# EPA DOCKET NO. A-98-49, II-A4-190

WASTE CHARACTERIZATION INSPECTION

CONTINUED COMPLIANCE REPORT

EPA INSPECTION OF THE CENTRAL CHARACTERIZATION PROJ ECT

WASTE CHARACTERIZATION PROGRAM

AT THE IDAHO NATIONAL LABORATORY

May 6–8, 2014

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air

Center for Waste Management and Regulations

1200 Pennsylvania Avenue, NW

Washington, DC 20460

July 2014

# i 

# TABLE OF CONTENTS

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

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

2.0 Purpose of Continued Compliance Inspections .......

................................................... ........ 7

3.0 Inspection Personnel ..............................

................................................... .......................... 7

4.0 Purpose of This Report ............................

................................................... ........................ 7

5.0 Scope of This Continued Compliance Inspection .....

................................................... ....... 8

6.0 Technical Evaluation ..............................

................................................... ......................... 8

6.1 Acceptable Knowledge ..............................

................................................... .......... 8

6.1.1 Contact-Handled Waste Streams ..................... ........................................... 8

6.1.2 Technical Evaluation: Remote-Handled Waste ........ ................................ 14

6.1.3 Acceptable Knowledge Findings and Approval ........ ............................... 17

6.2 Nondestructive Assay ..............................

................................................... .......... 18

6.2.1 Technical Evaluation: Waste Assay Gamma Spectromete r...................... 18

6.2.2 Technical Evaluation: Stored Waste Examination Pilo t Plant Gamma-Ray

Spectrometer ......................................

................................................... ................ 22

6.2.3 Technical Evaluation: Super High Efficiency Neutron Counter .............. 24

6.2.4 Nondestructive Assay Findings and Approval ........ ................................. 25

6.3 Dose-to-Curie .....................................

................................................... ................ 26

6.3.1 Dose-to-Curie Findings and Approval ............... ....................................... 27

6.4 Real-Time Radiography for Remote-Handled Waste .... ....................................... 28

6.4.1 Real-Time Radiography Findings and Approval ....... ............................... 29

6.5 Visual Examination ................................

................................................... ............ 29

6.5.1 Visual Examination of Contact-Handled Waste ....... ................................ 29

6.5.2 Visual Examination of Remote-Handled Waste ........ ............................... 31

6.5.3 Visual Examination Findings and Approval .......... ................................... 32

7.0 Findings and Concerns .............................

................................................... ...................... 32

8.0 Conclusions .......................................

................................................... ............................. 32

LIST OF TABLES

Table 1. Tiering of Contact-Handled Transuranic Wa ste Characterization Processes

Implemented by INL-CCP ............................

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

Table 2. Tiering of Remote-Handled Transuranic Was te Characterization Processes

Implemented by INL-CCP ............................

................................................... ............................... 5

Table 3. Contact-Handled Containers Evaluated for T raceability ....................................... ......... 10

Table 4. Remote-Handled Containers Evaluated for Tr aceability ........................................ ........ 15

# ii 

# ATTACHMENTS

Attachment A.1 Approval Summary for INL-CCP Contact -Handled Waste Characterization

Program

Attachment A.2 Approval Summary for INL-CCP Remote- Handled Waste Characterization

Program

Attachment B Inspection Personnel

Attachment C EPA Inspection Issue Tracking Form, Is sue No. INL-CCP-CH-WC-14-01C,

Final

Attachment D.1 AK Continued Compliance Inspection C hecklist: Contact-Handled Waste

Attachment D.2 AK Continued Compliance Inspection C hecklist: Remote-Handled Waste

