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 CENTER 

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 2009
i 

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 ......................................................................................................................... 52 
ii 

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 Density of 0.3 g/cm3

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

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

Based on December 2–4, 2008 Baseline Inspection .................................................... 52 
iii 

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 Authorized 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 form 
iv 

DTC dose-to-curie 

EPA U.S. Environmental Protection Agency 

Eu europium 

FGE fissile gram equivalent 

FR Federal Register 

g gram or grams 

g/cm3

 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 curie 
v 

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 Authorized 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 plan 
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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 zirconium
1 

1.0 EXECUTIVE SUMMARY 

This report discusses the U.S. Environmental Protection Agency’s approval of the remotehandled (RH) transuranic (TRU) debris waste (GEVNC.01) 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 approval, the GEVNC debris waste 

characterized by the Central Characterization Project (CCP) may be disposed of at the Waste 

Isolation Pilot Plant (WIPP). 

From December 2 through 4, 2008, the U.S. Environmental 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 the 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 approve CCP’s RH TRU debris 

waste characterization program and RH TRU debris waste 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 comments (see Docket ID No. EPA–HQ–OAR–

2009–0372). EPA evaluated the comments and made appropriate changes in this report. Section 

9.0 includes the comment received and EPA’s response. 

Beginning in 1958, Hot Cell 4 in Building 102 at GEVNC was used primarily for nondestructive examination of fuel materials and the production of radionuclide sources. The 

examinations consisted mainly of post-irradiation examination (PIE) of uranium fuel and reactor 

components until 1982. Since then, the hot cell has 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 during the inspection. This resulted in EPA 

identifying several significant issues. EPA concluded that the inspection could not be completed 

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

revised documentation in the form of additional technical information and objective evidence in 

response to outstanding issues discussed later in this report. 

The inspection scope covered only one RH waste stream, 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 radiological contents of individual TRU RH 

debris waste containers, and the use of the WIPP Waste Information System (WWIS) to report 

and track waste information. This inspection was similar 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, II-A4-111). 

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

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

regulations for TRU radioactive waste [63 Federal Register (FR) 27354 and 27405, May 18, 
2 

1998]. EPA Baseline Inspection No. EPA-GEVNC-CCP-RH-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 waste (see Attachments B.1 through B.6). 

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

After reviewing the documents provided by DOE through 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 following 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 designated 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 is documented in 

CCP-AK-GEV-501, Revision 1, as supported by the revised calculation packages and 

detailed in this report 

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

the waste 

(4) The WWIS to submit data for both characterization and 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 additional RH TRU debris waste streams requiring 

characterization by CCP for disposal at the Waste Isolation Pilot Plant will be generated. 

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

additional waste containers are characterized and waste-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 at the WIPP is of limited volume, and as 

of the date of the proposed report, more than 75% of the waste had been characterized and 

packaged. Soon after the CBFO issues their site certification, all RH TRU waste will be 

disposed of. No additional RH debris waste characterization will occur once the debris from 

D&D activity is complete and is characterized and disposed 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 submission, however, a one-time T2 

information submission to EPA notifying the end of the characterization activity will be 

necessary. Therefore, GEVNC-CCP must provide applicable 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 debris containers to CCP at the Idaho 

National Laboratory (INL-CCP) for characterization as CH TRU waste from small quantity sites 

prior to disposal at WIPP. DOE must notify EPA prior to shipment of these CH TRU waste(s) to 

INL-CCP. At that time, as part of this notification, 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 drums, and other supporting information, as 

appropriate. 

The Waste Characterization Program Implementation Plan (WCPIP) issued by DOE should be 

an accurate representation of the processes implemented 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 its 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 WCPIP and will work with DOE to produce a 

technically adequate version of the WCPIP. EPA will 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 15) 

Radiological Characterization, 

Dose-to-Curie (DTC), and the 

application 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 submission 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 Data 
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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 the last shipment of 

GEVNC RH debris proposed for approval to WIPP for disposal 

** No additional RH waste from GEVNC will be characterized 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 comply with the radioactive waste disposal 

regulations in 40 CFR Part 191. In this certification, EPA also included Condition 3, which 

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

other than LANL for disposal at the WIPP until the Agency has approved the processes for 

characterizing those waste streams for shipment using the process set forth in § 194.8.” The 

approval process described in 40 CFR 194.8 requires DOE to (1) provide EPA with information 

on AK1

 for waste streams proposed for disposal at the WIPP, and (2) implement a system of 

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

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

The rule applying to this baseline inspection can be 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 baseline inspection of a TRU waste generator 

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

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

limitations, can adequately characterize TRU wastes and comply with the regulatory 

requirements imposed on TRU wastes destined for disposal at the WIPP. 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, EPA’s inspection team verifies compliance 

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

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

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

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

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

limiting value described in the introductory text of paragraph 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 replaced the term process knowledge with acceptable 

knowledge. Acceptable knowledge refers to any information about the process used to generate waste, material 

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

analysis of waste conducted prior to or separate from the waste certification process authorized by an EPA 

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

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 shall specify the limiting value (expressed as an upper or lower 

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

limiting value, of the total inventory of such waste proposed for disposal in the disposal system.” 
5 

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

schemes used; and other documentation. 

In other words, the purpose of the baseline inspection is to implement the requirements of 

40 CFR 194 by assessing whether DOE sites that characterize 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 baseline inspection or to seek further 

clarification/discussion related to WC processes evaluated during a baseline inspection. By 

approving the CCP-implemented WC systems and processes at GEVNC-CCP for RH debris 

waste, EPA confirms that the Agency has evaluated the 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 tracked 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 evaluated during the baseline inspection, EPA is 

authorized to evaluate and approve, if necessary, changes to the site’s approved WC program by 

conducting additional inspections under the authority of 40 CFR 194.24(h). Under 

40 CFR 194.24, EPA has the authority to conduct continued compliance inspections to verify 

that the site continues to use only the approved WC processes to characterize the waste and 

remains in compliance with all regulatory requirements. Based on the adequacies of the WC 

processes demonstrated during the baseline inspection, including all conditions and limitations, 

EPA will specify which subsequent WC program changes or modifications must undergo further 

EPA inspection or approval under 40 CFR 194.24. EPA accomplishes this by assigning a tier 

level to selected aspects of the characterization program, as described below. 

T1 activities have more stringent reporting requirements 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 inspection report. DOE may choose to 

characterize and dispose of materials at its own risk while EPA considers the proposed T2 

changes. EPA does not expect CCP to require any changes 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 can 

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

select the matrix-appropriate radiological characterization 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, characterization 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 streams 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 for all WC systems 

• Identifies all relevant system limitations and/or conditions 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 concerns, as applicable, including their 

resolution and status 

The listings in each section reference the documents 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-CCP 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 accordance 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 characterize RH Waste Stream 

GEVNC.01. The EPA inspection team evaluated these systems with respect to their ability to 

perform the following functions: 

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

238Pu, 239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U, and 238U) and other TRU radionuclides using a 

combination of AK and DTC with the application of radionuclide scaling factors 

• Assign waste material parameters (WMPs) correctly using 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 wastes was technical evaluation of AK, DTC, 

VE, and WWIS, including the identification and quantification 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 measurement of the external dose rate 

of RH TRU debris waste, supported by the application 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 characterization 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 practices controlled by site procedures, and 

inspecting records related to each of the WC processes within the inspection’s scope. An 

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

the WC processes. Objective evidence typically takes the form of batch data reports (BDRs), 

Radioassay Data Sheets, AK accuracy reports, VET records 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 variety of items each WC process produced, 

consistent with standard auditing techniques. Because 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 determined 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 affect 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 magnitude 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 contacted 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, experimental critical facilities, hot cells, 

laboratories and engineering facilities, all of which have supported a variety of nuclear research 

for the U.S. Navy and DOE since the 1950s. The range 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 Hot Cell 4 in Building 102 was also used to 

manufacture Californium-252 (252Cf) and Americium-Beryllium (Am-Be) neutron sources. DOE 
9 

plans to decontaminate Hot Cell 4 and use it for commercial 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 for 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, and other technical information related 

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

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

above 

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

(4) Evaluating GEVNC-CCP’s implementation of WC processes for adequacy and 

demonstrating compliance with 40 CFR 194.24 requirements 

(5) Conducting the baseline inspection at GEVNC to verify the technical adequacy and/or 

qualifications of RH WC personnel, procedures, processes, and equipment 

(6) Recording five concerns and one finding on EPA Inspection 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 copy 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 were 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 application of DTC) 

• VE 

• WWIS 
10 

8.1 Acceptable Knowledge 

EPA examined the AK process and associated information to determine whether GEVNC-CCP 

demonstrated compliance with 40 CFR 194.8 requirements for RH waste stream GEVNC.01. 

WC Element Description

As part of the inspection, EPA reviewed the following 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), spent nuclear fuel (SNF) 

• Role of AK in the characterization methodology, including use of AK to support scaling 

factors derived by GEVNC-CCP 

• Adequacy of Waste Characterization Program Implementation 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 qualification 

• Confirmatory Test Plan (CTP) preparation and plan adequacy 

• Characterization Reconciliation Report (CRR) preparation and plan adequacy 

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

• Personnel training and qualifications 

• Non Conformance Reports (NCRs) and AK discrepancy resolution 

• AK accuracy 

• Plans for load management 

• Identification of the method for determining DQOs and DQOs attained through AK 

Qualification 

Documents Provided

The following documents were provided for review: 

• CS-OP-PN-015, Sampling and Analysis Plan GE Vallecitos Nuclear Center Hot Cell 

No. 4, Revision 0, Project No 13706, Effective Date May 30, 2008 

• CCP-AK-GEV-500, Central Characterization Project Acceptable Knowledge Summary 

Report For General Electric Vallecitos Nuclear Center Waste Stream: GEVNC.01 – Hot 

Cell Debris Waste, Revision 1, October 28, 2008 
11 

• CCP-AK-GEV-501, Central Characterization Project Remote-Handled Transuranic 

Radiological Characterization Technical Report For Remote-Handled Transuranic Debris 

Waste from the General Electric Vallecitos Nuclear Center (GEVNC) Revision 0, 

October 30, 2008 

• CCP-AK-GEV-502, Central Characterization Project Remote-Handled Transuranic 

Waste Certification Plan For 40 CFR Part 194 Compliance 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 Documentation 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 Stream 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 Electric Vallecitos Nuclear Center, 

Waste Stream Number GEVNC.01 Lot 1, Revision 2, December 4, 2008 

• Acceptable Knowledge Source Document Discrepancy Resolution for Waste Stream 

GEVCN.01, Hot Cell Debris Waste, EPA Hazardous Waste Number Revisions, 

K. Peters, December 3, 2008 

• CCP-TP-506, Revision 2, Preparation of the Remote-Handled Transuranic Waste 

Acceptable Knowledge Characterization Reconciliation Report, Effective Date: June 8, 

