidence Reviewed

The following documents were among those the EPA inspection team examined to assess 

whether all RTR operations follow the appropriate approved procedures: 

• CCP-TP-053, Revision 7, CCP Standard Real-Time Radiography (RTR) Inspection 

Procedure, October 21, 2009 

• CCP-TP-028, Revision 3, Radiography Test and Training Drum Requirements, 

January 19, 2006 

• CCP-QP-002, Training and Qualification Plan, Revision 27, September 30, 2008 

• CCP-QP-005, TRU Nonconforming Item Reporting and Control, Revision 18, August 13, 

2009 

• Standing Order CCP-SO-RL-01, April 14, 2010 

• CCP-QP-008, Records Management, Revision 15, October 28, 2009 

The following is a complete listing of all objective evidence the EPA team evaluated during the 

inspection: 

• RTR BDRs and audio/visual recording of RTR events for 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 RTR operators/ITRs 

• CCP NDE Test Drum Inventory Sheet for HAN-NDETEST-02, -03, and -04

• List of currently qualified RTR personnel 

• Measurement Conversion Chart 

Technical Evaluation

During the inspection, the EPA inspection team evaluated 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 implementation were considered and were 

found to be acceptable. 

The RTR procedure, documented in CCP-TP-053, Revision 7, Standard Real-Time Radiography 

(RTR) Inspection Procedure, contained specific information on performing non-intrusive 

radiography, including operational setup and checkout, identification of prohibited items, 
41

assignment of WMPs and estimation of weights and volumes, confirmation of WMCs, input of 

data, issuance of NCRs, and technical review of radiography results. 

(2) Characterization of Waste Material Parameters and prohibited items was assessed and 

was found to be adequate. 

Procedure CCP-TP-053, Revision 7, requires that radiography 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 RTR 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 inspection. 

At the beginning of a shift, and before examining any waste containers, the operator runs a scan 

on the lines-pair resolution test gauge to determine that images are clearly visible. On the day of 

the inspection, the operator had performed this check before EPA arrived at the facility, but the 

inspectors reviewed the image quality check for Batch RLRTRA0025. This check was 

determined to be acceptable and met Hanford-CCP requirements. 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 operator makes an audio/video recording of the 

RTR event. The first notations that the operator makes on the audio/video recording are the drum 

number and the date and time on the audio/video recording 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 degrees 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 staff 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 generated and processed in the PFP Building is 

MPFPDD, which is a debris (S5000) waste stream. There 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 recorded on the data sheet. The tare weight for 

containers is obtained from standing order CCP-SO-RL-01. 

As part of the inspection, the EPA team observed the examination of waste container 

RL0056204, which formed part of batch RLRTRA0025. The 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 record (BDR). During the on-site 

demonstration, the operator used an uncontrolled method to calculate the volume of liquid found 

in the folds of plastic within the drum. EPA discussed 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-10-001CR: The RTR operator used a 

“Measurement Conversion Chart” to calculate the volume of liquid identified during RTR 

examinations and made process decisions based on the 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 estimate 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 arithmetic 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 quality controls, including ITR review, are in place 

to identify discrepancies in free liquid volumes and 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 would have been identified and corrected. 

Status of Concern: EPA believes that approximation of waste components is adequate; 

however, EPA needs to have confidence that the information 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 including processes and equipment used for 

waste characterization, and training of personnel characterizing waste are credible. In this 

instance EPA is verifying the appropriate implementation of waste characterization processes at 

TRU sites. 

In the report accompanying the proposed approval, EPA required that when mathematically 

estimating volume of liquid in a container, the operator 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 maintenance of auditable records is necessary but 

also the process implemented to calculate liquid contents in a container needs to be revised, and 

EPA will review implementation of the revised procedure at CCP-serviced CH TRU sites. Also, 

RTR operators need to be trained to the revised procedures 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 that was not evaluated during the baseline 

inspection is a T1 change and will require EPA review and approval prior to implementation. 

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

Notification to EPA upon completion of modifications to approved equipment, RTR units A and 

B, changes made to RTR procedure(s) that require CBFO approval and the addition of new SCG 

to the RTR processes that are subject to this approval 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 continued compliance with EPA regulations. 

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

(3) Documentation of radiography activities was examined and was found to be adequate. 

Simultaneous written and audio/visual recordings are 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 Data Sheet, from procedure CCP-TP-053 as 

they are generated. 

(4) EPA ascertained that documentation of radiography procedures was adequate. 

Radiography procedures are well defined and the documents are controlled. During the 

inspection, the EPA team reviewed the adequacy and implementation of all radiography-related 

procedures. QC examinations were performed as required by the procedure. In batch 

RLRTRA0001, an independent observation was performed on container RL0037205 and a 

replicate scan was performed on container RL0063057; in batch RLRTRA0002, an independent 

observation was performed on container RL0058636 and a replicate scan was performed on 

container RL0066836; and in batch RLRTRA0003, an independent observation was performed 

on container RL0066877 and a replicate scan was performed on container RL0062953. 

Although NCRs were not available for review in BDRs RLRTRA0001, RLRTRA0002, and 

RLRTRA0003, the operator interviewed was able to describe how NCRs are initiated and 

documented. To verify this information, EPA reviewed NCR-RL-0642-10 issued against 

container RL0055166, BDR RLRTRB0018, even though this NCR had not been through the 

required reviews. EPA determined that the NCR was issued 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 documentation of the capability demonstration for 

selected radiography personnel. The inspectors viewed the audio/visual recording for the latest 

capability demonstration drum for the RTR SME and an RTR operator during the inspection. 

The RTR SME is responsible for verification of qualification for RTR operators. Training 

records reviewed indicate that only trained personnel were operating the RTR equipment. 

EPA also reviewed the Qualification Cards and training records for selected RTR personnel. 

Training documentation was complete and was filed correctly for purposes of reviewing and 

reference. 
44

Summary of RTR Findings and Concerns

The EPA team did not identify any findings and identified one concern requiring a response for 

RTR during the on-site inspection. 

Baseline Approval

The baseline conditions that the EPA inspection team 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 BDRs 

• RTR Units A and B 

This system is suitable for RTR of CH TRU S5000 debris wastes. 

RTR Tiers 

Based on the inspection and the results discussed above, EPA proposes assigning the following 

tiers: 

T1 RTR changes will require EPA review and approval prior to implementation. 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 Hanford-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. Upon evaluation with or without a site 

inspection, EPA will issue a decision. Only upon receiving EPA written approval may HanfordCCP implement T1 changes. 

T2 RTR changes that do not require EPA approval before implementation but require HanfordCCP to report and submit documentation discussing such changes include the following: 

• Modifications to approved equipment, RTR units A and B 

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

• Addition of new SCG to the RTR processes that are subject to this approval 

• Use of a different type of RTR unit from what was included in the baseline approval, e.g., 

a high-energy RTR unit 

Every three months from the date of EPA approval, Hanford-CCP will provide information 

concerning T2 changes. If new RTR equipment is in use, 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 whether 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, as well as the identification of WMPs and 

prohibited items, in reviewing the following VE elements: 

• Documentation of VE activities through use of an approved procedure 

• Proper execution of VE activities 

• Management oversight and independent review of VE activities 

• Training of VE personnel 

The VE process for CH debris (S5000) waste performed at Hanford uses manual examination to 

determine the following aspects of TRU waste characterization: 

• Identification and weight estimate of WMPs 

• Confirmation of the WMC 

• Confirmation of presence or absence of prohibited items 

The VE must be performed by two trained and qualified VEOs, as described in procedure 

CCP-TP-053. 

Documents, BDRs, and Objective Evidence Reviewed

The following documents were among those the EPA reviewed to assess whether VE operations 

follow the appropriate approved procedures and meet VE requirements: 

• CCP-TP-113, CCP Standard Contact-Handled Waste Visual Examination, Revision 13, 

March 11, 2009 

• CCP-QP-002, Training and Qualification Plan, Revision 27, September 30, 2008 

• CCP-QP-005, TRU Nonconforming Item Reporting and Control, Revision 18, August 13, 

2009 

• CCP-AK-RL-101, Revision 2, 

• CCP-QP-008, Records Management, Revision 15, October 28, 2009 

Following is a complete list of all objective evidence 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 VE 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 evaluated 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 implementation were assessed and found to be 

adequate. 

The VE procedure, documented in CCP-TP-113, Revision 13, contained specific information on 

performing VE, including identification of prohibited items, assignment of WMPs, and technical 

review of VE results. EPA inspectors usually observe a VE evolution as part of the inspection 

process, but this was not possible at Hanford-CCP due 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 evaluated 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 than using two trained operators to perform 

actual VE at the time of packaging (VE of records by 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 prohibited 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 respirator suits to work in the VE area and EPA 

inspectors are not trained for this type of operation. The waste stream being processed at the time 

of the on-site inspection was MPFPDD, which is a debris (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 currently being generated from break-down of 

glove boxes in PFP. These waste items, such as pipes, brackets, and saw-blades are taped 

together into packages and numerically identified on the outside of the package. VE data forms 

record both the contents of each package and the packaging 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-113, 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. Verification 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 and captured it on an Inspection Issue 

Tracking Form (see Attachment C.3 for a copy of this 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 dated July 2, 2009, which 

predates all VE characterization activities as documented on the VE BDRs. Additionally, 

Hanford-CCP also provided documentation of the rejection 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 prior to implementation include the following 

changes made to VE procedure(s) that require CBFO approval 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 RLVEPF0023 to verify that the VE data 

were documented correctly and completely. Site personnel used Attachment 2 from CCP-TP-113 

to record these data. The two BDRs had been reviewed 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 examined and found to be adequate. 

Hanford-CCP maintains a list of qualified individuals, which it uses to ensure that all training is 

current. Hanford-CCP documents the personnel who are 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 regulations or requirements. EPA discussed 

this with Hanford-CCP personnel and EPA captured this on an Inspection Issue Tracking Form. 

The issue is summarized below (see Attachment C.3 for 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 regulation(s) as required by CCP-PO-002, 

Revision 22, Appendix 10, Section 10.2. EPA had identified 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) before the first CH TRU waste shipment is 

scheduled from Hanford-CCP. 

Resolution: In response to this finding, CBFO provided a document 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 adequately addressed EPA’s concern.

Status of Concern: EPA considers this issue to be closed.

EPA identified a discrepancy with respect to the date on which the VEE was appointed. EPA 

discussed this with Hanford-CCP VE 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 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 closing 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 and 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, specifically 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 implementation, and will apply to 

any new waste category or process that was not evaluated during the baseline inspection. The 

one T1 change identified is performance of VE by any method other than using two trained 

operators to perform actual VE at the time of packaging (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 Hanford-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. Upon evaluation with or without a site 

inspection, EPA will issue a decision. Only upon receiving EPA written approval may HanfordCCP implement T1 changes. 

T2 VE changes that do not require EPA approval prior to implementation, but require HanfordCCP to report and submit documentation, include the following: 

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

• Addition of new SCG to the VE processes that are subject to this approval 

Hanford-CCP will provide EPA with information concerning T2 changes on a quarterly basis, 

including a brief description of the available information. EPA will evaluate these changes and 

communicate with Hanford-CCP as to whether the changes raise any concerns and require a 

Hanford-CCP response, or whether Hanford-CCP can continue to implement the changes. 

Consistent with EPA’s authority under 194.24(h), EPA may request information relative to these 

changes if EPA deems the information is necessary to 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-based system. This new system was named 

Waste Data System (WDS) and data entry procedure CCP-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 User’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 during 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 data could not be entered into the WDS 

proper to demonstrate that the effectiveness of data submission had not been compromised due to 

the change from WWIS to WDS. Procedure CCP-TP-030 is used for submittal of both 

characterization and certification CH data to the WDS. 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 inspectors reviewed to assess whether 

WDS operations follow the appropriate approved procedures and meet WDS requirements: 

• CCP-TP-030, Revision 27, CCP CH TRU Waste Certification 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 objective evidence during the inspection: 

• Waste Container Data Report for containers RL0063021 and RL0063034 

• CCP Correlation of Container Identification Numbers to Batch Data Reports, waste 

stream MPFPDD, lot #1 

• WDS data entry summary, characterization and certification, spreadsheet for containers 

RL0062930, RL0063034, RL0063014, RL0063021, RL0063040 

• CCP-QP-022, Software Quality Assurance Plan, Attachment 3, Software Problem 

Reporting and Change Request for WDS Master Template, 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 evaluated 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 essentially the same for both data bases. The 

WDS procedure documented in CCP-TP-030, RH TRU Waste Certification and WWIS/WDS 

Data Entry, Revision 27, is well defined and controlled, 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 Excel spreadsheet used for data entry was also 

adequate and controlled. WDS incorporates some changes 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 was 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 Profile 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, LANL drum LA00000064320 located in SWB 

LASB00811, was tracked back from emplacement to the original characterization BDRs. No 

issues were identified for the adequacy and implementation of this new system. 

EPA identified a discrepancy with respect to documentation 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-10-002CR: CCP training procedure 

CCP-QP-002, Revision 27, Section [C.3] requires WCOs to demonstrate proficiency in WWIS 

as part of training. However, WDS is not specifically identified in the training procedure, 

although this is the only User’s Manual listed in the reference section of CCP-TP-030. The 

Hanford-CCP Project Manager indicated that the procedure(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 for WCOs to demonstrate proficiency in WWIS 

as part of training as an example of the types of activities that may be performed after 

completion of a “core” qualification card. At the time of the Hanford-CCP baseline inspection, 

CCP-QP-002 was in revision to remove the list of sample activities that may be performed after 

completion of a “core” qualification card because inclusion of such a list is not a requirement. 

Deletion of this list removes any confusing references 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 activities 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 characterization and certification process by 

uploading CH data into the test instance of WDS. However, the usual records (e-mails, signed 

data spreadsheet, etc.) were not available for review. 

After the characterization data have been through every level of review and approval, they are 

entered into a controlled Excel spreadsheet by a WCA. A review of the spreadsheet is made by a 

second WCA to verify correct data entry. The WCO reviews 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 validation 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 retrieved, a randomly chosen LANL container 

was traced back from emplacement to the original characterization BDRs. Although EPA was 

not able to challenge WDS with data from waste stream MPFPDD, the WCO demonstrated 

sufficient information about the data system to enable 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 found to be adequate. 

The EPA inspectors observed limited job performance of a WCO to verify personnel training and 

qualification. Inspectors also reviewed the qualification 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. Hanford-CCP-CH-WDS-10-002CR to 

address this issue. 

Summary of WDS Findings and Concerns

The EPA inspection team did not identify any findings 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 elements: 

• 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 spreadsheet titled WDS Master Template.xls, 

Revision 2, Addendum #2, SCO #1065 

WDS Tiers

T1 WDS changes will require EPA review and approval prior to implementation, and will apply 

to any new waste category or process that was not evaluated 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 Hanford-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. Upon evaluation with or without a site 

inspection, EPA will issue a decision. Only upon receiving EPA written approval may HanfordCCP implement T1 changes. 

T2 WDS changes that do not require EPA approval prior to implementation, but require 

Hanford-CCP to report and submit documentation, include the following: 

• Changes to WDS procedure(s) that require CBFO approval 

• Changes to the Excel spreadsheet titled WDS Master Template.xls, Revision 2, 

Addendum #2, SCO #1065 

Hanford-CCP will provide EPA with information concerning T2 changes on a quarterly basis, 

including a brief description of the available information. EPA will evaluate these changes and 

communicate with Hanford-CCP whether the changes raise any concerns and require a HanfordCCP response, or whether Hanford-CCP can continue to implement the changes. Consistent with 

EPA’s authority under 194.24(h), EPA may request information relative to these changes, if EPA 

deems the information is necessary to ensure continued compliance with EPA regulations. 

9.0 RESPONSE TO COMMENTS 

On October 6, 2010, EPA received initial comments from one Commenter on the following two 

issues: (1) estimating the liquid contents of a drum using a mathematical equation(s); and (2) 

evaluation of High Energy RTR equipment as a T1 change. (See EPA Air Docket EPA-HQOAR-2010-0711 for complete comments). Both issues are 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 follow-up comments, a listing of the follow-up 

documentation, and EPA response to the public comments are included in Attachment E of this 

report. Below is EPA’s response. 

EPA Response to Comment No. 1: Estimating the liquid contents of a drum using a 

mathematical equation: EPA reviewed the additional information the commenter provided in 

response to the proposed requirement which is included as Attachment E of this report. The 

Commenter states “The RTR operator used a “Measurement 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 concerned 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 accuracy of the estimate. Also, the calculated 

liquid volumes as currently done may lead to a greater expectation of accuracy, and requiring 

these as auditable records is justified. As discussed below, EPA disagrees with Commenter’s 

contention that using mathematical formulae to calculate liquid volumes is a “process 

improvement.” This disagreement is based on the poor 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 attendance sheets for RTR personnel. The training 

modules provided in the Commenter’s response did not address significant figures or a technique 

for rounding values. The training material is comprehensive 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 modules. When calculating liquid volume more 

precision and accuracy is implied, though it is still just an estimate; if incorrect, then it is a poor 

estimate. EPA does not concur with CCP or CBFO’s insistence to calculate a precise quantity of 

liquid when the estimation method can provide the desired 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 of 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 included estimated WMP weights, which are 

critical to the repository’s performance, without appearing 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 following: 

• Maintain auditable records of calculated liquid volume in a container; 

• Revise the “Measurement Conversion Chart” to make it better suited to operator’s 

skill level; 

• Improve training of RTR Operators and make it consistent so that subjectivity is 

minimized; and 

• Provide EPA with the revised training material, test 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 volume in containers. 

