DOCKET NO: A-98-49; II-A4-152

WASTE CHARACTERIZATION INSPECTION REPORT

PROPOSED APPROVAL 

EPA BASELINE INSPECTION NO. EPA-SNL-CCP-RH-06.11-8

OF THE CENTRAL CHARACTERIZATION PROJECT

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION 

PROGRAM FOR THE SANDIA NATIONAL LABORATORY:

March 8, 2011; May 10, 2011; June 7-8, 2011

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air

Center for Waste Management and Regulations

1200 Pennsylvania Avenue, NW

Washington, DC 20460

August 2011
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TABLE OF CONTENTS

Section Page

Acronyms and Initializations.........................................................................................................iii

1.0 Executive Summary............................................................................................................ 1

2.0 Purpose of Inspections........................................................................................................ 5

3.0 Purpose of This Report ....................................................................................................... 6

4.0 Scope of Inspection............................................................................................................. 7

5.0 Inspection-Related Definitions ........................................................................................... 8

6.0 Personnel............................................................................................................................. 8

7.0 Performance of the Inspection ............................................................................................ 8

7.1 Sandia National Laboratories Background ............................................................. 8

7.2 Inspection Process Overview................................................................................ 10

8.0 Technical Evaluation ........................................................................................................ 11

8.1 Programmatic Requirements and Acceptable Knowledge ................................... 11

8.2 Radiological Characterization............................................................................... 27

8.3 Visual Examination............................................................................................... 39

9.0 Response to Comments..................................................................................................... 41

10.0 Summary of Results.......................................................................................................... 41

10.1 Environmental Protection Agency Findings and Concerns.................................. 41

10.2 Conclusions........................................................................................................... 41

11.0 References......................................................................................................................... 44
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ATTACHMENTS

Attachment A: Documents Reviewed During the Baseline Inspection

Attachment B: Inspection Personnel List

Attachment C: EPA Inspection Issue Tracking Form No. SNL-CCP-RH-AK-11-01CR

LIST OF TABLES

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by SNL-CCP..... 4

Table 2. Summary of PKE Reports.............................................................................................. 9

Table 3. Batch Data Reports Examined ..................................................................................... 12

Table 4. PKE00044 Radionuclide Activity Ratio Comparison.................................................. 19

Table 5. Drum Traceability ........................................................................................................ 22

Table 6. Objective Evidence of Training for AK Personnel...................................................... 24

Table 7. PKE00044 Samples...................................................................................................... 31

Table 8. Measurement Technique Used for Each Radionuclide................................................ 32

Table 9. Reported Radionuclides in the Six Primary Samples .................................................. 32

Table 10. Scaling Factors for Waste Stream SNL-HCF-S5400-RH............................................ 33

Table 11. Overall Uncertainty of Example Drum........................................................................ 35

Table 12. Tiering of RH TRU Waste Characterization Processes Implemented by SNL-CCP... 43

LIST OF FIGURES

Figure 1. Characterization and Qualification Process................................................................. 14

Figure 2. Flow Diagram of the Characterization Process for SNL-HCF-S5400-RH.................. 29
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ACRONYMS AND INITIALIZATIONS

ACRR Annular Core Research Reactor

AK acceptable knowledge

AKE acceptable knowledge expert

AKSR acceptable knowledge summary report

Am americium

Ba barium

BDR batch data report

CBFO Carlsbad Area Field Office

CCP Central Characterization Project

CFR Code of Federal Regulations

CH contact-handled

Ci curie

CIS Characterization Information Summary

Co cobalt

CRR Characterization Reconciliation Report

Cs cesium

CSSF Correlation and Surrogate Summary Form

CTP Confirmatory Test Plan

DOE U.S. Department of Energy

DQO data quality objective

DR discrepancy resolution

DTC dose-to-curie

DU Depleted Uranium

EPA U.S. Environmental Protection Agency

Eu europium

EU Enriched Uranium

FR Federal Register

g gram or grams

g/cm3grams per cubic centimeter

HCF hot cell facility
iv

HLW high-level waste

HIP high pressure container

ICP Idaho Cleanup Project

ICP-MS Inductively Coupled Plasma-Mass Spectrometry

in inch or inches

IDL instrument detection limit

INL Idaho National Laboratory

ITR Independent Technical Reviewer

kg kilogram or kilograms

ICP-MS Inductively Coupled Plasma-Mass Spectrometry

LANL Los Alamos National Laboratory

LCS laboratory control sample

LLW low-level waste

LOQI list of qualified individuals

LWA WIPP Land Withdrawal Act

MCNP5 Monte Carlo N-Particle Transport Code RSICC Computer Code 

Collection, Oak Ridge National Laboratory

MP melt progression

mR/hr/Ci milli Roentgen per hour per Curie

mrem/hr millirem per hour

MT Material Types

nCi/g nanocurie per gram

NCR non-conformance report

NDE non-destructive examination

NPR New Production Reactor

NWPA Nuclear Waste Policy Act

OM other metal

ORIA Office of Radiation and Indoor Air

Pu plutonium

PKE Process Knowledge Evaluation

QA quality assurance

QAO quality assurance objectives

QAPD Quality Assurance Program Document
v

QC quality control

RC radiological characterization

RH remote-handled

RTR real-time radiography

RWNMDD Regulated Waste Nuclear Material Disposition Department

SAP sampling and analysis plan

SCB steel containment box

SCG summary category group

SNF spent nuclear fuel

SNL Sandia National Laboratories

SPM Site Project Manager

SQS Small Quantity Sites

Sr strontium

T1 Tier 1

T2 Tier 2

TA technical area

Th thorium

TMU Total Measurement Uncertainty

TRU transuranic

U uranium

VE visual examination

VEE visual examination expert

VEO visual examination official

WAC waste acceptance criteria 

WCPIP Waste Characterization Program Implementation Plan

WDS WIPP Waste Data System

WIPP Waste Isolation Pilot Plant

WMC waste matrix code

WMP waste material parameter

WSPF Waste Stream Profile Form

WWIS WIPP Waste Information System

Y yttrium
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1.0 EXECUTIVE SUMMARY

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

single remote-handled (RH) transuranic (TRU) debris waste stream characterized using the waste 

characterization program implemented by the Central Characterization Project (CCP) at Sandia 

National Laboratories (SNL), in Albuquerque, New Mexico.1In accordance with 40 CFR 

194.8(b), the EPA conducted Baseline Inspection No. EPA-SNL-CCP-RH-06.11-8 of the CCP’s

waste characterization program for RH TRU waste at the U.S. Department of Energy’s (DOE) 

SNL located in Albuquerque, New Mexico. Upon EPA’s final approval, DOE can emplace SNLCCP RH TRU debris waste in the Waste Isolation Pilot Plant (WIPP).

The inspection took place in three steps: observation of the Visual Examination (VE) and 

sampling process at SNL on March 8, 2011; dose-to-curie (DTC) measurements on May 10, 

2011 at SNL; and, the formal baseline inspection on June 7-8, 2011, held in Golden, Colorado. 

The inspection’s scope included one RH waste stream, SNL-HCF-S5400-RH, consisting of 

research and experimental debris generated at SNL from 1973 through 1992. This inspection 

evaluated: acceptable knowledge (AK) records; DTC, in conjunction with radionuclide-specific 

scaling factors supported by radiochemical analyses of smear2samples from the parcels; and VE 

to confirm the physical and radiological contents of waste containers.3EPA identified one 

concern during this inspection related to the lack of objective evidence showing training of AK 

personnel, as discussed in Section 8.1, (13) of this report. A copy of the EPA Inspection Issue 

Tracking Form that captures the finding is included in Attachment C of this report. The EPA 

inspection team completed their review of the documents submitted in response to the EPA 

concern and determined that the response is adequate. EPA considers this issue to be closed and 

no issues resulting from this baseline inspection remain open at this time

EPA is proposing to approve the SNL-CCP waste characterization program implemented to 

characterize RH debris waste from the waste group PKE00044 belonging to Waste Stream SNLHCF-S5400-RH that was evaluated during this baseline inspection and is documented in this 

report. The proposed approval includes the following:

(1) The AK process for 19 parcels of the retrievably-stored TRU debris waste from the waste 

group PKE00044 designated as SNL Waste Stream SNL-HCF-S5400-RH

(2) The radiological characterization process using DTC and scaling factors for assigning 

radionuclide values to 19 parcels of waste from the waste group PKE00044 from Waste 

Stream SNL-HCF-S5400-RH that is documented in CCP-AK-SNL-501, Revision 1, and 

supported by the calculation packages referenced in this report

 

1

SNL also has a site in California and reference to SNL in this report is an exclusive reference to SNL, 

New Mexico, unless otherwise stated.

2 A smear, wipe or swipe is a non-quantitative test for the presence of removable radioactive materials in 

which a surface or area is wiped with a filter paper or other substance, which is then assayed for specific 

radionuclides using destructive or nondestructive techniques. The SNL-CCP sampling efforts used Q-Tips or cotton 

swabs for this purpose, as used in this report.

3 Containers is a generic term which applies to cans, canisters, drums, and any other types of waste 

packaging units that may be characterized individually for their radiological and physical contents.
2

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

the debris waste SNL-HCF-S5400-RH

This baseline inspection evaluated SNL-CCP’s RH waste characterization program for technical 

adequacy and, when approved, SNL-CCP will continue to use the program components to 

characterize RH waste in accordance with the conditions and restrictions discussed in this report. 

Decontamination operations conducted at SNL from 1995–1997 produced a total of 32 parcels of 

RH TRU waste that comprise Waste Stream SNL-HCF-S5400-RH. During this inspection, 

however, EPA evaluated the characterization process for containers from a subset of this waste 

stream, specifically 19 waste parcels of the waste group PKE00044, referred to as PKE00044 in 

this report. The remaining 13 parcels of Waste Stream SNL-HCF-S5400-RH are in two other 

waste groups, PKE00047 with nine parcels and PKE00027/54 with four parcels. Both of these 

PKEs will require separate Tier 1 (T1) approvals prior to disposal of waste containers belonging 

to these groups at WIPP. Table 1 below identifies the proposed tiering changes based on the 

baseline inspection elements discussed in this report. 

Like some previous RH approvals, this proposed approval is limited to a specific number of 

waste containers in PKE00044. However, SNL-CCP may add containers to the approved SNL 

RH waste group, provided the following conditions are met:

1. Additional containers have a pedigree similar to the containers in PKE00044 

described in this report; and

2. SNL-CCP can demonstrate that the radionuclide scaling factors used for waste 

containers from PKE00044 proposed for approval in this report are technically 

appropriate for use in the DTC determination of the radiological characterization of 

the additional containers. 

Following EPA’s approval of SNL-CCP’s RH program, if additional RH debris waste containers 

meeting the above criteria are to be emplaced in the WIPP facility, EPA notification and 

submission of the appropriate supporting documentation will be necessary immediately upon 

identification and characterization of the additional containers. Upon receiving the AK and 

radiological content documentation for the newly-generated RH waste containers to be added to 

PKE00044, EPA will verify (a) the adequacy and applicability of the scaling factors discussed in 

this report to the additional containers, (b) the common radiological aspects of the 19 original 

parcels of PKE00044 and the additional containers, and (c) the technical adequacy of the AK 

documentation. EPA will evaluate this documentation and, upon determining it to be adequate, 

SNL-CCP may dispose of the additional containers at the WIPP facility.

If a population of additional containers requires new or different radionuclide scaling factors, 

those containers will require a T1 evaluation and approval prior to disposal at the WIPP. At the 

time of this inspection, radionuclide-specific scaling factors had only been developed for 19 

parcels of waste in PKE00044, as discussed in Section 8.1, below. Therefore, as stated above, 

this proposed approval pertains only to the 19 parcels in PKE00044.
3

In the future, if contact-handled (CH) information is used to characterize SNL-CCP RH waste 

containers, EPA may determine that evaluation of the applicable CH program is necessary. This 

evaluation would be warranted since the EPA has not reviewed the documentation that SNL, a 

small quantity generator, prepares as part of the inter-site transfer of CH TRU wastes to the 

Idaho National Laboratory (INL) for characterization and disposal.

EPA must verify compliance with 40 CFR 194.24 before waste may be emplaced in the WIPP, 

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

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

1998]. EPA Baseline Inspection No. EPA-SNL-CCP-RH-06.11-8 was performed in accordance 

with the provisions of 40 CFR 194.8(b), as issued in a July 16, 2004, FR notice (Vol. 69, 

No. 136, pp. 42571–42583).
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Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by SNL-CCP

(Based on June 6-8, 2011 Baseline Inspection)

RH Waste 

Characterization Process 

Elements

SNL-CCP RH Waste Characterization Process - T1 Changes SNL-CCP RH Waste Characterization Process - T2 Changes*

Acceptable Knowledge (AK) Two remaining waste groups (PKE00047 and PKE00027/54) belonging to a debris 

waste stream SNL-HCF-S5400-RH and any new RH waste stream not approved to 

date or modification of an approved waste stream to include additional containers 

if new or different radionuclide scaling factors are required (AK1)

Substantive modification(s)** that have the potential to affect the characterization 

process to CCP-AK-SNL-500 or CCP-AK-SNL-502 (AK2, AK6)

Notification to EPA: 

Upon completion of revisions of CCP-AK-SNL-500, CCP-AK-SNL-502,

CCP-TP-005, or nonconformance and corrective action procedures that 

require CBFO approval*** (AK2, AK5, AK6, AK14)

When the final or revised WSPF, CRR, and related attachments are available 

(AK10)

When AK accuracy reports are completed, prepared annually at a minimum 

(AK11)

When Attachment 4 of CCP-TP-005 is generated to reflect the updated 

AKSR Source Document Reference List (AK6)

When Add Container Memoranda have been prepared (AK5)

When additional Discrepancy Resolution Reports have been prepared (AK4)

If a CSSF is prepared (AK11)

Radiological Characterization

(RC), including Dose-To-Curie 

(DTC) 

Application of new scaling factors for isotopic determination other than those 

documented in CCP-AK-SNL-501 (RC4, RC5)

Use of any alternate radiological characterization procedure other than DTC with 

established scaling factors as documented in CCP-TP-504 and CCP-AK-SNL-501, 

Revision 1, respectively, or substantive modification** thereof (RC4, RC5)

Any new RH waste stream not approved to date or the addition of containers to an 

approved waste stream that requires changing the established radionuclide scaling 

factors or radiological characterization process (RC1)

Notification to EPA upon completion of revisions of CCP-AK-SNL-501 or CCPTP-504 that require CBFO approval*** (RC1, RC8)

Notification to EPA of availability of a revised radiological characterization report, 

if required for the addition of containers to the approved waste streams (RC5)

Visual Examination (VE) VE by reviewing existing audio/visual recordings for Summary Waste Category 

not covered by this approval (VE2)

VE by any new process for S5000 debris wastes (VE2)

Notification to EPA upon completion of changes to VE procedure(s) that require 

CBFO approval*** (VE1)

Addition of new S5000 debris waste streams (VE2)

Notes:

* SNL-CCP will report all T2 changes to EPA every three months.

** Substantive modification refers to a change with the potential to affect SNL-CCP’s RH waste characterization process, e.g., the use of an inherently different type of 

measurement instrument or the use of probes not described in CCP-TP-504, excluding changes related to solely to safety or to address administrative concerns

*** Notification to EPA is not necessary when document updates are editorial in nature or are required solely to address administrative concerns
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2.0 PURPOSE OF INSPECTIONS

On May 18, 1998, EPA certified that the WIPP would comply with the radioactive waste 

disposal regulations in 40 CFR Part 191. In that certification, EPA also included Condition 3, 

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

generator site other than [Los Alamos National Laboratory (LANL)] for disposal at the WIPP 

until the Agency has approved the processes for characterizing those waste streams for shipment 

using the process set forth in §194.8.” The approval process described in 40 CFR 194.8 requires 

DOE to (1) provide EPA with information on acceptable knowledge (AK)4for waste streams 

proposed for disposal at the WIPP, and (2) implement a system of controls used to confirm that 

the total amount of each waste component that will be emplaced in the WIPP will not exceed 

limits identified in the WIPP Compliance Certification Application. 