2008 

• C011, Memorandum to Frank Marcinowski from W. M. Rose, RE: Defense 

Determination, GE Vallecitos, March 27, 2005 

• NMED Waste Stream Profile Form for GEVNC.01, provided 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. GE003, GE004, GE007, GE008, 

GE009 and GE010 

• Interoffice Correspondence, from R.J. Walker to Records, Acceptable Knowledge 

Accuracy Evaluation for Waste Containers in Waste Stream GEVCN.01, December 1, 

2008, (NMED) Revised December 3, 2008 

• Interoffice Correspondence, from C. Gomez to M. Sensibaugh, Acceptable Knowledge 

Accuracy Evaluation for Waste Containers in Waste Stream 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, November 13, 2008 
12 

• CCP-TP-005, Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, 

and Packaging, General Electric Vallecitos Nuclear Center, and related WMP Calculation 

Memorandum, August, 2008 

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

2008 

• Headspace Gas Summary Report for GEVNC.01, Lot 1 Containers 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 Memorandum for Lot 1 of 

Containers of Waste Stream GEVCN.01 Characterized by the Central Characterization 

Project at General Electric Vallecitos Nuclear Center, October 29, 2008 

• CCP-TP-005, Revision 18 CCP Waste Stream Characterization Checklist, undated, 

provided December 1, 2008 

• CCP-TP-005, Attachment 8 Waste Containers November 19, 2008; this includes 16 

containers, however container Nos. 01, 02, and 05 may be removed since their assay 

values are expected to be less than 100 nCi/g 

• CCP-TP-005, Attachment 1, Acceptable Knowledge Documentation Checklist, GE 

Vallecitos Nuclear Corporation, GEVNC.01 Waste Stream 

• CCP-TP-005, Revision 18, Acceptable Knowledge Source Document Reference List, 

November 19, 2008 

• CCP-TP-500, Revision 8, Attachment 3 Visual Examination 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 13, 2008 

• NCR GEVNC-0500-08, Uncertainty calculation on the GEVNC Dose-to-Curie 

spreadsheet contained a mathematical error 

• Transmittal of Completed Chain of Custody Forms, CHWM 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 17, 2008 

• CCP-TP-504, Revision 7, Attachment 8, SPM Checklist BDRGEVRHDTC08002, 

includes Container Nos. GE009 and GE0010, November 17, 2008 

• BDR No. GEHSGS08001 Containers GE001-010, HSG Summa Sampling Project Level 

Validation Checklist and Summary, CCP-TP-001 Revision 17, Attachment 10, 

November 1, 2008 
13 

• 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 Doherty Attachment 2, May 8, 2008 

• C013, Interview by Mark Doherty of Stan Lukezic, Hot Cell Operator Re: GEVNC Hot 

Cell Operations Information, Mark Doherty, Attachment 3, May 10, 2008 

• C020, Correspondence to T.W. Darmitzel from Jo Cullen, RE: Decontamination and 

Decommissioning Activities at GE, January 9, 1991 

• C024, Correspondence from Mike Dammann to Rodney Melgard, RE: Request for 

Service and Price Quotation, authored by Melissa Mannion, July 29, 2008 

• C025, Correspondence from Melissa Mannion to Steve Croslin, RE: Purchase Order No 

PO-004366 EAC R806140-3773 and R806141-3774, Radiochemistry Report for 20 

Smear Samples, September 18, 2008 

• DR001, Use of Paint Products in Hot Cell 4, K. Peters, 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, November 8, 1999 

• M006, Chemical Inventory for WEP, RHO Cribb, RHO Controlled Area, RHO Shop 

Area and Electric Shop, undated 

• M007, Memo to file from Mark Doherty Re: Calculation 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 Main Floor-Radioactive Materials 

Area Diagram, undated 

• M015, Container Certification No 1080, US DOT 7A Type 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 Solutions 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 Company to Energy Solutions, 

43701177, C. Suggs, March 25, 2008 
14 

• M021, Hot Cell 4 Smear Sample Log- Eberline Analysis, 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 of existing beta-gamma hot cell to 

an alpha-gamma hot cell, operation of the Cell 4 interlock, and procedure for chemical 

plutonium separation and transfer from Alpha Cell to N.L. Building 103, 1965-1972 

• P013, Cell 4 Standard Operating Procedures and Cs-137 Procedure 

• P015, Radioactive Waste Shipments to Hanford Retrievable Storage from the General 

Electric Vallecitos Nuclear Center, Pleasanton, California, E. J. Vejvoda, J. A. Pottmeyer, 

D. S. DeLorenzo, M. I. Weyns-Rollosson, D. R. Duncan, WHC-EP-0672 N/A, October 

1993 

• P016, File Drawer Cell 4: Flanders Alpha Cell PB-1401-1003, Operating Experience of 

G.E. Alpha Cell, Conversion of a Beta-Gamma Hot Cell 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. Corrigan, N. C. Howard, and G. L. 

Stimmell; J. E. Corrigan, 2003, 1969 and November 1966 

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

• P033 REDACTED Operations Change Notice; Section D. Part 1. Failed Low 

Enrichment Fuel Rods, Bonnie Streitz; J. A. Cook, Serial 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 (GEVNC) 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, Eberline, Rodney Melgard, July 31, 

2007 

• P050, Quality Assurance Procedures Manual, QAP, Eberline, Rodney Melgard, 

October 25, 2007 
15 

• P051, Quality Control Laboratory Procedures Manual, QCL, Eberline, Katsumi 

Yamamoto, April 16, 2008 

• P052, Section E, Part 2, REDACTED NaK Filling Procedure, 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, December 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 Detailed 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 Samples, RP-966, January 10, 2008 

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

• P079, Energy Solutions Work Plan Decontamination and 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 Project, TRU Waste Removal Work 

Instruction (Project No.137076), CS-WM-WI-005, Energy Solutions, LLC, October 2, 

2008 

• P099, Eberline Services Inc., Richmond Laboratory Internal Audit Report, Anthony W. 

Toth, November 30, 2007 

• P100, Vallecitos Nuclear Center Alpha Cell 4 Decontamination 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, Richard E. Campbell, May 31, 2007 

• P102, Quality Assurance Program for Vallecitos Operations 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 Sample ID 3774, Ebelrine, 

January 14, 2008 

• U006, RP&S Materials Hazard Control 

• U009, Logbook RML-575, 1971 to 1975 
16 

• 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 Examination 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 Detailed Work Plan No. 5 - 

Nondestructive Examination; HEDL Vendor Fuel Irradiation 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 Factor Development, J. Vance, 

November 19, 2008 

• U046, CCP Calculation Package - Fission Product Contribution to Total Dose Rate, 

J. Vance, November 19, 2008 

• U047, CCP Calculation Package- Determination of Reportable Isotopes, J. Vance, 

November 19, 2008 
17 

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 specific 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 definition were examined for Stream CCPAK-GEV-500 and were found to be adequate. 

The inspection scope was evaluation of AK documentation specific to a single newly-generated 

debris RH waste stream GEVNC.01. The AK Summary (CCP-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 cell equipment, tools, and support materials 

such as wipes and bottles that will be generated during 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 activity is expected to be generated 

requiring WIPP disposal. 

(2) The Correlation and Surrogate Summary Form (CSSF) process was evaluated and was 

found to be adequate. 

GEVNC-CCP indicated that a CSSF had not been prepared. 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 TRU waste stream AK 

information to meet the required DQOs. Such correlations must be documented 

on the Correlation and Surrogate Summary Form (Attachment 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 Laboratory (INL) for full characterization and 

disposal as a CH waste stream. EPA must be notified of the characterization and disposal of 

GEVNC CH waste containers by INL-CCP. It is expected that this information will provide 
18 

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 to be adequate. 

The waste included in this waste stream was described by GEVNC-CCP representatives as 

“newly generated.” Therefore, traceability of containers with respect to original packaging 

receipts could not be performed. BDRs were provided, 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 generated during the 

decontamination of Hot Cell 4 contaminated during the examination of irradiated 

fuel materials. These operations did not involve separation or reprocessing of 

constituent elements from reactor fuel and the waste 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 eligible 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 the following: 

According to the NWPA, spent nuclear fuel is “fuel that has been withdrawn from 

a nuclear reactor following irradiation, the constituent elements of which have 

not been separated by reprocessing.” The DOE Radioactive 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 to separate the remaining test 

specimens from other contaminated material. 

GEVNC-CCP stated that while fuel pins are removed, these are test specimens and waste 

associated with these fuel pins may be classified as TRU wastes. The AK Summary also states: 

High-level waste is defined by the NWPA as “the highly radioactive material 

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

produced directly in reprocessing and any solid material derived from such liquid 
19 

waste that contains fission products in sufficient concentrations, and other highly 

radioactive material that the Commission, consistent with existing law, 

determines by rule requires permanent isolation”. Waste Stream GEVNC.01 

consists of debris generated during the decontamination of Hot Cell 4 

contaminated during the examination of irradiated fuel materials...and did not 

involve separation or reprocessing of constituent elements from reactor fuel.

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

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

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

Cell 4” and that Hot Cell 4 contained radioactive contamination from the manufacturing of 

sources for Knolls Atomic Power Laboratory and the Naval Sea System Command. GEVNCCCP also states that ceramic pellets containing 239Pu were manufactured for the Lawrence 

Livermore SYNROC-D research program. GEVNC-CCP then concludes that while the majority 

of work performed in Hot Cell 4 was non-defense related, 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 place, GEVNC-CCP concludes that all waste is 

potentially contaminated with defense-related radionuclides and is therefore eligible for disposal 

at WIPP. 

(6) Sufficiency of the Acceptable Knowledge Summary Report (AKSR) was evaluated and 

found to be adequate, as was implementation of AK as required in Attachment A of the 

WCPIP. 

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

several technical and editorial modifications to the AKSR were required to meet these criteria. 

This concern was discussed with GEVNC-CCP AK personnel, 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 this concern are addressed separately: the 

Confirmation Test Plan (CTP) is discussed under section (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 editorial 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 activities presented on pages 8-9 of the AK 

Summary, and correlation of these activities (through 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 will 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 were made to the waste stream volume 

and radionuclide scaling factors, including the text and tables. 

• Information in the text of the AK Summary pertaining to the Q-tip smears obtained in 

1982, including the specific analysis and information provided by the activity, is 

insufficient. This is important because the Sampling and Analysis Plan (SAP) apparently 

uses this information as the basis for developing specific aspects. 

• The radionuclide discussion in Section 5 does not adequately address generalized waste 

composition. Of particular importance are changes in activities/potential radiological 

contamination pre-post 1978 (i.e., MOX prior with exceptions, sources post, with 

exceptions). GEVNC-CCP did not prepare a radiological analysis or table to accompany 

their own time line that may help make these changes. 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 reflect modified radionuclide 

scaling factors. 