EPA Response to Comment No. 2: Use of High Energy RTR 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 Hanford 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 months), then EPA may evaluate 

implementation of such RTR-specific T2 change(s) prior 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 inspection, as well as Hanford-CCP responses, 

are discussed in the preceding sections of this report. Attachment C includes copies of the EPA 

Inspection Issue Tracking Forms that capture these issues. 

Hanford-CCP responded to the one EPA finding and five EPA concerns subsequent to the 

inspection. The EPA inspection team members evaluated all responses for completeness and 

adequacy and concluded that each EPA issue requiring a response had been resolved 

satisfactorily. No EPA issues related to the baseline 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 baseline inspection and described in this report 

and the attached checklists (Attachments A.1 through A.5). This baseline compliance decision is 

based on EPA’s inspection completed April 27-29, 2010, 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 wastes 

(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 CH TRU wastes 

This baseline approval of Hanford-CPP does not include load management. Also, this approval 

prohibits Hanford-CCP from a process currently implemented 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 including 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 Conversion Chart” to make it better 

suited to match operator’s skill level; 

• Improved on-the-job training of RTR Operators to make it consistent among different 

operators to minimize subjectivity; and 

• Submission to EPA for evaluation and approval the revised training material, test 

questions for operator qualification, and test results 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 containers. 

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 approved unit are sufficiently significant (such as 

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

implementation of such RTR-specific T2 change(s) prior 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 the previous CH baseline approval reports. 

The table identifies applicable T1 and T2 changes that 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 Hanford-CCP waste characterization activities 

from the date of the baseline inspection. This approval 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 Table 10, below. (See Section 2.0 of this 

report for a brief discussion of tiering.) Upon approval 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 T2 changes. EPA expects the first report of 

Hanford-CCP’s T2 changes at the end of the first quarter following approval. 
57 

Table 10. Tiering of TRU Waste Characterization Processes Implemented by Hanford-CCP 

Based on April 27-29, 2010 Site Baseline Inspection

Process Elements Hanford-CCP T1 Changes Hanford-CCP T2 Changesa

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 changesb 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 equipmentc

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 to EPA upon the following: 

- Modificationc 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 method 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 to 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 report all T2 changes to EPA at the end of each fiscal quarter. Note: EPA 

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

b “Substantive changes” are changes with the potential to impact the site’s waste characterization activities or documentation 

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

c Modifications to approved equipment include all changes with the potential to affect NDA data relative to waste isolation and 

exclude minor changes, such as the addition of safety-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 Mexico, 1989. 

U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 191, 

“Environmental Radiation Protection Standards for Management 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, Compliance Certification Application for the 

Waste Isolation Pilot Plant,” DOE/CAO 1996-2184, Carlsbad, New Mexico, 1996. 

U.S. Department of Energy, “40 CFR Part 191, Subparts C and D, Compliance Recertification 

Application 2004,” DOE/WIPP/2004-3231, 2004. 

U.S. Department of Energy, “Transuranic Waste Baseline Inventory Report,” Revision 0, 

DOE/TRU-2206-3344. 

U.S. Department of Energy, Carlsbad Area Field Office, “Contact-Handled Transuranic Waste 

Acceptance Criteria for the Waste Isolation Pilot Plant (CH-WAC),” Revision 3, DOE/WIPP-02-

3122, Carlsbad, New Mexico, April 25, 2005. 

U.S. Department of Energy, Carlsbad Area Field Office, “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 Disposal Regulations: Certification Decision; 

Final Rule,” Federal Register, Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405. 

U.S. Environmental Protection Agency, “EPA Replicate Testing for WIPP Nondestructive Assay 

(NDA) Systems,” Revision 2, June 2002. 

U.S. Nuclear Regulatory Commission, “Contact-Handled Transuranic Waste Authorized 

Methods for Payload Control. 
A-1 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH AK Checklist Insp

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Example

GENERAL 

AK-1: Is the waste TRU by definition as presented in the 

LWA? (P.L.102-579) 

CCP-TP-005, Revision 18; Section 4.4.31; CH-WAC Revision 6.4; P.L. 102-579 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

Draft WSPF for Wexamined indicatedefinition, NDA B

AK-2: Do the presented volumes comport with LWA capacity restrictions? (P.L.102-579) 

CCP-TP-005, Revision 18; CH-WAC Revision 6.4; P.L. 102-579 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

WSPF for Waste SMPFPDD, CCP-Texamined identifiewaste volume. 

AK-3: Are any wastes considered (or previously considered) high-level wastes (HLW)? HLW are 

prohibited. 

(P.L.102-579) 

CH-WAC Revision 6.4; P.L. 102-579 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

AKSR MPFPDD, indicated that the inspection were by 

AK-4: Are any wastes considered (or previously considered) Spent Nuclear Fuel? SNF is prohibited. (P.L.102-579) 

CH-WAC Revision 6.4; P.L. 102-579 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

AKSR MPFPDD, indicated that the inspection were by 

AK-5: Are these defense wastes? Waste must be defense in origin. (P.L.102-579) 

CCP-TP-005, Revision 18, Section 4.4.1; CH-WAC Revision 6.4; P.L. 102-579 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

AKSR MPFPDD, during the inspectstream is or was cdefense 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 2009 

EPA Scope Letter: CHDebris AKSR MPFPDD, 

MPFPDD. Scope handled debris (S5newly generated. under this baseline S4000 wastes). 

AK-7: Is AK being used that was assembled prior to an EPA approved QA program? If so, what qualification

process is used? Is this waste undergoing confirmation as per 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. 102-579 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

RLRTRB0002, RLRLGEAA0002. 10confirm AK. 
A-2 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH AK Checklist Insp

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Example

AK-8: Is AK being assembled as waste is generated after

EPA approval of the QA program? Is this waste undergoing 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. 102-579 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

RLRTRB0002, RLRLGEAA0002AK5.4.1.2. All waste will undergo 100% 

AK-9: Procedures require staff to be qualified to assemble, compile, and confirm AK data, including, but not limited to: 

a. Identification of required reading list and successful 

completion of all required reading including, but not limited to: 

• Applicable portions of the WIPP WAP and TSDF 

WAC 

• WIPP Compliance Certification Decision Conditions 

2 and 3 

• State and Federal RCRA regulations associated with 

solid and hazardous waste characterization 

• Discrepancy resolution and reporting processes • Site-specific procedures associated with waste 

characterization using acceptable knowledge 

b. Successful completion of testing to demonstrate 

understanding of required reading list 

c. Completion of internal and/or external training 

programs pertinent to AK 

d. Participation in internal audits to assess AK program 

e. Other methodologies for demonstrating AK 

proficiency as developed on a site-specific basis 

(WAP B4, B4-3a) 

CCP-TP-005, Revision 18, Section 2.2; CCP-QP-002, Section 4.2 

Interview of Steve Schafer 

Natasha McCants, and 

Sheri Nance 

AKE Qualification Schafer, Natasha Mroster for most recCCP representativrequired reading fversions – they are using the most updthe FTP site. It is aware of the conte

procedure, but EP

documentation of the training recorddid not include an

been trained to EP

had participated in 

AK-10: 

a. Are procedures adequate to encompass the spectrum of 

wastes for which authorization is sought? 

CCP-TP-005, Revision 18; CCP-TP-066 

Review of objective evidence and interview of Steve Schafer and Sheri 

RLRTRB0002, RLRLGEAA0002, V0004,0008-0013 
A-3 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH AK Checklist Insp

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Example

b. Are there different procedures for newly generated vs. 

retrievably stored waste? Are there different 

procedures for solid, debris, or soil waste? Should 

there be? 

c. For newly generated waste, have adequate procedures 

been developed and implemented to characterize waste 

using acceptable knowledge prior to packaging? 

(WAP B4, B4-3b) 

Nance CCP-TP-005, Rev

retrievably stored RTR, NDA used teach container. Da

NDA and RTR ma

all of which activiaddressed in other generated waste mModification of CTier 2 change. 

ASSEMBLING AK INFORMATION AND COMPILING AK DOCUMENTATION INTO AN AUDITABLE RECORD AK-11: What is the breakdown of the types and quantities of TRU waste generated/stored at the site? (WAP B4, B4-2a) 

CCP-TP-005, Revision 18, Sections 4.4.8, 4.4.9, and Attachment 1 PR6 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

WSPF MPFPDD, AKSR MPFPDD waste stream), HN005, Attachment 6 MPFPDD waste scombination of thRLMPFPCD wastsubset of the RLMlater containing wWaste Treatment Ventilation/ExhauAncillary Facilitie

AK-12: Do procedures call for AK information to be collected for: a. 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr, 

137Cs + unexpected radionuclides 

b. Ferrous metals (in containers) 

c. Cellulosics, plastics, rubber d. Nonferrous metals (in containers) (CRA/CCA Ch 4 and Attachments/Appendices) 

CCP-TP-005, Revision 18, Sections 4.4.21, 4.4.22, 4.4.24 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

P976, P1084, AKCCP-TP-005 AttaMemo, reference RLRTRB0002, RLRLGEAA0002, V0004,0008-0013. A

238U are the most pWaste also containneptunium, cesiumMPFPDD is compmaterial representincluding plutoniuincineration, and Dthe NDA memo is 
A-4 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH AK Checklist Insp

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Example

AK-13: Do procedures require documentation of radionuclide process origin? Are the facility and TRU waste management operations correlated to specific waste stream information? (WAP B4; WAC Appendix A.2.2) 

CCP-TP-005, Revision 18, Section 4.4, Attachment 1 WS4, PR7 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

AKSR Section 4.0C104, , M047, P0material from the • 232-Z, Waste Indemolished) • 234-5Z, Plutoniu• 236-Z, Plutonium • 242-Z, Waste Tr• 2736-ZB, ProduFacility • 291-Z, Ventilatio• PFP Ancillary FCCP demonstrated Facilities are withon common physicomposition excepCCP removed the waste stream in a 

AK-14: Are correlations between waste streams, with regard to time of generation, waste generating processes, and site-specific facilities clearly described? For newly generated wastes, the rate and quantity of waste to be generated shall be defined. (WAP B4, B4-3c) 

CCP-TP-005, Revision 18, Section 4.4, Attachment 1 PR7 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

AKSR MPFPDD references: C117, P071 and P153 Historic time outli

4.2.2 Future volumAKSR 5.2 

AK-15: a. Are waste streams appropriately identified and are 

wastes characterized on a waste stream basis? 

b.Are wastes grouped on a waste stream basis using 

Acceptable Knowledge? 

(WAP B4, Section B-1a) 

CCP-TP-005, Revision 18, Sections 4.4, 4.2.3, 4.2.4 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

MPFPDD WSPF, Information and TContainer Report Drum Packaging DRL0063057 The MPFPDD wamixed heterogene

production, maint

decontamination, at the Plutonium Ffrom different buisupport processes radiological form no distinguishing 
A-5 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH AK Checklist Insp

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Example

areas in PFP. CCP 

because it is not p

drums came from must be assigned t

AK-16: Do procedures demonstrate a logical progression from general facility information to more detailed waste stream-specific information? 

CCP-TP-005, Revision 18, Section 4.4 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

MCPFPDD WSPFDocuments (C,DRincluding PTS PriSWITS, TRU DM

AK-17: Does the process include review of AK information to evaluate and document AK-AK information discrepancies? (WAC Section A.2.2.3, WAP B4, Section B4-3) 

CCP-TP-005, Revision 18, Sections 4.7, 4.8, 4.9 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

Discrepancy ResoDR013 

AK-18: Do procedures require collection of information regarding how waste is tracked and managed at the generator site (including historical and current operations)? (WAC Section A.2; WAP B4 Section B4-2a) 

CCP-TP-005, Revision 18, Section 4.4, Attachment 1 PR4 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance . 

SWITS database idatabase, Onsite Rand Solid Waste BAK Tracking SpreAttachment 8, WWcontainers). Data ehistoric waste tracascertained as wellocation. 

AK-19: Is AK information compiled in an auditable record, including a road map for all applicable information? 

CCP-TP-005, Revision 18, Attachments 1, 4 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

CCP-TP-005, Atta

AK-20: Has a reference list been provided that identifies 

documents, databases, Quality Assurance protocols, and other sources of information that support AK information? (WAP B4, Section B4-3c) 

CCP-TP-005, Revision 18, Attachment 4 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

CCP-TP-005 AttaReference list 

AK-21: Have the following mandatory information requirements been identified? • Map of the site that identifies the areas and facilities 

CCP-TP-005, Revision 18, Section 4.4.31, Attachment 1 

Review of objective evidence and interview of Steve Schafer and Sheri 

AKSR MPFPDD, AK-NDA Memo fFigures 1-3 
A-6 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH AK Checklist Insp

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Example

involved in TRU waste generation, treatment, and storage 

• Facility mission description related to TRU waste 

generation and management 

• Description of the operations that generate TRU waste 

at the site and process information, including: 

 - Area(s) or building(s) from which the waste stream 

was or is generated 

 - Estimated waste stream volume and time period of 

generation 

 - Waste generating process description for each 

building or area 

 - Process flow diagrams, if appropriate  - Generalized material inputs or other information that 

identifies the radionuclide content of the waste stream and the physical waste form 

 - Types and quantities of TRU waste generated, 

including historical generation through future 

projections 

• Physical/chemical waste composition that could affect 

isotopic distribution (i.e., processes to remove ingrown 

241Am) 

• Statement of all numerical adjustments applied to 

derive the material’s isotopic distribution, e.g., scaling 

factors, decay/ingrowth corrections and secular equilibrium considerations 

• Specification of isotopic ratios for the 10 WIPP-tracked 

radionuclides and, if applicable, the radionuclides that comprise 95% of the hazard 

(WAC Section A.2.2; WAP B4, B4-2a, B4-2b) 

 Nance AK data indicate t

produced at Hanfo

percentage betwee

material processed 

weight percent of technology as welHanford concludeindicated a range olikely be appropriThe NDA memo i

interference with 2

that may interfere associated with 152

interact with low-can interfere with 

boron, fluorine, ca

aluminum may co

AK-22: Does the site have procedures for the collection of supporting information? Examples of supplemental 

CCP-TP-005, Revision 18, Section 4.2.5, Attachment 1 

Review of objective evidence and interview of Steve Schafer and Sheri 

Numerous exampl

C043, C053, C074
A-7 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH AK Checklist Insp

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Example

information, from WAC, include: • Safeguards and security and other material control 

systems/programs 

• Reports of nuclear safety or criticality 

• Accidents involving SNM waste packaging and waste 

disposal 

• Building or nuclear material management area logs or 

inventory records 

• Site databases that provide SNM or nuclear material

information test plans 

• Research project reports, or laboratory notebooks that 

describe the radionuclide content of materials used in experiments 

• Information from site personnel • Historical analytical data relevant to isotopic 

distribution in the waste stream 

(WAC Section A.2.2.2; WAP B4 Section B4-2c) 

Nance M044, M305, P20

U202 

AK-23: Is all necessary supporting information assembled and has it been appropriately used? (WAP B4 Section B4-2c) 

CCP-TP-005, Revision 18, Section 4.2.5 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

Numerous exampl

C043, C053, C074M044, M305, P20U202Also, CCP pchanges addressinDR013. 

AK-24: 

a. Are waste categorization schemes presented and are 

they appropriate? 

b. Are waste identification/categorization schemes 

relevant to the isotopic composition of waste? 

(Attachment B4 Section B4-1, WAC Appendix A.2) 

CCP-TP-005, Revision 18, Section 4.4 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

AKSR MPFPDD, Attachment 7; DRassociated with PFdistribution applie
A-8 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH AK Checklist Insp

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Example

AK-25: Have data uses and limitations been assembled and are they technically adequate? (CRA/CCA; WAC Appendix A, Section A.2.2.3) 

CCP-TP-005, Revision 18, Section 4.3, Attachment 3 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

CC-TP-005 Rev 1document summarAttachment 3s frowhich as not been until Hanford. ThiSource Document Documents had thto loss of data and In the future, CCP not appropriate anSummaries to the 

AK-26: Site documents/procedures require the facility to

prepare an AK summary document that summarizes all 

information collected, including the basis for all waste 

stream designations. Is the AK Summary of sufficient scope and detail? (WAC Appendix A Section A.2.2; WAP Attachment B4 Sections B4-2b, B-3d) 

CCP-TP-005, Revision 18, Section 4.4 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

AKSR MPFPDD. associated with thmodification and wfreeze file change-Examine feed and to verify its inclus-Examine the use the document. -In Section 4.6.1, 

to waste stream deability to correlate 

processes. Also m

whether to-be-genupon generation o-Clarify intent of l

plutonium grades 

-Add information 6%, 12%, and 23% distributions as prDocuments and thdata that supports at the PFP as well -Remove first sent
A-9 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH AK Checklist Insp

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Example

Section 4.5 regardduring packaging later statements. -Verify number of Decontamination included in the PF-Add the total voluinventory. -In the final paragsecond predominaconsistent with the that identifies the 

by mass. 

