DOCKET NO: A-98-49, II-A4-115

WASTE CHARACTERIZATION INSPECTION REPORT

FINAL APPROVAL

EPA BASELINE INSPECTION NO. EPA-GEVNC-CCP-RH-12.08- 8

OF THE CENTRAL CHARACTERIZATION PROJECT

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION

PROGRAM FOR GENERAL ELECTRIC VALLECITOS NUCLEAR CEN TER December 2–4, 2008

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

August 2009i TABLE OF CONTENTS

Section Page

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

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

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

................................................... ........................... 1

2.0 Purpose of Inspection..........................

................................................... ............................. 4

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

................................................... ............................ 5

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

................................................... .............................. 6

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

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

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

................................................... .................................... 7
6.1 EPA Inspection Team............................

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

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

................................................... ................. 8

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

................................................... ........................ 8

8.0 Technical Evaluation...........................

................................................... ............................. 9
8.1 Acceptable Knowledge ...........................

................................................... ........... 10
8.2 Radiological Characterization..................

................................................... .......... 31

8.3 Visual Examination.............................

................................................... ............... 42
8.4 WIPP Waste Information System ..................

................................................... .... 46

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

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

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

................................................... ........................... 49
10.1 EPA Findings and Concerns .....................

................................................... ......... 50

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

................................................... ..................... 50

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

................................................... .................................. 52ii ATTACHMENTS

Attachment A.1 Visual Examination (VE) Checklist

Attachment A.2 WIPP Waste Information System (WWIS) Checklist

Attachment B.1 EPA Inspection Issue Tracking Form, EPA Inspection Issue No. GEVNCCCP-RH-AK-08-002CR, Final

Attachment B.2 EPA Inspection Issue Tracking Form, EPA Inspection Issue No. GEVNCCCP-RH-AK-08-001F, Final

Attachment B.3 EPA Inspection Issue Tracking Form

, EPA Inspection Issue No. GEVNCCCP-RH-AK-08-003CR, Final

Attachment B.4 EPA Inspection Issue Tracking Form, EPA Inspection Issue No. GEVNCCCP-RH-RC-08-006CR, Final

Attachment B.5 EPA Inspection Issue Tracking Form, Inspection Issue No. GEVNC-CCPRH-VE-08-004CR, Final

Attachment B.6 EPA Inspection Issue Tracking Form, Inspection Issue No. GEVNC-CCPRH-VE-08-005C, Final

LIST OF TABLES

Table 1. Tiering of RH TRU WC Processes Implemented by GEVNC-CCP, Based on December 2–4, 2008 Baseline Inspection .... .................................................. 3
Table 2. EPA Inspection Team Members...............

................................................... ................... 8
Table 3. Personnel Contacted During Inspection .....

................................................... ................. 8
Table 4. GEVNC Scaling Factors Derived from Sample Data ............................................... ... 35
Table 5. Overall Uncertainty for GEVNC Waste at a De nsity of 0.3 g/cm 3 .............................. 39
Table 6. Tiering of RH TRU WC Processes Implemented by GEVNC-CCP, Based on December 2–4, 2008 Baseline Inspection .... ................................................ 52iii ACRONYMS

AK acceptable knowledge

AKE acceptable knowledge expert

AKSR acceptable knowledge summary report

ALARA as low as reasonably achievable

Am americium

Ba barium

BDR batch data report

CBFO Carlsbad Field Office

CCP Central Characterization Project

Ce cerium

Cf californium

CFR Code of Federal Regulations

CH contact-handled

CH-TRAMPAC Contact-Handled Transuranic Waste Author ized Methods for Payload Control

CH WAC Contact-Handled Waste Acceptance Criteria

Ci curie

Ci/Ci curies per curie

Ci/L curies per liter

CIS Characterization Information Sheet

Cm curium

Co cobalt

CPR cellulose, plastic, and rubber

CRR Characterization Reconciliation Report

Cs cesium

CSS Correlation and Surrogate Summary

CSSF Correlation and Surrogate Summary Form

CTP Confirmatory Test Plan

DOE U.S. Department of Energy

DQO data quality objective

DR discrepancy resolution

DRF discrepancy resolution formiv

DTC dose-to-curie

EPA U.S. Environmental Protection Agency

Eu europium

FGE fissile gram equivalent

FR Federal Register

g gram or grams

g/cm 3 grams per cubic centimeter

GEVNC General Electric Vallecitos Nuclear Center

HLW high-level waste

INL Idaho National Laboratory

ITR Independent Technical Reviewer

kg kilogram or kilograms

LANL Los Alamos National Laboratory

lb pound or pounds

LO Lead Operator

LLW low-level waste

LWR light-water reactor

m 3 cubic meter

mR/hr milli Roentgen per hour

mrem/hr millirem per hour

MSDS material safety data sheets

N/A not applicable

nCi/g nanocurie per gram

NCR non-conformance report(s)

NDA non-destructive assay

NMED New Mexico Environment Department

No. number

Np neptunium

NWPA Nuclear Waste Policy Act

OJT on-the-job training

ORIA Office of Radiation and Indoor Air

PA performance assessment

PE Ci plutonium equivalent curiev

PTS Project Tracking System

Pu plutonium

QA quality assurance

QAO quality assurance objective

QAPD quality assurance program document

RC radiological characterization

Rem Roentgen Equivalent Man

RCRA Resource Conservation and Recovery Act

RH remote-handled

Ru ruthenium

SAP Sampling and Analysis Plan

Sb antimony

SCG Summary Category Group

SME Subject Matter Expert

SNF spent nuclear fuel

SPM Site Project Manager

SQAO software quality assurance officer

Sr strontium

SRS Savannah River Site

T1 Tier 1

T2 Tier 2

TCO Transportation Certification Official

TMU Total Measurement Uncertainty

TRAMPAC Contact-Handled Transuranic Waste Authorize d Methods for Payload Control

TRU transuranic

U uranium

VE visual examination

VEE visual examination expert

VEO visual examination operator

VET visual examination technique

VPM vendor project manager

WAC waste acceptance criteria

WAP waste analysis planvi

WC waste characterization

WCA Waste Certification Assistants

WCO Waste Certification Official

WCPIP Waste Characterization Program Implementation Plan

WG Pu weapons-grade plutonium

WIPP Waste Isolation Pilot Plant

WMC Waste Matrix Code

WMP waste material parameter

WSPF Waste Stream Profile Form

WSPS Waste Stream Profile Sheet

WWIS WIPP Waste Information System

Y yttrium

Zr zirconium1

1.0 EXECUTIVE SUMMARY

This report discusses the U.S. Environmental Protec tion Agency’s approval of the remotehandled (RH) transuranic (TRU) debris waste (GEVNC.0 1) generated from the decontamination and demolition (D&D) of Hot Cell 4 in Building 102 at the General Electric Vallecitos Nuclear Center (GEVNC) between 2008 and 2009. With this ap proval, the GEVNC debris waste characterized by the Central Characterization Proje ct (CCP) may be disposed of at the Waste Isolation Pilot Plant (WIPP).

From December 2 through 4, 2008, the U.S. Environme ntal Protection Agency (EPA or the Agency) conducted a baseline inspection (Inspection No. EPA-GEVNC-CCP-RH-12.08-8) at the GEVNC facility located in Sunol, California. Per th e Agency’s regulations at 40 CFR Part 194.8(b), EPA must inspect and approve RH TRU waste characterization (WC) activities for debris waste (S5000) implemented by the CCP. These regulations also require that EPA approves RH TRU waste prior to its disposal at WIPP . In June 2009, EPA issued a Federal Register notice with a 45-day comment period proposing to a pprove CCP’s RH TRU debris waste characterization program and RH TRU debris wa ste from D&D activities in Hot Cell 4 in Building 102 at GEVNC (see 74 FR 29694-29697). The public comment period closed on August 7, 2009, and EPA received one (1) set of com ments (see Docket ID No. EPA–HQ–OAR– 2009–0372). EPA evaluated the comments and made ap propriate changes in this report. Section 9.0 includes the comment received and EPA’s respons e.

Beginning in 1958, Hot Cell 4 in Building 102 at GE VNC was used primarily for nondestructive examination of fuel materials and the p roduction of radionuclide sources. The examinations consisted mainly of post-irradiation e xamination (PIE) of uranium fuel and reactor components until 1982. Since then, the hot cell ha s been used for the production of radionuclide sources. CCP was not prepared for the on-site EPA inspection and did not provide sufficient objective evidence for the Agency’s evaluation duri ng the inspection. This resulted in EPA identifying several significant issues. EPA conclu ded that the inspection could not be completed

and that extensive documentation revisions were nec essary. During early 2009, CCP provided

revised documentation in the form of additional tec hnical information and objective evidence in response to outstanding issues discussed later in t his report.

The inspection scope covered only one RH waste stre am, GEVNC.01, because no additional RH TRU waste is to be generated during the D&D of the Hot Cell 4. This inspection’s focus was to evaluate the acceptable knowledge (AK) records that had been assembled to document RH TRU WC activities, in conjunction with the development of scaling factors, dose-to-curie (DTC) and visual examination (VE) to confirm physical and rad iological contents of individual TRU RH debris waste containers, and the use of the WIPP Wa ste Information System (WWIS) to report and track waste information. This inspection was s imilar to previous EPA inspections of CCP WC activities at RH waste sites (see Air Docket Nos . A-98-49, II-A4-72; A-98-49, II-A4-73; A98-49, II-A4-96; A-98-49, II-A4-104; and A-98-49, I I-A4-111).

EPA must verify compliance with 40 CFR 194.24 befor e waste may be disposed of at the WIPP, as specified in Condition 3 of the Agency’s certifi cation of the WIPP’s compliance with disposal regulations for TRU radioactive waste [63 Federal Register (FR) 27354 and 27405, May 18,2

1998]. EPA Baseline Inspection No. EPA-GEVNC-CCP-R H-12.08-8 was performed in accordance with the provisions of 40 CFR 194.8(b), as issued in a July 16, 2004, FR notice (Vol. 69, No. 136, pp. 42571–42583).

The EPA inspection team identified one finding and five concerns related to WC processes GEVNC-CCP implemented to characterize RH debris wast e (see Attachments B.1 through B.6).

GEVNC-CCP revised a number of specific documents to address t he EPA finding and concerns.

After reviewing the documents provided by DOE throu gh early 2009, EPA determined that the GEVNC-CCP RH WC program was technically adequate and that all concerns have been resolved. Therefore, EPA is approving the followin g GEVNC-CCP RH WC program components implemented to characterize all GEVNC RH debris waste belonging to Waste

Stream GEVNC.01:

(1) The AK process for the RH TRU debris waste stream d esignated as Waste Stream GEVNC.01 generated during the D&D of Hot Cell 4

(2) The radiological characterization process using DTC and scaling factors for assigning

radionuclide values to Waste Stream GEVNC.01 that i s documented in CCP-AK-GEV-501, Revision 1, as supported by the rev ised calculation packages and detailed in this report

(3) The VE process to identify waste material parameter s (WMPs) and the physical form of

the waste

(4) The WWIS to submit data for both characterization a nd certification for RH TRU waste

(5) The attainment of pertinent data quality objectives (DQOs)

Since all the RH waste at GEVNC is only one debris waste stream (GEVNC.01) from D&D activities at Hot Cell 4 in Building 102, no Tier 1 (T1) changes for the EPA-evaluated waste characterization components are needed. No addition al RH TRU debris waste streams requiring characterization by CCP for disposal at the Waste I solation Pilot Plant will be generated.

Following an EPA inspection, CCP and other TRU site s routinely revise WC procedures as

additional waste containers are characterized and w aste-related information is generated. EPA refers to these changes as Tier 2 (T2) changes that require EPA review at regular intervals. The waste stream GEVNC.01, at GEVNC to be disposed of a t the WIPP is of limited volume, and as of the date of the proposed report, more than 75% o f the waste had been characterized and packaged. Soon after the CBFO issues their site ce rtification, all RH TRU waste will be disposed of. No additional RH debris waste charact erization will occur once the debris from D&D activity is complete and is characterized and d isposed of at WIPP. The quarterly notification of T2 changes required of other waste characterization sites is not applicable to GEVNC-CCP. In lieu of a quarterly T2 changes submis sion, however, a one-time T2 information submission to EPA notifying the end of the characterization activity will be necessary. Therefore, GEVNC-CCP must provide appli cable T2 changes included in Table 1

below to EPA for review.3

GEVNC has indicated that a small quantity of debris from the D&D operation may qualify as contact-handled (CH) TRU debris (i.e., not meeting the external dose rate criterion for RH TRU). It is expected that GEVNC- CCP will ship these CH d ebris containers to CCP at the Idaho National Laboratory (INL-CCP) for characterization a s CH TRU waste from small quantity sites prior to disposal at WIPP. DOE must notify EPA pri or to shipment of these CH TRU waste(s) to INL-CCP. At that time, as part of this notificatio n, DOE will identify its plan to provide EPA with documentation on how CH container-specific AK information was handled, including nondestructive assay (NDA) data on the individual drum s, and other supporting information, as appropriate.

The Waste Characterization Program Implementation P lan (WCPIP) issued by DOE should be an accurate representation of the processes impleme nted by the RH waste sites. During this and several previous RH inspections, EPA concluded that the current version of the WCPIP does not reflect the processes approved by EPA. As a result , in April 2009, DOE HQ made a

commitment that CBFO will revise the WCPIP before i ts implementation at any new RH site requiring a baseline approval (e.g., Hanford). As a result, in August 2009, EPA received the revised version. EPA is currently reviewing the WC PIP and will work with DOE to produce a technically adequate version of the WCPIP. EPA wil l concur with the revised WCPIP prior to its implementation at a new RH site.

Table 1. Tiering of RH TRU WC Processes Implemented by GEVNC-CCP,

Based on December 2–4, 2008 Baseline Inspection

RH WC Process Elements GEVNC-CCP RH WC - T1 Changes GEVNC-CCP RH WC - T2 Changes*

Acceptable Knowledge (AK) None** Notification and submission of the following items:

- Correlation and Surrogate Summary Form; (AK 2) - Revisions to the AK Summary CCP-AK-GEV-500, including changes to the associated Reference List; (AK 6) - Updates and revisions to CCP-AK-GEV-501; (AK 12) - Revision of reference M007; (AK 12) - Additional discrepancy resolutions; (AK 13)

- Final Waste Stream Profile Form and related attachments, and subsequent change requests; (AK 14 ) - AK Accuracy reports for this waste stream; (AK 1 5)

Radiological Characterization, Dose-to-Curie (DTC), and theapplication of radionuclidespecific scaling factors None** Notification and submission of the following items:

- Revisions of CCP-AK-GEV-501 or CCP-TP-504 that require CBFO approval; (RC 3)

- Generation of measurement data for any GEVNC RH TRU container(s) that subsequently qualifies as CH and is subject to NDA; (RC 8)

Visual Examination (VE) None** Notification and subm ission of the following items:

- Any change to VE procedure(s) that requires CBFO approval; (VE 2)***;

WIPP Waste Information System (WWIS) None at this time Notification and submission of the following items:

- Changes to WWIS procedure(s) that require CBFO approval; (WWIS 2)***;

- Changes to the Excel spreadsheet titled WWIS Dat a4

RH WC Process Elements GEVNC-CCP RH WC - T1 Changes GEVNC-CCP RH WC - T2 Changes*

Entry Summary Characterization and Certification; (WWIS 2)

* All applicable T2 changes must be provided to EPA in a one-time submission following completion of t he last shipment of GEVNC RH debris proposed for approval to WIPP for di sposal

** No additional RH waste from GEVNC will be characte rized using the site processes evaluated during the inspection *** Excluding changes that are editorial in nature or are required to address administrative concerns

2.0 PURPOSE OF INSPECTION

On May 18, 1998, EPA certified that the WIPP will c omply with the radioactive waste disposal regulations in 40 CFR Part 191. In this certificat ion, 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 for disposal at the WIPP until the Agency has approved the processes for characterizing those waste streams for shipment usi ng the process set forth in § 194.8.” The approval process described in 40 CFR 194.8 requires DOE to (1) provide EPA with information

on AK 1 for waste streams proposed for disposal at the WIP P, and (2) implement a system of

controls used to confirm that the total amount of e ach waste component that will be emplaced in

the WIPP will not exceed limits identified in the W IPP Compliance Certification Application.

The rule applying to this baseline inspection can b e found in the FR (Vol. 69, No. 136, pp. 42571–42583, July 16, 2004). Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, FR notice, EPA must perform a baseli ne inspection of a TRU waste generator site’s WC program. The purpose of the baseline ins pection is to approve the site’s WC program based on the demonstration that the program’s compo nents, with applicable conditions and limitations, can adequately characterize TRU wastes and comply with the regulatory requirements imposed on TRU wastes destined for dis posal at the WIPP. An EPA inspection team conducts an on-site inspection to verify that the site’s system of controls is technically adequate and properly implemented. Specifically, E PA’s inspection team verifies compliance with 40 CFR 194.24(c)(4), which states the followin g:

Any compliance application shall: . . . Provide inf ormation which demonstrates that a system of controls has been and will continu e to be implemented to confirm that the total amount of each waste component that will be emplaced in the disposal system will not exceed the upper limiting value or fall below the lower limiting value described in the introductory text o f paragraph of this section. 2
The system of controls shall include, but shall not be limited to: measurement;

1 As of the FR notice of July 16, 2004, EPA has repl aced the term process knowledge with acceptable knowledge . Acceptable knowledge refers to any information a bout the process used to generate waste, material inputs to the process, and the time period during w hich the wastes were generated, as well as data res ulting from the analysis of waste conducted prior to or separate fr om the waste certification process authorized by an EPA certification decision to show compliance with Cond ition 3 of the certification decision.

2 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 shal l 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 e rror) for each limiting value, of the total inventory of such wast e proposed for disposal in the disposal system.”5

sampling; chain of custody records; record keeping systems; waste loading
schemes used; and other documentation.

In other words, the purpose of the baseline inspect ion is to implement the requirements of 40 CFR 194 by assessing whether DOE sites that char acterize TRU waste prior to disposal at the WIPP are capable of characterizing and tracking the waste. EPA also may conduct follow-up inspections to address issues remaining from the ba seline inspection or to seek further clarification/discussion related to WC processes ev aluated during a baseline inspection. By approving the CCP-implemented WC systems and proces ses at GEVNC-CCP for RH debris waste, EPA confirms that the Agency has evaluated t he capabilities of systems and processes implemented by the site to accomplish two tasks: ( 1) the identification and measurement of waste components, such as plutonium, that must be t racked for compliance, 3 and (2) the confirmation that the waste in any given container has been properly identified as belonging to the group of approved waste streams.

Following EPA’s approval of the WC processes evalua ted during the baseline inspection, EPA is authorized to evaluate and approve, if necessary, c hanges to the site’s approved WC program by conducting additional inspections under the authori ty of 40 CFR 194.24(h). Under 40 CFR 194.24, EPA has the authority to conduct con tinued compliance inspections to verify that the site continues to use only the approved WC processes to characterize the waste and remains in compliance with all regulatory requireme nts. Based on the adequacies of the WC processes demonstrated during the baseline inspecti on, including all conditions and limitations, EPA will specify which subsequent WC program change s or modifications must undergo further EPA inspection or approval under 40 CFR 194.24. EP A accomplishes this by assigning a tier level to selected aspects of the characterization p rogram, as described below.

T1 activities have more stringent reporting require ments and require DOE to notify EPA and receive the Agency’s approval prior to implementing the change. DOE will report T2 activities to EPA based on the frequency established in the in spection report. DOE may choose to characterize and dispose of materials at its own ri sk while EPA considers the proposed T2 changes. EPA does not expect CCP to require any ch anges to the approved RH characterization program implemented at GEVNC.