• The prohibited item discussion in Section 5.4.12 does not include an updated and 

thorough SNF analysis. 

• Table 6 is unclear regarding the quantification methods 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 included. 

• 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 AKSR. The initial response for Bullets 6 and 

10 did not sufficiently address EPA’s concern. However, 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 revised 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 information 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 reasons for revisions are clearly explained. In the 

future, EPA expects GEVNC-CCP to develop a methodology whereby changes to references are 

readily apparent on the reference list (e.g., by listing revision numbers), and any changes to titles 

of references should also include a way to determine the reference’s previous title. 

Status of Concern: This concern is closed. 
21 

Revisions to the AK Summary CCP-AK-GEV-500 are T2 changes, including changes to the 

associated Reference List (e.g., Attachment 2, Appendix A, WCPIP). 

(7) Sufficiency of AK Support Documents, including the Sampling and Analysis Plan GE 

Vallecitos Nuclear Center Hot Cell 4, Revision 0, and related document tracking were 

evaluated and were found to be adequate. 

EPA examined several supporting documents, specifically 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-501 radiological characterization 

document. With respect to the SAPs, EPA found that there were several inconsistencies 

throughout the documentation pertaining to the number of samples collected, types of samples 

obtained, etc. During interviews with GEVNC and GEVNC-CCP representatives, it became 

clear that there was some confusion regarding the number of swipe samples initially slated for 

collection versus the ultimate number of samples that were actually collected, and the number of 

Quality Control (QC) samples. GEVNC-CCP did not provide a document that addressed the 

results of the sampling process (i.e., a sampling report), in which any field changes or 

modifications to the proposed plan must be presented and explained, and results of the sampling 

plan implementation discussed. This concern was discussed with GEVNC-CCP AK personnel, 

and EPA included it on an EPA Inspection Issue Tracking 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, Final: The Energy Solutions SAP 

for GE Vallecitos Nuclear Center Hot Cell 4 provides the Energy Solutions proposed 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 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 as it was implemented, including final 

sample locations, corresponding sample numbers, and location of field duplicates and associated 

sample identifiers. Needed information includes whether 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 discussions in CCP-AK-GEV-500 and 501 to be 

internally consistent and to reflect the results provided. 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 the sampling and analysis effort, providing infield modifications to the program and clarification pertaining to sample collection locations, 

sample numbers, etc. In summary, reference M023 clarifies that eleven samples and one 

duplicate (for a total of 12 samples) were collected; this number included an additional smear 

sample that was collected in-field to ensure that sufficient samples were available in case of 

sample damage or loss. In addition to these 12 samples, nine more samples were collected for 

“radiological protection purposes and analyzed by gamma spectroscopy”. These nine sample 

results were “not used for DOE waste characterization purposes”. No irregularities were noted 

with respect to the set of 12 smears collected for WIPP characterization purposes. As a result of 
22 

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-501, 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 includes 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 Form (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 materials in which the “RH TRU 

materials embedded in...other solid material may require 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 require this consideration. 

• The WCPIP requires that the SAP be submitted to CBFO for review and approval. 

Please provide evidence of the review and approval.

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

• 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 that 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 was 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 adequacy of the sampling and analysis data 

(i.e., representativeness) as opposed to strict compliance with the WIPP. See the 

discussion under the third bullet, below. 

• GEVNC-CCP personnel stated that because hot cell contamination is the result of 

destructive examination of fuel or fuel specimens on waste surfaces, all material in the 

waste stream would be contaminated from the same processes. Accordingly, radioactive 

materials embedded in the waste items would have the same isotopic ratios as any 

removable (surface) contamination. 

 
23 

• GEVNC-CCP personnel acknowledged that the SAP was not 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 wastes are visible and also are stored 

“below cell deck”, and the sampling plan must collect information representative of all 

waste in the cell, irrespective of its location. GEVNC-CCP personnel demonstrated that 

available data supported their contention that wastes above and below deck are equivalent 

with respect to the waste material parameters assumed for the waste stream as a whole 

and that there are no data to suggest otherwise. The 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 decommissioned 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 evaluated 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 compliance with the WCPIP. Like the CBFO CH 

Waste Acceptance Criteria (CH WAC), in the WCPIP, CBFO 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 implemented 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 processes and activities, implementation of 

WCPIP requirements in the context of actual waste characterization does not always address 

EPA requirements as specified in or related to the Compliance Certification Application and 

subsequent Recertification Application(s). While CBFO has revised the WCPIP, the revisions 

did not address the above needs, or the examples cited below: 

• For Performance Assessment (PA) purposes, DOE has committed to assessing 10 

radionuclides, and these radionuclides are therefore 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 basis for all characterization processes, 

but uses circular logic and references for AK qualification 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 the purpose of communicating 

specifically how CBFO intends to characterize the waste stream (i.e. DTC, VE). 

However, the WCPIP states that this information should be included in a certification 

plan that has proven to be an inappropriate location for the information. EPA expected a 
24 

clear and concise communication of the intended characterization 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 characterization 

information. However, this requirement is not necessarily 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 identified as the primary characterization 

methodology, but the intent of the comparison is not 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 the WCPIP (see Docket No. EPA-HQ-OAR2008-0820). Given the RH waste characterization experience of the last three years, it would be 

prudent to revise the proposed characterization approaches and update the WCPIP to either 

specify additional approaches or allow a more performance-based regulatory compliance 

demonstration. The EPA concern addressed to CBFO reflected 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 issues is pending. CBFO must revise the WCPIP 

to address the above concern before seeking EPA approval of RH waste characterization 

programs at other RH sites. 

(9) Content and technical adequacy of the CTP were evaluated and, upon modification, 

found to be adequate. 

The purpose of the CTP is to describe the characterization approach to be used for this GEVNC 

RH waste stream. The CTP states that radiological parameters will be determined by DTC using 

137Cs as the key gamma-emitting radionuclide and scaling factors for other radionuclides will be 

based on the results of radionuclide analyses of smear samples. As indicated in (7), above, the 

smear samples are considered to be AK, and GEVNC CCP qualified the data for use by the 

equivalent QA qualification approach. GEVNC-CCP also stated that physical waste form will be 

met using VE (see Section 8.3), and will be performed on the waste stream using “an approved 

VE procedure as it is being packaged”. The waste stream 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 methods 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, as in the case of physical form/liquid 

identification. EPA understands the characterization 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 Inspection Issue Tracking Form (see Attachment 

B.1 of this report for a copy of this form), as discussed below. Please note that the issue related 

to the CTP is one of the several items in this concern, 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 editorial modifications to correct errors and/or to 

clarify information. These modifications include the CTP, which states on page 12 that 

performance of additional swipe sample collection efforts 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 CCP-AK-GEV 500, 

not CCP-AK-GEV-502, to state that no additional samples will be collected. Since the CTP is 

written in “future tense” it is appropriate to clarify this question within CCP-AK-GEV-500. 

EPA understands that no clarification of the CTP-provided 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 revises the WCPIP to reflect actual RH waste 

characterization activities implemented at different 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 evaluated and was found to be generally 

compliant with the current WCPIP. 

Requirements set forth in CCP-TP-506, Revision 1, CCP Preparation of the Remote-Handled 

Transuranic Waste Acceptable Knowledge Characterization Reconciliation Report (CRR), were 

evaluated against the CRR to ensure that all required elements are presented. Mandatory check 

fields were included in the report. The CRR includes 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 data that address each DQO is vague and is 

bordering on insufficient. The CRR also did not include the signature of the Site Project 

Manager (SPM), and did not include the required table of contents. The SPM signature and table 

of contents were rectified during the inspection, but 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 DQOs. 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 the 10 WIPP-tracked radionuclides in the 

analysis, because characterization of these radionuclides is paramount to the EPA performance 

assessment (PA). EPA expects that this oversight will be rectified when CBFO revises the 

WCPIP as mentioned above. 

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

Personnel involved with the AK portion of the inspection were Mark Doherty (AKE), Irene 

Gallegos (SPM), Kevin Peters (AKE), Sherry Nance (AKE), Sheila Piercy (document 

coordination), and Hillari Neely (SPM). Of these, Qualification Cards and Job-Specific Training 

records for Mark Doherty and Kevin Peters were examined. The WCPIP specifies that AK 

personnel responsible for compiling AK, characterizing RH TRU waste streams using the AK 

process, and assessing the AK characterization shall 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 containers 

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

individual containers was not included in the listed training programs. During the inspection, it 

was ascertained that Jene Vance performed the radiological assessment required by the WCPIP. 

While this approach appeared appropriate during initial EPA RH inspections, this has resulted in 

less radiological characterization information being included in the related CCP-AK-500 

document to the point that the AK Summary has required 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 composition of the waste is necessary [see 

(12), below]. EPA expects GEVNC-CCP to address container-specific radiological training for 

all AKEs. EPA does not expect GEVNC CCP to revise training 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 information. 

EPA had expressed concern about the level of detail in the AKSR regarding the radiological 

composition of the waste. EPA’s concerns were as follows [see (7), above]: 

• The radionuclide discussion in Section 5 does not adequately address generalized waste 

composition. Of particular importance are changes in activities/potential radiological 

contamination pre-post 1978 (i.e., MOX prior with exceptions, sources post, with 

exceptions). GEVNC-CCP did not prepare a radiological analysis or table to accompany 

their own time line that may help make these changes. 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 reflect 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 cell was made based on 11 S-tip smears (swipe 

samples) collected in July and November of 1982. Analysis of the smear samples identified 

137Cs, 124Cs, 60Co, 106Ru, 125Sb, 144Ce, 154Eu, and 95Zr. These radionuclides served as the basis 

for the 2008 sampling and analysis performed to acquire information DTC measurements [see 

(7), above]. Reference C007 presents values for each 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 reactor histories were 

introduced into Hot Cell 4 over its operating lifetime...[so] there is no definitive 

information that is available to estimate the amounts and concentrations of the 

various radioactive materials introduced into the hot 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 contamination... 

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

which inferred that different materials were handled 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 updated and modified scaling factors. These 

scaling factors are: 

Radionuclide Scaling Factor

238Pu 1.13E-02 

239Pu 7.88E-02 

240Pu 3.67E-02 

241Pu 4.25E-01 

242Pu 2.17E-05 

241Am 9.45E-01 

233U 6.14E-07 

234U 1.518E-04 

238U 2.77E-06 

137Cs 1.00E+00 

90Sr 3.00E-01 

235U 5.45E-06 

236U 2.52E-06 

137mBa 3.00E-01 

90Y 3.00E-01 

Of these, 137mBa and 90Y are not included in CCP-AK-GE-501 Revision 2, because of their 

relatively short half-lives (reference M023). 