The rule applying to this baseline inspection can be found in the FR (Vol. 69, No. 136, 

pp. 42571–42583, July 16, 2004). Under the changes to 40 CFR 194.8 promulgated in the 

July 16, 2004, FR notice, EPA must perform a baseline inspection of a TRU waste generator 

site’s waste characterization program. The purpose of the 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. An EPA inspection team conducts an on-site inspection to verify that the site’s system 

of controls is technically adequate and properly implemented. Specifically, EPA’s inspection 

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

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

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

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

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

limiting value described in the introductory text of paragraph of this section.5The 

system of controls shall include, but shall not be limited to: measurement; 

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

schemes used; and other documentation. 

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

40 CFR 194 by assessing whether DOE sites that characterize TRU waste prior to disposal at the 

WIPP are capable of characterizing and tracking the waste. EPA may also conduct follow-up 

inspections to address issues remaining from the baseline inspection or to seek further 

 

4 As of the FR notice of July 16, 2004, EPA has replaced the term process knowledge with acceptable 

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

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

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

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

5 The introductory text of 40 CFR 194.24(c) states, “For each waste component identified and assessed 

pursuant to [40 CFR 194.24(b)], the Department shall specify the limiting value (expressed as an upper or lower 

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

limiting value, of the total inventory of such waste proposed for disposal in the disposal system.”
6

clarification/discussion related to waste characterization processes evaluated during a baseline 

inspection. By approving the CCP-implemented waste characterization systems and processes at 

SNL-CCP for RH debris waste, EPA confirms that it has evaluated the capabilities of systems 

and processes implemented by the site to accomplish two tasks: (1) identification and 

measurement of waste components, such as plutonium (Pu), that must be tracked for 

compliance,6and (2) confirmation that the waste in any given container has been properly 

identified as belonging to the group of approved waste streams. 

3.0 PURPOSE OF THIS REPORT

This report documents the basis for EPA’s proposed approval and explains the results of 

Baseline Inspection No. EPA-SNL-CCP-RH-06.11-8 in terms of findings or concerns. 

Specifically, this report does the following:

Describes the SNL-CCP waste characterization systems proposed for approval

Delineates a specific set of RH wastes proposed for approval

Provides objective evidence supporting the proposed approval basis for all waste 

characterization systems

Identifies all relevant system limitations and/or conditions for each waste characterization 

system and/or waste containers that are subject to this proposed approval

Provides objective evidence of EPA’s one concern, including its resolution and status

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

be reported to and, if applicable, approved by EPA, according to Table 1. Note that each T1 and 

Tier 2 (T2) change listed in Table 1 is followed by a reference to the report section where the 

technical basis for the T1 or T2 designation is presented. 

EPA will notify the public of the results of its evaluations of T1 and T2 changes established as 

part of the SNL-CCP final approval through the EPA Web site and by sending e-mails to the 

WIPPNEWS list. All T1 changes must be submitted for approval before their implementation 

and will be evaluated by EPA. Upon approval, EPA will post the results of the evaluations 

through the EPA Web site and the WIPPNEWS list, as described above. SNL-CCP must submit

T2 changes that have been implemented four times a year at the end of each fiscal quarter.

The DOE documents that EPA reviewed for this evaluation are cited throughout the report and 

are listed in Attachment A. Any of these documents can be requested from the following address:

 

6 The potential contents of a single waste stream or group of waste streams determine which processes can 

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

select the matrix-appropriate radiological characterization technique to obtain adequate radionuclide measurements. 

VE serves to confirm and quantify waste components, such as cellulosics, rubbers, plastics, and metals. Once the 

nature of the waste has been confirmed, characterization techniques quantify selected radionuclides in the waste. In 

some cases, a TRU waste generator site may be able to characterize a range of heterogeneous waste streams or only 

a few. A site’s stated limits on the applicability of proposed waste characterization processes govern the scope of 

EPA’s inspection.
7

Manager, National TRU Program

Carlsbad Field Office

U.S. Department of Energy

P.O. Box 3090

Carlsbad, NM 88221-3090

EPA’s final approval decision regarding the SNL-CCP RH waste characterization program will 

be conveyed to DOE separately by letter following EPA’s review of public comments received 

responding to the proposed approval discussed in this report. In accordance with 40 CFR 

194.8(b)(3), this information is also available on EPA’s Web site at 

www.epa.gov/radiation/WIPP.

4.0 SCOPE OF INSPECTION

The scope of Baseline Inspection No. EPA-SNL-CCP-RH-06.11-8 included the technical 

adequacy of the waste characterization systems used by SNL-CCP to characterize 19 parcels of 

RH TRU waste designated as PKE00044 contained in Waste Stream SNL-HCF-S5400-RH. The 

EPA inspection team evaluated these systems with respect to their ability to perform the 

following:

Provide adequate documentation regarding the origin and classification of the RH TRU 

wastes proposed for disposal at WIPP using AK

Identify and quantify the activities and associated uncertainties of the 10 WIPP-tracked 

radionuclides [americium-241 (241Am), cesium-137 (137Cs), plutonium-238 (238Pu), 239Pu, 

240Pu, 242Pu, strontium-90 (90Sr), uranium-233 (233U), 234U, and 238U] and other TRU 

radionuclides using a combination of AK and DTC with the application of radionuclidespecific scaling factors

Assign WMPs correctly for RH, retrievably-stored debris waste that was repackaged

using VE

During an inspection, EPA does not approve characterization data; that function is the sole 

responsibility of the entity being evaluated, in this case, SNL-CCP. EPA evaluates the site’s 

waste characterization processes to characterize RH TRU debris waste. The SNL-CCP 

evaluation consisted of reviewing training records and interviewing waste characterization 

personnel to assess their understanding of: (a) EPA’s waste characterization and WIPP waste 

disposal requirements; (b) waste characterization processes implemented and available as 

alternatives; and, (c) SNL-CCP’s documentation and record-keeping procedures. 

In addition, the EPA evaluation focused on observing equipment operations and waste 

characterization practices at SNL controlled by site procedures, and inspecting records related to 

each of the waste characterization processes within the inspection’s scope. An important aspect 

of this evaluation is the objective evidence documenting the effectiveness of the waste 

characterization processes. Objective evidence typically takes the form of batch data reports 

(BDRs), AK accuracy reports and VE records. During this inspection, EPA selected samples of 

each of these items, based on the number and variety of items each waste characterization 
8

process produced, consistent with standard auditing techniques. Based on evaluating the waste 

characterization processes in conjunction with the objective evidence, EPA determined the 

technical adequacy of these processes and associated records within the inspection’s scope.

DOE’s Remote Handled Waste Characterization Program Implementation Plan (WCPIP), DOE 

WIPP-02-3124, should be an accurate representation of the processes implemented to 

characterize RH TRU wastes for WIPP. Based on previous RH inspections conducted up to 

2010, EPA concluded that Revision 0 of the WCPIP did not adequately reflect the requirements 

for the processes approved by EPA. As a result, the DOE Carlsbad Field Office (CBFO) revised 

the WCPIP to adequately address RH waste characterization. CBFO approved the WCPIP, 

Revision 2 on April 21, 2011. EPA requires that all RH TRU waste characterization activities,

including the preparation of documentation and the documents themselves, conducted by SNLCCP comply with the revised WCPIP.

5.0 INSPECTION-RELATED DEFINITIONS

During the course of an inspection, EPA inspectors may encounter items or activities that require 

further inquiry for their potential to adversely affect waste characterization and/or isolation 

within the repository. The two main categories relevant to waste characterization inspections are 

identified below:

Finding: A determination that a specific item or activity does not conform to 

40 CFR 194.24(c)(4). A finding requires a response from CBFO prior to site approval.

Concern: A judgment that a specific item or activity may or may not have a negative 

effect on compliance and, depending on the magnitude of the issue, may or may not 

require a response. A concern requiring a response requires a response from CBFO prior 

to site approval. 

6.0 PERSONNEL

EPA and its support personnel conducted interviews with SNL-CCP personnel in several 

disciplines during two site visits to SNL and the meeting in Golden, Colorado. The members of 

the EPA inspection team and personnel contacted are listed in Attachment B.

7.0 PERFORMANCE OF THE INSPECTION

7.1 Sandia National Laboratories Background

SNL is located in Albuquerque, New Mexico. Its main focus has been to develop technical 

solutions to support national security and to counter national and international threats. Site 

activities support national needs in the area of nuclear weapons, nonproliferation and 

assessments, military technologies and applications, energy and infrastructure assurance, and 

homeland security.
9

Waste Generation Activities

CCP-AK-SNL-500 (AKSR) describes Waste Stream SNL-HCF-S5400-RH as consisting of 32 

waste parcels that are packaged in 29 containers; 27 of these are shielded and two are unshielded. 

The 32 waste parcels were generated during decontamination operations in the SNL7 Hot Cell 

Facility (HCF) from 1995–1997 (References I1030 and M1016). The HCF in the basement of 

Building 6580 provided support for reactor and other radiation facilities within Technical Area 

(TA)-V since the early 1960s. The waste originated from pre- and post-test processes associated 

with reactor fuel studies conducted in the HCF Steel Containment Boxes (SCBs), Zone 2A, and 

gloveboxes 1, 2, and 3 between the late 1970s and the mid-1990s. Melt Progression (MP) 

experiments, Source Term (ST) experiments, the Damaged Fuel experiment, and the New 

Production Reactor (NPR) experiments were conducted in the SCBs and Zone 2A (Reference 

P1102). 

All four experiments examined fuels pre- and post-irradiation in the Annular Core Research 

Reactor (ACRR); ST experiments were also conducted in gloveboxes 1, 2, and 3. Additionally, 

Fuel Disruption experiments, Sandia Transit Axial Relocation experiments, and Effective 

Equation of State experiments were performed in gloveboxes 1 and 2 (Reference P1015). The 

AKSR combines waste generated in the gloveboxes, SCBs, and Zone 2A into a single waste 

stream based upon: the similarity of waste generation processes and summary category groups; 

common sample storage areas; equipment sharing and overall cross-contamination between 

gloveboxes, and glove box areas (References C1004, M016, M019, P1015, P1102, and P1104).

Other SNL-CCP documents indicate that the radiological composition of waste from each area is 

distinct, and suggest that this distinction warrants dividing the waste into three separate waste 

streams. As discussed earlier, this report discusses only one waste group, PKE00044 belonging 

to RH Waste Stream SNL-HCF-S5400-RH. SNL-CCP determined that the radionuclide 

distributions in waste from the SCB/2A area and gloveboxes were different because different 

experiments and fuel types were used in the different areas. Regulated Waste/Nuclear Material 

Disposition Department (RWNMDD) personnel developed and used Process Knowledge 

Evaluation reports (PKEs) to establish radiological characterization of each parcel based on 

information provided in the disposal request (DR) documentation (Reference M1016). During 

decontamination of the HCF, there was little or no commingling between the waste generation 

sources (i.e., the SCB/2A area and the gloveboxes). The three PKEs that are presented in the 

AKSR as components of the single Waste Stream SNL-HCF-S5400-RH are summarized in 

Table 2.

Table 2. Summary of PKE Reports

Document Number Waste Generation Source Number of Parcels

PKE00044 SCBs and Zone 2A 19

PKE00047 Gloveboxes 1 and 2 9

PKE00027/54 Glovebox 3 4

 

7

In this report, the use of SNL refers to the host site and its past and present waste generation, management 

and storage activities. The use of SNL-CCP means the party responsible for the TRU waste characterization 

activities that are within the scope of EPA’s baseline inspection.
10

SNL-CCP is developing a separate set of scaling factors for each of the three groups described in 

Table 2 to account for the three distinct, area-specific radiological signatures. Therefore, this 

inspection and proposed approval are limited to the 19 parcels in PKE00044. [See Section 8.1, 

Item (1) for further discussion of the waste stream definition.]

Upon EPA approval of the RH waste characterization program and SNL RH waste group 

PKE00044, SNL-CCP may add containers to this waste group if the following conditions are 

met:

1. Additional containers must have a pedigree similar to the containers in PKE00044 

described in this report; and

2. SNL-CCP must able to demonstrate that the radionuclide scaling factors used for waste 

containers from PKE00044 proposed for approval in this report (discussed in Section 8.2, 

below) are technically appropriate for use in the DTC determination of the radiological 

characterization of the additional containers. 

Following EPA’s approval of SNL-CCP’s RH program, if additional RH debris waste containers 

meeting the above criteria are to be emplaced in the WIPP facility, EPA notification and 

submission of the appropriate supporting documentation will be necessary immediately upon 

identification and characterization of the additional containers. Upon receiving the AK and 

radiological content documentation for the newly-generated RH waste containers to be added to 

PKE00044, EPA will verify (a) the adequacy and applicability of the scaling factors discussed in 

this report to the additional containers, (b) the common radiological aspects of the 19 original 

parcels of PKE00044 and the additional containers, and (c) the technical adequacy of the AK 

documentation. EPA will evaluate this documentation and, upon determining it to be adequate, 

SNL-CCP may dispose of the additional containers at the WIPP facility. 

7.2 Inspection Process Overview

EPA conducted Baseline Inspection No. EPA-SNL-CCP-RH-06.11-8 of SNL-CCP’s program to 

characterize RH TRU wastes at SNL on two occasions from March through May 2011 and at the 

Courtyard Inn in Golden, Colorado from June 7 through 8, 2011. This inspection had the scope 

described in Section 4.0 for the purpose of determining the site’s compliance with 40 CFR 

194.24. The inspection was conducted in the following steps:

(1) Obtaining and reviewing site procedures, reports, and other technical information related 

to RH waste characterization activities used to characterize SNL-CCP Waste Stream 

SNL-HCF-S5400-RH

(2) Observing SNL-CCP personnel perform VE, sample collection and DTC at SNL on two 

separate occasions in 2011 in advance of the baseline inspection in Golden, Colorado 

during June 2011

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

above

(4) Interacting with CBFO and SNL-CCP personnel to arrange inspection logistics
11

(5) Evaluating SNL-CCP’s implementation of waste characterization processes for adequacy 

and demonstrating compliance with 40 CFR 194.24 requirements

(6) Conducting the baseline inspection to verify the technical adequacy and/or qualifications 

of RH waste characterization personnel, procedures, processes, and equipment, as 

documented in SNL-CCP records

(7) Evaluating the radiometric and spectrometric data used to support the development of 

radionuclide-specific scaling factors

(8) Evaluating the correlations of containers for the purpose of identifying common attributes

(9) Recording one concern on an EPA Inspection Issue Tracking Form, which was 

completed and provided to CBFO and SNL-CCP personnel as it was generated (see 

Attachment C for a copy of this form)

(10)Communicating all pertinent information to CBFO and SNL-CCP personnel

(11)Conducting entrance, exit, and daily briefings for CBFO and SNL-CCP management 

personnel for all four segments of the inspection

(12)Obtaining and reviewing SNL-CCP documents that were revised and/or created in 

response to the EPA concern after the inspection, and closing the concern

(13)Issuing the inspection report and proposed approval

8.0 TECHNICAL EVALUATION

Sections 8.1 through 8.3 of this report detail the three technical areas assessed during this 

inspection:

AK

Radiological Characterization 

VE

8.1 Programmatic Requirements and Acceptable Knowledge

EPA examined the programmatic requirements as specified in the WCPIP, Revision 2, dated 

April 21, 2011, and AK process and associated information to determine if SNL-CCP 

demonstrated compliance with 40 CFR 194.8 requirements for RH Waste Stream SNL-HCFS5400-RH.

