DOCKET NO: A-98-49, II-A4-168 

WASTE CHARACTERIZATION REPORT 

EPA TIER 1 EVALUATION 

OF THE CENTRAL CHARACTERIZATION PROJECT 

CONTACT-HANDLED TRANSURANIC WASTE CHARACTERIZATION PROGRAM 

FOR THE LOS ALAMOS NATIONAL LABORATORY: 

APPROVAL OF THE ADDITION OF SUMMARY CATEGORY GROUP S4000 (SOILS) 

 

September–November 2012 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

December 2012
ii 

TABLE OF CONTENTS 

Section Page

1.0 Introduction ..........................................................................................................................1

2.0 Purpose of Tier 1 Evaluation ...............................................................................................4

3.0 Purpose of This Report ........................................................................................................4

4.0 Scope of the Tier 1 Evaluation.............................................................................................5

5.0 Evaluation Personnel ...........................................................................................................5

6.0 Technical Evaluation ...........................................................................................................5

6.1 Acceptable Knowledge ............................................................................................8

6.2 Real-Time Radiography .........................................................................................20

7.0 Conclusions ........................................................................................................................22

LIST OF TABLES 

Table 1. Tiering of Contact-Handled Transuranic Waste Characterization Processes 

Implemented by LANL-CCP ......................................................................................... 2

Table 2. Tier 1 Evaluation Participants ........................................................................................... 5

Table 3. TA-21 Material Disposal Area Information and TRU Waste Soil Generation ................ 7

Table 4. Batch Data Reports Examined, Waste Stream LA-MSG04.001 ...................................... 8

Table 5. Material Types Potentially Present in Waste Stream LA-MHG04.001 .......................... 10

Table 6. Traceability of Selected Containers in Waste Stream LA-MSG04.001 ......................... 15

ATTACHMENTS 

Attachment A: Approval Summary for LANL-CCP CH Waste Characterization Program 

Attachment B: List of Documents Reviewed for This Evaluation 

Attachment C: CCP Standing Order CCP-SO-086, Revision 0 
iii 

ABBREVIATIONS, ACRONYMS AND INITIALIZATIONS 

Ac actinium 

AK acceptable knowledge 

AKE acceptable knowledge expert 

AKIR Acceptable Knowledge Isotopic Ratio (database)

AKSR acceptable knowledge summary report 

Am americium 

BDR batch data report 

CBFO Carlsbad Field Office 

CCP Central Characterization Project 

CFR Code of Federal Regulations 

CH contact-handled 

cm centimeter 

Cm curium 

CONCERT Container Certification (database) 

D&D decontamination and decommissioning 

DOE U.S. Department of Energy 

DP Delta Prime 

EA expert analyst 

EPA U.S. Environmental Protection Agency 

HENC High Efficiency Neutron Counter 

HENC No. 1 HENC Unit 1 

HENC No. 2 HENC Unit 2 

HLW high-level waste 

ITR Independent Technical Reviewer 

LANL Los Alamos National Laboratory 

LLW low-level waste 

MDA material disposal area 

MT material type 

NCR nonconformance report 

NDA nondestructive assay 

NDE nondestructive examination 
iv 

NTP National TRU Programs 

NWP Nuclear Waste Partnership, LLC 

NWPA Nuclear Waste Policy Act 

ORNL Oak Ridge National Laboratory 

OSRP Offsite Sealed Source Recovery Program 

Po polonium 

Pu plutonium 

QMIS Quality and Management Integrated System 

R&D research and development 

RTR real-time radiography 

SCG summary category group 

SNF spent nuclear fuel 

SPM site project manager 

SuperHENC Super High-Efficiency Neutron Counter 

Sr strontium 

SSVET Sealed Source VET 

T1 Tier 1 

T2 Tier 2 

Th thorium 

TRU transuranic 

U uranium 

VE visual examination 

VET visual examination technique 

WAC waste acceptance criteria 

WIPP Waste Isolation Pilot Plant 

WMP waste material parameter 

WSPF waste stream profile form 

WWIS WIPP Waste Information System 
1 

1.0 INTRODUCTION 

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

proposed Tier 1 (T1) change to the EPA-approved transuranic (TRU) waste characterization 

program at Los Alamos National Laboratory (LANL). This T1 approval allows the LANL 

Central Characterization Project (CCP) to dispose of retrievably-stored, contact-handled (CH) 

TRU Summary Category Group (SCG) S4000 (Soils) waste at the Waste Isolation Pilot Plant 

(WIPP). 

In accordance with Title 40 of the Code of Federal Regulations (40 CFR) 194.8(b), EPA 

conducted Baseline Inspection No. EPA-LANL-CCP-05.05-8 of LANL-CCP on May 3–5, 2005. 

As a result of this baseline inspection, EPA approved the LANL-CCP waste characterization 

program with conditions and limitations as documented in the LANL baseline final inspection 

report (see EPA Docket No. A-98-49, II-A4-88). 

On July 16, 2012, the Carlsbad Field Office (CBFO) requested EPA approval of the addition of 

SCG S4000 (Soils) to LANL-CCP’s EPA-approved CH waste characterization program as a T1 

change. EPA’s review, conducted in September–November 2012, covered LANL SCG S4000 

Waste Stream LA-MSG04.001. EPA’s desktop evaluation focused on (1) acceptable knowledge 

(AK) with a supplemental review of relevant components of nondestructive assay (NDA), and 

(2) nondestructive examination (NDE), specifically, real-time radiography (RTR). During the 

evaluation, EPA did not identify any findings or concerns; however, EPA had questions 

concerning AK and the required semiannual training of RTR operators and asked that LANLCCP address EPA’s AK questions by revising pertinent AK documents. Based on this 

evaluation, EPA approves the addition of SCG S4000 (Soils) to the EPA-approved CH waste 

characterization program at LANL-CCP. This EPA approval required revisions to the Tier 2 (T2) 

designations, which are indicated in bold in the revised tiering table (see Table 1). 

This report serves as EPA’s public notification of the approval of this T1 change. EPA will 

provide this information through the EPA website and by sending emails to the WIPPNEWS list, 

in accordance with 40 CFR 194.8(b)(3).
2

Table 1. Tiering of Contact-Handled Transuranic Waste Characterization Processes Implemented b

(Based on May 23–25, 2006, Baseline Inspection and Subsequent T1 Evaluations, Updated Decem

Waste Characterization 

Process Elements LANL-CCP Waste Characterization Process – T1 Changes LANL-CCP Waste Characteriza

Acceptable Knowledge (AK) and Load Management 

Any new waste category, or new Offsite Sealed Source Recovery 

Program (OSRP) wastes addressed in AK summary reports 

(AKSRs) separate from CCP-AK-008 Implementation of load management for waste streams other than 

AK-009 

Notification to EPA upon completion o

modification*** to the following: 

- AK accuracy reports; - AK reassessment memoranda an

that were distinct at the time of 

- AK-VE memoranda related to V

- AK-NDA memoranda; - AKSRs (new and updated ver- Site procedures requiring CBFO - AKSR CCP-AK-008, if changed 

and/or following the addition of 

- Any new or updated waste strea

including all associated attachinformation summary and sumchange notices used to modify aadditions to waste stream(s) wit

Nondestructive Assay (NDA) New equipment or physical modifications to approved equipment**

Extension or changes to approved calibration range for approved equipment 

Notification to EPA upon completion o

approved equipment, operating range(sCBFO approval 

Real-Time Radiography (RTR) N/A Notification to EPA upon the following

- Implementation of new equipme

to approved equipment; 

- Completion of changes to site p

approvals 

Visual Examination (VE) and Visual Examination Technique (VET), including OSRP Wastes (Sealed Source VET or SSVET) 

N/A Notification to EPA upon the following

- Completion of changes to site V

CBFO approvals, including OSR
3

WIPP Waste Information System (WWIS) 

N/A Notification to EPA upon the following

- Completion of changes to WWI

approvals; 

- Changes to the Excel spreadshe

characterization and certificatio

New T1s, T2s and significant modifications to existing T1s or T2s are in bold text; T1s or T2s that were only revised for style are not shown in 

* Upon receiving EPA approval, LANL-CCP will report all T2 changes to EPA at the end of each fiscal year quarter. 

** “Modifications to approved equipment” include all changes with the potential to affect NDA data relative to waste isolation and exclude min

safety-related equipment. *** “Substantive modification” means changes with the potential to impact the site’s waste characterization activities or documentation thereof, 

related to environmental safety and health, nuclear safety, the Resource Conservation and Recovery Act, or are editorial in nature.
4

2.0 PURPOSE OF TIER 1 EVALUATION 

Certain changes to the waste characterization activities since the date of the baseline inspection 

must be reported to and, if applicable, approved by EPA according to the tiering requirements set 

forth in 40 CFR 194.8 and incorporated into the LANL-CCP baseline final report cited in EPA 

Docket No. A-98-49, II-A4-88. 