GEVNC-CCP addressed EPA’s concerns, but did not provide relative time differentiation of 

waste management activities in Hot Cell 4 as discussed during the inspection and as requested in 

EPA’s concern. Inclusion of a generalized compositional range of MOX fuel managed in the 

cells, as well as additional information pertaining to 241Am and 252Cf, 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 distribution for all waste. EPA has observed this at 

other RH TRU sites (See Docket No. A-98-49, II-A4-99); if this were to occur at GEVNC, both 
28 

CCP-AK-GE-500 and CCP-AK-GEV-501 would require revision. Because GEVNC-CCP 

provides AK-related radiological information in CCP-AK-GE-501, notifications of updates and 

revisions to this document are considered T2 changes. 

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

waste stream volume estimate is about 12.5 m3

, 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 knowledge about the weight of waste materials 

from other sites. GEVNC-CCP expects the waste to be composed primarily of organic (27%) 

and inorganic (73%) debris. It should be noted that 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 anticipated WMP distribution as the waste is 

removed and visually examined. Revision of reference M007 is a T2 change, as this 

memorandum documents the calculation of waste material 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 the 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 EPA (DR001, dated December 4, 2008). 

DRFs must be provided to EPA as a T2 change. 

Data limitations are included as a line item on Attachment 5 of the WCPIP Appendix A, and this 

is included as a cover page to every source document. 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 the discovery of a mathematical error 

associated with the DTC calculations. 

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

A draft WSPF was provided during the inspection. It is noted that this form was for “audit 

purposes only”, and it will be revised and finalized 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 GEVNC-CCP has elected to generate two 

WSPFs, one that they believe focuses on EPA requirements or requirements of the WCPIP, and a 

second that complies with the WAP (i.e., contains the 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. GEVNC-CCP should consider combining 

the two forms in the future, as a majority of the required information is common to each. 

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

Upon evaluation of AK accuracy, EPA identified a concern. This concern was discussed with 
29 

GEVNC-CCP AK personnel, 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 

the issue related to AK accuracy is one of the several 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 modifications 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 compilation for the waste stream is complete and 

the required AK accuracy report is therefore incorporated into CCP-AK-GEV-502. This is not 

correct, as the waste stream contains only six characterized containers. 

Concern Response: GEVNC-CCP responded to this concern by modifying the AK Summary 

during the inspection to ensure that the appropriate number of containers was included in the AK 

Accuracy Report. This approach required multiple iterations. 

Status of Concern: This concern is closed. 

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

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

GEVNC-CCP representatives were questioned whether any containers generated during 

repackaging would contain less than 100 nCi/g of TRU radionuclides. GEVNC-CCP indicated 

that if any containers were identified that contained 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 GEVNC.01. 

(17) Attainment of DQOs through AK verification was evaluated 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 must be addressed per the WCPIP: 

 

• Defense determination 

• TRU waste determination 

• RH waste determination 

• Activity determination (TRU Alpha Activity per canister, including quantification and 

identification of the EPA 10 WIPP-tracked radionuclides) 

• 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 as 
30 

determined by AK is verified through direct measurement of the container’s surface dose rate 

and the TRU alpha activity is determined by AK-derived isotopics (qualified by equivalent QA), 

and direct DTC measurements. The CTP states that residual 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 intent of the WCPIP. 

Summary of AK Findings and Concerns

The EPA inspection team identified three concerns related to AK, which are discussed above. 

Please note that for logistical reasons, one concern is discussed in three sections above. Copies 

of the EPA Inspection Tracking Forms are included in Attachments B.1 through B.3. EPA 

considers all aspects of these concerns to have been adequately addressed, and there are no open 

findings or concerns related to AK resulting from this inspection. 

Baseline Approval

EPA is proposing to approve the AK process evaluated 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 during 2008-2009, as defined in CCP-AK-GEV500, Revision 2. 

AK Tiers

T1 AK changes are not identified for this approval. Once the subject debris waste stream is 

characterized and disposed of at WIPP, GEVNC-CCP will 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 parentheses: 

• Availability of the CSSF (2) 

• Revisions to the AK Summary CCP-AK-GEV-500, including changes to the associated 

Reference List (6) 

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

• Revision of reference M007, as this memorandum documents the calculation of waste 

material parameters (12) 

• Availability of additional discrepancy resolutions (13) 

• Notification of availability of the final WSPF and related 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 concerning T2 changes 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 information relative to these changes if EPA deems the 

information is necessary to ensure compliance with EPA regulations. 

8.2 Radiological Characterization 

During radiological characterization (RC) inspection, EPA inspected one Dose-to-Curie (DTC) 

measurement system located on site at GEVNC, supported by the development of radionuclidespecific scaling factors. 

Overview of GEVNC RH Waste

Waste Stream GEVNCR.01 consists of heterogeneous debris wastes containing mixtures of 

radionuclides from the hot cell operations and analytical 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 amounts of 137Cs to produce RH dose rates, i.e., 

in excess of 200 mRem/hr, however some wastes may ultimately be deemed CH TRU or nonTRU (low level waste or LLW), based on the characterization results. Typical hot cell activities 

have included MOX fuel rod development; PIE of various types of fuel; and the manufacturing 

of 252Cf 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 cell was initiated and completed in May 2008 

and the analytical data produced by this effort were 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 with 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 external radiation fields in excess of 200 millirem 

per hour (mrem/hr), RH TRU waste containers typically contain concentrations of energetic 

photon emitters, i.e., 137Cs, 60Co, 152Eu, and 154Eu, that prevent a meaningful measurement-based 

isotopic determination.4

 Accordingly, RH radiological characterization relies on alternate 

methods, such as the development of scaling factors that correlate an easily measured parameter 

like a waste container’s external exposure (dose) rate with isotopic distributions for specific TRU 

radionuclides. The development of radionuclide scaling factors at GEVNC-CCP is comparable 

to what EPA has evaluated and approved in previous RH baseline inspections.

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

information: 

 

4

 There are other gamma-emitting fission and activation products with shorter half-lives that typically decay 

sufficiently to allow their contribution to a container’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 and the waste generating activities. This 

information is essentially the same as what is presented 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 combination with the results of 

MicroShield® modeling to develop the fractional contribution of radionuclides other than 

137Cs 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 supported by the program’s documents, procedures, 

and controls, and the knowledge and understanding of the personnel involved in the RH WC 

program. During this RH inspection, the EPA inspection team evaluated the following elements 

of the GEVNC-CCP radiological characterization program: 

• External gamma measurements made at GEVNC 

• Development of a DTC correlation as a function of waste density using MicroShield® 

based on each drum’s measured external exposure (dose) rate, assuming the main 

contributor to the external exposure was 137Cs 

• Derivation of radionuclide scaling factors for the WIPP-tracked radionuclides using 

analysis of swipe samples collected in Hot Cell 4 in 2008 

Documents Reviewed

The list provided below includes all documents related to the ORNL-CCP RH radiological 

characterization program that were evaluated to support this inspection: 

• CCP-AK-GEVNC-501, Central Characterization Project Remote-Handled Radiological 

Characterization Technical Report For Remote-Handled Transuranic Debris Waste From 

the General Electric Vallecitos Nuclear Center (GEVNC); Revision 0, October 30, 2008 

and Revision 1, January 23, 2009 

• CCP-AK-GEV-500, Central Characterization Project Acceptable Knowledge Summary 

Report For General Electric Vallecitos Nuclear Center; Waste Stream: GEVNC.01 – Hot 

Cell Debris; Revision 1, October 28, 2008 and Revision 2, January 8, 2009 

• CCP-AK-GEV-502, Central Characterization Project RH TRU Waste Certification Plan 

for 40 CFR Part 194 Compliance and Confirmation Test 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 Procedure for Remote-Handled 

Transuranic Waste; February 6, 2008 

• DTC BDR Nos. GEVRHDTC08001, GEVRRHDTC08002, and GEVRRHDTC08003 

• AK Accuracy Report, December 1, 2008 

• WSPF, Draft 
33 

• 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, Revision 1 

• Compact disk (CD) containing radiochemical data reports and supporting information 

from Eberline provided during the inspection 

Technical Evaluation

The EPA inspection team evaluated the following aspects: 

(1) The technical adequacy and documentation of the correlation of the GEVNC radionuclide 

inventory values to the 137Cs concentrations were evaluated and were found to be 

adequate. 

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

137Cs scaling factors relate to the inventory values of the radionuclides of interest, i.e., the 10 

WIPP-Tracked radionuclides. This concept is appropriate for co-located wastes provided that 

additional processing or other events have not selectively isolated specific radionuclides. This is 

addressed in subsequent parts of this section, below. 

There were no concerns regarding the technical adequacy and documentation of the correlation 

of the GEVNC radionuclide inventory values to the 137Cs 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 report. 

(2) The radiochemical data were evaluated and found to be representative and technically 

adequate to support the development of scaling factors. 

The degree to which the 11 swipe samples that were subjected to radiochemical analysis are 

representative of the wastes that were handled within Hot Cell 4 is of key importance. The 

contamination on the swipes must represent the types 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 were collected from numerous 
34 

surfaces and items within Hot Cell 4 and eleven samples were sent to Eberline Services 

Analytical Corporation for radiochemical analysis and gamma spectrometry. An aliquot of each 

of the 11 samples was sent to Southwest Research Institute (SWRI) for Inductively-Coupled 

Plasma Mass Spectrometry (ICP-MS) to determine the contributions of 233U, 234U, 235/236U, 239Pu, 

240Pu and 242Pu. 

In the course of reviewing the sample collection and analyses, the EPA inspection team 

expressed concern related to the lack of records documenting these activities. It became clear 

that the requested information, at a minimum, was not 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 supported 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. The EPA inspection team was 

unable to examine objective evidence that supported several aspects of the sample collection and 

analyses. Following the onsite inspection, the information from Eberline was reviewed and EPA 

determined that there was sufficient support to address 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 numbering. Specifically, an error in sample marking 

produced an anomalous value for uranium isotopes which, when corrected, produced a small 

change in the numerical value of radionuclide scaling 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 CCP-AK-GEV-501 and the 

calculation packages, there were no technical issues 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 technically 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 137Cs. Scaling factors were developed based on the radiochemical and MS results. The 

MS data were used for isotopics pairs that could not be resolved using alpha spectrometry, i.e., 

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

A ratio of each of these values to 137Cs was developed to derive the radionuclide-specific scaling 

factors that are listed in Table 4, below. As a check 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 handled MOX beginning in the earlier 

1960s through the late 1970s5

. This comparison is shown in CCP-AK-GEV-501, Figure 4-1. 

