# DOCKET NO: A-98-49; II-A4-153

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT:

EVALUATION OF THE SUPER HIGH EFFICIENCY NEUTRON COU NTER

(SuperHENC) NON DESTRUCTIVE ASSAY SYSTEM AT

THE LOS ALAMOS NATIONAL LABORATORY (LANL) CENTRAL

CHARACTERIZATION PROJECT

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air

Center of Federal Regulations

1200 Pennsylvania Avenue, NW

Washington, DC 20460

October 2011

# i 

# TABLE OF CONTENTS

Section Page

Abbreviations, Acronyms and Initializations .......

................................................... ....................... ii

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

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

2.0 Purpose of Tier 1 Evaluations .....................

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

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

................................................... ........................ 2

4.0 Scope of Evaluation ...............................

................................................... .......................... 2

5.0 Evaluation Team ...................................

................................................... ........................... 2

6.0 Evaluation of the LANL-CCP SuperHENC ..............

................................................... ...... 3

7.0 Summary of Results ................................

................................................... ......................... 9

LIST OF TABLES

Table 1. Evaluation Personnel .....................

................................................... ................................ 3

ATTACHMENTS

Attachment A.1 Replicate Testing SuperHENC Results for Container LASB01243

Attachment A.2 Replicate Testing SuperHENC Results for Container LASB01263

Attachment A.3 Replicate Testing SuperHENC Results for Container LASB01265

# ii 

# ABBREVIATIONS, ACRONYMS AND INITIALIZATIONS

AaS Add-a-Source

Am americium

BDR batch data report

CBFO Carlsbad Field Office

CCP Central Characterization Project

Cf californium

CFR Code of Federal Regulations

CH contact-handled

Ci curie

Cs cesium

DOE U.S. Department of Energy

EPA U.S. Environmental Protection Agency

Eu europium

FR Federal Register

FRAM Fixed-Energy Response Function Analysis with M ultiple Efficiencies

FWHM Full-Width-at-Half-Maximum

g gram

HENC High Efficiency Neutron Counter

HERTR High Energy Real-Time Radiography

HPGe high-purity germanium

keV kiloelectron volt

LANL Los Alamos National Laboratory

LLD lower limit of detection

LOQI list of qualified individuals

μCi microcurie

MDA minimum detectable activity

MDC minimum detectable concentration

MGA MultiGroup Analysis

NCC Neutron Coincidence Counting

nCi nanocurie

# iii



# NDA non-destructive assay

NIST National Institute of Standards and Technology

NMED New Mexico Environmental Department

Np neptunium

PDP Performance Demonstration Program

Pu plutonium

SGEAS SuperHENC Gamma Energy Analysis System

Sr strontium

SuperHENC Super High Efficiency Neutron Counter

SWB Standard Waste Box

T1 Tier 1

TMU Total Measurement Uncertainty

TRU transuranic

U uranium

WG weapons grade

WIPP Waste Isolation Pilot Plant

WTS Washington TRU Solutions

# 1



# 1.0 EXECUTIVE SUMMARY

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

of a Tier 1 (T1) change request in the form of the addition of the Super High Efficiency Neutron

Counter (SuperHENC) non destructive assay (NDA) sys tem. On July 5, 2011, the Carlsbad Field

Office (CBFO) requested approval of this T1 change. EPA conducted a T1 evaluation of the

SuperHENC onsite at Los Alamos National Laboratory (LANL) on August 16-17, 2011.

In accordance with 40 CFR 194.8(b), the U.S. Enviro nmental Protection Agency (EPA)

conducted Baseline Inspection No. EPA-LANL-CCP-05.0 5-8 of the Central Characterization

Project (CCP), located at LANL from May 3-5, 2005. As a result of this baseline inspection,

EPA approved the LANL-CCP waste characterization pr ogram with conditions and limitations

as documented in the LANL Baseline Final Inspection Report (see EPA Docket No. A-98-49, IIA4-88). This baseline approval specified three non- destructive assay (NDA) systems, two High

Efficiency Neutron Counters (HENCs) and one portabl e tomographic gamma scanner for

characterizing debris (S5000) and solid (S3000) was tes, respectively 1 

# . LANL-CCP requested

EPA approval of a Tier 1 (T1) change in the form of the addition of the Super High Efficiency

Neutron Counter (SuperHENC) for assaying Standard W aste Boxes (SWBs). Based on EPA’s

evaluation detailed in this report, EPA approves th e SuperHENC for assaying contact-handled

(CH) transuranic (TRU) wastes in SWBs containing fo ur 55-gallon drums of retrievably stored

S5000 debris waste and uncontained (loose) S5000 de bris waste

This report serves as EPA’s evaluation of the Super HENC at LANL-CCP as a T1 change. Using

the information provided in this report, EPA has de termined that the SuperHENC is adequate for

characterization of CH TRU waste. Changes to the ap proved components of the SuperHENC

system at LANL-CCP must follow the tiering requirem ents described in the baseline inspection

report issued for the LANL-CCP CH program (Docket N o. A-98-49, II-A4-88, June 2007).

2.0 PURPOSE OF TIER 1 EVALUATIONS

Any changes to the waste characterization activitie s from the date of the baseline inspection must

be in the LANL-CCP Baseline Final Report cited abov e. Under the changes to 40 CFR 194.8

promulgated in the July 16, 2004, Federal Register notice, EPA must perform a single baseline

inspection of a TRU waste generator site’s waste ch aracterization program and approve the

program. EPA’s approval must be based on the demons tration that the program’s components,

with applicable conditions and limitations, can ade quately characterize TRU wastes and comply

with the regulatory requirements imposed on TRU was tes 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.