CCP submitted a fadequately addresModifications to t

AK-27: Are conclusions and interpretations presented in the AK Summary technically sound and supported by referenced mandatory and supplemental information? 

CCP-TP-005, Revision 18 Review of objective 

evidence and interview of Steve Schafer and Sheri 

Nance 

See Item AK-26; ESource documents 

AK-28: If AK data discrepancy is identified, site will evaluate the source of the discrepancy to determine if discrepant information is credible. Information that is not credible will be identified as such and reasons fordismissing will be justified in writing. Limitations concerning information will be documented in the AKrecord and summarized in the AK report. If a discrepancy cannot be resolved, the site will perform direct measurements for the impacted population. (WAC Appendix A.2, Section A.2.2.3) 

CCP-TP-005, Revision 18, section 4.9 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

DR005, DR006 D

AK-29: Has the use of load management been proposed? Does the AK Summary include the following from the WAC, Revision 3, Appendix E? 

CCP-TP-005, Revision 18, Section 4.4.31 

Review of objective evidence and interview of Steve Schafer and Sheri 

AKSR MPFPDD, Modification of Achange. CCP Hanmanagement woul
A-10 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH AK Checklist Insp

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Example

• Each TRU waste stream selected for payload 

management must include in its acceptable knowledge

summary report an estimate of the total waste volume and the percentage of the waste volume that is above and below 100 nCi/g. (It should be noted that this information, although based on the best available AK information, is preliminary and subject to the 

performance of WIPP-certified NDA measurements 

and cannot and will not be used as a measure of AK accuracy.) (Reference E3) 

(WAC, Appendix E) 

Nance under the CCP Ha

load management 

AK-30: Are nonconforming wastes segregated? Are 

NCRs dispositioned in an appropriate and technically 

defensible manner? (WAP B4, Section B4-3b, Attachment B3, Section B3-13) 

CCP-TP-005, Revision 18, Section 4.9 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

NCR-RL-001-10,NCR 1201-1203. presence of variou

prohibited quantit

through NCR prep

AK-31: Do site procedures require that additional information be collected before waste may be shipped if the required AK information is not available for a waste stream or if available AK is poor or unacceptable? (WAP B4 ) 

CCP-TP-005, Revision 18, Sections 4.4.2, 4.4.3 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

CCP indicated thawhere additional i

because of poor A

access historic site 

NDA data acquireprogram. 

AK-32: Do these procedures facilitate the mandatory traceability analysis performed for each Summary Waste Category Group examined during the audit, noting that EPA will determine whether the available waste streams adequately demonstrate the full characterization process for the proposed scope? (WAP B4, Section B4-2) 

CCP-TP-005, Revision 18, Section 4.4 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

AKSD MCPFPDDSource Document(RTR, VE, NDA) 0055034; Historic records, PTS/CTScontainers. All of initial AK documecharacterization anrecords examined -Historic DocumeRecords Storage FManagement systeMixed Waste Con
A-11 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH AK Checklist Insp

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Example

Designation workLoaded/Sealed TRInspection Sheet fDrum, and Certifi-Solid Waste Infor(SWITS) database Container Listing -TRU Electronic D(TRUEDMT) data-BDRs (NDA and -CCP Program Trcontainer These data indicat

pertaining to wast

AK-33: If AK was used (i.e., data collected prior to QA 

program), what method was employed to qualify the 

information? Approved methods or peer review, corroborating data, confirmatory testing, and QA program 

equivalency? If confirmatory testing is used, has the following been considered (from WAC)?* • At a minimum, to confirm existing AK data, it is 

necessary to compare ratios of the two most prevalent 

radionuclides in the isotopic mix 

*If the WAC requirements are not followed, identify how 

the specific radionuclides are characterized via AK, and how 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 objective 

evidence and interview of Steve Schafer and Sheri 

Nance 

AKSR MPFPDD, 

NDA Memo; P97

confirmatory testidescribes how AK noted that the WAfollowed because 

not amenable to thCCP Hanford evaof the waste stream represents the MCstream. Data from (4528 drums emplWWIS that were n

prevalent isotopes 

distribution was ethat will be used bresults are not accthat initial weaponexhibited a 240Pu w

approximately 0.9Hanford exhibited for experimental rother technologiesof 241Pu or from th
A-12 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH AK Checklist Insp

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Example

(242-Z). CCP use

percent 240 Pu (6

defaults based on records. These dis

based on available 

isotopics with meaindicated good agrthe WWIS was rep

AK-34: Are radioassay and NDE results compared to the AK to verify implementation of the characterization

program? 

(194.24 (c)(3); 194.22(b)) 

CCP-TP-005, Revision 18, Section 4.5.3, Attachment 13 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

AK Accuracy Repexample characterthat data examined indicates that resuto AK. 

AK-35: This procedure requires a reevaluation of AK if 

NDE identifies it to be a different waste matrix code. This 

procedure 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 10 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

CCP-TP-005 Revi

No Attachment 10

audited waste stredemonstrated the Attachments as wof a LANL Attach

AK-36: Does the generator site have written procedures for newly generated waste to document the confirmation of acceptable knowledge information with visual examination 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 objective evidence and interview of Steve Schafer and Sheri 

Nance 

VE BDRs RLVEPindicate that conficharacterization/c

provided for revie

AK-37: Procedures require the following steps to be followed if wastes are reassigned to a different waste matrix code based on NDE: • Review existing information based on the container 

identification number and document all differences 

• Reassess and document all analytical data associated 

with the waste 

• Reevaluate waste material parameter determinations 

CCP-TP-005, Revision 18, Section 4.8, Attachment 10 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

CCP did not proviEvaluation Checkthis waste stream required up to the an example for LA
A-13 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH AK Checklist Insp

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Example

and document any changes 

• Reevaluate the radionuclide content and document any 

changes 

• Verify and document that the reassigned waste matrix 

code was generated within the specified time period, area and buildings, waste generating process, and that the process material inputs are consistent with the waste material parameters identified during radiography or visual examination 

• Record all changes to acceptable knowledge records • If discrepancies exist in the acceptable knowledge 

information for the reassigned waste matrix code, complete a nonconformance report, document the segregation of this container, and define the corrective actions necessary to fully characterize the waste 

(WAP B4, Section B4-3e) 

AK-38: Has the site project manager calculated the 

percent changes in waste matrix code based on AK and 

NDE/VE? Were accuracy evaluations assigned? Are 

these acceptable? (WAP B3, Section B3-9; WAC Appendix A, Section A.6.5) 

CCP-TP-005, Revision 18, Section 4.6, Attachment 14 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

AK Accuracy Rep

No containers wer

Knowledge as havexpected ranges foreport indicated thradionuclides are 

indicates that 239Pu 

most prevalent baisn’t enough data shift in expected Aan AK Accuracy ireassignment of W

based on HWN asbased on these cri

stream is 100%. 

AK-39: Are the following items addressed with respect to AK-NDA communication and the use of AK data by 

NDA personnel? 

CCP-TP-005, Revision 18, Section 4.4.22 

Review of objective evidence and interview of Steve Schafer and Sheri 

P976, P1084, NDA Personnel preparememo which addr
A-14 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH AK Checklist Insp

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Example

• Do procedures require the identification of AK data

limitations? 

• Are AK data and associated limitations communicated

to NDA personnel and is this required by procedure?

• How is AK used by NDA personnel? • Do AK and NDA personnel communicate and agree 

about the use of AK? 

• Is this agreement proceduralized? (WAC, Appendix A) 

Nance descriptions and r

prevalent radionuc

limitations. It also data will be used d

based default isoto

not yield adequate also addressed. 

AK-40: Have internal AK audits been performed? (WAP B4, Section B4-3d, g) 

CCP-TP-005, Revision 18, Section 4.5.1 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

WTS Quality Assu2009. The Audit odid not address thindicated that an acomprehensively wnot available for E

AK-41: If data consistently indicate discrepancies with acceptable knowledge information, the site increases sampling, reassesses the materials and processes that generate the waste, and resubmits waste stream profile information. (WAP B4, Sections B4-3b, B4-33) 

CCP-TP-005, Revision 18, Attachment 10 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

MPFPDD WSPF, (not available for that thus far, consto AK information 

AK-42: Are acceptable knowledge processes consistently applied among all generator sites, and does each generator site comply with the following data quality requirements for acceptable knowledge documentation: a. Precision - Precision is not applicable to AK (see 

Attachment B4) 

b. Accuracy - Accuracy is the degree of agreement 

between an observed sample result and the true value. 

The percentage of waste containers which require reassignment to a new waste matrix code is based onthe reevaluation of acceptable knowledge and sampling and analysis data will be reported as a measure of 

CCP-TP-005, Revision 18 Review of objective 

evidence and interview of Steve Schafer and Sheri 

Nance 

AK Accuracy RepTrend Report, MaSteve Schafer, Sheaddressed in AttacReport provides a including results otrend analysis resuQuality Control (Qassessments againRecords contain th
A-15 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH AK Checklist Insp

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Example

acceptable knowledge accuracy. Accuracy based on radionuclide content is typically assessed by comparing measured results with AK data. 

c. Completeness - Completeness is an assessment of the 

number of waste streams or number of samples collected to the number of samples determined to beuseable through the data validation process. The acceptable knowledge record must contain 100 percent of the information specified in Section B4-2. The usability of the acceptable knowledge information will 

be assessed for completeness during audits. 

d. Comparability - Data are considered comparable when 

one set of data can be compared to another set of data. Comparability is ensured through sites meeting the training requirements and complying with the minimum standards outlined for procedures that are used to implement the acceptable knowledge process. WAC Section A.6.5: Additionally, comparison of measured data with AK-derived or -based values, as applicable, 

provides a means to assess comparability on a waste

stream basis. 

e. Representativeness - Representativeness expresses the 

degree to which sample data accurately and precisely represent characteristics of a population. Representativeness is a qualitative parameter that will 

be satisfied by ensuring that the process of obtaining, 

evaluating, and documenting acceptable knowledge information is performed in accordance with the minimum standards established in Section B3. Sites also must assess and document the limitations of the acceptable knowledge information used to assign waste 

parameters. 

(WAP B3, Section B3-9) 

AK-43: Does the generator site address quality control 

by tracking its performance with regard to the use of 

acceptable knowledge by: (1) assessing the frequency of inconsistencies among information, and (2) documenting 

CCP-TP-005, Revision 18, CCP-QP-019 

Review of objective evidence and interview of Steve Schafer and Sheri 

Semi-annual Tren019 identifies itemIt identified the nu

were performed du
A-16 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH AK Checklist Insp

Required Technical Elements Procedure Location/ Adequacy Verification of Activity Example

the results of acceptable knowledge confirmation through radiography or visual examination? In addition, the acceptable knowledge process and waste stream documentation must be evaluated through internal assessments by quality assurance organizations and assessments by auditors or observers external to the organization (i.e., CBFO, NMED, EPA). (WAP B3, Section B3-9) 

Nance identified, signific

PDP results, resuletc. It was noted thINL that were not assayed drums wedrums were removTrend Report statetrends. The report Code Ls dealing w2009. This means of error as reporteto all other Trend were issued. 

AK-44: Did the generator site implement, or does it currently implement, process controls to ensure that prohibited items are documented and managed in accordance with site-specific certification plans? What process controls are in 

place to assess prohibited items and other waste 

characteristics (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 1 PR8, Attachment 6 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

Fast Scan (RTR); indicated a non-cealso be performeddetected containerhistoric NDE and 

AK-45: Does the generator site document, justify, and consistently delineate waste streams based on site-specific 

permit requirements or state-enforced agreements? How 

do these agreements impact waste characterization? (WAP B4, Section B4-3e) 

CCP-TP-005, Revision 18, Attachment 1 O16 

Review of objective evidence and interview of Steve Schafer and Sheri 

Nance 

AKSR MPFPDD; 

being performed i

agreement. D&D/outside of CCP. 
Revision No.: Site specific checklist A-17 

Attachment A.2 Non-Destructive Assay (NDA) Checklist 

EPA Inspection No.: EPA-HANFORD-CCP-10.05-8 NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B) Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

System Description Identify the NDA systems by name, location and number, as appropriate. 

Y General system information The GEA units identified as 

follows: GEA-A 104-ND-06-102A; GEA-B 104-ND-06-102B. 

- O

ain

Describe the system’s operational history including deployment at other DOE sites. 

Y General system information Both units were previously used for 

WIPP-related TRU assays at Hanford and had been approved for this use by EPA several times, most recently during EPA baseline inspection of Hanford (Non-CCP) in 2008. 

- E

I

For systems that have been deployed at multiple DOE sites document pertinent aspects 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 essentially 

unchanged with respect to hardware. Minor software changes have been made. 

- O

ain

System PerformanceIdentify the period of performance relevant to this inspection and if this NDA system has 

prior EPA approval(s). 

Y General system information The GEA units became operation 

for WIPP assays on March 2, 2010. 

- G

N

SBG

N

SB

Identify the number of waste containers this system assayed during the period of 

performance. Of these, indicate how many 

Batch Data Reports (BDRs) were assembled. And how many BDRs have been promoted through Project Level Review and are available for EPA’s evaluation. 

Y General system information A total of 237 containers assayed 

for both GEA units as of 4-21-10; 30 BDRs; 13 BDRs promoted through data generation level review; 12 BDRs through Site Project Manager review; 6 BDRs (3 from GEA-A and 3 from GEA-B) were provided for EPA review 

- G

RGR
Revision No.: Site specific checklist A-18 

Attachment A.2 Non-Destructive Assay (NDA) Checklist 

EPA Inspection No.: EPA-HANFORD-CCP-10.05-8 NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B) Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

General Reporting RequirementsAssay systems must report quantitative values and uncertainties for 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 233U, 234U, 238U, 90Sr, and 137Cs. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Both GEA units report quantitative values and uncertainties for 238Pu, 

239Pu, 240Pu, 242Pu, 241Am, 233U, 234U, 238U, 90Sr, and 137Cs. 

Y C

0SCRR(CV

Each container characterized and intended for disposal at WIPP must contain TRU waste. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Containers assayed on both GEA units meet criteria for TRU waste or they are removed via NCRs. 

Y G

RGR

NDA instruments and procedures must be 

appropriate for the waste streams being assayed. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Both GEA units are appropriate for the waste streams they are currently assaying. 

Y C

0SCRR(CV

NDA instruments and procedures result in 

unbiased values for the cumulative activity of the WIPP radionuclide inventory. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

GEA radionuclide values are acceptable for calculating the cumulative activity of the WIPP radionuclide inventory. 

Y C

0SCRR(CVRRRR
Revision No.: Site specific checklist A-19 

Attachment A.2 Non-Destructive Assay (NDA) Checklist 

EPA Inspection No.: EPA-HANFORD-CCP-10.05-8 NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B) Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

Some radionuclides are derived by the application of scaling factors or correlation techniques. Identify all radionuclides that are quantified in this manner. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Scaling factors are used to quantify 

234U and 90Sr based on correlations with 235U/238U and 137Cs, 

respectively. MGA and MGA-U are used and both software programs key on specific photons lines and use them to infer other radionuclides. 

Y C

0SCRR(CV

Assess the technical adequacy of the calculations involving the application of scaling factors and/or correlation techniques. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Scaling factors used to quantify 234U 

and 90Sr based on correlations with 

235U/238U and 137Cs are technically 

adequate. 

Y C

Identify the procedures that govern this function and where the results of these calculations are documented. 

Y The procedure that governs the 

application of scaling factors is CCP-TP-072, Revision 0 and the results are documented in the NDA BDRs. 

CBRGR

Acceptable Knowledge (AK)If isotopic ratios based on AK are used the values must be qualified by confirmatory testing. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Isotopic ratios are used in quantifying radionuclides for waste streams that have approved AKbased data. 

Y C

Do NDA personnel use AK derived isotopic values to calculate radionuclide values? If so, is this function performed according to a formal procedure? Assess the technical adequacy of this process(s). 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

NDA personnel using AK-derived 

isotopic values to calculate radionuclide values use a formal CCP technical procedure. 

Y C

BRGR

Identify the procedure and where the results of these calculations are documented. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The procedure for AK related calculations is CCP-TP-072, Revision 0 and results of these calculations are recorded in the 

NDA BDRs. 

Y C

BRGR
Revision No.: Site specific checklist A-20 

Attachment A.2 Non-Destructive Assay (NDA) Checklist 

EPA Inspection No.: EPA-HANFORD-CCP-10.05-8 NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B) Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

Isotopic DeterminationIdentify the radionuclides that are measured directly and the specific radiation type that is measured. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The radionuclides that are measured directly are all gamma (photon) emitters. 