Attachment E.1 NDA Continued Compliance Inspection Checklist: WAGS

Attachment E.2 NDA Continued Compliance Inspection Checklist: SGRS

Attachment F.1 Replicate Testing Data for Drum SRP2 1732 – WAGS

Attachment F.2 Replicate Testing Data for Drum SRP2 1773 – WAGS

Attachment F.3 Replicate Testing Data for Drum SRP1 8745– WAGS

Attachment G Dose-to-Curie Continued Compliance Ins pection Checklist

Attachment H NDE Continued Compliance Inspection Ch ecklist: RH RTR

Attachment I.1 NDE Continued Compliance Inspection Checklist: CH VE

Attachment I.2 NDE Continued Compliance Inspection Checklist: RH VE

Attachment J List of Documents Reviewed for this In spection

# iii 

# ACRONYMS AND ABBREVIATIONS

%R percent recovery

%RSD percent relative standard deviation

σ sigma

μR/hr microroentgen per hour

χ 2 

# chi-squared

AK acceptable knowledge

AKE Acceptable Knowledge Expert

AKSR acceptable knowledge summary report

AKTSS acceptable knowledge tracking spreadsheet

Am americium

AMWTP Advanced Mixed Waste Treatment Project

ANL-E or ANLE Argonne National Laboratory-East

ARP Accelerated Retrieval Project

ASTM American Society for Testing and Materials

Att. Attachment

Ba barium

BDR batch data report

BEGe broad energy germanium

BeO beryllium oxide

BKG background count rate

CBFO Carlsbad Field Office

CCP Central Characterization Program

CFR Code of Federal Regulations

CH contact-handled

Ci Curie

CIS characterization information summary

cps counts per second

CRR characterization reconciliation report

Cs cesium

# iv



# CSSF correlation and surrogate summary form

CTAC Carlsbad Technical Assistance Contractor

CWI CH2M-WG Idaho, LLC

DEQ Department of Environmental Quality

DOE U.S. Department of Energy

DPS drum packaging stations

DQO data quality objective

DR discrepancy resolution

DSA digital spectrum analyzer

DTC dose-to-curie

DU depleted uranium

DVD digital video disk

EA Expert Analyst

EPA U.S. Environmental Protection Agency

EU enriched uranium

FWHM full width at half maximum

FY fiscal year

g gram

HFEF Hot Fuel Examination Facility

HLW high-level waste

HWN hazardous waste number

ICP Idaho Cleanup Project

INEEL Idaho National Engineering and Environmental Laboratory

INEL Idaho National Engineering Laboratory

INL Idaho National Laboratory

INTEC Idaho Nuclear Technology and Engineering Cent er

ITR Independent Technical Reviewer

IWTS Integrated Waste Tracking System

keV kilo electron volt

kg kilogram

kg/L kilogram per liter

# v



# kV kilovolt

La 3 

# Br(Ce) cerium-drifted lanthanum bromide

LLD lower limit of detection

LLW low-level waste

LOQI list of qualified individuals

MCS Mobile Characterization Services

MFC Materials and Fuel Complex

MGA multi-group analysis

MGA-U multi-group analysis-uranium

mR/hr milliroentgen per hour

nCi/g nanocuries per gram

NCR nonconformance report

NDA nondestructive assay

NDE nondestructive evaluation

NRF Naval Reactors Facility

NWP Nuclear Waste Partnership, LLC

OJT on-the-job training

ORIA Office of Radiation and Indoor Air

PCB polychlorinated byphenyl

PDP Performance Demonstration Program

PK process knowledge

PSAP Project-specific Sampling and Analysis Plan

Pu plutonium

QA quality assurance

QAPD quality assurance program document

QAPP Quality Assurance Project Plan

QC quality control

R roentgen

R/hr roentgen per hour

Ra radium

RDS radioassay data sheet

# vi



# Rev. revision

RFP Rocky Flats Plant

RH remote-handled

RTR real-time radiography

RWMC Radioactive Waste Management Complex

SC&A S. Cohen and Associates (SC&A, Inc.)

SCG summary category group

SD source document

SDA Subsurface Disposal Area

SGRS SWEPP Gamma-Ray Spectrometer

SME Subject-Matter Expert

SNF spent nuclear fuel

SPC sludge pan container

SPM Site Project Manager

Sr strontium

SRP Sludge Repackage Project

STR Host Site Subcontract Technical Representative

SuperHENC Super High Efficiency Neutron Counter

SWEPP Stored Waste Examination Pilot Plant

T1 Tier 1

T2 Tier 2

TAAC TRU Alpha Activity Concentration

Th thorium

TMU total measurement uncertainty

TRU transuranic

TSA Transuranic Storage Area

U uranium

UREX Uranium Recovery by Extraction

VE visual examination

VEE Visual Examination Expert

VEO Visual Examination Operator

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# VHS Video Home System

VPM Vendor Project Manager

WAC waste acceptance criteria

WAGS Waste Assay Gamma Spectrometer

WCPIP Waste Characterization Program Implementation Plan

WDS WIPP Waste Data System

WG Pu weapons-grade plutonium

WIPP Waste Isolation Pilot Plant

WMC waste matrix code

WMO Waste Management Operations Department

WMP waste material parameter

WSPF waste stream profile form

# 1



# 1.0 EXECUTIVE SUMMARY

This report supports the U.S. Environmental Protect ion Agency’s (EPA’s) determination that the

waste characterization program at the U.S. Departme nt of Energy’s (DOE’s) Idaho National

Laboratory (INL) continues to be in compliance with federal regulations. In accordance with

Title 40 of the Code of Federal Regulations (40 CFR ) 194.24(h), EPA can conduct a continued

compliance inspection of the EPA-approved transuran ic (TRU) waste characterization systems

used at the TRU waste sites operated by DOE. Since 2005, the Central Characterization Program

(CCP) 1 

# , a mobile waste characterization systems provider, has operated a waste characterization

program for contact-handled (CH) and remote-handled (RH) TRU wastes at INL in Idaho Falls,

Idaho.

On May 6–8, 2014, EPA conducted a continued complia nce inspection of the site’s program to

characterize CH and RH TRU wastes proposed for disp osal at the Waste Isolation Pilot Plant

(WIPP). During this inspection, EPA evaluated sampl es of the following waste characterization

activities:

• Acceptable knowledge (AK) for CH and RH waste strea ms.

• Three nondestructive assay (NDA) systems for charac terizing CH TRU wastes: the

Waste Assay Gamma Spectrometer (WAGS), the Stored W aste Examination Pilot Plant

(SWEPP), Gamma-Ray Spectrometer (SGRS) and the Supe r High Efficiency Neutron

Counter (SuperHENC).

• Dose-to-curie (DTC) for RH TRU waste.

• Real-time radiography (RTR) for RH TRU waste.

• Visual examination (VE) for CH and RH TRU waste.

Based on the results of this continued compliance i nspection, EPA confirms that the INL-CCP

CH and RH TRU waste characterization programs in th e configuration observed during this

inspection are consistent with the limitations desc ribed in the baseline inspection reports (see

EPA Docket Nos. A-98-49; II-A4-59, dated November 1 , 2005, and A-98-49; II-A4-72, dated

January 12, 2007) and subsequent EPA Tier 1 (T1) ap provals. Attachments A.1 and A.2

summarize all of EPA’s approvals of the INL-CCP CH and RH TRU waste characterization

programs.

Based on this evaluation, there are no substantive changes to the CH or RH T1 designations.

There are substantive changes to the NDA, DTC, VE a nd RTR Tier 2 (T2) designations which

require DOE action:

1. Submission to EPA of a list of all INL-CCP NDA pers onnel who performed work during

the previous quarter is a new NDA T2 change. Specif ically, the list must include all

operators, Expert Analysts (EAs) and Independent Te chnical Reviewers (ITRs).

1 

# The Central Characterization Program was formerly known as the Central Characterization Project.

# 2



# 2. Submission to EPA of lists of all INL-CCP RH and CH RTR and VE personnel who

performed work during the previous quarter are new RTR and VE T2 changes.

Specifically, the list must include all VE and RTR operators, ITRs and Visual

Examination Experts (VEEs).

3. Submission to EPA of a list of all INL-CCP DTC oper ators, EAs and ITRs that

performed work during the previous quarter is a new DTC T2 change.