Following EPA’s approval of waste characterization processes evaluated during the baseline

inspection, EPA is authorized to evaluate and appro ve, if necessary, changes to the site’s

approved waste characterization program by conducti ng additional inspections under the

1 

# NDA systems are typically not matrix-specific in t he same manner as other characterization techniques and

their approval is not tied to specific waste matrix categories (i.e., S3000 or S5000). Specifically, v irtually any

material within the system’s matrix calibration ran ge may be assayed.

# 2



# authority of 40 CFR 194.24(h). Under 40 CFR 194.24, EPA has the authority to conduct

continued compliance inspections to verify that the site continues to use only the approved waste

characterization processes to characterize the wast e and remains in compliance with all the

regulatory requirements. Based on the adequacies of the waste characterization processes

demonstrated during the baseline inspection, includ ing all conditions and limitations, EPA

specified which subsequent waste characterization p rogram changes or modifications must

undergo further EPA approval under 40 CFR 194.24. T his was accomplished by assigning a tier

level to each aspect of LANL-CCP’s characterization program. Tier 1 (T1) activities have more

stringent reporting requirements and require that D OE notify EPA, and that EPA provide

approval prior to implementation. The rule under wh ich baseline inspections are conducted can

be found in the Federal Register (Vol. 69, No. 136, pages 42571–42583 of July 16, 2 004).

3.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluatio n of a T1 change of the implementation of the

LANL SuperHENC NDA system (NDA PDP 2 

# Registration Number LA08/LAN7) for assaying

CH TRU wastes. This report documents the basis for EPA’s approval decision and explains the

results of the technical evaluation of the SuperHEN C at LANL-CCP. EPA’s final approval

decision regarding the LANL-CCP SuperHENC 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).

4.0 SCOPE OF EVALUATION

The scope of this evaluation was the operation of t he SuperHENC NDA system located at

LANL-CCP. The SuperHENC was evaluated with respect to its ability to identify and quantify

the activities of the 10 WIPP-tracked radionuclides , the lower limit of detection (LLD), total

measurement uncertainty (TMU), and other related te chnical aspects, including the performance

of replicate analyses of containers and the statist ical evaluation of those replicates as described in

Section 6 of this report.

5.0 EVALUATION TEAM

All personnel involved in the SuperHENC evaluation are listed in Table 1, along with each

person’s affiliation and function for the purpose o f this inspection.

2 

# PDP is the CBFO sponsored NDA Performance Demonstr ation Program.

# 3 Table 1. Evaluation Personnel

Personnel Affiliation Evaluation Function - Area of

Expertise

Edward Feltcorn US EPA HQ EPA Evaluation Team Leade r, NDA

Rajani Joglekar US EPA HQ EPA Inspector, NDA

Patrick Kelly SC&A EPA Inspector, NDA

Rose Gogliotti SC&A EPA Inspector, NDA

Dorothy Gill SC&A EPA Inspector, NDE

Norma Castaneda DOE/CBFO Observer/NTP Manager

Michael Sensibaugh CCP/WTS CCP Projects Manager

Joe Harvill CCP/WTS Technical Support, SuperHENC

Craig Simmons CCP/WTS Project Manager

Neil Dickes CCP/WTS Technical Support, SuperHENC

John Bevz CCP/WTS TRU Waste Engineering

Sean Stanfield CCP/Canberra Technical Support, Supe rHENC

Daphne Brotheis CCP NDE Lead Operator/ Escort

Tim Hall NMED Observer

Ricardo Maestas NMED Observer



# 6.0 EVALUATION OF THE LANL-CCP SUPERHENC

EPA inspected one SuperHENC NDA system that will be used to characterize CH TRU wastes

at LANL-CCP. The inspection occurred as an on-site evaluation of the SuperHENC system and

associated records and personnel at LANL on August 16-17, 2011. As part of the inspection,

EPA reviewed the following elements of the SuperHEN C process:

• Capability of the measurement hardware and software to perform the required analyses

• Technical adequacy of the NDA documents and procedu res

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

Attachment A identifies the objective evidence that was examined for EPA’s evaluation. The

following documents were examined to assess the LAN L-CCP SuperHENC:

• CCP-CM-032, CCP SuperHENC (High-Efficiency Neutron Counter) Equipment

Description, Draft, Revision 0), Draft D

• CCP-TP-059, CCP Operating the Super High Efficiency Neutron Counter (SuperHENC)

Using NDA 2000, Revision 0, May 4, 2011

• CCP-TP-103, CCP Data Reviewing, Validating, and Rep orting Procedure for the High

Efficiency Neutron Counter and the Super High Effic iency Neutron Counter Using

NDA2000, Revision 9, March 14, 2011

• CCP-TP-103, CCP Data Reviewing, Validating, and Rep orting Procedure for the High