3.0 PURPOSE OF THIS REPORT

This report documents the basis for EPA’s approval and explains the results of Baseline Inspection No. EPA-GEVNC-CCP-RH-12.08-8 in terms of findings or concerns. It also responds to public comment specific to the proposed approval of June 2009. Specifically, this report does the following:

3 The potential contents of a single waste stream or group of waste streams determine which processes c an adequately characterize the waste. For example, if AK suggests that the waste form is heterogeneous, the site should select the matrix-appropriate radiological characte rization technique to obtain adequate radionuclide measurements. VE serves to confirm and quantify waste components, such as cellulosics, rubbers, plastics, and metals . Once the nature of the waste has been confirmed, characteriz ation techniques quantify selected radionuclides in the waste. In some cases, a TRU waste generator site may be able to characterize a range of heterogeneous waste stre ams or only a few. A site’s stated limits on the applicability of proposed WC processes govern the scope of EPA’s inspection.6

• Describes the GEVNC-CCP WC systems for approval

• Delineates a specific set of RH wastes for approval

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

• Identifies all relevant system limitations and/or c onditions for each WC system and/or waste containers that are subject to this approval

• Identifies T1 and T2 elements, as applicable

• Provides objective evidence of EPA’s findings or co ncerns, as applicable, including their

resolution and status

The listings in each section reference the document s that the EPA inspection team members 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

U.S. DOE/Carlsbad Field Office

P.O. Box 3090 Carlsbad, NM 88221.

EPA’s final approval decision regarding the GEVNC-C CP RH WC program will be conveyed to DOE separately by letter following EPA’s review of public comments received responding to a proposed approval discussed in this report. In acc ordance with 40 CFR 194.8(b)(3), this

information is also available on EPA’s Web site at http://www.epa.gov/radiation/WIPP.

4.0 SCOPE OF INSPECTION

The scope of Baseline Inspection No. EPA-GEVNC-CCP- RH-12.08-8 included the technical adequacy of the WC systems used by GEVNC-CCP to char acterize RH Waste Stream GEVNC.01. The EPA inspection team evaluated these s ystems with respect to their ability to perform the following functions:

• Identify and quantify the activities of the 10 WIPP -tracked radionuclides ( 241 Am, 137 Cs,

238 Pu, 239 Pu, 240 Pu, 242 Pu, 90 Sr, 233 U, 234 U, and 238 U) and other TRU radionuclides using a combination of AK and DTC with the application of r adionuclide scaling factors

• Assign waste material parameters (WMPs) correctly u sing VE for RH, retrievably-stored debris waste that was repackaged

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

The focus for characterization of RH TRU debris was tes was technical evaluation of AK, DTC, VE, and WWIS, including the identification and quan tification of the 10 WIPP-tracked radionuclides listed above. The inspection’s scope consisted of reviewing records and observing WC practices performed by GEVNC-CCP. Specifically, these systems consisted of the following components:7

• The AK process for characterization of radiological and physical contents of S5000 RH

TRU debris waste

• The DTC system implemented at GEVNC for the measurem ent of the external dose rate of RH TRU debris waste, supported by the applicatio n of radionuclide-specific scaling

factors

• VE for RH TRU debris waste

• The WWIS for the purpose of data transfer for waste components of all RH TRU waste containers that are destined for WIPP emplacement

During an inspection, EPA does not approve characte rization data; that function is the sole responsibility of the site being evaluated, in this case, GEVNC-CCP. EPA evaluated the site’s WC processes to characterize RH TRU debris waste. The evaluation consisted of interviewing personnel, observing equipment operations and WC pr actices controlled by site procedures, and inspecting records related to each of the WC proces ses within the inspection’s scope. An important aspect of this evaluation was the objecti ve evidence documenting the effectiveness of the WC processes. Objective evidence typically tak es the form of batch data reports (BDRs), Radioassay Data Sheets, AK accuracy reports, VET re cords from two-person examinations, and WWIS printouts for specific TRU containers. During this inspection, EPA selected samples of each of these items, based on the number and variet y of items each WC process produced, consistent with standard auditing techniques. Beca use the WC activities at GEVNC-CCP have been operational for a short time, EPA selected all the DTC and VE BDRs that had been generated, essentially a 100% sample. Based on the evaluation of the WC processes in conjunction with the objective evidence, EPA determ ined the technical adequacy of the WC processes and records within the inspection’s scope

.

5.0 INSPECTION-RELATED DEFINITIONS

During the course of an inspection, EPA inspectors may encounter items or activities that require further inquiry for their potential to adversely af fect WC and/or isolation within the repository. The two main categories relevant to WC 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 prior to site approval.

• Concern : A judgment that a specific item or activity may or may not have a negative effect on compliance and, depending on the magnitud e of the issue, may or may not require a response. A concern requiring a response requires a response from CBFO prior to site approval.

6.0 PERSONNEL

6.1 EPA Inspection Team

The members of the GEVNC-CCP EPA WC inspection team are identified in Table 2.8 Table 2. EPA Inspection Team Members

Inspection Team Member Position Affiliation

Mr. Edward Feltcorn Inspection Team Leader U.S. EPA ORIA

Ms. Rajani Joglekar Inspector U.S. EPA ORIA

Ms. Connie Walker Inspector S. Cohen & Associates

Ms. Dorothy Gill Inspector S. Cohen & Associates

Mr. Patrick Kelly Inspector S. Cohen & Associates

6.2 Personnel Contacted

EPA and its support personnel conducted interviews with GEVNC-CCP personnel in several disciplines on several occasions. The personnel co ntacted represent a sample of the GEVNCCCP WC staff and are listed in Table 3, along with their affiliation and technical area. This listing includes personnel present at all meetings conducted as part of this baseline inspection.

Table 3. Personnel Contacted During Inspection

Personnel Name Affiliation Area of Expertise, Function

Jene Vance CCP Radiological Characterization Buddy Fussell CCP VPM Michael Sensibaugh CBFO WTS RH Manager Tommy Mojica CCP/URS VEE Alyca Attwood CCP CCP Records

Joe Tenorio CCP VEO

Mike Ramirez CCP WCO Joe Harvill CCP Radiological Characterization David Moody CCP Radiological Characterization Hillari Neely CCP SPM Irene Quintana CCP Lead RH SPM Creta Kirkes CCP WWIS, WCO Sheri Nance CCP AK, AKE Steve Schafer CCP AK, AKE Kevin Peters CCP AK, AKE Lisa Watson CCP AK, AKE Mark Doherty CCP AK, AKE J.R. Stroble DOE/CBFO RH Certification Manager

7.0 PERFORMANCE OF THE INSPECTION

Background and History

GEVNC is a 1,600-acre facility located in Sunol near the cities of Pleasanton and Livermore, California. GEVNC has four nuclear reactors, exper imental critical facilities, hot cells, laboratories and engineering facilities, all of whi ch have supported a variety of nuclear research for the U.S. Navy and DOE since the 1950s. The ran ge of activities at GEVNC since its inception includes defense and non-defense related work with nuclear fuels, waste stabilization and reactor startup source manufacturing. Alpha Ho t Cell 4 in Building 102 was also used to manufacture Californium-252 ( 252 Cf) and Americium-Beryllium (Am-Be) neutron sources . DOE9

plans to decontaminate Hot Cell 4 and use it for co mmercial purposes upon removal of all the

RH TRU wastes.

Inspection Process Overview

EPA conducted Baseline Inspection No. EPA-GEVNC-CCP -RH-12.08-8 of GEVNC-CCP’s program to characterize RH TRU wastes at GEVNC from December 2 through 4, 2008. This inspection had the scope described in Section 4.0 f or the purpose of determining the site’s compliance with 40 CFR 194.24. The inspection was conducted in the following steps:

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

to RH WC activities used to characterize GEVNC Waste Stream GEVNC.01

(2) Preparing technical questions prior to the inspecti on based on the activities cited in (1)

above

(3) Interacting with CBFO and GEVNC-CCP personnel to ar range inspection logistics

(4) Evaluating GEVNC-CCP’s implementation of WC process es for adequacy and demonstrating compliance with 40 CFR 194.24 require ments

(5) Conducting the baseline inspection at GEVNC to verif y the technical adequacy and/or qualifications of RH WC personnel, procedures, proc esses, and equipment

(6) Recording five concerns and one finding on EPA Insp ection Issue Tracking Forms, which were completed and provided to CBFO and GEVNC- CCP personnel as they were generated (see Attachments B.1 through B.6 for a co py of these forms)

(7) Communicating all pertinent information to CBFO and GEVNC-CCP personnel

(8) Pursuing resolution of all identified issues prior to completion of the inspection, when

feasible

(9) Conducting entrance, exit, and daily briefings for CBFO and GEVNC-CCP management personnel

(10) Obtaining and reviewing GEVNC-CCP documents that wer e revised in response to the EPA concerns after the inspection, and closing all concerns when possible

(11) Issuing the inspection report and proposed approval

8.0 TECHNICAL EVALUATION

Sections 8.1 through 8.4 of this report detail the four technical areas assessed during this inspection:

• AK

• Radiological Characterization (performed by applica tion of DTC)

• VE

• WWIS10

8.1 Acceptable Knowledge

EPA examined the AK process and associated informat ion to determine whether GEVNC-CCP demonstrated compliance with 40 CFR 194.8 requireme nts for RH waste stream GEVNC.01.

WC Element Description

As part of the inspection, EPA reviewed the followi ng with respect to the use of AK for RH waste characterization by GEVNC-CCP:

• Inspection scope and waste stream identification to verify that the subject waste is not high-level waste (HLW), low-level waste (LLW), spen t nuclear fuel (SNF)

• Role of AK in the characterization methodology, inc luding use of AK to support scaling factors derived by GEVNC-CCP

• Adequacy of Waste Characterization Program Implemen tation Plan (WCPIP) AK process implementation

• Adequacy of the AK Summary Report (AKSR)

• AK data traceability

• AK source document sufficiency

• WCPIP interpretation with respect to AK qualificati on

• Confirmatory Test Plan (CTP) preparation and plan a dequacy

• Characterization Reconciliation Report (CRR) prepar ation and plan adequacy

• Correlation and Surrogate Summary (CSS) form and CH -RH correlation

• Personnel training and qualifications

• Non Conformance Reports (NCRs) and AK discrepancy re solution

• AK accuracy

• Plans for load management

• Identification of the method for determining DQOs a nd DQOs attained through AK Qualification

Documents Provided

The following documents were provided for review:

• CS-OP-PN-015, Sampling and Analysis Plan GE Valleci tos Nuclear Center Hot Cell No. 4, Revision 0, Project No 13706, Effective Date May 30, 2008

• CCP-AK-GEV-500, Central Characterization Project Ac ceptable Knowledge Summary Report For General Electric Vallecitos Nuclear Cente r Waste Stream: GEVNC.01 – Hot Cell Debris Waste, Revision 1, October 28, 200811

• CCP-AK-GEV-501, Central Characterization Project Re mote-Handled Transuranic Radiological Characterization Technical Report For Remote-Handled Transuranic Debris

Waste from the General Electric Vallecitos Nuclear C enter (GEVNC) Revision 0, October 30, 2008

• CCP-AK-GEV-502, Central Characterization Project Re mote-Handled Transuranic Waste Certification Plan For 40 CFR Part 194 Compli ance and Confirmation Test Plan

For General Electric Vallecitos Nuclear Center Waste Stream: GEVNC.01, Revision 0, October 30, 2008

• CCP-TP-005 Revision 18, CCP Acceptable Knowledge Do cumentation Effective Date: November 16, 2006, CCP-TP-005, Revision 18

• Interoffice Correspondence, from I Quintana to CCP Records; Acceptable Knowledge Accuracy Evaluation for Waste Containers in Waste S tream GEVNC.01, Lot 1, Revision 2, December 3, 2008

• Interoffice Correspondence for Audit Purposes Only, from C. Gomez to M. Sensibaugh, Acceptable Knowledge Accuracy Report: General Elec tric Vallecitos Nuclear Center, Waste Stream Number GEVNC.01 Lot 1, Revision 2, Dec ember 4, 2008

• Acceptable Knowledge Source Document Discrepancy Re solution for Waste Stream GEVCN.01, Hot Cell Debris Waste, EPA Hazardous Wast e Number Revisions, K. Peters, December 3, 2008

• CCP-TP-506, Revision 2, Preparation of the Remote-H andled Transuranic Waste Acceptable Knowledge Characterization Reconciliatio n Report, Effective Date: June 8,

2008

• C011, Memorandum to Frank Marcinowski from W. M. Ro se, RE: Defense Determination, GE Vallecitos, March 27, 2005

• NMED Waste Stream Profile Form for GEVNC.01, provide d December 2, 2008, and attached Characterization Information Sheet (CIS)

• EPA Waste Stream Profile Form Attachment 4 GEVNC.01 and attached CRR, Undated, provided December 1, 2008

• CRR Container Data Worksheets for Container Nos. GE 003, GE004, GE007, GE008,

GE009 and GE010

• Interoffice Correspondence, from R.J. Walker to Rec ords, Acceptable Knowledge Accuracy Evaluation for Waste Containers in Waste S tream GEVCN.01, December 1, 2008, (NMED) Revised December 3, 2008

• Interoffice Correspondence, from C. Gomez to M. Sen sibaugh, Acceptable Knowledge Accuracy Evaluation for Waste Containers in Waste S tream GEVNC.01, Lot 1, December 1, 2008, (NMED), Revised December 3, 2008

• Training Records: Christine Gomez, Irene Quintana, Mark Doherty, Kevin Peters, Provided November 18, 2008 and December 2, 2008

• CCP-TP-005 Attachment 5, Hazardous Constituents, No vember 13, 200812

• CCP-TP-005, Attachment 6, Waste Form, Waste Materia l Parameters, Prohibited Items, and Packaging, General Electric Vallecitos Nuclear C enter, and related WMP Calculation Memorandum, August, 2008

• CCP-TP-005 Attachment 8, Acceptable Knowledge Accur acy Report, November 20,

2008

• Headspace Gas Summary Report for GEVNC.01, Lot 1 Co ntainers GE001-GE010, November 21, 2008

• CCP Waste Stream Characterization Checklist, Waste Stream No. GEVNC.01, undated, provided December 2, 2008

• Interoffice Correspondence, from R.J. Walker to CCP Records, Re: Subsequent Headspace Gas Random Sample Selection Candidate Mem orandum for Lot 1 of

Containers of Waste Stream GEVCN.01 Characterized b y the Central Characterization Project at General Electric Vallecitos Nuclear Cent er, October 29, 2008

• CCP-TP-005, Revision 18 CCP Waste Stream Characteri zation Checklist, undated, provided December 1, 2008

• CCP-TP-005, Attachment 8 Waste Containers November 1 9, 2008; this includes 16 containers, however container Nos. 01, 02, and 05 m ay be removed since their assay values are expected to be less than 100 nCi/g

• CCP-TP-005, Attachment 1, Acceptable Knowledge Docu mentation Checklist, GE Vallecitos Nuclear Corporation, GEVNC.01 Waste Strea m

• CCP-TP-005, Revision 18, Acceptable Knowledge Sourc e Document Reference List, November 19, 2008

• CCP-TP-500, Revision 8, Attachment 3 Visual Examina tion Site Project Manager Checklist—BDR RHGEVE08001, 8002, 8003

• CCP-TP-504, Revision 7, Attachment 8 SPM Checklist BDRGEVRHDTC08003, includes Container Nos. GE008 and GE007, November 1 3, 2008

• NCR GEVNC-0500-08, Uncertainty calculation on the GE VNC Dose-to-Curie spreadsheet contained a mathematical error

• Transmittal of Completed Chain of Custody Forms, CH WM WG, from James Kaylor, INTEC Area Operations to Paul Gomez, May 9, 2006.

• CCP-TP-504, Revision 7, Attachment 8, SPM Checklist BDRGEVRHDTC08001, includes Container Nos. GE003 and GE004, November 1 7, 2008

• CCP-TP-504, Revision 7, Attachment 8, SPM Checklist BDRGEVRHDTC08002, includes Container Nos. GE009 and GE0010, November 1 7, 2008

• BDR No. GEHSGS08001 Containers GE001-010, HSG Summa Sampling Project Level Validation Checklist and Summary, CCP-TP-001 Revisi on 17, Attachment 10, November 1, 200813

• C007, Memorandum to R.E. Butler regarding Estimate of Surface Contamination in Cell Four, Ben Murray, November 18, 1982

• C012, Interview by Mark Doherty of Joseph Tenorio, Manager, RH Operations Re: GEVNC Hot Cell 4 Operations Information, Mark Doher ty Attachment 2, May 8, 2008

• C013, Interview by Mark Doherty of Stan Lukezic, Ho t Cell Operator Re: GEVNC Hot Cell Operations Information, Mark Doherty, Attachme nt 3, May 10, 2008

• C020, Correspondence to T.W. Darmitzel from Jo Cull en, RE: Decontamination and Decommissioning Activities at GE, January 9, 1991

• C024, Correspondence from Mike Dammann to Rodney Me lgard, RE: Request for Service and Price Quotation, authored by Melissa Ma nnion, July 29, 2008

• C025, Correspondence from Melissa Mannion to Steve Croslin, RE: Purchase Order No PO-004366 EAC R806140-3773 and R806141-3774, Radioc hemistry Report for 20 Smear Samples, September 18, 2008

• DR001, Use of Paint Products in Hot Cell 4, K. Pete rs, December 3, 2008

• M001, Material Hazard Control 1973, 1973-1974

• M002, 1996 BEMR General Electric Vallecitos Nuclear Center, U.S. Department of Energy, Office of Environmental Management, Novembe r 8, 1999

• M006, Chemical Inventory for WEP, RHO Cribb, RHO Co ntrolled Area, RHO Shop Area and Electric Shop, undated

• M007, Memo to file from Mark Doherty Re: Calculati on of WMPs for GEVNC, Mark Doherty, August 1, 2008

• M008, General Electric Vallecitos Nuclear Center, E. J. Strain, undated

• M013, Hot Cell Facility, Drawing, undated

• M014, Remote Handling Operations and Building 102 M ain Floor-Radioactive Materials Area Diagram, undated

• M015, Container Certification No 1080, US DOT 7A Typ e A- Radioactive Materials, Andy Lopez, May 30, 2002

• M016, Visual Examination Data Forms for Repackaged Drums, CCP, November 18,

2008

• M017, Purchase Order No: PO-004366 from Energy Solu tions to Eberline Services, PO004366, Katharine V. Hatfield, July 21, 2008

• M018, Specifications for Sample Analysis for GE VNC Hot Cell 4, Eberline Services, July 18, 2008

• M019, Southwest Research Institute Sample Analysis Data Sheet, 080802-1, Southwest Research Institute, August 1, 2008

• M020, Standard Purchase Order- General Electric Com pany to Energy Solutions, 43701177, C. Suggs, March 25, 200814

• M021, Hot Cell 4 Smear Sample Log- Eberline Analysi s, Willie Mah, May 30, 2008

• M022, Hot Cell Smear Locations, undated

• M023, Summary Report for GE Vallecitos Hot Cell No 4 Samples, Steve Croslin, December 4, 2008

• P001, Processed Isotope Procedures - Calibration of Neutron Sources, S.K. Jain, Chapter X, Section UU, Revision 0, November 12, 1973

• P002, Remote Handling Technician Training Checklist - R54 (January 1977); Irradiated Materials Examination - Special, Section J. Fission Gas Puncture and Collection System (Fission Gas Release Program) J. I. Tenorio, G. P. Wozadlo, Serial No. RPoS362, January 28, 1977; August 2, 1978

• P012, Design Change Authorizations for conversion o f existing beta-gamma hot cell to an alpha-gamma hot cell, operation of the Cell 4 in terlock, and procedure for chemical plutonium separation and transfer from Alpha Cell t o N.L. Building 103, 1965-1972

• P013, Cell 4 Standard Operating Procedures and Cs-1 37 Procedure

• P015, Radioactive Waste Shipments to Hanford Retrie vable Storage from the General Electric Vallecitos Nuclear Center, Pleasanton, Cal ifornia, E. J. Vejvoda, J. A. Pottmeyer, D. S. DeLorenzo, M. I. Weyns-Rollosson, D. R. Dunca n, WHC-EP-0672 N/A, October