Y G

LCR2

Identify the method(s) used to derive the isotopic contribution for the unmeasured radionuclides, e.g., MGA, FRAM or other technique. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The isotopic contributions for the unmeasured radionuclides are derived using MGA, MGAU and FRAM, as needed. 

Y C

IsD

G

Lower Level of Detection (LLD)The LLD for each NDA system must be determined. For multi modal systems this may require a separate determination for each mode, i.e., active neutron, passive neutron and gamma. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The LLDs for both GEA units have 

been determined and documented. 

Y C

0SCRR(CV

Site-specific environmental backgrounds and container-specific interferences must be accounted for in LLD determinations. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Site-specific backgrounds are taken in account for both GEA units. 

Y C

0SCRR(CV

NDA instruments performing TRU/NonTRU waste discrimination measurements are 

required to have a LLD no greater than 100 nCi/g. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Both GEA unit are used to discriminate TRU and Non-TRU wastes and each system has the required sensitivity, i.e., an LLD < 100 nCi/g. 

Y C

0SCRR(
Revision No.: Site specific checklist A-21 

Attachment A.2 Non-Destructive Assay (NDA) Checklist 

EPA Inspection No.: EPA-HANFORD-CCP-10.05-8 NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B) Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

CV

The technical basis and derivation for LLDs must be technically adequate and appropriately documented. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The technical basis and derivation for LLDs for both GEA units are technically adequate and appropriately documented. 

Y C

0SCRR(CV

For radionuclides that are not determined 

primarily by measurement an LLD analog, 

i.e., a reporting threshold must be used when it is technically feasible. Identify all instances when this occurs and the form of the documentation of these activities. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The radionuclides that are not determined primarily by measurement an LLD analog, i.e., a reporting threshold is used when it is technically feasible. All instances when this occurs are documented appropriately. 

Y C

0SCRR(CV

Identify any/all instances where an LLD value for a non-measured radionuclide is not 

provided basis on a lack of technical 

feasibility. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Any/all instances where an LLD value for a non-measured radionuclide is not provided basis on a lack of technical feasibility are documented. 

Y C

0SCRR(CV

Are LLD values container/assay event specific or are typical LLD values applied to a class or type of wastes, i.e., those with similar attributes? If LLD values are not container/assay event specific identify the attributes or characteristics whereby waste 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

LLD values have been determined for classes of wastes by density to demonstrate adequate sensitivity over the operational range, however, each assay event produces a unique LLD. 

Y C

0SCRR(
Revision No.: Site specific checklist A-22 

Attachment A.2 Non-Destructive Assay (NDA) Checklist 

EPA Inspection No.: EPA-HANFORD-CCP-10.05-8 NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B) Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

containers are grouped. C

V

Total Measurement Uncertainty (TMU)The method used to calculate the TMU for all required quantities must be documented and technically justified. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The method used to calculate the TMU for all required quantities is documented and technically 

justified. 

Y C

MfoS

TMU determination accounts for all sources of uncertainty, specifically 

• Random errors • Calibration • Isotopic determination • Matrix inhomogeneity • Difference between calibration 

assumptions and actual waste 

• Non uniform source distribution 

• End effects • Self absorption • Transmission source • Self shielding • Neutron multiplication 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The TMU determination accounts for all sources of uncertainty, specifically: 

• Random errors • Calibration • Isotopic determination • Matrix inhomogeneity • Difference between calibration 

assumptions and actual waste 

• Non uniform source distribution • End effects • Self absorption • Transmission source • Self shielding • Neutron multiplication 

Y C

MfoS

Methods to determine TMU must be documented, reviewed and approved by CBFO for each NDA instrument. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The TMU report for both GEA units was approved by CBFO. 

 C

MfoS
Revision No.: Site specific checklist A-23 

Attachment A.2 Non-Destructive Assay (NDA) Checklist 

EPA Inspection No.: EPA-HANFORD-CCP-10.05-8 NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B) Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

System CalibrationEach NDA instrument must be calibrated 

before its initial use. Determine the date of 

the system’s calibration of record and where this is documented. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The energy calibrations for both GEA units that were established by Hanford outside of CCP are the calibrations of record. Both GEA units had new efficiency calibrations performed by CCP. 

Y C

0SCRR(CV

The range of applicability of the system’s calibration(s) must be specified in site 

procedures or other formal documentation. 

Identify the manner in which the range is expressed, i.e., curies or Pu/SNM mass for activity and salient physical characteristics for matrix. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The ranges of both GEA units are expressed in terms of nuclear material content (grams of WG Pu) and matrix (material density in g/cm3). 

Y C

0SCRR(CV

Any matrix/source surrogate waste combinations must be representative of the activity ranges and relevant waste matrix characteristics currently in use or planned for use by the system. The system must be calibrated to 100% recovery. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Matrix/source surrogate waste combinations used are representative of the activity ranges and relevant physical characteristics of the matrices currently measured or planned for use by the system. The system is calibrated to 100% recovery. 

Y C

GCVGEA VGEB V

The use of consensus standards for calibration is required, when such standards exist. If consensus standards do not exist, the calibration technique must be approved by CBFO. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

ASTM C-1133-03 is the consensus standard that was used for calibration of both GEA units. 

Y C

GCV
Revision No.: Site specific checklist A-24 

Attachment A.2 Non-Destructive Assay (NDA) Checklist 

EPA Inspection No.: EPA-HANFORD-CCP-10.05-8 NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B) Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

Identify the specific consensus standards that were used for the system calibration or, in their absence, the alternate calibration technique. Evaluate the CBFO approval of the alternate technique. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

See answer to previous checklist item. 

Y S

it

Primary standards must be obtained from suppliers maintaining a nationally accredited measurement program. Identify the nationally accredited measurement program. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Primary gamma standards have 

been obtained from LANL (WG Pu 

standards) and North American Scientific (mixed gamma sources). Both suppliers maintain a nationally accredited measurement program that has been identified and appropriately documented. 

Y C

0SCRR(CV

List the standards used for calibration and verify the pedigree of each standard. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The calibration standards are listed in the calibration reports and the 

pedigree of each has been verified. 

Y C

0SCRR(CV

Calibration Verification & ConfirmationVerification of an NDA instrument’s calibration must be performed after any of the following occurrences: major system repairs and/or modifications, replacement of the system’s components, significant changes to the system’s software, and relocation of the system. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The calibration of both GEA units has been verified performed and documented as required. 

Y C

GCVGEA VGEB V
Revision No.: Site specific checklist A-25 

Attachment A.2 Non-Destructive Assay (NDA) Checklist 

EPA Inspection No.: EPA-HANFORD-CCP-10.05-8 NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B) Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

Recalibration of the system must occur if the calibration verification demonstrates that the system’s response has significantly changed. 

NA CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Not applicable, theses systems have 

not been relocated. 

NA 

The system calibration must be confirmed by 

performing replicate measurements of a noninterfering matrix. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The system calibration has been confirmed by performing replicate measurements of a non-interfering matrix. 

Y C

RGSCRR(CV

Replicate measurements must be performed with containers of the same nominal size and according to the same procedures used for actual waste assays. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Replicate measurements have been 

performed with containers of the 

same nominal size and according to the same procedures as those used for actual waste assays. 

Y C

0SCRR(CV

Replicate measurements must be performed using nationally recognized standards or standards derived from nationally recognized standards that span the range of use of the instrument with respect to disintegration rate and/or matrix effects. Identify all standards that were used and indicate their application (verification or confirmation). 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Replicate measurements have been 

performed using nationally 

recognized standards or standards derived from nationally recognized standards that span the range of use of the instrument with respect to disintegration rate and/or matrix effects. All standards that were used have been identified and their application documented. 

Y C

0SCRR(CV

Identify the nationally accredited measurement program. List the standards used for verification/confirmation and verify 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The nationally accredited measurement program has been identified and the pedigree of the gamma and WG Pu standards used 

Y C

0SC
Revision No.: Site specific checklist A-26 

Attachment A.2 Non-Destructive Assay (NDA) Checklist 

EPA Inspection No.: EPA-HANFORD-CCP-10.05-8 NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B) Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

the pedigree of each standard. for verification and/or confirmation 

has been verified. 

RR(CV

The standards used for calibration confirmation must not be the same sources as those used for the system’s calibration of record. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The WG Pu standards used for calibration confirmation are not the same as the gamma sources used for the system’s calibration of record. 

Y C

0SCRR(CV

Requirements for accuracy, expressed as %R, and precision, expressed as %RSD, must be met as specified in DOE/WIPP-02-3122, Appendix A, Table A-3.2 for precision and ±30% for accuracy. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Requirements for accuracy and 

precision have been met as specified 

in DOE/WIPP-02-3122, Appendix A, Table A-3.2 for precision and ±30% for accuracy. 

Y C

0SCRR(CV

Quality ControlAll radioassay and data validation must be 

performed by appropriately trained and 

qualified personnel. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

All radioassay and data validation has been performed by appropriately trained and qualified 

personnel. 

Y G

RGR

Identify the name, title and function of all 

personnel performing NDA data validation. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The name, title and function of all 

personnel performing NDA data 

validation are documented. 

Y G

RGR

Requalification of personnel must be based on evidence of continued satisfactory 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Requalification of personnel is 

based on evidence of continued 

Y H

In
Revision No.: Site specific checklist A-27 

Attachment A.2 Non-Destructive Assay (NDA) Checklist 

EPA Inspection No.: EPA-HANFORD-CCP-10.05-8 NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B) Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

performance and must be performed at least 

every two years. 

satisfactory performance and is current. 

2

All computer programs, including spreadsheets used for data reduction or analysis, must meet the applicable requirements in the CBFO QAPD. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Not assessed during this inspection. NA N

in

The site must participate in relevant measurement comparison programs sponsored or approved by CBFO, including the NDA PDP. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Hanford-CCP participated in the CBFO-sponsored NDA PDP, Cycle 17A (May 2010 distribution) by assaying S5000 wastes containing debris, glass, and sludge. 

Y 

Background and Performance ChecksAssay system background measurements must be taken daily, unless otherwise approved by CBFO. Determine the form of CBFO approval documentation of the alternate approach to backgrounds, if applicable. Contributions to backgrounds from nearby radiation sources must be carefully controlled, or more frequent 

backgrounds must be measured. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Daily background measurements have been taken and recorded daily. Contributions to backgrounds from nearby radiation sources (i.e., other waste drums stored or staged inWRAP) have been carefully controlled. 

Y G

RGR

Assess how often background radiation was 

problematic to the extent that measurement personnel had to make adjustments. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Background records document the 

performance of both GEA units 

over time. 

Y G

RGR

Identify the criteria used to evaluate instrument backgrounds and assess the technical adequacy of this criterion, i.e., statistical or administrative. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Backgrounds have been evaluated against a technically appropriate acceptance criterion and the nature and results of these evaluations have 

been documented. 

Y G

RGR

Identify the number of data points required to derive the initial control limit. At what interval(s) will new limits be calculated? 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The number of data points required to derive the initial control limit and the interval(s) at which will new limits be calculated are documented. 

Y C
Revision No.: Site specific checklist A-28 

Attachment A.2 Non-Destructive Assay (NDA) Checklist 

EPA Inspection No.: EPA-HANFORD-CCP-10.05-8 NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B) Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

System performance checks must be 

performed at least once per operational day. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Performance checks have been 

performed at least once per 

operational day and all checks have 

been documented. 

Y G

RGR

System performance checks must include, as applicable, efficiency, matrix correction checks, and systems peak position and resolution for spectrometric systems. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Performance checks include efficiency, matrix correction checks, and peak position and resolution checks. 

Y G

RGR

At a minimum of once per operational week an interfering matrix must be assayed to assess the long term stability of the NDA instrument and its matrix corrections and how this performance is documented. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

An interfering matrix is used to assess the long term stability of the GEA units and their matrix corrections at least once per operational week. This activity is appropriately documented. 

Y C

0SCRR(CV

Interfering surrogate waste matrices must be constructed in a way that the salient matrix characteristics do not change over time. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Interfering surrogate waste matrices have been constructed such that the salient matrix characteristics do not change over time. 

Y C

RGSCRR(CV

The radionuclide sources used for 

performance checks must be long-lived and 

of sufficient strength (activity) to provide statistically sufficient results over a short measurement time. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The WG Pu and gamma sources used for performance checks are long-lived and are of sufficient activity to provide statistically sufficient results over a short measurement time. 

Y C

RGSCRR(
Revision No.: Site specific checklist A-29 

Attachment A.2 Non-Destructive Assay (NDA) Checklist 

EPA Inspection No.: EPA-HANFORD-CCP-10.05-8 NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B) Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

CV

Radioactive sources are decay corrected as a function of their physical half life, as appropriate, specifically133Ba, 252Cf, 137Cs, 75Se and 109Cd. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Radioactive sources are decay corrected as a function of their 

physical half life, as appropriate. 

Y C

RGSCRR(CV

Performance checks must be quantitative and 

based on 2 and 3 sigma limits. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Performance checks are quantitative and based on 2 and 3 sigma limits. 

Y C

RGSCRR(CV

Data ManagementAll radioassay data must be reviewed and approved by qualified personnel before being reported to WWIS. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

All radioassay data have been reviewed and approved by qualified 

personnel before being reported to 

WWIS. 

Y C

BRGR

Identify the name, title and function of the individual(s) performing technical review and approval of NDA BRDs. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

The name, title and function of the individual(s) performing technical review and approval of NDA BRDs are documented on the LOQI and in CCP training records. 

Y C

HIn2
Revision No.: Site specific checklist A-30 

Attachment A.2 Non-Destructive Assay (NDA) Checklist 

EPA Inspection No.: EPA-HANFORD-CCP-10.05-8 NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B) Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

Radioassay BDRs must consist of the following elements: 

• Testing facility name, testing batch 

number, container numbers, and signature of the Site Project Officer (SPO) or designee(s) 

• Table of Contents • Background and performance check data 

or control charts for the relevant time 

period. 

• Data validation per the QAPD and site 

procedures 

• Separate testing report sheets for each 

container. 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Radioassay BRDs consist of the following elements: 

• Testing facility name, testing 

batch number, container 

numbers, and signature of the Site Project Officer (SPO) or designee(s) 

• Table of Contents • Background and performance 

check data or control charts for the relevant time period. 

• Data validation per the QAPD 

and site procedures 

• Separate testing report sheets 

for each container. 

Y G

RGR

Radioassay data sheets must include: 

• Title “Radioassay Data Sheet” • Method/procedure used • Date of radioassay • Activities and associated TMU for 

individual radionuclides 

• TRU alpha concentration and its 

associated TMU 

• Operator signature • Reviewer signature 

Y CCP-PO-002, CCP Waste 

Certification Plan, Revision 24 

Radioassay data sheets include: 

• Title “Radioassay Data Sheet” • Method/procedure used • Date of radioassay • Activities and associated TMU 

for individual radionuclides 

• TRU alpha concentration and 

its associated TMU 

• Operator signature • Reviewer signature 

Y G

RGR

The following nonpermanent records must be maintained at the radioassay-testing facility or forwarded to the site project office: 

• Testing batch reports 

NA NA Not assessed during this 

inspection. 

NA 
Revision No.: Site specific checklist A-31 

Attachment A.2 Non-Destructive Assay (NDA) Checklist 

EPA Inspection No.: EPA-HANFORD-CCP-10.05-8 NDA System: Gamma Energy Analysis Units A & B (GEA-A & GEA-B) Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

• All raw data, including instrument 

readouts, calculation records, and radioassay QC results 

• All applicable instrument calibration 

reports 
Revision No.: Site specific checklist A-32 

ATTACHMENT A.3 REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH RTR Checklist Inspect

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Objective Evide

RTR-1: Site procedures identify required training and qualifications for RTR personnel. 

CCP-TP-028, Revision 3 CCP-QP-002, Revision 27 

Operator training was consistent with applicable procedures. Operator certification is current. OJT was documented for each operator. Operators are re-qualified every two years. RTR operators passed a training drum test that includes items common to the waste streams examined at the site (biannually). RTR operators receive training on the waste matrix parameters and typical packaging configurations expected in each waste stream. Current LOQI. 

The EPA inspectors reviewed demonstration of capability reoperators were adequately trawere complete. Operators use 

only qualified operators perfo

Objective evidence:

1. RTR BDRs and audio/vis

for selected drums contaiRLRTRA0002, and RLR

2. Written and audio/visual 

Demonstration Data SheeWaste for various RTR o

3. Qualification card and tra

operators/ITRs 

4. CCP NDE Test Drum Inv

NDETEST-02, -03, and -

5. List of currently qualified 

RTR-2: Site procedure(s) provide complete instructions for operators to 

perform the RTR examination and 

completion of the associated documentation. 

CCP-TP-053, Revision 7 

RTR operator adequately explained the 

process followed for examining a drum and 

entering data into data forms (whether hard copy or electronic data entry is used). 

Prior to observing the RTR evRL0056204, EPA interviewed that they were knowledgeable 

performed and what records w

was able answer all questions Objective evidence:

1. RTR BDRs and audio/vis

for selected drums contaiRLRTRA0002, and RLR

2. SOP CCP-TP-053, Attach3. List of currently qualified 

RTR-3: The RTR procedure(s) require an image quality check to be 

performed. 