Under the changes to 40 CFR 194.8 promulgated in the Federal Register on July 16, 2004 

(Vol. 69, No. 136, pages 42571–42583), EPA must perform a single baseline inspection of a 

TRU waste generator site’s waste characterization program. The purpose of EPA’s baseline 

inspection is to approve the site’s waste characterization 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. 

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

necessary, to the site’s approved waste characterization program by conducting additional 

inspections under the authority of 40 CFR 194.24(h). Changes requiring EPA notification and 

approval prior to implementation (T1) and those requiring post-implementation notification (T2) 

are identified in the site-specific baseline inspection reports. When evaluating proposed T1 

changes for approval, EPA may conduct a site inspection to observe the implementation of the 

change, or EPA can decide to conduct a desktop review of information provided specific to a 

change. The U.S. Department of Energy (DOE) may choose to characterize and dispose of, at 

risk of subsequent EPA disapproval, any previously approved TRU waste using processes, 

procedures or equipment implemented as T2 changes. EPA reviews T2 changes on a quarterly 

basis and may conduct continued compliance inspections to evaluate implemented T2 changes to 

verify adequacy. 

 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of EPA’s evaluation of a T1 change to add SCG S4000 soils to 

LANL-CCP’s EPA-approved CH waste characterization program. This report presents the 

technical basis of EPA’s approval decision, which has been conveyed to DOE separately by 

letter. EPA will also announce the decision on its website at www.epa.gov/radiation/wipp, in 

accordance with 40 CFR 194.8(b)(3). 

The DOE documents that EPA reviewed for this evaluation are cited in different sections 

throughout the report and are listed in Attachment B. Any of these documents can be requested 

from the following address: 

Carlsbad Field Office 

Manager, National TRU Program 

U.S. Department of Energy 

PO Box 3090 

Carlsbad, NM 88221-3090 
5

4.0 SCOPE OF THE TIER 1 EVALUATION 

The scope of this T1 evaluation is the addition of SCG S4000 soils to LANL-CCP’s EPAapproved CH waste characterization program. Sections 6.1 and 6.2 of this report detail the two 

technical areas assessed during this evaluation: 

• Programmatic requirements and AK, including NDA. 

• RTR. 

5.0 EVALUATION PERSONNEL 

EPA and its support personnel conducted a desktop AK review followed by a meeting with 

LANL-CCP AK experts (AKEs) to resolve outstanding questions. Additional EPA questions 

related to RTR were addressed by email with CBFO and LANL-CCP personnel. Table 2 lists the 

EPA evaluation team members and LANL-CCP personnel who participated in this evaluation, 

with each person’s position during the evaluation and affiliation. 

Table 2. Tier 1 Evaluation Participants 

Inspection Team Member Position Affiliation

Ed Feltcorn Lead Inspector U.S. EPA 

Rajani Joglekar Inspector U.S. EPA 

Connie Walker Technical Inspector, AK S. Cohen & Associates, Inc. 

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

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

Rose Gogliotti Technical Inspector, NDA S. Cohen & Associates, Inc. 

Randy Fitzgerald Acceptable Knowledge Expert LANL-CCP 

Jim Shoen Acceptable Knowledge Expert LANL-CCP 

Mike Papp Acceptable Knowledge Expert LANL-CCP 

Tom Morgan NTP-CCP Manager CBFO 

Ron Reeves Technical Support-Team Lead NWP-CCP 

The two waste characterization technical areas of AK and NDE are addressed in section 6.0 of 

this report. The AK evaluation was comprehensive because the documentation for LANL CH 

soil waste had not been previously reviewed. The NDA and NDE reviews were limited and 

focused primarily on evaluating NDA and RTR batch data reports (BDRs); the NDA review is 

included in the AK section of this report (section 6.1). 

6.0 TECHNICAL EVALUATION 

Waste-Generating Activities

Waste Stream LA-MSG04.001 consists of soil generated during cleanup, retrieval and 

decontamination and decommissioning (D&D) activities at the LANL TA-21 Delta Prime (DP) 

West Facility. The waste includes minor absorbents that were added during packaging and small 

amounts of debris, including blacktop, concrete and piping, and contains radionuclides from 
6

operations at TA-21. Contaminated soil originated from the removal of acid wells and lines 

associated with the liquid waste water treatment systems, tunnels below buildings in which “non 

standard event” spills occurred, material disposal areas (MDAs), and other spill locations. 

Ongoing cleanup of TA-21 may generate TRU waste soil that would be included in this waste 

stream (References C033, D006, D008, D058, D060, D069, M003, M004, M020, P036 and 

P037), a part of SCG S4000. 

Soils in Waste Stream LA-MSG04.001 were exclusively generated at TA-21, DP-West 

(References D008, D010, D016, D035, D058, D059 and D060). DP-West began plutonium (Pu) 

processing operations in September 1945 (References D059 and U001). Operations included: 

• Pu recovery operations (pretreatment, dissolution and purification). 

• Pyrochemical operations (e.g., metal preparation, electrorefining, direct oxide reduction). 

• Metal operations (alloy development, assembly, casting and inspection). 

•

239Pu fuels programs (e.g., advanced fuels fabrication and analysis). 

• Americium (Am) processing operations (oxide production and hydroxide precipitation). 

•

238Pu heat source fabrication. 

• Miscellaneous and special processing. 

• Waste management and D&D operations. 

LANL used five onsite MDA (MDAs A, B, T, U and V) trenches at TA-21 for solid and liquid 

waste disposal between 1945 and 1984 (Reference D069). Pu-bearing waste generated at TA-21 

between 1945 and 1978 was primarily disposed of in these trenches. The TA-21 DP-West Pu 

operations were transferred to TA-55 in 1978. Waste from Pu processing generated after 1978 

was shipped to TA-54 Area G, but LLW disposal in the TA-21 MDAs continued through 1984 

(Reference D059). Table 3 summarizes information about each MDA, including remediation 

status and anticipated generation of TRU soil (References D059, D069 and P036). 

As shown in Table 3, LANL used the TA-21 MDAs for disposal of TRU waste (References 

D010 and D059). Soil waste from MDA B is currently in the waste stream. TRU waste may be 

retrieved from MDA A and MDA T, which could be added to this waste stream if physical and 

radiological characteristics are similar. Remediation of TA-21 MDAs is ongoing under LANL’s 

Environmental Restoration Project. 

Following the movement of Pu production to TA-55, some TA-21 buildings were 

decontaminated to a level that allowed “continued occupancy of non-plutonium research 

operations” between 1978 and 1981 (Reference D035). Decontamination included walls and 

floors and removal of process service systems and gloveboxes; soil was also generated during 

D&D of Building 257 and all of these wastes were sent to TA-54 Area G for management 

(References C033, D006, D008, D035, D058, D060, D069, M003, M004, M008, M020, P036 

and P037). See section 6.1, Item (7), for more information about TA-54 Area G waste 

management. 
7

Table 3. TA-21 Material Disposal Area Information and TRU Waste Soil Generation 

MDA Period of Use Disposal Features and Activities Radiological Material Other Information Remediation Sta

MDA A 1945–1946; 

Reactivated 1969–1977 for LLW disposal 

Three disposal pits and two 50,000-gallon tanks 

Po, Pu, U and Thbearing solid and liquid wastes 

Tanks used for Pu-bearing 

precipitation wastes. In 1975, 

10,600 gallons transferred to TA-21-257, leaving precipitate in tank. 

Backfilled in 1978. Remediation ongoinunder LANL Environmental RestoProgram. 

MDA B 1946–1948 One large pit Pu, Po, U, Am, 

Cm and Ac, solid wastes 

Western 2/3 asphalted in 1966, eastern 1/3 used for “in-situ experimental trench cap studies” as of 1986. 

Remediation ongoinunder LANL Environmental RestoProgram. 

MDA T 1945–1984 Four absorption beds 

used for disposal of Pu process waste (1945–1952). Also 62 asphalt-lined vertical shafts used for LLW disposal and retrievable waste 

pit used to 1984. 

Pu process wastes Liquid waste diverted to TA-21-

35 after 1952 for treatment, but few hundred gallons/year were 

placed in beds up to 1967, after 

which liquid wastes were diverted to TA-21-257. 1968–1983: liquid LLW solidified and emplaced in asphalt-lined shafts. TRU liquid wastes were cemented and pumped into vertical shafts lined with corrugated metal pipes. 

Corrugated metal pipwere removed in 19transferred to TA-54 G. Surface area stabin 1984. Remediatioongoing under LANEnvironmental RestoProgram. 