1993

• P016, File Drawer Cell 4: Flanders Alpha Cell PB-1 401-1003, Operating Experience of G.E. Alpha Cell, Conversion of a Beta-Gamma Hot Cel l for Examination of PlutoniumEnriched Fuel Capsules; Letter from J. E. Corrigan to W. H. Bone regarding Proposed Alpha SOP; G. L. Stimmell and N. C. Howard; E. Corri gan, N. C. Howard, and G. L. Stimmell; J. E. Corrigan, 2003, 1969 and November 1 966

• P031, HAW Sedimentation J. A. Cook, Revision 0, Mar ch 7, 1972

• P033 REDACTED Operations Change Notice; Section D. Part 1. Failed Low Enrichment Fuel Rods, Bonnie Streitz; J. A. Cook, S erial No. REDACTED 606; February 1, 1979; June 13, 1972

• P036 Settlement Agreement Between The United States Department of Energy (DOE) and General Electric Vallecitos Nuclear Center (GEV NC) Concerning Expired Contracts, October 23, 2007

• P039, Cesium-137 Change Authorization and Work Plan for Cesium-137 Microsphere Processing for 3M Company, J.B. Meyers, IP-102-66, September 7, 1978

• P042, The Vallecitos Nuclear Center Hot Cells, R. E . Butler, T. C. Hall, D. Dutina, NEDO-12732, November 1979

• P049, Quality Assurance Program Manual, QAM, Eberli ne, Rodney Melgard, July 31,

2007

• P050, Quality Assurance Procedures Manual, QAP, Ebe rline, Rodney Melgard, October 25, 200715

• P051, Quality Control Laboratory Procedures Manual, QCL, Eberline, Katsumi Yamamoto, April 16, 2008

• P052, Section E, Part 2, REDACTED NaK Filling Proce dure, S.K. Jain, October 19,

1972

• P053, REDACTED, Operations Change Notice, Section F , Part 1, Preparation of Capsule for Shipment to [REDACTED], Ferguson and Cook, Dece mber 6, 1971 and September 16, 1972

• P054, Chapter XII, Irradiated Materials Examination , General Section K, Fuel Rod Decrudding, R.W. Burton, June 6, 1978

• P056, HEDL Vender Fuel Irradiation Program PP&S Det ailed Work Plan No.6- Desctructive Examination, June 14, 1974

• P059, SW-846 Method 6020 Inductively Coupled Plasma Mass Spectrometry Analysis, TAP-01-0406-046, Chad Vailey, March, 2008

• P063, Nickel Purification Reactor Procedure, RP-281 , January 10, 2008

• P067, Purification of AM-CM in Reactor Waste Sample s, RP-966, January 10, 2008

• P071, I-129 Purification-Reactor Procedure, RP-530, January 10, 2008

• P079, Energy Solutions Work Plan Decontamination an d Disposal of Hot Cell 4 Waste for the GE-Hitachi Radioactive Materials Laboratory(Project No.137076), CS-OP-PN017, Energy Solutions, LLC, September 29, 2008

• P080, GEH Vallecitos Nuclear Center Hot Cell Projec t, TRU Waste Removal Work Instruction (Project No.137076), CS-WM-WI-005, Ener gy Solutions, LLC, October 2,

2008

• P099, Eberline Services Inc., Richmond Laboratory I nternal Audit Report, Anthony W. Toth, November 30, 2007

• P100, Vallecitos Nuclear Center Alpha Cell 4 Decont amination and Radwaste Removal Project; Supplement 36 of Quality Assurance Program 2, QAP-2, Supplement 36, GEVNC, October 8, 2008

• P101, Quality Assurance Program, ES-QA-PG-001, Rich ard E. Campbell, May 31, 2007

• P102, Quality Assurance Program for Vallecitos Oper ations Products and Services QAP2, C. Bassett, January, 2006

• P103, Cell 4 Smear Standard Operating Procedures No . 087-14, J. Tenorio, May 29, 2008

• P104, Reactor Waste Work Plan for Damp Smear Swab, Sample ID 3773, Eberline,

undated

• P105, Reactor Waste Work Plan for Damp Smear Swam S ample ID 3774, Ebelrine, January 14, 2008

• U006, RP&S Materials Hazard Control

• U009, Logbook RML-575, 1971 to 197516

• U015, Logbook RML-453, R.E. Smith, RML-453, October 23, 1969

• U016, Logbook RML-479, R.E. Smith, RML-479, July 2, 1970

• U017, Logbook RML-231, R.E. Smith, RML-231, 1967

• U022, Volume Estimate, May 20, 1998

• U023, Logbook RML-720, 1974

• U051, Thermo/Nutech Ge(Li) Analysis Report, August 14, 2008

• U052, Iodine Analysis Data, August 8, 2008

• U053, Energy Solutions Analytical Logbook, Logbook 3773, July 23, 2008

• U054, Neptunium-237 Data, August 24, 2008

• U055, Nickel Data, August 11, 2008

• U056, Technetium Data, August 7, 2008

• U057, Plutonium Data, August 10, 2008

• U058, Radiometrics Log Verification Report, August 20, 2008

• U059, Strontium Data, August 8, 2008

• U060, Trans Pu Data, August 11, 2008

• U061, Tritium Data, August 6, 2008

• U062, Uranium Data, August 8, 2008

• U063, Gamma Data, August 13, 2008

• U031, Logbook RML-455: Letter from K. J. Perry to D. L. Zimmerman and G. P. Ferguson regarding the Examination of F8A Fuel Pins ; Metallographic Examination of Task F8A Irradiated Fuel Pins; Metallographic Exami nation of F8A Capsule Tubing

• K. J. Perry, R. E. Smith, November 11, 1969; April 13, 1970; January 30, 1970

• U036, HEDL Vendor Fuel Irradiation Program RP&S Det ailed Work Plan No. 5 - Nondestructive Examination; HEDL Vendor Fuel Irradia tion Program RP&S Detailed

Work Plan No. 6 - Destructive Examination Fuel Pin/ Capsule Nos. 59-63 Revision 0; Revision 0, April 23, 1974; June 14, 1974

• U044, CCP Calculation Package - Cs-137 Scaling Fact or Development, J. Vance, November 19, 2008

• U046, CCP Calculation Package - Fission Product Con tribution to Total Dose Rate, J. Vance, November 19, 2008

• U047, CCP Calculation Package- Determination of Rep ortable Isotopes, J. Vance, November 19, 200817

The VE and DTC BDRs that were examined during this inspection are shown in the table below.

Container No. DTC BDR No. VE BDR No, GE001, GE002 - RHGEVE08001
GE003, GE004 GERHDTC08001 RHGEVE08002
GE005, GE006 - RHGEVE08003
GE007, GE008 GEVRHDTC08003 -

GE009. GE010 GEVRHDTC08002 -

Technical Evaluation

EPA evaluated the adequacy of AK information specif ic to GE Waste Stream GEVNC.01 as described in CCP-AK-GEV-500, which consisted of TRU newly-generated debris waste from D&D of a Hot Cell 4 in the following areas:

(1) The scope of the inspection and waste stream defini tion were examined for Stream CCPAK-GEV-500 and were found to be adequate.

The inspection scope was evaluation of AK documenta tion specific to a single newly-generated debris RH waste stream GEVNC.01. The AK Summary (C CP-AK-GE-500, Revision 1) states that this stream is composed of between 12.5 and 17 m 3 of debris generated in Hot Cell 4 in Building 102. Wastes include HEPA filters, hot cel l equipment, tools, and support materials such as wipes and bottles that will be generated du ring D&D. The current plan is to remove debris as the cell undergoes D&D with the intention of returning the cell to GEVNC to use for purposes that will not generate WIPP-eligible waste . The AK Summary states that wastes will be generated from September 2008 to the “summer” of 2009. Inclusion of any GEVNC waste stream(s) for disposal at WIPP other than GEVNC.01, is not permitted under this baseline approval. No additional RH TRU waste from D&D activ ity is expected to be generated requiring WIPP disposal.

(2) The Correlation and Surrogate Summary Form (CSSF) p rocess was evaluated and was found to be adequate.

GEVNC-CCP indicated that a CSSF had not been prepare d. Attachment A Section 5.3 of the

WCPIP states:

If correlations and similarities between CH TRU and RH TRU waste operations at the generator/storage site can be demonstrated, include characterization information for the CH TRU waste as part of the RH T RU waste stream AK information to meet the required DQOs. Such correla tions must be documented on the Correlation and Surrogate Summary Form (Atta chment 3) and included as part of the AK Summary Report.

GEVNC-CCP representatives stated that three CH drums from the D&D activity would be generated and will be shipped to Idaho National Lab oratory (INL) for full characterization and disposal as a CH waste stream. EPA must be notifie d of the characterization and disposal of GEVNC CH waste containers by INL-CCP. It is expecte d that this information will provide18

useful information to the GEVNC RH program, and the information from this CH characterization process must be shared with GEVNC- CCP representatives to be used and integrated as applicable. When this occurs, a CSSF must be prepared and provided to EPA as a T2 change.

(3) Traceability of wastes was examined and was found t o be adequate.

The waste included in this waste stream was describ ed by GEVNC-CCP representatives as “newly generated.” Therefore, traceability of cont ainers with respect to original packaging receipts could not be performed. BDRs were provide d, as indicated in the table, above. Selected

drums could be traced to the DTC and VE BDRs.

(4) Identifications of HLW, TRU versus LLW, and SNF were examined and were found to have been defined appropriately.

The AK Summary examined during the inspection (CCP- AK-GE-500 Revision 1) stated the following with regard to SNF in the waste:

... Waste Stream GEVNC.01 consists of debris waste gene rated during the decontamination of Hot Cell 4 contaminated during t he examination of irradiated fuel materials. These operations did not involve s eparation or reprocessing of constituent elements from reactor fuel and the wast e stream does not contain the irradiated fuel elements withdrawn from a reactor. Therefore, the waste is not a spent nuclear fuel or high-level waste and is eligi ble for disposal at WIPP as RH TRU waste (Reference C011).

EPA pointed out that this explanation lacked detail [see (6), below], and should be revised to better address why the waste is not spent nuclear fuel. As a result of EPA’s concern, GEVNCCCP revised the AK Summary (Revision 2) to state th e following:

According to the NWPA, spent nuclear fuel is “fuel that has been withdrawn from a nuclear reactor following irradiation, the consti tuent elements of which have not been separated by reprocessing.” The DOE Radio active Waste Management Manual (Reference 26) expands on this definition to clarify that “Test specimens of fissionable material irradiated for research and development only, and not production of power of plutonium, may be classified as waste, and managed in accordance with the requirements of this Order when it is technically infeasible, cost prohibitive, or would increase work exposure t o separate the remaining test specimens from other contaminated material.

GEVNC-CCP stated that while fuel pins are removed, t hese are test specimens and waste associated with these fuel pins may be classified a s TRU wastes. The AK Summary also states:

High-level waste is defined by the NWPA as “the high ly radioactive material resulting from the reprocessing of spent nuclear fu el, including liquid waste produced directly in reprocessing and any solid mat erial derived from such liquid19

waste that contains fission products in sufficient concentrations, and other highly
radioactive material that the Commission, consisten t with existing law, determines by rule requires permanent isolation”. Waste Stream GEVNC.01 consists of debris generated during the decontamina tion of Hot Cell 4 contaminated during the examination of irradiated f uel materials...and did not involve separation or reprocessing of constituent e lements from reactor fuel.

GEVNC-CCP therefore states that GEVNC.01 wastes are, by definition, not HLW.

(5) Waste defense determination was evaluated and was f ound to be appropriate.

GEVNC-CCP states that: “a variety of defense-relate d research activities were conducted in Hot

Cell 4” and that Hot Cell 4 contained radioactive c ontamination from the manufacturing of sources for Knolls Atomic Power Laboratory and the Naval Sea System Command. GEVNCCCP also states that ceramic pellets containing 239 Pu were manufactured for the Lawrence Livermore SYNROC-D research program. GEVNC-CCP the n concludes that while the majority of work performed in Hot Cell 4 was non-defense rel ated, there is radioactive material within Hot Cell No. 4 that supported defense research and Naval Reactors. Since segregation of defense and non-defense activities did not take pla ce, GEVNC-CCP concludes that all waste is potentially contaminated with defense-related radio nuclides and is therefore eligible for disposal

at WIPP.

(6) Sufficiency of the Acceptable Knowledge Summary Rep ort (AKSR) was evaluated and found to be adequate, as was implementation of AK a s required in Attachment A of the

WCPIP.

EPA examined the AKSR for clarity, technical comple teness, and adequacy. EPA found that

several technical and editorial modifications to th e AKSR were required to meet these criteria. This concern was discussed with GEVNC-CCP AK personn el, and EPA included it on an EPA Inspection Issue Tracking Form (see Attachment B.1 of this report for a copy of this form), as discussed below. Please note that two aspects of t his concern are addressed separately: the Confirmation Test Plan (CTP) is discussed under sec tion (9), below; and AK accuracy is discussed under section (15), below.

EPA Inspection Issue No. GEVNC-CCP-RH-AK-08-002CR, Final: CCP-AK-GEV-500 and other AK-related documents require technical and ed itorial modifications to correct errors and clarify information. These modifications include, but are not limited to, the items that are listed

below:

• References for each of the bulleted time-line activ ities presented on pages 8-9 of the AK Summary, and correlation of these activities (throu gh reference to detailed discussions) on pages 12-16 are not provided.

• The AK Summary does not clearly state that Hot Cell 4 will be decontaminated and the interior enclosure will be removed, but the cell wi ll not be demolished and will instead be used in the future for other purposes.20

• Section 4.1 is unclear regarding which discussions address GEVNC as a whole versus activities that took place in Hot Cell 4.

• The AK record does not reflect all changes that wer e made to the waste stream volume and radionuclide scaling factors, including the tex t and tables.

• Information in the text of the AK Summary pertainin g to the Q-tip smears obtained in 1982, including the specific analysis and informati on provided by the activity, is insufficient. This is important because the Sampli ng and Analysis Plan (SAP) apparently uses this information as the basis for developing s pecific aspects.

• The radionuclide discussion in Section 5 does not a dequately address generalized waste composition. Of particular importance are changes in activities/potential radiological contamination pre-post 1978 (i.e., MOX prior with e xceptions, sources post, with exceptions). GEVNC-CCP did not prepare a radiologi cal analysis or table to accompany their own time line that may help make these change s. Note that Section 5.4.10 may also require revision based on EPA Concern No. GEVNC-CCP- RH-AK-08-003CR.

• Table 5 of the CCP-AK-GEV-500 does not adequately r eflect modified radionuclide scaling factors.

• The prohibited item discussion in Section 5.4.12 do es not include an updated and thorough SNF analysis.

• Table 6 is unclear regarding the quantification met hods for TRU Waste, RH Waste, Activity, and determination of the 10 WIPP-Tracked radionuclides.

• Table 6 does not include all AK source documents. It is not clear why reference C007 (e.g., for TRU Waste DQO determinations) is include d.

• Ensure that reference lists, including Attachments 2 (WCPIP) and 4 (CCP-TP-005), include all references presented in CCP-AK-GEV-501.

Concern Response: GEVNC-CCP responded by providing Revision 2 of CCP- AK-GEV 500, dated January 8, 2009. EPA examined this document and determined that Bullets 1-5 and 7-9 were adequately addressed through revision of the A KSR. The initial response for Bullets 6 and 10 did not sufficiently address EPA’s concern. How ever, the revisions were provided subsequently in a freeze-file change. Additionally, over 120 individual new references were

added to the reference list at the end of the revis ed AKSR, Revision 2 (Bullet 11). Some references previously listed were either renamed or apparently removed, and it is unclear whether references were updated to include new info rmation and if coordination of reference revision and updating of AK documents is ongoing. It is important that changes or revisions to references are readily ascertainable, and the reaso ns for revisions are clearly explained. In the future, EPA expects GEVNC-CCP to develop a methodol ogy whereby changes to references are readily apparent on the reference list (e.g., by li sting revision numbers), and any changes to titles of references should also include a way to determin e the reference’s previous title.

Status of Concern: This concern is closed.21

Revisions to the AK Summary CCP-AK-GEV-500 are T2 c hanges, including changes to the associated Reference List (e.g., Attachment 2, Appe ndix A, WCPIP).

(7) Sufficiency of AK Support Documents, including the Sampling and Analysis Plan GE Vallecitos Nuclear Center Hot Cell 4, Revision 0, a nd related document tracking were evaluated and were found to be adequate.

EPA examined several supporting documents, specific ally the Sampling and Analysis Plan (SAP) prepared by GE Vallecitos Nuclear Center and included in GEVNC Hot Cell 4, Revision 0, AK Summary CCP-AK-GE-500 (AKSR) and CCP-AK-GE-50 1 radiological characterization document. With respect to the SAPs, EPA found that there were several inconsistencies throughout the documentation pertaining to the numb er of samples collected, types of samples obtained, etc. During interviews with GEVNC and GE VNC-CCP representatives, it became clear that there was some confusion regarding the n umber of swipe samples initially slated for collection versus the ultimate number of samples th at were actually collected, and the number of Quality Control (QC) samples. GEVNC-CCP did not pr ovide a document that addressed the results of the sampling process (i.e., a sampling r eport), in which any field changes or modifications to the proposed plan must be presente d and explained, and results of the sampling plan implementation discussed. This concern was di scussed with GEVNC-CCP AK personnel, and EPA included it on an EPA Inspection Issue Trac king Form (see Attachment B.2 of this report for a copy of this form), as discussed below

.

EPA Inspection Issue No. GEVNC-CCP-RH-AK-08-001F, F inal: The Energy Solutions SAP for GE Vallecitos Nuclear Center Hot Cell 4 provide s the Energy Solutions proposed sampling locations and sample numbers for swipes to be colle cted from Hot Cell 4. However, the final sample numbers and locations presented in CCP-AK-GE V-500 and 501 are inconsistent with the proposed sample numbers and locations presented in the SAP. There was no report or

memorandum that documented the results of the SAP a s it was implemented, including final sample locations, corresponding sample numbers, and location of field duplicates and associated sample identifiers. Needed information includes wh ether any trip blanks or other field-related quality control samples were collected, and whether these were transmitted to the laboratory for analysis. It may be necessary to revise discussion s in CCP-AK-GEV-500 and 501 to be internally consistent and to reflect the results pr ovided. Once these documents have been revised, they should be provided to EPA, along with the report or documents from Energy

Solutions.

Concern Response: GEVNC-CCP provided revisions to CCP-AK-GEV-500 and 501, as well

as reference M023 that documented the results of th e sampling and analysis effort, providing infield modifications to the program and clarificatio n pertaining to sample collection locations, sample numbers, etc. In summary, reference M023 cl arifies that eleven samples and one duplicate (for a total of 12 samples) were collecte d; this number included an additional smear sample that was collected in-field to ensure that s ufficient samples were available in case of sample damage or loss. In addition to these 12 sam ples, nine more samples were collected for “radiological protection purposes and analyzed by g amma spectroscopy”. These nine sample

results were “not used for DOE waste characterizati on purposes”. No irregularities were noted with respect to the set of 12 smears collected for WIPP characterization purposes. As a result of22

this information, both CCP-AK-GEV-500 and 501 were revised to address the correct sample

numbers and locations. In the case of CCP-AK-GEV-5 01, modifications were made to scaling factors and other information based on the updated sampling information and changes to specific technical documents were also made [see 8.2(2)].

Status of Concern: This concern is closed.

In addition to the above concern, the WCPIP include s specific requirements for SAP. Comparison of the Energy Solutions’ SAP against the sampling and analysis requirements in the WCPIP produced a concern, which was discussed with GEVNC-CCP AK personnel, and EPA included it on an EPA Inspection Issue Tracking For m (see Attachment B.3 of this report for a copy of this form), as discussed below.

EPA Inspection Issue No. GEVNC-CCP-RH-AK-08-003CR, Final: The SAP must meet the requirements as specified in Attachment C, Section 6 of the RH WCPIP. Please address the following:

• The WCPIP states that the sampling plan “...shall be developed using the guidance provided in EPA QA/G5 and QA/G9.” Please indicate how this was attained.

• According to the WCPIP, the waste may include mater ials in which the “RH TRU materials embedded in...other solid material may requ ire samples to be obtained from within the material.” Based on the available data, please address whether any material are present in the GEVNC waste stream that may requ ire this consideration.