CCP-TP-053, Revision 7, Section 4.3 

Operator adequately explained how the acceptability of an image is determined. Image quality (IQI) check is performed once 

per day. 

Performance of the image quality check is documented and recorded. 

EPA inspectors confirmed adh

verification requirements thro

operators, observation of a RTwritten BDRs and audio/video review the IQI for batch RLRobserved drum was part of). Objective evidence:

1. RTR BDRs and audio/vis
Revision No.: Site specific checklist A-33 

ATTACHMENT A.3 REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH RTR Checklist Inspect

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Objective Evide

for selected drums contaiRLRTRA0002, and RLR

RTR-4: The procedure allows the operator to adjust the RTR to accommodate the physical properties of the waste and waste containers likely to be encountered at the site. 

CCP-TP-053, Revision 7, Section 4.4 

Operator could identify applicable policies and procedures governing the operation of RTR equipment. The RTR system could be adjusted. High-density material was examined with the X-ray device set on the maximum voltage and low density material at a lower voltage. Operator adequately explained what is done if an image is unacceptable (e.g., the waste is solidified or the container is lead-lined). 

EPA inspectors observed the Rcontainer RL0056204 on RTR completed BDRs to ensure thacomplete and adequately recoexamination, the RTR operato

to ensure identification of all 

was able to explain dispositioimpenetrable image is observeObjective evidence:

1. RTR BDRs and audio/vis

for selected drums contaiRLRTRA0002, and RLR

2. List of currently qualified 

RTR-5: CCP-TP-053, 

Revision 7, Section 4.3 

RTR tape is high quality, the sound track is audible, and the required information is contained on the audible portion of the tape. The RTR tape is consistent with the data 

package for the same drum. 

EPA inspectors confirmed adh

verification requirements thro

operators, observation of a RTwritten BDRs and audio/video Objective evidence:

1. RTR BDRs and audio/vis

for selected drums contaiRLRTRA0002, and RLR

RTR-6: There is a procedure for determining whether the waste matches the waste stream description and Waste Matrix Code, and for determining Waste Material Parameters and weights. 

CCP-TP-053, Revision 7, Section 4.4, Table 3, Attachment 2 

The procedure is adequately implemented. Operators verify that the waste matches the waste stream description. Waste Matrix Code is verified. If not, corrective action is taken. WMP weights are estimated by compiling an inventory of waste items and residual/packaging materials. Does the RTR operator use a standard weight lookup table to provide an estimate of WMP weights? If so, has the table been updated to reflect additional information gained through 

EPA inspectors observed the RRL0056204 on RTR unit A anBDRs to ensure that examinatadequately recorded. Attachmused to record data and other WMP weights were estimated weight table provided in the Rwere obtained from Standing Objective evidence:

1. RTR BDRs and audio/vis

for selected drums contaiRLRTRA0002, and RLR

2. SOP CCP-TP-053, Attach
Revision No.: Site specific checklist A-34 

ATTACHMENT A.3 REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH RTR Checklist Inspect

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Objective Evide

previous RTR/VE exams or updated AK 

information? 

3. List of currently qualified 

RTR-7: The RTR procedure 

provides instructions for identifying prohibited items and for processing 

drums containing prohibited items. 

CCP-TP-053, Revision 7, Section 4.4, Table 1, Attachment 2 

Operator could name prohibited items. Operator adequately explained how the 

presence of free liquids is determined. 

Operator’s explanation of required actions if 

prohibited items were encountered was 

consistent with procedure. Corrective actions are taken when necessary. 

EPA inspectors observed the RRL0056204 on RTR unit A. T

performed in accordance with 

uncontrolled and incorrect liqused by the operator. This cal

piece of scrap paper and did n

official record. EPA Concern 001CR was generated to addrThe RTR operator, who perfodemonstration, was able to dewhat actions would be taken iduring RTR examination. Although no NCRs had been 

batches, EPA reviewed NCR-

NCRs were documented corre

the RTR operators understood Objective evidence:

1. RTR BDRs and audio/vis

for selected drums contaiRLRTRA0002, and RLR

2. NCR-RL-0642-10 

3. List of currently qualified 

4. Measurement Conversion 

RTR-8: RTR procedures include the required QC examinations, evaluation accuracy and reproducibility of the RTR process 

CCP-TP-053, Revision 7, Section 4.5, 4.6 

An independent replicate scan is performed on one waste container per day or on one container per testing batch (whichever is less frequent). An independent observation of one scan (not the replicate) is performed, by a qualified RTR operator (anyone but the initial RTR operator). 

EPA reviewed 3 BDRs and de

QC was performed for these bObjective evidence:

1. RTR BDRs and audio/vis

for selected drums contaiRLRTRA0002, and RLR

RTR-9: Procedure(s) contain standardized forms for recording 

CCP-TP-053, Revision 7, Attachments 1 

RTR operator adequately explained the 

process followed for examining a drum and 

entering data into data forms (whether hard 

A qualified RTR operator per

second person electronically e

This second person is not requ
Revision No.: Site specific checklist A-35 

ATTACHMENT A.3 REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH RTR Checklist Inspect

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Objective Evide

RTR data and 2 copy or electronic data entry is used). 

Direct data entry into an electronic form is done by the RTR operator using a computer while the operator is still in the RTR booth. The electronic data file undergoes the same quality control (QC) checks used for handwritten data entries. 

operator. WMP weights were estimated weight table provided in the Rwere obtained from Standing Objective evidence:

1. RTR BDRs and audio/vis

for selected drums contaiRLRTRA0002, and RLR

2. SOP CCP-TP-053, Revis3. Standing Order CCP-SO-

RTR-10: Site procedures require review of Batch Data Reports (BDRs) at the data generation and project level 

CCP-TP-053, Revision 7, Attachment 3 CCP-TP-001, Revision 17, Attachment 2 

Data generation level reviews are performed and documented (ITR). Project level reviews are performed and documented (SPM). 

EPA verified that the 3 BDRs inspection had been reviewed 

project level. 

Objective evidence:

1. BDRs RLRTRA0001, RL

RLRTRA0003 
Revision No.: Site specific checklist A-36 

ATTACHMENT A.4 VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH VE Checklist Insp

Establishment of Required 

Technical Elements in 

Procedures 

Location Execution of Procedures Objective Evidenc

VE-1: Site procedures identify required training and qualifications for VE personnel. 

CCP-QP-002, Revision 27 

Visual Examination Expert’s (VEE) explanation of job duties was consistent with applicable procedures. VE personnel’s training was consistent with applicable procedures. VE personnel’s certification is current. VE personnel are re-qualified every two years. VE personnel received training on specific waste generating processes, typical 

packaging configurations, WMPs expected 

to be found in each Waste Matrix Code. 

EPA reviewed training records to ensucurrent. EPA interviewed operators an

received training about EPA’s regulatidid not have any knowledge of these s

Hanford-CCP-CH-VE-10-005F to add

The VEE was appointed in March of 2site. EPA issued Concern Hanford-CCPthis issue. The CCP Site Project Managclosing meeting that this was a problem all VE’d containers (except those contaand RLVEPF0023). 

Objective evidence:

1. Visual Examination BDRs RLVEP2. List of currently qualified VE perso

3. Qualification card and training reco

one VE operator/Visual Examinatio

4. Letter appointing the VEE, March 5. CCP-TP-113, CCP Standard Conta

Examination, Revision 13, March 1

VE-2: Procedures and technical guidance documents provide complete instructions for 

performing VE. 

CCP-TP-113, Revision 13 

The site uses AK to identify the waste matrix code category and to estimate waste material parameters present. Procedures are sufficiently detailed to enable the operator to determine if a waste container meets the criteria of '194.24 with regard to identifying applicable parameters with waste limits. Establish standard nomenclature, based on current site practice, so that all staff recognize waste by the same descriptors. 

SOP CCP-TP-113 is a well-established instructions necessary to perform VE. Tstandard weights for common waste ite

Objective evidence:

1. Visual Examination BDRs RLVEP2. List of currently qualified VE perso

3. Qualification card and training reco

one VE operator/Visual Examinatio

4. CCP-TP-113, CCP Standard Conta

Examination, Revision 13, March 1

VE-3: Procedure requires an audio/visual recording of the VE event to be made. 

CCP-TP-113, Revision 13 

VEE is responsible for overall VE activities. 

VEE/operator’s explanation of how to operate the data recording system was 

The EPA team interviewed this projectVEO/ITRs and reviewed 2 BDRs to deimplemented as written. 
Revision No.: Site specific checklist A-37 

ATTACHMENT A.4 VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH VE Checklist Insp

Establishment of Required 

Technical Elements in 

Procedures 

Location Execution of Procedures Objective Evidenc

consistent with applicable procedures. The video camera was focused prior to the start of VE. An audio/videotape is made of the waste container exam and maintained as a nonpermanent record. Data on the audio/visual recording is consistent with documentation. 

No audio/visual recording is made of th

qualified VEOs perform VE. 

Objective evidence:

1. Visual Examination BDRs RLVEP2. List of currently qualified VE perso

3. Qualification card and training reco

one VE operator/Visual Examinatio

4. Letter appointing the VEE, March 5. CCP-TP-113, CCP Standard Conta

Examination, Revision 13, March 1

VE-4: There is a procedure for handling instances when the VE Expert is unable to see through the inner plastic bags/ packages/ containers of waste. 

CCP-TP-113, Revision 13 

The VEE has decision making criteria for assessing the need to open the 

bags/packages in order to identify all of 

their contents. If the bags are not opened, a brief written description of the contents of the bags is 

prepared with estimates of the amount of 

each waste type in the bags. 

The VEE is not necessarily in the operaevents. The VEOs can contact the VEE 

assignment of WMPs and any other iss

being Ve’d and containerized comes fr

glove boxes in the PFP Building and co

processed is easily recognizable. 

Objective evidence:

1. Visual Examination BDRs RLVEP2. List of currently qualified VE perso

3. Qualification card and training reco

one VE operator/Visual Examinatio

4. Letter appointing the VEE, March 5. CCP-TP-113, CCP Standard Conta

Examination, Revision 13, March 1

VE-5: The VE procedure requires verification of Waste Matrix Code and WMP weights. 

CCP-TP-113, Revision 13 

If an automated data entry system is used, data entry VE personnel could navigate through the various screens. A VE data form is used to document the waste matrix code and estimated WMP weights of the waste. VE staff have access to standardized charts or tables to aid in the consistent estimation/assignment of weights, waste material parameters, and waste matrix codes. 

Raw data is collected during VE and tr

sheets outside of the VE area. This varidue to the safety concerns associated wto wear full respirator suits. The BDRs AT previous baseline inspections, the Ethe VE event for a selected container. Bdescribed above, EPA’s inspection of Vdocuments and records, and interview o

Objective evidence:

1. Visual Examination BDRs RLVEP2. List of currently qualified VE perso
Revision No.: Site specific checklist A-38 

ATTACHMENT A.4 VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH VE Checklist Insp

Establishment of Required 

Technical Elements in 

Procedures 

Location Execution of Procedures Objective Evidenc

The estimated or weighed WMP weights are determined by compiling an inventory of waste items, residual materials and 

packaging materials. 

The items on the inventory list are sorted by WMP and combined with a standard weight look-up table to provide an estimate of WMP weights. References tables are updated as site gains information from VE. VEE verifies Waste Matrix Code and recommends changes as needed. 

3. Qualification card and training reco

one VE operator/Visual Examinatio

4. Letter appointing the VEE, March 

5. CCP-TP-113, CCP Standard Conta

Examination, Revision 13, March 1

VE-6: Procedure provides instructions for processing of containers with prohibited items. 

CCP-TP-113, Revision 13 

VE operator/expert’s explanation of required actions if prohibited items were encountered was consistent with procedure. The VE operator describes any liquids found, including a description of their location in the container and estimated volume. Other prohibited items, including sealed containers are identified and segregated. 

Waste items are broken down by speciaVEOs can verify that no prohibited itemVE procedure provides instructions for if they are found. 

Objective evidence:

1. Visual Examination BDRs RLVEP2. List of currently qualified VE perso

3. Qualification card and training reco

one VE operator/Visual Examinatio

4. Letter appointing the VEE, March 5. CCP-TP-113, CCP Standard Conta

Examination, Revision 13, March 1

VE-7: Personnel can describe how an NCR is 

initiated. 

Review of training records and intervieenabled the EPA inspectors to determi

necessary. Objective evidence:

1. Visual Examination BDRs RLVEP2. List of currently qualified VE perso

3. Qualification card and training reco

one VE operator/Visual Examinatio

4. Letter appointing the VEE, March 
Revision No.: Site specific checklist A-39 

ATTACHMENT A.4 VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH VE Checklist Insp

Establishment of Required 

Technical Elements in 

Procedures 

Location Execution of Procedures Objective Evidenc

5. CCP-TP-113, CCP Standard Conta

Examination, Revision 13, March 1

VE-8: CCP-TP-113, 

Revision 13 

The gross weight of the waste container (container plus contents) is recorded on the VE data form. Volume utilization of the container is documented. 

Attachment 2, CCP Waste Visual ExamTP-113 requires operators to record vothis by review of 2 BDRs. Gross weight of the container is determand hence was not reviewed. 

Objective evidence:

1. Visual Examination BDRs RLVEP2. List of currently qualified VE perso

3. CCP-TP-113, CCP Standard Conta

Examination, Revision 13, March 1

VE-9: CCP-TP-113, 

Revision 13 CCP-QP-005, Revision 18 

The procedure is adequately implemented. Corrective actions are taken when necessary. 

EPA determined by review of completwas implemented as written. Objective evidence:

1. Visual Examination BDRs RLVEP2. List of currently qualified VE perso

3. CCP-TP-113, CCP Standard Conta

Examination, Revision 13, March 1

VE-10: Site procedure(s) require data generation and 

project level reviews of Batch 

Data Reports (BDRs). 

CCP-TP-113, Revision 13 CCP-TP-001, Revision 17, Attachment 1 

BDRs contain all required information. Data generation and project level reviews are complete. 

EPA inspectors reviewed 2 VE BDRs tinformation was recorded and that the B

both data generation and project level. 

problems with the BDRs. 

Objective evidence:

1. Visual Examination BDRs RLVEP2. List of currently qualified VE perso

3. CCP-TP-113, CCP Standard Conta

Examination, Revision 13, March 1
Revision No.: Site specific checklist A-40 

 ATTACHMENT A.5 WIPP WASTE DATA SYSTEM (WDS) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH WDS Checklist Inspe

Establishment of Required 

Technical Elements in Procedures Location Execution of Procedures Objective Eviden

WDS-1: WDS and Data Entry Personnel must be trained to assess data and properly enter data into the Waste Data System (WDS). 

CCP-QP-002, Revision 27 CCP-TP-030, Revision 27 

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

The EPA inspections reviewed th

training records for the WCO whdemonstration. The training recor

except for training on the new WDHanford-CCP-CH-WDS-10-002CCP training procedure CCP-QP[C.3] requires Waste Certification 

demonstrate proficiency in WWI

However, WDS is not specifically 

procedure although this is the onl

reference section of CCP-TP-030Manager indicated that the procedentry are being revised at this tim

Objective evidence:

1. CCP-TP-030, Revision 27 

2. WCO qualification card and 

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

Y 

CCP-TP-030, Revision 27, Section 4.1 

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

The Data Administrator is requirethe request from CCP and DA res

communications. This type of com

rescind access as necessary. EPA 

from the DA eliminating a person

Objective evidence:

1. CCP-TP-030, Revision 27 

2. WCO qualification card and 

3. DA email rescinding databas

WDS-3: Y 

CCP-TP-030, Revision 27, Sections 3.0, 4.0 

Employee’s explanation of job duties was consistent with applicable procedures. WCO and WCA adequately explained how data are assessed, input, and transferred into WDS. 

The EPA team interviewed an exduring the on-site inspection. The changes between WDS and WWthe WCO to change data in WDSinformation about WDS and EPA demonstration, EPA determined tuploading and retrieving charactedata. 
Revision No.: Site specific checklist A-41 

 ATTACHMENT A.5 WIPP WASTE DATA SYSTEM (WDS) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH WDS Checklist Inspe

Establishment of Required 

Technical Elements in Procedures Location Execution of Procedures Objective Eviden

1. CCP-TP-030, Revision 27 

2. Waste Container Data Repor

and RL0063034 

3. CCP Correlation of Containe

Batch Data Reports, waste st

4. WDS data entry summary, ch

certification, spreadsheet for RL0063034, RL0063014, RL

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

Y 

CCP-TP-030, Revision 27, Section 4.3, Table 1 

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

performed and review checklists are 

complete. 