Efficiency Neutron Counter and the Super High Effic iency Neutron Counter Using

NDA2000, Revision 10, DRAFT

# 4



# • CCP-TP-064, CCP Calibrating the High Efficiency Neu tron Counter and the Super High

Efficiency Neutron Counter Using NDA 2000, Revision 6, April 6, 2011

• LANL-SHENC3-NDA-1003, Calibration Report for the Su perHENC at Los Alamos

National Laboratory Including Passive Neutron and G amma Spectrometer Calibration

and Confirmation, Revision 0, May 12, 2011

• CI-SHENC-TMU-102, Total Measurement Uncertainty for the Los Alamos SuperHENC

with Gamma Spectroscopy, Revision 0, May 25, 2011

• CCP-AK-LANL-006, Central Characterization Project A cceptable Knowledge Summary

Report for Los Alamos National Laboratory TA-55 Mix ed Transuranic Waste, Waste

Streams: LA-MHD01.001, LACIN01.001, LA-MIN02-V.001, LA-MIN04-S.001,

Revision 10, May 4 2010

• CCP- LANL List of Qualified Individuals (LOQI), Jul y 27, 2011 and August 11, 2011

• CSM-01-06, Idaho National Laboratory Central Charac terization Facility Standard Waste

Box Matrix Surrogate Inspection Summary Report, Sep tember 18, 2006

• Sample SuperHENC BDR Nos. 3LANDA0003, July 15, 2011 ; 3LANDA0004, July 20-

21, 2011; and 3LANDA0005, July 21, 2011

During the inspection, the EPA inspection team memb ers assessed several technical elements of

the SuperHENC system that are detailed in Attachmen t A and are discussed below.

(1) The design and operational history of the Supe rHENC was assessed.

The SuperHENC system is located in a trailer on sit e at LANL in TA 54 on Pad 10 in Area G,

Building No. 547. The SuperHENC is a self-contained NDA unit that is physically housed in a

mobile manufactured enclosure made up of a “High-Cu be” freight container measuring

approximately 48 feet long by 8-1/2 feet wide by 13 -1/2 feet high. It has the capability to

measure SWBs, 55-gallon and 100-gallon product drum s and is used for TRU and non-TRU

waste container sorting using integrated neutron/ga mma algorithms.

The SuperHENC was previously deployed at the Hanfor d Site’s Plutonium Finishing Plant,

though it has never been certified for WIPP assays. It was moved to LANL where it was

refurbished to operate under the Canberra NDA2000 S oftware. LANL-CCP will use this system

to assay only SWBs, and LANL-CCP does not anticipat e a need to use the SuperHENC to assay

container types other than an SWB or wastes other t han S5000 debris. The addition of other

container types would require a T1 change.

The possible assay configuration for the SuperHENC is as follows:

• SWBs containing four 55-gallon drums of retrievably stored S5000 debris waste

• SWBs containing S5000 debris waste

This system consists of a passive neutron coinciden ce counter and two integral gamma-ray

spectrometers, the SuperHENC Gamma Energy Analysis System (SGEAS). The passive neutron

counter uses 260 3 

# He proportional counters in a 4- π geometry and an external 252 

# Cf source for

# 5



# the Add-a-Source (AaS) matrix correction function. The neutron component determines the mass

of spontaneously fissioning material in waste conta iners, referred to as the 240 

# Pu Effective 

# ( 240 

# Pu Eff 

# ).

The 240 

# Pu Eff 

# is defined as the amount of 240 

# Pu that would produce the observed true coincidence

rate, after correcting for the neutron moderation p roperties of the waste matrix. The system’s

calibration is based on measurements of a non-inter fering matrix and it includes a curve that

relates the measured doubles rate for each containe r with the 240 

# Pu Eff

# , as documented in LANLSHENC3-NDA-1003. An AaS correction factor is necess ary to effectively correct for cases

where the matrix and radioactive contents are non-u niform. The AaS correction curve is

sufficiently robust to enable corrections over a wi de range of materials or matrices. The

SuperHENC is operated by a custom-tailored version of the LANL Neutron Coincidence

Counting (NCC) software that controls data collecti on and analysis, AaS movements and all

calibration and exception handling functions.

The SGEAS consists of two high-purity germanium (HP Ge) detectors that function in two

modes: relative ratio mode, where isotopic ratios a re determined using the PCFRAM 3 

# isotopic

code; and absolute mode, where the quantities of sp ecific radionuclides are determined based on

analyzing gamma spectra. The gamma ray spectrometer s are appropriate for direct quantification

of plutonium-238 ( 238 

# Pu), 239 

# Pu, 240 

# Pu, americium-241 ( 241 

# Am), uranium-233 ( 233 

# U), 235 

# U, 238 

# U,

cesium-137 ( 137 

# Cs), and neptunium-237 ( 237 

# Np). The detectors use a multi-curve efficiency

calibration to compensate for variations in matrix density. The gamma spectrometers also are

used to acquire spectra for the determination of pl utonium isotopic ratios. Ratios are also

determined through MultiGroup Analysis (MGA) and Fi xed-energy Response-function Analysis

with Multiple-efficiencies (FRAM) software. Each de tector is covered with a combination tincopper filter. The filters are removable, although the instrument is not currently calibrated for use

without the filters or with any other filters.

Data acquisition and analysis are handled by Canber ra Genie 2000 and NDA 2000 software

working in concert. A reporting threshold is derive d for those radionuclides that are not directly

measured. Each waste container’s 234 

# U content is performed by application of scaling fa ctors that

are based on observed values for 235 

# U and 238 

# U. The determination of 90 

# Sr is performed by

application of a scaling factor based on 137 

# Cs.

There are no EPA technical concerns regarding the d esign and ability of the SuperHENC to

quantify the 10 WIPP-tracked radionuclides.