• The WCPIP requires that the SAP be submitted to CBF O for review and approval. Please provide evidence of the review and approval.

Concern Response: GEVNC-CCP responded to EPA’s three points as follow s:

• CCP-GEVNC acknowledged that GEVNC/Energy Solutions prepared and implemented the sampling program prior to CCP’s involvement in characterizing the GEVNC RH debris waste stream. GEVNC-CCP personnel stated th at the sampling program incorporated the guidance in EPA QA/G5 and QA/G9s, and that the Data Quality Indicators (DQIs) in QAG-5S and the WCPIP QAOs are “synonymous”. The EPA inspection team took issue with this and CCP-GEVNC w as not able to demonstrate that Energy Solutions used the guidance in EPA QA/G5 and QA/G9 while developing their SAP. EPA’s primary focus was the technical adequac y of the sampling and analysis data (i.e., representativeness) as opposed to strict com pliance with the WIPP. See the discussion under the third bullet, below.

• GEVNC-CCP personnel stated that because hot cell co ntamination is the result of destructive examination of fuel or fuel specimens o n waste surfaces, all material in the waste stream would be contaminated from the same pr ocesses. Accordingly, radioactive

materials embedded in the waste items would have th e same isotopic ratios as any removable (surface) contamination.23

• GEVNC-CCP personnel acknowledged that the SAP was n ot approved prospectively by CBFO. EPA focused on the technical adequacy of the SAP with respect to obtaining representative samples within Hot Cell 4 to support the development of radionuclide scaling factors [see 8.2 (4), below]. Hot Cell 4 w astes are visible and also are stored “below cell deck”, and the sampling plan must colle ct information representative of all waste in the cell, irrespective of its location. G EVNC-CCP personnel demonstrated that available data supported their contention that wast es above and below deck are equivalent with respect to the waste material parameters assum ed for the waste stream as a whole and that there are no data to suggest otherwise. T he data EPA reviewed indicated that the samples collected are adequately representative of wastes in the cell, assuming that no

information is obtained as the cell is decommission ed to suggest different radiological or physical parameters are associated with “below deck ” waste [see item (12), below].

Status of Concern: This concern is closed.

(8) Implementation of the WCPIP requirements was evalua ted and continues to be inadequate.

In its inspections, EPA examines and determines the adequacy of RH WC programs with respect to 40 CFR 194 requirements directly, not by complia nce with the WCPIP. Like the CBFO CH Waste Acceptance Criteria (CH WAC), in the WCPIP, C BFO includes the EPA regulatory requirements at 40 CFR 194.8 and (a) explains which system of controls must be documented in procedures and (b) requires that they be implemente d appropriately to show compliance with regulations governing WIPP disposal of TRU RH waste . CBFO developed the WCPIP in 2003, approximately three years prior to approval of the first RH waste stream by EPA. While the WCPIP was developed based on the anticipated WC pro cesses and activities, implementation of WCPIP requirements in the context of actual waste c haracterization does not always address EPA requirements as specified in or related to the Compliance Certification Application and subsequent Recertification Application(s). While C BFO has revised the WCPIP, the revisions did not address the above needs, or the examples ci ted below:

• For Performance Assessment (PA) purposes, DOE has c ommitted to assessing 10 radionuclides, and these radionuclides are therefor e tracked as part of the waste characterization process. However, the WCPIP does not include determination of these radionuclides in the DQO process.

• The WCPIP states that AK will essentially be the ba sis for all characterization processes, but uses circular logic and references for AK quali fication methodologies (i.e., sampling and analysis). CBFO should consider clarifying the process so that each characterization method is clearly presented.

In some instances, the WCPIP is too specific (e.g., DTC), but not specific enough in others.

• The WCPIP requires the preparation of a “CTP” for t he purpose of communicating specifically how CBFO intends to characterize the w aste stream (i.e. DTC, VE). However, the WCPIP states that this information sho uld be included in a certification plan that has proven to be an inappropriate locatio n for the information. EPA expected a24

clear and concise communication of the intended cha racterization process, but the format doesn’t always allow this.

• The WCPIP mandates the assessment of AK accuracy to address significant discrepancies in radionuclide information by comparing AK and ch aracterization information. However, this requirement is not nece ssarily followed when the characterization approach includes an AK component, and what constitutes a significant discrepancy is not defined. The intent of the passage was to require comparison of AK and related confirmatory testing when AK is identif ied as the primary characterization methodology, but the intent of the comparison is no t always addressed.

During a previous RH baseline inspection at the Oak Ridge National Laboratory, EPA issued a concern against CBFO to address the inadequacy of t he WCPIP (see Docket No. EPA-HQ-OAR2008-0820). Given the RH waste characterization ex perience of the last three years, it would be prudent to revise the proposed characterization app roaches and update the WCPIP to either specify additional approaches or allow a more perfo rmance-based regulatory compliance

demonstration. The EPA concern addressed to CBFO r eflected that. CBFO provided a written response to EPA by September 30, 2008, as requested . EPA evaluated the CBFO response and found it to be lacking, and resolution of EPA’s iss ues is pending. CBFO must revise the WCPIP to address the above concern before seeking EPA app roval of RH waste characterization programs at other RH sites.

(9) Content and technical adequacy of the CTP were eval uated and, upon modification, found to be adequate.

The purpose of the CTP is to describe the character ization approach to be used for this GEVNC RH waste stream. The CTP states that radiological parameters will be determined by DTC using

137 Cs as the key gamma-emitting radionuclide and scali ng factors for other radionuclides will be based on the results of radionuclide analyses of sm ear samples. As indicated in (7), above, the smear samples are considered to be AK, and GEVNC CC P qualified the data for use by the equivalent QA qualification approach. GEVNC-CCP al so stated that physical waste form will be met using VE (see Section 8.3), and will be perform ed on the waste stream using “an approved VE procedure as it is being packaged”. The waste s tream is considered newly-generated, as it is being characterized under the GEVNC-CCP approved QA program using procedures and processes for VE that will take place as the waste is generated/packaged. The CTP is unclear with respect to whether the characterization method s are AK-based with subsequent qualification through sampling, peer review, or equivalent QA, or whether the DQOs will be met through visual examination without “qualification” of AK, a s in the case of physical form/liquid

identification. EPA understands the characterizati on approach, but it would be prudent for CBFO when revising WCPIP, should clarify steps for generating CTPs for RH waste

characterization.

EPA’s review of the CTP identified a concern. This concern was discussed with GEVNC-CCP AK personnel, and EPA included it on an EPA Inspect ion Issue Tracking Form (see Attachment B.1 of this report for a copy of this form), as dis cussed below. Please note that the issue related

to the CTP is one of the several items in this conc ern, and that the other items are addressed in sections (6) and (15).25

EPA Inspection Issue No. GEVNC-CCP-RH-AK-08-002CR: CCP-AK-GEV-500 and other AK-related documents require technical and editoria l modifications to correct errors and/or to clarify information. These modifications include t he CTP, which states on page 12 that performance of additional swipe sample collection e fforts will be evaluated if the variability of sample results so warrants; please clarify whether this will actually be performed.

Concern Response: GEVNC-CCP responded to this concern by modifying CC P-AK-GEV 500, not CCP-AK-GEV-502, to state that no additional sam ples will be collected. Since the CTP is written in “future tense” it is appropriate to clar ify this question within CCP-AK-GEV-500. EPA understands that no clarification of the CTP-pr ovided information is expected to be done by GEVNC-CCP as no additional samples will be collected and analyzed. However, CBFO must clarify CTP-relevant modifications when CBFO revise s the WCPIP to reflect actual RH waste characterization activities implemented at differen t RH sites approved by EPA. [See the last paragraph under item (8), above.]

Status of Concern: This concern is closed.

(10) Content and technical adequacy of the CRR was evalu ated and was found to be generally compliant with the current WCPIP.

Requirements set forth in CCP-TP-506, Revision 1, C CP Preparation of the Remote-Handled Transuranic Waste Acceptable Knowledge Characteriza tion Reconciliation Report (CRR), were evaluated against the CRR to ensure that all requir ed elements are presented. Mandatory check fields were included in the report. The CRR includ es data fields that are intended to address the specific content requirements in the WCPIP. While the mandatory information fields are included, data in fields pertaining to AK record da ta that address each DQO is vague and is bordering on insufficient. The CRR also did not in clude the signature of the Site Project Manager (SPM), and did not include the required tab le of contents. The SPM signature and table of contents were rectified during the inspection, b ut EPA expects the CRR to be sufficiently complete at the time of the inspection and that the content will be improved to include more information with regard to how AK addresses the DQO s. EPA will examine forthcoming CRRs to ensure that these improvements have been made. Additionally and most significantly, EPA has always indicated that the CRR should address th e 10 WIPP-tracked radionuclides in the analysis, because characterization of these radionu clides is paramount to the EPA performance assessment (PA). EPA expects that this oversight w ill be rectified when CBFO revises the

WCPIP as mentioned above.

(11) Personnel training was evaluated and was found to b e adequate.

Personnel involved with the AK portion of the inspe ction were Mark Doherty (AKE), Irene Gallegos (SPM), Kevin Peters (AKE), Sherry Nance (AK E), Sheila Piercy (document coordination), and Hillari Neely (SPM). Of these, Qualification Cards and Job-Specific Training records for Mark Doherty and Kevin Peters were exam ined. The WCPIP specifies that AK personnel responsible for compiling AK, characteriz ing RH TRU waste streams using the AK process, and assessing the AK characterization shal l be qualified and trained in the following:26

• RH WCPIP

• The nonconformance and corrective action processes

• Procedures presented in Attachment A of the WCPIP

• Site-specific training relative to the contents of the site’s waste streams

• Determining radiological contents of individual con tainers

As found during past inspections, training specific to determining radiological contents of

individual containers was not included in the liste d training programs. During the inspection, it was ascertained that Jene Vance performed the radio logical assessment required by the WCPIP. While this approach appeared appropriate during ini tial EPA RH inspections, this has resulted in less radiological characterization information bein g included in the related CCP-AK-500 document to the point that the AK Summary has requi red consistent revision to include more radiological information [see (6) and (12), below]. More overlap between CCP-AK-GE-500 and CCP-AK-GE-501 in terms of the AK radiological compo sition of the waste is necessary [see (12), below]. EPA expects GEVNC-CCP to address con tainer-specific radiological training for all AKEs. EPA does not expect GEVNC CCP to revise t raining qualification cards of GEVNC CCP AK personnel.

(12) Physical and radiological compositions of the waste stream presented in the AKSR were assessed and found to be adequate.

The AKSR CCP-AK-GE-500 Revision 2 was evaluated for adequacy with respect to radiological and physical waste composition. This revision was provided after the inspection and was edited to address EPA concerns about waste composition inf ormation.

EPA had expressed concern about the level of detail in the AKSR regarding the radiological composition of the waste. EPA’s concerns were as f ollows [see (7), above]:

• The radionuclide discussion in Section 5 does not a dequately address generalized waste composition. Of particular importance are changes in activities/potential radiological contamination pre-post 1978 (i.e., MOX prior with e xceptions, sources post, with exceptions). GEVNC-CCP did not prepare a radiologi cal analysis or table to accompany their own time line that may help make these change s. Note that Section 5.4.10 may also require revising based on EPA Concern No. GEVNC-CCP- RH-AK-08-003CR.

• Table 5 of the CCP-AK-GEV-500 does not adequately r eflect modified radionuclide scaling factors.

GEVNC-CCP revised the radiological section of the AK Summary to indicate that a “rough

estimate” of the surface contamination in the hot c ell was made based on 11 S-tip smears (swipe samples) collected in July and November of 1982. A nalysis of the smear samples identified

137 Cs, 124 Cs, 60 Co, 106 Ru, 125 Sb, 144 Ce, 154 Eu, and 95 Zr. These radionuclides served as the basis for the 2008 sampling and analysis performed to acq uire information DTC measurements [see (7), above]. Reference C007 presents values for ea ch isotope in units of μCi/smear. Additionally, the AKSR was revised to indicate that isotopic contamination in the waste is predominantly from MOX fuel destructively examined in the cell, but that:27

Numerous stoichiometric combinations of MOX and rea ctor histories were introduced into Hot Cell 4 over its operating lifet ime...[so] there is no definitive information that is available to estimate the amoun ts and concentrations of the

various radioactive materials introduced into the h ot cell and how much of that material may have been left behind...the inability to realistically determine an estimate of the isotopic ratios that may be present in the hot cell resulted in the need to collect samples of the hot cell contaminati on...

This information is helpful, but does not reflect t he data provided to EPA during the inspection,

which inferred that different materials were handle d within Hot Cell 4 during different time periods. It is clear that the 1982 smear sampling served as a basis for the later sampling program, so additional information could have been summarized in the AK document to support the use of this AK data in the sampling program.

GEVNC-CCP also revised the AKSR to include the updat ed and modified scaling factors. These scaling factors are:

Radionuclide Scaling Factor

238 Pu 1.13E-02

239 Pu 7.88E-02

240 Pu 3.67E-02

241 Pu 4.25E-01

242 Pu 2.17E-05

241 Am 9.45E-01

233 U 6.14E-07

234 U 1.518E-04

238 U 2.77E-06

137 Cs 1.00E+00

90 Sr 3.00E-01

235 U 5.45E-06

236 U 2.52E-06

137m Ba 3.00E-01

90 Y 3.00E-01

Of these, 137m Ba and 90 Y are not included in CCP-AK-GE-501 Revision 2, bec ause of their relatively short half-lives (reference M023).

GEVNC-CCP addressed EPA’s concerns, but did not prov ide relative time differentiation of waste management activities in Hot Cell 4 as discus sed during the inspection and as requested in EPA’s concern. Inclusion of a generalized composit ional range of MOX fuel managed in the cells, as well as additional information pertaining to 241 Am and 252 Cf, including when each was managed in the cell, would strengthen this document considerably. This information is important because the waste “below deck” may prove to differ to the extent that GEVNC-CCP would reconsider the use of a single isotopic distr ibution for all waste. EPA has observed this at other RH TRU sites (See Docket No. A-98-49, II-A4-9 9); if this were to occur at GEVNC, both28

CCP-AK-GE-500 and CCP-AK-GEV-501 would require revi sion. Because GEVNC-CCP provides AK-related radiological information in CCP -AK-GE-501, notifications of updates and revisions to this document are considered T2 change s.

With respect to physical characteristics of the was te, GEVNC-CCP indicates that the current

waste stream volume estimate is about 12.5 m 3 , with an expected period of generation from September 2008 to Summer 2009. WMPs were estimated based of the materials observed to be present in the cell through the cell windows, and k nowledge about the weight of waste materials from other sites. GEVNC-CCP expects the waste to b e composed primarily of organic (27%) and inorganic (73%) debris. It should be noted tha t waste will be evaluated by visual examination (see Section 8.3) during packaging, and the waste content will be verified and assessed through AK Accuracy calculations [see (15) , below]. EPA expects GEVNC-CCP to verify the waste stream and WMCs, as well as the an ticipated WMP distribution as the waste is removed and visually examined. Revision of referen ce M007 is a T2 change, as this

memorandum documents the calculation of waste mater ial parameters.

(13) Data limitations, NCRs, and Discrepancy Resolution Forms (DRFs) were examined and were found to be adequate.

DRFs were not provided to EPA at the beginning of t he inspection. However, during the inspection a discrepancy was identified pertaining to the chemical content of the waste, and a draft DRF was prepared that was later provided to E PA (DR001, dated December 4, 2008). DRFs must be provided to EPA as a T2 change.

Data limitations are included as a line item on Att achment 5 of the WCPIP Appendix A, and this is included as a cover page to every source documen t. Typically, data limitations are addressed on this form. GEVNC-CCP provided one example NCR, No . GEVNC-0500-08, that pertained to uncertainty calculations. This NCR documented t he discovery of a mathematical error

associated with the DTC calculations.

(14) The Draft Waste Stream Profile Form (WSPF) was exam ined and found to be adequate.

A draft WSPF was provided during the inspection. I t is noted that this form was for “audit purposes only”, and it will be revised and finalize d as characterization of the waste stream progresses. The final WSPF and related Attachments (i.e., CRR), and subsequent change requests is a T2 change. It should be noted that G EVNC-CCP has elected to generate two WSPFs, one that they believe focuses on EPA require ments or requirements of the WCPIP, and a second that complies with the WAP (i.e., contains t he Characterization Summary Sheet). While it is GEVNC-CCP’s prerogative to use this approach, it is inefficient and adds an unnecessary layer of documentation and document management. GE VNC-CCP should consider combining the two forms in the future, as a majority of the r equired information is common to each.

(15) AK Accuracy was assessed and was found to be adequa te as demonstrated by GEVNCCCP’s ability to generate AK accuracy reports.

Upon evaluation of AK accuracy, EPA identified a co ncern. This concern was discussed with29

GEVNC-CCP AK personnel, and EPA included it on an EP A Inspection Issue Tracking Form (see Attachment B.1 of this report for a copy of th is form), as discussed below. Please note that the issue related to AK accuracy is one of the seve ral items in this concern, and that the other items are addressed in sections (6) and (9), above.

Inspection Issue No. GEVNC-CCP-RH-AK-08-002CR: CCP-AK-GEV-500 and other AKrelated documents require technical and editorial m odifications to correct errors and/or to clarify

information. These modifications include the items related to the AK Accuracy Report (December 1, 2008), which states that the AK compil ation for the waste stream is complete and the required AK accuracy report is therefore incorp orated into CCP-AK-GEV-502. This is not correct, as the waste stream contains only six char acterized containers.

Concern Response: GEVNC-CCP responded to this concern by modifying th e AK Summary during the inspection to ensure that the appropriat e number of containers was included in the AK Accuracy Report. This approach required multiple i terations.

Status of Concern: This concern is closed.

AK Accuracy reports for this waste stream must be p rovided as a T2 change.

(16) Load Management was assessed and was found to not a pply to GEVNC-CCP at this time.

GEVNC-CCP representatives were questioned whether an y containers generated during repackaging would contain less than 100 nCi/g of TR U radionuclides. GEVNC-CCP indicated that if any containers were identified that contain ed less than 100 nCi/g of TRU radionuclides, the containers would be segregated and would not be load managed. EPA understands that load management will not be performed for waste stream G EVNC.01.

(17) Attainment of DQOs through AK verification was eval uated and found to be acceptable.

As a result of the analysis presented in items (1) through (16) above, EPA was able to assess how each DQO will be addressed. The following DQOs mus t be addressed per the WCPIP:

• Defense determination

• TRU waste determination

• RH waste determination

• Activity determination (TRU Alpha Activity per cani ster, including quantification and

identification of the EPA 10 WIPP-tracked radionucl ides)

• Residual Liquids

• Physical Form, including metals and CPR

CCP-TP-502 indicated that the defense determination is supported solely by documented information that is compiled through the AK process . The TRU waste determination is made through a combination of AK (sampling qualified by equivalent QA) and DTC. RH status as30

determined by AK is verified through direct measure ment of the container’s surface dose rate and the TRU alpha activity is determined by AK-deri ved isotopics (qualified by equivalent QA),

and direct DTC measurements. The CTP states that r esidual liquid content and physical form will be documented during waste packaging. The use of AK to determine DQOs as described in the CTP was acceptable and meets the fundamental in tent of the WCPIP.

Summary of AK Findings and Concerns

The EPA inspection team identified three concerns r elated to AK, which are discussed above. Please note that for logistical reasons, one concer n is discussed in three sections above. Copies of the EPA Inspection Tracking Forms are included i n Attachments B.1 through B.3. EPA considers all aspects of these concerns to have bee n adequately addressed, and there are no open findings or concerns related to AK resulting from t his inspection.

Baseline Approval

EPA is proposing to approve the AK process evaluate d during this baseline inspection. This approval is limited to newly generated debris waste generated in Hot Cell 4 that will be packaged into 55-gallon drums. Waste will be generated duri ng 2008-2009, as defined in CCP-AK-GEV500, Revision 2.

AK Tiers

T1 AK changes are not identified for this approval. Once the su bject debris waste stream is characterized and disposed of at WIPP, GEVNC-CCP wil l not characterize any additional GEVNC RH waste for WIPP disposal.