Apart from small discrepancies with respect to 241Am and 233U

6

, the agreement provides a check 

 

5

 Specifically, the DOE sites are the Idaho National Laboratory, Argonne National Laboratory-East and Los 

Alamos National Laboratory. 

6

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

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

on the reasonableness of using these scaling factors 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 137Cs 

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 aspects: 

• Activity values used are derived from modeling and statistical metrics that support their 

use, and the statistical metrics include mean and standard 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., 137Cs and 60Co 

• The appropriateness of the choice of physical constants and radionuclide-specific 

attributes (specific activity, physical half-life, decay heat, neutron cross-sections, photon 

transition probabilities, etc.) and the technical correctness 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 appropriate 

• 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 radionuclides to the radiological hazard7

• Shielding and other calculations supporting the scaling factors were performed using 

MicroShield ® to derive the appropriate DTC relationships as a function 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 aspects of a container’s radiological characterization. 
36 

There are no issues related to the technical adequacy or documentation of the radionuclide 

scaling factors for Waste Stream GEVNC.01. Any revision to CCP-AK-GEV-501 that requires 

CBFO approval is a T2 change. 

(4) The technical basis of the Dose-to-Curie correlation was evaluated and found to be 

technically adequate. 

 

The DTC correlation was based on the following assumptions: 

• The waste drum is full of waste 

• The radionuclides of interest are dispersed uniformly throughout the waste 

• The waste matrix is iron, which is the most representative, 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-gallon drum filled 

with RH TRU waste in terms of mR/hr for a 1-curie source of 137Cs, 152Eu, and 154Eu, shown in 

Figure 1.8

 There are no issues related to the technical adequacy or documentation of DTC for 

Waste Stream GEVNC.01. 

 

8

 This plot was developed and used for ORNL-CCP. Given 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 Density

y = 51.722x2 - 235.53x + 382.19

r

2

 = 0.9993

y = 30.261x2 - 127.25x + 181.47

r

2

 = 0.9984 y = 47.213x2

 - 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/cc

Dose 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 Density at a Distance of 1 Meter 

for GEVNC Debris Waste 

(5) Technical aspects and documentation of the radiological characterization process were 

evaluated and found to be acceptable upon modification of CCP-AK-ORNL-501. 

The technical basis for the radiological characterization process is documented in ten calculation 

packages prepared and/or reviewed by Jene Vance, Jim Holderness, Dave Moody and Larry 

Porter. These packages document development of radionuclide scaling factors, uncertainty 

analyses, the DTC correlation discussed above, and other technical aspects. These packages 

provide the technical basis for several aspects, including the following: 

• Application and verification of MicroShield®

• Evaluation of all potential contributors to a container’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 technical concerns and discrepancies with GEVNC-
38 

CCP personnel. The calculation packages documented the technical activities upon which the 

radiological characterization was based, much of which was summarized in CCP-AK-GEV-501, 

Revision 0. Several aspects of CCP-AKGEV-501, Revision 0 required clarification to accurately 

describe and support GEVNC-CCP’s approach, as did calculation packages GEVNC-RH-01 and 

GEVNC-RH-03. These were noted and discussed with GEVNC-CCP personnel during the 

inspection. EPA captured these issues on an EPA Inspection 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 the CCP report CCP-AK-GEV-501 have 

multiple technical and editorial errors. As presented during the inspection, these documents 

require revision to accurately serve as objective evidence 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 calculation packages GEVNC-RH-01 and GEVNCRH-03. The other five calculation packages discussed in (2) above were also provided in 

electronic form to address changes to the scaling factors. These revisions adequately addressed 

EPA’s issues. 

Concern Status: This issue is closed. 

There were no technical issues related to the determination and documentation of the 

radiological characterization process for GEVNC Waste Stream GEVNC.01. 

(6) The technical basis and derivation of Total Measurement 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 determination of the radiological constituents of RH 

TRU waste. The TMU determination included the contributions 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 GEVNC-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 evaluated and approved by EPA during previous 

RH inspections. There were no concerns regarding the determination of TMU and its 

documentation for waste stream GEVNC.01. 
39 

Table 5. Overall Uncertainty for GEVNC Waste at a Density of 0.3 g/cm3

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 Stream GEVNC.01 were evaluated: 

BDR Nos. GEVRHDTC08001, GEVRHDTC08002 and GEVRHDTC08003. Because there 

were only three BDRs available, EPA’s evaluation amounted to a one hundred percent sample 

for this inspection, as opposed to selecting a subset or sample from a larger population. The 

EPA inspection team verified that all three DTC BDRs 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 calculated 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 other 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 liter 
40 

• The DTC spreadsheets observed during the inspection had to be reissued following the 

inspection as a result of the changes made to the radionuclide scaling factors. The scaling 

factors used in these BDRs were incorrect, as discussed 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 official 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 definition of TRU wastes (TRU alpha activity 

with half-lives greater than 20 years at a concentration 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 evaluated 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 evaluated by EPA during this 

inspection contained dose rate values for all containers in excess of 200 mRem/hr in all cases. 

The EPA inspection team was not able to observe collection 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 described in CCP-TP-504 and CCP 

Operator Aid RH-GEVNC.001, Revision 1, dated November 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 crane (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 gamma 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 drum 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 calibrations9

. 

 

9

 One of the meters lacked the appropriate calibration tag when EPA observed it in Building 217 but 

GEVNC-CCP personnel provided objective evidence that the meter had a current calibration and the tag 

inadvertently fell off the meter. EPA personnel verified that the appropriate tag was applied during the inspection. 
41 

Based on information from GEVNC-CCP personnel, it is expected that some of the containers 

from this waste stream will not qualify as RH and will eventually be characterized as CH, based 

on the observed DTC results, and these containers would then be subject to NDA. Because there 

is no approved CH WC program at GEVNC it is not clear 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 concerns regarding the TRU and RH 

determinations for GEVNC Waste Stream GEVNC.01. 

Summary of Radiological Characterization Findings and Concerns

The EPA inspection team did not identify any findings related to radiological characterization 

and identified one concern requiring a response during the inspection related to radiological 

characterization that is discussed above. A copy of the EPA Inspection Issue Tracking Form 

recording it is provided in Attachment B.3. EPA considers this concern to have been adequately 

addressed upon submission of revisions of the calculation packages and CCP-AK-GEV-501. 

There are no open findings or concerns related to radiological characterization resulting from this 

inspection. 

Baseline Approval

EPA is proposing to approve the DTC process as described 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 approval 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 what 

has been proposed for approval will be characterized 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 require 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 concerning T2 changes no later than 4 weeks 

after the last shipment of RH waste from the site is completed. Consistent with EPA’s authority 
42 

under 194.24(h), EPA may request information relative 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, packaged 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 items 

• Determination of Primary Contents 

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

Documents, BDRs, and Objective Evidence Reviewed

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

follow the appropriate approved procedures and meet VE requirements: 

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

2008 

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

• CCP-AK-GEV-500, Revision 1, Acceptable Knowledge Summary Report for General 

Electric Vallecitos Nuclear Center, Waste Stream GEVNC.01 – Hot Cell Debris Waste, 

October 28, 2008 

• CCP-AK-GEV-502, Revision 0, CCP Remote-Handled Transuranic Waste Certification 

Plan for 40 CFR Part 194 Compliance and Confirmation Test Plan for General Electric 

Vallecitos Nuclear Center, Waste Stream GEVNC.01, October 30, 2008 

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

2008 

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

• Draft WSPF, GEVNC.01 

• DOE/WIPP 02-3214, Remote-Handled TRU Waste Characterization Program 

Implementation Plan, Revision 0D, October 30, 2003 

Following is a complete list of all objective evidence that the EPA inspection team evaluated 

during the inspection: 

• Visual Examination BDRs RHGEVE080001, RHGEVE080002, RHGEVE080003, 

RHGEVE08006 
43 

• List of currently qualified VE personnel 

• Letter appointing VEE, dated August 21, 2006, and clarification email dated 

December 04, 2008 

• Letter appointing VEE, dated January 4, 2006 

• Qualification card and training records for two VEEs 

• Qualification cards and training records for one VEO

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

Technical Evaluation

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

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

(1) Overall procedural technical adequacy and implementation were assessed and were found 

to be adequate. 

The VE procedure, documented in CCP-TP-500, Revision 8, contained specific information on 

performing VE, including identification of prohibited 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 was 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 discussed below. 

EPA Inspection Issue Tracking Form, Issue No. GEVNC-CCP-RH-VE-08-004CR, Final: 

The packaging process implemented for VE is not incorporated 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 certified” and that the waste “packaging process 

does not need to be formalized as the host site reserves the option to vary the final [waste] 

packaging configuration with CCP’s concurrence”. EPA accepted this response.

Status of Concern: This concern is closed. 

Note that a related concern was identified with respect to the characterization of WMPs and 

prohibited items, as discussed under (3), below. The EPA concern listed above incorporates both 

issues. 
44 

The EPA inspectors identified one implementation 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.6 of this report for 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 and 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 evaluated 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 took place in Hot Cell 4 in Building 102. 

An audio/visual recording of the VE event was not required 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 process. 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 both operators agreed on the identity of the 

waste and its WMP, was the item electronically entered 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 waste into a duffle bag, which served to 

keep small waste items together. The duffle bag was recorded on the data form as “poly bag”. 

The duffle bag and its contents were loaded into the 55-gallon drum at the end of the 

demonstration. The duffle bag was transferred through an access port to the interlock for Hot 

Cell 4, the bag being heat-sealed in the plastic sleeve during this transfer. After the sealed plastic 

was vented, a cradle and hoist were used to place the duffle bag into the 55-gallon drum. The 

process used for transferring waste from the hot cell into the 55-gallon drum was not included in 

the VE procedure CCP-TP-500. This concern was discussed with GEVNC-CCP AK personnel, 

and EPA included it on the EPA Inspection Issue Tracking Form listed under (1), above. 

At the time of the on-site inspection, no prohibited items had been found in the waste processed. 

None of the eighteen containers that had been through 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 that the four data packages were correctly 

completed, three being reviewed at both data generation ITR and project level (SPM) and one at 
45 

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

“steel”. 

Any change made to the VE procedure(s) that requires 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 CCP-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 found to be adequate. 

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

and only qualified individuals perform characterization activities. As part of the inspection, the 

EPA team reviewed the qualification packages for VEOs and VEEs and found that they 

demonstrated comprehensive and adequate training for VE personnel. 

The EPA inspectors reviewed the following records: 

• List of currently qualified VE personnel 

• Letter appointing VEE dated August 21, 2006, and clarification e-mail dated 

December 04, 2008 

• Letter appointing VEE dated January 4, 2006 

• Qualification card and training records for two VEEs 

• Qualification cards and training records for one VEO

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

The EPA found the training and qualification records 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 are 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 this inspection. 
46 

Baseline Approval

EPA is proposing to approve the VE system for debris waste that the EPA inspection team 

evaluated during this baseline inspection, consisting 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 form, CCP-TP-500 review 

checklists, and VE BDRs 

VE as performed by two trained operators is suitable 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 concerning 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 information relative to this change if EPA deems 

the information is necessary to ensure compliance with EPA regulations. 

