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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 PaperEnclosure

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 DocumentsI;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 trainingto 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.