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 F OR 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 2011i 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 Radiolog ical 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

................................ ................................ ................................ ......................... 44ii ATTACHMENTS

Attachment A: Documents Reviewed During the Baseline Inspection Attachment B: Inspection Personnel List Attachment C: EPA Inspec tion 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 Act ivity 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 FI GURES
Figure 1. Characterization and Qualification Process

................................ ................................ . 14 Figure 2. Flow Diagram of the Characterization Process for SNL

- HCF

- S540 0

- RH

.................. 29iii ACRONYMS AND INITIAL IZATIONS

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 C arlsbad 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 Surrogat e 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/cm 3 grams per cubic centimeter
HCF hot cell facilityiv

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
LW A 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

mr em/hr millir em 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 quali ty assurance objectives QAPD Quality Assurance Program Documentv

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
SC B 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
W MC waste matrix code
WMP waste material parameter
WSPF Waste Stream Profile Form
WWIS WIPP Waste Information System
Y yttrium1

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. 1 In accordance with 40 CF R 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 em place SNL

CCP 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) me asurements on May 10, 201 1 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 i nspection evaluated: acceptable knowledge (AK) records; DTC, in conjunction with radionuclide

- specific scaling factors supported by radiochemical analyses of smear 2 samples from the parcels ; and VE to confirm the physical and radiological contents of waste containers. 3 EPA 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

n o 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 SNL

HCF

- S5400

- RH th at 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 materi als 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 u sed 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 c haracterization 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 conduc ted 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, specificall y 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 PKE s 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.

L ike some pre vious 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 ped igree 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 notifi cation 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 w aste 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 add itional containers, and (c) the technical adequacy of the AK documentation. EPA will evaluate this documentation and, upon determining it to be adequate, S NL

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

. If a population of additiona l 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 was te containers, EPA may determine that evaluation of the applicable CH program is necessary. This evaluation would be warranted since the EPA has not review ed the documentation that SNL , a small quantity generator, prepares as part of the inter

- site transfe r 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 complian ce 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).4 Table 1

. Tiering of RH TRU Waste Characterization Processes Implemented by S NL

- CCP (Based on June 6

- 8 , 20 11 Baseline Inspection )

RH Waste Characterization Process Elements S NL

- C CP RH Waste Characterization Process

- T1 Changes S NL

- 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 a ny new RH w aste stream not approved to date or m odification of an approved w aste s tream to include additional containers if new or different radionuclide scaling factors are required (AK1)

Substantive modification(s)** that have the potential to affect the character iz ation process to CCP

- AK

- SNL

- 500 or CCP

- AK

- SNL

- 502 (AK2 , AK6 ) Notification to EPA: U pon completion of revisions of CCP

- AK

- S NL

- 50 0, 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

- S NL

- 501 or CCP

TP

- 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 mod ification 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 so lely 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 administ rative concerns5

2.0 PURPOSE OF INSPECTIO NS
On May 18, 1998, EPA certified th at 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 th an [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 requi res DOE to (1) provide EPA with information on acceptable knowledge (AK) 4 for 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 promulgate d 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 demonstrat ion 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 va lue or fall below the lower limiting value described in the introductory text of paragraph of this section. 5 The system of controls shall include, but shall not be limited to: measurement; sampling; chain of custody records; record keeping systems; waste l oading 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 c haracterizing 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 generate d, 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 te xt 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 as sociated 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 in spection. 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) identi fication and measurement of waste components, such as plutonium (Pu), that must be tracked for compliance, 6 and (2) confirmation that the waste in any given container has been properly identified as belonging to the group of approved waste streams.

3.0 PURPO SE 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 limi tations 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 characteriza tion 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 te chnical 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 l ist. 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 fro m 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 confir m 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 sep arately 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 w aste 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 R H 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 ( 241 Am), cesium

- 137 ( 137 Cs), plutonium

- 238 ( 238 Pu), 239 Pu, 240 Pu, 242 Pu, strontium

- 90 ( 90 Sr), uranium

- 233 ( 233 U), 234 U, and 238 U] and other TRU radionuclides using a combination of AK and DTC with the application of radionuclide

specific 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 evaluate s the site’s waste characterization processes to characterize RH TRU debris was te. 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 process es 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 procedu res, 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. Objec tive 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 characterization8

process produ ced, 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 SNL

CCP compl y with the revised WCPIP.