(2) The passive neutron and gamma calibrations of the SuperHENC had been performed as

required and adequately documented.

The original calibration of the SuperHENC was perfo rmed at Hanford; this calibration was never

used for WIPP waste characterization. The calibrati on of record for the LANL-CCP SuperHENC

was completed on May 12, 2011. This calibration was confirmed at LANL, and is documented in

LANL-SHENC3-NDA-1003. Calibration confirmation was performed with six measurements of

an empty SWB over a range of Pu loadings from 0.006 to 34.01 g 240 

# Pu Eff 

# (0.1 to 190 g Pu

3 

# PCFRAM or FRAM is an initialization for Fixed-Ener gy Response Function Analysis with Multiple

Efficiencies, a software code that is often used to determine the relative abundance (isotopic distrib ution) of

radionuclides in weapons grade (WG) Pu.

# 6



# Total). The acceptance criteria for accuracy (Perce nt Recovery) and precision (Percent Relative

Standard Deviation) were met for each of the six ru ns. The calibration itself is matrix

independent, and additional testing will be perform ed in the future through the Weekly

Interfering Matrix Checks that are required in DOE- WIPP-02-3122. The system’s stated

operational range for neutron assays is from the Lo wer Limit of Detection or LLD (discussed

below) to 34.0 g 240 

# Pu Eff



# . The stated range for gamma assays is the LLD to 3 25 g weapons grade

(WG) Pu, as stated in LANL-SHENC3-NDA-1003.

The calibration for the HPGe was performed using a set of NIST traceable sources. Three photon

lines from 152 

# Eu at 121.8, 344.8 and 778.9 keV are used for this calibration. This relationship is

checked daily to ensure that the 344.8 keV peak’s c entroid and Full-Width-Half-Maximum

(FWHM) are within predetermined criteria shown in L ANL-SHENC3-NDA-1003, Table 2.

Because the SGEAS is used in relative ratio mode on ly, there is no true gamma operational

range, although between 1 and 5 g of WG Pu are need ed to successfully execute FRAM,

depending on the matrix. These efforts are document ed in WTS CCP LANL SWB Summary

Report WIPP1-406914, Idaho National Laboratory Cent ral Characterization Facility Standard

Waste Box Matrix Surrogate Inspection Summary Repor t dated September 18, 2006. This is a

reasonable approach to procuring additional matrix standards suitable for the SuperHENC. At

this time, LANL-CCP stated that there was no plan t o calibrate the SuperHENC for other waste

containers.

There are no technical concerns regarding the passi ve neutron and gamma calibrations of the

SuperHENC.

(3) The total measurement uncertainty of assays pe rformed on the SuperHENC had been

determined and documented.

The determination of the total measurement uncertai nty (TMU) for the SuperHENC is

documented in CI-SHENC-TMU-102, Revision 0. Section 3 of this document addresses the

effects on the passive neutron assay of the contrib utions from source position, calibration

uncertainty and counting statistics, background, se lf-shielding, systematic end and spatial effects,

neutron multiplication and isotopics. The TMU is di fferent for each measurement because of

variations in matrix, radioactive content and measu rements conditions.

For the gamma component, the evaluation includes th e propagation of both random and

systematic uncertainties. Random uncertainties are derived from counting statistics and as

calculated by the analysis software. Systematic unc ertainties include those related to source

distribution effects and matrix non-homogeneities. It is assumed that individual uncertainty

components are statistically independent, allowing them to be added in quadrature. The primary

sources of uncertainty in the gamma analysis includ e: counting statistics; inferences from other

radionuclides present; matrix non-homogeneity; isot opic measurement uncertainty background

fluctuations; calibration source uncertainties; sou rce distribution within the matrix; and selfabsorption. These are discussed in detail in CI-SHE NC-TMU-102, Section 4. There are no

technical concerns regarding the determination and documentation of TMU for the LANL-CCP

SuperHENC.

# 7



# (4) The Lower Limit of Detection, including the mi nimum detectable concentration, of the

SuperHENC had been determined and documented.

The LLD was defined in CCP-PO-002, “CCP Transuranic Waste Certification Plan,” as:

That level of radioactivity which, if present, yiel ds a measured value greater than

the critical level with a 95% probability, where th e critical level is defined as that

value which measurements of the background will exc eed with 5% probability

.

In order to be able to discriminate TRU and non-TRU wastes, an NDA system must have an

LLD less than 100 nCi of TRU alpha activity per gra m (nCi/g) of waste. The LLD of any given

NDA measurement depends on the type of measurement (passive neutron or gamma), the

properties of the waste matrix being assayed, the d ata acquisition (measurement) time, and the

environmental background. For this reason, the LLD is expected to vary from drum to drum and

also may vary between measurements of the same drum . To determine the minimum detectable

activities (MDAs) for the ten WIPP-tracked radionuc lides, sets of three replicate measurements

were performed on one surrogate matrix SWB without radioactive sources. NDA 2000 software

calculated the MDAs from these measurements and the MDAs were then used to calculate the

minimum detectable concentrations (MDCs) based on t he surrogate matrix’s net weight. The

surrogate matrix used for the gamma MDA calculation s was plywood and cardboard. MDCs for

the gamma and neutron modalities were calculated in this way and are shown in LANLSHENC3-NDA-1003, Tables 7a and 7b. Only measured va lues that exceeded the reported LLD

for a measurement will be reported and used in calc ulations of derived quantities, such as total

TRU alpha activity and TRU alpha activity concentra tion. There are no technical concerns

regarding the technical derivation and application of LLDs and LLD equivalents relative to the

SuperHENC.