Waste Characterization Element Description

As part of the inspection, EPA reviewed the following with respect to programmatic 

requirements and the use of AK for RH waste characterization by SNL-CCP: 

Inspection scope and waste stream identification 

Identification of the WCPIP waste characterization process

Adequacy of the Certification Plan and other WCPIP documentation
12

Adequacy of WCPIP waste qualification pathway

Adequacy of data management reviews, validation activities, data reporting and records 

retention

Adequacy of training

Adequacy of waste stream profile form (WSPF) and related attachments

Adequacy of Nonconformance and Discrepancy Resolution (DR) documentation

Waste Stream definition including radiological and physical characteristics of the waste 

stream 

Verification that the subject waste is of defense origin and is not low-level waste (LLW), 

high-level waste (HLW), or spent nuclear fuel (SNF)

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

derived by SNL-CCP

Adequacy of AK procedure and procedure implementation, including Attachments [AK 

Accuracy, Characterization Reconciliation Reports (CRR), Correlation and Surrogate 

Summary Forms (CSSF)]

Adequacy of the AKSR and associated source documents

AK data traceability

Attainment of Data Quality Objectives (DQOs) 

Documents and Batch Data Reports Reviewed

Source documents, attachments, forms, and other data were provided to EPA and were reviewed 

as part of this T1 evaluation, as applicable. The listing of all documentation examined is in 

Attachment A. The BDRs examined are listed in Table 3.

Table 3. Batch Data Reports Examined

Drum No. Sampling BDR Analysis BDR VE BDR DTC BDR

SNLNM005339 SNRH1001 ALD11007 RHSNLVE100001 SNLRHDTC11001

SNLNM007007 SNRH1101 ALD11007 RHSNLVE110001 SNLRHDTC11001

SNLNM007008 SNRH1101 ALD11007 RHSNLVE110001 SNLRHDTC11001

SNLNM007009 SNRH1101 ALD11007 RHSNLVE110001 SNLRHDTC11001

SNLNM007010 – ALD11007 RHSNLVE110002 SNLRHDTC11001

SNLNM007011 SNRH1101 ALD11007 RHSNLVE110001 SNLRHDTC11001

Technical Evaluation

EPA evaluated the adequacy of AK information specific to the PKE00044 parcels in Waste 

Stream SNL-HCF-S5400-RH as described in the ASKR, Revision 1 and CCP-AK-SNL-501, 

Revision 1. EPA also evaluated the records relative to the programmatic requirements in the 

WCPIP as part of Waste Stream SNL-HCF-S5400-RH characterization activities.
13

(1) The scope of the baseline inspection request and waste stream determination were 

examined for Waste Stream SNL-HCF-S5400-RH and found to be adequate (WCPIP, 

Revision 2, Section 3.0, p 13)8.

The scope of EPA’s baseline inspection was to evaluate the adequacy, implementation, and 

effectiveness of technical processes SNL-CCP used to characterize the repackaged, RH TRU 

debris (S5000) Waste Stream SNL-HCF-S5400-RH, as described in the AKSR. EPA reviewed 

the submission and agrees that the scope of the inspection is limited to the PKE00044 waste 

group described in the AKSR, Revision 1; the scope of the inspection was adequately defined. 

EPA also examined data presented by SNL-CCP to determine whether the waste stream was 

adequately defined. The WCPIP, Revision 2, defines the waste stream as waste material that is 

(1) generated from a single process/activity, and (2) similar in material, physical form, and 

radiological properties. EPA concludes that the parcels associated with PKE00044 and described 

in the CCP-AK-SNL-501, Revision 1 exhibit common process origins and radiological 

compositions based on AK and sampling information. 

Waste parcels associated with PKE00047 (gloveboxes 1 and 2) and PKE00027/54 (glovebox 3) 

were sampled separately and EPA expects that these will be included in future versions of CCPAK-SNL-501 as T1 changes.

9 When the T1 changes for including these two waste groups in 

Waste Stream SNL-HCF-S5400-RH are submitted, the AKSR must clearly justify inclusion of 

these groups in the same waste group as PKE00044. Information showing more commonality of 

experiments and radiological materials between the SCB/Zone 2A area and gloveboxes, as well 

as more justification as to why the distinct radiological populations do not warrant designation as 

separate waste streams as implied by the WCPIP, Revision 2 is necessary. Alternatively, if 

radiological data suggest designating these two groups as two new waste streams or a new single 

waste stream consisting of these two groups, SNL-CCP must accordingly revise the existing 

AKSR.

In the future, if CH information is used to characterize RH waste containers at SRS-CCP, EPA 

may determine that evaluation of the CH program is necessary. This evaluation may be

warranted since the EPA has not had opportunity to review documentation that the Sandia 

National Laboratory, a small quantity generator, prepares as part of the inter-site transfer of CH 

TRU waste to the INL for characterization and disposal.

(2) The Certification Plan, including a description of the waste characterization process, was 

examined and found to be complete and technically adequate (WCPIP, Revision 2, 

Section 3, pp. 14-15).

The Certification Plan is presented in CCP-AK-SNL-502, Revision 0. The WCPIP, Revision 2, 

states that the Certification Plan must describe the process for certification of the waste stream, 

 

8 The WCPIP references are examples and are not meant to be an exhaustive list. Many of these 

requirements are discussed in several places within the WCPIP.

9

If the additional containers to be added to Waste Stream SNL-HCF-S5400-RH do not require new or 

different scaling factors, a T1 change is not required. See Section 7.1 for details about these requirements.
14

including a description of the characterization methods selected (described in Section 4.1 of the 

WCPIP) and AK qualification method(s) (described in Section 5.0 of the WCPIP). 

EPA’s characterization requirements in 40 CFR 194.24 are presented schematically in Figure 1. 

The Certification Plan must satisfy requirements in 40 CFR Part 191 (Subparts B and C) and Part 

194, the EPA final certification decision, and the WIPP Land Withdrawal Act (LWA) (Public 

Law 102-579).

Figure 1. Characterization and Qualification Process

EPA reviewed the Certification Plan entitled “Central Characterization Project RH TRU Waste 

Certification Plan for 40 CFR Part 194 Compliance and Confirmation Test Plan.” SNL-CCP’s 

Certification Plan did not adequately represent the characterization and qualification processes as 

presented in Figure 1. SNL-CCP, therefore, revised the Certification Plan to indicate (a) which 

* AK data must be qualified if used to quantify parameters [194.24(c)(3)]

Yes No

Qualification not 

required

Qualify by Peer 

Review, Equivalent 

QA, Confirmatory 

Testing, or 

Corroborating Data

AK NDA, DA, or 

DTC VE or RTR WDS

Other, including 

programmatic 

controls

System of Controls to 

Characterize Waste

[40 CFR 194.24(c)(4)]

Are data obtained 

under approved QA

program?*

[§194.24(c)(3), (5)]
15

radiological characteristics of the waste (TRU, RH, and activity determinations) will be 

determined by sampling/analysis, by surface dose measurements, and by the DTC process; (b) 

how physical parameters and the absence of liquid will be determined through VE; (c) how the 

waste stream determination, defense determination, and absence of SNF and HLW will be 

determined by AK; and (d) that AK is not used directly to quantify any parameter, thus not 

requiring AK qualification. The revised Certification Plan addressed required elements and 

adequately addressed the waste characterization and qualification requirements. Notification to 

EPA when formal revisions of the Certification Plan are available is a T2 change. (See Table 1 

where this is included as a T2 change; substantive modification of CCP-AK-SNL-502 that has 

the potential to affect the characterization process is a T1 change)

(3) The waste qualification pathway was identified and the selected approach and

documentation were adequate (WCPIP, Revision 2, Figure 2, p.15 and Sections 5.0–5.4).

40 CFR 194.24(c)(3)-(5) state that a system of controls must be implemented to characterize 

waste components, and this system must comply with quality assurance (QA) requirements 

found at 40 CFR 194.22. If AK is used to quantify components, its use must comply with 

§194.22(b) which states that data collected prior to implementation of the WIPP-specific QA 

program must be qualified by peer review, corroborating data, confirmatory testing, or 

demonstration that a QA program equivalent to ASME NQA-1

10 requirements was in place at the 

time of characterization.

Based on information presented in the revised Certification Plan, the physical and radiological 

compositions of the waste stream are determined through sampling, measurement, modeling, and 

VE, all of which are conducted under an approved QA program, and do not require qualification. 

AK is used to define the waste stream and to meet the DQOs associated with defense 

requirements and the absence of SNF and HLW, which do not require qualification per 

40 CFR 194.24(c)(3). This approach was adequately presented in the revised Certification Plan 

[see Item (2), above]. EPA concluded that the qualification pathway was adequately identified 

and appropriate for the characterization approach used for this waste stream.

(4) Example Nonconformance Documentation and Discrepancy Resolution were examined 

and found to be adequate (WCPIP, Revision 2, Section 3.4.2.3, p. 24).

SNL-CCP provided two examples of non conformance reports (NCRs). Example 1 was NCRRHSNL-2345-11 that dealt with an error on Attachment 1 of the VE form that identified a 

discrepancy associated with the container listed in Block 3 of the form. This resulted in the AKE 

being unable to complete an update to Attachment 8 for Waste Stream SNL-HCF-S5400-RH.

Example 2 was NCR-RHSLN-2350-11 that addressed the identification of a solid (WMC S3000) 

drum in the S5000 Waste Stream SNL-HCF-S5400-RH. SNL-CCP stated that this drum will be 

characterized as a separate waste stream and has been removed from the S5000 debris waste 

stream. 

SNL-CCP provided three examples of Discrepancy Resolution (DR) documents:

 

10 Quality Assurance Program Requirements for Nuclear Quality Assurance, ASME NQA-1-1989 Edition, 

The American Society of Mechanical Engineers
16

DR1001 and DR1003 are AK-AK DRs that deal with discrepant information pertaining 

to the assignment of hazardous waste numbers

DR1002 is an AK-Characterization DR that addresses the discrepant AK identification of 

a drum as being S5000 that was later discovered during VE to contain S3000. 

Note that with implementation of CCP-TP-005, Revision 22, for RH and CH AK documentation 

(replacing portions of the WCPIP, Revision 0d Appendix A), CCP may also generate AKCharacterization discrepancy resolutions. The preparation of NCRs and discrepancy resolution 

reports is adequate. Notification to EPA of the availability of additional discrepancy resolution 

reports is a T2 change. (See Table 1 where this is included as a T2 change.)

(5) The Acceptable Knowledge Procedure was examined and found to be adequate and 

appropriately implemented (WCPIP, Revision 2, Section 4.1, pp. 32-33).

EPA compared the requirements in the original WCPIP (WCPIP, Revision 0d), the new WCPIP 

(WCPIP, Revision 2), and CCP-TP-005, Revision 22 to determine whether this transfer 

adequately addressed the initial WCPIP requirements. EPA discussed procedural questions, 

discrepancies, and deficiencies with SNL-CCP personnel during the inspection, including: 

correct referencing of WCPIP requirements; modification of the waste stream definition in 

CCP-TP-005, Revision 22, Attachment 12 to agree with the WCPIP; inclusion of WCPIP 

radiological data collection requirements by reference, records maintenance, container-specific 

data acquisition, waste correlations, collection of container-specific information; and, 

determination of AK accuracy calculations [see Item (11) for additional information about AK 

Accuracy]. 

Additionally, CCP-TP-005, Revision 22, includes 15 attachments and also requires development 

and maintenance of an AK tracking spreadsheet that presents a running compilation of drums 

within each waste stream at a site. SNL-CCP completed Attachments 1, 4, 6, 8, 10, and 13 for 

Waste Stream SNL-HCF-S5400-RH and they are adequate. Attachment 4 was not updated to 

include all AK source documents and references, but a revised version was later provided that 

was complete [see Item (6)]. SNL-CCP implemented a new approach to complete Attachment 8, 

which is the waste stream container list used to develop the WSPF. Attachment 8 will now 

contain all drums identified at the time of AKSR approval but will not be updated as in the past. 

Instead, Add Container Memoranda that document the addition and removal of containers from 

the waste stream will be generated and these memoranda will be placed in a single source 

document in the AK record. 

Therefore, Attachment 8, associated Add Container Memoranda, and the AK Tracking 

Spreadsheet will together provide the full drum history and current waste stream inventory. SNLCCP revised CCP-TP-005 (Revision 23) to address three EPA issues; the limited revisions to 

CCP-TP-005 are adequate provided the interpretations presented during the inspection are 

implemented as discussed. EPA will examine this implementation during the next applicable 

inspection or T1 review along with adequacy of the new drum tracking method using Attachment 

8, the AK tracking spreadsheet, and Add Container Memoranda. Notifications to EPA when Add 
17

Container Memoranda are available and upon completion of revisions of procedure CCP-TP-005 

are T2 changes. (See Table 1 where these are included as T2 changes.)

(6) The Acceptable Knowledge Summary Report was examined, along with the reference list 

and associated source documents, and found to be adequate for parcels associated with 

PKE00044 (WCPIP, Revision 2, Section 4.1, p. 31).

EPA reviewed the AKSR and found it to be deficient in several areas, including: 

Adequate support for the waste stream determination (all three waste groups as a single 

waste stream)

Clear identification of the process areas within the HCF

Adequate support for the defense determination

Adequate explanation of the WMP calculations

SNL-CCP subsequently revised the AKSR to adequately identify process areas, better support 

the defense determination, and explain the WMP determinations. As indicated in Item (1), the 

AKSR adequately describes wastes associated with PKE00044 and the AKSR and additional 

information reviewed by EPA during the inspection indicate that waste from PKE00047 and 

PKE00027/54 show common processes and the exchange or comingling of activities and 

experiments. However, if needed as a part of the T1 change, the AKSR must be revised to 

include additional information justifying that waste belonging to PKE00044, PKE00047, and 

PKE00027/54 constitute RH Waste Stream SNL-HCF-S5400-RH [see Item (1)]. The waste 

stream definition in the AKSR, Revision 2, is adequate for 19 parcels associated with PKE00044 

that were evaluated during this baseline inspection. 

CCP-TP-005, Revision 22 Attachment 4 presents all AK source documents reviewed in 

association with the waste stream, including references cited in CCP-AK-SNL-500, Revision 1 

and documents that were not cited in the AKSR. Attachment 4 was revised after the EPA 

inspection to include all source documents identified as of the date provided, noting that 

Attachment 4 is continually updated. SNL-CCP representatives stated that the historical source 

documents that are generated by the site(s) independent of SNL-CCP are maintained by the sites. 

SNL-CCP AK personnel typically maintain copies of these as working files and submit them to 

CCP records where they are maintained as non-QA records. SNL-CCP does maintain the records 

that the AKEs generate as required by CCP-TP-P005, e.g., WSPF and other attachments, as QArecords. This approach is satisfactory as long as it is clearly understood that all records requested 

by EPA must to be obtainable and provided in a timely manner (e.g., prior to or during an 

inspection or T1 evaluation). Notifications to EPA when formal revisions of the AKSR and 

Attachment 4 are available are T2 changes. (See Table 1 where these are included as T2 changes; 

substantive modification of CCP-AK-SNL-500 that has the potential to affect the 

characterization process is a T1 change.)
18

(7) The radiological and physical properties of the waste stream were examined and found to 

be adequately described for PKE00044 wastes based on Acceptable Knowledge (WCPIP, 

Revision 2, Section 3.0, p. 13).