T2 AK changes do not require EPA approval before implementation, but require that GEVNCCCP provide EPA the following documents for review, as listed below with a reference to the specific AK section where each is discussed in pare ntheses:

• Availability of the CSSF (2)

• Revisions to the AK Summary CCP-AK-GEV-500, includi ng changes to the associated Reference List (6)

• Updates and revisions to CCP-AK-GE-501 (12)

• Revision of reference M007, as this memorandum docu ments the calculation of waste material parameters (12)

• Availability of additional discrepancy resolutions (13)

• Notification of availability of the final WSPF and r elated Attachments (i.e., CRR), and subsequent change requests (14)

• Availability of AK Accuracy reports for this waste stream (15)31

GEVNC-CCP will provide EPA with information concerni ng T2 changes no later than 4 weeks after the last shipment of RH waste from the site i s completed. Consistent with EPA’s authority under 194.24(h), EPA may request information relati ve to these changes if EPA deems the information is necessary to ensure compliance with EPA regulations.

8.2 Radiological Characterization

During radiological characterization (RC) inspectio n, EPA inspected one Dose-to-Curie (DTC) measurement system located on site at GEVNC, support ed by the development of radionuclidespecific scaling factors.

Overview of GEVNC RH Waste

Waste Stream GEVNCR.01 consists of heterogeneous de bris wastes containing mixtures of radionuclides from the hot cell operations and anal ytical fuel pin examinations that were conducted in Hot Cell 4 within Building 102. These wastes are currently unpackaged and GEVNC-CCP intends to remove the wastes directly from Hot Cell 4 into 55-gallon drums. These wastes are expected to contain sufficient amo unts of 137 Cs to produce RH dose rates, i.e., in excess of 200 mRem/hr, however some wastes may u ltimately be deemed CH TRU or nonTRU (low level waste or LLW), based on the characte rization results. Typical hot cell activities have included MOX fuel rod development; PIE of vari ous types of fuel; and the manufacturing

of 252 Cf and Am-Be neutron sources. An effort to collect and analyze a set of smear (swipe) samples from a number of locations within the hot c ell was initiated and completed in May 2008 and the analytical data produced by this effort wer e used to develop radionuclide scaling factors, as discussed subsequently in this report.

Overview of GEVNC Radiological Characterization

The nature of RH TRU wastes presents difficulties w ith respect to obtaining meaningful measurement data, as is routinely done with CH TRU wastes. Apart from the obvious personnel exposure concerns associated with working in extern al radiation fields in excess of 200 millirem per hour (mrem/hr), RH TRU waste containers typical ly contain concentrations of energetic photon emitters, i.e., 137 Cs, 60 Co, 152 Eu, and 154 Eu, that prevent a meaningful measurement-based isotopic determination. 4 Accordingly, RH radiological characterization rel ies on alternate methods, such as the development of scaling factors that correlate an easily measured parameter like a waste container’s external exposure (dose) r ate with isotopic distributions for specific TRU radionuclides. The development of radionuclide sca ling factors at GEVNC-CCP is comparable to what EPA has evaluated and approved in previous RH baseline inspections.

The development of the 137 Cs scaling factors was supported by the following t wo sources of

information:

4 There are other gamma-emitting fission and activat ion products with shorter half-lives that typically decay sufficiently to allow their contribution to a conta iner’s external gamma measurement to be ignored for purposes of

DTC.32

• Information on the activities conducted within Hot Cell 4 including the radionuclide

content of the materials handled in the hot cell an d the waste generating activities. This information is essentially the same as what is pres ented in CCP-AK-GEV-500, as

discussed in Section 8.1.

• Radiochemical sample results from a smear sampling and analysis campaign conducted in May 2008. This sample information was used in c ombination with the results of MicroShield® modeling to develop the fractional con tribution of radionuclides other than

137 Cs to the total gamma dose rate.

The characterization methods used for the GEVNC-CCP RH wastes were evaluated in terms of the technical adequacy of the approach, as supporte d by the program’s documents, procedures, and controls, and the knowledge and understanding o f the personnel involved in the RH WC program. During this RH inspection, the EPA inspec tion team evaluated the following elements of the GEVNC-CCP radiological characterization progr am:

• External gamma measurements made at GEVNC

• Development of a DTC correlation as a function of w aste density using MicroShield® based on each drum’s measured external exposure (do se) rate, assuming the main contributor to the external exposure was 137 Cs

• Derivation of radionuclide scaling factors for the WIPP-tracked radionuclides using analysis of swipe samples collected in Hot Cell 4 i n 2008

Documents Reviewed

The list provided below includes all documents rela ted to the ORNL-CCP RH radiological characterization program that were evaluated to sup port this inspection:

• CCP-AK-GEVNC-501, Central Characterization Project Remote-Handled Radiological Characterization Technical Report For Remote-Handle d Transuranic Debris Waste From the General Electric Vallecitos Nuclear Center (GEV NC); Revision 0, October 30, 2008 and Revision 1, January 23, 2009

• CCP-AK-GEV-500, Central Characterization Project Ac ceptable Knowledge Summary Report For General Electric Vallecitos Nuclear Cente r; Waste Stream: GEVNC.01 – Hot Cell Debris; Revision 1, October 28, 2008 and Revis ion 2, January 8, 2009

• CCP-AK-GEV-502, Central Characterization Project RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmation Tes t Plan for General Electric Vallecitos Nuclear Center; Waste Stream: GEVNC.01; Revision 0, October 30, 2008

• CCP-TP-504, Revision 6, CCP Dose-To-Curie Survey Pr ocedure for Remote-Handled Transuranic Waste; February 6, 2008

• DTC BDR Nos. GEVRHDTC08001, GEVRRHDTC08002, and GEV RRHDTC08003

• AK Accuracy Report, December 1, 2008

• WSPF, Draft33

• List of Qualified Individuals (LOQI), as of November 11, 2008: VE, HSG & DTC

• GEVNC-RH-01, Revision 0

• GEVNC-RH-02, Revision 1

• GEVNC-RH-03, Revision 0

• GEVNC-RH-04, Revision 0

• INL-RH-04, Revision 0

• GEVNC-RH-05, Revision 0

• GEVNC-RH-06, Revision 1

• ORNL-RH-07, Develop DTC Correlation for Cs-137, Eu- 152 and Eu-154, Revision 1

• GEVNC-RH-07, Revision 1

• ORNL-RH-13, MCNP5 Analysis for DTC Uncertainty, Rev ision 1

• Compact disk (CD) containing radiochemical data rep orts and supporting information from Eberline provided during the inspection

Technical Evaluation

The EPA inspection team evaluated the following asp ects:

(1) The technical adequacy and documentation of the cor relation of the GEVNC radionuclide inventory values to the 137 Cs concentrations were evaluated and were found to be adequate.

The basic assumption for the radiological character ization of GEVNC hot cell waste is that the

137 Cs scaling factors relate to the inventory values o f the radionuclides of interest, i.e., the 10 WIPP-Tracked radionuclides. This concept is approp riate for co-located wastes provided that additional processing or other events have not sele ctively isolated specific radionuclides. This is addressed in subsequent parts of this section, belo w.

There were no concerns regarding the technical adeq uacy and documentation of the correlation of the GEVNC radionuclide inventory values to the 137 Cs concentrations in GEVNC.01. The application of radionuclide values described above applies only to the wastes generated in Hot Cell 4 at GEVNC, as discussed throughout this repor t.

(2) The radiochemical data were evaluated and found to be representative and technically adequate to support the development of scaling fact ors.

The degree to which the 11 swipe samples that were subjected to radiochemical analysis are representative of the wastes that were handled with in Hot Cell 4 is of key importance. The contamination on the swipes must represent the type s and characteristics of the materials that were handled in hot cell to technically support the scaling factor development presented in GEVNC-RH-02 and CCP-AK-GEV-501. The smear samples w ere collected from numerous34

surfaces and items within Hot Cell 4 and eleven sam ples were sent to Eberline Services Analytical Corporation for radiochemical analysis a nd gamma spectrometry. An aliquot of each of the 11 samples was sent to Southwest Research In stitute (SWRI) for Inductively-Coupled Plasma Mass Spectrometry (ICP-MS) to determine the contributions of 233 U, 234 U, 235/236 U, 239 Pu,

240 Pu and 242 Pu.

In the course of reviewing the sample collection an d analyses, the EPA inspection team expressed concern related to the lack of records do cumenting these activities. It became clear that the requested information, at a minimum, was n ot available or perhaps did not exist. On the morning of the last day of the inspection, GEVNC-CCP provided a DVD that they stated contained all of the requested information that sup ported or documented the sample collection and analyses. Given the timing of the information, EPA was not able to adequately review it during the on-site inspection. This is related to the situations that are documented in two formal EPA concerns, as discussed in Section 8.1(7), above , i.e., EPA Inspection Issue Nos. GEVNCCCP-RH-AK-08-001F and GEVNC-CCP-RH-AK-08-003CR. Th e EPA inspection team was unable to examine objective evidence that supported several aspects of the sample collection and analyses. Following the onsite inspection, the inf ormation from Eberline was reviewed and EPA determined that there was sufficient support to add ress the technical questions posed at GEVNC.

As GEVNC-CCP reviewed the Eberline results in detail following the inspection, they determined an error with respect to sample numberin g. Specifically, an error in sample marking produced an anomalous value for uranium isotopes wh ich, when corrected, produced a small change in the numerical value of radionuclide scali ng factors. This in turn necessitated revising CCP-AK-GEV-501 and calculation packages GEVNC-RH-02 , GEVNC-RH-04, GEVNC-RH05, GEVNC-RH-06 and GEVNC-RH-07. Upon revision of C CP-AK-GEV-501 and the calculation packages, there were no technical issue s regarding the representativeness of the samples collected and their radiometric analyses.

(3) The development of radionuclide scaling factors was evaluated and found to be technically adequate.

A radionuclide scaling factor provides a technicall y sound method of deriving a value for

radionuclides that are difficult to measure on the basis of an easily measurable attribute like external dose rate, assuming the measured dose rate can be correlated to a known constituent,

such as 137 Cs. Scaling factors were developed based on the ra diochemical and MS results. The MS data were used for isotopics pairs that could no t be resolved using alpha spectrometry, i.e.,

233 U/ 234 U, 235 U/ 236 U and 239 Pu/ 240 Pu, specifically to determine the contribution of e ach isotope.

A ratio of each of these values to 137 Cs was developed to derive the radionuclide-specifi c scaling factors that are listed in Table 4, below. As a ch eck on the reasonableness of the scaling factors, the GEVNC scaling factors were compared to what had been derived for other sites that had processed MOX, since the AK indicated that GEVNC han dled MOX beginning in the earlier 1960s through the late 1970s 5 . This comparison is shown in CCP-AK-GEV-501, Figu re 4-1. Apart from small discrepancies with respect to 241 Am and 233 U 6 , the agreement provides a check

5 Specifically, the DOE sites are the Idaho National Laboratory, Argonne National Laboratory-East and L os Alamos National Laboratory.

6 The difference in 241 Am results from Am-Be neutron sources having been m anufactured in Hot Cell 4.

The 233 U difference is attributed to the fact that GEVNC d id not process thorium fuel while the other DOE sit es did.35

on the reasonableness of using these scaling factor s for the feed materials from which the Hot

Cell 4 radionuclides was derived.

Table 4. GEVNC Scaling Factors Derived from Sample Data

Radionuclide Cs-137 Scaling Factor

Ci Radionuclide/Ci 137 Cs

Sr-90 2.68E-01

U-233 7.26E-07

U-234 1.40E-04

U-235 5.41E-06

U-236 2.68E-06

U-238 2.69E-06

Pu-238 1.07E-02

Pu-239 6.89E-02

Pu-240 3.31E-02

Pu-241 4.03E-01

Pu-242 2.29E-05

Am-241 9.62E-01

Cs-137 1.00E+00

The EPA inspection team evaluated the following asp ects:

• Activity values used are derived from modeling and statistical metrics that support their use, and the statistical metrics include mean and s tandard deviation values for each

measured radionuclide

• Isotopic activity values are correlated to the long -lived radionuclides that are responsible for the measured external dose rate, i.e., 137 Cs and 60 Co

• The appropriateness of the choice of physical const ants and radionuclide-specific attributes (specific activity, physical half-life, decay heat, neutron cross-sections, photon transition probabilities, etc.) and the technical c orrectness of the values assigned to each

attribute

• Contributions of the short-lived radionuclides and other gamma-emitting radionuclides to

the total measured dose rate are sufficiently small to ignore

• All radionuclide values are decay-corrected, as app ropriate

• The calculated results used to develop the scaling factors and convert the measured external dose rates to radionuclide activity levels

• The determination of the contribution of all radion uclides to the radiological hazard 7

• Shielding and other calculations supporting the sca ling factors were performed using

MicroShield

® to derive the appropriate DTC relationships as a fu nction of waste density for the 55-gallon-drum geometry

7 Although the determination of a waste container’s radiological hazard is not an EPA requirement, this information may be useful in understanding other as pects of a container’s radiological characterizatio n.36

There are no issues related to the technical adequa cy or documentation of the radionuclide scaling factors for Waste Stream GEVNC.01. Any rev ision to CCP-AK-GEV-501 that requires CBFO approval is a T2 change.

(4) The technical basis of the Dose-to-Curie correlatio n was evaluated and found to be technically adequate.

The DTC correlation was based on the following assu mptions:

• The waste drum is full of waste

• The radionuclides of interest are dispersed uniform ly throughout the waste

• The waste matrix is iron, which is the most represe ntative, i.e., photon attenuation is primarily a function of the matrix density, rather than specific waste composition or

atomic number

• Waste densities range from 0.1 g/cc to 2.1 g/cc

Using MicroShield ® , GEVNC-CCP developed a DTC correlation for a 55-ga llon drum filled

with RH TRU waste in terms of mR/hr for a 1-curie s ource of 137 Cs, 152 Eu, and 154 Eu, shown in Figure 1. 8 There are no issues related to the technical adeq uacy or documentation of DTC for

Waste Stream GEVNC.01.

8 This plot was developed and used for ORNL-CCP. Gi ven that the waste density and source strengths are

identical the MicroShield ® results would be the same.37 One Meter Dose Rate for 1 Ci as a Function of Densi ty

y = 51.722x 2 - 235.53x + 382.19

r 2 = 0.9993

y = 30.261x 2 - 127.25x + 181.47

r 2 = 0.9984 y = 47.213x 2 - 207.9x + 322.88

r 2 = 0.9988

0 50 100 150 200 250 300 350 400

0 0.5 1 1.5 2 2.5

Waste Density, g/ccDose Rate, mR/hr/Ci

One Meter Cs-137 Dose Rate, mR/hr/Ci One Meter Eu-154 Dose Rate, mR/hr/Ci

One Meter Eu-152 Dose Rate, mR/hr/Ci Poly. (One Meter Eu-154 Dose Rate, mR/hr/Ci)

Poly. (One Meter Cs-137 Dose Rate, mR/hr/Ci) Poly. (One Meter Eu-152 Dose Rate, mR/hr/Ci)
Figure 1. DTC Correlations as a Function of Waste D ensity at a Distance of 1 Meter

for GEVNC Debris Waste

(5) Technical aspects and documentation of the radiolog ical characterization process were evaluated and found to be acceptable upon modificat ion of CCP-AK-ORNL-501.

The technical basis for the radiological characteri zation process is documented in ten calculation packages prepared and/or reviewed by Jene Vance, Ji m Holderness, Dave Moody and Larry Porter. These packages document development of rad ionuclide scaling factors, uncertainty analyses, the DTC correlation discussed above, and other technical aspects. These packages provide the technical basis for several aspects, in cluding the following:

• Application and verification of MicroShield ®

• Evaluation of all potential contributors to a conta iner’s dose rate

• Evaluation of mass spectrometry data

• DTC calculations

• Data input checks

• Potential sources of uncertainty

The EPA inspection team reviewed these packages in advance of the on-site GEVNC inspection, and also had the opportunity to discuss all technic al concerns and discrepancies with GEVNC-38

CCP personnel. The calculation packages documented the technical activities upon which the radiological characterization was based, much of wh ich was summarized in CCP-AK-GEV-501, Revision 0. Several aspects of CCP-AKGEV-501, Revi sion 0 required clarification to accurately describe and support GEVNC-CCP’s approach, as did c alculation packages GEVNC-RH-01 and

GEVNC-RH-03. These were noted and discussed with GE VNC-CCP personnel during the inspection. EPA captured these issues on an EPA In spection Issue Tracking Form, as discussed below (see Attachment B.4 of this report for a copy of this form).

EPA Concern No. EPA-GEVNC-CCP-RH-RC-08-006CR, Final : The ten calculation packages that document the RC process as well as th e CCP report CCP-AK-GEV-501 have multiple technical and editorial errors. As presen ted during the inspection, these documents require revision to accurately serve as objective e vidence for the RC process.

Concern Response: A revised version of CCP-AK-GEVNC-501 (Revision 1) was provided to

EPA in electronic form as were the revised calculat ion packages GEVNC-RH-01 and GEVNCRH-03. The other five calculation packages discuss ed in (2) above were also provided in electronic form to address changes to the scaling f actors. These revisions adequately addressed

EPA’s issues.

Concern Status: This issue is closed.

There were no technical issues related to the deter mination and documentation of the radiological characterization process for GEVNC Wast e Stream GEVNC.01.

(6) The technical basis and derivation of Total Measure ment Uncertainty (TMU) were evaluated and were found to be adequate.

The development of TMU for Waste Stream GEVNC.01 is based on the propagation of uncertainties present in all aspects of the determi nation of the radiological constituents of RH

TRU waste. The TMU determination included the cont ributions of:

• Drum weight measurement

• Measurement uncertainty

• Scaling factor uncertainty

• MicroShield ® issues: internal code issues and modeling

• Contributions of other gamma emitters

• Drum-to-drum variation within each campaign

• Uncertainty in reported campaign inventories

The treatment of TMU is presented primarily in GEVN C-RH-13, ORNL-RH-07, and supported by MCNP sensitivity analyses documented in INL-RH-04 . The results are summarized in CCPAK-GEV-501. Statistical independence is essential if the individual contributors to uncertainty are to be added in quadrature, as was done in this case. The overall uncertainties listed by radionuclide are listed in Table 5. The conceptual approach for the TMU determination and its documentation was equivalent to what had been evalu ated and approved by EPA during previous RH inspections. There were no concerns regarding t he determination of TMU and its

documentation for waste stream GEVNC.01.39

Table 5. Overall Uncertainty for GEVNC Waste at a D ensity of 0.3 g/cm 3

Dose Rate

Measurement Uncertainty MicroShield ®

Code Uncertainty Modeling

Uncertainty Scaling

Factor Uncertainty Total

Uncertainty

U-233 25.0% 10.0% 13.9% 118.7% 122.5%

U-234 25.0% 10.0% 13.9% 50.4% 58.8%

U-235 25.0% 10.0% 13.9% 59.9% 67.2%

U-238 25.0% 10.0% 13.9% 78.7% 84.4%

Pu-238 25.0% 10.0% 13.9% 47.0% 55.9%

Pu-239 25.0% 10.0% 13.9% 50/6% 59.0%

Pu-240 25.0% 10.0% 13.9% 51.7% 59.9%

Pu-241 25.0% 10.0% 13.9% 46.3% 55.3%

Pu-242 25.0% 10.0% 13.9% 76.7% 82.4%

Am-241 25.0% 10.0% 13.9% 99.4% 103.9%

Sr-90 25.0% 10.0% 13.9% 44.5% 53.8%

Cs-137 25.0% 10.0% 13.9% - 30.3%

(7) Radionuclide Documentation in DTC BDRs was assessed and found to be adequate.