8.4 WIPP Waste Information System 

WC Element Description

CCP has successfully submitted both RH and CH WC data for TRU waste containers to the 

WWIS in the past. The CCP procedures, practices, and the personnel who process container data 

that the EPA inspectors observed at GEVNC-CCP are the 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 WWIS. 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 inspectors reviewed to assess whether 

WWIS operations follow the appropriate approved procedures 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 objective evidence during the inspection: 

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

GE003 

• WWIS Data Entry Summary – Characterization and Certification for GEVNC Containers 

GE003 and GE004 

• Waste Container Data Report for Containers GE003 and 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 TRU Waste Certification and WWIS 

Data Entry, Revision 7, is well defined and controlled and contains instructions for entering, 

reviewing, and transmitting data. The WWIS data entry procedure incorporates adequate 

reviews to minimize the transmittal of noncompliant or incorrect data. The Microsoft Excel 

spreadsheet used for data entry was adequate and was 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 records for EPA review. A qualified GEVNC 

WCO demonstrated the certification process by uploading RH data into the test instance of 

WWIS. However, the usual records (emails, signed data spreadsheet, etc.) were not available for 

review. The process used for GEVNC container certification is the same as that used on other 

CCP sites, including the procedure, process and personnel. Personnel entering data into the 

WWIS can only do so after being granted access by the WWIS administrator, and access is 

password-protected. After the data have been through every level of review and approval, the 

WCA entered the data into a controlled Excel spreadsheet that had been validated in accordance 

with CCP-QP-22, Revision 10, Software Quality Assurance Plan. The control number for this 

spreadsheet is SCO 1023. All radionuclides identified 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 they are WIPP-compliant and signs the 

spreadsheet to accept the data. At this point, site personnel convert the data into ASCII format 

files and transmit them to the WWIS. The information contained in the container file is 

subsequently used for transportation activities. The WCO is also responsible for building 

canisters, which contain three certified containers. The list that informs the WCO of which 
48 

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 Certification Official (TCO). 

 

The EPA inspectors viewed demonstrations of data entry 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 internal WWIS checks were able to identify 

problem data. The WCO was able to retrieve and print requested records, including waste 

container data reports for containers GE003 and GE004. 

Any changes to WWIS procedure(s) that requires CBFO approval is a T2 change. Any change 

to the Excel spreadsheet, WWIS data entry summary—characterization and certification, is a T2 

change. 

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

The EPA inspectors observed the actual job performance of a WCA/WCO to verify training and 

qualification. Inspectors also reviewed the qualification card for a WCA (data entry personnel) 

and WCO. Required training included use of the WWIS 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 during 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 data 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 where 

each is discussed in parentheses: 
49 

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

• Changes to the Excel spreadsheet titled WWIS Data Entry Summary Characterization 

and Certification (2) 

GEVNC-CCP will provide EPA with information concerning T2 changes 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 information relative 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 Docket ID No. EPA–HQ– 

OAR–2009–0372, for actual comment. The comments and 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 changes are made. 

Comment 2: Add an exception to the T2 requirement that CH NDA 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 about 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-Coupled Plasma Mass 

Spectrometry (ICP-MS) on page 34 

EPA Response: Appropriate change has been made. 

 

10.0 SUMMARY OF RESULTS 
50 

10.1 EPA Findings and Concerns 

The one finding and four concerns requiring responses that were identified during this inspection 

related to the WC processes GEVNC-CCP implemented to 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 EPA Inspection Issue Tracking Forms that 

capture the finding and the four concerns are included in Attachments B.1 through B.5 of this 

report. The one concern that did not require a response is included in Attachment B.6. GEVNCCCP revised a number of documents to address the finding and the concerns that required 

responses and submitted them for EPA review following the initial onsite inspection. The EPA 

inspection team completed their review of the revised 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 EPA issues related to this inspection 

remain open at this time. 

10.2 Conclusions 

The scope of this approval is based on EPA’s baseline inspection conducted between 

December 2 and 4, 2008. EPA has determined that the 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 this baseline inspection, as described and 

documented in this report. The approval includes the following: 

(1) The AK process for the RH TRU debris waste stream, designated as Waste Stream 

GEVNC.01 that will be generated from decontamination 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 form of the waste. 

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

This approval is limited to RH TRU debris wastes from 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 excluded from this approval, hence no T1 changes 

are included. Since the EPA December 2008 inspection, 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. GEVNC-CCP will provide EPA with 

information concerning T2 changes 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 

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 them 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 debris containers to CCP at the Idaho 

National Laboratory (INL-CCP) for characterization as CH TRU waste from small quantity sites 

prior to disposal at WIPP. DOE must notify EPA prior to shipment of these CH TRU waste(s) to 

INL-CCP. At that time, as part of this notification, 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 drums, 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 15) 

Radiological Characterization, 

Dose-to-Curie (DTC), and the 

application 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 submission 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 Data 

Entry Summary Characterization and Certification; 

(WWIS 2) 

* All applicable T2 changes must be provided to EPA in a one-time submission following completion of the last shipment of 

GEVNC RH debris proposed for approval to WIPP for disposal 

** No additional RH waste from GEVNC will be characterized 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 Office, “Contact-Handled Transuranic Waste 

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

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

U.S. Environmental Protection Agency, “Criteria for the Certification and Recertification of the 

Waste Isolation Pilot Plant’s Compliance with the Disposal Regulations: Certification Decision; 

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

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

Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level 

and Transuranic Radioactive Wastes.” 
53 

U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 194, “Criteria for the 

Certification and Re-Certification of the Waste Isolation Pilot Plant’s Compliance with the 

40 CFR Part 191 Disposal Regulations.” 

U.S. Department of Energy, Carlsbad Area Field Office, “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, Compliance Certification Application for the 

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

U.S. Department of Energy, Title 40 CFR Part 191, SUBPART D AND C, Compliance 

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

U.S. Department of Energy, Carlsbad Area Field Office, “Quality Assurance Program Document 

(QAPD),” DOE/CBFO-94-1012, Revision 7, Carlsbad, New Mexico, July 2005. 

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

Methods for Payload Control (CH-TRAMPAC).
VE - 1 

ATTACHMENT A.1: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8 Inspection Date: December 2–4, 2008

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evidence/Comment 

RHVE-1: Site procedures identify required training and qualifications for RHVE 

personnel.

WCPIP, Rev. 0D, Sect. 4.1.2 CCP-QP-002, Rev. 27 

• Formal training elements include: 

project requirements, container 

identification and labeling, applicable state and federal regulations 

• Site-specific training program: OJT, 

identification of summary category groups, WMPs, packaging configurations, residual liquids 

Y EPA reviewed training records for both VE operators and VE 

Experts (VEEs). CCP records contained specific job training and required reading records. Site-specific training is 

provided through the required reading system and is

appropriate. VEEs are designated by SPMs and are considered qualified to perform their duties when training is completed and the individual is added to the LOQI. At the time of the inspection, there were two personnel qualified as Operator/ITR/SME/OJT and one qualified as Operator/ITR for VE at GEVNC. Objective evidence: 

1. LOQI for VE 2. Training records for two VE SME and one VE operator

RHVE-2: Operator qualification and re-qualification requirements 

are described.

WCPIP, Rev. 0D, Sect. 4.1.2 CCP-QP-002, Rev. 27, Sect. 4.2.5 

• To become qualified, the RHVE operator 

must pass a comprehensive written test 

based on training objectives with a 

minimum score of 80% 

• Demonstrate capability in the presence 

of the site VEE during OJT 

• RHVE operators re-qualified every 2 

years based on continued satisfactory 

performance 

• Unsatisfactory performance – failed to 

identify prohibited item during OJT of score of less than 80% on exam 

Y The personnel performing VE at the facility are experienced 

and have been qualified on other CCP projects. EPAreviewed training records for personnel on the LOQI and 

determined that only qualified personnel were performing 

VE. Training included required reading, examination, and OJT. Objective evidence;

1. LOQI for VE 2. Training records for two VE SME and one VE operator

(VEO) 

RHVE-3: Each site has a designated VE expert (VEE). 

WCPIP, Rev. 0D, Sect. 4.2.2 

• VEE designation is documented • VEE has knowledge of the RH TRU 

waste being characterized 

Y VEE designations are communicated by e-mail and the 

e-mails are retained as records. This e-mail states that the VEE meets the prerequisite for the position and requests initiation of training. Only after this training has been 
VE - 2 

ATTACHMENT A.1: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8 Inspection Date: December 2–4, 2008

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evidence/Comment 

CCP-PO-001, QAPjP, Rev. 16 

• Responsible for overall direction and 

implementation of VE at the facility 

• Certification Plan specifies the 

selection, qualification, and training requirements of VEE 

completed 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 VE 2. Training records for two VE SME and one VEO 

RHVE-4 • Operators review AK Tracking 

Spreadsheet to verify that correct containers examined 

• Rejected containers are placed in a 

shielded container with a CCP Hold Tag attached 

• Provide container processing information 

to SPM/VPM 

NA The process inspected was VE performed during packaging 

of waste contained in a glovebox. 

RHVE-5: Procedures and technical guidance documents 

provide complete instructions for performing RHVE. 

WCPIP, Rev. 0D, Sect. 4.1.2.1, CCP-TP-500, Rev. 8, Sect. 4.1–4.2, Attachment 1 

Procedures are sufficiently detailed to enable the operator to determine if a waste container meets the criteria of 40 194.24 with regard to identifying applicable parameters with waste 

limits [40 194.24, c, (4) – demonstrate that a system of controls has been and will continue to be implemented to confirm that the total amount of each waste component that will be emplaced in the disposal system will not exceed the upper limiting value or fall below the lower limiting value described in the introductory text of paragraph (c) of this section]. 

Y The EPA observed the packaging operations for 55-gallon 

drum GE019 in Cell 4 of Building 102. The two glovebox operators who manipulated and packaged the waste were GE employees. Two CCP VE personnel performed the actual VE, identifying and documenting the waste loaded into 

container GE019. CCP did not make an audio/visual recording of the VE event (GE did make a recording, but not for VE purposes). VEOs reviewed the AK summary sheet to verify 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 the WMPs into Attachment 1 after identification and concurrence 

between the CCP VE personnel. The identity of the waste, 

e.g., “rubber glove,” was called out by the VEE and verbally 
VE - 3 

ATTACHMENT A.1: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8 Inspection Date: December 2–4, 2008

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evidence/Comment 

• All existing VE tapes will be reviewed 

and the VE data will be documented (NA for ORNL-CCP) 

• Existing waste container packaging 

records will be qualified by VE or RTR 

• 100% of containers will be subject to VE 

at the time of packaging 

• Waste Stream Description and WMC 

verified 

• Presence/absence of prohibited items 

repeated by the VEO before it was entered into Attachment 1. Small pieces of waste were loaded into a plastic duffel bag to keep the waste together. The operators used a flashlight to 

illuminate items if they are difficult to identify. Both the 

duffle bag and waste were loaded into the 55-gallon drum. 