(5) EPA replicate testing of the SuperHENC was per formed and evaluated.

The purpose of the replicate testing performed as p art of this inspection is to provide EPA with

an independent means to verify that the SuperHENC c an provide consistent, reproducible results

for the determination of the quantity of 10 WIPP-tr acked radionuclides ( 241 

# Am, 137 

# Cs, 238 

# Pu,

239 

# Pu, 240 

# Pu, 242 

# Pu, 90 

# Sr, 233 

# U, 234 

# U and 238 

# U) and the TRU alpha concentration. This is normall y accomplished by requesting that the site reassay dr ums that were previously characterized on the

same system or instrument in order to demonstrate t he following:

• The instrument produces results consistent with the reported TMU by comparing the

sample standard deviation for a number of replicate measurements taken over several

hours or days to the reported TMU.

• The instrument provides reproducible results over l onger periods of time, such as weeks

or months, by comparing the results of the replicat e measurement(s) to the original

reported values.

EPA requested that LANL-CCP reassay three SWBs that EPA randomly selected from a list of

nine containers previously assayed on the SuperHENC . Two of the nine SWBs were rejected

from their initial assay and EPA chose the replicat es from the remaining seven. Each SWB was

# 8



# packed with four 55-gallon drums containing S5000 w aste, each of which had a valid assay from

one of the LANL-CCP HENC NDA instruments. At the ti me of this evaluation, the LANL-CCP

High Energy Real-Time Radiography (HERTR) unit was not operational. This unit is needed to

determine the fill height of S5000 wastes that have been directly loaded in an SWB. The 55-

gallon drums had a fill height from their initial a ssay on the HENC and the fill heights of the four

drums were used to determine the fill height of the SWB. This approach was used to demonstrate

the functionality of the SuperHENC and although eac h SWB assay met WIPP acceptance

criteria, none of the seven SWB assays will be used as the assay of record. This was discussed

with LANL-CCP and CBFO personnel and EPA determined that the assays provided sufficient

evidence of the SuperHENC’s functionality. As a cou rtesy, LANL-CCP agreed to provide EPA

with the first BDR containing waste assayed on the SuperHENC when the HERTR is

operational.

Due to the system’s short operational history, the list of potential candidates for replicate assays

was small, and the time between the original measur ement and the five replicates was short. EPA

chose four SWBs, Container Nos. LASB01243, LASB0126 3, and LASB01265, each of which

contained four previously-assayed 55-gallon drums o f S5000 debris waste, as discussed above.

Each SWB was reassayed five times on the SuperHENC and two statistical tests, a chi squared

(χ 2 

# ) test and a t test, were performed on the replicate analyses. Ana lytical data for each assay

event and results of the statistical analysis are i ncluded in Attachments A.1 through A.3.

The chi squared test on SWB Containers Nos. LASB012 43 and LASB01263 resulted in

significant

and highly significant flags, respectively, for the difference between the original

measurement assay values and the average of the fiv e replicate measurements for 237 

# Np. The

original 237 

# Np assay value for Container No. LASB01243 was 27.6 μCi, while the sample mean

for the five replicates was 28.7 μCi. This represen ts a relatively low activity of 237 

# Np to be

determined in the presence of concentrations of its progenitor ( 241 

# Am) approximately 200 times

higher (5.4 Ci), and the magnitude of the differenc e is small. The values for the five replicates

for 237 

# Np range from 20.3 to 32.8 μCi, with the original a ssay value occurring approximately in

the center of this distribution. The original assay value for Container No. LASB01263 for 237 

# Np

was 8 μCi, while the sample mean for the five repli cates was 7.8 μCi. Again, this represents a

relatively low activity of 237 

# Np to be determined in the presence of concentratio ns of its

progenitor at significantly higher concentrations, and the magnitude of the difference is small.

The values for the five replicates for 237 

# Np range from 6.2 to 9.5 μCi, with the original val ue

occurring approximately in the center of the distri bution. In both instances, the flags are due to

the variability in the five replicate assays. The 237 

# Np flags are of minimal concern mainly

because: 237 

# Np is not a WIPP-tracked radionuclide; the differen ces among the values in absolute

terms is small; and the decay of large concentratio ns of 241 

# Am can produce variability in the

237 

# Np content as were observed here, the statistical r esults notwithstanding. All other replicate

measurements for all three containers passed both s tatistical tests. There are no technical

concerns regarding the ability of the SuperHENC to provide consistent, reproducible results for

the determination of the quantity of 10 WIPP-tracke d radionuclides.

# 9



# 7.0 SUMMARY OF RESULTS

During this T1 evaluation, EPA evaluated the perfor mance of the LANL-CCP SuperHENC. The

EPA evaluation did not identify any concerns or fin dings related to the operation of the LANLCCP SuperHENC. Based on the results of this evaluat ion, EPA is approving the LANL-CCP

SuperHENC NDA system for assaying retrievably store d and/or newly generated wastes in the

following configurations:

• SWBs containing four 55-gallon drums of retrievably stored S5000 debris waste

• SWBs containing S5000 debris waste

This approval does not make any changes to the tier ing table provided with the baseline

approval, with the exception of adding the SuperHEN C. Changes to the approved components of

the SuperHENC system at LANL-CCP must follow the ti ering requirements described in the

LANL-CCP CH baseline inspection report.