The AKSR describes wastes from the SCB/Zone 2A area as organic and inorganic debris 

generated during the destructive and nondestructive examinations conducted in the HCF. The 

waste also includes personal protective equipment and plastic from decontamination and 

repackaging activities (References C1039, M1016, and M1019). SNL-CCP approximated the 

weight percentages using values and waste descriptions presented in DR documentation. For 

most parcels, the net weights were presented on the SNL RWNMDD Radiological Form, as well 

as other more detailed descriptions in the Discrepancy Report (DR) documentation and 

Reference M1019. EPA pointed out that the WMP weight percentage ranges presented in AKSR 

Table 3 did not adequately represent the possible distribution of material in the waste because the 

lower-end value of each parameter range is actually "0", rather than the numeric value presented 

on the table. SNL-CCP stated that the actual lowest weight percent identified in waste containers 

provides more information than the technically more accurate “0” and added a footnote 

explaining that the range includes the lowest non-zero estimated values for parcels prior to 

repackaging. The footnote adequately explains the ranges presented in AKSR Table 3.

Estimated WMP weight percent calculations and distributions by parcel were presented in a 

memorandum to Attachment 6 of CCP-TP-005, Revision 22. Weight percentage data indicate 

that PKE00044 is composed of about 65% or greater iron-based metals, with the remaining 

consisting of other metals, inorganic, and organic materials. These calculations are estimates 

based on records and assumptions pertaining to overall percentages of materials in the drums. 

The methods used by SNL-CCP provided WMP weight and volume estimates, and the actual 

percentage of WMPs in each drum could vary. The physical composition of each parcel can be 

determined from AK documents and the overall waste composition of the PKE00044 waste 

parcel is adequately described.

AK data indicate that the predominant radionuclides include cobalt-60 (60Co), 90Sr, 235U, 238U, 

137Cs, and small amounts of TRU radionuclides, primarily 238Pu, 239Pu, and 241Am (References 

M1016 and M1019). In the late 1990s, SNL RWNMDD waste handlers characterized each 

parcel by gamma spectrometry, using either the laboratory Q Squared (Q2)

11 system or a 

portable system, in conjunction with activity ratios (scaling factors) for undetected radionuclides. 

If gamma spectrometry was not performed, SNL personnel used external exposure rate (dose 

rate) surveys in conjunction with MicroShield® modeling to estimate the 137Cs activity 

(References M1016, M1019, M1020, and M1021). RH containers with high dose rate were 

initially characterized using only the portable gamma system because of dose rate limits 

associated with the Q2system. SNL confirmed the list of radionuclides in PKE00044 internally 

in 2004, based on limited swipe samples collected from the parcels that were analyzed by 

destructive and non-destructive radiometric analyses. The measurements indicated that 

PKE00044 was sufficiently accurate to allow differentiation of TRU and Non-TRU waste 

consistent with the 100 nCi/gram criterion. Comparison of the 2004 sampling results and the 

original PKE00044 radionuclide activities is presented in Table 4 (References M1016, M1020, 

 

11 Q2

is a Canberra Industries standard segmented gamma spectrometry assay system.
19

and M1021). The radiological composition for each parcel is well known and adequately 

described in the PKE reports.

Table 4. PKE00044 Radionuclide Activity Ratio Comparison

Radionuclide

2004 

Measured 

Activity Ratio 

to 137Cs

PKE00044 

Activity Ratio 

to 137Cs

2004 

Measured 

Activity Ratio 

to 241Am

PKE00044 

Activity Ratio 

to 241Am

241Am 1.95E-03 6.94E-04 1.00E+00 1.00E+00

238Pu 1.31E-02 7.17E-03 6.73E+00 1.03E+01

239/240Pu 1.29E-03 2.00E-03 6.64E-01 2.89E+00

90Sr 2.95E-01 9.41E-01 NA NA

147Pm 2.50E-02 6.42E-02 NA NA

241Pu 2.79E-02 1.75E-02 1.43E+01 2.52E+01

TRU Alpha 1.63E-02 9.86E-03 8.39E+00 1.42E+01

NA: Not applicable since the radionuclide is not TRU.

SNL-CCP used radionuclide information from the DR documents to develop a summary of the 

radionuclides present in all 32 waste parcels. The gram value for each reported radionuclide was 

divided by the mass of all radioactive constituents in the waste stream and converted to a 

percentage to calculate the “Total Radioactive Weight %.” A radionuclide weight percent range 

was also determined by dividing the mass of each individual radionuclide in a parcel by the total 

radiological mass for that parcel, and expressing it as a percentage. The minimum and maximum 

results are listed as “Radionuclide Weight % Range for Individual Parcels.” Similar processes 

were used to determine the “Total Radionuclide Curie%” and “Radionuclide Ci% Range for 

Individual Parcels.” The radiological compositions of each parcel, the groups of parcels in each 

PKE, and all 32 parcels together are adequately described.

(8) The waste stream information was examined and indicates that the waste stream does not 

contain spent nuclear fuel or high level waste (WCPIP, Revision 2, Section 2.2.7, p. 12).

The Land Withdrawal Act (LWA) prohibits the disposal of Spent Nuclear Fuel (SNF) and High 

Level Waste (HLW) as defined by the Nuclear Waste Policy Act (NWPA) at WIPP. The NWPA 

and DOE M435.1-1

12 state 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... [However,] test specimens of fissionable material irradiated for research and 

development only, and not production of power or plutonium, may be classified as waste, and 

managed in accordance with the requirements of this Order when it is technically infeasible, cost 

prohibitive, or would increase worker exposure to separate the remaining test specimens from 

other contaminated material.” The NWPA states that HLW is “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.”

 

12 DOE M435.1-1 is the Department of Energy’s Radioactive Waste Management Manual. 
20

Waste Stream SNL-HCF-S5400-RH consists of debris contaminated during pre- and postirradiation experiments and decontamination operations. The waste stream does not include: 

accountable13 material; all test residues, materials, and fragments; or intact irradiated fuel pin test 

specimens that were removed from the HCF separately. Operations at the HCF did not include 

the separation or reprocessing of irradiated fuel elements withdrawn from a reactor. As a result, 

Waste Stream SNL-HCF-S5400-RH does not contain SNF or HLW as defined by the LWA and 

NWPA and is eligible for disposal at WIPP (References M1016 and P1041).

(9) The waste stream information was examined and indicates that the waste stream has a 

defense pedigree (WCPIP, Revision 2, Section 2.2.7, p. 12).

The scope of this inspection is limited to the 19 parcels associated with PKE00044. Waste from 

the SCBs and Zone 2A has been separately packaged in 13 parcels and will be evaluated at a 

later date. The NPR program was designed to develop a long-term source of tritium for use in 

nuclear weapons production, and is, therefore, entirely defense related (References P1030 and 

P1044). All of the materials examined in this area had been or were to be irradiated in the 

ACRR, which supported DOE and U.S. Department of Defense experiments, including 

irradiating components for defense programs and tritium production (References M1015 and 

P1102). Waste and material management practices in place in the late 1980s and 1990s were 

such that test materials were stored in common areas of the HCF and materials and machinery 

were passed between the SCBs, resulting in commingling of the wastes; segregation of defense 

from non-defense wastes is not possible (References C1038 and P1104). The defense 

determination is justified based on commingling and cross contamination with defense activities.

(10) The Waste Stream Profile Form and attached Characterization Reconciliation Reports 

were examined and found to be adequate (WCPIP, Revision 2, Section 3.4.2.1, p. 22).

The draft Waste Stream Profile Form (WSPF) and Characterization Reconciliation Reports 

(CRR) were provided to EPA on June 1, 2011. Revision 2 of the WCPIP explicitly lists the 

required contents of both of these documents. The WSPF did not specify the Batch Data Report 

(BDR) numbers supporting waste stream characterization, and instead referenced the 

Characterization Information Summary (CIS). The CIS is not required or mentioned in either the 

WCPIP, Revision 2 or CCP-TP-005, Revision 22, and was not initially provided to EPA. SNLCCP, however, has elected to combine the once separate EPA and New Mexico Environmental 

Department WSPFs; therefore, a CIS must be prepared and may be used in conjunction with the 

WSPF to meet EPA requirements as documented in WCPIP, Revision 2. SNL-CCP provided the 

CIS to EPA on June 23, 2011. The WSPF and CIS are draft documents, and therefore do not 

include the SPM signature and date. Together, the WSPF and CIS are complete and adequate.

The draft CRR did not accurately reflect the WCPIP, Revision 2 in the QAO and DQO sections. 

The DQO section needed to be revised to reflect edits to the Certification Plan discussed in Item 

(2), above. EPA interprets the WCPIP list of CRR elements to be required as applicable, and 

expects that some of the items (including the documentation of qualification) will not apply to all 

 

13 Accountable materials are nuclear items and related materials that must be controlled as specified in 

DOE Order 410.2, Management of Nuclear Materials, and generally include fissile materials, source materials used 

to produce fissile materials and other materials of special interest.
21

waste streams. Similarly, EPA interprets the intent of the CRR and the DQO section in particular 

is to briefly summarize how the DQOs are met–whether through AK or a different 

characterization method. If AK is used to meet one or more DQOs, this section should include 

information about how, if applicable, the AK is being qualified. A revised draft CRR was 

provided to EPA on June 27, 2011, that updated the radiological information for each 

characterized container and addressed the needed revisions as discussed above. The CRR is a 

draft document, and therefore does not include the SPM signature and date. The revised draft 

CRR is adequate. Notification to EPA of the availability of the final WSPF and CRR and any 

revisions to these documents and their attachments (e.g., CIS) are T2 changes. (See Table 1

where these are included as T2 changes.)

(11) The AK Accuracy Report was examined and found to be adequate; a Correlation and 

Surrogate Summary Form was not required (WCPIP, Revision 2, Sections 4.1, p. 30 and 

3.2.2, pp. 17-19).

The AK accuracy report documents the comparison of AK information and measurement data 

used to characterize the waste and documents that the measurement-based DQOs have been met. 

As part of the AK accuracy process, the Site Program Manager (SPM) checks measurement 

values to verify that the waste contents match the AK-based waste stream definition. AK 

accuracy is affected by any containers that have to be reassigned to a different SCG or waste 

stream based on the reevaluation of AK or on testing, sampling, and/or analysis data. Issues with 

the individual data points are addressed during the characterization process and should be 

resolved before the data are sent to the SPM.

A draft AK accuracy report for Lot 1 consisting of six 55-gallon containers, i.e., seven of 19 

parcels of PKE00044, was provided to EPA on June 1, 2011, wherein AK accuracy is reported at 

100%. As a result of EPA’s inquiries during the inspection, this AK accuracy report required 

revision to reflect the changes to CCP-AK-SNL-502 discussed in Item (2), above. SNL-CCP 

provided a revised draft AK accuracy report on June 21, 2011, that reflects those changes and is 

adequate. Notification to EPA when AK accuracy reports are completed, prepared annually at a 

minimum, is a T2 change. (See Table 1 where this is included as a T2 change.)

Waste Stream SNL-HCF-S5400-RH has a companion CH waste stream; however, none of the 

CH information was used to characterize the RH waste stream. In the future, if CH information is 

used to characterize RH, a Correlation and Surrogate Summary Form (CSSF) will be required. 

Notification to EPA of the preparation of a CSSF is a T2 change. (See Table 1 where this is 

included as a T2 change.)

SNL-CCP expects to identify some RH wastes in the course of characterizing the companion CH 

waste stream. If this RH waste fits the AK description of waste in PKE00044 and if the same 

radiological characteristics are exhibited, then this newly-generated RH waste would be disposed 

of as PKE00044. When this happens, EPA notification is necessary along with the submission of 

supporting information, as discussed in Sections 1.0 and 7.1, above.

(12) Drum data are adequately traceable and are in the AK Record (WCPIP, Revision 2, 

Sections 3.4.4.1, p. 20; 3.4.2.2, p. 23; and 4.1, pp. 29-34).
22

The primary sources of drum traceability information are the DR forms in Reference M1016, 

which include: the location and date of parcel packaging; a list of the parcel contents (in some 

cases this includes information about the contributing experiment); the date the parcel was 

transferred to the Manzano Base; and the storage location of the parcel within the Manzano 

Bunkers. From packaging to disposal, each parcel will have been assigned five different 

identifying numbers, specifically: 

Original packaging parcel number

New parcel number assigned at a future date

Number of the container into which the parcel was placed for storage

Number of the 30-gallon drum into which the parcel was/will be repackaged during VE

Number of the 55-gallon drum into which the 30-gallon drum was packed.

To clarify the connections between each identification number, SNL-CCP modified Reference 

M1019 to include a crosswalk of all the identification numbers for each parcel. To verify drum 

traceability in the AK record, EPA randomly selected six parcels from PKE00044 that were 

described in two DR forms, as summarized in Table 5. Drum data are in the AK record and are 

traceable to packaging records from the decontamination operations in the HCF.

Table 5. Drum Traceability

Parcel 

No.

Original 

Parcel No.

Container 

No.

30-gallon 

No. (if 

known)

55-gallon No.

(if known)

DR 

Form

Packaging

Date and 

Location

Contributing 

Experiment 

(if known)

Transfer 

Date and 

Storage 

Bunker at 

Manzano

P9800937 HCF-RW96-KC-07 C980373 P1110126 SNLNM007011 005965 3/14/96

SCBs Unknown 4/30/9878

P9800938 HCF-RW96-KC-06 C980374 Not yet Repackaged 005965 3/12/96

SCBs Unknown 4/30/9878

P9800939 HCF-RW96-KC-04 C980375 Not yet Repackaged 005965 2/13-14/96

SCBs Unknown 4/30/9878

P9800940 HCF-RW96-KC-03 C980376 Not yet Repackaged 005965 2/12/96

SCBs Unknown 4/30/9878

P9800941 HCF-RW96-KC-02 C980377 Not yet Repackaged 005965 2/7-8, 4/8/96

SCB ST, NPR 4/30/9878

P9900531 HCF-RW95-KC-01 C990238 C080215 SNLNM005339 007205 10/25/95

SCB1 ST, MP 11/24/9837063

(13) Acceptable Knowledge training was examined and found to be adequate after the EPA 

identified a concern that was resolved (WCPIP, Revision 2, Section 4.1, p. 32). 

The WCPIP, Revision 2 requires that characterization personnel responsible for compiling AK, 

characterizing RH TRU waste streams using the AK process, and assessing the AK 

characterization shall be qualified and trained to:

The WCPIP

The characterization program nonconformance and corrective action process
23

Site-specific training relative to the site’s waste streams (e.g., current AKSRs)

Determining radiological contents of individual containers

Through interviews and discussions with the AKEs, EPA was able to conclude that the SNLCCP AKEs are current with respect to the training requirements listed above; however, SNLCCP was unable to provide objective evidence of this training. The WCPIP, Revision 2 states in 

bold text on page 33: “The RH TRU characterization program is responsible for maintaining 

records of the training provided to personnel responsible for compiling AK.” EPA discussed the 

issue with CBFO and SNL-CCP personnel and formalized it as a concern requiring a response on 

EPA Inspection Issue Tracking Form No. SNL-CCP-RH-AK-11-01CR. (See Attachment C for a 

copy of this form.) The details of addressing this issue are provided below.

