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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

J.R. Stroble 

Director, National TRU Program 

Carlsbad Field Office 

U.S. Department of Energy 

P.O. Box 3090 

Carlsbad, NM 88221-3090 

Dear Mr. Stroble: 

APrt 7 2011 OFFICE OF 

AIR AND RADIATION 

This letter discusses the U. S. Environmental Protection Agency's (EPA) evaluation of a 

Tier 2(T2) change implemented at the Savannah River Site (SRS) by the Central 

Characterization Project (CCP). The enclosed report discusses EPA's evaluation results. 

In 2006, EPA approved SRS-CCP's contact-handled (CH) transuranic (TRU) waste 

characterization program. As part of that approval, implementation of new real time radiography 

(RTR) equipment similar to the one approved at the baseline was identified as a T2 change 

requiring no EPA approval prior to implementation. In January 2011, SRS-CCP began the use of 

the High Energy Large Container RTR (LCRTR) unit to characterize CH TRU debris waste 

packaged in standard waste boxes and Standard Large Boxes (SLB-2). At SRS-CCP, on 

February 1-2, EPA evaluated the use of this equipment and associated procedures and 

determined them to be technically adequate. EPA found no issues with SRS-CCP operation of 

the unit. Therefore SRS-CCP may continue to use LCRTR. 

In addition to an evaluation of the T2 change, EPA observed an audio/visual recording of 

Container # SR57053606. EPA observed this process to determine improvements made to 

address the concern EPA raised during the 2010 Hanford-CCP Baseline Inspection and a 2010 

Continued Compliance Inspection at Idaho National Laboratory. CCP informed that the revised 

guidelines for RTR operators were being implemented. EPA will continue to monitor this issue 

during future evaluations and inspections. 

lf you have any questions regarding this approval, please contact Rajani Joglekar (202 

343-9462) or Ed Feltcorn (202 343-9422). 

Sincerel 

(~ 

Tom Peake, Director 

Center for Waste Management and Regulations 

Intemet Address (URL) • http://www.epa.gov 

Recycled/Recyclable * Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper 
Enclosure 

cc: Electronic Distribution 

Alton Harris, DOE EM 

Courtland Fesmire, CBFO 

Norma Castaneda, CBFO 

Martin Navarrete, CBFO 

Dennis Miehls, CBFO 

Steve Zappe, NMED 

Ray Lee, EPA 

Allison Pangle, CTAC 

Site Documents 
I;nclosure 

"I'ier 2 Evalua6fion Report 

High Cnergy Large Container Real Time Rsudiography Unit at Savannah River Site 

On February 1-2, 2011, EPA performed a Tier 2(T2) evaluation of the High Energy Large 

Container Real-Time Radiography (LC RTR) unit manufactured by High Tech and operated by 

Central Characterization Project (CCP) at the Savannah River Site (SRS). An evaluation of this 

T2 change implemented at SRS was necessary since this unit is significantly different than an 

RTR unit EPA approved in July 2006 as part of the baseline inspection and approval process. 

This review was performed by Ms. Rajani Joglekar (EPA), Mr. Edward Feltcorn (EPA), and Ms. 

Dorothy Gill (SC&A). Personnel contacted during the inspection included: 

Name 

_— --- 

Affiliation 

-- ----------- -- -- 

Craig Simmons WTS/CCP 

Court Fesmire CBFO 

David Haar WTS/CCP 

Vijay Alreja VJ Technologies 

Buddy Fussell CCP 

Steve Halliwell VJ Technologies 

David McCoy VJ Technologies, RTR Operator/SME 

Andrea Huff VJ Technologies, RTR Operator 

Documents and Records Reviewed 

SRS-CCP provided the written and audio/visual records for Batch Data Report (BDR) Nos. 

SRLBR0001, SRLBR0002, SRLBR0003, and SRLBR0004 for EPA's review. While reviewing 

samples of RTR recordings from these BDRs, EPA observed that the recording for container 

FBLBOX3406, BDR No. SRLBR0003 was unclear, and "black blobs" appeared on the image 

throughout the recording. The other recordings reviewed during the on-site evaluation were of 

sufficient visual clarity and demonstrated that RTR data were generated in accordance witlt 

required processes and procedures. Therefore, EPA asked SRS-CCP to verify whether that was 

an artifact of the copying process. SRS-CCP was unable to explain the origin of this effect and 

offered to reexamine this container. Following the site visit, SRS-CCP provided the 

supplemental DVD recording to EPA for review. The "blobs" were not present on the second 

recording and EPA determined that SRS-CCP satisfactorily addressed this issue. 

Trainin~ 

At the time of the evaluation, there were two operators performing RTR examinations on large 

containers. These operators are employed by VJ Technologies, but are trained and qualified by 

SRS-CCP to perfonm RTR on large containers. The EPA team reviewed the training and 

qualification records for the operators and determined that the operators were adequately trained 

to generate RTR data on the LC RTR unit. SRS-CCP Site personnel provided on-the job training 
to the operators for 1-2 months before the operators independently commenced routine 

operations. EPA reviewed the List of Qualified Individuals for the time periods when BDR Nos. 

SRLBR0001, SRLBR0002 and SRLBR0004 were generated, and determined that the operators 

were qualified to perform the examinations. 

EPA reviewed the RTR recordings for the ongoing demonstration of capability for Standard 

Waste Boxes (SWBs) and drums for one of the SRS-CCP RTR operators and found them to be 

satisfactory. The SRS-CCP operators had received determination of liquid volumes training (Test 

12WAC). RTR operations require that a second operator perform quality control examinations 

in each batch in the form of an Independent Observation'and Replicate Scan. Neither of these 

operators can perform the required Independent Technical Review (ITR); this is performed by 

another SRS-CCP qualified RTR operator. SRS-CCP qualifies the ITRs separately for RTR on 

SWBs and drums. EPA did not identify any issues associated with training records. 

Proccdures 

CCP-TP-074, CCP LCNDE Operating Procedure, Revision 1, provides instruction for safe startup, operation, and shut-down of the LCRTR system. This procedure is outside of EPA's purview 

and was not reviewed during the on-site visit. CCP-TP-053, CCP Standard Real-Time 

Radiography (RTR) Inspection Procedure, Revision 9, is used to guide RTR operations and data 

recording. The procedure was revised prior to the commencement of operations to include a new 

Image Test device required by this RTR unit. Image tests are performed using three sieves of 

different mesh sizes. Sieve No. 6 must be viewable for the Image Test to be acceptable. 

Observation of Oaerations 

On February l, 2011 EPA observed the examination of Standard Large Box No. SR55680719, 

BDR No. SRLBR0005, from Waste Stream SRW026-221F-HET. The examination took place at 

SRS E Area, in Building 661-6E, Ce112 of the Low Activity Waste vaults. The Test Image check 

had already been performed satisfactorily for the day's operations and an audio/visual recording 

of the RTR event was recorded. Both sides of the box were examined and Waste Material 

Parameters (WMPs) recorded on CCP-TP-053, Attachment 2, CCP Radiography Data Sheet. The 

RTR operator did not pause the audio/visual recording during the time he entered data into the 

RTR data sheet. EPA determined that operations were performed correctly and in accordance 

with procedure CCP-TP-053. 

Conclusion 

EPA did not identify any issues during its on-site evaluation of RTR and determined that LC 

RTR data were generated in accordance with an approved procedure by qualified personnel.