5.0 INSPECTION

- RELAT ED 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 th at 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 PERSO NNEL
EPA and its support personnel conducted interviews with SNL

- CCP personnel in several disciplines during two site visits to SN L and the meeting in Golden, Colorado. The members of the EPA inspection team and personnel contacted are listed in Attachmen t B.

7.0 PERFORMANCE OF THE I NSPECTION

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 ( AKS R ) 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 SNL 7 Hot Cell Fac ility (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 p rocesses 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 Fu el 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 generat ed 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 separ ate 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 b ecause 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 characterizat ion 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 glovebo xes). 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 Sou rce 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 s ite 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 fo r the three distinct, area

- specific radiological signatures. Therefore, t his 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 o f 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 submiss ion 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, S NL

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

.
7.2 Inspection Process Overview

EPA conducted Base line Inspection No. EPA

- SNL

- CCP

- RH

- 06.11

- 8 of SNL

- CCP’s program to characterize RH TRU wastes at SN L 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 descri bed 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 characte rization 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 logistics11

(5) Evaluating SNL

- CCP’s implementation of waste characterization processes for ad equacy 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 E PA 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 Accept able 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 St ream SNL

- HCF

S5400

- 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 str eam identification Identification of the WCPIP waste characterization process Adequacy of the Certification Plan and other WCPIP documentation12

Adequacy of WCPIP waste qualification pathway Adequacy of data management reviews, validation activities, data r eporting 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 ch aracteristics 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 scalin g 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 sourc e 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 applica ble. 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 B DR VE BDR DTC BDR SNLNM0053 39 SNRH1001 ALD11007 RHSNLVE100001 SNLRHDTC11001 SNLNM007007 SNRH1101 ALD11007 RHSNLVE110001 SNLRHDTC11001 SNLNM007008 SNRH1101 ALD11007 RHSNLVE110001 SNLRHDTC11001 SNLNM007009 SNRH1101 ALD11007 RHSNLVE110001 SNLRHDTC11001 SNLNM007010

– ALD11007 RHSNLV E110002 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 b aseline inspection request and waste stream determin ation 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 u sed 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, Revisio n 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 fro m 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

co mpositions 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 CCP

AK

- SNL

- 501 as T1 chang es. 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 a nd 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. Alte rnatively, 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 chara cterize 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 ha d opportunity to review documentation that the Sandia National Laboratory, a small quantity g enerator, 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 technicall y 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 ar e 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 4 0 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 Confirmat ion 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 Qual ify 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

- 50 2 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 use d 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 pr ogram 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, m easurement, 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 d o 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 characteriza tion 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 example s of non conformance reports ( NCR s). Example 1 was N CR

RHSNL

- 2345

- 11 that deal t 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 Engineers16

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 AK

Characterization discrepancy resolutions. The preparation of NCRs and discrepancy resolution reports is adequate. Notification to EPA of the availability of additional discr epancy 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, Revisio n 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 d rums 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 approva l 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.

There fore, Attachment 8, associated Add Container Memoranda, and the AK Tracking Spreadsheet will together provide the full drum history and current waste stream inventory. SNL

CCP revised CCP

- TP

- 005 (Revision 23) to address three EPA issues; the limited revisi ons 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 m ethod using Attachment 8, the AK tracking spreadsheet, and Add Container Memoranda. Notifications to EPA when Add17

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, Revisio n 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 wit hin 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 determination s. 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 exchang e 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

- H CF

- 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 document s 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 maintai n 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 QA

records. This approa ch is satisfactory as long as it is clearly understood that all records requested by EPA must to be obtain able and provided in a timely manner (e.g., prior to or during an inspection or T1 evaluation). Notification s to EPA when formal revisions of the AKSR and Attachment 4 are available are T2 change s . (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/Zon e 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 C 1039, 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 des criptions in the D iscrepancy R eport (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

- en d 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 c ould 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 ( 60 Co), 90 Sr, 235 U, 238 U, 13 7 Cs, and small amounts of TRU radionuclides, primarily 238 Pu
, 239 Pu, and 241 Am (References M1016 and M1019). In the late 1990s, SNL RWNMDD waste handlers characterized each parcel by gamma spectrometry, using either the laboratory Q Squar ed (Q 2 ) 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 MicroShiel d® modeling to estimate the 137 Cs 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 Q 2 system. SNL confi rmed 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 a ccurate 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 Q 2 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 Act ivity Ratio to 137 Cs PKE00044