EPA Concern Related to the Training of AK Personnel: The WCPIP, Revision 2, requires 

that characterization personnel responsible for compiling AK, characterizing RH TRU waste 

streams using the AK process, and assessing the AK characterization shall be qualified and 

trained to (1) the WCPIP, (2) the characterization program nonconformance and corrective 

action process, (3) site-specific waste streams (e.g., current AKSR), and (4) determination of 

radiological contents of individual containers. The WCPIP requires (on page 33): “The RH TRU 

characterization program is responsible for maintaining records of the training provided to 

personnel responsible for compiling AK.” SNL-CCP was unable to provide objective evidence 

showing that the AKEs compiling AK documents for the Sandia waste are trained to the above 

requirements. Through interviews and discussions with AKEs, EPA was able to conclude that 

they are up to date on the training requirements listed above. However, the RH TRU 

characterization program does not maintain the required records and that deficiency in the RH 

Program at SNL-CCP must be addressed to be in compliance with WCPIP, Revision 2 that was 

effective April 21, 2011.

CBFO Response to the EPA Concern: Several rounds of communication between EPA and 

CBFO personnel followed issuance of this concern. This process continued until sufficient 

objective evidence to support up-to-date knowledge of each of the four bullets listed above had 

been provided for all personnel responsible for compiling AK for RH waste at SNL-CCP. Three 

different CBFO responses to EPA’s concern14 are included in entirety in the EPA Air Docket 

supporting the Federal Register notice announcing the proposed baseline approval of SNLCCP’s RH program. The Docket Number for the docketed material mentioned in Footnote 13 

can be found in the Federal Register notice announcing this proposed approval.

Resolution of EPA’s Concern: Table 6 provided by SNL-CCP lists the AK personnel 

associated with the SNL-CCP RH TRU waste characterization program and identifies the 

objective evidence provided. Upon evaluation of all documentation provided by CBFO, EPA 

closed Concern No. SNL-CCP-RH-AK-11-01CR.

 

14 CBFO response dated June 27, 2011 (EPA-HQ-OAR-2011-XXXX-0003), CBFO response dated August 

2, 2011 (EPA-HQ-OAR-2011-XXXX-0004), and CBFO response dated August 11, 2011 (EPA-HQ-OAR-2011-

XXXX-0005), can be found in the Agency’s electronic docket at http://www.regulations.gov.
24

Table 6. Objective Evidence of Training for AK Personnel

Name

WCPIP

Nonconformance and 

Corrective Action

Process (CCP-QP-005) Site-Specific 

Training

Determining 

Radiological 

Contents of 

Containers

Current 

Revision of 

Initial CCP-TP-005

Training

Current 

Revision

Initial 

Training

Current 

Revision

John Kleckner

Qual Card 

9-30-08

Revised 

Qual Card 

6-16-11

Qual Card 

9-30-08

Revised 

Qual Card 

6-16-11

CCP 

Document 

Control 

Screenshot

Briefing

R22: Att 6, 8, 

10

R23: Briefing

C. Allen 

Dickerson Qual Card 

9-7-10

Revised 

Qual Card 

6-16-11

Qual Card 

9-7-10

Revised 

Qual Card 

6-16-11

E-Mail 

Statement Briefing

R22: Att 1, 4, 

3s

R23: Briefing

Christopher 

Chancellor Qual Card 

9-30-08

Revised 

Qual Card 

6-16-11

Qual Card 

9-30-08

Revised 

Qual Card 

6-16-11

E-Mail 

Statement Briefing R22: Att 5R23: Briefing

Kevin Peters

Qual Card 

8-6-03

Revised 

Qual Card 

6-16-11

Qual Card 

8-6-03

Revised 

Qual Card 

6-16-11

CCP 

Document 

Control 

Screenshot

Briefing

R22: Revised 

Qual Card 6-

16-11

R23: Briefing

Steve Schafer

Qual Card 

10-6-03

Revised 

Qual Card 

6-16-11

Qual Card 

10-6-03

Revised 

Qual Card 

6-16-11

CCP 

Document 

Control 

Screenshot

Briefing

R22: Revised 

Qual Card 

6-16-11

R23: Briefing

Jene Vance*

Qual Card 

5/23/07

Revised 

Qual Card 

8-8-11

*Mr. Vance is not an AKE, he is a member of the Radiological Characterization Technical Staff, and therefore he 

requires minimal AK training. See discussion below.

SNL-CCP states that Mr. Vance “is primarily responsible for producing Radiological 

Characterization Technical Reports” and that he “does not compile or prepare AK summary 

reports.” EPA agrees with this statement. SNL-CCP also states that, “Mr. Vance uses 

information in the AK Summary Report to determine radiological content”, and implies that Mr. 

Vance uses only information provided to him by the qualified AKEs. EPA has regularly found 

that AK information presented in the Radiological Characterization Technical Report is not 

found anywhere in the AKSR and is sometimes in direct opposition to the AK presented in the 

AKSR. Therefore, EPA must conclude that Mr. Vance is compiling his own AK information and 

should receive the same training as the AKEs. 

For the purposes of this baseline inspection, EPA accepted SNL-CCP’s statement that Mr. Vance 

does not compile AK and considered the provision of qualification cards as sufficient evidence 

of Mr. Vance’s limited AK training. However, in future RH inspections (baseline and T1 

evaluations), EPA will require that all AK information included in the Radiological 

Characterization Technical Report be clearly identifiable as coming from the associated AKSR. 

In addition, EPA may require that SNL-CCP or other characterization entity prepare a 

memorandum (equivalent to the AK-Nondestructive Assay Memorandum for CH waste) 

evaluating the radionuclide characterization of the waste stream. The Memorandum would

include a section written by the Radiological Characterization Technical Staff describing the 

waste characterization process and the application of AK.
25

For any future revisions of relevant procedures, e.g., CCP-TP-005 and procedures for 

nonconformance and corrective action that have the potential to impact execution and 

documentation of the AK process, EPA expects that the briefings will be held and attendance of 

these briefings will be documented and maintained in the records for each AKE. EPA will rely 

on inspection interviews to determine if AKEs are familiar with procedure revisions that are less 

critical. Notification of the procedural revisions to EPA will continue to be a T2 change.

In addition to the SNL-CCP training issue discussed above, EPA has observed during recent site 

inspections/evaluations that the current scope of SNL-CCP-implemented training program shows 

varied familiarity and understanding of SNL-CCP’s waste characterization staff in the following 

areas: 

EPA requirements and DOE upper tier documents (e.g., WCPIP, WAC or QAPD)

Information EPA needs to support adequacy of each of EPA's inspection report elements 

and eventual approval15

Type of source documents and information needed/used to develop waste stream

characteristics (defense waste, TRU basis, non-SNF and non-HLW, waste contents)

Host site's facility and equipment training requirements

Need for adequate number of waste samples for radiological characterization for scaling 

factors, and available/applicable analytical options for radiological contents of a drum

Physical contents of waste drums subjected to nondestructive evaluation

Working knowledge of TRU waste from previously-approved sites

This has affected the quality of documents prepared by SNL-CCP, particularly the 500- and 501-

series, that EPA receives for evaluation. Improving the proficiency of SNL-CCP waste 

characterization personnel specific to the above would allow the staff to produce comprehensive 

documents for EPA. Separately, as a program-wide effort, EPA and CBFO need to discuss how 

CCP can achieve improved proficiency.

(14) Data Quality Objectives were evaluated and found to be adequately met (WCPIP, 

Revision 2, Section 3.4.2, p. 22).

The WCPIP, Revision 2, identifies the following DQOs that must be addressed:

Defense Waste, HLW, and SNF Determination (Regulatory Basis: LWA): This is required to 

ensure that the waste stream was generated by atomic energy defense activities, is not HLW, and 

is not SNF. These are addressed in CCP-AK-SNL-500, Revision 2, and CCP-AK-SNL-502, 

Revision 1, as discussed in (9) and (8), above, respectively.

Radioactive Properties (Regulatory Basis: LWA, EPA Certification of the WIPP):

 

15 EPA provided an annotated outline of an EPA Inspection Report detailing EPA’s information and 

document needs to CBFO most recently in January 2010.
26

TRU Waste Determination: Waste must contain more than 100 nanocuries (nCi) of TRU 

isotopes per gram of waste 

RH Waste Determination: Surface dose rate must be equal to or greater than 200 millirem 

per hour (mrem/hr) and less than 1,000 rem/hr

Activity Determination: The total waste inventory can be no more than 5.1 million curies 

of RH TRU; activity limit per canister is 23 Ci per liter; and all radionuclides important 

to release calculations must be tracked 

These three DQOs are addressed in CCP-AK-SNL-501, Revision 1, as discussed in Section 6.2, 

below.

Physical Properties (Regulatory Basis: EPA Certification of the WIPP):

Liquids: The absence of liquids in excess of one percent must be confirmed

Physical Form: The physical form of the waste to delineate the waste stream as required 

by the final certification rule must be determined

These two DQOs are addressed in VE BDR Nos. RHSNLVE100001, RHSNLVE110001, and 

RHSNLVE110002, as discussed in Items (7) and (12), above.

EPA determined that the documents cited above supported that all DQOs were achieved.

Summary of Acceptable Knowledge Findings and Concerns

The EPA evaluation team identified one AK-related concern, which is discussed in Item (13), 

above. A copy of the EPA Inspection Issue Tracking Form is included in Attachment C, SNLCCP’s response is included in Attachment D, and EPA’s response to SNL-CCP’s response is 

included in Attachment E. EPA considers all aspects of this concern to have been adequately 

addressed, and there are no open findings or concerns related to AK resulting from this 

inspection.

Proposed Baseline Acceptable Knowledge Approval

EPA is proposing to approve the AK process evaluated during this baseline inspection. This 

approval is limited to the 19 parcels in PKE00044. Any additional newly-generated RH waste 

resulting from characterization of the associated CH waste stream, however, may be added to 

PKE00044 provided specific conditions are met, as discussed in Sections 1.0 and 7.1, above. 

Specifically:

1. Additional containers must have a pedigree similar to the containers in PKE00044 

described in this report; and

2. SNL-CCP must able to demonstrate that the radionuclide scaling factors used for waste 

containers from PKE00044 proposed for approval in this report (discussed in Section 8.2, 
27

below) are technically appropriate for use in the DTC determination of the radiological 

characterization of the additional containers. 

Following EPA’s approval of SNL-CCP’s RH program, if additional RH debris waste containers 

meeting the above criteria are to be emplaced in the WIPP facility, EPA notification and 

submission of the appropriate supporting documentation will be necessary immediately upon 

identification and characterization of the additional containers. Upon receiving the AK and 

radiological content documentation for the newly-generated RH waste containers to be added to 

PKE00044, EPA will verify (a) the adequacy and applicability of the scaling factors discussed in 

this report to the additional containers, (b) the common radiological aspects of the 19 original 

parcels of PKE00044 and the additional containers, and (c) the technical adequacy of the AK 

documentation. EPA will evaluate this documentation and, upon determining it to be adequate, 

SNL-CCP may dispose of these additional containers at the WIPP facility. 

If a population of additional containers requires new or different radionuclide scaling factors, 

those containers will require a T1 evaluation and approval prior to disposal at the WIPP. At the 

time of this inspection, radionuclide-specific scaling factors had only been developed for 19 

parcels of waste in PKE00044, as discussed in Section 8.1, below. Therefore, this proposed 

approval pertains only to the 19 parcels in PKE00044. Separate approvals for the remaining two 

waste groups (PKE00047 and PKE00027/54) of RH Waste Stream SNL-HCF-S5400-RH will be 

necessary as T1 changes. Additionally, if CH information is used to characterize SNL-CCP RH 

waste containers, EPA may determine that evaluation of the applicable CH program is necessary. 

This evaluation would be warranted since the EPA has not reviewed the documentation that 

SNL, a small quantity generator, prepares for the inter-site transfer of CH TRU waste to the INL 

for characterization and disposal.

8.2 Radiological Characterization

Waste Characterization Element Description

The radiological characterization of SNL-CCP Waste Stream SNL-HCF-S5400-RH relies on 

DTC in conjunction with radionuclide-specific scaling factors that were developed for this waste 

stream based primarily on the following two sources of information:

AK for Waste Stream SNL-HCF-S5400-RH, as summarized in CCP-AK-SNL-500 and 

associated source documents

Radionuclide-specific laboratory results from the analysis of smear samples collected for 

six randomly selected parcels from a population of 19 parcels associated with the 

PKE00044 source, as summarized in CCP-AK-SNL-501 and its supporting calculation 

packages

The radiological characterization methods used for SNL-CCP Waste Stream SNL-HCF-S5400-

RH were evaluated in terms of the technical adequacy, as supported by the program’s 

documents, procedures, and controls, and the knowledge and understanding of the personnel 

involved in the RH waste characterization program. During this RH inspection, the EPA 
28

inspection team evaluated the following elements of the SNL-CCP radiological characterization 

program:

Sample collection observed at SNL in March 2011

External gamma measurements (DTC) made at SNL in May 2011

Development of DTC correlation for 30-gallon drums overpacked in 55-gallon drums 

using waste densities ranging from 0.2 g/cm3to 1.8 g/cm3based on MicroShield®

modeling of the drum’s gamma dose rate using a one-curie source of 137Cs, assumed to be 

the main contributor to the dose

Derivation of radionuclide scaling factors using radiometric and spectrometric analyses 

of smear (swipe) samples obtained from randomly selected parcels

Representativeness and technical adequacy of the analytical data used to support the 

scaling factors 

Documents Reviewed

All SNL-CCP RH radiological characterization documents that were reviewed to support this 

inspection are listed in Attachment A.

Technical Evaluation

The EPA inspection team evaluated the following aspects:

(1) The overall radiological characterization process and its documentation were evaluated 

and found to be adequate.

The radiological characterization process for Waste Stream SNL-HCF-S5400-RH was 

comparable to the processes observed at previous RH TRU sites. The main technical components 

consisted of the following: collecting representative smear samples; radiometric and 

spectrometric analyses of the samples; determining isotopic distributions to develop 

radionuclide-specific scaling factors; measuring each container’s external exposure (dose) rate; 

and computer modeling to correlate the waste container’s dose rate and radionuclide 

concentration. Each of these components is discussed in the subsequent parts of this section. 

Members of the EPA inspection team prepared a flow diagram of the process, shown in Figure 2, 

below. The radiological characterization process for Waste Stream SNL-HCF-S5400-RH was 

found to be technically adequate and appropriately documented.

Any new RH waste stream not approved to date or the addition of containers to Waste Stream 

SNL-HCF-S5400-RH that requires changing the established radionuclide scaling factors or the 

use of a different radiological characterization process from what is documented in CCP-AKSNL-501, Revision 1, is a T1 change. (See Table 1 where this is included as a T1 change.) Any 

change to CCP-AK-SNL-501 that requires CBFO approval is a T2 change. (See Table 1 where 

this is included as a T2 change.)
29

Figure 2. Flow Diagram of the Characterization Process for SNL-HCF-S5400-RH

 

(2) The collection of representative samples from the waste stream was evaluated and found 

to be adequate and appropriately documented.

The sampling and analysis plan CCP-AK-SNL-505 (SAP), Revision 0, describes the sampling 

basis, methods, and applicable Quality Assurance/Quality Control (QA/QC) requirements. 

Procedure CCP-TP-512, Revision 4, presents the sampling procedures implemented by SNLCCP for sampling Waste Stream SNL-HCF-S5400-RH. EPA reviewed both of these documents

along with CCP-AK-SNL-501, Revisions 1 and 2, and the Holderness Post-sampling 

Memorandum dated April 26, 2011. The SAP also documented the methodology for calculating 

the minimum number of samples required, the applicable QAOs (accuracy, precision, 

representativeness, completeness, and comparability) and how they were achieved, and the QC 

requirements based on the analytical laboratory’s criteria. 