MDA U 1945–1968 Two absorption beds 227Ac and 210Po 

waste water 

Disposal of non-TRU waste, 

based on available records. 

Soil removed in 198transferred to Area GExcavated area was and is now monitoreRemediation is ongounder LANL Environmental RestoProgram. 

MDA V 1945–1961 Three interconnected 

pits used laundry 

operation liquid waste disposal. 

“Small quantities” of 90Sr and 239Pu 

Area was isolated in 1984 with chain link fence and surface waste stabilized. 

Remediation ongoinunder LANL Environmental RestoProgram. 
8

Documents, Waste Containers, Batch Data Reports and Calculation Packages Provided

EPA evaluated the documentation that LANL-CCP prepared to support the addition of the S4000 

SCG to the LANL-CCP baseline approval. Attachment B presents the full list of all documents 

reviewed. 

EPA examined the following RTR and NDA BDRs: 

Table 4. Batch Data Reports Examined, Waste Stream LA-MSG04.001 

Example Drum Number RTR BDR No. NDA BDR No. 

89987 LA-RTR2-11-0116 1LANDA1470 

89983 LA-RTR2-11-0116 1LANDA1470 

89982 LA-RTR2-11-0116 2LANDA0878 

6.1 Acceptable Knowledge 

EPA examined the AK process and associated information specific to the radiological and 

physical contents of the waste stream to determine whether LANL-CCP’s proposed addition of 

CH retrievably-stored and newly-generated SCG S4000 waste complies with 40 CFR 194.24 and 

194.8. EPA also reviewed RTR BDRs for technical adequacy. The results of this evaluation are 

presented below. 

Technical Evaluation

EPA performed a T1 evaluation of Waste Stream LA-MSG04.001 to determine whether SCG 

S4000 waste should be included in EPA’s LANL-CCP CH baseline approval. EPA evaluated the 

adequacy of AK information in the following areas. 

 

(1) The definition of the waste stream was evaluated and found to be adequate. 

CCP-TP-005, Revision 24, page 22, defines a waste stream as “waste materials that have 

common physical form, that contain similar hazardous constituents (similar radiological 

properties for WCPIP compliance) and that are generated from a single process or activity.” 

Waste Stream LA-MSG04.001 was evaluated to determine whether the waste stream was 

adequately defined by its physical and radiological contents. As described in section 6.0 above, 

Waste Stream LA-MSG04.001 consists of soil generated during various activities at the TA-21 

DP-West Facility. LANL-CCP historically assigned number MSG01-DD to contaminated soil 

from the TA-21 DP-West Facility (References C033, D006, D008, D058, D060, D069, M003, 

M004, M020, P036 and P037). 

The TA-21 DP-West plutonium operations were transferred to TA-55 in 1978. The AK available 

for TA-21 operations is minimal; however, operational activities at TA-55 mirrored those 

performed at TA-21. Table 3 in the acceptable knowledge summary report (AKSR) compares 

these activities. Therefore, the TA-55 process information as detailed in the AKSR is an 

adequate substitute for the TA-21 process information. 
9

Based on the above information, the processes generating Waste Stream LA-MSG04.001 are 

adequately defined. 

LANL-CCP described the physical composition of the waste stream in the AKSR and in CCPTP-005, Attachment 6. LANL-CCP based this description on an Oak Ridge National Laboratory 

(ORNL) soil because stream-specific NDE was not available. However, the soil characteristics of 

Waste Stream LA-MSG04.001 and the ORNL soil waste stream are very different. The ORNL 

soil waste stream underwent homogenization and was mixed with various sorbents (e.g., 

RADSORB), so ORNL soil does not contains debris like what is expected in Waste Stream LAMSG04.001, which will not be sorted or homogenized to remove debris. LANL-CCP will 

reevaluate the physical characteristics of the waste stream as CCP NDE data become available 

and will revise the AKSR appropriately. See Item (4) for additional information. When this 

evaluation is complete, the physical characteristics of Waste Stream LA-MSG04.001 will be 

adequately defined. Notification to EPA upon completion of new or revised AKSRs is a new T2 

change (see Table 1). 

The AKSR states that the two predominant radionuclides by mass are plutonium-239 (239Pu) and 

uranium-238 (238U), as represented by Material Type (MT) 52.1 Generator-reported radionuclide 

composition data are available for many containers in the waste stream, but the nature of this 

information ranges from detailed isotopic distributions to only 239Pu values or identification of 

MTs (References C033, C037, M004, M009 and M020). The radiological composition of Waste 

Stream LA-MSG04.001 is adequately defined and will be verified through actual assay; the 

AKSR will be updated as necessary to reflect this information. See Item (2) for additional 

information. 

(2) Acceptable knowledge information pertaining to the radiological characteristics of 

transuranic wastes was examined and found to be adequate. 

Table 14 in the AKSR presents the overall radiological composition based on generator TRU 

waste storage and solid waste disposal records, information from the LANL Acceptable 

Knowledge Isotopic Ratio (AKIR) and Container Certification (CONCERT) databases, 

augmented by LANL-CCP NDA data. Historical measurement data were not reported on 

reviewed documentation, but the MT was sometimes reported. LANL-CCP included this 

information in the AK tracking spreadsheet. AKSR Table 14 indicates that 239Pu and 238Pu are 

the predominant radionuclides by weight and that 239Pu and 241Am are the predominant 

radionuclides by activity. 

EPA determined that radiological information for each container generated between 1978 and 

1981 included 239Pu mass information, and nearly two-thirds of the drums with data also reported 

masses for 235U, 238Pu and 241Am. Recently generated MDA B soil data results also reported 

mass data for 234U, 238U, strontium-90 (90Sr), cesium-137 and tritium (Reference M020). EPA 

examined representative solid waste disposal and TRU waste storage records as well as data 

from the AKIR and CONCERT databases and AK tracking spreadsheet to verify radiological 

information about each container (References C033, C037, M004, M009 and M020). 

 

1

 MTs represent a range of specific isotopic compositions focusing on accountable (nuclear) material, 

i.e., Pu, U, 241Am and other radionuclides, as appropriate. 
10

As mentioned in Item (1), the Pu processing operations that took place at TA-55 directly 

correlate to processing that took place at TA-21; therefore, the radiological characteristics of 

material managed at the two facilities should be comparable. LANL-CCP assigned common 

MTs to the TA-21 activities that directly correlate to TA-55 activities. Table 5 presents 

radiological MTs managed at TA-21. 

Table 5. Material Types Potentially Present in Waste Stream LA-MHG04.001 

Material 

Type 

(MT) 

Plutonium Isotope (Weight %) 

Estimated Weight % 

Relative to Total 

Plutoniuma

238Pu 239

Pu 240Pu 241Pu 242Pu 244Pu 234U 235U 241Am 

MT 51 0.006 96.77 3.13 0.076 0.018 — 0.001 0.1 0.06

MT 52 0.01 93.78 6.0 0.2 0.02 — 0.002 0.1 0.2 

MT 53 0.03 91.08 8.45 0.366 0.071 — 0.007 0.09 0.3 

MT 54 0.046 87.42 11.5 0.81 0.22 — 0.01 0.09 0.7 

MT 55 0.06 83.88 14.73 1.03 0.304 — 0.02 0.09 0.9 

MT 56 0.061 81.99 16.51 1.18 0.355 — 0.02 0.09 1.0 

MT 57 0.433 74.63 20.7 2.55 1.69 — 0.1 0.08 2.0 

MT 42 0.73 1.06 6.4 1.97 89.83 — 0.3 0.0009 3.0 

MT 83 78.9 18.4 2.5 0.055 0.15 — 33.1 0.02 0.42 

 

Uranium Isotope (Weight %) 

234U 235U 236U 238U 

MT 12 0.0015 0.23 0.008 99.77 

MT 35 0.36 37.6 0.14 61.9 

MT 36 0.63 62.44 0.18 36.75 

MT 38 1.03 93.04 0.41 5.53 

MT 39 1.32 97.52 0.17 0.99 

Source: CCP-AK-LANL-010, Central Characterization Project Acceptable Knowledge Summary Report for Los 

Alamos National Laboratory, TA-21 DP West Facility, Waste Streams: LA-MHD04.001, LA-MSG04.001, 

Revision 5, May 1, 2012, Table 7 and Table 8. 

a

 Assumes no chemical fractionation (References C021 and D034). 