Three completed DTC BDRs for GEVNC RH TRU Waste Stre am GEVNC.01 were evaluated: BDR Nos. GEVRHDTC08001, GEVRHDTC08002 and GEVRHDTC0 8003. Because there were only three BDRs available, EPA’s evaluation am ounted to a one hundred percent sample for this inspection, as opposed to selecting a subs et or sample from a larger population. The EPA inspection team verified that all three DTC BDR s contained the following information for

each RH TRU container:

• Container number

• Waste stream designation

• Waste net weight and material type

• Measured dose rates from four quadrants and the cal culated average dose rate in mR/hr

• Scaling factor in curies per mR/hr

• Activity and mass values and uncertainties for the 10 WIPP-tracked radionuclides in curies and grams, respectively

• Activity and mass values and uncertainties for othe r TRU radionuclides in curies and grams, respectively, when applicable

• TRU alpha activity and concentration

• Plutonium equivalent curies (PE Ci) in curies

• Fissile gram equivalents (FGE) in grams

• Decay heat in watts

• Volume activity in curies per liter40

• The DTC spreadsheets observed during the inspection had to be reissued following the inspection as a result of the changes made to the r adionuclide scaling factors. The scaling factors used in these BDRs were incorrect, as discu ssed in (5), above. However the magnitude of the difference in each scaling factor is small and the impact on the radionuclide values will be minimal. Nonetheless, the BDRs observed during this inspection require revision prior to submittal as o fficial records supporting the containers’

certification.

(8) RH and TRU determinations were evaluated and found to be adequate.

The determination that the RH containers meet the d efinition of TRU wastes (TRU alpha activity with half-lives greater than 20 years at a concentr ation greater than 100 nCi/g) and RH waste (contact dose equivalent rate in excess of 200 mrem /hr) were examined, as discussed below.

TRU Determination : The three DTC BDRs that were prepared and evaluate d by EPA during this inspection contained values for the 10 WIPP-tracked and other TRU radionuclides at concentrations greater than 100 nCi/g in all cases.

RH Determination : The three DTC BDRs that were prepared and evalua ted by EPA during this inspection contained dose rate values for all conta iners in excess of 200 mRem/hr in all cases. The EPA inspection team was not able to observe col lection of measurements for actual waste containers during this inspection. GEVNC personnel provided a demonstration of the DTC process in Building 217 and confirmed the following aspects:

• All radiation dose rate measurements are made as de scribed in CCP-TP-504 and CCP Operator Aid RH-GEVNC.001, Revision 1, dated Novemb er 6, 2008

• The DTC operator (James Roswell) was listed on the GEVNC-CCP LOQI and he was current with respect to all appropriate training

• All drum movements were controlled using a small cr ane (2,000 lb maximum lifting capacity) and drums were weighed using a scale that had a current calibration

• A standard instrument jig was used to hold the gamm a probe at a one-meter distance

from the waste drum

• Drum rotations for DTC measurements were controlled by the operator located in a separate room a sufficient distance from the waste drum being assayed, assisted by a

camera to maintain visual contact with the waste dr um throughout the process

• Three survey meters were observed in Building 217, and all were the correct meter body and probe models and all had current calibrations 9

.

9 One of the meters lacked the appropriate calibrati on tag when EPA observed it in Building 217 but GEVNC-CCP personnel provided objective evidence tha t the meter had a current calibration and the tag inadvertently fell off the meter. EPA personnel ve rified that the appropriate tag was applied during the inspection.41

Based on information from GEVNC-CCP personnel, it i s expected that some of the containers from this waste stream will not qualify as RH and w ill eventually be characterized as CH, based on the observed DTC results, and these containers w ould then be subject to NDA. Because there is no approved CH WC program at GEVNC it is not clea r where such assays would be performed, although it appears that a site like INL -CCP is a likely candidate. Regardless of where such analyses occur, if any wastes from GEVNC Waste Stream GEVNC.01 are characterized as CH using NDA, EPA must receive the results from all such assays as a T2 change.

There were no technical or documentation-related co ncerns regarding the TRU and RH

determinations for GEVNC Waste Stream GEVNC.01

.

Summary of Radiological Characterization Findings a nd Concerns

The EPA inspection team did not identify any findin gs related to radiological characterization and identified one concern requiring a response dur ing the inspection related to radiological characterization that is discussed above. A copy o f the EPA Inspection Issue Tracking Form recording it is provided in Attachment B.3. EPA co nsiders this concern to have been adequately addressed upon submission of revisions of the calcu lation packages and CCP-AK-GEV-501. There are no open findings or concerns related to r adiological characterization resulting from this inspection.

Baseline Approval

EPA is proposing to approve the DTC process as desc ribed in CCP-TP-504 in conjunction with the radionuclide scaling factors documented in CCP- AK-GEV-501, Revision 1, that were evaluated during this baseline inspection. This ap proval is limited to newly generated debris wastes that will originate from decontamination of Hot Cell 4 in Building 102 at GEVNC.

Radiological Characterization Tiers

T1 radiological characterization changes are not included since no new waste other than wha t has been proposed for approval will be characterize d requiring development of DTC values and scaling factors.

T2 radiological characterization changes listed below with a reference to the specific radiological characterization section where each is discussed in parentheses must be provided to

EPA:

• Revisions of CCP-AK-GEV-501 or CCP-TP-504 that requ ire CBFO approval (3)

• Generation of measurement data for any GEVNC RH TRU container(s) that subsequently qualifies as CH and is subject to NDA (8)

GEVNC-CCP will provide EPA with information concerni ng T2 changes no later than 4 weeks after the last shipment of RH waste from the site i s completed. Consistent with EPA’s authority42

under 194.24(h), EPA may request information relati ve to these changes if EPA deems the information is necessary to ensure compliance with EPA regulations.

8.3 Visual Examination

WC Element Description

The VE process for RH debris (S5400) waste, package d from alpha Hot Cell 4 was inspected to determine the following aspects of TRU WC:

• Identification of WMPs

• Confirmation of the WMC

• Confirmation of presence or absence of prohibited i tems

• Determination of Primary Contents

VE is performed by two trained and qualified operat ors, as described in procedure CCP-TP-500.

Documents, BDRs, and Objective Evidence Reviewed

The following documents were among those the EPA re viewed to assess whether VE operations follow the appropriate approved procedures and meet VE requirements:

• CCP-TP-500, Revision 8, CCP Remote-Handled Waste Vi sual Examination, July 24,

2008

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

• CCP-AK-GEV-500, Revision 1, Acceptable Knowledge Su mmary Report for General Electric Vallecitos Nuclear Center, Waste Stream GE VNC.01 – Hot Cell Debris Waste, October 28, 2008

• CCP-AK-GEV-502, Revision 0, CCP Remote-Handled Tran suranic Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmatio n Test Plan for General Electric Vallecitos Nuclear Center, Waste Stream GEVNC.01, O ctober 30, 2008

• CCP-QP-005, Revision 16, TRU Nonconforming Item Repo rting and Control, May 07,

2008

• CCP-QP-008, Revision 14, Records Management, Septem ber 19, 2007

• Draft WSPF, GEVNC.01

• DOE/WIPP 02-3214, Remote-Handled TRU Waste Characte rization Program Implementation Plan, Revision 0D, October 30, 2003

Following is a complete list of all objective evide nce that the EPA inspection team evaluated during the inspection:

• Visual Examination BDRs RHGEVE080001, RHGEVE080002, RHGEVE080003,

RHGEVE0800643

• List of currently qualified VE personnel

• Letter appointing VEE, dated August 21, 2006, and c larification email dated December 04, 2008

• Letter appointing VEE, dated January 4, 2006

• Qualification card and training records for two VEE s

• Qualification cards and training records for one VE O

• Required Reading Report for CCP-AK-GEV-500

Technical Evaluation

During the inspection, the EPA team evaluated the t echnical elements of the VE process using

the checklist included as Attachment A-1 to this re port. These areas are summarized as follows:

(1) Overall procedural technical adequacy and implement ation were assessed and were found to be adequate.

The VE procedure, documented in CCP-TP-500, Revisio n 8, contained specific information on performing VE, including identification of prohibit ed items, assignment of WMPs, and technical

review of VE results. Waste items were identified by two VEOs and entered into an electronic Visual Examination Data Form (Attachment 1, CCP-TP- 500) after concurrence by the operators. Identification and isolation of prohibited items wa s not an issue for this waste stream as the VE performed was packaging of waste contained in a hot cell. The EPA inspectors identified one adequacy issue for the procedure. This concern was discussed with GEVNC-CCP AK personnel, and EPA included it on an EPA Inspection Issue Tracking Form (see Attachment B.5 of this report for a copy of this form), as discuss ed below.

EPA Inspection Issue Tracking Form, Issue No. GEVNC -CCP-RH-VE-08-004CR, Final: The packaging process implemented for VE is not inc orporated in a formal CCP procedure and is only described in the AK summary, CCP-AK-GEV-500 , Revision 1, Section 5.5. Incorporating the packaging process instructions in a formal CCP procedure is necessary to ensure consistency of operation.

Concern Response: A formal response to this concern was submitted to EPA on January 30, 2009. In the response, CBFO stated that “the waste packaging process performed by GE and its contractors is not part of the CCP system to be cer tified” and that the waste “packaging process

does not need to be formalized as the host site res erves the option to vary the final [waste] packaging configuration with CCP’s concurrence”. E PA accepted this response.

Status of Concern: This concern is closed.

Note that a related concern was identified with resp ect to the characterization of WMPs and prohibited items, as discussed under (3), below. T he EPA concern listed above incorporates both

issues.44

The EPA inspectors identified one implementation is sue for the procedure. This concern was discussed with GEVNC-CCP AK personnel, and EPA incl uded it on an EPA Inspection Issue Tracking Form (see Attachment B.6 of this report fo r a copy of this form), as discussed below.

EPA Inspection Issue Tracking Form, Issue No. GEVNC -CCP-RH-VE-08-005C, Final: VE Procedure CCP-TP-500, Revision 8, Section 4.2.5 [C] states: “Ensure the waste package is stored with reasonable protection from tampering.” This activity is assigned to the VEO. In practice, the VEO does not perform this activity an d is not, therefore, in compliance with CCP’s written procedure whenever VE is performed.

Concern Response: This concern did not require a response.

Status of Concern: This concern is closed.

(2) Characterization of WMPs and prohibited items was e valuated and was found to be adequate.

During the inspection EPA observed VE and packaging of S5400 debris waste into a 55-gallon drum, container number GE019. This demonstration t ook place in Hot Cell 4 in Building 102. An audio/visual recording of the VE event was not r equired because two VEOs performed the examination, one of these VEOs also acted as VEE. An electronic version of the VE procedure, CCP-TP-500, was used by the VEOs to guide the VE pr ocess. The VEOs electronically verified the WMC from the AK summary as debris waste S5400.

Using manipulator arms within the hot cell, the GE operators picked up individual waste items for identification by the CCP VEOs. Only after bot h operators agreed on the identity of the waste and its WMP, was the item electronically ente red into a Visual Examination Data Form, Attachment 1, CCP-TP-500. One operator called out the waste item identity and its WMP, which was orally confirmed by the second operator. After a VEO recorded the identity and WMP for the item, the GEVNC operators placed the wa ste into a duffle bag, which served to keep small waste items together. The duffle bag wa s recorded on the data form as “poly bag”. The duffle bag and its contents were loaded into th e 55-gallon drum at the end of the demonstration. The duffle bag was transferred thro ugh an access port to the interlock for Hot Cell 4, the bag being heat-sealed in the plastic sl eeve during this transfer. After the sealed plasti c was vented, a cradle and hoist were used to place t he duffle bag into the 55-gallon drum. The process used for transferring waste from the hot ce ll into the 55-gallon drum was not included in the VE procedure CCP-TP-500. This concern was disc ussed with GEVNC-CCP AK personnel, and EPA included it on the EPA Inspection Issue Tra cking Form listed under (1), above.

At the time of the on-site inspection, no prohibite d items had been found in the waste processed. None of the eighteen containers that had been throug h VE had been removed from the Hot Cell 4

interlock.

CCP had provided four BDRs for review by EPA: BDR Nos. RHGEVE080001, RHGEVE080002, RHGEVE080003, and RHGEVE080006. No NCRs had been generated for any of these four BDRs. The EPA inspectors found t hat the four data packages were correctly completed, three being reviewed at both data genera tion ITR and project level (SPM) and one at45

the ITR level only. The primary contents for all c ontainers in the four BDRs were listed as

“steel”.

Any change made to the VE procedure(s) that require s CBFO approval is a T2 change.

Documentation of VE activities was examined and was found to be adequate.

EPA inspectors reviewed data packages listed above to verify that the VE data were documented correctly and completely. Site personnel used an electronic VE data form for data entry during the on-site demonstration, i.e., Attachment 1 of CC P-TP-500. All valid data packages reviewed included completed review checklists (Attachments 2 and 3, CCP-TP-500).

(3) Training for VE personnel was examined and was foun d to be adequate.

CCP maintains a list of qualified individuals, whic h it uses to ensure that all training is current and only qualified individuals perform characteriza tion activities. As part of the inspection, the EPA team reviewed the qualification packages for VE Os and VEEs and found that they demonstrated comprehensive and adequate training fo r VE personnel.

The EPA inspectors reviewed the following records:

• List of currently qualified VE personnel

• Letter appointing VEE dated August 21, 2006, and cl arification e-mail dated December 04, 2008

• Letter appointing VEE dated January 4, 2006

• Qualification card and training records for two VEE s

• Qualification cards and training records for one VE O

• Required Reading Report for CCP-AK-GEV-500

The EPA found the training and qualification record s for VE personnel to be complete and

available for review.

Summary of VE Findings and Concerns

The EPA inspection team identified the two concerns related to VE that are discussed above. Copies of the EPA Inspection Issue Tracking Forms a re provided as Attachment B.5 – B.6 of this report. EPA considers these concerns to have been adequately addressed and there are no open findings or concerns related to VE resulting from t his inspection.46

Baseline Approval

EPA is proposing to approve the VE system for debri s waste that the EPA inspection team evaluated during this baseline inspection, consisti ng of the following elements:

• Trained personnel—VE operators, VEE, and SPM

• Approved and controlled operating procedures—CCP-TP -500, Revision 8; CCP-QP-002, Revision 27

• VE records and supporting data—electronic VE data f orm, CCP-TP-500 review checklists, and VE BDRs

VE as performed by two trained operators is suitabl e for RH S5400 debris waste, waste stream

GEVNC.01.

VE Tiers

No T1 VE changes have been included in this approval because no additional RH waste will be

characterized at GEVNC-CCP.

Only the following T2 VE change is included.

• Any changes made to a VE procedure(s) that requires CBFO approval (2)

GEVNC-CCP will provide EPA with information concerni ng this T2 change no later than 4 weeks after the last shipment of RH waste from the site is completed. Consistent with EPA’s authority under 194.24(h), EPA may request informat ion relative to this change if EPA deems the information is necessary to ensure compliance w ith EPA regulations.

8.4 WIPP Waste Information System

WC Element Description

CCP has successfully submitted both RH and CH WC da ta for TRU waste containers to the WWIS in the past. The CCP procedures, practices, a nd the personnel who process container data that the EPA inspectors observed at GEVNC-CCP are t he same as those used at other CCP sites whose WC programs EPA has approved. Procedure CCP- TP-530 is used for submittal of both

characterization and certification RH data to the W WIS. Waste Certification Assistants (WCAs) and Waste Certification Officials (WCOs) are based in the CCP office in Carlsbad, New Mexico, and data transfer is performed electronically

.

Documents, Records and Objective Evidence Reviewed

The following documents were among those the EPA in spectors reviewed to assess whether WWIS operations follow the appropriate approved pro cedures and meet WWIS requirements:47

• CCP-TP-530, Revision 7, RH TRU Waste Certification and WWIS Data Entry, July 11,

2008

• CCP-QP-002, Revision 27, Training and Qualification Plan, February 7, 2008

The EPA inspectors evaluated the following objectiv e evidence during the inspection:

• Testing results (DTC, VE, radiological survey, and AK tracking sheet) for container

GE003

• WWIS Data Entry Summary – Characterization and Cert ification for GEVNC Containers

GE003 and GE004

• Waste Container Data Report for Containers GE003 an d GE004

• Draft WSPF, GEVNC.01

• WWIS WCA and WCO qualification card

Technical Evaluation

(1) Overall procedural technical adequacy was evaluated and was found to be adequate.

The WWIS procedure, documented in CCP-TP-530, RH TR U Waste Certification and WWIS Data Entry, Revision 7, is well defined and control led and contains instructions for entering, reviewing, and transmitting data. The WWIS data en try procedure incorporates adequate reviews to minimize the transmittal of noncompliant or incorrect data. The Microsoft Excel spreadsheet used for data entry was adequate and wa s controlled.

(2) Implementation and documentation of WWIS activities were examined and were found to be adequate.

GEVNC-CCP did not have an approved WSPF for RH waste at the time of the onsite inspection and consequently had not generated any official rec ords for EPA review. A qualified GEVNC WCO demonstrated the certification process by uploa ding RH data into the test instance of WWIS. However, the usual records (emails, signed d ata spreadsheet, etc.) were not available for review. The process used for GEVNC container certi fication is the same as that used on other CCP sites, including the procedure, process and per sonnel. Personnel entering data into the WWIS can only do so after being granted access by t he WWIS administrator, and access is password-protected. After the data have been throu gh every level of review and approval, the WCA entered the data into a controlled Excel spread sheet that had been validated in accordance with CCP-QP-22, Revision 10, Software Quality Assur ance Plan. The control number for this spreadsheet is SCO 1023. All radionuclides identif ied by DTC are entered into the spreadsheet for RH waste. A review of the spreadsheet is made by a second WCA to verify correct data entry. The WCO reviews the data to ensure that the y are WIPP-compliant and signs the spreadsheet to accept the data. At this point, sit e personnel convert the data into ASCII format

files and transmit them to the WWIS. The informati on contained in the container file is subsequently used for transportation activities. T he WCO is also responsible for building canisters, which contain three certified containers . The list that informs the WCO of which48

containers are to be placed in the same canister is called the “build list” (see Concern above) and is sent to the WCO by the Transportation Certificat ion Official (TCO).

The EPA inspectors viewed demonstrations of data en try and retrieval. GEVNC-CCP was able to demonstrate the container certification process using the characterization test instance of

WWIS for container Nos. GE003 and GE004. The WWIS processes were challenged by entering non-compliant data to ensure that the inte rnal WWIS checks were able to identify problem data. The WCO was able to retrieve and pri nt requested records, including waste container data reports for containers GE003 and GE0 04.

Any changes to WWIS procedure(s) that requires CBFO approval is a T2 change. Any change to the Excel spreadsheet, WWIS data entry summary—c haracterization and certification, is a T2 change.

(3) Training of WWIS personnel was reviewed and was fou nd to be adequate.

The EPA inspectors observed the actual job performa nce of a WCA/WCO to verify training and qualification. Inspectors also reviewed the qualif ication card for a WCA (data entry personnel) and WCO. Required training included use of the WWI S user’s guide, and the required reading list included the RH WCPIP. Training documentation was complete and filed correctly for viewing and reference. WCOs and WCAs are qualified for the type of waste (CH or RH) and for individual generator sites.

Summary of WWIS Findings and Concerns

There were no findings or concerns related to WWIS identified dur ing this inspection.

Baseline Approval

EPA is approves the container certification system that was evaluated during this baseline inspection, consisting of the following:

• Trained WWIS WCA and WCO

• Approved and controlled operating procedures - CCP- TP-530, Revision 7; CCP-QP-002,

Revision 26

• Approved and controlled Excel spreadsheet, WWIS dat a entry summary—
characterization and certification

WWIS Tiers

No T1 WWIS change is included.

The following are two T2 WWIS changes with a reference to the specific WWIS section wher e each is discussed in parentheses:49

• Changes to WWIS procedure(s) that require CBFO appr oval (2)

• Changes to the Excel spreadsheet titled WWIS Data E ntry Summary Characterization and Certification (2)

GEVNC-CCP will provide EPA with information concerni ng T2 changes no later than 4 weeks after the last shipment of RH waste from the site i s completed. Consistent with EPA’s authority under 194.24(h), EPA may request information relati ve to these changes if EPA deems the information is necessary to ensure compliance with EPA regulations.

9.0 RESPONSE TO COMMENTS

EPA received one set of public comments (see EPA Do cket ID No. EPA–HQ– OAR–2009–0372, for actual comment. The comments an d corresponding EPA responses are given below.