Locate and retrieve relevant AK 

records

Develop and execute plans to 

obtain representative swipe samples 

from waste parcels

Develop 137Cs-based scaling 

factors for radionuclides of 

interest using laboratory results

Use MicroShield®to model the 

gamma dose rate in mR/hr/Ci 137Cs 

as a function of waste density and 

develop DTC correlation

Find 1-meter gamma dose rate 

based on four measurements and 

determine waste density based on 

drum net weight and fill factor

Multiply scaling factors by 137Cs 

activity to determine radionuclides 

activity

Divide the measured dose rate by 

the DTC conversion factor to find 

the 137Cs activity in Curies

Determine Radionuclide 

Specific Scaling Factors:

Determine DTC Conversion 

Factor Measure Cs-137:
30

EPA inspectors observed the sampling process for Waste Stream SNL-HCF-S5400-RH in a hotcell in Building 6597 on March 8, 2011, at SNL. The hot-cell manipulator operators were SNL 

personnel, but sampling was directed, supervised and recorded by qualified SNL-CCP personnel, 

all of whom were listed as current on the LOQI. The parcel EPA observed being sampled was 

No. P2000998; the original container was No. C200357, which had been repackaged into 30-

gallon container No. P1110158; the final 55-gallon shipping container into which the 30-gallon 

drum had been repackaged was No. SNLNM007020. This parcel is not included in PKE00044 

and therefore was not technically a part of this baseline inspection. However, EPA considers it to 

be a surrogate, i.e., observing its sampling was sufficient to demonstrate the adequacy of the 

SNL-CCP sampling process. 

Smears were taken at pre-designated locations using pre-numbered Q-tips that were stored in the 

hot-cell post-sampling after packaging in individual sample bottles. Sampling personnel 

minimized cross contamination during all aspects of the process that EPA observed. A total of 18 

smear samples were taken from the surfaces of six randomly selected parcels (out of a population 

of 19 parcels), and all samples were obtained in accordance with the sampling procedure and 

SAP. Three Q-Tip swabs were taken from each parcel and these were combined into six 

laboratory composite samples, one for each of six parcels associated with PKE00044. The 

samples were sent to the Idaho Cleanup Project (ICP) Analytical Laboratory16 for radiometric 

and spectrometric analyses. SNL-CCP personnel correctly recorded and reviewed the sampling 

data, which are contained in the laboratory BDRs. EPA did not directly observe the final 

packaging of the smear samples, Chain-of-Custody procedures and sample preparation for 

transportation, but EPA did review the records that documented these activities and they 

demonstrated compliance with SNL-CCP procedures. The applicable QAOs of accuracy, 

precision, representativeness, completeness, and comparability were achieved.

(3) The radiochemical data were found to be representative and technically adequate to 

support the development of radionuclide-specific scaling factors.

Based on a review of the SAP and J. Holderness Memorandum, EPA agreed that the sample size 

of six was adequate to meet the predetermined accuracy criterion for the sample mean, i.e., that 

the uncertainty in the mean scaling factor must not exceed a factor of two. EPA agreed that the 

samples collected were representative of the population of 19 parcels associated with PKE00044. 

Table 7 correlates the sample collection and laboratory identifiers with the specific parcel of 

PKE00044, and indicates if a sample was Primary or a Duplicate, and Table 8 lists the 

measurement technique(s) used to quantify each radionuclide (Reference U1029). EPA 

inspectors reviewed randomly selected analytical data to ensure complete and accurate reporting 

of results and verify the use of appropriate quality control. This review demonstrated the 

following:

Batch narratives provided a complete and correct description of the analytical process(es) 

Appropriate preparation, analytical procedures and radiometric techniques were used

Appropriate standards and verification samples were employed and evaluated

Control and verification samples were within pre-established acceptance criteria 

 

16 This facility was formerly known as the INTEC (Idaho Nuclear Technology Center) laboratory.
31

Data had been subject to review before release

Analytical results were reported with correct units of measure including uncertainty and 

data were flagged as required

EPA determined that the case narratives correctly described the analytical processes and data for 

each batch reviewed. EPA noted that Table 4-1 of the SAP requires laboratory duplicates for 

alpha, beta and gamma analyses, but the J. Holderness Memorandum states: “A laboratory 

duplicate sample was created for Sample IDF52, but only for the gamma spectrometry.” The 

WCPIP, Section 4.3.4.3, states that the laboratory may use its own QC requirements for analyses 

if it has an established QA program. This modifier to the QC requirements was not flowed down 

from the WCPIP to the SAP. Table 9, below, shows the radionuclides that were reported for the 

primary samples and the number of reported values. 

Table 7. PKE00044 Samples 

Sample ID Parcel

Laboratory 

ID Sample Description

SN11301001 P9900531 IDF52 

IDF52D

Primary Sample 

Duplicate Sample

SN12011001

SN12011002

SN01201101 P9800937 IDF53 Primary Sample

SN01201102

SN01201103

SN1261101 P9800943 IDF54 Primary Sample

SN1261102

SN1261103

SN02031101 P9800964 IDF55 Primary Sample

SN02031102

SN02031103

SN02151101 P9800944 IDF56 Primary Sample

SN02151102

SN02151103

SN02211101 P9800660 IDF20 Primary Sample

SN02221102

SN02231103
32

Table 8. Measurement Technique Used for Each Radionuclide

Liquid 

Scintillation

Gas Flow 

Proportional 

Alpha 

Spectrometry

Gamma 

Spectrometry

ICP-Mass 

Spectrometry

Pu-241 Sr-90 Am-241

Cm-244

Cm-245

Pu-238

Pu-239/Pu-240

U-233/U-234

U-235/U-236

U-238

Eu-154

Cs-137

U-233

U-234

U-235

U-236

U-238

Pu-239

Pu-240

Pu-242

Table 9. Reported Radionuclides in the Six Primary Samples

Radionuclide

Number of 

Reported Values

U-233/U-23416

U-23320

U-23426

U-235/U-23616

U-23526

U-23626

U-238 6

Pu-238 6

Pu-239/Pu-2401,3 6

Pu-23925

Pu-24025

Pu-241 6

Pu-242 0

Am-241 6

Cm-242 6

Cm-244 6

Cm-245 6

Sr-90 6

Cs-134 2

Cs-137 6

Co-60 1

Eu-154 6

Pb-210 1

1Value derived by Alpha Spectrometry

2Value derived by ICP-MS

3Because 239Pu and 240Pu cannot be resolved by alpha spectrometry the values 

reported include contributions of both radionuclides
33

(4) The development of scaling factors based on cesium-137 was found to be technically 

adequate and correctly documented.

In the context of the SNL-CCP RH characterization program, a scaling factor is the ratio of the 

activity of a typically difficult-to-measure radionuclide, e.g., 239Pu or 241Am, to an easily 

measured radionuclide, in this case 137Cs. Assuming that the container’s measured dose rate is 

attributable essentially to 137Cs, the container’s dose rate and 137Cs concentration can be 

correlated. Using radionuclide-specific scaling factors, i.e., for 238Pu, 240Pu, 233U, 234U and others, 

radionuclides are quantified by scaling them to the 137Cs content, i.e., the container’s measured 

dose rate. This allows the determination of multiple radionuclides by virtue of a single 

measurement of the container’s dose rate. The correlation of dose rate and 137Cs concentration is 

discussed in Item (5), below, and the scaling factors are summarized in Table 10.

Table 10. Scaling Factors for Waste Stream SNL-HCF-S5400-RH 

Radionuclide

137Cs Scaling Factor,

Ci Radionuclide/Ci 137Cs

Am-241 7.48E-3

Cm-242 3.78E-5

Cm-244 3.25E-4

Cm-245 2.51E-4

Pu-238 1.49E-2

Pu-239 8.81E-4

Pu-240 1.07E-3

Pu-241 5.58E-2

Pu-242 5.84E-5

U-233 1.85E-6

U-234 1.02E-3

U-235 3.35E-5

U-236 1.22E-5

U-238 4.44E-6

Cs-137 1.00E0

Eu-154 5.83E-3

Sr-90 5.67E-1

SNL-CCP developed radionuclide-specific scaling factors based on the analytical results from 

the six composite smear samples collected from parcels in PKE00044 discussed in Items (2) and 

(3), above. The radiometric and ICP-MS data from the laboratory analyses used to derive scaling 

factors were adequate for this purpose. EPA personnel reviewed the contents of the spreadsheet 

for completeness, accuracy and adequacy. Based on the J. Holderness Memorandum, the 

geometric mean of the sample scaling factors for each reported radionuclide was presented as the 

scaling factor for that radionuclide, as the distribution of sample data for each radionuclide 

appeared to be log normal distribution. For the 233U/234U radionuclide pair, SNL-CCP assigned 

the reported value from the alpha spectrometry measurements to 234U, because 233U was below 

the instrument detection limit (IDL). Other radionuclide pairs were 239Pu/240Pu and 235U/236U. For 

the 239Pu/240Pu pair, SNL-CCP used the alpha spectrometry result for each sample in conjunction 

with the 239Pu240Pu split fractions from ICP-MS to determine the activity of each radionuclide. 
34

The average split fractions were 0.453 and 0.547 for 239Pu and 240Pu, respectively. There were no 

reported activity values for 242Pu, so the 242Pu IDL was used as the 242Pu activity. 

The use of any alternate radiological characterization procedure other than DTC with established 

scaling factors as documented in CCP-TP-504 and CCP-AK-SNL-501, Revision 1, respectively, 

or substantive modification, is a T1 change. (See Table 1 where this is included as a T1 change.) 

Any revision to CCP-AK-SNL-501 that requires CBFO approval is a T2 change. (See Table 1

where this is included as a T2 change.)

(5) Computer modeling to develop the dose-to-curie correlation was evaluated and was 

found to be adequate.

SNL-CCP used the MicroShield®computer code to develop DTC correlation for a 30-gallon 

drum containing the debris waste overpacked in a 55-gallon drum. This was based on the 

assumption that a one-curie source of 137Cs was uniformly distributed within the drum and that 

the only significant gamma emitter in the drum was 137Cs. Specifically, the contributions of 

Europium-154 (154Eu), cobalt-60 (60Co) or other gamma emitters in the drum were negligible. 

This provided the specific correlation of a container’s measured dose rate and 137Cs content for 

waste densities ranging from 0.2 g/cm3to 1.8 g/cm3. Based on the measured one-meter dose

rates a least-squares curve-fitting routine was used to derive a function relating waste density and

MicroShield®-calculated dose rates. CCP-AK-SNL-501 shows a schematic of the 30-gallon 

drum overpacked in a 55-gallon drum and the 137Cs correlation curve in Figures 5-1 and 5-2, 

respectively. Reference U1032 details the development of the DTC calculation. Revision 1 of 

CCP-AK-SNL-501 and Revision 1 of SNL-RH-04 were developed to incorporate correct 

dimensions for the 30-gallon drum in the computer model. The use of any alternate scaling 

factors other than those documented in CCP-AK-SNL-501, Revision 1, is a T1 change. (See 

Table 1 where this is included as a T1 change.)

(6) Correlation of radionuclide values to the 137Cs concentration for each drum was evaluated 

and was found to be technically adequate and appropriately documented.

SNL-CCP applied the DTC correlation factor to determine the 137Cs concentration in the drum 

using the arithmetic mean of four dose measurements, made at a distance of one meter from the 

drum surface at the vertical mid-point at four 90 degree intervals. This value was divided by the 

DTC correlation factor corresponding to the waste density. SNL-CCP combined the dose 

measurements used to quantify the radionuclides of interest in the drum with the radionuclidespecific scaling factors to produce the list of radionuclides as follows: 233U, 234U, 

235U, 238U, 

238Pu, 239Pu, 240Pu, 241Pu, 242Pu, 241Am,137Cs, barium-137 (137mBa) (137Cs progeny), 90Sr, and 

yttrium-90 (90Y) (90Sr progeny). This list goes beyond the 10 WIPP-tracked radionuclides 

because all radionuclides that contribute to at least 95% of the radionuclide hazard, at least 95% 

of the thermal loading and any radionuclide that contributes greater than one percent of the total 

must be reported, which includes 137mBa and 90Y

17. Additionally, the 235U value must be 

considered for criticality purposes. The determination of radionuclide activities by SNL-CCP is 

technically adequate and correctly documented.

 

17 Transportation is not within EPA’s regulatory purview; however, this information may be useful in 

understanding a container’s radionuclide composition.
35

(7) The technical basis and documentation of total measurement uncertainty were evaluated 

and found to be adequate.

The development of Total Measurement Uncertainty (TMU) for Waste Stream SNL-HCFS5400-RH is based on the propagation of uncertainties present in the determination of the 

radiological constituents of RH TRU waste. These aspects are assumed to be independent, which 

allows them to be added in quadrature18. The TMU determination included contributions of the 

following:

137Cs DTC correlation – MicroShield® code, MicroShield® modeling, and waste density 

uncertainties

137Cs activity measurement – dose rate measurement uncertainty and uncertainty due to 

the contribution of other gamma-emitting radionuclides

Scaling factor uncertainty – sample data uncertainty (except 233U and 242Pu), isotopic 

fractions uncertainty (

239Pu and 240Pu), and ICP-MS IDL values uncertainties (233U and 

242Pu)

A general treatment of TMU for PKE00044 is presented in CCP-AK-SNL-501, Revision 1, 

Section 6, and the detailed treatment of TMU is provided in Uncertainty Analysis for the Drums 

– PKE00044, Calculation Package SNL-RH-05, Revision 1 (Reference U1033). The overall

uncertainties are consistent with what EPA has observed for RH determinations at other RH 

TRU generator sites. The overall uncertainties for PKE00044 drums are provided in Table 11, 

below. 

Table 11. Overall Uncertainty of Example Drum

Radionuclide

137Cs Uncertainty Total Scaling 

Factor

Uncertainty

Total 

Uncertainty

U-233 28.0% 100% 103.8%

U-234 28.0% 37.5% 46.8%

U-235 28.0% 37.9% 47.1%

U-238 28.0% 39.3% 48.3%

Pu-238 28.0% 32.9% 43.2%

Pu-239 28.0% 42.7% 51.1%

Pu-240 28.0% 42.6% 51.0%

Pu-241 28.0% 39.0% 48.0%

Pu-242 28.0% 100% 103.8%

Am-241 28.0% 40.5% 49.2%

Sr-90 28.0% 20.4% 34.6%

Cs-137 28.0% 0.0% 28.0%

Y-90 28.0% 20.4% 34.6%

Ba-137m 28.0% 0.0% 28.0%

 

18 Adding in quadrature is a standard statistical technique that allows one to combine the square root of the 

sum of each contributor to uncertainty squared, resulting in a lower value than what would be obtained if the values 

were simply added. For example, the total uncertainty for 239Pu is derived by taking the square root of (28.0%)2plus 

(42.7%)2, which equals 51.1%, which is less than the value obtained by simply adding the values, i.e., less than 

70.7%, as shown in Table 11.
36

(8) Execution and documentation of the dose-to-curie technique was assessed and found to 

be adequate.

EPA observed the DTC technique on May 10, 2011, in the TA-V Building 6597 for drum Nos. 

SNLNM007008, SNLNM007009 and SNLNM00702019. The SNL-CCP DTC operators were 

James Rowsell and Jimmy Palmer, both of whom were listed on the current LOQI. They 

supervised the SNL personnel who actually handled the drums and ensured that all appropriate 

CCP aspects of the process were addressed. The DTC personnel began by performing the 

operational check on Dyna-Link Scale No. XC0702, which was last calibrated on June 3, 2010, 

and is due for recalibration on June 3, 2015. SNL personnel weighed the drum and CCP 

operators recorded the weight. The weights were recorded on the Measurement Control Report 

(CCP-TP-504, Attachment 1) and summarized in the operational log book.