Activity Ratio to 137 Cs 2004

Measured Activity Ratio to 241 Am PKE00044

Activity Ratio to 241 Am

241 Am 1.95E

- 03 6.94E

- 04 1.00E+00 1.00E+00

238 Pu 1.31E

- 02 7.17E

- 03 6.73E+00 1.03E+01

239/240 Pu 1.29E

- 03 2.00E

- 03 6.64E

- 01 2.89E+0 0

90 S r 2.95E

- 01 9.41E

- 01 NA NA

147 Pm 2.50E

- 02 6.42E

- 02 NA NA

241 Pu 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 maxim um 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 g roups 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 S pent N uclear F uel (SNF) and H igh L evel W aste (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 NWP A 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 su fficient 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 post

irradiati on experiments and decontamination operations. The waste stream does not include: accountable 13 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 PKE 000 44. W aste fr om 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 relat ed (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 pro duction (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 c ommingling 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 Fo rm and attached Characterization Reconciliation Reports were examined and found to be adequate (WCPIP, Revision 2, Section 3.4.2.1, p. 22).

The draft W aste S tream P rofile F orm (WSPF) and Characterization Reconciliation Reports ( CRR ) were provided to EPA o n June 1, 2011. Revision 2 of the WCPIP explicitly lists the required contents of both of these documents. The WSPF did not specify the B atch D ata R eport (BDR) numbers supporting waste stream characterization, and instead referenced the Characterization In formation 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. SNL

CCP, however, has elected to combine the once separate EPA and New Mexico Environmental Dep artment 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 Cert ification 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 i nterprets 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 do cument, 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 o r 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

- ga llon 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 i s 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 li st 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, e ach 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 a ll 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 re cord 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

- RW

96

- KC

- 07 C980373 P1110126 SNLNM007011 005965 3/14/96 SCBs Unknown 4/ 30 / 98 78
P9800938 HCF

- RW

96

- KC

- 06 C980374 Not yet Repackaged 005965 3/ 12 / 96 SCBs Unknown 4/ 30 / 98 78
P9800939 HCF

- RW

96

- KC

- 04 C980375 Not yet Repackaged 005965 2/ 13

- 14 / 96 SCBs Unknown 4/ 30 / 98 78
P9800940 HCF

- RW

96

- KC

- 03 C980376 Not yet Repackaged 005965 2/ 12 / 96 SCBs Unknown 4 / 30 / 98 78
P9800941 HCF

- RW

96

- KC

- 02 C980377 Not yet Repackaged 005965 2 / 7

- 8, 4 / 8 / 96 SCB ST, NPR 4/ 30 / 98 78
P9900531 HCF

- RW

95

- KC

- 01 C990238 C080215 SNLNM005339 007205 10/ 25 / 95 SCB1 ST, MP 11 / 24 / 98 37063

(13) Acceptable Knowledge training was examined and found to be adequate after the EPA identified a conce rn 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 sha ll be qualified and trained to:
The WCPIP The characterization program nonconformance and corrective action process23

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 SNL

CCP AKEs are current with respect to the training requirements listed above; however, SNL

CCP was unable to provide objective evidence of this training. The WCPIP, Re vision 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 charact erization 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 pro gram 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 req uirements. 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. T his 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 concern 14 are included in entirety in the EPA Air Docket supporting the Federal Register notice announcing the proposed baseline approval of SNL

CCP’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 obje ctive 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 Augus t 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 CCP

- TP

- 005 Initial 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: At t 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 5 R23: 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 Bri efing 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 m inimal 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 fut ure 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 p repare 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 C haracterization 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 i mpact 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 ar e 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/evaluat ions 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 Q AP D )

I nfo rmation EPA needs to support adequacy of each of EPA's inspection report elements and eventual approval 15 Type of source documents and information needed/used to develop waste stream characteristics (defense waste, TRU basis, non

- SNF and non

- HLW, waste cont ents)

H ost 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

P hysical content s 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. I mproving 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 pro ficiency.