The T2 changes listed above are necessary to make t he INL-CCP tiering designations consistent

with the requirements at other TRU sites and to sup port EPA’s process for conducting T1

evaluations. Tables 1 and 2 show the substantive T2 changes for CH and RH in bold text. T1 and

T2 changes that were initiated during the CH and RH baseline and subsequent T1 approvals

remain in effect. The language in Tables 1 and 2 re garding AK documentation applies to all INLCCP waste streams.

EPA did not identify any findings during this evalu ation. EPA identified one concern not

requiring a response regarding documentation of for mal and informal calibration verifications.

This concern is documented on the EPA Inspection Is sue Tracking Form, Issue No. INL-CCPCH-WC-14-01C, which is included in Attachment C. IN L-CCP revised several documents

during the evaluation and provided them to EPA. Att achment J is a list of all documentation

reviewed, including batch data reports (BDRs).

This report serves as EPA’s public notification of the results of the continued compliance

inspection. This information will be provided throu gh the EPA website and by sending emails to

the WIPPNEWS list, in accordance with 40 CFR 194.8( b)(3).3Table 1.Tiering of Contact-Handled Transuranic Waste Characterization Processes Implemented by INL-CCP(Based on May 3–5, 2005, Baseline Inspection and Subsequent Evaluations, Updated June 2014)Process ElementsINL-CCP CH Waste Characterization Processes – T1 ChangesINL-CCP CH Waste Characterization Processes – T2 Changes*Acceptable Knowledge,including LoadManagementAny new waste categoryChanges to the accelerated retrieval project targeted wastes fromwhat was presented in CCP-AK-INL-001, Revision 7Submission of a list of active INL-CCP CH AKEs andSPMsNotification to EPA upon completion of or substantive modification** to:•AK-NDA memoranda•AK accuracy reports (annually, at a minimum)•AK-AK and AK-NDA/NDE discrepancy resolution reports•WSPFs, including updates or additions to waste streams within anapproved waste category•New and revised AK summary reports•The load management status of approved waste streams•Site procedures requiring CBFO approval•Any analysis evaluating effectiveness of the WasteIdentificationProcessNondestructive Assay New equipment or substantive physical modifications** to approvedequipmentExtension of or changes to approved calibration range for approvedequipmentSubmission of a list of INL-CCP NDA operators, EAsand ITRs thatperformed work during the previous quarterNotification to EPA upon substantive modification**to:•Software for approved equipment•Operating ranges upon CBFO approval•Site procedures requiring CBFO approvalReal-Time Radiography NoneSubmission of a list of INL-CCP RTR operators and ITRs thatperformed work during the previous quarterNotification to EPA upon:•Substantive modification** to site procedures requiring CBFO approval•New equipment or substantive physical modifications** to approvedequipmentVisual Examination andVisual ExaminationTechniqueChanges in the vendor performing visual examinationor visualexamination techniqueSubmission of a list of INL-CCP VE operators, VE Experts and ITRsthat performed work during the previous quarterNotification to EPA upon substantive modification**to site proceduresrequiring CBFO approvalWIPP Waste DataSystemChanges to WDS algorithms specific to load management requiringrevisions to the load management provisions of DOE’s CH WACNotification to EPA upon substantive modification**to:•Site procedures requiring CBFO approval•WDS algorithms corresponding to changes to the loadmanagementprovisions of the CH WACNew T1s, T2s and significant modifications to existing T1s or T2s are inboldtext; T1s or T2s that were only revised for styleare not shown in bold.* INL-CCP will report all T2 changes to EPA every three months.4** “Substantive modification” refers to a change with the potential to affect INL-CCP’s CH waste characterization processes or documentation of them, excluding changes thatare solely related to the environment, safety and health; nuclear safety; or the Resource Conservationand Recovery Act; or that are editorial in natureor are required toaddress administrative concerns. EPA may request copies of new references that DOE adds during a document revision.5Table 2. Tiering of Remote-Handled Transuranic Waste Characterization Processes Implemented by INL-CCP(Based on June 12–16 and August 9 and 26, 2006, Baseline Inspection and Subsequent Tier 1 Evaluations,Updated June 2014)Process ElementsINL-CCP RH Waste Characterization Process – T1 ChangesINL-CCP RH Waste Characterization Process – T2 Changes*Acceptable KnowledgeAny new waste stream not approved under the baselineAddition of containers to approved waste streams ifnew or differentradionuclide scaling factors are requiredSubstantive modification** to AKSRs and certification confirmationtest plans (e.g., CCP-AK-INL-500, CCP-AK-INL-502)Load management for any RH waste streamSubmission of a list of active INL-CCP RH AKEs andSPMsNotification to EPA upon availability or nonsubstantivemodification** of AKSRs and certification confirmation test plans(e.g., CCP‐AK‐INL-500, CCP-AK-INL-502)Notification to EPA upon availability or modification of:•CCP-TP-005, Attachment 4 that reflects the updatedAKSRSource Document Reference List•The WSPF or WSPF change notice; current related attachments,including the CRR, CIS and Summation of Aspects, should beprovided with each requested WSPF•AK accuracy reports (annually, at a minimum)•Discrepancy resolution reports and nonconformance reports•AK documentation as a result of Waste CharacterizationProgram Implementation Plan revisions (e.g., CRR)•Correlation or surrogate summary forms for each ofthe RHcontainers in this waste stream identified as contact-handled,based on measured dose rates that present nondestructive assayresults for assayed containersNotification to EPA of the intention to add containers to anapproved waste stream, including the approximate number ofcontainers and volume of waste, the timeframe for waste generation,characterization, and disposal and submission of anupdated AKSRdocumenting that the pedigree of the additional containers is thesame as those covered by the baseline or subsequentT1approvals***Submission of a list of fully characterized containers from apopulation of additional containers proposed as a T2 change,above***Radiological Characterization,including Dose-to-CurieAny new waste stream not approved under the baseline or subsequentT1 evaluations or addition of containers to an approved waste streamthat requires changing the established radionuclidescaling factorsUse of any alternate radiological characterizationprocedure other thanDTC with established scaling factors as documentedin CCP-TP-504Use of any alternate gamma detector with the OSPREYTM systemcharacterization procedure other than the La3Br(Ce) detector observedSubmission of a list of INL-CCP DTC operators, EAsand ITRsthat performed work during the previous quarterNotification to EPA upon nonsubstantive** modification ofprocedures or radiological technical reports (e.g.,CCP-TP-504,CCP-AK-INL-501) requiring CBFO approvalSubmission of an updated radiological technical report (e.g., CCPAK-INL-501) documenting that the radiological characterizationprocesses used for the additional containers is thesame as those6Process ElementsINL-CCP RH Waste Characterization Process – T1 ChangesINL-CCP RH Waste Characterization Process – T2 Changes*in July 2010Application of new (i.e., not EPA-approved) scalingfactordevelopment processes for isotopic determination (applies to new RHwaste streams and to the addition of containers toan approved wastestream)Substantive modification** to EPA-approved procedures orradiological characterization technical reports (e.g., CCP-TP-504,CCP-AK-INL-501)covered by the baseline or subsequent T1 approvals***Submission of BDRs or calculation packagesfor containers selectedby EPA from a list of fully characterized containers provided byINL-CCP***Visual Examination Visual examination by any new process for SCG S3000, S4000 orS5000 waste.Visual examination by review of existing audio/visual recordings forSCG S3000 or S4000 waste.Submission of a list of INL-CCP VE operators, VE Experts andITRs that performed work during the previous quarterNotification to EPA upon substantive modification**to siteprocedures requiring CBFO approvalSubmission of BDRs for containers selected by EPA from a list offully characterized containers provided by INL-CCP***Real-Time Radiography Any new debris waste stream or waste from SCG S3000 or S4000Addition of any new RTR unitsSubmission of a list of INL-CCP RTR operators and ITRs thatperformed work during the previous quarterNotification to EPA upon substantive modification**to siteprocedures requiring CBFO approvalSubmission of BDRs for containers selected by EPA from a list offully characterized containers provided by INL-CCP***WIPP Waste Data System NoneNotification to EPA upon substantive modification**to siteprocedures requiring CBFO approvalNew T1s, T2s and significant modifications to existing T1s or T2s are inboldtext; T1s or T2s that were only revised for styleare not shown in bold.* INL-CCP will report all unmarked T2 changes to EPA every three months.** “Substantive modification” refers to a change with the potential to affect INL-CCP’s RH waste characterization processes or documentation of them, excluding changes thatare solely related to the environment, safety and health; nuclear safety; or the Resource Conservationand Recovery Act; or that are editorial in natureor are required toaddress administrative concerns. EPA may request copies of new references that DOE adds during a document revision.*** INL-CCP will report this T2 change immediately.