Soil generated during site cleanup may contain several different MTs because multiple releases 

occurred from different origins. Individual container data may not correlate to a specific MT and 

may be better represented by a combination of MTs, as implied by the overall composition 

presented in AKSR Table 14. The AK-NDA memorandum presented with CCP-TP-005, 

Attachment 7 (September 23, 2012), states, “The primary MT fed into the processes producing 

this waste stream is weapons grade Pu (MT 52), however, other material types were also 

introduced as feed material.” Distributions presented in AKSR Table 14 show that 239Pu is the 

predominant plutonium isotope, but the distributions do not match the MT 52 distribution 

exactly, supporting LANL-CCP’s determination that soil contains mixtures of various MTs. 

Based on current information, the radiological composition of the waste is adequately defined 

and will be modified as necessary to reflect ongoing LANL-CCP NDA data. EPA expects 

LANL-CCP to modify AKSR Table 14, as necessary. EPA will evaluate revisions of this table 

when the AKSR is submitted as a T2 change. 
11

(3) Radioassay batch data reports were evaluated and were found to be adequate. 

EPA reviewed NDA BDR Nos. 1LANDA1470 and 2LANDA0878 for the High Efficiency 

Neutron Counter Unit 1 (HENC No. 1) and HENC No. 2, respectively, which contained assays 

of S4000 and S5000 wastes. The two BDRs contained a total of 14 drums, seven of which were 

S4000 waste: Drum Nos. 89987, 89985 and 89984 from HENC No. 1 BDR 1LANDA1470; and 

Drum Nos. 89982, 89988, 89891 and 89986 from HENC No. 2 BDR 2LANDA0878. EPA 

verified that each BDR included the following: 

• Site project manager (SPM) checklist, Attachment 3. 

• BDR cover sheet, Attachment 1. 

• Discrepancy resolution table of contents, Attachment 2. 

• BDR narrative summary, Attachment 3. 

• Independent technical reviewer (ITR) review checklist, Attachment 4. 

• Measurement control report. 

• Container data sheets. 

• Evidence of signatures by the ITR and an SPM. 

• Type of waste in each container, SCG S4000 or S5000. 

Both of the BDRs were technically adequate. 

(4) Identification of physical form, including waste material parameters and prohibited items, 

was assessed and found to be adequate. 

Waste Stream LA-MSG04.001 is soil, sand and gravel and has been assigned Waste Matrix Code 

S4200. The waste stream has total volume of 168.4 cubic meters. Additional waste volume is 

anticipated through repackaging and radiological characterization of the containers, and it is also 

possible that additional TRU soil could be generated during remediation of MDAs A and T 

(References C033, C037, D058, D059, D060, M004, M009 and M020). The waste stream may 

also contain absorbent material such as vermiculite, as well as debris such as plastic packaging, 

blacktop, concrete, insulation and piping. LANL-CCP estimated the soil percentages presented in 

the AKSR based on an ORNL soil waste stream that is composed of 97% soil and 3% inorganic 

matrix and plastic. However, as discussed in Item (1) above, this approach does not accurately 

represent Waste Stream LA-MSG04.001 because the ORNL soil does not include debris 

anticipated in the LANL soil waste. LANL soil may contain more debris than that represented in 

the AKSR, as evidenced by Reference DR007, which documents reassignment of a soil container 

to the debris waste stream. 

LANL-CCP will perform NDE on each container to determine its physical composition and will 

also identify the presence of prohibited items. Because LANL-CCP revised the AKSR to commit 

to re-evaluating the physical composition of the waste stream based on actual NDE data and 

because it is unclear whether this information will be available in the near future, EPA is not 

requiring LANL-CCP to provide the revised waste material parameter (WMP) estimates prior to 

approving this T1 change. EPA will evaluate future versions of the AKSR as part of ongoing T2 

review of AKSRs. When LANL-CCP completes its review based on actual NDE information, 

the physical characteristics of Waste Stream LA-MSG04.001 will be adequately defined. 
12

(5) Acceptable knowledge procedural adequacy and implementation were assessed and 

found to be adequate (e.g., assembly compilation, interpretation, confirmation, 

discrepancy resolution). 

CCP-TP-005, Revision 24, was effective as of November 28, 2011, and was in place when the 

latest version of the AKSR was prepared. It includes the following attachments: 

• “Attachment 1 – Acceptable Knowledge Documentation Checklists.” 

• “Attachment 2 – Record of Communication.” 

• “Attachment 3 – Acceptable Knowledge Source Document Summary.” 

• “Attachment 4 – Acceptable Knowledge Source Document Reference List.” 

• “Attachment 5 – Hazardous Constituents.” 

• “Attachment 6 – Waste Form, WMPs, Prohibited Items, and Packaging.” 

• “Attachment 7 – Radionuclides.” 

• “Attachment 8 – Waste Containers List.” 

• “Attachment 9 – Waste Characterization Data Cross-Reference.” 

• “Attachment 10 – Acceptable Knowledge Re-evaluation Checklist.” 

• “Attachment 11 – Acceptable Knowledge Source Document Discrepancy Resolution 

Form.” 

• “Attachment 12 – Form and Content Guide for AKSRs.”

• “Attachment 13 – CCP Waste Stream Characterization Checklist.” 

• “Attachment 14 – CCP Acceptable Knowledge Accuracy Report.” 

• “Attachment 15 – CCP TRU Waste Correlation and Surrogate Summary Form.” 

LANL-CCP provided Attachments 1, 2, 3, 4, 5, 6, 7, 8, 10 and 11. Attachments 1 and 4 are 

adequate. Attachment 2s are listed in Attachment B to this evaluation as “C” source documents 

and Attachment 3s are source document summaries and quality assurance records that are 

retained separately. Attachment 5 is not applicable to EPA’s review. Attachments 6 and 7 are 

addressed under Items (2), (4) and (15). Attachment 8 presents the number of containers in the 

waste stream at the time the attachment was generated and will be augmented when the wastes 

are repackaged. The AK tracking spreadsheet is updated in real time when repackaging occurs 

and presents ongoing waste stream contents and container status. The generation dates were in 

error on the original Attachment 8, dated August 7, 2012, so LANL-CCP revised Attachment 8 

and provided the revision to EPA on September 23, 2012. LANL-CCP provided an example 

Attachment 10 that addressed misidentification of a drum and also provided the related 

Attachment 11 discrepancy resolution (Reference DR007). 

Attachments 9, 12 and 15 are not required. Attachments 13 and 14 have not yet been prepared 

due to the early characterization status of the waste stream; therefore, LANL-CCP did not 

provide them. 

EPA examined the attachments and the source documents and interviewed the AKEs. EPA 

verified that all AK source documents are provided to CCP document control as electronic 

records, but only CCP-generated documents (e.g., CCP-TP-005 attachments and AKSRs) are 

retained as quality assurance records. EPA found that some of the attachments were prepared 
13

using CCP-TP-005, Revision 18, not Revision 24. The general content of the forms applicable to 

CH waste did not change substantially between Revisions 18 and 24. In the future, EPA expects 

CCP-TP-005 attachments to reflect the version of this procedure in place at the time that the final 

AKSR is prepared. EPA determined that LANL-CCP demonstrated the ability to follow the AK 

procedure for the elements examined. 

(6) The acceptable knowledge summary report was assessed and found to be adequate. 

EPA examined the AKSR, Revision 5, for Waste Stream LA-MSG04.001 to determine whether 

major technical components were present and to ensure that the document adequately justified 

and described the waste stream. EPA found that the AKSR did not adequately address the 

following: 

• Process information pertaining to soil waste generation at MDAs. 

• Radiological characterization of the waste stream and consistency between the AK-NDA 

memorandum and AKSR. 

• Physical characterization of the waste stream. 

LANL-CCP representatives provided a freeze-file2 modification of the AKSR representing the 

changes in progress. These changes include additional process information concerning soil 

generation from MDA cleanup, modification of the AK-NDA memorandum [see Item (15) 

below] and modification of the AKSR to indicate that evaluation of physical WMPs will be 

based on LANL-CCP NDE data. LANL-CCP will provide a revised AKSR incorporating freezefile changes to EPA. Notification of the availability of an updated AKSR is a new T2 change 

(see Table 1). EPA expects that the freeze file changes will be incorporated in the next revision 

of the AKSR. 

(7) Drum traceability and the ability to follow the acceptable knowledge process for 

containers was assessed and found to be adequate. 

Waste Stream LA-MSG04.001 soil generated during the 1978–1981 TA-21 D&D effort was 

placed in TA-54 Area G Pits 1, 2 and 9, or Domes 33, 153, 232 or 283. Waste Stream LAMSG04.001 soils generated during remediation of MDA B were shipped directly to Area G, 

Pad 1. The AKSR states that, “Of the current population of 82 soil containers, 45 are currently 

stored below-grade at Area G.” Specifically, crates previously placed in domes or generated 

through remediation of MDA B are currently stored on Pad 1, while 55-gallon drums and a few 

crates remain in burial Pit 9 (Reference M003). Waste on the pads is subsequently repackaged as 

necessary and characterized before WIPP shipment. TRU waste management at Area G currently 

includes below-grade retrieval operations from pits and other areas, as well as container storage, 

container venting, decontamination and volume reduction at Building 412, Dome 231 Permacon 

 

2

 “Freeze file”: As a result of an inspection-related EPA issue, LANL-CCP may have to revise a document. 