(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 DQO s 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), ab ove, respectively.
Radioactive Properties (Regulatory Basis: LWA, EPA Certification of the WIPP) :

15 EPA provided an annotate d 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 radionuclide s 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 identif ied 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, SNL

CCP’s response is included in Attachment D, and EPA’s response to SNL

- CCP’s response is included in Attachment E . EPA conside rs 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 evaluate d during this baseline inspection. This approval is limited to the 19 parcels in PKE00044 . A ny additional newly

- generated RH waste resulting from characterization of the associated CH waste stream , however, may be added to PKE00044 provided specific condit ions 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 i dentification 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 sca ling 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 doc umentation 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 approv al 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 SN L

- 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 review ed the documentation that SNL , a small quantity generator, prepares for the inter

- site tr ansfer 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 r adionuclide

- 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 l aboratory 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 ra diological 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 in volved in the RH waste characterization program. During this RH inspection, the EPA28

inspection team evaluated the following elements of the SNL

- CCP radiological characterization program:
Sample collection observed at SN L in March 2011 External gamma measu rements (DTC) made at SN L in May 2011 Development of DTC correlation for 30

- gallon drums overpacked in 55

- gallon drums using waste densities ranging from 0.2 g/cm 3 to 1.8 g/cm 3 based on MicroShield ® modeling of the drum’s gamma dose rate using a one

- curie source of 137 Cs, assumed to be t he main contribu tor 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 adequa cy 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 t eam 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 proces ses 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

- spec ific 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 appropriat ely 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 proces s from what is documented in CCP

- AK

SNL

- 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 f rom 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) requ irements

. Procedure CCP

- TP

- 512, Revision 4, presents the sampling procedures implemented by SNL

CCP 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

- sampl ing 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 137 Cs

- based scaling factors for radionuclides of interest using labora tory results Use MicroShield ® to model the gamma dose rate in mR/hr/Ci 137 Cs as a function of waste density and develop DTC correlation

Find 1

- meter gamma dose rate based on four measurements and determine wa ste density based on drum net weight and fill factor

Multiply scaling factors by 137 Cs activity to determine radionuclides activity Divide the measured dose rate by the DTC conversion factor to find the 137 Cs activity in Curies Determine Radionuclide Specific Scaling Fac tors: Determine DTC Conversion Factor Measure Cs

- 137:30

EPA inspectors observed the sampling process for Waste Stream SNL

- HCF

- S5400

- RH in a hot

cell in Building 6597 on March 8, 2011, at SNL. The hot

- cell manipulator operators were SNL per sonnel, 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 repack aged 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 insp ection. 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 par cels (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 parc els associated with PKE00044. The samples were sent to the Idaho Cleanup Project (ICP) Analytical Laboratory 16 for radiometric and spectrometric analyses. SNL

- CCP personnel correctly recorded and reviewed the sampling data, which are contained in the labora tory 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 S NL

- 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

- s pecific 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 spe cific 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 complet e 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 Anal ytical 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 tha t 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 IDF 56 Primary Sample

SN02151102
SN02151103
SN02211101 P9800660 IDF20 Primary Sample

SN02221102
SN0223110332 Table 8

. Measurement Technique Used for Each Radionuclide
Liquid Scintillation Gas Flow

Proportional Alpha

Sp ectrometry 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 Radionucl ides in the Six Primary Samples

Radionuclide Number of

Reported Values
U

- 233/U

- 234 1 6
U

- 233 2 0
U

- 234 2 6
U

- 235/U

- 236 1 6
U

- 235 2 6
U

- 236 2 6
U

- 238 6
Pu

- 238 6
Pu

- 239/Pu

- 240 1,3 6
Pu

- 239 2 5
Pu

- 240 2 5
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
1 Value derived by Alpha Spectrometry 2 Value derived by ICP

- MS 3 Because 239 Pu and 240 Pu cannot be resolved by alpha spectrometry the values reported include contributions of both radionucli des33

(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., 239 Pu or 241 Am, to an easily measured radionuclide, in this case 137 Cs. Assuming that the container’s measured dose rate is attributable essentially to 137 Cs, the container’s dose rate and 137 Cs concentration can be correlated. Using radionuclide

- specific scaling factors, i.e., for 238 Pu, 240 Pu, 233 U, 234 U and others, radionuclides are quantified by scaling them to the 137 Cs content, i.e., the container’s measured dose rate. This allows the determination of multiple radionuclide s by virtue of a single measurement of the container’s dose rate. The correlation of dose rate and 137 Cs 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 137 Cs Scaling Factor,

Ci Radionuclide/Ci 137 Cs 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 a nd 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 233 U/ 234 U radionuclide pair, SNL

- CCP assigned the reported value from the alpha spectrometry measurements to 234 U, because 233 U was below the instrument detection limit (IDL). Other radionuclide pairs were 239 Pu/ 240 P u and 235 U/ 236 U. For the 239 Pu/ 240 Pu pair, SNL

- CCP used the alpha spectrometry result for each sample in conjunction with the 239 Pu

240 Pu split fractions from ICP

- MS to determine the activity of each radionuclide.34

The average split fractions were 0.453 and 0.547 for 239 Pu and 240 Pu, respectively. There were no reported activity values for 242 Pu, so the 242 Pu IDL was used as the 242 Pu 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 requir es CBFO approval is a T2 change. (See Table 1 where this is included as a T2 change.)