# Attachments A.1 through A.3Attachment A.1 SuperHENC Replicate Testing Resultsfor Container LASB01243 (SWB)A-1Instrument: SuperHENCContainer: LASB01243, SWBOriginal Measurement Replicate #1 Replicate #2Quantity of ReportedAbsolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value UncertaintyUncertainty Value UncertaintyUncertaintyValue UncertaintyUncertainty233U Activity (Ci) N/AN/AN/A234U Activity (Ci) N/AN/AN/A238U Activity (Ci) N/AN/AN/A238Pu Activity (Ci) 5.30E+006.10E-011.15E-015.70E+003.30E-015.79E-026.10E+003.53E-015.79E-02239Pu Activity (Ci) 8.78E+001.00E+001.14E-019.44E+005.25E-015.56E-021.02E+015.68E-015.57E-02240Pu Activity (Ci) 2.67E+003.28E-011.23E-012.88E+002.06E-017.15E-023.10E+002.23E-017.19E-02242Pu Activity (Ci) 1.09E-031.31E-041.20E-011.17E-034.40E-043.76E-011.26E-038.47E-056.72E-02241Am Activity (Ci) 5.25E+006.00E-011.14E-015.13E+002.88E-015.61E-026.09E+003.42E-015.62E-0290Sr Activity (Ci) N/AN/AN/A137Cs Activity (Ci) N/AN/AN/ATRU Alpha Conc. (nCi/g) 1.16E+057.18E+036.19E-021.23E+053.78E+033.07E-021.35E+054.15E+033.07E-02Replicate #3 Replicate #4 Replicate #5Quantity of ReportedAbsolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value UncertaintyUncertainty Value UncertaintyUncertaintyValue UncertaintyUncertainty233U Activity (Ci) N/AN/AN/A234U Activity (Ci) N/AN/AN/A238U Activity (Ci) N/AN/AN/A238Pu Activity (Ci) 5.44E+003.14E-015.77E-024.84E+002.80E-015.79E-025.56E+003.21E-015.77E-02239Pu Activity (Ci) 9.02E+005.00E-015.54E-028.01E+004.46E-015.57E-029.21E+005.12E-015.56E-02240Pu Activity (Ci) 2.75E+001.96E-017.13E-022.44E+001.75E-017.17E-022.80E+002.01E-017.18E-02242Pu Activity (Ci) 1.12E-037.47E-056.67E-029.94E-046.66E-056.70E-021.14E-037.65E-056.71E-02241Am Activity (Ci) 5.39E+003.01E-015.58E-024.80E+002.69E-015.60E-025.51E+003.09E-015.61E-0290Sr Activity (Ci) N/AN/AN/A137Cs Activity (Ci) N/AN/AN/ATRU Alpha Conc. (nCi/g) 1.20E+053.65E+033.04E-021.06E+053.26E+033.08E-021.22E+053.75E+033.07E-02Attachment A.1 SuperHENC Replicate Testing Resultsfor Container LASB01243 (SWB)A-2Instrument:SuperHENCContainer:LASB01243, SWBOriginal MeasurementSampleRelativeQuantity ofReportedAbsoluteSampleStandardStandardInterest Value Uncertainty Mean Deviation Deviationχ2Pr(x<| 