LANL-CCP makes the change(s) and provides the revised document to EPA as a freeze file to serve as objective 

evidence for the inspection. CCP’s document control process in Carlsbad, NM, then generates an official version of 

the revised document. 
14

and Dome 375 Box Line Process (References D010, D030, D032, D036, D058, D059 and 

D060). 

From 1971 to 1992, container data were documented on radioactive solid waste disposal records 

that included container origin, radionuclides, waste description and disposal location. LANL 

requires a waste profile form for each waste stream (and sometimes each container) generated 

since 1991, and this form documents the waste’s origin and chemical content. Also, TRU waste 

storage records documenting the waste’s origin and radioassay were required after 1992. 

LANL-CCP obtained information about the waste stream from various databases, including: 

AKIR database, listing available isotopic information by container; CONCERT, a historical 

LANL database that was not used after the early 2000s and also includes radiological 

information; and TA-54’s own database documenting its waste management practices. All of 

these were examined by LANL-CCP and are included in EPA’s traceability analysis. 

EPA selected seven containers for traceability analysis: Container Nos. 89987, 89983, 89982, 

66122, S780204, S794044 and S813323. Table 6 presents available traceability information for 

these selected drums. EPA obtained much of the information presented in this table through 

interviewing the LANL-CCP AKEs. 

As shown in Table 6, documentation available for each container varied based on the generation 

date and management practices. LANL-CCP representatives track the radiological 

characterization status of each container on the AK tracking spreadsheet. However, it was 

impossible to determine the traceability presented in Table 6 based solely on records review, as 

some source documents (such as M009) did not include the soil waste stream (LANL-CCP 

revised M009 to include this information). EPA interviewed LANL-CCP representatives to 

obtain a better understanding of drum traceability. EPA ascertained that containers are generally 

traceable from the point of origin to their current location, although this process required 

examination of several different source documents and databases. Table 6 verifies the drum 

contents and transfer information for the seven containers chosen and demonstrates that 

container information is traceable from waste generation through the characterization process. 
15

Table 6. Traceability of Selected Containers in Waste Stream LA-MSG04.001 

CCP 

Drum 

Number 

Original 

LANL 

Drum or 

Container 

Number 

Original 

Container 

Type

a

Date of Drum 

Generation

a

Drum Receipt at 

Area G and 

Subsurface 

Storage 

Locationa 

Transfer 

from Area G 

Subsurface 

Location to 

Pad 

Repackaging 

Information 

and Date 

CCP-TP-005 

Attachment 

8 Generation 

Date (date 

accepted at 

Area G for 

storage) 

Final Wa

Contain

66122 66122 Standard Waste Box 4/14/11 

Not applicable, 

sent directly from 

MDA B to 

Pad 1b,c

Not 

applicable, 

sent directly 

from MDA B 

to Pad 1a,b,c

Not applicable, 

sent directly 

from MDA B 

to Pad 1a,b,c

4/14/11 Standar

Waste B

89982 S813240 Crate 

Original Crate 

S813240 

3/10/80, closure 

date 1/27/81 

1/29/81 Pit 1 1998

d

Repackaged 

9/13/11 at 

Building 412

e

1/29/81 55-Gallo

Drum 

89983 S813240 Crate 

Original Crate 

S813240 

3/10/80, closure 

date 1/27/81 

1/29/81 Pit 1 1998

d

Repackaged 

9/13/11 at 

Building 412

e

1/29/81 55-Gallo

Drum 

89987 S813240 Crate 

Original Crate 

S813240 

3/10/80, closure 

date 1/27/81 

1/29/81 Pit 1 1998

d

Repackaged 

9/13/11 at 

Building 412

e

1/29/81 55-Gallo

Drum 

S780204 S780204 55-Gallon Drum 2/6/78 2/15/78 Pit 9 N/A, still in Pit 9 N/A, still in Pit 9 2/15/78 TBD, bas

on conditio

retrieva

S794044 S794044 Crate 7/5/79 7/19/79 Pit 1 1998

d

During 

repackaging, 

determined to 

be LLW 

7/23/12

f

7/19/79 Unknown 

LLW stre

S813323 Crate 4/29/80 12/8/81 Pit 2 1998

d

During 

repackaging, 

determined to 

be LLW 

7/23/12

f

12/8/81 Unknown 

LLW stre

a Reference M020, radioactive solid waste disposal or TRU waste storage records. b TA-54 database (as presented in the AK tracking spreadsheet). c References P035 and P036 applicable to 18 Standard Waste Boxes. d Reference M008, CONCERT database. e Reference M009, AKIR database. f CCP Waste Data System.
16 

(8) The defense origin of transuranic wastes was examined and found to be adequate. 

The TRU waste streams to be emplaced in the WIPP must be “defense” waste. LANL-CCP 

states that, based on DOE guidance, a waste is defense in origin if it was generated “in whole or 

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

Waste Policy Act of 1982 (NWPA).” The AKSR states that, while both defense and nondefense 

activities were performed at TA-21, the waste contains radionuclides that originated from atomic 

energy defense activities, including defense nuclear materials production, byproducts 

management and research and development (Reference D059). Defense-related activities 

included the Hanford Ash Program, the objective of which was to produce driver fuel for the 

liquid metal fast breeder reactor program at Hanford (References C002 and C022). Also, 

research and development operations were conducted at TA-21 that were ultimately used in 

national defense applications. For example, the AKSR states, “the LANL Space Heat Source 

Program not only provided R&D [research and development] results that were directly applied to 

military applications at both LANL and other Atomic Energy Commission sites, but also used 

Pu-238 derived from a defense reactor to produce heat source materials that were incorporated 

into those applications. There were no possible distinctions between operations and materials 

that supported the non-defense space program and the similar requirements of some defense 

programs that benefited simultaneously” (References C001, C002, C003, C022, D014, D032, 

D049 and D050). 

Pu production focused on extraction and recovery of Pu from materials that originated from both 

defense and nondefense activities, but individual containers cannot be traced to a solely 

nondefense origin due to waste commingling (References D059 and M020). The isotopic 

distribution of radionuclides in soil cannot be used to support a defense origin for those 

radionuclides (References C009, C021, D020, D025, D026, D027 and D029). Based on the 

AKSR, the supporting references and DOE’s guidance regarding defense waste, this waste 

stream is defense in origin. 

(9) The presence of spent nuclear fuel and high-level waste status was evaluated, and this 

waste stream was found to be in compliance with the Waste Isolation Pilot Plant Land 

Withdrawal Act. 

The WIPP Land Withdrawal Act prohibits the disposal of spent nuclear fuel (SNF) and highlevel waste (HLW) as defined by the NWPA at the WIPP. The NWPA states that SNF is “fuel 

that has been withdrawn from a nuclear reactor following irradiation, the constituent elements of 

which have not been separated by reprocessing. SNF may not include test specimens irradiated 

for research and development only (i.e., these may be classified as waste when it is technically 

infeasible, cost prohibitive, or would increase worker exposure).” HLW is defined by the NWPA 

as “the highly radioactive material resulting from the reprocessing of spent nuclear fuel, 

including liquid waste produced directly in reprocessing and any solid material derived from 

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

radioactive material that the Commission, consistent with existing law, determines by rule 

requires permanent isolation.” Waste Stream LA-MSG04.001 contains radioactive material 

derived from Pu processing and related operations that did not involve the use of SNF or 

reprocessing of constituent elements from reactor fuel. Therefore, the soils are neither SNF nor 
17 

HLW, have not been historically managed as HLW and, therefore, are eligible for disposal at the 

WIPP (References D058, D059 and D060). 

(10) Waste stream profile form preparation and completeness were evaluated and found to be 

adequate. 

LANL-CCP provided a draft waste stream profile form (WSPF) to demonstrate its ability to 

prepare this required document. The WSPF did not include the characterization information 

summary or summation of aspects typically attached to the profiles, presumably because neither 

were yet prepared. EPA expects that both items will be included with the final WSPF. EPA 

assumed that the references cited in section 27 of the WSPF are the same as those cited in the 

AKSR, and EPA found the following issues related to the draft WSPF: 

• References cited in Item 27D were not waste packaging logs. 

• References M004, M008 and M009 in Item 27F did not address TA-21 soils. References 

D017 and P035 in Item 27H were not representative of industry standard documents, as 

D017 was an historical Rocky Flats document pertaining to pyrochemical salts and P035 

contained MDA B-specific packaging requirements. 