(5) C omputer modeling to develop the dose

- to

- curie correlation was evaluated and was found to be adequate.

SNL

- CCP used t he MicroS hield ® 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 137 Cs was uniformly distributed within the drum and that the only s ignificant gamma emitter in the drum was 137 Cs. Specifically, the contributions of Europium

- 154 ( 154 Eu), cobalt

- 60 ( 60 Co) or other gamma emitters in the drum were negligible. This provided the specific correlation of a container’s measured dose rate and 13 7 Cs content for waste densities ranging from 0.2 g/cm 3 to 1.8 g/cm 3 . 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

- 50 1 shows a schematic of the 30

- gallon drum overpacked in a 55

- gallon drum and the 137 Cs 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 SN L

- 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 137 Cs 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 137 C s 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 cor relation factor corresponding to the waste density. SNL

- CCP combined t he dose measurements used to quantify the radionuclides of interest in the drum with the radionuclide

specific scaling factors to produce the list of radionucli des as follows: 233 U, 234 U
, 235 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 241 Pu, 242 Pu, 241 Am
, 137 Cs, barium

- 137 ( 137m Ba) ( 137 Cs progeny), 90 Sr
, and yttrium

- 90 ( 90 Y) ( 90 Sr 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

m ust be reported, which includes 137m Ba and 90 Y 17 . Additionally, the 235 U value must be considered for criticality p urposes. T he determination of radionuclide activities by SNL

- CCP is technically adequate and correctly documented.

17 Transportation is not within EPA’s r egulatory 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 Mea surement Uncertainty (TMU) for Waste Stream SNL

- HCF

S5400

- 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 ad ded in quadrature 18 . The TMU determination included contributions of the following:

137 Cs DTC correlation

– MicroShield® code, MicroShield® modeling, and waste density uncertainties

137 Cs activity measurement

– dose rate measurement uncertainty and uncerta inty due to the contribution of other gamma

- emitting radionuclides Scaling factor uncertainty

– sample data uncertainty (except 233 U and 242 Pu)
, isotopic fractions uncertainty ( 239 Pu and 240 Pu) , and ICP

- MS IDL values uncertainties ( 233 U and 242 Pu )
A gener al treatment of T MU 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

. Over all Uncertainty of Example Drum

Radionuclide 137 Cs 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% 4 2.7 % 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 unce rtainty squared, resulting in a lower value than what would be obtained if the values were simply added. For example, the total uncertainty for 239 Pu is derived by taking the square root of ( 28.0 %) 2 plus ( 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 dos e

- 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 SNLNM007020 19 . The SNL

- CCP DTC operators were James Rowsell and Jimmy Palmer, b oth 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

- Li nk 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, Att achment 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 w as 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 Revisi on 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 pr ocess 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 do se 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 acco mpanying 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 p rocedure 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 includ ed 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 o bserved the DTC process as executed by SNL

- CCP for all three drums.37

(9) Radionuclide documentation in dose

- to

- curie batch data reports was asse ssed 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 requi red 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

- T P

- 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 w as RH, i.e., had a contact dose rate in excess of 200 mrem/hr, must be base d 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 dru m 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 t he 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

- HC F

- 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 a ppropriate . 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 PKE0 0027/54) 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 PKE 00044 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 rep ort 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 i t 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 n ecessary. This evaluation would be warranted since the EPA has not review ed 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 Examinat ion
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 rev iewing 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

Techn ical 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 W aste M aterial P arameter s (WMP) , data recording and technical review of the VE results. The EPA assessed this proce dure 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) Char acterization 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 pin t) 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 performed40

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 da ta 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. RH SNL E100001 , 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 Dat a 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 weight s are reported into WWIS/WDS as “plastic”. Waste item categories were identified, for example, cellulosi cs (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 V E 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. T he EPA team reviewed the Qualification Cards for the VEO and VEE and found that the se VE op erators were comprehensive ly 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 thi s 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 re sponses 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. T his process continued until suffi cient objective evidence to support up

to

- 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 SNL

CCP’s RH program

. (The direct link to the docket for these documents can be found in the Federal Register noti ce 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 re sponse 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