Only complete and validated BDR The EPA inspectors traced a randcontainer (LA00000064320 in SWemplacement back to the original 

verify upload of compliant data aretrieve certification data. 1. CCP-TP-030, Revision 27 

2. Waste Container Data Repor

and RL0063034 

3. CCP Correlation of Containe

Batch Data Reports, waste st

4. WDS data entry summary, ch

certification, spreadsheet for 

RL0063034, RL0063014, RL

WDS-5: Y 

CCP-TP-030, Revision 27, Section 4.4, Table 1 

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

The new WDS template Excel spdata entry and review as WWIS. uploading data. 1. CCP-TP-030, Revision 27 

2. WDS data entry summary, ch

certification, spreadsheet for RL0063034, RL0063014, RL

3. CCP-QP-022, Software Qual

Attachment 3, Software Prob

Request for WDS Master Te1 and 2 

4. WCO qualification 

WDS-6: Y Verify that there are no unresolved NCRs Verified by email from the SPM. 
Revision No.: Site specific checklist A-42 

 ATTACHMENT A.5 WIPP WASTE DATA SYSTEM (WDS) CHECKLIST 

EPA Inspection No.: EPA-Hanford-CCP-CH-04.10-8 Hanford-CCP CH WDS Checklist Inspe

Establishment of Required 

Technical Elements in Procedures Location Execution of Procedures Objective Eviden

CCP-TP-030, Revision 27, Section 4.4.4 

for containers. 1. CCP-TP-030, Revision 27 

2. Waste Container Data Repor

and RL0063034 

3. CCP Correlation of Containe

Batch Data Reports, waste st

4. WDS data entry summary, ch

certification, spreadsheet for 

RL0063034, RL0063014, RL

WDS-7: Resolution of data deficiencies 

Y 

CCP-TP-030, Revision 27, Section 4.5.5 

WDS Administrator rejects data via email. 

NCR 

The WDS processes are similar to 

have the internal checks that can pcompliant data. 

1. CCP-TP-030, Revision 27 

2. Waste Container Data Repor

and RL0063034 

3. WDS data entry summary, ch

certification, spreadsheet for 

RL0063034, RL0063014, RL

WDS-8: Records retention Y 

CCP-TP-030, Revision 27, Section 5.0 CCP-QP-008, Revision 15 

QA/Lifetime records:

WDS Master Template Correspondence, including container rejection emails QA/Nonpermanent:

CDS Database (electronic) 

Only the template could be verifi

inspection because of the limited lack of an approved WSPF). 

1. CCP-TP-030, Revision 27 

2. CCP-QP-022, Software Qual

Attachment 3, Software ProbRequest for WDS Master Te

1 and 2 
Revision No.: Site specific checklist A-43 
B-1 

ATTACHMENT B.1 REPLICATE TESTING DATA FOR CONTAINER RL0063023, GE

Quantity of Interest 

Original Measurement Replicate No. 1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 2.60E-02 7.38E-03 2.84E-01 2.43E-02 6.78E-03 2.79E-01 2.74E-02 239Pu Activity (Ci) 2.68E-01 6.67E-02 2.49E-01 2.87E-01 7.15E-02 2.49E-01 2.73E-01 240Pu Activity (Ci) 8.97E-02 2.27E-02 2.53E-01 6.77E-02 1.72E-02 2.54E-01 6.53E-02 242Pu Activity (Ci) 7.82E-06 2.16E-06 2.76E-01 5.56E-06 1.54E-06 2.77E-01 5.40E-06 241Am Activity (Ci) 3.23E-02 8.50E-03 2.63E-01 5.43E-02 1.44E-02 2.65E-01 4.18E-02 90Sr Activity (Ci) 1.09E-07 2.96E-08 2.72E-01 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 9.94E-08 2.69E-08 2.71E-01 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 5.80E+03 9.93E+02 1.71E-01 6.04E+03 1.05E+03 1.74E-01 5.67E+03 232U Activity (Ci) 3.58E-08 2.05E-08 5.73E-01 0.00E+00 N/A 0.00E+00 0.00E+00 237Np Activity (Ci) 4.71E-07 1.25E-07 2.65E-01 0.00E+00 N/A 0.00E+00 0.00E+00 Quantity of Interest 

Replicate No. 3 Replicate No. 4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 1.67E-02 5.20E-03 3.11E-01 2.35E-02 6.56E-03 2.79E-01 1.59E-02 239Pu Activity (Ci) 2.74E-01 6.83E-02 2.49E-01 2.74E-01 6.82E-02 2.49E-01 2.66E-01 240Pu Activity (Ci) 4.57E-02 1.19E-02 2.60E-01 6.55E-02 1.66E-02 2.53E-01 6.56E-02 242Pu Activity (Ci) 3.29E-06 9.74E-07 2.96E-01 5.29E-06 1.46E-06 2.76E-01 5.39E-06 241Am Activity (Ci) 5.08E-02 1.34E-02 2.64E-01 4.61E-02 1.21E-02 2.62E-01 5.08E-02 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 5.40E+03 9.86E+02 1.83E-01 5.70E+03 9.96E+02 1.75E-01 5.55E+03 232U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 237Np Activity (Ci) 0.00E+00 N/A 0.00E+00 2.11E-07 5.67E-08 2.69E-01 0.00E+00 
B-2 

ATTACHMENT B.2 REPLICATE TESTING RESULTS FOR CONTAINER RL0063023, 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation 

χ

Reported 

Value 

Absolute 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V238Pu Activity (Ci) 2.60E-02 7.38E-03 2.16E-02 5.03E-03 2.33E-01 1239Pu Activity (Ci) 2.68E-01 6.67E-02 2.75E-01 7.60E-03 2.76E-02 5240Pu Activity (Ci) 8.97E-02 2.27E-02 6.20E-02 9.14E-03 1.48E-01 6242Pu Activity (Ci) 7.82E-06 2.16E-06 4.99E-06 9.53E-07 1.91E-01 7241Am Activity (Ci) 3.23E-02 8.50E-03 4.88E-02 4.86E-03 9.97E-02 190Sr Activity (Ci) 1.09E-07 2.96E-08 0.00E+00 0.00E+00 N/A 0137Cs Activity (Ci) 9.94E-08 2.69E-08 0.00E+00 0.00E+00 N/A 0TRU Alpha Conc. (nCi/g) 5.80E+03 9.93E+02 5.67E+03 2.37E+02 4.18E-02 2 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V232U Activity (Ci) 3.58E-08 2.05E-08 0.00E+00 0.00E+00 N/A 0237Np Activity (Ci) 4.71E-07 1.25E-07 4.22E-08 9.44E-08 2.24E+00 2Quantity of Interest T Pr(x <|t|) χ2 Test t Test 233U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A #VALUE! Not Applicable 238U Activity (Ci) N/A N/A #VALUE! Not Applicable 238Pu Activity (Ci) 8.06E-01 4.65E-01 Not Significant Not Significant 239Pu Activity (Ci) -8.17E-01 4.60E-01 Not Significant Not Significant 240Pu Activity (Ci) 2.77E+00 5.03E-02 Not Significant Not Significant 242Pu Activity (Ci) 2.71E+00 5.33E-02 Not Significant Not Significant 241Am Activity (Ci) -3.09E+00 3.65E-02 Not Significant Significant 90Sr Activity (Ci) N/A N/A Not Significant Not Applicable 137Cs Activity (Ci) N/A N/A Not Significant Not Applicable TRU Alpha Conc. (nCi/g) 4.93E-01 6.48E-01 Not Significant Not Significant 

N/A N/A #VALUE! Not Applicable 

232U Activity (Ci) N/A N/A Not Significant Not Applicable 237Np Activity (Ci) 4.15E+00 1.43E-02 Not Significant Significant 
B-3 

ATTACHMENT B.3 REPLICATE TESTING DATA FOR CONTAINER RL0050614, GE

Quantity of Interest 

Original Measurement Replicate No. 1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 1.01E-05 2.69E-06 2.66E-01 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 5.05E-06 1.34E-06 2.65E-01 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 4.81E-02 1.94E-02 4.03E-01 1.20E-01 2.68E-02 2.23E-01 1.30E-01 239Pu Activity (Ci) 1.60E+00 3.09E-01 1.93E-01 1.74E+00 3.36E-01 1.93E-01 1.66E+00 240Pu Activity (Ci) 4.05E-01 8.16E-02 2.01E-01 4.43E-01 8.68E-02 1.96E-01 4.14E-01 242Pu Activity (Ci) 4.44E-05 1.01E-05 2.27E-01 4.33E-05 9.64E-06 2.23E-01 3.96E-05 241Am Activity (Ci) 3.82E-01 7.47E-02 1.96E-01 6.58E-01 1.28E-01 1.95E-01 5.97E-01 90Sr Activity (Ci) 6.86E-07 1.41E-07 2.06E-01 1.81E-06 3.56E-07 1.97E-01 1.06E-06 137Cs Activity (Ci) 6.23E-07 1.29E-07 2.07E-01 1.65E-06 3.24E-07 1.96E-01 9.65E-07 TRU Alpha Conc. (nCi/g) 5.29E+04 7.15E+03 1.35E-01 6.43E+04 8.07E+03 1.26E-01 6.09E+04 237Np Activity (Ci) 5.13E-06 1.01E-06 1.97E-01 4.67E-06 9.13E-07 1.96E-01 5.24E-06 243Am Activity (Ci) 4.50E-05 1.27E-05 2.82E-01 0.00E+00 N/A 0.00E+00 0.00E+00 Quantity of Interest 

Replicate No. 3 Replicate No. 4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 7.78E-02 1.91E-02 2.46E-01 1.34E-01 2.88E-02 2.15E-01 1.15E-01 239Pu Activity (Ci) 1.68E+00 3.25E-01 1.93E-01 1.68E+00 3.25E-01 1.93E-01 1.68E+00 240Pu Activity (Ci) 4.52E-01 8.83E-02 1.95E-01 3.88E-01 7.61E-02 1.96E-01 4.56E-01 242Pu Activity (Ci) 4.25E-05 9.47E-06 2.23E-01 3.63E-05 8.09E-06 2.23E-01 4.35E-05 241Am Activity (Ci) 6.06E-01 1.18E-01 1.95E-01 5.56E-01 1.08E-01 1.94E-01 6.21E-01 90Sr Activity (Ci) 8.35E-07 1.65E-07 1.98E-01 7.06E-07 1.40E-07 1.98E-01 1.89E-07 137Cs Activity (Ci) 7.59E-07 1.50E-07 1.98E-01 6.42E-07 1.27E-07 1.98E-01 1.72E-07 TRU Alpha Conc. (nCi/g) 6.12E+04 7.77E+03 1.27E-01 5.99E+04 7.65E+03 1.28E-01 6.25E+04 237Np Activity (Ci) 5.39E-06 1.06E-06 1.97E-01 4.70E-06 9.55E-07 2.03E-01 5.53E-06 243Am Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 
B-4 

ATTACHMENT B.4 REPLICATE TESTING RESULTS FOR, CONTAINER RL0050614, GE

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation 

χ

Reported 

Value 

Absolute 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V234U Activity (Ci) 1.01E-05 2.69E-06 0.00E+00 0.00E+00 N/A 0238U Activity (Ci) 5.05E-06 1.34E-06 0.00E+00 0.00E+00 N/A 0238Pu Activity (Ci) 4.81E-02 1.94E-02 1.15E-01 2.23E-02 1.94E-01 5239Pu Activity (Ci) 1.60E+00 3.09E-01 1.69E+00 3.03E-02 1.80E-02 3240Pu Activity (Ci) 4.05E-01 8.16E-02 4.31E-01 2.89E-02 6.72E-02 5242Pu Activity (Ci) 4.44E-05 1.01E-05 4.10E-05 3.08E-06 7.49E-02 3241Am Activity (Ci) 3.82E-01 7.47E-02 6.08E-01 3.71E-02 6.10E-02 990Sr Activity (Ci) 6.86E-07 1.41E-07 9.20E-07 5.91E-07 6.43E-01 7137Cs Activity (Ci) 6.23E-07 1.29E-07 8.38E-07 5.39E-07 6.44E-01 6TRU Alpha Conc. (nCi/g) 5.29E+04 7.15E+03 6.18E+04 1.70E+03 2.75E-02 2237Np Activity (Ci) 5.13E-06 1.01E-06 5.11E-06 3.98E-07 7.79E-02 6243Am Activity (Ci) 4.50E-05 1.27E-05 0.00E+00 0.00E+00 N/A 0Quantity of Interest T Pr(x <|t|) χ2 Test t Test 233U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A Not Significant Not Applicable 238U Activity (Ci) N/A N/A Not Significant Not Applicable 238Pu Activity (Ci) -2.75E+00 5.14E-02 Not Significant Not Significant 239Pu Activity (Ci) -2.65E+00 5.71E-02 Not Significant Not Significant 240Pu Activity (Ci) -8.08E-01 4.64E-01 Not Significant Not Significant 242Pu Activity (Ci) 9.97E-01 3.75E-01 Not Significant Not Significant 241Am Activity (Ci) -5.56E+00 5.14E-03 Not Significant Highly Significant90Sr Activity (Ci) -3.61E-01 7.36E-01 Highly Significant Not Significant 137Cs Activity (Ci) -3.63E-01 7.35E-01 Highly Significant Not Significant TRU Alpha Conc. (nCi/g) -4.77E+00 8.86E-03 Not Significant Highly Significant237Np Activity (Ci) 5.51E-02 9.59E-01 Not Significant Not Significant 243Am Activity (Ci) N/A N/A Not Significant Not Applicable 
B-5 

ATTACHMENT B.5 REPLICATE TESTING DATA FOR CONTAINER RL0063005, GE

Quantity of Interest 

Original Measurement Replicate No. 1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 3.53E-02 7.64E-03 2.16E-01 3.51E-02 7.62E-03 2.17E-01 3.22E-02 239Pu Activity (Ci) 1.38E-01 2.63E-02 1.91E-01 1.37E-01 2.62E-02 1.91E-01 1.37E-01 240Pu Activity (Ci) 6.82E-02 1.36E-02 1.99E-01 6.33E-02 1.27E-02 2.01E-01 5.75E-02 242Pu Activity (Ci) 1.61E-05 3.56E-06 2.21E-01 1.55E-05 3.42E-06 2.21E-01 1.36E-05 241Am Activity (Ci) 1.03E-01 2.05E-02 1.99E-01 1.34E-01 2.61E-02 1.95E-01 1.19E-01 90Sr Activity (Ci) 1.10E-07 3.19E-08 2.90E-01 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 1.00E-07 2.90E-08 2.90E-01 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 9.09E+03 9.70E+02 1.07E-01 9.76E+03 1.05E+03 1.08E-01 9.12E+03 152Eu Activity (Ci) 1.27E-07 3.92E-08 3.09E-01 0.00E+00 N/A 0.00E+00 0.00E+00 237Np Activity (Ci) 1.08E-06 2.11E-07 1.95E-01 5.96E-07 1.23E-07 2.06E-01 7.35E-07 232U Activity (Ci) 5.56E-08 1.95E-08 3.51E-01 0.00E+00 N/A 0.00E+00 0.00E+00 Quantity of Interest 

Replicate No. 3 Replicate No. 4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 3.53E-02 7.52E-03 2.13E-01 3.88E-02 8.31E-03 2.14E-01 3.61E-02 239Pu Activity (Ci) 1.37E-01 2.62E-02 1.91E-01 1.34E-01 2.55E-02 1.90E-01 1.33E-01 240Pu Activity (Ci) 5.46E-02 1.09E-02 2.00E-01 6.70E-02 1.34E-02 2.00E-01 5.24E-02 242Pu Activity (Ci) 1.41E-05 3.11E-06 2.21E-01 1.72E-05 3.87E-06 2.25E-01 1.40E-05 241Am Activity (Ci) 1.19E-01 2.30E-02 1.93E-01 1.40E-01 2.72E-02 1.94E-01 1.14E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 9.13E+03 9.84E+02 1.08E-01 1.00E+04 1.07E+03 1.07E-01 8.85E+03  0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 152Eu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 237Np Activity (Ci) 6.16E-07 1.29E-07 2.09E-01 7.58E-07 1.48E-07 1.95E-01 7.51E-07 232U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 
B-6 

ATTACHMENT B.6 REPLICATE TESTING RESULTS FOR CONTAINER RL0063005, 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation 