Comment 1 : Clarify that the approval applies to all RH TRU waste from waste stream

GEVCN.01 – Hot Cell Debris Waste characterized with processes evaluated during the inspection.

EPA Response : EPA agrees with the commenter and appropriate ch anges are made.

Comment 2 : Add an exception to the T2 requirement that CH N DA data be provided within 4 weeks. Also, allow up to 12 weeks for CH NDA data to be provided.

EPA Response : EPA disagrees with the comment, as specifying a due date in the approval is unnecessary. CBFO/INL-CCP can identify when EPA can expect to receive the CH NDA data when INL-CCP/CBFO notifies EPA abou t the CH waste from GE VNC being characterized by INL-CCP.

Comment 3 : Change all references to CCP-TP-500 to Revision Number 8.

EPA Response : Appropriate change has been made throughout this document.

Comment 4 : Delete names of certain individuals from Table 3 as they were not contacted during the inspection.

EPA Response : Table 3 has been revised accordingly.

Comment 5 : Change Mass Spectrometry (MS) to Inductively-Coup led Plasma Mass Spectrometry (ICP-MS) on page 34

EPA Response : Appropriate change has been made.

10.0 SUMMARY OF RESULTS50

10.1 EPA Findings and Concerns

The one finding and four concerns requiring respons es that were identified during this inspection related to the WC processes GEVNC-CCP implemented t o characterize RH TRU debris waste. The specific issues requiring a response and GEVNC- CCP’s responses are discussed in the preceding sections of this report. Copies of the E PA Inspection Issue Tracking Forms that capture the finding and the four concerns are inclu ded in Attachments B.1 through B.5 of this report. The one concern that did not require a res ponse is included in Attachment B.6. GEVNCCCP revised a number of documents to address the findin g and the concerns that required responses and submitted them for EPA review followi ng the initial onsite inspection. The EPA inspection team completed their review of the revis ed documents and determined that they adequately addressed all aspects of the EPA finding and the four concerns that required responses. All issues relative to the finding and all concerns were adequately addressed and EPA

considers these issues to be closed. No GEVNC-CCP E PA issues related to this inspection remain open at this time.

10.2 Conclusions

The scope of this approval is based on EPA’s baseli ne inspection conducted between December 2 and 4, 2008. EPA has determined that th e GEVNC-CCP RH WC program is technically adequate. EPA, therefore, is approving the GEVNC-CCP RH WC program for RH Waste Stream GEVNC.01 that was evaluated during thi s baseline inspection, as described and documented in this report. The approval includes t he following:

(1) The AK process for the RH TRU debris waste stream, designated as Waste Stream GEVNC.01 that will be generated from decontaminatio n activities of the Hot Cell 4 in Building 102.

(2) The radiological characterization process using DTC and radionuclide scaling factors for assigning radionuclide values to Waste Stream GEVNC. 01, as documented in CCP-AK-GEV-501, Revisions 0 and 1, and detailed in this report.

(3) The VE process to identify WMPs and the physical fo rm of the waste.

(4) The WWIS to submit data for both characterization a nd certification for RH TRU waste.

This approval is limited to RH TRU debris wastes fr om GEVNC Waste Stream GEVNC.01, as supported by the WC processes and documentation the EPA inspection team evaluated during this inspection. Wastes other than these are exclu ded from this approval, hence no T1 changes are included. Since the EPA December 2008 inspecti on, however, as the RH debris waste was being characterized GEVNC-CCP changed WC procedures which are identified in this report as T2 changes above and included in Tables 1 and 6. G EVNC-CCP will provide EPA with information concerning T2 changes no later than 4 w eeks after the last shipment of RH waste from the site is completed. Consistent with EPA’s authority under 194.24(h), EPA may request information relative to these changes if EPA deems the information necessary to ensure compliance with EPA regulations.51

Upon review of the T2 changes submitted to EPA. We will notify the public regarding the results of the evaluations of the T2 changes by posting the m on to the EPA Web site and sending emails to the WIPPNEWS list (see Section 2.0 of this report for a brief discussion of tiering).

GEVNC has indicated that a small quantity of debris from the D&D operation may qualify as contact-handled (CH) TRU debris (i.e., not meeting the external dose rate criterion for RH TRU). It is expected that GEVNC- CCP will ship these CH d ebris containers to CCP at the Idaho National Laboratory (INL-CCP) for characterization a s CH TRU waste from small quantity sites prior to disposal at WIPP. DOE must notify EPA pri or to shipment of these CH TRU waste(s) to INL-CCP. At that time, as part of this notificatio n, DOE will identify its plan to provide EPA with documentation on how CH container-specific AK information was handled, including nondestructive assay (NDA) data on the individual drum s, and other supporting information, as appropriate.52

Table 6. Tiering of RH TRU WC Processes Implemented by GEVNC-CCP,

Based on December 2–4, 2008 Baseline Inspection

RH WC Process Elements GEVNC-CCP RH WC - T1 Changes GEVNC-CCP RH WC - T2 Changes*

Acceptable Knowledge (AK) None** Notification and submission of the following items:

- Correlation and Surrogate Summary Form; (AK 2) - Revisions to the AK Summary CCP-AK-GEV-500, including changes to the associated Reference List; (AK 6) - Updates and revisions to CCP-AK-GEV-501; (AK 12) - Revision of reference M007; (AK 12) - Additional discrepancy resolutions; (AK 13)

- Final Waste Stream Profile Form and related attachments, and subsequent change requests; (AK 14 ) - AK Accuracy reports for this waste stream; (AK 1 5)

Radiological Characterization, Dose-to-Curie (DTC), and theapplication of radionuclidespecific scaling factors None** Notification and submission of the following items:

- Revisions of CCP-AK-GEV-501 or CCP-TP-504 that require CBFO approval; (RC 3)

- Generation of measurement data for any GEVNC RH TRU container(s) that subsequently qualifies as CH and is subject to NDA; (RC 8)

Visual Examination (VE) None** Notification and subm ission of the following items:

- Any change to VE procedure(s) that requires CBFO approval; (VE 2)***;

WIPP Waste Information System (WWIS) None at this time Notification and submission of the following items:

- Changes to WWIS procedure(s) that require CBFO approval; (WWIS 2)***;

- Changes to the Excel spreadsheet titled WWIS Dat a Entry Summary Characterization and Certification; (WWIS 2)

* All applicable T2 changes must be provided to EPA in a one-time submission following completion of t he last shipment of GEVNC RH debris proposed for approval to WIPP for di sposal

** No additional RH waste from GEVNC will be characte rized using the site processes evaluated during the inspection *** Excluding changes that are editorial in nature or are required to address administrative concerns

11.0 REFERENCES

U.S. Department of Energy, Carlsbad Area Field Offi ce, “Contact-Handled Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot P lant (CH-WAC),” Revision 3, DOE/WIPP-02- 3122, Carlsbad, New Mexico, April 25, 2005.

U.S. Environmental Protection Agency, “Criteria for the Certification and Recertification of the Waste Isolation Pilot Plant’s Compliance with the D isposal Regulations: Certification Decision; Final Rule,” Federal Register , Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405.

U.S. Code of Federal Regulations, Title 40

, Protection of Environment , Part 191, “Environmental Radiation Protection Standards for Management and D isposal of Spent Nuclear Fuel, High-Level

and Transuranic Radioactive Wastes.”53

U.S. Code of Federal Regulations, Title 40

, Protection of Environment , Part 194, “Criteria for the

Certification and Re-Certification of the Waste Iso lation Pilot Plant’s Compliance with the 40 CFR Part 191 Disposal Regulations.”

U.S. Department of Energy, Carlsbad Area Field Offi ce, “Remote Handled TRU Waste Characterization Program Implementation Plan,” DOE/ WIPP-02-3214, Revision 0D, Carlsbad, New Mexico, October 30, 2003.

U.S. Department of Energy, Title 40 CFR Part 191, C ompliance Certification Application for the Waste Isolation Pilot Plant, DOE/CAO 1996-2184, Car lsbad, New Mexico, 1996.

U.S. Department of Energy, Title 40 CFR Part 191, S UBPART D AND C, Compliance Recertification Application 2004, DOE/WIPP/2004-323 1.

U.S. Department of Energy, Carlsbad Area Field Offi ce, “Quality Assurance Program Document (QAPD),” DOE/CBFO-94-1012, Revision 7, Carlsbad, Ne w Mexico, July 2005.

U.S. Nuclear Regulatory Commission, “Contact-Handled Transuranic Waste Authorized Methods for Payload Control (CH-TRAMPAC).VE - 1ATTACHMENT A.1: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8Inspection Date: December 2–4, 2008Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentRHVE-1:Site proceduresidentify required training andqualifications for RHVEpersonnel.WCPIP,Rev. 0D,Sect. 4.1.2CCP-QP-002,Rev. 27•Formal training elements include:project requirements, containeridentification and labeling, applicablestate andfederalregulations•Site-specific training program:OJT,identification of summary categorygroups, WMPs, packagingconfigurations, residual liquidsY EPA reviewed training records for both VE operators and VEExperts (VEEs). CCP records contained specific jobtrainingand required reading records. Site-specific training isprovided through the required reading system and isappropriate. VEEs are designated by SPMs and areconsidered qualified to perform their duties when training iscompleted and the individual is added to the LOQI.At thetime of the inspection, there were two personnel qualified asOperator/ITR/SME/OJT and one qualified as Operator/ITRfor VE at GEVNC.Objective evidence:1.LOQI for VE2.Training records for two VE SME and one VE operatorRHVE-2:Operator qualificationand re-qualificationrequirementsare described.WCPIP,Rev. 0D,Sect. 4.1.2CCP-QP-002,Rev. 27,Sect. 4.2.5•To become qualified, the RHVE operatormust pass a comprehensive written testbased on training objectives with aminimum score of 80%•Demonstrate capability in the presenceof the site VEE during OJT•RHVE operators re-qualified every 2years based on continued satisfactoryperformance•Unsatisfactory performance – failed toidentify prohibited item during OJT ofscore of less than 80% on examYThe personnel performing VE at the facility are experiencedand have been qualified on other CCP projects. EPAreviewed training records for personnel on the LOQIanddetermined that only qualified personnel were performingVE. Training included required reading, examination, andOJT.Objective evidence;1.LOQI for VE2.Training records for two VE SME and one VE operator(VEO)RHVE-3:Each site has adesignated VE expert (VEE).WCPIP,Rev. 0D,Sect. 4.2.2•VEE designation is documented•VEE has knowledge of the RH TRUwaste being characterizedY VEE designations are communicated by e-mail and thee-mails are retained as records. This e-mail states that theVEE meets the prerequisite for the position and requestsinitiation of training. Only after this training has beenVE - 2ATTACHMENT A.1: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8Inspection Date: December 2–4, 2008Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentCCP-PO-001,QAPjP,Rev. 16•Responsible for overall direction andimplementation of VE at the facility•Certification Planspecifies theselection, qualification, and trainingrequirements of VEEcompleted is the VEE considered fully qualified.Site-and waste stream-specific training are provided by CCP.Personnel received training on the AK summary CCP-AKGEV-500 prior to performing VE operations.Objective evidence:1.LOQI for VE2.Training records for two VE SME and one VEORHVE-4•Operators review AK TrackingSpreadsheet to verify that correctcontainers examined•Rejected containers are placed in ashielded container with a CCP HoldTag attached•Provide container processing informationto SPM/VPMNAThe process inspected was VE performed during packagingof waste contained in a glovebox.RHVE-5:Procedures andtechnical guidance documentsprovide complete instructions forperforming RHVE.WCPIP,Rev. 0D,Sect. 4.1.2.1,CCP-TP-500,Rev. 8,Sect. 4.1–4.2,Attachment 1Procedures are sufficiently detailed to enablethe operator to determine if a waste containermeets the criteria of 40 194.24 with regard toidentifyingapplicable parameters with wastelimits [40 194.24, c, (4) – demonstrate that asystem of controls has been and will continueto be implemented to confirm that the totalamount of each waste component that will beemplaced in the disposal system will notexceed the upper limiting value or fall belowthe lower limiting value described in theintroductory text of paragraph (c) of thissection].YThe EPA observed the packaging operations for 55-gallondrum GE019 in Cell 4 of Building 102. The two gloveboxoperators who manipulated and packaged the waste were GEemployees. Two CCP VE personnel performed the actualVE, identifying and documenting the waste loaded intocontainer GE019. CCP did not make an audio/visualrecording of the VE event (GE did make a recording,but notfor VE purposes). VEOs reviewed the AK summary sheet toverify the waste matrix code for the container (S5400).The CCP VEE and VEO had an electronic copy of CCP-TP500 to guide their activities and electronically entered theWMPs into Attachment 1 after identification and concurrencebetween the CCP VE personnel. The identity of thewaste,e.g., “rubber glove,” was called out by the VEE andverballyVE - 3ATTACHMENT A.1: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8Inspection Date: December 2–4, 2008Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Comment•All existing VE tapes will be reviewedand the VE data will be documented (NAfor ORNL-CCP)•Existing waste container packagingrecords will be qualified by VE or RTR•100% of containers will be subject to VEat the time of packaging•Waste Stream Description and WMCverified•Presence/absence of prohibited itemsrepeated by the VEO before it was entered into Attachment 1.Small pieces of waste were loaded into a plastic duffel bag tokeep the waste together. The operators used a flashlight toilluminate items if they are difficult to identify.Both theduffle bag and waste were loaded into the 55-gallondrum.The duffle bag was recorded as “poly bag” on the containerinventory. The process used for waste transfer outof the hotcell and into the drum was not included in the VE procedureCCP-TP-500. EPA generated a concern.CCP was able to confirm the waste stream description andwaste matrix code.Prohibited items are not loaded into containers andare left inthe glovebox for remediation.The waste was transferred through the access port to theinterlock for cell 4 and heat-sealed before being placed in thecontainer. Transfer of the waste into the container wasachieved using a cradle and hoist. The heat-sealedbag wasvented prior to loading. The loaded and closed container isthen placed in a shielded container, which allows thecontainer to be moved for storage. At the time oftheinspection, no containers had been removed after completionof VE.The primary content was recorded as “Steel” for allcontainers in the BDRs reviewed.Objective evidence:1.BDRs RHGEVE080001, RHGEVE080002 andRHGEVE080003, RHGEVE080006RHVE-6CCP-TP-500,Rev. 8,•Corrective actions are taken whennecessaryY No corrective actions have been generated up to andincluding the time of the inspection. CCP personnel areexperienced at identifying and generating corrective actionVE - 4ATTACHMENT A.1: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8Inspection Date: December 2–4, 2008Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentSect. 2.4.2reports due to work at other CCP sites.RHVE-7: Site procedure(s)require data generation andproject level reviews of BatchData Reports (BDRs).WCPIP,Rev. 0D,Sect. 3.5.1CCP-TP-500,Rev. 8•ITR review Attachment 2•SPM review Attachment 3Y EPA reviewed three BDRs during the on-site inspection.These BDRs were RHGEVE080001, RHGEVE080002,RHGEVE080003 and. Each BDR consisted of VE data fortwo containers. All BDRs had been reviewed by anIndependent Technical Review and BDRs RHGEVE080001,RHGEVE080003 and RHGEVE080006 had been reviewedby the SPMObjective evidence:1.BDRs RHGEVE080001, RHGEVE080002 andRHGEVE080003, RHGEVE080006RHVE- 8CCP-TP-500,Rev. 8,Sect. 5.0•Lifetime/QA records – Attachments 1–5,Copy of NCRs•QA/nonpermanent records – VHS tape orDVD (primary and backup)Y Audio/visual recording was not made because two operatorsperformed the VE.No NCRs had been generated at the time of the inspection.BDRs contained attachments as required.RHVE-9: Quality AssuranceObjectives are defined and met.WCPIP,Rev. 0D,Table 2.140 CFRPart 194.22.bData Accuracy:194.22, b, (1): the degree to which data agreewith an acceptable reference or true valueWCPIP: maintained by requiring operators topass a comprehensive test with a score of80% and demonstrated satisfactoryperformance for initial qualification and requalificationData Precision:194.22, b, (2): a measure of the mutualagreement between comparable data gatheredor developed under similar conditionsY Data Accuracy: CCP VE personnel training recordsincludeexamination, required reading and OJT.Data Precision: Two operators agreed on waste identificationand WMP before it was entered on Attachment 1, VisualExamination Data Form.VE - 5ATTACHMENT A.1: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8Inspection Date: December 2–4, 2008Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentexpressed in terms of a standard deviationWCPIP: maintained by reconciling anydiscrepancies between two operators (oroperator and ITR) with regard to physicalform of waste, absence of residual liquidData Representativeness194.22, b, (3): the degree to which dataaccurately and precisely represent acharacteristic of a population, a parameter,variations at a sampling point, orenvironmental conditionsWCPIP: Contents placed in a container willbe described on the data formsData Completeness194.22, b, (4): a measure of the amount ofvalid data obtained compared to the amountthat was expectedWCPIP: relevant waste information must becollected and documented on a videotapeand/or data form or other unalterable mediaData Comparability194.22, b, (5): a measure of the confidencewith which one data set can be compared toanotherWCPIP: ensured by site meeting trainingrequirements and complying with theminimum standards used to implement VEData Representativeness: Two operators agreed on wasteidentification and WMP before it was entered on Attachment1, Visual Examination Data Form. The waste item was calledout by one operator and orally confirmed by the secondoperator who entered the data into the electronic data form.Data Completeness: All waste items were identifiedandrecorded prior to loading. Small items were collected in aduffle bag, which was ultimately loaded into the 55-gallondrum.Data Comparability: CCP has a well established trainingprogram for VE personnel. Initial qualification for theoperators included required reading, OJT and examination.Re-qualification takes place every 2 years.VE - 6ATTACHMENT A.1: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8Inspection Date: December 2–4, 2008Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentRHVE-10:VE as a method toqualify AK dataWCPIP,Rev. 0D,Sect. 4.3,4.3.3CCP-TP-500,Rev. 8CCP-QP-002,Rev. 26194.24, c, (4) – demonstrate that a system ofcontrols has been and will continue to beimplemented to confirm that the total amountof each waste component that will beemplaced in the disposal system will notexceed the upper limiting value or fall belowthe lower limiting value described in theintroductory text of paragraph (c) of thissectionIf VE is used as a qualification method forAK, all of the requirements in Sections 4.3and 4.3.3 are met:•Quality and reliability of themeasurement control program underwhich the data were generated (QCsamples included in the VE process)•Extent to which the data demonstrate theproperties of interest (VE processgenerates data for allitems incontainers)•Qualification of personnel generatingdata (training records for personnel ontapes performing the original VE eventif qualifying existing data)•Technical adequacy of the proceduresused to generate the original data (copiesof original procedures)Y QC for this type of VE process is limited to concurrencebetween two operators. Because this was origin packagingactivities, other QC e.g., duplicates to assess precision, arenot applicable. Data are subject to two levels ofreview bythe ITR and SPM.During the demonstration, all waste items were identified,recorded and packaged.CCP has a well-established training program for VEpersonnel. Initial qualification for the operatorsincludedrequired reading, OJT and examination. Re-qualificationtakes place every 2 years.EPA inspectors reviewed the VE procedure, CCP-TP-500, R.8 and generated the following concern requiring a responsebecause final packaging instructions were not included in theprocedure:GEVNC-CCP-RH-VE-08-004CR: The packaging processimplemented for VE is not incorporated in a formalCCPprocedure and is only described in the AK summary,CCPAK-GEV-500, Revision 1, Section 5.5. Incorporatingthepackaging process instructions in a formal CCP procedure isnecessary to ensure consistency of operation.Procedure CCP-TP-500 requires the VEO to protect the wastefrom tampering. Because this is not performed by the VEOor other personnel, EPA generated the following concern notrequiring a response:GEVNC-CCP-RH-VE-08-005C: VE Procedure CCP-TP500, Revision 8, Section 4.2.5 [C] states: “Ensurethe wastepackage is stored with reasonable protection fromtampering.” This activity is assigned to the VEO. In practice,the VEO does not perform this activity and is not,therefore,VE - 7ATTACHMENT A.1: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8Inspection Date: December 2–4, 2008Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentin compliance with CCP’s written procedure wheneverVE isperformed.WWIS-1ATTACHMENT A.2: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLISTEPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8Inspection Date: December 2–4, 2008Establishment of RequiredTechnical Elements in ProceduresLocationExecution of ProceduresY/NObjective Evidence/CommentWWIS-1:WWIS and Data EntryPersonnel must be trained to assessdata and properly enter data into theWWIS.CCP-QP-002,Rev. 27CCP-TP-530,Rev. 7,Sect. 2.2.1•WCO and Data Entry Personnel aretrained to assess data and properly enterand transfer all data in the WWIS.•Training for Data Entry Personnel anddata reviewers/verifiers includes theWIPP Waste Information System User’sManual and the applicable siteprocedures.•Training records are available for reviewand are complete.YEPA reviewed the training records for the twoWCA/WCOs qualified for this site.Initial training includes WIPP Waste InformationSystem User’s Manual and OJT. Addendum Grecords WCA training for all RH TRU sites.Addendum H records WCO training for all RH TRUsites. The WCO qualifying examination is performedverbally with an SME.Training records were complete for the WCA/WCOwho performed the onsite demonstration of WWIS.Objective evidence:3.Training records for two WWIS WCA/WCOsWWIS-2:Security measures forensuring data integrity and accessingWWIS are sufficient.CCP-TP-530,Rev. 7,Sect. 4.1Access to WWIS is controlled. WWISaccess requests are recorded in an access logthat is available for review.Y Access to WWIS is password controlled. Each WCAand/or WCO must obtained a password from theWWIS Administrator prior to beginning work, andpasswords become invalid if an employee leaves CCP.WWIS-3:There are adequateprocedures for entering data into theWWIS and transmitting data to WIPP.CCP-TP-530,Rev. 7,Sect. 3.0, 4.0Employee’s explanation of job duties wasconsistent with applicable procedures.WWIS and Data Entry Personnel adequatelyexplained how data are assessed, input, andtransferred into WWIS.Y A WCO demonstrated, in the test instance, how dataare entered, checked, and uploaded into WWIS forGEVNC data. At the time of the onsite inspection,GEVNC did not have an approved Waste Stream ProfileForm (WSPF) and containers could not be certified forshipment. A minimum of results from 10 containersare needed to approve a WSFP. These data are enteredinto the Characterization module of WWIS andtransferred to the Certification module of WWIS afterWSPF approval. During the demonstration, data wereentered into the test instance of WWIS.Objective evidence;1.WWIS Data Entry Summary – Chaz & Cert forGEVNC containers GE003 and GE004WWIS-4:Procedures require thatonly verified and validated data areCCP-TP-530,Rev. 7,Data generation and project-level reviews ofcontainer data for WWIS entry have beenY The WCO explained the process used for certifyingcontainers from GEVNC prior to entering some dataWWIS-2ATTACHMENT A.2: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLISTEPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8Inspection Date: December 2–4, 2008Establishment of RequiredTechnical Elements in ProceduresLocationExecution of ProceduresY/NObjective Evidence/Commententered into WWIS. Sect. 4.3,Table 1performed and review checklists arecomplete.into WWIS. Containers only become eligible forWWIS entry after completion of the review checklists(ITR and SPM) are completed. A WCA obtains a listof eligible containers from a SPM and obtains hardcopies of the applicable BDRs to facilitate WWIS dataentry. The following information is required forWWIS entry: dose-to-curie results (radionuclideactivities), VE data, radiological survey results,and theAK tracking sheet for the waste stream.Objective evidence;1.Testing results (dose-to-curie, VE, radiologicalsurvey, and AK tracking sheet) for containerGE0032.WWIS Data Entry Summary – Chaz & Cert forGEVNC containers GE003 and GE004WWIS-5:Procedures includeinstructions for enteringcharacterization data into theCharacterization Data System (CDS)WCO Review Form and datadiscrepancy resolution.CCP-TP-530,Rev. 7,Sect. 4.4,Table 1•WCA uses Table 1 to identify and enterrequired data into the CDS.•Second WCA reviews data, initials, anddates.•If data discrepancies cannot be resolvedthe form is sent to WCO or SPM forresolution.Y CDS was not used for this site at the time of theonsiteinspection and all data were obtained from hard copies.A spreadsheet, GEVNC RH template.xls, is used toenter data, and this completed spreadsheet is reviewedby a second WCA. Results of this 100% review ofdata are recorded on the spreadsheet. If data iscorrected in the spreadsheet, the change is made andinitialed. If the actual data appear to be incorrect, it isreturned a SPM for verification.The spreadsheet has been validated in accordance withprocedure CCP-QP-22, R.10, Software QualityAssurance Plan. The control number for thisspreadsheet is SCO 1023.If data discrepancies cannot be resolved by the twoWCAs, then a SPM or WCO is contacted forresolution.Objective evidence:WWIS-3ATTACHMENT A.2: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLISTEPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8Inspection Date: December 2–4, 2008Establishment of RequiredTechnical Elements in ProceduresLocationExecution of ProceduresY/NObjective Evidence/Comment1.WWIS Data Entry Summary – Chaz & Cert forGEVNC containers GE003 and GE004WWIS-6:Containers are notsubmitted to WWIS if there are openNCR/CARs.CCP-TP-530,Rev. 7,Sect. 4.3.11WCA requests QAO to confirm that thereare no open NCR/CARs for the containersentered into the CDS.NA CDS was not used for this site at the time of the onsiteinspection. No NCRs had been issued for thecontainers processed to date. CCP has a well-definedprocess for ensuring that there are no open NCRsassociated with candidate containers, which has beendemonstrated at other sites for both CH and RH waste.The container number is entered into the PTS database,which identifies any open NCR for that container.WWIS-7:Procedures provideinstructions for WCO review ofcharacterization and certification toWWIS.CCP-TP-530,Rev. 7,Sect. 4.4WCPIP,Rev. 0D,Sect. 4.2.9The WCO verifies:•TRU alpha activity is >100 nCi/g foreach payload container.•Confirm WWIS Data Spreadsheet orCDS WCO Review Form information isaccurate and complete.•TRUCON Code (waste is notincompatible).•WSPF number.•Site-specific identifier precedescontainer number.YDuring the inspection, the WCO explained to EPAentries on the spreadsheet, including TRU alphaactivity, TRUCON code, and WSPF (not yetapproved). To challenge the edit limit checks builtinto the spreadsheet, the WCO changed TRU alphaactivity, so that it was below the required value.WWIS rejected these data.The TRUCON code is reviewed by the WCO to ensurethat when canisters are “built,” they will be compatible(3 containers per each canister).The WSPF number for this waste stream isGEVNC.01, which was not approved at the time of theinspection.The site-specific identifier for this site is “cc.”Objective evidence:1.WWIS Data Entry Summary – Chaz & Cert forGEVNC containers GE003 and GE0042.Waste Container Data Report for container GE003and GE004WWIS-4ATTACHMENT A.2: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLISTEPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8Inspection Date: December 2–4, 2008Establishment of RequiredTechnical Elements in ProceduresLocationExecution of ProceduresY/NObjective Evidence/CommentWWIS-8:WMP weights for eachSCG are entered into WWIS inaccordance with the procedure.CCP-TP-530,Rev. 7,Sect. 4.5.9–4.5.10WCPIP,Rev. 0D,Sect. 4.2.9S5000:•If calculated CPR weight is = or < netweight of container, enter the net weightof the container as “plastic.”•If calculated CPR weight is = or > netweight of container, enter maximumweight of CPR as “plastic.”YEPA reviewed the spreadsheets for containers GE003and GE004 and the Waste Container Data Report forcontainer GE003 to verify that all waste was entered as“PW” (plastic waste). The amount of PW entered wascalculated for the gross and net weights for thecontainer. This is a debris waste stream, S5400.Objective evidence;1.WWIS Data Entry Summary – Chaz & Cert forGEVNC containers GE003 and GE0042.Waste Container Data Report for containers GE003and GE004WWIS-9:Reviewed data are enteredinto WWIS.CCP-TP-530,Rev. 7,Sect. 4.5•WCO signs and dates CDS or WWISData spreadsheet.•WCO or WCA submits data to WWIS(certification module if WSPF approved,characterization module if WSPF notapproved).•WWIS Administrator accepts/rejects datavia e-mailNANo data had been submitted to the characterizationmodule WWIS at the time of the inspection. Datafrom 10 containers are needed for WSPF approval.The demonstration used the WWIS test instance fordata entry.WWIS-10:Resolution of datadeficiencies.CCP-TP-530,Rev. 7,Sect. 4.4.17-4.4.18,4.4.22-4.4.24,4.5.11•Hold•NCRNANo NCRs had been issued against the containersprocessed at the time of the inspection. CCP has awell-defined process for ensuring that there are noopen NCRs associated with candidate containers,which has been demonstrated at other sites for bothCHand RH waste. The container number is entered intothe PTS database, which identifies any open NCR forthat container.WWIS-11CCP-TP-530,Rev. 7,•After submission, the Waste ContainerYEPA reviewed the data sheets for container GE003 andthe required information was available. The filterWWIS-5ATTACHMENT A.2: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLISTEPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8Inspection Date: December 2–4, 2008Establishment of RequiredTechnical Elements in ProceduresLocationExecution of ProceduresY/NObjective Evidence/CommentSect. 4.6.13Data Report is printed, signed. and dated,•Copies of data, radiological survey, filterinformation, signed Waste ContainerData Report, and correspondence sent toCCP records custodian.information was recorded in the comments section ofthe VE data sheet. Because GEVNC containers hadnot yet been entered into WWIS, the records availablewere limited to characterization data.Objective evidence;1.WWIS Data Entry Summary – Chaz & Cert forGEVNC containers GE003 and GE0042.Waste Container Data Report for containers GE003and GE004WWIS-12:Records retention.CCP-TP-530,Rev. 6,Sect. 5.0QA/Lifetime records:•WWIS Data SS or CDS WCO ReviewForms.•Waste Container Data Report.•WWIS Data Approval/Rejection Reports.•Correspondence.QA/Nonpermanent:•CDS Database (electronic).YCDS database was not used for this waste stream atthetime of the inspection.Characterization data, spreadsheets, and WasteContainer Data Reports were available for thedemonstration containers GE003 and GE004.Objective evidence:1.WWIS Data Entry Summary – Chaz & Cert forGEVNC containers GE003 and GE0042.Waste Container Data Report for containers GE003and GE004B-1 ATTACHMENT B.1. EPA INSPECTION ISSUE TRACKING FOR M, EPA INSPECTION ISSUE NO. GEVNC-CCP-RH-AK-08-002CR, FINAL