# 7



# 2.0 PURPOSE OF CONTINUED COMPLIANCE INSPECTIONS

Under the changes to 40 CFR 194.8 promulgated in th e July 16, 2004, Federal Register notice,

EPA must perform a single baseline inspection of a TRU waste generator site’s waste

characterization program (Vol. 69, No. 136, pages 4 2571–42583, July 16, 2004). The purpose of

EPA’s baseline inspection is to approve the site’s waste characterization program, based on a

demonstration that the program’s components, with a pplicable conditions and limitations, can

adequately characterize TRU wastes and comply with the regulatory requirements imposed on

TRU wastes destined for disposal at the WIPP.

Following EPA’s baseline approval, EPA has the auth ority to conduct continued compliance

inspections to verify that the site (1) continues t o use only the approved waste characterization

processes to characterize the waste, and (2) remain s in compliance with all the regulatory

requirements in 40 CFR 194. EPA is also authorized to evaluate and approve changes (i.e.,

tiering changes), if necessary, to the site’s appro ved waste characterization program by

conducting additional inspections under the authori ty of 40 CFR 194.24(h).

EPA performs annual continued compliance inspection s of each TRU waste characterization

program, covering all elements of the programs, inc luding the common elements of waste

characterization processes that are not expected to significantly vary by waste stream. Examples

of the common characterization elements are personn el training, procedures and equipment

capabilities. EPA will consider the results of cont inued compliance inspections when setting the

scope and evaluating site-specific T1 changes.

The results of this continued compliance inspection and the review of quarterly T2 changes

submitted since the May 2014 inspection will be the basis for EPA’s evaluation of any INL-CCP

T1 change requests submitted before the next EPA co ntinued compliance inspection. Thus, EPA

can focus on only those waste characterization comp onents that are critical to the specific T1

change request, evaluation and approval (e.g., wast e-stream-specific AK records). In addition,

EPA may not revisit the elements discussed in this report until the next continued compliance

inspection, at the Agency’s discretion.

3.0 INSPECTION PERSONNEL

EPA and its support personnel conducted interviews with INL-CCP waste characterization

personnel in several disciplines. The personnel con tacted represented a sample of the CH and RH

TRU waste characterization staff. The EPA inspectio n team and INL-CCP personnel contacted

are listed in Attachment B, with their affiliations and areas of expertise or function.

4.0 PURPOSE OF THIS REPORT

This report documents the basis for EPA’s decision to maintain the approval of the INL-CCP

waste characterization program for CH and RH TRU wa stes. Specifically, this report:

• Describes the sample of the INL-CCP waste character ization systems evaluated during

this inspection.

# 8



# • Identifies all areas where waste characterization s ystems have changed relative to what

was approved during the baseline inspection and oth er subsequent EPA T1 evaluations

and assesses the impact, if any, of those changes.

• Provides objective evidence to support the basis fo r EPA’s continued approval of all

waste characterization systems.

• Describes any tests or demonstrations completed dur ing the course of the inspection and

their relevance to EPA’s approval decision.

5.0 SCOPE OF THIS CONTINUED COMPLIANCE INSPECTION

The scope of this continued compliance inspection i ncluded the evaluation of selected elements

of the waste characterization systems in use at INL -CCP to characterize CH and RH TRU wastes

that were approved during the baseline inspection a nd subsequent T1 evaluations. Waste

characterization activities evaluated included AK f or all CH and RH waste streams characterized

since the May 2013 EPA continued compliance inspect ion, all operating NDA systems (WAGS,

SGRS and SuperHENC) for CH waste characterization a nd DTC systems for RH waste

characterization, RTR operations for RH summary cat egory group (SCGs) S5000 (heterogeneous

debris), and VE operations for multiple CH and RH S CGs.