Thi s 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

me asurements 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 inc ludes 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 radionu clide values to 19 parcels of PKE00044 waste 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 (3) The VE process to identify WMPs and the physical form of t he debris waste SNL

- HCF

S5400

- 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 debris42

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 identifica tion 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 fact ors 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 documentatio n 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 review ed 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 tieri ng changes requiring EPA approval (for T1 changes) or concurrence (for T2 changes).43 Table 12

. Tiering of RH TRU Waste Characterization Processes Implemented by S NL

- CCP (Based on June 6

- 8 , 20 11 Baseline Inspection )
RH Waste Charact erization Process Elements S NL

- CCP RH Waste Characterization Process

- T1 Changes S NL

- CCP RH Waste Characterization Process

- T2 Changes *

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

- HCF

- S5400

- RH and a ny new RH waste stream not approved to date or m odification of an approved w aste s tream to include additional containers if new or different radionuclide scaling factors are required (AK1)

Substantive modification(s)** that have the p otential to affect the characteriz ation process to CCP

- AK

- SNL

- 500 or CCP

- AK

- SNL

- 502 (AK2 , AK6 ) Notification to EPA: U pon completion of revisions of CCP

- AK

- S NL

- 50 0, 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 doc umented 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 establis hed radionuclide scaling factors or radiological characterization process (RC1) Notification to EPA upon completion of revisions of CCP

- AK

- S NL

- 501 or CCP

- TP

504 that require CBFO approval *** (RC1, RC8)
Notification to EPA of availability of a revised radi ological 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 administ rative concerns44

11.0 REFERENCES

U.S. Enviro nmental 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, 2 7405.
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 R egulations, 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 Environmen tal 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, Revisi on 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 Applic ation 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 A cceptable 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

- SN L

- 501 , Central Char acterization 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 a nd 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 Debr is Waste, Waste Stream: SNL

- HCF

S5400

- 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 St ream: SNL

- HCF

S5400

- 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 Ch ecklist, 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

C CP

- 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 , 2010A

- 2

Characterization Reconciliation Report for Waste Stream SNL

- HCF

- S5400

- RH, Draf t for Audit Purposes, P rovided 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 Cu stodian , 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: N CR

- 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 card s 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 Packag es: 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 lnterv iew 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 fo r the Assignment of EPA Hazardous Waste Numbers, Kevin J. Peters and Steve Schafer, February 15, 2011A

- 3

DR1002, Discrepancy Resolution for Container #P1110154 (Parent Container C980313), John Kleckner, April 21, 2011
DR1003, Discrepancy Resolution: Assignm ent 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., PKE00 044 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, Sandi a 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

U 1029
, Radiochemistry and Mass Spectrometry Data Input Check, J. Vance, SNL

- RH

- 01, Revision 0, Ma y 6, 2011

U 103 0 , Scaling Factor Development Debris

– PKE00044 , J. Vance, SNL

- RH

- 02, Revision 0
, May 6, 2011A

- 4

U 1031, Determination of Reportable Radionuclides

– PKE00044
, J. Vance, SNL

- RH

- 03
, Revision 0, May 6, 2011

U 1032
, Drum Dose

- to

- Curie Derivation for Cs

- 137 , J. Va nce, SNL

- RH

- 04, Revision 0, Ma y 6, 2011

U 1032
, Drum Dose

- to

- Curie Derivation for Cs

- 137 , J. Vance, SNL

- RH

- 04, Revision 1 , Ma y 31, 2011

U 1033
, Uncertainty Analysis for Drums

- PKE00044 , J. Holderness
, SNL

- RH

- 05, Revision 0
, May 6, 2011

U 1033
, Uncertainty A nalysis for Drums

- PKE00044 , J. Holderness
, SNL

- RH

- 05, Revision 1
, May 31, 2011

U 1034 , DTC and Related Calculations for Drums PKE00044 , J. Holderness
, SNL

- RH

- 06, Revision 0
, May 6, 2011

U 1034 , DTC and Related Calculations for Drums PKE00044 , J. Holderness
, SNL

- RH

- 06, Revision 1
, May 31, 2011B

- 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 In spection 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 Tea m, 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 Exper t  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 stre ams (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 responsibl e 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. D iscussed 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: Jun e 23, 2011