DTC personnel performed the source checks for Thermo Scientific Model FH 40 G Dose Rate 

Measuring Unit with FHZ 612 Probe (Instrument No. 023553) attached to Probe No. XC0676. 

The ambient background was measured and source checks were performed for the high and low 

ranges and all measurements were recorded on the Measurement Control Report and summarized 

in the operational log book. DTC personnel consulted CCP Operator Aid: RH-SNLNM-001, 

Revision 0, 5-09-11, which listed tolerances for the Test Drum Weights, Scale Error, Operational 

Ranges for the Geiger Mueller Probes and acceptance criteria for the source checks. This 

operator aid was revised to correct minor inconsistencies and was reissued as Revision 1 on May 

12, 2011. DTC operators took a background dose reading while all containers were in a shielded 

position. SNL personnel then lifted drum No. SNLNM007008 onto the DTC assembly and J. 

Palmer and J. Rowsell observed SNL personnel perform the DTC process in accordance with 

CCP-TP-504, Revision 11. A copy of the Measurement Control Report was provided to EPA and 

it included all pertinent information. Measurements were made in four locations on the drum’s 

circumference (0 , 90 , 180 and 270 ) and all measurements were recorded on the Container 

Data Sheet (CCP-TP-504, Revision 11, Attachment 2), a copy of which was provided to EPA. 

EPA observed the same process for two additional drums (Nos. SNLNM007009 and 

SNLNM007020), as stated previously. Contact dose rates for each of the three drums exceeded 

the 200 mrem/hr dose rate, which was inferred by multiplying the one-meter readings by 18. All 

contact dose rate readings exceeded three times the measured background of 0.2 mr/hr. The 

measurements and all accompanying parameters were acceptable, and a copy of the 

Measurement Control Report and the Container Data Sheet for all drums are contained in DTC 

BDR SNLRHDTC11001, as discussed in Item (9), below. 

The use of any alternate radiological characterization procedure other than DTC with established 

scaling factors documented in CCP-TP-504 and CCP-AK-SNL-501, Revision 1, respectively, or 

substantive modification thereof, is a T1 change. (See Table 1 where this is included as a T1 

change.) Any change to CCP-TP-504 that requires CBFO approval is a T2 change. (See Table 1

where this is included as a T2 change.)

 

19 Container No. SNLNM007020 is not part of PKE00044 and technically is not within the scope of this 

inspection however EPA observed the DTC process as executed by SNL-CCP for all three drums.
37

(9) Radionuclide documentation in dose-to-curie batch data reports was assessed and found 

to be adequate.

The DTC results for all containers were documented in a single BDR, SNLRHDTC11001. The 

EPA inspection team verified that this BDR included the following:

SPM Checklist, Attachment 8

BDR Cover Sheet, Attachment 4

DR Table of Contents, Attachment 5

BDR Narrative Summary, Attachment 6

ITR Review Checklist, Attachment 7

Measurement Control Report with all parameters acceptable, Attachment 1

Container Data Sheets, Attachment 2

Waste Container DTC Conversion Records with all required parameters, Attachment 3

Evidence of signatures by the ITR on Attachment 7 and an SPM on Attachment 8

Type of waste in each container on Attachment 3, organic and inorganic

TRU determination for all containers on Attachment 3 

Correct revision of CCP-TP-504, Revision 11

The BDR was technically adequate. 

(10) Remote-handled determinations were evaluated and found to be adequate.

The determination that each container in the stream was RH, i.e., had a contact dose rate in 

excess of 200 mrem/hr, must be based on unshielded dose rates. This required the use of a 

surface dose multiplier, defined as the ratio of the surface dose rate where no credit is taken for 

shielding to the shielded dose rate. SNL-CCP used MicroShield to model the unshielded dose on 

the drum surface, and developed dose rate multipliers for both configurations, as documented in 

calculation package SNL-RH-07, Calculation of Drum Surface Dose Rate (Reference U356) [see 

Item (5), above]. SNL-CCP corrected the measured (shielded) dose rate using the surface dose 

multiplier to make the RH determination. Memorandum B-NEO(NE)DNE-64E, dated April 12, 

2011, titled Erratum: Surface Dose Rates for 55-Gallon Drums Loaded with Sandia National 

Laboratory Remote Handled Transuranic Debris Waste Stream SNL-HCF-S5400-RH adequately 

documents this procedure.

(11) TRU determinations were evaluated and were found to be adequate.

DTC BDR SNLRHDTC11001 contained values and the associated uncertainties for the 10 

WIPP-tracked radionuclides plus other radionuclides, as appropriate. In all cases the TRU alpha 

concentration exceeded 100 nCi/g. 

Summary of Radiological Characterization Findings and Concerns

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

characterization. There are no open issues related to radiological characterization resulting from 

this inspection.
38

Proposed Baseline Approval

EPA is proposing to approve the radiological characterization process consisting of DTC as 

described in CCP-TP-504 in conjunction with the radionuclide scaling factors documented in 

CCP-AK-SNL-501, Revision 1, that were evaluated during this baseline inspection. This 

approval is limited to the 19 parcels in PKE00044, and separate approvals for the remaining two 

waste groups (PKE00047 and PKE00027/54) of RH Waste Stream SNL-HCF-S5400-RH will be 

necessary as T1 changes. However, any additional PKE00044 parcels that are identified to be 

RH during characterization of the associated CH waste stream may be added to PKE00044, as 

discussed in Sections 1.0 and 7.1, above. Specifically:

1. Additional containers must have a pedigree similar to the containers in PKE00044 

described in this report; and

2. SNL-CCP must be able to demonstrate that the radionuclide scaling factors used for 

waste containers from PKE00044 proposed for approval in this report (discussed in 

Section 8.2, below) are technically appropriate for use in the DTC determination of the 

radiological characterization of the additional containers. 

Following EPA’s approval of SNL-CCP’s RH program, if additional RH debris waste containers 

meeting the above criteria are to be emplaced in the WIPP facility, EPA notification and 

submission of the appropriate supporting documentation will be necessary immediately upon 

identification and characterization of the additional containers. Upon receiving the AK and 

radiological content documentation for the newly-generated RH waste containers to be added to 

PKE00044, EPA will verify (a) the adequacy and applicability of the scaling factors discussed in 

this report to the additional containers, (b) the common radiological aspects of the 19 original 

parcels of PKE00044 and the additional containers, and (c) the technical adequacy of the AK 

documentation. EPA will evaluate this documentation and, upon determining it to be adequate, 

SNL-CCP may dispose of the additional containers at the WIPP facility. 

If a population of additional containers requires new or different radionuclide scaling factors, 

those containers will require a T1 evaluation and approval prior to disposal at the WIPP. 

Therefore, this proposed approval pertains only to the 19 parcels in PKE00044. 

In the future, if CH information is used to characterize SNL-CCP RH waste containers, EPA 

may determine that evaluation of the applicable CH program is necessary. This evaluation would 

be warranted since the EPA has not reviewed the documentation that SNL, a small quantity 

generator, prepares as part of the inter-site transfer of CH TRU waste to the INL for 

characterization and disposal.
39

8.3 Visual Examination

Waste Characterization Element Description

As part of the inspection of the VE activities, the EPA inspection team focused on overall 

procedural technical adequacy and implementation, as well as the identification of WMPs and 

prohibited items, in reviewing the following VE elements: 

Documentation of activities through use of an approved procedure

Proper execution of VE activities

Management oversight and independent review

Personnel training

A complete listing of all objective evidence the EPA team evaluated during the inspection is 

provided in Attachment A. VE was used to determine the following aspects of TRU waste 

characterization:

Types and amounts of WMPs

Confirmation of Waste Matrix Codes (WMC) 

Presence or absence of prohibited items 

Technical Evaluation

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

process. These areas are summarized as follows:

(1) Overall procedural technical adequacy and implementation were adequate.

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

visual examination, including identification of prohibited items, assignment of Waste Material 

Parameters (WMP), data recording and technical review of the VE results. The EPA assessed 

this procedure for technical adequacy and completeness and found it to be adequate. Any change 

to the VE procedure(s) that requires CBFO approval is a T2 change. (See Table 1 where this is 

included as a T2 change.)

(2) Characterization of WMPs and prohibited items was assessed and was found to be 

adequate.

VE operations and sampling activities took place simultaneously. EPA observed the VE 

operations for parcel P2000998, original container No. C200357, which was repackaged into 30-

gallon container P1110158, and the final 55-gallon container SNLNM007020. The operators 

verified that the receiving (daughter) drum was empty. The parcel was a 5-gallon paint can, 

labeled “HCFSCB-3 sweeping.” A smaller can (approximate volume 1 pint) was removed from 

the 5-gallon paint can. VE was performed on the contents of the inner can and the waste items 

were placed into the receiving 30-gallon container, No. P1110158. Waste items removed from 

the 1-pint can were identified and recorded by the CCP VE personnel. Two operators performed 
40

VE in accordance with procedure CCP-TP-500 using Attachment 1, the VE data form from the 

procedure. The EPA reviewed BDR Nos. RHSNLVE100001, RHSNLVE110001, 

RHSNLVE110002, and RHSNLVE110003 and determined that VE data contained within the 

BDRs had been generated and recorded in accordance with procedure requirements. Data sheets 

were completed and signed. EPA inspectors determined that ITR- and SPM-level reviews were 

adequately performed and appropriately recorded.

The use of VE for waste SCGs not covered by this approval or by any new process for S5000 

debris wastes is a T1 change. (See Table 1 where these are included as T1 changes.) The addition 

of new SNL-CCP S5000 debris waste streams is a T2 change. (See Table 1 where this is 

included as a T2 change.)

(3) Documentation of VE activities was examined and was found to be adequate.

EPA reviewed BDR Nos. RHSNLE100001, RHSNLVE110001 and RHSNLVE110001, which 

contain VE data for PKE00044 examined during this inspection. EPA also reviewed BDR No. 

RHSNLVE110003 which contained VE data from the parcel observed on-site during the March 

visit. WMPs were identified and recorded on the VE Data Form, and the absence of prohibited 

items was confirmed and recorded. WMP weights are not assigned during VE of RH waste 

because all waste item weights are reported into WWIS/WDS as “plastic”. Waste item categories 

were identified, for example, cellulosics (C) and “other metal” (OM), and recorded on the VE 

data sheets. Table 2 of CCP-TP-500 provides a complete listing of WMPs. A listing of 

prohibited items is provided in Table 1 of the procedure and the absence or presence of these 

items was recorded on VE data sheets. No prohibited items were identified in the containers 

subject to VE and reported in the above BDRs.

(4) Training of VE personnel was evaluated and was found to be adequate.

SNL-CCP maintains a list of qualified individuals (LOQI), which it uses to ensure that all 

training is current. SNL-CCP documents the personnel who are trained for performing VE and 

data generation-level data review, and the VEE. The EPA team reviewed the Qualification Cards 

for the VEO and VEE and found that these VE operators were comprehensively and adequately 

trained to perform VE operations. The training records were complete and available for review.

Summary of VE Findings and Concerns

The EPA team did not identify any findings or concerns related to VE during this baseline 

inspection.

Proposed Baseline Approval

EPA is proposing to approve the VE process for RH TRU Waste Stream SNL-HCF-S5400-RH 

as observed at SNL and documented in VE BDR No. RHSNLVE100001.
41

9.0 RESPONSE TO COMMENTS

This section is reserved for responses to public comments.

10.0 SUMMARY OF RESULTS 

10.1 Environmental Protection Agency Findings and Concerns

EPA identified one concern during this inspection related to the processes SNL-CCP 

implemented to characterize RH TRU debris Waste Stream SNL-HCF-S5400-RH. A copy of the 

EPA Inspection Issue Tracking Form that captures the finding is included in Attachment C of 

this report. Several rounds of communication between EPA and CBFO personnel followed 

issuance of this concern. This process continued until sufficient objective evidence to support upto-date knowledge of each of the four bullets listed in Section 8.1 (13) above had been provided

for all personnel responsible for compiling AK for RH waste at SNL-CCP. CBFO responses to 

EPA’s concern are included in entirety as three different reports in the EPA Air Docket 

supporting the Federal Register notice announcing the proposed baseline approval of SNLCCP’s RH program. (The direct link to the docket for these documents can be found in the 

Federal Register notice announcing the proposed approval.) The specific issue (namely, lack of 

objective evidence showing training of AK personnel) is discussed in Section 8.1, (13) of this 

report. The EPA inspection team completed their review of the documents submitted in response 

to the EPA concern and determined that objective evidence provided supporting the response is 

adequate. As a result, EPA considers this issue to be closed. No issues resulting from this 

baseline inspection remain open at this time.

10.2 Conclusions

This proposed approval is based on EPA’s baseline inspection conducted in three steps: 

observation of the VE and sampling processes at SNL on March 8, 2011; observation of DTC 

measurements on May 10, 2011 at SNL; and the formal baseline inspection on June 7-8, 2011, 

held in Golden, Colorado. EPA evaluated the SNL-CCP’s RH waste characterization program

for the 19 parcels of waste group PKE00044 from the debris waste stream SNL-HCF-S5400-RH 

and determined it to be technically adequate. The proposed approval includes the following:

(1) The AK process for 19 parcels of the retrievably-stored TRU debris waste from 

PKE00044 waste designated as SNL Waste Stream SNL-HCF-S5400-RH

(2) The radiological characterization process using DTC and scaling factors for assigning 

radionuclide values to 19 parcels of PKE00044 waste from Waste Stream SNL-HCFS5400-RH that is documented in CCP-AK-SNL-501, Revision 1, and supported by the 

calculation packages referenced in this report

(3) The VE process to identify WMPs and the physical form of the debris waste SNL-HCFS5400-RH

This approval is limited to the 19 parcels in PKE00044; however, any additional PKE00044 

parcels that are identified to be RH during characterization of the associated CH waste stream 

may be added. Following EPA’s approval of SNL-CCP’s RH program, if additional RH debris 
42

waste containers meeting the above criteria are to be emplaced in the WIPP facility, EPA 

notification and submission of the appropriate supporting documentation will be necessary 

immediately upon identification and characterization of the additional containers. Upon 

receiving the AK and radiological content documentation for the newly-generated RH waste 

containers to be added to PKE00044, EPA will verify (a) the adequacy and applicability of the 

scaling factors discussed in this report to the additional containers, (b) the common radiological 

aspects of the 19 original parcels of PKE00044 and the additional containers, and (c) the 

technical adequacy of the AK documentation. EPA will evaluate this documentation and, upon 

determining it to be adequate, SNL-CCP may dispose of the additional containers at the WIPP 

facility. 

In the future, if CH information is used to characterize SNL-CCP RH waste containers, EPA 

may determine that evaluation of the applicable CH program is necessary. This evaluation would 

be warranted since the EPA has not reviewed the documentation that SNL, a small quantity 

generator, prepares for the inter-site transfer of CH TRU waste to the INL for characterization 

and disposal.