6.0 TECHNICAL EVALUATION

EPA’s technical evaluation is summarized in section s 6.1–6.5 of this report. The details of EPA’s

technical evaluation are located in the completed i nspection checklists, which are included in this

report as Attachments D.1–E.2 and G–I.2. When evalu ating future T1 change requests and

concurring with quarterly T2 change submissions, EP A may use these checklists to supplement

their review. Attachments F.1–F.3 contain the resul ts of INL-CCP’s NDA replicate scanning as

discussed in section 6.2.1, Item (8), of this repor t. The DOE documents that EPA reviewed for

this evaluation are cited throughout the report and are listed in Attachment J. Any of these

documents can be requested from the following addre ss:

Carlsbad Field Office

Manager, National TRU Program

P.O. Box 3090

Carlsbad, NM 88221-3090

6.1 Acceptable Knowledge

6.1.1 Contact-Handled Waste Streams

EPA evaluated INL-CCP’s continued compliance with E PA-approved AK procedures for CH

waste characterization. INL-CCP’s CH AK characteriz ation program is EPA-approved for (

Summary Category Group (SCG) S3000 (homogeneous sol ids), SCG S4000 (soils) and SCG

S5000 (heterogeneous debris) waste. INL-CCP managem ent stated that INL-CCP performed

waste characterization activities for Waste Streams ID-AECHDM, ID-AECHHM, ID-RF-S3114,

ID-SDA-DEBRIS, ID-SDA-SOIL, ID-SDA-SLUDGE and ID-SR P-S3000 since EPA’s 2013

continued compliance inspection. EPA reviewed a sel ection of documents from each of these

# 9



# waste streams as representative samples of the INL- CCP CH AK waste characterization

program. The AK checklists used for this inspection are included in Attachment D.1.

(1) EPA examined select Central Characterization Progra m procedures and found them to be

adequate.

EPA reviewed several CCP procedures for AK document ation, training of AK Experts (AKEs)

and disposition of nonconformances for technical su fficiency and scope. Specifically, EPA

reviewed:

• CCP-QP-002, Revision 36, “Training and Qualificatio n Plan,” June 6, 2013.

• CCP-QP-005, Revision 24, “Nonconforming Item Report ing and Control,” June 25,

2013.

• CCP-TP-002, Revision 26, “Reconciliation of DQOs an d Reporting Characterization

Data,” June 19, 2013.

• CCP-TP-005, Revision 26, “CCP Acceptable Knowledge Documentation,” August 12,

2013.

CCP revised CCP-QP-002 and CCP-QP-005 since the las t time EPA reviewed these procedures.

The procedure revisions are mostly editorial or cha nges that do not significantly impact the EPAapproved waste characterization program. The revisi on of CCP-QP-002 reflects a Nuclear Waste

Partnership (NWP; CCP’s parent organization) policy and procedural shift regarding conditions

adverse to quality and corrective action. As a resu lt of the change to corrective action

procedures, some of the required training documents for AKEs have changed. CCP provided a

sample modified AKE qualification card reflecting t hese changes.

The procedures adequately reflect the requirements of 40 CFR 194. Procedure implementation is

evidenced by adequate preparation and maintenance o f the required documentation, as reviewed

below.

Notification to EPA upon completion of or substanti ve modification to site procedures requiring

Carlsbad Field Office (CBFO) approval remains a T2 change (see Table 1).

(2) EPA verified that the acceptable knowledge characte rization process for containers,

including acceptable knowledge assembly, compilatio n and verification, was adequately

implemented.

EPA evaluated INL-CCP’s completion of each of the 1 5 attachments associated with CCP

procedure CCP-TP-005 (AK documentation) by reviewin g samples of each attachment for the

active waste streams listed above.

Prior to this continued compliance inspection, INL- CCP had not revised the waste material

parameter (WMP) memorandum for waste from the subsu rface disposal area (SDA) since 2009.

This means that the memorandum and associated CCP-T P-005, Attachment 6s, did not account

for the impact of expected WMPs from the newly adde d Accelerated Retrieval Project (ARP)

# 10



# areas. During the continued compliance inspection, INL-CCP revised the three CCP-TP-005,

Attachment 6s, and the WMP memorandum to include AR P-V–ARP-VIII.

(3) EPA verified that waste traceability was adequately demonstrated.

EPA randomly selected containers, listed in Table 3 , from several of the active waste streams to

assess traceability. The waste in Waste Streams ID- SDA-SLUDGE and ID-SRP-S3000 is

considered newly generated and is traceable from ge neration at INL-CCP through INL-CCP

characterization. Historical waste disposal into th e SDA and container movements for Rocky

Flats Plant (RFP) waste that would become Waste Str eam ID-SRP-S3000 is also well

documented.

Table 3. Contact-Handled Containers Evaluated for T raceability

The waste in Waste Streams ID-AECHDM and ID-RF-S311 4 is traceable from the DOE facility

of origin through INL-CCP characterization.

(4) EPA assessed the acceptable knowledge summary repor ts and found them to be adequate.

EPA evaluated three AK summary reports (AKSRs): CCP -AK-INL-001 for Waste Streams IDSDA-SOIL, ID-SDA-SLUDGE and ID-SDA-DEBRIS; CCP-AK-I NL-025 for Waste Streams

ID-AECHHM and ID-AECHDM; and CCP-AK-INL-026 for Was te Stream ID-SRP-S3000.

EPA evaluated these AKSRs for inclusion of sufficie nt information, supported by appropriate

source documents, to support the following statemen ts:

• All waste within the waste stream was generated fro m a single process/activity.

• All waste within the waste stream is similar in mat erial and physical form.

• All waste within the waste stream has similar radio logical properties.