• Reference D017 in Item 27K did not contain sampling and analysis data from a surrogate 

waste form, as this reference addresses pyrochemical salts and reactivity, not soils. 

LANL-CCP revised the draft WSPF to reference the correct source documents. Notification of 

availability of a final approved WSPF, including the characterization information summary and 

summation of aspects, continues to be a T2 change. The applicable T2 designation in Table 1 

was modified to specify that completion of or revision to the WSPF attachments (e.g., 

characterization information summary and summation of aspects) is a notification requirement. 

(11) Training for acceptable knowledge personnel was examined and found to be adequate. 

CCP-TP-005, Revision 24, references CCP-QP-002, Revision 31, for AK training. This requires 

that personnel assigned to compile, evaluate and resolve AK discrepancies have training in the 

following areas: 

• WIPP Waste Analysis Plan briefing. 

• WAC knowledge. 

• Federal and state Resource Conservation and Recovery Act regulations associated with 

solid and hazardous waste determinations. 

• Knowledge of CCP procedures associated with: 

o Waste characterization using AK. 

o CCP AK records development, including AK discrepancy resolution. 

o Nonconformance report (NCR)/corrective action report process. 

o Knowledge of resolving and managing prohibited items as noted in 

nonconformance reporting. 
18 

The LANL-CCP lead SPM is responsible for ensuring that LANL-CCP personnel are qualified 

and trained to perform their assigned job functions. Ms. Veronica Waldram is the SPM; because 

EPA recently reviewed her qualifications during a separate inspection, EPA did not re-examine 

them as part of this T1 review. 

LANL-CCP provided qualification cards for AKEs Jim Shoen, Randy Fitzgerald and Michael 

Papp indicating that their training with respect to the WIPP permit, WAC, CCP Procedures CCPTP-001 through 005, CCP Procedures CCP-PO-001 through 003, CCP Procedure CCP-PO-505, 

CCP Procedures CCP-QP-004 through 008, and CCP Procedure CCP-QP-036 is current as of 

June 2011. The qualification cards did not specify any procedural revision dates and clearly 

could not apply to CCP-TP-005, Revision 24, which was approved in November 2011. Quality 

and Management Integrated System (QMIS) screen shots verified that Randy Fitzgerald had read 

the most recent version of CCP-AK-LANL-10, Revision 5; EPA determined that Mr. Papp and 

Mr. Shoen were authors of the document and therefore did not require QMIS verification. EPA 

determined that these individuals were familiar with the updated waste characterization 

procedures and that LANL-CCP demonstrated adequate training for AK personnel. 

(12) Preparation of nonconformance reports was evaluated and found to be adequate. 

LANL-CCP provided two NCRs for this waste stream associated with NDA BDRs. Each 

addressed “insufficient AK or isotopic information for analysis.” LANL-CCP AKEs clarified 

that the NCRs were issued because 241Am was detected on assay but was not addressed in the 

AKSR. The NCRs and affected drums in this waste stream are as follows: 

• NCR-LANL-3636-11 for soil Drum Nos. 89987, 89985, 89984 and 89983. 

• NCR-LANL-3637-11 for soil Drum Nos. RL-6043-11, 89988, 89986, 89892 and 89891. 

The NCRs were dispositioned by the AK-NDA memorandum and a revised AKSR, as stated in 

NCR-LANL-3636-11 and NCR-LANL-3637-11: “CCP-AK-LANL-010 Rev. 5 and the 

corresponding LA-MSG04.001 NDA memo have been issued, so the analysis and S4000 drums 

in BDRs 1LANDA1470 and 2LANDA0878 are now compliant with AK. NCR-LANL-3636 and 

NCR-LANL-3637 can now have a final disposition of ‘use-as-is.’” A LANL-CCP AKE stated 

that an AK re-evaluation and discrepancy resolution report are typically issued when AK-NDA 

discrepancies are found. However, the AKSR was in the process of being revised when NCRLANL-3636-11 and NCR-LANL-3637-11 were issued, so the AKSR was updated to comply 

with radioassay data and no discrepancy resolution was issued. LANL-CCP also provided NCRLANL-3697-11 and discrepancy resolution DR007, which were prepared when Container No. 

S843289 was found to contain more than 50% debris. Preparation of NCRs was adequately 

demonstrated. 

(13) Acceptable knowledge accuracy was assessed and found to be adequate. 

LANL-CCP AKEs confirmed that an AK accuracy report has not yet been prepared, even though 

radiological characterization has been completed for two NDA BDRs. EPA has examined the 
19 

AK accuracy process for several waste streams and found it to be adequate. Notification of the 

availability of a completed AK accuracy report for this waste stream remains a T2 change. 

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

LANL-CCP personnel indicated that load management would not be performed by LANL-CCP. 

(15) Nondestructive assay–acceptable knowledge communication was assessed and found to 

be adequate. 

CCP-TP-005, Revision 24, requires preparation of an AK-NDA memorandum that presents how 

AK will be applied during assay, including a discussion of its limitations. LANL-CCP provided 

the AK-NDA memorandum, but the radionuclide distribution it presented differed from the 

AKSR, as did the predominant radionuclides by weight. LANL-CCP revised the AK-NDA 

memorandum to be consistent with the AKSR. 

The AK-NDA memorandum states that limitations associated with AK data include “zero assay” 

values for some containers that are inconsistent with MTs associated with TA-21 soil. The 

AK-NDA memorandum reported a large-gram value of 244Pu in one container (the origin of 

which is unknown and may be an error). Radioassay of the waste stream will be performed using 

HENC Nos. 1 and 2 and the SuperHENC. LANL-CCP proposed to use AK in the radiological 

characterization process as follows: 

• When gamma isotopic measurements fail or are suspect, AK will be used to determine 

the plutonium isotopic distribution. 

• The radiological expert analyst (EA) will determine when AK is used and will also 

determine the “representativeness of the AK isotopics for each particular measurement.” 

The EA will determine the appropriate AK-based isotopics for the measurement. 

• The final determination of whether measurement results confirm AK will be made by the 

SPM during lot evaluation and preparation of AK confirmation checklists. 

• The AKE will provide container-specific information to the EA, and all AK used by the 

EA will be included in the BDRs. 

LANL-CCP did not provide an AK re-evaluation checklist specific to radioassay, and the AKEs 

confirmed that, to date, EAs have not used AK to determine isotopic distributions. The LANLCCP AK tracking spreadsheet includes radiological information for the EAs’ use. 

Notification of availability of AK-NDA memoranda and updates of those memoranda for all 

LANL CH waste streams continues to be a T2 change. 

Summary of Acceptable Knowledge Findings and Concerns

EPA did not identify any findings or concerns during this T1 evaluation and there are no open 

issues relative to this T1 evaluation. 
20 

Changes to Tiering

Based on the results of this T1 evaluation, EPA has revised the AK T2 designations to add 

notification of availability of all new and revised AKSRs as a T2 change and to specify that 

completion of or revision to the WSPF attachments (e.g., characterization information summary 

and summation of aspects) is a notification requirement. For consistency, all of the T2 elements 

listed under AK in Table 1 apply to all approved LANL CH TRU waste streams.

Acceptable Knowledge Approval

Based on this evaluation, EPA approves this T1 change. LANL-CCP is approved to characterize 

SCG S4000 CH TRU waste, consistent with the limitations specified in this report. 

6.2 Real-Time Radiography 

Waste Characterization Element Description

EPA reviewed RTR BDRs to support DOE’s Tier 1 request for Waste Stream LA-MSG04.001, 

SCG S4000. This is a CH waste stream. EPA reviewed the containers that were subject to RTR 

examination in September 2011. EPA’s review included the RTR written procedure, audiovisual 

and written records, and operator training. 

Documents Reviewed

EPA reviewed the following documents and records: 

• BDR LA-RTR2-11-0116, both written and audiovisual records. 

• List of qualified individuals (LOQI) for the time periods covered by the BDRs. 

• CCP-TP-053, “CCP Standard Real-Time Radiography (RTR) Inspection Procedure,” 

Revision 11. 

• Demonstration-of-capability audiovisual recordings for two of the operators responsible 

for RTR of the subject containers. 

• Remote-handled radiography test drum inventory sheet for containers NDE-TEST-14 and 

INL-RH-NDE-TEST-14. 

• Remote-handled radiography training drum inventory sheet for containers NDE-Training09, NDE-Training-14 and NDE-Training-19. 

• CCCP Standing Order CCP-SO-LANL-50, Revision 0. 