At the time of this inspection, scaling factors had only been developed for PKE00044 population 

wastes. Therefore, this proposed approval pertains only to the 19 parcels in the PKE00044 

population in Waste Stream SNL-HCF-S5400-RH. Characterization of the 13 remaining parcels 

in PKE00047 and PKE00027/54 of Waste Stream SNL-HCF-S5400-RH is a T1 change requiring 

EPA approval. Characterization of any additional RH wastes at SNL-CCP will require a new 

baseline inspection and approval. Table 12 below proposes specific tiering changes requiring 

EPA approval (for T1 changes) or concurrence (for T2 changes). 
43

Table 12. Tiering of RH TRU Waste Characterization Processes Implemented by SNL-CCP

(Based on June 6-8, 2011 Baseline Inspection)

RH Waste 

Characterization Process 

Elements

SNL-CCP RH Waste Characterization Process - T1 Changes SNL-CCP RH Waste Characterization Process - T2 Changes*

Acceptable Knowledge (AK) Two remaining waste groups (PKE00047 and PKE00027/54) belonging to a 

debris waste stream SNL-HCF-S5400-RH and any new RH waste stream not 

approved to date or modification of an approved waste stream to include 

additional containers if new or different radionuclide scaling factors are required 

(AK1)

Substantive modification(s)** that have the potential to affect the characterization 

process to CCP-AK-SNL-500 or CCP-AK-SNL-502 (AK2, AK6)

Notification to EPA: 

Upon completion of revisions of CCP-AK-SNL-500, CCP-AK-SNL-502,

CCP-TP-005, or nonconformance and corrective action procedures that 

require CBFO approval*** (AK2, AK5, AK6, AK14)

When the final or revised WSPF, CRR, and related attachments are available 

(AK10)

When AK accuracy reports are completed, prepared annually at a minimum 

(AK11)

When Attachment 4 of CCP-TP-005 is generated to reflect the updated AKSR 

Source Document Reference List (AK6)

When Add Container Memoranda have been prepared (AK5)

When additional Discrepancy Resolution Reports have been prepared (AK4)

If a CSSF is prepared (AK11)

Radiological Characterization

(RC), including Dose-To-Curie 

(DTC) 

Application of new scaling factors for isotopic determination other than those 

documented in CCP-AK-SNL-501 (RC4, RC5)

Use of any alternate radiological characterization procedure other than DTC with 

established scaling factors as documented in CCP-TP-504 and 

CCP-AK-SNL-501, Revision 1, respectively, or substantive modification**

thereof (RC4, RC5)

Any new RH waste stream not approved to date or the addition of containers to 

an approved waste stream that requires changing the established radionuclide 

scaling factors or radiological characterization process (RC1)

Notification to EPA upon completion of revisions of CCP-AK-SNL-501 or CCP-TP504 that require CBFO approval*** (RC1, RC8)

Notification to EPA of availability of a revised radiological characterization report, if 

required for the addition of containers to the approved waste streams (RC5)

Visual Examination (VE) VE by reviewing existing audio/visual recordings for Summary waste category 

not covered by this approval (VE2)

VE by any new process for S5000 debris wastes (VE2)

Notification to EPA upon completion of changes to VE procedure(s) that require 

CBFO approval*** (VE1)

Addition of new S5000 debris waste streams (VE2)

Notes:

* SNL-CCP will report all T2 changes to EPA every three months.

** Substantive modification refers to a change with the potential to affect SNL-CCP’s RH waste characterization process, e.g., the use of an inherently different type of 

measurement instrument or the use of probes not described in CCP-TP-504, excluding changes related to solely to safety or to address administrative concerns

*** Notification to EPA is not necessary when document updates are editorial in nature or are required solely to address administrative concerns
44

11.0 REFERENCES 

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

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

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

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

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

and Transuranic Radioactive Wastes.”

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

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

40 CFR Part 191 Disposal Regulations.”

U.S. Department of Energy, Office of Environmental Management, “Radioactive Waste 

Management Manual,” DOE M435.1-1, July 9, 1991, Change 1: June 19, 2001.

U.S. Department of Energy, Carlsbad Field Office, “Remote Handled TRU Waste 

Characterization Program Implementation Plan,” DOE/WIPP-02-3214, Revision 0D, Carlsbad, 

New Mexico, October 30, 2003.

U.S. Department of Energy, Carlsbad Field Office, “Remote Handled TRU Waste 

Characterization Program Implementation Plan,” DOE/WIPP-02-3214, Revision 2, Carlsbad, 

New Mexico, April 21, 2011.

U.S. Department of Energy, Title 40 CFR Part 191, Compliance Certification Application for the 

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

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

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

U.S. Department of Energy, “Remote-Handled Transuranic Waste Authorized Methods for 

Payload Control (RH-TRAMPAC),” Carlsbad, New Mexico.
A-1

ATTACHMENT A: DOCUMENTS REVIEWED

CCP-AK-SNL-500, Central Characterization Project Acceptable Knowledge Summary Report 

for Sandia National Laboratories/New Mexico Remote-Handled Hot-Cell Facility Transuranic 

Waste (Debris), Waste Stream: SNL-HCF-S5400-RH, Revision 1, March 4, 2011 and Revision 

2, July 6, 2011

CCP-AK-SNL-501, Central Characterization Project Remote-Handled Transuranic Radiological 

Characterization Technical Report for Sandia National Laboratories/New Mexico Hot-Cell 

Facility Remote-Handled Transuranic Debris Waste, Waste Stream: SNL-HCF-S5400-RH,

Revision 0, May 10, 2011 and Revision 1, August 3, 2011

CCP-AK-SNL-502, Central Characterization Project RH TRU Waste Certification Plan for 40 

CFR Part 194 Compliance and Confirmation Test Plan for Sandia National Laboratories/New 

Mexico Laboratory Remote-Handled Transuranic Debris Waste, Waste Stream: SNL-HCFS5400-RH, Revision 0, May 10, 2011 and Revision 1, August 10, 2011

CCP-AK-SNL-505, Central Characterization Project Sampling and Analysis Plan for Sandia 

National Laboratory Remote-Handled Transuranic Debris Waste, Waste Stream: SNL-HCFS5400-RH, Revision 0, November 29, 2010

CCP-TP-002, Attachment 2 – CCP Waste Stream Profile Form, Waste Stream SNL-HCF-S5400-

RH, Draft for Audit Purposes, Provided June 1, 2011

CCP-TP-005, Attachment 1, Acceptable Knowledge Documentation Checklist, April 25, 2011

CCP-TP-005, Attachment 4, Acceptable Knowledge Source Document Reference List, April 25, 

2011 and June 16, 2011

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

Packaging, April 21, 2011

CCP-TP-005, Attachment 8, Waste Containers, April 21, 2011

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

NCR-RHSNL-2350-11, June 16, 2011

CCP-TP-005, Attachment 13, CCP Waste Stream Characterization Checklist, Draft, Provided 

June 21, 2011

CCP-TP-500, Revision 10, CCP Remote-Handled Waste Visual Examination, December 29, 

2010

CCP-TP-512, CCP Remote-Handled Waste Sampling, Revision 4, December 29, 2010
A-2

Characterization Reconciliation Report for Waste Stream SNL-HCF-S5400-RH, Draft for Audit 

Purposes, Provided June 1, 2011 and June 27, 2011

Characterization Information Summary, Waste Stream SNL-HCF-S5400-RH, Draft, Provided 

June 24, 2011

DTC BDR No. SNLRHDTC11001

Inter-Office Correspondence, from Irene Quintana to CCP Records Custodian, Acceptable 

Knowledge Accuracy Report, Sandia National Laboratory/New Mexico Waste Stream Number 

SNL-HCF-S5400-RH, Lot 1, For Audit Purposes Only, May 31, 2011

List of qualified individuals (LOQI) for waste sampling and VE; January 1, 2011 and May 4, 

2011

NCRs: NCR-RHSNL-2345-11 and NCR-RHSLN-2350-11

Post Sampling Analysis Memorandum: Analysis of Sample Data for Sandia National 

Laboratory/New Mexico (SNL/NM), Waste Stream SNL-HCF-S5400-RH, J. Holderness, April 

26, 2011

Qualification Card for J. Kleckner, provided May 3, 2011

Qualification cards and training records for VE operators/ITRs, and VEEs

Sampling BDR Nos. SNRH1001 and SNRH1101

VE BDR Nos. RHSNLVE100001, RHSNLVE110001, RHSNLVE110002, and 

RHSNLVE110003

Laboratory Analytical Data Packages: ALD 11007A, Actinides by Alpha Spectrometry, 

Radiochemical Analysis Data Report; ALD11007L, Liquid Scintillation Counting 

Radiochemical Analysis Data Report; ALD11007I, ICP-MS Isotopic Data Report and Narrative

C1004, Reactor Accident Experiments and Funding, Sandia National Laboratories, Summer 

1978

C1038, Ken Reil lnterview by John Kleckner, February 3, 2010

C1039, Waste Material Parameter Memorandum for Waste Stream SNL-HCF-S5400, John 

Kleckner, February 1, 2010

DR1001, Discrepancy Resolution for the Assignment of EPA Hazardous Waste Numbers, Kevin 

J. Peters and Steve Schafer, February 15, 2011
A-3

DR1002, Discrepancy Resolution for Container #P1110154 (Parent Container C980313), John 

Kleckner, April 21, 2011

DR1003, Discrepancy Resolution: Assignment of EPA Hazardous Waste Numbers, Steve 

Schafer, June 15, 2011

I1030, Hot Cell Facility (HCF) Decontamination Plan, December 13, 1994

M1015, Miscellaneous Articles and Public Extracts, 1976 to 2008, not inclusive

M1016, Disposal Requests from the 2007/2008 Repackaged Containers, 2007 through 2008

M1019, Collection of Spreadsheets Pertaining to TRU Waste Generated at the AHCF and Other 

Locations in TA-V, September 18, 2007

M1020, Process Knowledge Evaluations (PKE) for Radiological Ratios (e.g., PKE00044 and 

PKE00047), March 1980 through March 2004

M1021, Memo to Record, re: Evaluation of Radionuclide Activity Ratios for Hot Cell Facility 

Wastes (PKE00044 and PKE00047) and Memo to Record, re: PKE000047 Radionuclide 

Activity Ratios, Michael Enghauser, June 24, 2004 and June 24, 2004

P1015, Sampling and Analysis Plan for Characterization of Waste Arising From Hot Cell 

Facility Glovebox Decontamination, PLA 95-28, Revision 1, October 12, 1995

P1030, Plutonium, The First 50 Years, undated

P1041, Sandia National Laboratories/New Mexico Environmental Information Document, 

Volume II, J.V. Guerrero, K.A. Kuzio, W.H. Johns, L.S. Bayliss, and B.B. White, SAND99-

2022/2, September 1999

P1044, The Department of Energy's Tritium Production Program, R.E. Rowberg, RL30425, 

November 02, 2001

P1102, Building 6580 Hot Cell Facility, Steel Containment Boxes and Zone 2A Process 

Knowledge Documentation: Isotope Production Program, Hot Cell Facility Decontamination 

Project, L. Fugelso, S. Longley, and S. Bourcier, June 26, 1996

P1104, Hot Cell Facility (HCF) Safety Analysis Report, Main Report and Appendices, Louis F. 

Restrepo, SAND94-2650, October 21, 1994

U1029, Radiochemistry and Mass Spectrometry Data Input Check, J. Vance, SNL-RH-01, 

Revision 0, May 6, 2011

U1030, Scaling Factor Development Debris – PKE00044, J. Vance, SNL-RH-02, Revision 0, 

May 6, 2011
A-4

U1031, Determination of Reportable Radionuclides – PKE00044, J. Vance, SNL-RH-03, 

Revision 0, May 6, 2011

U1032, Drum Dose-to-Curie Derivation for Cs-137, J. Vance, SNL-RH-04, Revision 0, May 6, 

2011

U1032, Drum Dose-to-Curie Derivation for Cs-137, J. Vance, SNL-RH-04, Revision 1, May 31, 

2011

U1033, Uncertainty Analysis for Drums-PKE00044, J. Holderness, SNL-RH-05, Revision 0, 

May 6, 2011

U1033, Uncertainty Analysis for Drums-PKE00044, J. Holderness, SNL-RH-05, Revision 1, 

May 31, 2011

U1034, DTC and Related Calculations for Drums PKE00044, J. Holderness, SNL-RH-06, 

Revision 0, May 6, 2011

U1034, DTC and Related Calculations for Drums PKE00044, J. Holderness, SNL-RH-06, 

Revision 1, May 31, 2011
B-1

ATTACHMENT B: PERSONNEL CONTACTED DURING INSPECTION

Personnel Name Affiliation Area of Expertise, Function Sampling - VE DTC AK

Rajani Joglekar U.S. EPA ORIA Inspection Team Leader  

Ed Feltcorn U.S. EPA ORIA Inspection Team  

Connie Walker SC&A Inspection Team, AK 

Kira Darlow SC&A Inspection Team, AK 

Dorothy Gill SC&A Inspection Team, VE  

Rose Gogliotti SC&A Inspection Team, Radiological Characterization  

Patrick Kelly SC&A Inspection Team, Radiological Characterization  

Amir Mobasheran* SC&A Inspection Team, Radiological Characterization – – –

Andrew Stallings CCP SQS Project Manager 

James Rowsell CCP DTC Operator 

Jimmy Palmer CCP DTC Operator 

Mitchell Callahan SNL Radiation Protection 

John Miller SNL Radiation Protection 

Tommy Mojica WTS-CCP Visual Examination Expert 

Spencer Pattee WTS-CCP Visual Examination Operator 

Ronnie Lee WTS-CCP CCP Project Manager 

Michael Sensebaugh WTS-CCP CCP Projects Manager 

Laura Nelson CCP RH Site Project Manager 

Mark Doherty CCP-TechSpecs AK Expert 

Betty Humphrey SNL TRU Waste Specialist 

Jim Holderness WTS-CCP Radiological Characterization 

Kevin Peters CCP-TechSpecs SNL-CCP AK Expert 

John Kleckner CCP-TechSpecs SNL-CCP AK Expert 

Steve Schafer CCP-TechSpecs SNL-CCP AK Expert 

Court Fesmire CBFO CBFO Representative  

Irene Quintana WTS-CCP RH Site Project Manager   

Jene Vance WTS-CCP Radiological Characterization 

*Amir Mobasheran performed his evaluations via a desk-top review.
C-1

ATTACHMENT C: EPA INSPECTION ISSUE TRACKING FORM 

NO. SNL-CCP-RH-AK-11-01CR

Inspection No. EPA-SNL-CCP-RH-06.11-8 Issue Number: SNL-CCP-RH-AK-11-01CR

Date: June 8, 2011

Inspector: C. Walker and K. Darlow

Attachments? YES NO

Sample Size: Unknown

Population size (if known): Unknown

A. Description of Issue: The WCPIP, Revision 2, requires that characterization personnel 

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

assessing the AK characterization shall be qualified and trained to (1) the WCPIP, (2) the 

characterization program nonconformance and corrective action process, (3) site-specific waste 

streams (e.g., current AKSR), and (4) determination of radiological contents of individual 

containers. The WCPIP requires (on page 33): “The RH TRU characterization program is 

responsible for maintaining records of the training provided to personnel responsible for 

compiling AK.”

SNL-CCP was unable to provide objective evidence showing that the AKEs compiling AK 

documents for the Sandia waste are trained to the above requirements. Through interviews and 

discussions with AKEs EPA was able to conclude that they are up to date on the training 

requirements listed above. However, the RH TRU characterization program does not maintain the 

required records and that deficiency in the RH Program at SNL-CCP must be addressed to be in 

compliance with WCPIP, Revision 2 that was effective April 21, 2011.

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): WCPIP, Revision 2, Section 4.1 describes the requirements for AK 

training documentation and the AK QA comparability that includes training.

D. Discussed with: M. Doherty, C. Fesmire, I. Quintana, Kevin Peters and Steve Schafer

E. Additional Comments: None

F. Site Response Information:

Site Response Required? YES NO

Site Initial Response Due Date: June 23, 2011