The duffle bag was recorded as “poly bag” on the container inventory. The process used for waste transfer out of the hot cell and into the drum was not included in the VE procedure 

CCP-TP-500. EPA generated a concern. CCP was able to confirm the waste stream description and waste matrix code. Prohibited items are not loaded into containers and are left in the glovebox for remediation. The waste was transferred through the access port to the interlock for cell 4 and heat-sealed before being placed in the container. Transfer of the waste into the container was achieved using a cradle and hoist. The heat-sealed bag was vented prior to loading. The loaded and closed container is then placed in a shielded container, which allows the container to be moved for storage. At the time of the inspection, no containers had been removed after completion of VE. The primary content was recorded as “Steel” for allcontainers in the BDRs reviewed. Objective evidence: 

1. BDRs RHGEVE080001, RHGEVE080002 and 

RHGEVE080003, RHGEVE080006 

RHVE-6 CCP-TP-500, 

Rev. 8, 

• Corrective actions are taken when 

necessary 

Y No corrective actions have been generated up to and 

including the time of the inspection. CCP personnel are 

experienced at identifying and generating corrective action 
VE - 4 

ATTACHMENT A.1: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8 Inspection Date: December 2–4, 2008

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evidence/Comment 

Sect. 2.4.2 reports due to work at other CCP sites. 

RHVE-7: Site procedure(s) require data generation and 

project level reviews of Batch 

Data Reports (BDRs). 

WCPIP, Rev. 0D, Sect. 3.5.1 CCP-TP-500, Rev. 8 

• ITR review Attachment 2 • SPM review Attachment 3 

Y EPA reviewed three BDRs during the on-site inspection. 

These BDRs were RHGEVE080001, RHGEVE080002, RHGEVE080003 and. Each BDR consisted of VE data for 

two containers. All BDRs had been reviewed by an Independent Technical Review and BDRs RHGEVE080001,

RHGEVE080003 and RHGEVE080006 had been reviewed 

by the SPM 

Objective evidence: 

1. BDRs RHGEVE080001, RHGEVE080002 and 

RHGEVE080003, RHGEVE080006 

RHVE- 8 CCP-TP-500, 

Rev. 8, Sect. 5.0 

• Lifetime/QA records – Attachments 1–5, 

Copy of NCRs 

• QA/nonpermanent records – VHS tape or 

DVD (primary and backup) 

Y Audio/visual recording was not made because two operators 

performed the VE. No NCRs had been generated at the time of the inspection. 

BDRs contained attachments as required. 

RHVE-9: Quality Assurance Objectives are defined and met. 

WCPIP, Rev. 0D, Table 2.1 40 CFR Part 194.22.b 

Data Accuracy: 194.22, b, (1): the degree to which data agree 

with an acceptable reference or true value WCPIP: maintained by requiring operators to 

pass a comprehensive test with a score of 

80% and demonstrated satisfactory 

performance for initial qualification and requalification 

Data Precision: 194.22, b, (2): a measure of the mutual 

agreement between comparable data gathered or developed under similar conditions 

Y Data Accuracy: CCP VE personnel training records include 

examination, required reading and OJT. Data Precision: Two operators agreed on waste identification and WMP before it was entered on Attachment 1, Visual Examination Data Form. 
VE - 5 

ATTACHMENT A.1: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8 Inspection Date: December 2–4, 2008

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evidence/Comment 

expressed in terms of a standard deviation WCPIP: maintained by reconciling any 

discrepancies between two operators (or operator and ITR) with regard to physical form of waste, absence of residual liquid Data Representativeness194.22, b, (3): the degree to which data 

accurately and precisely represent a characteristic of a population, a parameter, variations at a sampling point, or environmental conditions WCPIP: Contents placed in a container will 

be described on the data forms 

Data Completeness 194.22, b, (4): a measure of the amount of 

valid data obtained compared to the amount that was expectedWCPIP: relevant waste information must be 

collected and documented on a videotape and/or data form or other unalterable media Data Comparability 194.22, b, (5): a measure of the confidence 

with which one data set can be compared to another WCPIP: ensured by site meeting training 

requirements and complying with the minimum standards used to implement VE 

Data Representativeness: Two operators agreed on waste identification and WMP before it was entered on Attachment 1, Visual Examination Data Form. The waste item was called out by one operator and orally confirmed by the second operator who entered the data into the electronic data form. Data Completeness: All waste items were identified and recorded prior to loading. Small items were collected in a duffle bag, which was ultimately loaded into the 55-gallon drum. Data Comparability: CCP has a well established training 

program for VE personnel. Initial qualification for the 

operators included required reading, OJT and examination. Re-qualification takes place every 2 years. 
VE - 6 

ATTACHMENT A.1: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8 Inspection Date: December 2–4, 2008

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evidence/Comment 

RHVE-10: VE as a method to qualify AK data 

WCPIP, Rev. 0D, Sect. 4.3, 4.3.3 CCP-TP-500, Rev. 8 CCP-QP-002, Rev. 26 

194.24, c, (4) – demonstrate that a system of controls has been and will continue to be implemented to confirm that the total amount of each waste component that will be emplaced in the disposal system will not exceed the upper limiting value or fall below the lower limiting value described in the introductory text of paragraph (c) of this section If VE is used as a qualification method for AK, all of the requirements in Sections 4.3 and 4.3.3 are met: • Quality and reliability of the 

measurement control program under which the data were generated (QC samples included in the VE process) 

• Extent to which the data demonstrate the 

properties of interest (VE process 

generates data for all items in 

containers) 

• Qualification of personnel generating 

data (training records for personnel on tapes performing the original VE event if qualifying existing data) 

• Technical adequacy of the procedures 

used to generate the original data (copies of original procedures) 

Y QC for this type of VE process is limited to concurrence 

between two operators. Because this was origin packaging 

activities, other QC e.g., duplicates to assess precision, are 

not applicable. Data are subject to two levels of review by the ITR and SPM. During the demonstration, all waste items were identified, 

recorded and packaged. CCP has a well-established training program for VE 

personnel. Initial qualification for the operators included 

required reading, OJT and examination. Re-qualification takes place every 2 years. EPA inspectors reviewed the VE procedure, CCP-TP-500, R. 8 and generated the following concern requiring a response 

because final packaging instructions were not included in the procedure: 

GEVNC-CCP-RH-VE-08-004CR: The packaging process 

implemented for VE is not incorporated in a formal CCP 

procedure and is only described in the AK summary, CCPAK-GEV-500, Revision 1, Section 5.5. Incorporating the 

packaging process instructions in a formal CCP procedure is 

necessary to ensure consistency of operation. Procedure CCP-TP-500 requires the VEO to protect the waste from tampering. Because this is not performed by the VEO or other personnel, EPA generated the following concern not requiring a response: GEVNC-CCP-RH-VE-08-005C: VE Procedure CCP-TP500, 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 and is not, therefore, 
VE - 7 

ATTACHMENT A.1: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8 Inspection Date: December 2–4, 2008

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evidence/Comment 

in compliance with CCP’s written procedure whenever VE is 

performed. 
WWIS-1

 ATTACHMENT A.2: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLIST 

EPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8 Inspection Date: December 2–4, 2008

Establishment of Required 

Technical Elements in Procedures Location Execution of Procedures Y/N Objective Evidence/Comment 

WWIS-1: WWIS and Data Entry Personnel must be trained to assess data and properly enter data into the WWIS. 

CCP-QP-002, Rev. 27 CCP-TP-530, Rev. 7, Sect. 2.2.1 

• WCO and Data Entry Personnel are 

trained to assess data and properly enter and transfer all data in the WWIS. 

• Training for Data Entry Personnel and 

data reviewers/verifiers includes the WIPP Waste Information System User’s Manual and the applicable site 

procedures. 

• Training records are available for review 

and are complete. 

Y EPA reviewed the training records for the two 

WCA/WCOs qualified for this site. 

Initial training includes WIPP Waste Information 

System User’s Manual and OJT. Addendum G records WCA training for all RH TRU sites. Addendum H records WCO training for all RH TRU sites. The WCO qualifying examination is performedverbally with an SME. 

Training records were complete for the WCA/WCO 

who performed the onsite demonstration of WWIS. 

Objective evidence: 

3. Training records for two WWIS WCA/WCOs 

WWIS-2: Security measures for ensuring data integrity and accessing WWIS are sufficient. 

CCP-TP-530, Rev. 7, Sect. 4.1 

Access to WWIS is controlled. WWIS access requests are recorded in an access log that is available for review. 

Y Access to WWIS is password controlled. Each WCA 

and/or WCO must obtained a password from the WWIS Administrator prior to beginning work, and 

passwords become invalid if an employee leaves CCP.

WWIS-3: There are adequate 

procedures for entering data into the 

WWIS and transmitting data to WIPP. 

CCP-TP-530, Rev. 7, Sect. 3.0, 4.0 

Employee’s explanation of job duties was consistent with applicable procedures. WWIS and Data Entry Personnel adequately explained how data are assessed, input, and transferred into WWIS. 

Y A WCO demonstrated, in the test instance, how data 

are entered, checked, and uploaded into WWIS for GEVNC data. At the time of the onsite inspection, GE VNC did not have an approved Waste Stream Profile Form (WSPF) and containers could not be certified for shipment. A minimum of results from 10 containers are needed to approve a WSFP. These data are entered into the Characterization module of WWIS and transferred to the Certification module of WWIS after 

WSPF approval. During the demonstration, data were

entered into the test instance of WWIS. Objective evidence;

1. WWIS Data Entry Summary – Chaz & Cert for 

GEVNC containers GE003 and GE004 

WWIS-4: Procedures require that only verified and validated data are 

CCP-TP-530, Rev. 7, Data generation and project-level reviews of container data for WWIS entry have been Y The WCO explained the process used for certifying containers from GEVNC prior to entering some data 
WWIS-2

 ATTACHMENT A.2: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLIST 

EPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8 Inspection Date: December 2–4, 2008

Establishment of Required 

Technical Elements in Procedures Location Execution of Procedures Y/N Objective Evidence/Comment 

entered into WWIS. Sect. 4.3, 

Table 1 

performed and review checklists are 

complete. 

into WWIS. Containers only become eligible for WWIS entry after completion of the review checklists (ITR and SPM) are completed. A WCA obtains a list of eligible containers from a SPM and obtains hard copies of the applicable BDRs to facilitate WWIS data entry. The following information is required for WWIS entry: dose-to-curie results (radionuclide activities), VE data, radiological survey results, and the AK tracking sheet for the waste stream. Objective evidence;

1. Testing results (dose-to-curie, VE, radiological 

survey, and AK tracking sheet) for container GE003 

2. WWIS Data Entry Summary – Chaz & Cert for 

GEVNC containers GE003 and GE004 

WWIS-5: Procedures include instructions for entering characterization data into the Characterization Data System (CDS) WCO Review Form and data discrepancy resolution. 