• All of the waste in the waste stream is defense in origin. 2



# • None of the waste in the waste stream is high-level waste (HLW). 2



# • None of the waste in the waste stream is spent nucl ear fuel (SNF). 2

2 

# As defined by U.S. Code, Title 42, “The Public Heal th and Welfare,” Chapter 108, “Nuclear Waste Policy

Act of 1982.” Drum No. Waste Stream

10187486 ID-RF-S3114

ARP70164 ID-SDA-SLUDGE

ARP70264 ID-SDA-SLUDGE

ARP70625 ID-SDA-DEBRIS

ARP71044 ID-SDA-SOIL

RW49567 ID-AECHDM

RW88680 ID-AECHDM

SRP19302 ID-RF-S3114

SRP19363 ID-SRP-S3000

SRP19813 ID-SRP-S3000

SRP21731 ID-SRP-S3000

# 11



# EPA found each examined AKSR to be adequate. Explan ations and source documents

supporting each of the above statements are include d in the checklist in Attachment D.1.

During recent T1 evaluations and continued complian ce inspections, EPA has noticed that CCP

AKEs inconsistently apply the labels “waste” or “pa ckaging material” to inner containers when

assigning WMPs and SCGs. The AKSR for Waste Stream ID-AECHHM states that many of the

drums will have solidified liquids or fines package d inside paint cans within the larger drum. The

INL-CCP AKE responsible for this report did not con sider the inner paint cans as “waste,” did

not include them in the WMP assessment, and conclud ed that the waste stream is part of the

homogenous solid SCG (S3000). During a recent INL-C CP T1 change evaluation, EPA noted

that INL-CCP relied on inclusion of the inner paint cans as “waste” in order to conclude that the

waste stream was part of the heterogeneous debris S CG (S5000). These two conflicting examples

led EPA to question whether INL-CCP is selectively choosing which rules to apply to their waste

characterization activities. INL-CCP AKEs explained that their decision to include the inner

packaging materials as “waste” or “not waste” is so mewhat meaningless. As long as the AKSR

describes the inner containers and mentions that th e estimated WMPs do not account for the

inner containers, the nondestructive examination (N DE) operators have all of the information

that they need in order to perform the NDE and dete rmine if AK assigned the correct waste

matrix code (WMC) to the drums. According to the IN L-CCP AKE, NDE personnel always

count the inner packaging materials as “waste.” The Advanced Mixed Waste Treatment Project

(AMWTP) is currently performing RTR of Waste Stream ID-AECHHM drums. AMWTP is a

separate TRU waste characterization program operati ng under a separate approval from EPA.

EPA will discuss the “waste” versus “not waste” det erminations with AMWTP NDE operators

during the next EPA continued compliance inspection at AMWTP, and will continue to monitor

INL-CCP’s application of SCG determinations to INL- CCP waste streams.

Notification to EPA upon completion of or revisions to all AKSRs remains a T2 change (see

Table 1).

(5) EPA evaluated waste stream profile form preparation and completeness and found them

to be adequate.

EPA reviewed the waste stream profile forms (WSPFs) , including the characterization

information summaries (CISs) and summations of aspe cts, and related change notices for Waste

Streams ID-AECHDM, ID-AECHHM and ID-SRP-S3000 and f ound them to be complete and

adequate.

Notification to EPA upon completion of or revisions to all WSPFs, including generation of any

Change Notices, remains a T2 change (see Table 1).

(6) EPA assessed acceptable knowledge personnel trainin g and found it to be adequate.

INL-CCP indicated that Scott Smith, Carrie Johnson, Steve Schafer and Kevin Peters are the

only AKEs responsible for CH waste in the INL-CCP p rogram. INL-CCP provided completed

qualification cards and documentation showing famil iarity of the AKEs with the current

revisions of AK procedures. INL-CCP also provided c omplete CH Site Project Manager (SPM)

qualification cards for several SPMs listed in Atta chment D.1. The primary SPM for the INL-

# 12



# CCP CH waste characterization program is Rich Kantr owitz. Training records for the personnel

listed above are complete and adequate. EPA will re view training records for any additional

personnel supporting CH waste characterization duri ng a future T1 evaluation or the next

continued compliance inspection.

Submission to EPA of a list of AKEs and SPMs who pe rformed work in these roles for the INLCCP CH waste characterization program in the previo us quarter remains a T2 change (see Table

1).

(7) EPA assessed nonconformance and discrepancy resolut ion documentation and found it to

be adequate.

EPA has previously evaluated INL-CCP’s ability to p roduce compliant nonconformance reports

(NCRs) several times. EPA evaluated sample NCRs ass ociated with Waste Streams IDAECHDM, ID-RF-3114 and ID-SRP-S3000. EPA also revie wed discrepancy resolution (DR)

reports for Waste Streams ID-AECHDM and ID-SRP-S300 0. EPA found that INL-CCP

adequately prepared these documents as necessary.

Notification to EPA upon completion of or substanti ve modification to AK-AK and AKNDA/NDE DR reports remains a T2 change (see Table 1 ).

(8) EPA assessed acceptable knowledge accuracy and foun d it to be adequate.

EPA reviewed recent AK accuracy reports for several of the sample waste streams and found

them to be adequate. However, AK accuracy is calcul ated by comparing AK against

measurement data, long after the waste stream has b een filtered to remove troublesome

containers identified by fast scan and other pre-sc reening methods. Containers that were initially

included in a waste stream but were removed prior t o the WIPP-certifiable characterization do

not count against AK accuracy. The AK accuracy repo rt cannot be used to evaluate the accuracy

of the original AK or the decision to include or ex clude certain containers in the waste stream

based on AK alone.

Notification to EPA upon completion of or substanti ve modification to AK accuracy reports

(annually, at a minimum) remains a T2 change (see T able 1).

(9) EPA assessed communication between acceptable knowl edge and nondestructive assay

personnel and found it to be adequate.

EPA reviewed the current AK-NDA memorandum for Wast e Streams ID-AECHDM, IDAECHHM, ID-SDA-DEBRIS, ID-SDA-SOIL and ID-SDA-SLUDG E. EPA evaluated the

memoranda for completeness and compared the memoran da with the AKSRs.