# χ2|)t Pr(x<|t|)233U Activity (Ci) 0.00E+00N/AN/AN/AN/AN/AN/AN/AN/A234U Activity (Ci) 0.00E+00N/AN/AN/AN/AN/AN/AN/AN/A238U Activity (Ci) 0.00E+00N/AN/AN/AN/AN/AN/AN/AN/A238Pu Activity (Ci) 5.30E+006.10E-015.53E+004.58E-018.28E-022.25E+006.89E-01-4.54E-016.73E-01239Pu Activity (Ci) 8.78E+001.00E+009.18E+007.91E-018.62E-022.50E+006.44E-01-4.57E-016.71E-01240Pu Activity (Ci) 2.67E+003.28E-012.79E+002.39E-018.55E-022.12E+007.13E-01-4.74E-016.60E-01242Pu Activity (Ci) 1.09E-031.31E-041.14E-039.61E-058.46E-022.15E+007.07E-01-4.44E-016.80E-01241Am Activity (Ci) 5.25E+006.00E-015.38E+004.80E-018.91E-022.56E+006.35E-01-2.55E-018.11E-0190Sr Activity (Ci) 0.00E+00N/AN/AN/AN/AN/AN/AN/AN/A137Cs Activity (Ci) 0.00E+00N/AN/AN/AN/AN/AN/AN/AN/ATRU Alpha Conc. (nCi/g)1.16E+057.18E+031.21E+051.03E+048.52E-028.28E+008.19E-02-4.60E-016.70E-01Quantity ofInterestχ2Testt Test233U Activity (Ci) Not Applicable Not Applicable234U Activity (Ci) Not Applicable Not Applicable238U Activity (Ci) Not Applicable Not Applicable238Pu Activity (Ci)Not SignificantNot Significant239Pu Activity (Ci)Not Significant Not Significant240Pu Activity (Ci)Not Significant Not Significant242Pu Activity (Ci)Not Significant Not Significant241Am Activity (Ci)Not Significant Not Significant90Sr Activity (Ci) Not Applicable Not Applicable137Cs Activity (Ci) Not Applicable Not ApplicableTRU Alpha Conc. (nCi/g)Not Significant Not SignificantAttachment A.2 SuperHENC Replicate Testing Resultsfor Container LASB01263 (SWB)A-3Instrument: SuperHENCContainer: LASB01263, SWBOriginal Measurement Replicate #1 Replicate #2Quantity of ReportedAbsolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value UncertaintyUncertainty Value UncertaintyUncertaintyValue UncertaintyUncertainty233U Activity (Ci) N/AN/AN/A234U Activity (Ci) N/AN/AN/A238U Activity (Ci) N/AN/AN/A238Pu Activity (Ci) 3.73E+009.94E-012.66E-013.73E+009.75E-012.61E-013.61E+009.34E-012.59E-01239Pu Activity (Ci) 5.93E-011.58E-012.66E-015.94E-011.55E-012.61E-015.75E-011.49E-012.59E-01240Pu Activity (Ci) 1.59E-014.23E-022.66E-011.59E-014.15E-022.61E-011.54E-013.97E-022.58E-01242Pu Activity (Ci) 1.75E-044.66E-052.66E-011.75E-044.57E-052.61E-011.69E-044.38E-052.59E-01241Am Activity (Ci) 5.39E-011.44E-012.67E-015.40E-011.41E-012.61E-015.21E-011.35E-012.59E-0190Sr Activity (Ci) N/AN/AN/A137Cs Activity (Ci) N/AN/AN/ATRU Alpha Conc. (nCi/g) 1.60E+043.25E+032.03E-011.60E+043.19E+031.99E-011.55E+043.05E+031.97E-01Replicate #3 Replicate #4 Replicate #5Quantity of ReportedAbsolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value UncertaintyUncertainty Value UncertaintyUncertaintyValue UncertaintyUncertainty233U Activity (Ci) N/AN/AN/A234U Activity (Ci) N/AN/AN/A238U Activity (Ci) N/AN/AN/A238Pu Activity (Ci) 3.66E+009.59E-012.62E-013.90E+001.01E+002.59E-013.74E+009.72E-012.60E-01239Pu Activity (Ci) 5.82E-011.53E-012.63E-016.20E-011.61E-012.60E-015.95E-011.55E-012.61E-01240Pu Activity (Ci) 1.56E-014.08E-022.62E-011.66E-014.30E-022.59E-011.59E-014.14E-022.60E-01242Pu Activity (Ci) 1.72E-044.50E-052.62E-011.83E-044.74E-052.59E-011.75E-044.56E-052.61E-01241Am Activity (Ci) 5.28E-011.38E-012.61E-015.62E-011.46E-012.60E-015.41E-011.41E-012.61E-0190Sr Activity (Ci) N/AN/AN/A137Cs Activity (Ci) N/AN/AN/ATRU Alpha Conc. (nCi/g) 1.57E+043.14E+032.00E-011.68E+043.31E+031.97E-011.61E+043.18E+031.98E-01Attachment A.2 SuperHENC Replicate Testing Resultsfor Container LASB01263 (SWB)A-4Instrument:SuperHENCContainer:LASB01263, SWBOriginal MeasurementSampleRelativeQuantity ofReportedAbsoluteSampleStandardStandardInterest Value Uncertainty Mean Deviation Deviationχ2Pr(x<| 