Inspection No. EPA-GEVNC-CCP-RH.12-08.8 Issue Number: GEVNC-CCP-RH-AK-08-002CR

Date: December 5, 2008, Final
Inspector: Connie Walker

Attachments? YES Sample Size: NA Population size (if known): NA

Description of Issue: CCP-AK-GEV-500 and other AK-related documents req uire technical and

editorial modifications to correct errors and/or to clarify information. These modifications include, but are not limited to, the items that are listed in At tachment 1.

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable

D. Discussed with: Mark Doherty, Kevin Peters, Irene Qunitana

E. Additional Comments: None

F. Site Response Information:

Site Response Required? YES Site Response Due Date: January 14, 2009B-2 EPA Concern No. GEVNC-CCP-RH-AK-08-002CR

Attachment 1, Page 1 of 2

Issues Related to CCP-AK-GEV-500, Partial List

• References for each of the bulleted time-line activ ities presented on pages 8-9 of the AK Summary, and correlation of these activities (throu gh reference to detailed discussions) on pages 12-16 are not provided.

• The AK Summary does not clearly state that Hot Cell 4 will be decontaminated and the interior enclosure will be removed, but the cell wi ll not be demolished and will instead be used in the future for other purposes.

• Section 4.1 is unclear regarding which discussions address GEVNC as a whole versus activities that took place in Hot Cell 4.

• The AK record does not reflect all changes that wer e made to the waste stream volume and radionuclide scaling factors, including the tex t and tables.

• Information in the text of the AK Summary pertainin g to the Q-tip smears obtained in 1982, including the specific analysis and informati on provided by the activity, is insufficient. This is important because the Sampli ng and Analysis Plan (SAP) apparently uses this information as the basis for developing s pecific aspects.

• The radionuclide discussion in Section 5 does not a dequately address generalized waste composition. Of particular importance are changes in activities/potential radiological contamination pre-post 1978 (i.e., MOX prior with e xceptions, sources post, with exceptions). CCP did not prepare a radiological an alysis or table to accompany their own time line that may help make these changes. Note th at Section 5.4.10 may also require

revision based on EPA Concern No. GEVNC-CCP-RH-AK-08-003CR.

• Table 5 of the CCP-AK-GEV-500 does not adequately r eflect modified radionuclide scaling factors.

• The prohibited item discussion in Section 5.4.12 do es not include an updated and thorough spent nuclear fuel (SNF) analysis.

• Table 6 is unclear regarding the quantification met hods for TRU Waste, RH Waste, Activity, and determination of the 10 WIPP-Tracked radionuclides.

• Table 6 does not include all AK source documents. It is not clear why reference C007 (e.g., for TRU Waste DQO determinations) is include d.B-3 EPA Concern No. GEVNC-CCP-RH-AK-08-002CR

Attachment 1, Page 2 of 2

Issues Related to AK Accuracy Report, Partial List :

• The AK Accuracy Report (December 1, 2008) states th at the AK compilation for the waste stream is complete and the required AK accura cy report is therefore incorporated into CCP-AK-GEV-502. This is not correct, as the w aste stream contains only six

characterized containers.

• Ensure that reference lists, including Attachments 1 (WCPIP) and 4 (CCP-TP-005), include all references presented in CCP-AK-GEV-501.

Issues Related to Confirmation Test Plan, Partial L ist:

The Confirmation Test Plan CCP-AK-GEV-502 states on page 12 that performance of additional swipe sample collection efforts will be evaluated i f the variability of sample results so warrants; please clarify whether this will actually be perfor med.B-4 ATTACHMENT B.2. EPA INSPECTION ISSUE TRACKING FOR M, EPA INSPECTION ISSUE NO. GEVNC-CCP-RH-AK-08-001F, F INAL

Inspection No. EPA-GEVNC-CCP-RH.12-08.8 Issue Number: GEVNC-CCP-RH-AK-08-001F

Date: December 5, 2008, Final
Inspector: Connie Walker

Attachments? NO Sample Size: NA Population size (if known): NA

Description of Issue: The Energy Solutions Sampling and Analysis Plan (SA P) GE Vallecitos Nuclear Center Hot Cell #4 provides the proposed Ene rgy Solutions sampling locations and sample numbers for swipes to be collected from Hot Cell 4. However, the final sample numbers and locations presented in CCP-AK-GEV-500 and 501 are i nconsistent with the proposed sample numbers and locations presented in the SAP. There was no report or memorandum that documented the results of the SAP as it was implemented, inclu ding final sample locations, corresponding sample numbers, and location of field duplicates an d associated sample identifiers. Also indicate whether any trip blanks or other field-related qual ity control samples were collected, and whether these were transmitted to the laboratory for analys is. Revise, as necessary, all discussions in CCPAK-GEV-500 and 501 to be internally consistent and to reflect the results provided. Provide the revised CCP-AK-GEV-500 and 501, as well as the repo rt or documents from Energy Solutions.

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): WCPIP, Attachment C, Section 6

D. Discussed with: Mark Doherty, Jene Vance, Dick Blauvelt

E. Additional Comments: None

F. Site Response Information:

Site Response Required? YES Site Response Due Date: January 14, 2009B-5 ATTACHMENT B.3. EPA INSPECTION ISSUE TRACKING FOR M

, EPA INSPECTION ISSUE NO. GEVNC-CCP-RH-AK-08-003CR, FINAL

Inspection No. EPA-GEVNC-CCP-RH.12-08.8 Issue Number: GEVNC-CCP-RH-AK-08-003CR

Date: December 5, 2008, Final
Inspector: Connie Walker

Attachments? NO Sample Size: 1 Population size (if known): NA

Description of Issue: The Sampling and Analysis Plan (SAP) must meet th e requirements as specified in Attachment C, Section 6 of the RH WCPIP. Please address the following:

• The WCPIP states that the sampling plan “...shall be developed using the guidance provided in EPA QA/G5 and QA/G9.” Please indicate how this was attained.

• According to the WCPIP, the waste may include mater ials in which the “RH TRU materials embedded in...other solid material may require sample s to be obtained from within the material.” Based on the available data, please add ress whether any material are present in the GEVNC waste stream that may require this considerati on.

• The WCPIP requires that the SAP be submitted to CBF O for review and approval. Please provide evidence of the review and approval.

B. Regulatory Reference: 40 CFR 194.24(c)

2C. Site requirement(s): RH WCPIP

D. Discussed With: Mark Doherty

E. Additional Comments: None

F. Site Response Information:

Site Response Required? YES Site Response Due Date: January 14, 2009B-6 ATTACHMENT B.4. EPA INSPECTION ISSUE TRACKING FOR M, EPA INSPECTION ISSUE NO. GEVNC-CCP-RH-RC-08-006CR, FINAL

Inspection No. EPA-GEVNC-CCP-RH.12-08.8 Issue Number: GEVNC-CCP-RH-RC-08-006CR

Date: December 5, 2008, Final
Inspector : Patrick Kelly

Attachments? NO Sample Size: 8 Population size (if known): 11

Description of Issue: The ten calculation packages that document the radi ological characterization (RC) process and the CCP report CCP-AK-GEV-501 have multiple technical and editorial errors. As presented during this inspection, these documents r equire revision to accurately serve as objective evidence for the RC process.

B. Regulatory Reference: 40 CFR 194.24(c)

2C. Site requirement(s): Not applicable

D. Discussed with: Joe Harvill, Jene Vance, Earl Bradford, Mark Dohert y

E. Additional Comments: None

F. Site Response Information:

Site Response Required? YES Site Response Due Date: January 14, 2009B-7 ATTACHMENT B.5. EPA INSPECTION ISSUE TRACKING FOR M, INSPECTION ISSUE NO. GEVNC-CCP-RH-VE-08-004CR, FINA L

Inspection No. EPA-GEVNC-CCP-RH.12-08.8 Issue Number: GEVNC-CCP-RH-VE-08-004CR

Date: December 5, 2008, Final
Inspector: Dorothy E Gill

Attachments? NO Sample Size: 1 Population size (if known): NA

Description of Issue: The packaging process implemented for VE is not i ncorporated in a formal CCP procedure and is only described in the AK summary, CCP-AK-GEV-500, Revision 1, Section 5.5. Incorporating the packaging process instructions in a formal CCP procedure is necessary to ensure consistency of operation.

B. Regulatory Reference: 40 CFR 194.24(c)

2C. Site requirement(s): Not applicable

D. Discussed with: Tommy Mojica, Joe Garcia

E. Additional Comments: None

F. Site Response Information:

Site Response Required? YES Site Response Due Date: January 14, 2009B-8 ATTACHMENT B.6. EPA INSPECTION ISSUE TRACKING FOR M, INSPECTION ISSUE NO. GEVNC-CCP-RH-VE-08-005C, FINAL

Inspection No. EPA-GEVNC-CCP-RH.12-08.8 Issue Number: GEVNC-CCP-RH-VE-08-005C

Date: December 5, 2008, Final
Inspector: Dorothy E Gill

Attachments? NO Sample Size: 1 Population size (if known): NA

Description of Issue: VE Procedure CCP-TP-500, Revision 8, Section 4.2. 5 [C] states: “Ensure the waste package is stored with reasonable protection from tampering.” This activity is assigned to the Visual Examination Operator (VEO). In practice, th e VEO does not perform this activity and is not, therefore, in compliance with CCP’s written procedu re whenever VE is performed.

B. Regulatory Reference: 40 CFR 194.24(c)

2C. Site requirement(s): Not applicable

D. Discussed with: Tommy Mojica, Joe Garcia

E. Additional Comments: None

F. Site Response Information:

Site Response Required? NO Site Response Due Date: Not applicable