χ

Reported 

Value 

Absolute 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V238Pu Activity (Ci) 3.53E-02 7.64E-03 3.55E-02 2.36E-03 6.66E-02 3239Pu Activity (Ci) 1.38E-01 2.63E-02 1.36E-01 1.95E-03 1.44E-02 2240Pu Activity (Ci) 6.82E-02 1.36E-02 5.90E-02 6.08E-03 1.03E-01 7242Pu Activity (Ci) 1.61E-05 3.56E-06 1.49E-05 1.48E-06 9.96E-02 6241Am Activity (Ci) 1.03E-01 2.05E-02 1.25E-01 1.12E-02 8.92E-02 190Sr Activity (Ci) 1.10E-07 3.19E-08 0.00E+00 0.00E+00 N/A 0137Cs Activity (Ci) 1.00E-07 2.90E-08 0.00E+00 0.00E+00 N/A 0TRU Alpha Conc. (nCi/g) 9.09E+03 9.70E+02 9.37E+03 4.85E+02 5.17E-02 9152Eu Activity (Ci) 1.27E-07 3.92E-08 0.00E+00 0.00E+00 N/A 0237Np Activity (Ci) 1.08E-06 2.11E-07 6.91E-07 7.85E-08 1.14E-01 5232U Activity (Ci) 5.56E-08 1.95E-08 0.00E+00 0.00E+00 N/A 0Quantity of Interest t Pr(x <|t|) χ2 Test t Test 233U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A #VALUE! Not Applicable 238U Activity (Ci) N/A N/A #VALUE! Not Applicable 238Pu Activity (Ci) -7.73E-02 9.42E-01 Not Significant Not Significant 239Pu Activity (Ci) 1.12E+00 3.24E-01 Not Significant Not Significant 240Pu Activity (Ci) 1.39E+00 2.37E-01 Not Significant Not Significant 242Pu Activity (Ci) 7.51E-01 4.94E-01 Not Significant Not Significant 241Am Activity (Ci) -1.81E+00 1.44E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A Not Significant Not Applicable 137Cs Activity (Ci) N/A N/A Not Significant Not Applicable TRU Alpha Conc. (nCi/g) -5.31E-01 6.23E-01 Not Significant Not Significant 152Eu Activity (Ci) N/A N/A Not Significant Not Applicable 237Np Activity (Ci) 4.52E+00 1.07E-02 Not Significant Significant 232U Activity (Ci) N/A N/A Not Significant Not Applicable 
B-7 

ATTACHMENT B.7 REPLICATE TESTING DATA FOR CONTAINER RL0063034, GE

Quantity of Interest 

Original Measurement Replicate No. 1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 1.34E-02 4.88E-03 3.64E-01 1.54E-02 5.46E-03 3.55E-01 3.53E-03 239Pu Activity (Ci) 1.94E-01 5.48E-02 2.82E-01 2.00E-01 5.66E-02 2.83E-01 1.95E-01 240Pu Activity (Ci) 5.09E-02 1.48E-02 2.91E-01 4.07E-02 1.20E-02 2.95E-01 4.64E-02 242Pu Activity (Ci) 4.05E-06 1.28E-06 3.16E-01 3.12E-06 1.00E-06 3.21E-01 3.55E-06 241Am Activity (Ci) 3.43E-02 9.85E-03 2.87E-01 3.25E-02 9.35E-03 2.88E-01 3.05E-02 90Sr Activity (Ci) 3.38E-08 1.31E-08 3.88E-01 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 3.08E-08 1.20E-08 3.90E-01 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 4.86E+03 9.62E+02 1.98E-01 4.80E+03 9.79E+02 2.04E-01 4.57E+03 

 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00  0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 

237Np Activity (Ci) 8.91E-08 3.57E-08 4.01E-01 0.00E+00 N/A 0.00E+00 0.00E+00 Quantity of Interest 

Replicate No. 3 Replicate No. 4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 1.50E-02 5.51E-03 3.67E-01 1.06E-02 4.34E-03 4.09E-01 1.23E-02 239Pu Activity (Ci) 1.98E-01 5.61E-02 2.83E-01 1.88E-01 5.32E-02 2.83E-01 1.88E-01 240Pu Activity (Ci) 4.78E-02 1.41E-02 2.95E-01 4.49E-02 1.32E-02 2.94E-01 4.01E-02 242Pu Activity (Ci) 3.79E-06 1.22E-06 3.22E-01 3.61E-06 1.16E-06 3.21E-01 3.21E-06 241Am Activity (Ci) 3.40E-02 9.80E-03 2.88E-01 3.45E-02 9.93E-03 2.88E-01 3.21E-02 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 4.91E+03 9.80E+02 2.00E-01 4.62E+03 9.30E+02 2.01E-01 4.53E+03 

 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00  0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 

237Np Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 
B-8 

ATTACHMENT B.8 REPLICATE TESTING RESULTS FOR CONTAINER RL0063034, 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation 

χ

Reported 

Value 

Absolute 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V238Pu Activity (Ci) 1.34E-02 4.88E-03 1.14E-02 4.80E-03 4.23E-01 3239Pu Activity (Ci) 1.94E-01 5.48E-02 1.94E-01 5.59E-03 2.88E-02 4240Pu Activity (Ci) 5.09E-02 1.48E-02 4.40E-02 3.43E-03 7.80E-02 2242Pu Activity (Ci) 4.05E-06 1.28E-06 3.46E-06 2.82E-07 8.15E-02 1241Am Activity (Ci) 3.43E-02 9.85E-03 3.27E-02 1.59E-03 4.87E-02 190Sr Activity (Ci) 3.38E-08 1.31E-08 0.00E+00 0.00E+00 N/A 0137Cs Activity (Ci) 3.08E-08 1.20E-08 0.00E+00 0.00E+00 N/A 0TRU Alpha Conc. (nCi/g) 4.86E+03 9.62E+02 4.69E+03 1.62E+02 3.46E-02 1

 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V

237Np Activity (Ci) 8.91E-08 3.57E-08 0.00E+00 0.00E+00 N/A 0Quantity of Interest t Pr(x <|t|) χ2 Test t Test 233U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A #VALUE! Not Applicable 238U Activity (Ci) N/A N/A #VALUE! Not Applicable 238Pu Activity (Ci) 3.86E-01 7.19E-01 Not Significant Not Significant 239Pu Activity (Ci) 3.27E-02 9.75E-01 Not Significant Not Significant 240Pu Activity (Ci) 1.84E+00 1.39E-01 Not Significant Not Significant 242Pu Activity (Ci) 1.92E+00 1.27E-01 Not Significant Not Significant 241Am Activity (Ci) 9.05E-01 4.17E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A Not Significant Not Applicable 137Cs Activity (Ci) N/A N/A Not Significant Not Applicable TRU Alpha Conc. (nCi/g) 9.79E-01 3.83E-01 Not Significant Not Significant 

N/A N/A #VALUE! Not Applicable N/A N/A #VALUE! Not Applicable 

237Np Activity (Ci) N/A N/A Not Significant Not Applicable 
B-9 

ATTACHMENT B.9 REPLICATE TESTING DATA FOR CONTAINER RL0056338, GE

Quantity of Interest 

Original Measurement Replicate No. 1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 9.75E-03 3.25E-03 3.33E-01 7.46E-03 3.45E-03 4.62E-01 5.45E-03 239Pu Activity (Ci) 1.13E-01 2.30E-02 2.04E-01 1.15E-01 2.33E-02 2.03E-01 1.11E-01 240Pu Activity (Ci) 3.04E-02 6.80E-03 2.24E-01 2.89E-02 7.31E-03 2.53E-01 2.75E-02 242Pu Activity (Ci) 2.72E-06 6.88E-07 2.53E-01 2.74E-06 8.23E-07 3.00E-01 2.60E-06 241Am Activity (Ci) 4.56E-04 1.27E-04 2.79E-01 4.52E-04 1.26E-04 2.79E-01 4.56E-04 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 3.33E+03 5.24E+02 1.57E-01 3.28E+03 5.35E+02 1.63E-01 3.13E+03 Quantity of Interest 

Replicate No. 3 Replicate No. 4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 4.69E-03 2.48E-03 5.29E-01 4.12E-03 2.67E-03 6.48E-01 2.44E-03 239Pu Activity (Ci) 1.14E-01 2.32E-02 2.04E-01 1.11E-01 2.37E-02 2.14E-01 1.12E-01 240Pu Activity (Ci) 2.99E-02 6.65E-03 2.22E-01 3.67E-02 8.44E-03 2.30E-01 2.70E-02 242Pu Activity (Ci) 2.63E-06 6.65E-07 2.53E-01 3.24E-06 8.47E-07 2.61E-01 2.45E-06 241Am Activity (Ci) 4.51E-04 1.26E-04 2.79E-01 4.49E-04 1.25E-04 2.78E-01 4.64E-04 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 3.23E+03 5.26E+02 1.63E-01 3.29E+03 5.48E+02 1.67E-01 3.06E+03 
B-10 

ATTACHMENT B.10 REPLICATE TESTING RESULTS FOR CONTAINER RL0056338, 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation 

χ

Reported 

Value 

Absolute 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V238Pu Activity (Ci) 9.75E-03 3.25E-03 4.83E-03 1.84E-03 3.81E-01 1239Pu Activity (Ci) 1.13E-01 2.30E-02 1.13E-01 1.82E-03 1.61E-02 2240Pu Activity (Ci) 3.04E-02 6.80E-03 3.00E-02 3.92E-03 1.31E-01 1242Pu Activity (Ci) 2.72E-06 6.88E-07 2.73E-06 3.02E-07 1.11E-01 7241Am Activity (Ci) 4.56E-04 1.27E-04 4.54E-04 6.16E-06 1.36E-02 990Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VTRU Alpha Conc. (nCi/g) 3.33E+03 5.24E+02 3.20E+03 9.98E+01 3.12E-02 1Quantity of Interest t Pr(x <|t|) χ2 Test t Test 233U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A #VALUE! Not Applicable 238U Activity (Ci) N/A N/A #VALUE! Not Applicable 238Pu Activity (Ci) 2.44E+00 7.12E-02 Not Significant Not Significant 239Pu Activity (Ci) 2.01E-01 8.51E-01 Not Significant Not Significant 240Pu Activity (Ci) 9.32E-02 9.30E-01 Not Significant Not Significant 242Pu Activity (Ci) -3.62E-02 9.73E-01 Not Significant Not Significant 241Am Activity (Ci) 2.52E-01 8.13E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A #VALUE! Not Applicable 137Cs Activity (Ci) N/A N/A #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) 1.21E+00 2.94E-01 Not Significant Not Significant 
B-11 

ATTACHMENT B.11 REPLICATE TESTING DATA FOR CONTAINER RL062952, GE

Quantity of Interest 

Original Measurement Replicate No. 1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 3.77E-03 1.01E-03 2.68E-01 2.26E-03 3.03E-03 1.34E+00 1.57E-02 239Pu Activity (Ci) 4.85E-02 1.11E-02 2.29E-01 3.91E-02 7.15E-03 1.83E-01 4.23E-02 240Pu Activity (Ci) 1.14E-02 3.07E-03 2.69E-01 1.84E-02 4.98E-03 2.71E-01 1.63E-02 242Pu Activity (Ci) 6.57E-07 1.76E-07 2.68E-01 2.19E-06 8.11E-07 3.70E-01 5.70E-06 241Am Activity (Ci) 6.98E-04 2.03E-04 2.91E-01 7.01E-04 2.05E-04 2.92E-01 6.93E-04 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 2.15E+03 3.85E+02 1.79E-01 2.02E+03 3.09E+02 1.53E-01 2.51E+03 Quantity of Interest 

Replicate No. 3 Replicate No. 4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 8.11E-03 4.43E-03 5.46E-01 3.12E-03 3.21E-03 1.03E+00 1.33E-02 239Pu Activity (Ci) 4.50E-02 8.25E-03 1.83E-01 4.07E-02 7.31E-03 1.80E-01 4.07E-02 240Pu Activity (Ci) 2.38E-02 6.85E-03 2.88E-01 1.92E-02 5.20E-03 2.71E-01 1.56E-02 242Pu Activity (Ci) 4.25E-06 1.39E-06 3.27E-01 2.67E-06 9.38E-07 3.51E-01 5.21E-06 241Am Activity (Ci) 7.09E-04 2.08E-04 2.93E-01 6.96E-04 2.02E-04 2.90E-01 7.19E-04 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 2.59E+03 3.88E+02 1.50E-01 2.13E+03 3.19E+02 1.50E-01 2.35E+03 
B-12 

ATTACHMENT B.12 REPLICATE TESTING RESULTS FOR CONTAINER RL062952, 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation 

χ

Reported 

Value 

Absolute 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V238Pu Activity (Ci) 3.77E-03 1.01E-03 8.50E-03 5.98E-03 7.03E-01 1239Pu Activity (Ci) 4.85E-02 1.11E-02 4.16E-02 2.23E-03 5.37E-02 1240Pu Activity (Ci) 1.14E-02 3.07E-03 1.87E-02 3.23E-03 1.73E-01 4242Pu Activity (Ci) 6.57E-07 1.76E-07 4.00E-06 1.54E-06 3.84E-01 3241Am Activity (Ci) 6.98E-04 2.03E-04 7.04E-04 1.05E-05 1.50E-02 190Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #V137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VTRU Alpha Conc. (nCi/g) 2.15E+03 3.85E+02 2.32E+03 2.43E+02 1.05E-01 1Quantity of Interest t Pr(x <|t|) χ2 Test t Test 233U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A #VALUE! Not Applicable 238U Activity (Ci) N/A N/A #VALUE! Not Applicable 238Pu Activity (Ci) -7.22E-01 5.10E-01 

Highly 

Significant Not Significant 

239Pu Activity (Ci) 2.84E+00 4.69E-02 Not Significant Significant 240Pu Activity (Ci) -2.05E+00 1.09E-01 Not Significant Not Significant 242Pu Activity (Ci) -1.99E+00 1.18E-01 

Highly 

Significant Not Significant 

241Am Activity (Ci) -4.86E-01 6.53E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A #VALUE! Not Applicable 137Cs Activity (Ci) N/A N/A #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) -6.39E-01 5.58E-01 Not Significant Not Significant 
C-1 

ATTACHMENT C.1 

EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. HANFORD-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 made process decisions based on the 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. 

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable 

D. Discussed with: Dale Simpson, Jeremy Vesely 

E. Additional 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 

Description of Issue: CCP training procedure CCP-QP-002, Revision 27, Section [C.3] requires Waste 

Certification Officials (WCOs) to demonstrate proficiency in WWIS as part of training. However, WDS is

not specifically identified in the training procedure although this is the only User’s Manual listed in the 

reference section of CCP-TP-030. The Hanford-CCP Project Manager indicated that the procedure(s) 

associated with data entry are being revised at this 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. HANFORD-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 contained control limits for the 

transmission 239Pu mass daily standard that were incorrect. The control limits had been recalculated on 

March 10, 2010 but the control limits stated in the BDRs were different from what was documented in the 

calibration verification report. There is no concern regarding the technical adequacy of the performance 

check data, this concern is focused on the records that document the performance checks. 

Additionally, the GEA-A log book did not contain any entry regarding the incorporation of the new limits. 

B. Regulatory Reference: 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. HANFORD-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 technical issues and elements 

identified during the inspection. These modifications are required to ensure adequate representation of the 

waste stream and its radiological and physical characteristics. The following must be addressed: 

• Examine feed and other data for 232-Z Incinerator to 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 segregated upon generation or packaging. 

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

• Add information to Section 5.4.2 pertaining to the 6%, 12%, and 23% 240Pu isotopic 

distributions as presented in AK Source Documents and 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 Section 4.5 regarding intent to segregate waste 

during packaging or repackaging, as it contradicts later statements. 

• Verify number of HEHF (Emergency Decontamination Facility) drums and how they are 

included in the PFP drum population. 

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

• In the final paragraph of Section 5.4.2, add the second predominant radionuclide by activity, to 

be consistent with the previous portion of the sentence 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 knowledge or understanding of EPA 

regulation(s) as required by CCP-PO-002, Revision 22, Appendix 10, Section 10.2. This NDE issue was 

previously identified by EPA at both ORNL-CCP and SRS-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. HANFORD-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 although 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 through March 22, 2010. 

AKE Qualification Card for Sheri Nance, 2004 through March 22, 2010. 

CCP-AK-RL-101, Central Characterization Project Acceptable Knowledge Summary Report For 

Hanford Plutonium Finishing Plant (PFP) Contact-Handled Transuranic Debris Waste From 

Decontamination and Decommission, Waste Stream: MPFPDD, Revision 1, January 15, 2010. 

CCP-AK-RL-101 Central Characterization Project Acceptable Knowledge Summary Report For 

Hanford Plutonium Finishing Plant (PFP) Contact-Handled Transuranic Debris Waste, Waste 

Stream: MPFPDD, Revision 2 March 30, 2010. 

CCP-AK-RL-101, from Sheri Nance to CCP Central Records, 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 Records, 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 Documentation, 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 Visual Examination, Carlsbad, New 

Mexico, Washington TRU Solutions, LLC. 

C013 Interview of Michael Wesselman by Richard Clinton concerning Sr-90/Cs-137, Ratio 

Determination. R. Clinton, March 28, 2002. 

C014 E-mail from Bisping to Rollosson re: Heat-Sealed Bag Question and Clarification, S.W. 

Bisping, July 25, 2002. 

C018 Email Response from Elizabeth Curfman to Richard 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 Venetz 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 Concentration 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 about Heat Sealing, J. L. Aranda, August 7, 

1996. 

C026 PFP Soil Record of Communication with Jose Mejia, M.E. Lakes and P.H. Wicks, 

December 19, 2006. 

C027 PFP Soil Record of Communication with J. Aranda, 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 Campaign - 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 February 7, 2003. 

C034 Fax from Manthos to Hamilton re: Values used for 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 concerning 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 regarding 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, 2001. 

C041 Email from Richard Clinton to Gregg Krehel regarding and inquiry of the Chemical Makeup of Fluid in Stanley Works Torpedo Levels, R. Clinton, 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, 2000. 

C046 Interview of J. A. Mortenson re: Heat Sealed Packages, 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 Packages, M. Watson, September 27, 2000. 