# χ2|)t Pr(x<|t|)233U Activity (Ci) 0.00E+00N/AN/AN/AN/AN/AN/AN/AN/A234U Activity (Ci) 0.00E+00N/AN/AN/AN/AN/AN/AN/AN/A238U Activity (Ci) 0.00E+00N/AN/AN/AN/AN/AN/AN/AN/A238Pu Activity (Ci) 3.73E+009.94E-013.73E+001.10E-012.95E-024.89E-021.00E+001.66E-029.88E-01239Pu Activity (Ci) 5.93E-011.58E-015.93E-011.72E-022.89E-024.72E-021.00E+00-1.06E-029.92E-01240Pu Activity (Ci) 1.59E-014.23E-021.59E-014.55E-032.87E-024.63E-021.00E+004.01E-029.70E-01242Pu Activity (Ci) 1.75E-044.66E-051.75E-045.22E-062.98E-025.01E-021.00E+003.50E-029.74E-01241Am Activity (Ci) 5.39E-011.44E-015.38E-011.56E-022.90E-024.71E-021.00E+003.50E-029.74E-0190Sr Activity (Ci) 0.00E+00N/AN/AN/AN/AN/AN/AN/AN/A137Cs Activity (Ci) 0.00E+00N/AN/AN/AN/AN/AN/AN/AN/ATRU Alpha Conc. (nCi/g)1.60E+043.25E+031.60E+044.97E+023.10E-029.35E-029.99E-01-3.67E-029.72E-01Quantity ofInterestχ2Testt Test233U Activity (Ci) Not Applicable Not Applicable234U Activity (Ci) Not Applicable Not Applicable238U Activity (Ci) Not Applicable Not Applicable238Pu Activity (Ci)Not Significant Not Significant239Pu Activity (Ci)Not Significant Not Significant240Pu Activity (Ci)Not Significant Not Significant242Pu Activity (Ci)Not Significant Not Significant241Am Activity (Ci)Not Significant Not Significant90Sr Activity (Ci) Not Applicable Not Applicable137Cs Activity (Ci) Not Applicable Not ApplicableTRU Alpha Conc. (nCi/g)Not Significant Not SignificantAttachment A.3 SuperHENC Replicate Testing Resultsfor Container LASB01265 (SWB)A-5Instrument: SuperHENCContainer: LASB01265, SWBOriginal Measurement Replicate #1 Replicate #2Quantity of ReportedAbsolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value UncertaintyUncertainty Value UncertaintyUncertaintyValue UncertaintyUncertainty233U Activity (Ci) N/AN/AN/A234U Activity (Ci) N/AN/AN/A238U Activity (Ci) N/AN/AN/A238Pu Activity (Ci) 1.24E+003.27E-012.64E-011.19E+003.14E-012.64E-011.23E+003.25E-012.64E-01239Pu Activity (Ci) 7.94E+002.10E+002.64E-017.62E+002.01E+002.64E-017.89E+002.08E+002.64E-01240Pu Activity (Ci) 1.92E+005.06E-012.64E-011.84E+004.85E-012.64E-011.90E+005.03E-012.65E-01242Pu Activity (Ci) 3.28E-048.66E-052.64E-013.15E-048.31E-052.64E-013.26E-048.61E-052.64E-01241Am Activity (Ci) 1.90E+005.02E-012.64E-011.80E+004.76E-012.64E-011.89E+005.00E-012.65E-0190Sr Activity (Ci) N/AN/AN/A137Cs Activity (Ci) N/AN/AN/ATRU Alpha Conc. (nCi/g) 6.92E+041.19E+041.72E-016.62E+041.14E+041.72E-016.87E+041.18E+041.72E-01Replicate #3 Replicate #4 Replicate #5Quantity of ReportedAbsolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value UncertaintyUncertainty Value UncertaintyUncertaintyValue UncertaintyUncertainty233U Activity (Ci) N/AN/AN/A234U Activity (Ci) N/AN/AN/A238U Activity (Ci) N/AN/AN/A238Pu Activity (Ci) 1.22E+003.22E-012.64E-011.27E+003.36E-012.65E-011.23E+003.25E-012.64E-01239Pu Activity (Ci) 7.82E+002.06E+002.63E-018.15E+002.15E+002.64E-017.87E+002.08E+002.64E-01240Pu Activity (Ci) 1.89E+004.98E-012.63E-011.97E+005.19E-012.63E-011.90E+005.02E-012.64E-01242Pu Activity (Ci) 3.23E-048.53E-052.64E-013.37E-048.88E-052.64E-013.25E-048.59E-052.64E-01241Am Activity (Ci) 1.87E+004.95E-012.65E-011.95E+005.16E-012.65E-011.89E+004.98E-012.63E-0190Sr Activity (Ci) N/AN/AN/A137Cs Activity (Ci) N/AN/AN/ATRU Alpha Conc. (nCi/g) 6.81E+041.17E+041.72E-017.09E+041.22E+041.72E-016.86E+041.18E+041.72E-01Attachment A.3 SuperHENC Replicate Testing Resultsfor Container LASB01265 (SWB)A-6Instrument:SuperHENCContainer:LASB01265, SWBOriginal MeasurementSampleRelativeQuantity ofReportedAbsoluteSampleStandardStandardInterest Value Uncertainty Mean Deviation Deviationχ2Pr(x<| 

# χ2|)t Pr(x<|t|)233U Activity (Ci) 0.00E+00N/AN/AN/AN/AN/AN/AN/AN/A234U Activity (Ci) 0.00E+00N/AN/AN/AN/AN/AN/AN/AN/A238U Activity (Ci) 0.00E+00N/AN/AN/AN/AN/AN/AN/AN/A238Pu Activity (Ci) 1.24E+003.27E-011.23E+002.86E-022.33E-023.07E-021.00E+003.83E-017.22E-01239Pu Activity (Ci) 7.94E+002.10E+007.87E+001.90E-012.41E-023.26E-021.00E+003.37E-017.53E-01240Pu Activity (Ci) 1.92E+005.06E-011.90E+004.64E-022.44E-023.36E-021.00E+003.94E-017.14E-01242Pu Activity (Ci) 3.28E-048.66E-053.25E-047.89E-062.43E-023.32E-021.00E+003.24E-017.62E-01241Am Activity (Ci) 1.90E+005.02E-011.88E+005.39E-022.86E-024.60E-021.00E+003.39E-017.52E-0190Sr Activity (Ci) 0.00E+00N/AN/AN/AN/AN/AN/AN/AN/A137Cs Activity (Ci) 0.00E+00N/AN/AN/AN/AN/AN/AN/AN/ATRU Alpha Conc. (nCi/g)6.92E+041.19E+046.85E+041.68E+032.45E-027.95E-029.99E-013.81E-017.23E-01Quantity ofInterestχ2Testt Test233U Activity (Ci) Not Applicable Not Applicable234U Activity (Ci) Not Applicable Not Applicable238U Activity (Ci) Not Applicable Not Applicable238Pu Activity (Ci)Not Significant Not Significant239Pu Activity (Ci)Not Significant Not Significant240Pu Activity (Ci)Not Significant Not Significant242Pu Activity (Ci)Not Significant Not Significant241Am Activity (Ci)Not Significant Not Significant90Sr Activity (Ci) Not Applicable Not Applicable137Cs Activity (Ci) Not Applicable Not ApplicableTRU Alpha Conc. (nCi/g)Not Significant Not Significant