EPA determined that the reviewed AK-NDA memoranda a re adequate. EPA will continue to

review the AK record to ensure that information add ressing americium-241 ( 241 

# Am) in-growth is

incorporated as appropriate.

Notification to EPA upon completion of or substanti ve modification to AK-NDA memoranda

remains a T2 change (see Table 1).

# 13



# (10) EPA found load management to be adequately implemen ted.

The WIPP waste acceptance criteria allow that a pay load container may include drums that

measure less than 100 nanocuries per gram (nCi/g) o f TRU radionuclides so long as the TRU

Alpha Activity Concentration (TAAC) of the payload in total is greater than 100 nCi/g. The

AKSR for each waste stream selected for payload man agement must include an estimate of the

total waste volume and percentage of the waste volu me that is above and below100 nCi/g

TAAC. Each container selected for payload managemen t must contain at least one TRU

radionuclide whose activity exceeds the lower limit of detection (LLD) of the radioassay system

used to characterize the waste (i.e., is measureabl e), and each container may only be overpacked

into a payload container with other containers from the same TRU waste stream.

EPA previously reviewed and approved load managemen t for Waste Stream ID-RF-S3114.

CBFO extended the load management approval to inclu de Waste Stream ID-SRP-S3000,

because it is composed of waste from Waste Stream I D-RF-S3114 and Waste Stream

BNINW216, a waste stream from AMWTP. CCP-AK-INL-026 , Revision 0, states that 34% of

the ID-RF-S3114 containers are above 100 nCi/g TAAC and 64% of the containers are below

100 nCi/g TAAC and that 92% of the BNINW216 contain ers are above 100 nCi/g TAAC and

8% of the containers are below 100 nCi/g TAAC. The report also states that each payload

container will be certified as containing “more tha n 100 nCi/g of alpha emitting isotopes with

half-lives greater than 20 years.” INL-CCP assays e ach drum and if an assay indicates at least

one measureable TRU radionuclide but has a TAAC bel ow 100 nCi/g, the drum is a candidate

for load management. Any drum that does not contain at least one measurable TRU radionuclide

must be removed from the waste stream. Load managem ent for Waste Stream ID-SRP-S3000 is

acceptable.

Notification to EPA upon modification to the load m anagement status of approved waste streams

remains a T2 change (see Table 1).

(11) EPA evaluated compliance with tiering requirements and found it to be adequate.

T2 notification to EPA upon completion of or substa ntive modification to the waste-streamspecific documents listed in Table 1 is required on a quarterly basis. EPA compared the revision

dates of documents provided during this continued c ompliance inspection with the T2

notification reports provided to EPA by CBFO from M ay 2013 to May 2014.

EPA found that the revised AK-NDA memorandum for Wa ste Stream ID-AECHDM (revised in

August 2013) was not reported in any of the T2 repo rts and that the lists of active INL-CCP CH

AKEs and SPMs for the previous quarter were not rep orted until the 2 nd 

# quarter report for fiscal

year (FY) 2014. EPA discussed these deficiencies wi th INL-CCP and determined that the AKNDA memorandum was a one-time oversight. INL-CCP al so said that the list of active personnel

requirement did not make it into the site certifica tion documentation until spring 2014; therefore,

the FY2014 2 nd 

# quarter T2 report was the first opportunity they h ad to report this list. EPA

restated that all CH T2 requirements apply to all I NL-CCP CH waste streams, unless specifically

stated otherwise. The tiering changes identified du ring the INL-CCP CH baseline inspection and

subsequent T1 inspections remain in effect and are included as Table 1 of this document.

# 14



# Summary of Acceptable Knowledge for Contact-Handled Waste

EPA did not identify any findings or concerns relat ed to AK for CH waste as a result of this

continued compliance inspection.

There are no changes to the T1 or T2 designations f or CH AK as a result of this continued

compliance inspection.

Based on the results of this evaluation and the dat a examined, EPA determines that INL-CCP

demonstrated continued AK characterization complian ce for CH waste streams.

6.1.2 Technical Evaluation: Remote-Handled Waste

EPA evaluated INL-CCP’s continued compliance with E PA-approved AK procedures for RH

waste characterization, which includes SCG S3000 (h omogeneous solids) and SCG S5000

(heterogeneous debris) waste. INL-CCP management st ated that INL-CCP performed waste

characterization activities on four waste streams s ince EPA’s 2013 continued compliance

inspection. EPA has approved T1 changes for the act ive portions of two of the four waste

streams: ID-ANLE-S5000 (Lot 2) and ID-HFEF-S5400-RH (Lots 1A and 1B). EPA reviewed

documents from each of these waste streams as a rep resentative sample of the INL-CCP RH AK

waste characterization program. The AK checklist us ed for this inspection is included in

Attachment D.2.

(1) EPA examined select Central Characterization Progra m procedures and found them to be

adequate.

EPA reviewed several CCP procedures for AK document ation, training of AKEs and disposition

of nonconformances for technical sufficiency and sc ope. In addition to the procedures listed and

discussed in section 6.1.1, Item (1), EPA reviewed CCP-TP-506. 3 

# The procedures adequately

reflect the requirements of 40 CFR 194. Procedure i mplementation is evidenced by adequate

preparation and maintenance of the required documen tation, as reviewed below.

Notification to EPA upon completion of or substanti ve modification to site procedures requiring

CBFO approval remains a T2 change (see Table 2).

(2) EPA verified that INL-CCP adequately implemented th e acceptable knowledge

characterization process for containers, including acceptable knowledge assembly,

compilation and verification.