CCP-TP-530, Rev. 7, Sect. 4.4, Table 1 

• WCA uses Table 1 to identify and enter 

required data into the CDS. 

• Second WCA reviews data, initials, and 

dates. 

• If data discrepancies cannot be resolved 

the form is sent to WCO or SPM for resolution. 

Y CDS was not used for this site at the time of the onsite 

inspection and all data were obtained from hard copies.

A spreadsheet, GEVNC RH template.xls, is used to enter data, and this completed spreadsheet is reviewed 

by a second WCA. Results of this 100% review of 

data are recorded on the spreadsheet. If data is corrected in the spreadsheet, the change is made and 

initialed. If the actual data appear to be incorrect, it is returned a SPM for verification. The spreadsheet has been validated in accordance with 

procedure CCP-QP-22, R.10, Software Quality 

Assurance Plan. The control number for this spreadsheet is SCO 1023. If data discrepancies cannot be resolved by the twoWCAs, then a SPM or WCO is contacted for resolution. Objective evidence: 
WWIS-3

 ATTACHMENT A.2: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLIST 

EPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8 Inspection Date: December 2–4, 2008

Establishment of Required 

Technical Elements in Procedures Location Execution of Procedures Y/N Objective Evidence/Comment 

1. WWIS Data Entry Summary – Chaz & Cert for 

GEVNC containers GE003 and GE004 

WWIS-6: Containers are not submitted to WWIS if there are open 

NCR/CARs. 

CCP-TP-530, Rev. 7, Sect. 4.3.11 

WCA requests QAO to confirm that there are no open NCR/CARs for the containers entered into the CDS. 

NA CDS was not used for this site at the time of the onsite 

inspection. No NCRs had been issued for the containers processed to date. CCP has a well-defined 

process for ensuring that there are no open NCRs 

associated with candidate containers, which has been demonstrated 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 provide instructions for WCO review of characterization and certification to WWIS. 

CCP-TP-530, Rev. 7, Sect. 4.4 WCPIP, Rev. 0D, Sect. 4.2.9 

The WCO verifies: • TRU alpha activity is >100 nCi/g for 

each payload container. 

• Confirm WWIS Data Spreadsheet or 

CDS WCO Review Form information is accurate and complete. 

• TRUCON Code (waste is not 

incompatible). 

• WSPF number. 

• Site-specific identifier precedes 

container number. 

Y During the inspection, the WCO explained to EPA 

entries on the spreadsheet, including TRU alpha activity, TRUCON code, and WSPF (not yet approved). To challenge the edit limit checks built 

into the spreadsheet, the WCO changed TRU alpha activity, so that it was below the required value. 

WWIS rejected these data. The TRUCON code is reviewed by the WCO to ensure that when canisters are “built,” they will be compatible (3 containers per each canister). The WSPF number for this waste stream is GEVNC.01, which was not approved at the time of the

inspection. The site-specific identifier for this site is “cc.”Objective evidence: 

1. WWIS Data Entry Summary – Chaz & Cert for 

GEVNC containers GE003 and GE004 

2. Waste Container Data Report for container GE003 

and GE004 
WWIS-4

 ATTACHMENT A.2: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLIST 

EPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8 Inspection Date: December 2–4, 2008

Establishment of Required 

Technical Elements in Procedures Location Execution of Procedures Y/N Objective Evidence/Comment 

WWIS-8: WMP weights for each SCG are entered into WWIS in accordance with the procedure. 

CCP-TP-530, Rev. 7, Sect. 4.5.9– 4.5.10 WCPIP, Rev. 0D, Sect. 4.2.9 

S5000: • If calculated CPR weight is = or < net 

weight of container, enter the net weight of the container as “plastic.” 

• If calculated CPR weight is = or > net 

weight of container, enter maximum weight of CPR as “plastic.” 

Y EPA reviewed the spreadsheets for containers GE003 

and GE004 and the Waste Container Data Report for container 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 the container. This is a debris waste stream, S5400. Objective evidence;

1. WWIS Data Entry Summary – Chaz & Cert for 

GEVNC containers GE003 and GE004 

2. Waste Container Data Report for containers GE003 

and GE004 

WWIS-9: Reviewed data are entered into WWIS. 

CCP-TP-530, Rev. 7, Sect. 4.5 

• WCO signs and dates CDS or WWIS 

Data spreadsheet. 

• WCO or WCA submits data to WWIS 

(certification module if WSPF approved, characterization module if WSPF not approved). 

• WWIS Administrator accepts/rejects data 

via e-mail 

NA No data had been submitted to the characterization 

module WWIS at the time of the inspection. Data from 10 containers are needed for WSPF approval. The demonstration used the WWIS test instance for data entry. 

WWIS-10: Resolution of data deficiencies. 

CCP-TP-530, Rev. 7, Sect. 4.4.17-4.4.18, 4.4.22-4.4.24, 4.5.11 

• Hold • NCR 

NA No NCRs had been issued against the containers 

processed at the time of the inspection. CCP has a

well-defined process for ensuring that there are noopen NCRs associated with candidate containers, which has been demonstrated at other sites for both CH and RH waste. The container number is entered intothe PTS database, which identifies any open NCR forthat container. 

WWIS-11 CCP-TP-530, 

Rev. 7, 

• After submission, the Waste Container Y EPA reviewed the data sheets for container GE003 and 

the required information was available. The filter
WWIS-5

 ATTACHMENT A.2: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLIST 

EPA Inspection No.: EPA-GEVNC-CCP-RH 12.08-8 Inspection Date: December 2–4, 2008

Establishment of Required 

Technical Elements in Procedures Location Execution of Procedures Y/N Objective Evidence/Comment 

Sect. 4.6.13 Data Report is printed, signed. and dated, 

• Copies of data, radiological survey, filter 

information, signed Waste Container Data Report, and correspondence sent to CCP records custodian. 

information was recorded in the comments section of

the VE data sheet. Because GEVNC containers had not yet been entered into WWIS, the records available were limited to characterization data. 

Objective evidence;

1. WWIS Data Entry Summary – Chaz & Cert for 

GEVNC containers GE003 and GE004 

2. Waste Container Data Report for containers GE003 

and GE004 

WWIS-12: Records retention. CCP-TP-530, 

Rev. 6, Sect. 5.0 

QA/Lifetime records: 

• WWIS Data SS or CDS WCO Review 

Forms. 

• Waste Container Data Report. • WWIS Data Approval/Rejection Reports. • Correspondence. 

QA/Nonpermanent: 

• CDS Database (electronic). 

Y CDS database was not used for this waste stream at the 

time of the inspection. Characterization data, spreadsheets, and Waste Container Data Reports were available for the demonstration containers GE003 and GE004. Objective evidence: 

1. WWIS Data Entry Summary – Chaz & Cert for 

GEVNC containers GE003 and GE004 

2. Waste Container Data Report for containers GE003 

and GE004 
B-1 

ATTACHMENT B.1. EPA INSPECTION ISSUE TRACKING FORM, 

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 require 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 Attachment 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, 2009 
B-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 activities presented on pages 8-9 of the AK 

Summary, and correlation of these activities (through 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 will 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 were made to the waste stream volume 

and radionuclide scaling factors, including the text and tables. 

• Information in the text of the AK Summary pertaining to the Q-tip smears obtained in 

1982, including the specific analysis and information provided by the activity, is 

insufficient. This is important because the Sampling and Analysis Plan (SAP) apparently 

uses this information as the basis for developing specific aspects. 

• The radionuclide discussion in Section 5 does not adequately address generalized waste 

composition. Of particular importance are changes in activities/potential radiological 

contamination pre-post 1978 (i.e., MOX prior with exceptions, sources post, with 

exceptions). CCP did not prepare a radiological analysis or table to accompany their own 

time line that may help make these changes. 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 reflect modified radionuclide 

scaling factors. 

• The prohibited item discussion in Section 5.4.12 does not include an updated and 

thorough spent nuclear fuel (SNF) analysis. 

• Table 6 is unclear regarding the quantification methods 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 included. 
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 that the AK compilation for the 

waste stream is complete and the required AK accuracy report is therefore incorporated 

into CCP-AK-GEV-502. This is not correct, as the waste 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 List: 

The Confirmation Test Plan CCP-AK-GEV-502 states on page 12 that performance of additional 

swipe sample collection efforts will be evaluated if the variability of sample results so warrants; 

please clarify whether this will actually be performed. 
B-4 

ATTACHMENT B.2. EPA INSPECTION ISSUE TRACKING FORM, 

EPA INSPECTION ISSUE NO. GEVNC-CCP-RH-AK-08-001F, FINAL 

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 (SAP) GE Vallecitos 

Nuclear Center Hot Cell #4 provides the proposed Energy 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 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 as it was implemented, including final sample locations, corresponding 

sample numbers, and location of field duplicates and associated sample identifiers. Also indicate 

whether any trip blanks or other field-related quality control samples were collected, and whether 

these were transmitted to the laboratory for analysis. 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 report 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, 2009 
B-5 

ATTACHMENT B.3. EPA INSPECTION ISSUE TRACKING FORM, 

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 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 materials in which the “RH TRU materials 

embedded in...other solid material may require 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 require this consideration. 

• The WCPIP requires that the SAP be submitted to CBFO 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, 2009 
B-6 

ATTACHMENT B.4. EPA INSPECTION ISSUE TRACKING FORM,

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 radiological characterization 

(RC) process and the CCP report CCP-AK-GEV-501 have multiple technical and editorial errors. As 

presented during this inspection, these documents require 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 Doherty 

E. Additional Comments: None 

F. Site Response Information: 

 Site Response Required? YES 

 Site Response Due Date: January 14, 2009 
B-7 

ATTACHMENT B.5. EPA INSPECTION ISSUE TRACKING FORM, 

INSPECTION ISSUE NO. GEVNC-CCP-RH-VE-08-004CR, FINAL 

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 incorporated 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, 2009 
B-8 

ATTACHMENT B.6. EPA INSPECTION ISSUE TRACKING FORM,

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, the VEO does not perform this activity and is not, 

therefore, in compliance with CCP’s written procedure 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