Technical Evaluation

EPA randomly selected containers from the BDR and reviewed them to ensure that RTR data 

were generated in accordance with CCP’s procedure. 
21 

Before starting RTR operations, LANL-CCP verified that the resolution of the x-ray system met 

requirements by performing an image test pattern test. The number of line pairs per centimeter 

(lines-pair/cm) recorded for each day of operations met the minimum requirement of five linespair/cm. EPA verified, through review of the BDR, that data sheets were completed and signed 

as required. LANL-CCP performed the quality control examinations for the BDR; specifically, 

the replicate and independent observations. No NCRs were generated for this BDR. 

EPA reviewed demonstration-of-capability audiovisual recordings for two operators. EPA 

identified an issue in the training of one RTR operator (Dillard). The EPA Lead Inspector 

informed CBFO and LANL-CCP managers of the particulars of the issue in an email, dated 

October 22, 2012. EPA was concerned that the operator was not current in his training when he 

performed RTR on S4000 containers. Specifically, the training requirement was for operators to 

complete training containers semiannually or every six months, but the operator of concern 

performed training containers over eight months apart. The following excerpt from the EPA 

Lead Inspector’s email of October 22, 2012, provided the details supporting EPA’s issue: 

• CCP-QP-002, R. 33, section 4.3.2[D] states that training containers are 

completed semiannually 

• Dillard performed training container on 1/25/11 (record completed 2/1/11) 

• Dillard completed training container 9/29/11 (record completed 10/5/11) 

• RTR (S4000) examinations took place 9/26/11, with corrections on 9/28/11 

• LOQI for 9/26 &9/27 (the only ones provided for review) had Dillard as 

qualified with a note in red “Training cont. 09/2011” 

On December 4, 2012, EPA received LANL-CCP’s final response in the form of Standing Order 

CCP-SO-086, Revision 0, “Clarification of the Time Period for Performance of the RTR 

Semiannual Training Container Required by CCP-QP-002,” which stated that a two-month grace 

period would be applied to the RTR biannual training period if needed but would be structured to 

ensure that training took place every 6 months. EPA’s response was to require the grace period 

to be reduced to one month. LANL-CCP agreed to this change and subsequently provided the 

revised standing order to EPA (see Attachment C). 

Summary of Real-Time Radiography Findings and Concerns

RTR characterization activities for these drums were performed in accordance with required 

procedures by trained and qualified operators. 

Changes to Tiering

Based on the results of this T1 evaluation, there are no revisions to the RTR T2 designations. 
22 

Real-Time Radiography Approval

Based on this evaluation, EPA approves this T1 change. LANL-CCP is approved to characterize 

SCG S4000 CH TRU waste using RTR, consistent with the limitations specified in this report. 

7.0 CONCLUSIONS 

Summary of Findings and Concerns

EPA concluded that the waste characterization processes of AK, NDA and RTR that LANL-CCP 

used to characterize retrievably stored and newly generated SCG S4000 CH TRU waste are 

adequate. There were no findings or concerns, and there are no open issues relative to this T1 

evaluation. 

Tiering Changes

Based on the results of this T1 evaluation, EPA has revised the AK T2 designations to add 

notification of availability of all new and revised AKSRs as a T2 change and to specify that 

completion of or revision to the WSPF attachments (e.g., characterization information summary 

and summation of aspects) is a notification requirement. For consistency, all of the T2 elements 

listed under AK in Table 1 apply to all approved LANL CH TRU waste streams. No revision of 

T1 requirements was warranted. Consistent with EPA’s authority under 40 CFR 194.24(h), EPA 

may request any information relative to these activities if EPA deems it necessary to ensure 

continued compliance with EPA regulations. 

Approval

This T1 change consisted of the waste characterization processes of AK, NDA and RTR as 

evidenced by the records LANL-CCP generated in characterizing SCG S4000 CH TRU waste. 

Based on this evaluation, EPA approves LANL-CCP to characterize SCG S4000 waste, 

consistent with the limitations specified in this report. 
A-1 

ATTACHMENT A 

APPROVAL SUMMARY FOR LANL-CCP 

CONTACT-HANDLED WASTE CHARACTERIZATION PROGRAM 

Approved Activity EPA Inspection Number, Approval Dates Docket Number 

LANL-CCP CH Baseline Approval LANL-CCP-05.06-8 — June 21, 2007 A-98-49, II-A4-88 

T1 Change – Extension of range for the 

High Efficiency Neutron Counter No. 2 October 28, 2007 A-98-49; II-A4-91 

T1 Change – Extension of range for the 

High Efficiency Neutron Counter No. 1 December 7, 2007 A-98-49, II-A4-95 

T1 Change – Assay of lead-lined drums on 

the High Efficiency Neutron Counter 

No. 2 

November 10, 2010 A-98-49, II-A4-139 

T1 Change – Addition of the SuperHENC October 28, 2011 A-98-49, II-A4-153 

T1 Change – Calibration extension of High 

Efficiency Neutron Counter No.1 and 

SuperHENC 

August 14, 2012 A-98-49; II-A4-164 
B-1 

ATTACHMENT B 

LIST OF DOCUMENTS REVIEWED FOR THIS EVALUATION 

Acceptable Knowledge Expert (AKE) Qualification Cards, Randy Fitzgerald, Michael Pap and 

Jim Shoen, June 9, 2011 

Acceptable Knowledge Isotopic Ratio (AKSR) database printouts, provided September 23, 2012 

Area TA-55 412 Box Line Production Report, Drum Nos. 89993–89987, provided September 23, 

2012 

CCP-AK-LANL-006, Central Characterization Project Acceptable Knowledge Summary Report 

for Los Alamos National Laboratory TA-55 Mixed Transuranic Waste Streams: 

LA-MHD01.001, LA-CIN01.001, LA-MIN02-V.001, LA-MIN04-S.001, Revision 11, 

September 23, 2011 

CCP-AK-LANL-010, Central Characterization Project Acceptable Knowledge Summary Report 

for Los Alamos National Laboratory, TA-21 DP West Facility, Waste Streams: LA-MHD04.001, 

LA-MSG04.001, Revision 5, May 1, 2012 

CCP-SO-LANL-50, Revision 0 

CCP-SO-086, Revision 0, Clarification of the Time Period for Performance of the RTR 

Semiannual Training Container Required by CCP-QP-002, June 14, 2011 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, effective date 

November 28, 2011 

CCP-TP-005, Revision 24, AK Tracking Spreadsheet, July 7, 2012, and September 6, 2012 

CCP-TP-005, Attachment 1, Revision 24, Acceptable Knowledge Documentation Checklists, 

July 3, 2012 

CCP-TP-005, Attachment 4, Revision 24, Acceptable Knowledge Source Document Reference 

List, July 18, 2012 

CCP-TP-005, Attachment 6, Revision 24, Waste Form, WMPs, Prohibited Items, and Packaging, 

April 12, 2012 

CCP-TP-005, Attachment 7, Revision 24, Radionuclides (including AK-NDA memorandum), 

July 24, 2012, revised September 23, 2012 

CCP- TP-005, Attachment 8, Revision 24, Waste Containers List, August 7, 2012, revised 

September 23, 2012 
B-2 

CCP-TP-005, Attachment 10, Revision 24, Acceptable Knowledge Re-evaluation Checklist, 

November 3, 2009, and June 7, 2012 

CCP-TP-005, Attachment 11, Revision 18, Acceptable Knowledge Source Document 

Discrepancy Resolution Form (see DR007), provided September 23, 2012 

CCP-TP-053, CCP Standard Real-Time Radiography (RTR) Inspection Procedure, Revision 11 

CCP Waste Stream Profile Form, Waste Stream Profile Number: LA-MSG04.001, Draft 

September 6, 2012, revised September 23, 2012 

Container Certification (CONCERT) database printouts, provided September 23, 2012 

Correspondence from Los Alamos Site Office to James Bearzi, Bureau Chief, Hazardous Waste 

Bureau, New Mexico Environment Department, Request for Extension of Date for Submittal of 

Material Disposal Area T Remedy Completion Report, April 27, 2010 

Correspondence from Los Alamos Site Office to James Bearzi, Bureau Chief, Hazardous Waste 

Bureau, New Mexico Environment Department, RE: Request for Extension of Date for Submittal 

of Material Disposal Area A Investigation/Remediation Report, January 12, 2011 

C001, Correspondence from T. Keenan and J. Foxx, Plutonium-238 Heat Source Fabrication for 

Space and Artificial Heart R&D Activities at TA-21 West and CMR Building from 1970 to 

1978, TWCP-19811/P2010-0778, January 1, 2004 

C002, Correspondence from J. Foxx and C. Smith, TA-21 Operations at Buildings 2, 3, 4, 5 and 

150 and Pu-238 questions, TWCP-19433/P2010-0695, January 8, 2004 

C003, Correspondence from J. Foxx and C. Smith, Pu-238 Information at TA-21 West, TWCP19812/P2010-0777, January 8, 2004 