C051 Sr-90 To Cs-137 Ratio for Appendix E of Hanford Site Transuranic Waste Certification 

Plan for NDA, M4T00-PJC-02-076, R. Clinton, April 11, 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 Farms Database, TWINS, L. Djang, February 

27, 2002. 

C054 Memorandum to L. F. Perkins re: TRU Site Project 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 Project 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, August 28, 1998. 

C059 Coffins from PFP – Mtg Notes, E. M Greager, August 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. Rollosson, October 12, 2007. 

C062 E-Mail Response to Questionnaire sent by MS Watson to Several Former Workers at PFP 

Regarding the Use of Heat Sealed Bags Generating Heat Sealed Packages, R. Trainer, September 

6, 2000. 

C063 Internal Memo to E. T. Abramowski re: PCB Determination 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 Sealed Inner Package, L. J. Estey, May 7, 

1990. 

C077 Transmittal of AK Confirmation Checklist for 19 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 Crucible Waste, FH-0003830, E.S. Aromi and 

P.J. Crane. 

C084 Proposed Waste Designation of Carbon Tetrachloride 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. Clinton, 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, 2001. 

C106 Internal memo to R. L. Granberg re: Solvent Waste Designations 80132-89-069, R. J. 

Landon, May 15, 1989. 

C107 Plutonium Purification and Fabrication of Technical Manual HW-29200. 

C108 Slurping Vacuum System and Analytical Laboratory 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. Fitzgerald, September 13, 2000. 

C113 Internal Memo to E. G. Backlund re: Corrosivity 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, Waste 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 Hanford 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: MPFPDD, Interviewers: Steve Schafer and 

Sheri Nance, Interviewee: Rhonda J (Roni) Swan, Melvin E (Mel) Lakes, Subject: Feed to the 

Building 232-Z Incinerator, May 4, 2010. 
D-6 

DOE/WIPP-02-3122, Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant, 

Carlsbad, New Mexico, U.S. Department of Energy. 

Draft Waste Stream Profile Form, Hanford Waste Stream MPFPDD, Prepared by CCP, March 

10, 2010. 

DR005 AK Source Document Discrepancy, R. Clinton, May 20, 1999. 

DR006 NaI Discrepancy, R. Clinton, July 15, 1999. 

DR010 Acceptable Knowledge source document Discrepancy Resolution waste stream 

MPFPDD, TRU-Mixed heterogeneous debris resulting from production, maintenance, cleanout, 

stabilization and decontamination and decommissioning (D&D) at the Hanford Plutonium 

Finishing Plant (PFP), S. Schafer, provided April 27, 2010. 

DR013 Acceptable Knowledge Source Document Discrepancy Resolution, Waste Stream 

Number MPFPDD, TRU mixed heterogeneous debris resulting from production, maintenance, 

cleanout, stabilization, and decontamination and decommissioning (D&D) at the Hanford 

Plutonium Finishing Plant (PFP). 

Discrepancy Resolution for Incinerator Feed (Building 232-Z). 

Engineering Data Transmittal, EDT 125236, to Distribution from WRAP Project Engineer, 

Preliminary Safety Evaluation, W-026 Waste Receiving and Processing Facility Module 1, 

December 9, 1994. 

Freeze File Changes, prepared by Steve Schafer, Changes to CCP-AK-RL-101, R. 2 (and 

attachments) identified and agreed to during the April 5 - 7, 2010 CBFO/NMED audit, provided 

April 27, 2010. 

Freeze File Modification of CCP-AK-RL-101Central Characterization Project Acceptable 

Knowledge Summary Report For Hanford Plutonium Finishing Plant (PFP) Contact-Handled 

Transuranic Debris Waste, Waste Stream: MPFPDD, Revision 3, MARKUPSN, Provided May 

13, 2010.

HNF-6489 Revision 1, Acceptable Knowledge (AK) Document 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 and Decommissioning Technical Safety 

Requirements, Administrative Control 5.20 and Specific Administrative Controls 5.24. 
D-7 

Inter-Office Correspondence, Washington TRU Solutions LLC, from J.E. Hoff to Distribution, 

Transmittal and Closure of WTS Quality Assurance Audit 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 Designation 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 MPFPD, 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 Chemical Company. 

M044 Solid Waste Burial Records – Addendum for 218-W-3A, July 23, 1980. 

M046 Radioactive Waste Storage/Disposal Analysis Record 14-1D-8LM-0401, M. F. Pascual, 

September 16, 1995. 

M047 MPFPD Isotopes Data from SWITS, R. Clinton, June 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 Inorganic Matrix Material, M. I. 

Rollosson. 

M054 PFP PCB Debris Designation PFP-DES-02-00, M. Lakes, 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, April 24, 2007. 

M062 Shell Chemical Company-Solvents Technical Support-American Region-Fax On Demand 

System, Shell Chemical Company, September 22, 2000.

M063 Fax to R. Clinton re: Waste Material to be Disposed 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 Stream 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-2008-3425, Annual Transuranic 

Waste Inventory Report – 2008. 

NCR-RL-0001; NCR-RL-600-617; NCR 1201-1203; Waste Stream MPFPDD, various dates. 

P041 Past Practices Technical Characterization Study-300 Area- Hanford Site WHC-MR-0388, 

M.S. Gerber, December 1992. 
D-9 

P051 Hanford Site Solid Waste Acceptance Criteria HNF-EP-0063, May 1, 2003. 

P052 Hanford Site Transuranic Waste Management Program Acceptable Knowledge 

Documentation for Retrievably Stored Contact-Handled 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 Defense 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 Hanford 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 Historical 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 Control Plan RHO-CD-644, R. L. Walser, R. 

E. Van der Cook. 

P121 Z Plant RMA Oxide Line Flowsheet Addendum-Filtrate Concentration, RHO-CD-616, 

ADD R.L. Walser and R.E. Van der Cook. 

P122 Plutonium Finish Plant Environmental Operations, Recan Plutonium Metal, ZO-200-504, 

June 27, 1994. 
D-10 

P123 Criticality Prevention Specification, Incinerator Burning Hood Characterization and 

Disassembly Activities, CPS-Z-165-80625, May 8, 1995. 

P124 Criticality Prevention Specification, Glovebox Clean-up Operations, CPS-Z-165-80012, 

May 8, 1995. 

P125 Plutonium Finishing Plant Process Flow Document 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 230A, 234-5 Building. 

PFD-Z-190-00004, Revision A-0, G.R. Wittman, October 1994. 

P127 Plant Operating Procedure, Oxidize Plutonium Metal in Glovebox HC-21-C and HA-21-I 

ZO-160-033, Revision A-7, Rockwell Hanford Operations. 

P128 Stabilize Reactive Scrap (Operate HC-21C Muffle Furnace) ZO-160-032, August 26, 1982. 

P129 Criticality Prevention Specification: Plutonium Finishing Plant/Plutonium Metal 

Production, CPS-Z-165-80350, January 9, 1990. 

P130 Engineering Evaluation/Cost Analysis for the Plutonium 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. Dodd. 

P134 PFP Liquid Organic Disposal as 20 Year Retrievable TRU Waste, HNF-26402, M.W. 

Gibson and L.H. Rodgers. 

P135 PFP Impure Plutonium Oxide: Characterization of Items with Greater 

than 30 & less than 85 Weight Percent Plutonium, HNF-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 Disposition of Sand, Slag, and Crucible Materials 

Stored at the Plutonium Finishing Plant HNF-9734, Revision 2, A.M. Hopkins December, 2003. 

P139 216-Z-9 Crib at the PFP, D. Lini, J. Teal, February 27, 2004. 

P140 242-Z Waste Treatment Facility, D.C. Lini, December 29, 2003. 

P141 Handling of Pu Contaminated, Acid Soaked Rags in Hood, 5 ZO-160-031. 
D-11 

P143 Decommissioning of Division of Military Application Equipment at Richland Operations 

Office: Quarterly Report, ARH-R-215, 1Q. 

P144 Decommissioning of Division of Military Application Equipment at Richland 

Operations Office: Quarterly Report, ARH-R-215, 2Q.

P145 Decommissioning of Division of Military Application at Richland Operations Office: 

Quarterly Report, ARH-R-215, 3Q. 

P146 Decommissioning of Division of Military Application (DMA) Equipment at 

Hanford - Summary Report: June 1977 ARH-ST-141, M.N. Raile, June, 1977. 

P147 Handle Pu Contaminated Acid Soaked Rags, ZO-160-030. 

P148 Critical Mass Specification, Waste Treatment Facility, Buildings 241-Z and 242-Z, 

HW-82632, R.J. Sloat. 

P149 Process Design Basis for Fabrication Oil Storage 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 Division of Military Application Equipment at 

the Hanford Site, WHC-IP-0791, J.A. Demiter, D.R. Duncan, and W.E. Meeuwsen, December 

11, 1991. 

P153 WST History of the Plutonium Production Facilities at the Hanford Site Historic District 

1943-1990, DOE/RL-97-1047, T.E. Marceau, D.W. Harvey, et al, June, 2002. 

P154 Stabilize Material Handling, ZO-160-034, Revision B-0, D-1, February 22, 1995. 

P155 Operating Specifications for Plutonium Finishing 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-190-0001, S. Yarbo. 

P157 PFP Process Control Engineering, PFD-Z-190-0004, M. Gibson. 

P158 Estimation and Characterization of D&D Solid Waste Expected from PFP, WHC-EP-0829, 

Revision 0, J.S. Miller, J.A. Pottmeyer, T.J. Stratton, 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-165-80716, Revision C-1, PFP. 

P164 Access Glovebox: 2nd Floor East, CPS-Z-165-80709. 

P165 Access Glovebox: 1st Floor West, CPS-Z-165-80708. 

P166 Access Glovebox: 1st Floor East, CPS-Z-165-80707. 

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. Kronvall, 1987. 

P170 Handling of Plutonium Contaminated Acid and Water 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 Building. 

P172 Sample Plutonium Bearing Powders for the International 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, Revision D-0, E-2 C, Barr and G.B. 

Chronister 1993, 1996. 

P175 Sorting Glove Box CPS-Z-165-80290, September 12, 1983. 

P176 Dismantle HEPA Filters, ZO-170-823, July 7, 1994. 

P177 Repackage 55-Gallon Waste Drums, ZO-170-040, April 3, 1989. 

P178 Seal Out, ZO-170-0299, G. Barr, et al. 

P179 Handle and Package TRU Solid Waste in 55-Gallon Drums, ZO-170-015, PFP. 

P180 Solid Waste Repackaging and Disposal, ZL-100-323, September 18, 1998. 

P181 PFP Analytical Laboratory Organic Waste Loadout, 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 Dosimetry 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. Black, et al, February 22, 1982. 

P186 PFP Operations Overview (1949-2004): Contamination 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-SAR-011, G. L. Jones, March 1, 1984. 

P188 Radiological History of the Plutonium Finishing Plant (1954-1997), FSP-PFP-IP-003, A. 

L. Ehlert, April 1, 1999. 

P189 Plutonium Process Support Laboratories, D. Lini, June 21, 2004. 

P191 Engineering Evaluation/Cost Analysis for the Plutonium 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 Blend Plan WHC-88-245, J. F. Durnil, E. 

V. Weiss, June 24, 1988. 

P194 D&D Assessment for the Waste Incineration Facility (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. Simiele. 

P198 T-Plant Operating Procedure Package Transuranic Waste, DO-100-039 C, Martin. 

P199 Plutonium Finishing Plant Stabilization Operations Technical Procedure - Pipe-N-Go 

Operations ZO-160-080, Revision C-17, May 3, 2006. 

P200 Remote Mechanical C (RMC) Line Material Balance and Lead Summary – June 27, 1985 

to December 11, 1985, RHO-SS-SR-183-85-1, D. L. Bouse, 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 Finishing 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 Quality 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 Management Operations, Hanford Reservation, 

Richland, Washington, ERDA-1538, J.L. Liverman. 

P210 Z Plant Aggregate Area Management Study Technical Baseline Report, BHI-00175, D.H. 

DeFord. 

P211 216-Z-12 Transuranic Crib Characterization: Operational 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. Lewis. 

P215 RCRA/SUPERFUND/OUST Hotline Monthly Report Question October 1992, October 1, 

1992. 

P216 RCRA/SUPERFUND/OUST Hotline Monthly Report Question 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 Laboratory Samples, ZL-090-304. 

P220 Seal In and Seal Out of Material from Glove Box by Plastic Bag or Sphincter, ZL161-302. 

P221 Interim Plutonium Stabilization Engineering Study, PNL-10507, P. J. Sevigny, et al, 

August 1, 1995. 
D-15 

P222 Technical Basis for Characterization of Plutonium for PFP, WHC-SD-CP-TI-190, R. 

Crow, R. W. Szempruch. 

P225 Listing Background Document, EPA. 

P226 Hanford Tank Chemical and Radionuclide Inventories: HDW Model LA-UR-96-3860, 

S. Agnew. 

P227 Hanford Defined Waste Models Limitations and Improvements, 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-High 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-180-00003, 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 Results for the Final Report, R. A. Esch, 

May 1, 2000. 

P237 Final Report for the Hydraulic Oil Samples Received 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-SAR-021, Revision 0, J.E. Shapely. 

P244 Transmittal of the Waste Stream-Specific Documents for the AK Document 

Management Program for PFP Non-Mixed and Mixed Debris 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 Material in Process Systems, HNF-22064, R. 

C. Hoyt, J. Teal. 
D-16 

P246 Transmittal of the Waste Stream-Specific Document SS&C01, Revision 5, for the 

Acceptable Knowledge Documentation Management Program for PFP Sand, Slag, and Crucible 

Waste, M4T00-TRU-04-472, S.W. Bisping, June 17, 2004. 

P247 Deactivation and Cleanout of the 308 Fuels Laboratory 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 Facilities, 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, Chapter 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 Characterization Alternatives Study WHCWD-W026-ES-013 C. L Bergeson, R. A. Hyre, et al, September 1, 1994. 

P277 PFP Standard Practices, Seal In, ZO-170-301, June 21, 1994. 

P278 Experimental Isotopic Analysis of Point Exposure Data in Hanford Production Reactor, 

DUN-72443, RD H. Toffer and A.F. Kupinski, September 8, 1970. 

P279 Contact Handled TRU Solid Waste Disposal OSD-Z-184-00020. 

P403 Characterization of Past and Present Solid Waste Streams from the Plutonium-Uranium 

Extraction Plant, WHC-EP-0646, H. Toffer, A. F. Kupinski, September 8, 1970. 

P405 Characterization of Past and Present Solid Waste 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. Rodgers, March 1, 2002. 

P414 Retrieval Process Description, HNF-5597, Revision 3, March 31, 2004. 

P415 TRU Waste Phase I Retrieval Plan HNF-4781, Revision 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 Containers with TRU Waste ZO-170-044, 

Revision F, Change 26, PFP, August 25, 2004. 

P507 Visual Examination Technique for PFP Debris Waste 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, April 28, 2008. 

P511 PFP Debris Draft AK Report, HNF-36515. 

P512 Procedure for Equipment Removal from the PRF West Gallery Gloveboxes, 2Z-08-7986. 

P513 RadPro Chemical Decontamination of Equipment/Gloveboxes and Hoods Containing 

Plutonium ZDD-1-002, Revision B, Change 2 PFP April 29, 2009. 

P514 Technical Data: Plutonium Finishing Plant Chemical 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, December 22, 2008. 

P1079 Hanford Facility Fact Sheet, 234-5Z. 

P1081 Safety Evaluation Report for Stabilization Processing of High Chloride Bearing 

Plutonium Materials at the Plutonium Finishing Plant, 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 Techniques to Determine 242Pu 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 Residues/Legacy Holdup. 

U202 Waste Certification Summary – Radionuclides Reported in SWITS. 

URS, Washington TRU Solutions LLC, March 3, 2010, to 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 Stream Profile Form Number 

RLMPDT.001, approved, misdated. 
E-1 

ATTACHMENT E 

PUBLIC COMMENT ON THE PROPOSED APPROVAL 

Public comments received in response to the proposed 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 estimating 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 specific to this issue, which the Commenter 

provided on October 25, 2010 (see Attachment E-1) and additional documents listed below: 

1) PDF file documenting an 80-page PowerPoint course presentation on Real-Time 

Radiography Training – Liquid Volume Calculation. 

(RTR_TRAINING_Liquids_4-09_(3)_.pdf) 

2) PDF file documenting a 63-page PowerPoint course presentation on Real-Time 

Radiography Training – Determination of Residual Liquids. 

(RTR_TRAINING_Liquids_Prohibited_Items_10-09_.pdf) 

3) PDF file documenting the CCP Attendance Sheets for: the RTR Training Summit 

conducted April 27-30, 2009; the RTR Training Summit conducted June 12 – 16, 2009; 

and the RTR Training Summit — Part II conducted June 8-10, 2009. 

(RTR_Attendance_Sheets.pdf) 

4) PDF file documenting the RTR Training Examination. 

(LANL_Volumes_Test_11-09.pdf) 
E-2 

ATTACHMENT E-1 
E-3 
E-4