C009, Correspondence from J. Foxx and C. Smith, TA-21 DP West Plutonium-238 Operations, 

1970–1977, Purity of Pu-238 Feed Material, Commingling of Pu-238 with Other Material Types, 

TWCP-19900/P2010-0561, February 17, 2004 

C021, Correspondence from W. Schueler, Material Type Isotopic Compositions and Am-241 

Content in Solid Transuranic Waste Benchmark Environmental Corporation, AL-7193/LA-UR01- 6170, TWCP-0698, May 2, 1997 

C022, Correspondence from J. Foxx, Commingling of Defense and Nondefense TRU Waste, 

Memo to TWCP Records Center, LA-UR-02-6087, TWCP-0887, August 21, 1997 

C033, Correspondence from J. Schoen, Evaluation of Volume, Period Generation, and 

Calculation of Individual and Total Radionuclide Masses and Activities for Waste Stream 

LA-MSG04.001, September 30, 2009 
B-3 

C037, Correspondence from J. Schoen, Evaluation of Volume, Period of Generation and 

Calculation of Individual and Total Radionuclide Masses and Activities for Waste Streams 

LA-MHD04.001, LA-MSG04.001, April 4, 2012 

D006, Demolition of Building 12, An Old Plutonium Filter Facility, R. Garde, A. Valentine and 

E. Christensen, LA-5755, TWCP-18949, January 1975 

D008, Historic Building Assessment for the DOE Conveyance and Transfer Project, E. McGehee 

and K. Garcia, LA-UR-00-1003, TWCP-18951, Volume 1, Report No. 178, December 23, 1999 

D010, TA-21 Operable Unit RFI Work Plan for Environmental Restoration Los Alamos 

National Laboratory, LA-UR-91-0962, TWCP-19101, May 1991 

D014, Final Safety Analysis Report for TRANSIT RTG Volume 1, Reference Design 

Document—Introduction and Table 1-1, TRW Systems Group, TRW(A)-11464-0491, TWCP19438, March 1, 1971 

D016, Plutonium Research: Historical Role of DP-West in the Atom, V. Lees, TWCP-19768, 

Volume 4, Number 12, pp.1–8, December 1967 

D017, Backlog Waste Reassessment Baseline Book, Rocky Mountain Remediation Services, 

TWCP-02501, P2010-0670, January 4, 1995 

D020, K. Johnson, The Atom, Nuclear Power for an Artificial Heart, TWCP-19770, Volume 7, 

No. 6, June 1970 

D025, Fused Salt Processing of Impure Plutonium Dioxide to High-Purity Plutonium Metal, 

L. Mullins, D. Christensen and B. Babcock, TWCP-22580, LA- 9154-MS, January 1982 

D026, Los Alamos TRU Waste Certification Plan for Newly Generated TRU Waste, Los Alamos 

National Laboratory, LA-UR-02-6085/TWCP-00697, WCP-HSE7-CPL-01, November 1984 

D027, Direct Reduction of 238-PuO2 and 239-PuO2 to Metal, C. Foxx and L. Mullins, TWCP22581, LA-9073, February 1982 

D029, Six-Kilogram Scale Electrorefining of Plutonium Metal, A. Morgan, S. Apgar and 

D. Christensen, TWCP-22582, LA-9469-MS, September 1982 

D030, Plutonium Scrap Processing at the Los Alamos Scientific Laboratory, A Nixon, 

B. McKerley and E. Christensen, LA-UR-80-835, CONF-800303—12, Revision 0, 

March 24, 1980 

D032, Bi-Monthly Progress Report – Multi-Hundred Watt Radioisotope Thermoelectric 

Generator Program, C. Whitmore, TWCP-22029, June 30, 1975 
B-4 

D034, Final Documentation for RadWaste ORACLE Database’s List of Acceptable 

Radioisotopes, Specific Activities, Categories, and Regulatory Limits, D.Taggart, TWCP-8003, 

January 31, 1992 

D035, Los Alamos DP West Plutonium Facility Decontamination Project 1978–1981, R. Garde, 

E. Cox and A. Valentine, LA-9513-MS, TWCP-14396, September 1982 

D036, Process AK Report for Chloride Operations at TA-55, J. Musgrave, TWCP-15411, 

TWCP-AK-2.1-002, LA-UR-02-1710, LAUR-01-2557, Revisions 2 and 2/IC1, May 17, 2001, 

and March 31, 2002 

D049, Initial Development and Characterization of Plutonia-Iridium Cermets, M. Tokar, TWCP21979, LA- 5255-MS, undated 

D050, Data Sheets for PPO Radioisotopic Fuel, T. Keenan, R. Kent, R. Mulford and M. Shupe, 

TWCP-21978, LA-5160-MS, February 1973 

 

D058, Los Alamos National Laboratory Transuranic Waste Characterization Acceptable 

Knowledge Information Summary (AKIS), TWCP-PLAN-0.2.7-001, February 28, 2003 

D059, Acceptable Knowledge Operations Report for Plutonium Processing at the TA-21 DP 

West Facility (Draft Report), C. Smith, P2010-0608, TWCP 23596; AK-00-23, Revision 0, 

July 8, 2004 

D060, Acceptable Knowledge Information Summary for LANL Transuranic Waste Streams, 

AK-00-019, Revision 1, C. Smith, September 22, 2003

D069, A History of Waste Disposal at Technical Area 21 1943–1978, E. Merrill, March 1990 

DR007, Removal of One (1) Debris Container from Soil Waste Stream LA-MSG04.001, 

R. Fitzgerald, June 7, 2012 

Freeze File Changes, CCP-AK-LANL-010, Revision 5, September 6, 2012, and 

September 23, 2012 

Los Alamos National Laboratory Waste Profile 23358: Soil from MDA-B Enclosure Number 2, 

printed July 26, 2012 

Los Alamos National Laboratory, Information Sheet: Technical Area 21 Material Disposal 

Areas, ER2002-0466, printed September 17, 2012 

Los Alamos National Laboratory, Corrective Measures Evaluation Report for Material Disposal 

Area A, Solid Waste Management Unit 21-014, at Technical Area TA-21, LA-UR-08-5520, 

EP2008-0448, September 2008 
B-5 

M003, Waste Streams from Buildings TA-21, TA-55, TA-50, and TA-00 at LANL, Appendices 

B, C, D, E and F (Changes to Sampling Plan), TWCP-04138, TWCP Plan-0.2.7-001, Revision 2, 

June 4, 1999 

M004, TA-55 NMT Waste Management System (CONCERT Database) LANL, NMT division, 

undated 

M008, Excerpt from CONCERT Database, LANL, August 17, 2006 

M009, AKIR Database Extracted DP West (TA-21) Radionuclides in Grams, LANL AK-00-020, 

Revision 0, August 22, 2006 

M020, Radioactive Solid Waste Disposal/TRU Waste Storage Records for LA-MSG04.001, 

undated 

NCR No. NCR-LANL-3537-11, Revision 0, May 21, 2012 

NCR No. NCR-LANL-3636-11, Revision 0, May 21, 2012 

NCR No. NCR-LANL-3637-11, Revision 0, December 20, 2011 

NDA BDR Nos. 1LANDA1470, 1LANDA1470 and 2LANDA0878 

P030, Sort, Segregate, Size Reduction, and Repackaging Activity, S. Miller, EP-AREAGWODOP-0216, Revision 15, May 23, 2011 

P031, TA-54 Area G Sludge Remediation Activities, S. Miller, EP-AREAG-WODOP-0219, 

Revision 8, May 23, 2011 

P032, TA-54 Area G TRU Crate SSSR Activities, EP-AREAG-WODOP-0227, Revision 11, 

P. Newberry, February 13, 2012 

P035, MDA-B TRU Waste Container Packaging in SWBs, TA21-MDAB-00017, Revision 0, 

D. Allen, April 21, 2011 

P036, Waste Management Plan for Material Disposal Area (MDA) B, TA21-MDAB-PLAN00014, Revision 1, D. Allen, December 15, 2010 

P037, Waste Management Procedure for Environmental Program TA-21 Closure Project 

Activities (U), TA21-AP-00002, Revision 0, D. Allen, March 16, 2012 

Quality Management Integrated System (QMIS) Screen Shot for CCP-AK-LANL-010, 

Revision 5, electronic signature, Randy Fitzgerald, provided September 23, 2012 

RTR BDR No. LA-RTR2-11-0116 
B-6 

U001, A Brief History of C-AAC, no author cited, TWCP-19898, January 20, 2004 
C-1 

ATTACHMENT C 

CCP STANDING ORDER CCP-SO-086, REVISION 0 
C-2