EPA evaluated INL-CCP’s completion of the attachmen ts associated with procedure CCP-TP005 for AK documentation for each of two sample was te streams, i.e., Waste Stream ID-ANLES5000 and Waste Stream ID-HFEF-S5400-RH. EPA evalua ted whether INL-CCP revised the

attachments as necessary to incorporate the ongoing waste characterization and whether INLCCP prepared the attachments using forms from the a ppropriate revisions of CCP-TP-005. EPA

3 

# CCP-TP-506, CCP Preparation of the Remote-Handled Transuranic Waste Acceptable Knowledge

Characterization Reconciliation Report, Revision 4, November 21, 2013

# 15



# found that INL-CCP should have generated revised At tachments 1 and 4 for Waste Stream IDHFEF-S5400-RH at the same time that INL-CCP revised the AKSR, or at least prior to the EPA

continued compliance inspection. INL-CCP provided a ppropriately revised attachments during

the inspection. EPA found that the rest of the atta chments had been appropriately revised as

necessary.

Notification to EPA when Attachment 4 of CCP-TP-005 is generated to reflect an updated

AKSR source document reference list remains a T2 ch ange (see Table 2).

(3) EPA verified that INL-CCP adequately demonstrated w aste traceability.

EPA examined traceability from waste generation thr ough characterization for newly

characterized drums from Waste Stream ID-ANLE-S5000 , Lot 2, and Waste Stream ID-HFEFS5400-RH, Lots 1a and 1b, as shown in Table 4. EPA examined documentation for initial

canisters, subsequent repackaging, final drum ident ification and characterization and these data

show that the final drums can be traced to the orig inal sources.

Table 4. Remote-Handled Containers Evaluated for Tr aceability

Traceability for Waste Streams ID-ANLE-S5000 and ID -HFEF-S5400-RH was adequately

demonstrated.

(4) EPA assessed the acceptable knowledge summary repor t and found it to be adequate.

EPA evaluated the AKSR for each sample waste stream to determine whether INL-CCP

appropriately revised the document to account for a ll waste currently being characterized. INLCCP prepared the most recent AKSR revision for both waste streams in response to EPA

comments during T1 change evaluations. The AKSRs in clude all requested modifications.

Notification to EPA upon completion of or revisions to all AKSRs, including those for which

EPA has not yet approved the waste stream [see sect ion 6.1.2, Item (10) below] remains a T2

change (see Table 2).

(5) EPA evaluated waste stream profile form preparation and completeness and found them

to be adequate.

The waste characterization activities have not iden tified any changes to the radiological or

physical characteristics of the waste streams; ther efore, INL-CCP has not revised the WSPF for

either waste stream since the last time EPA reviewe d these documents. Drum No. Waste Stream

ANLE3D-1 ID-ANLE-S5000

ANLE43L ID-ANLE-S5000

ANLE45A ID-ANLE-S5000

B521A ID-HFEF-S5400-RH

B521B ID-HFEF-S5400-RH

FC010012-3 ID-HFEF-S5400-RH

IDAWANL870203C ID-HFEF-S5400-RH

# 16



# Notification to EPA upon completion of or substanti ve modification to WSPFs remains a T2

change (see Table 2).

(6) EPA assessed acceptable knowledge personnel trainin g and found it to be adequate.

INL-CCP indicated that Scott Smith and Kevin Peters are the primary AKEs responsible for RH

waste in the INL-CCP program, with Steve Schafer al so trained for INL waste and primarily

providing radiological technical support. INL-CCP p rovided complete qualification cards and

documentation of familiarity with the current revis ion of the Waste Characterization Program

Implementation Plan (WCPIP) (Revision 3) for these three AKEs. Submission to EPA of a list of

AKEs and SPMs who performed work in these roles for the INL-CCP RH waste characterization

program in the previous quarter remains a T2 change (see Table 2).

(7) EPA assessed nonconformance and discrepancy resolut ion documentation and found it to

be adequate.

EPA previously evaluated INL-CCP’s ability to produ ce compliant non-conformance reports

(NCR) and discrepancy resolution (DR) reports durin g numerous T1 evaluations and continued

compliance inspections. Therefore, EPA evaluated a small sample of NCRs and DR reports

specific to Waste Streams ID-ANLE-S5000 and ID-HFEF -S5400-RH.

Notification to EPA upon completion of or modificat ion to DR reports and NCRs for AK

nonconformances remains a T2 change (see Table 2).

(8) EPA assessed acceptable knowledge accuracy and foun d it to be adequate.

EPA evaluated the most recent AK accuracy report fo r Waste Streams ID-ANLE-S5000 and IDHFEF-S5400-RH. The AK accuracy reports are technica lly adequate. However, as discussed in

section 6.1.1, Item (8), the AK accuracy report can not be used to evaluate the accuracy of the

original AK or the decision to include or exclude c ertain containers in the waste stream based on

AK alone.

Notification to EPA upon completion of or substanti ve modification to AK accuracy reports

(annually, at a minimum) remains a T2 change (see T able 1).

(9) EPA evaluated the certification plans and identific ation of data quality objectives in the

certification plan, and found them to be adequate.

The certification plan does not always agree precis ely with the AKSR with regard to the number

of containers in the waste stream. INL-CCP indicate d that revision of the certification plan is

ongoing and the discrepancies in container numbers do not alter the description of AK’s role in

the waste characterization methodology as presented in the certification plans.

Notification to EPA upon availability of nonsubstan tive modifications to certification plans

remains a T2 change (see Table 2).

# 17



# (10) EPA found load management to not be applicable.

The WIPP waste acceptance criteria allow payload ma nagement such that a payload container

may include drums that measure less than 100 nCi/g so long as the TAAC of the payload in total

is greater than 100 nCi/g. Neither Waste Stream ID- ANLE-S5000 nor Waste Stream ID-HFEFS5400-RH will be load managed.

Addition of load management to any RH waste stream remains a T1 change (see Table 2).

(11) EPA evaluated compliance with tiering requirements and found it to be adequate.

T2 notification to EPA upon completion of or substa ntive modification to the waste-streamspecific documents listed in Table 2 is required on a quarterly basis. EPA compared the revision

dates of documents provided during this continued c ompliance inspection with the T2

notification reports provided to EPA by CBFO.

Most of the examined documents were appropriately r eported. INL-CCP has not yet started

including a list of active INL-CCP RH AKEs and SPMs in the T2 report. EPA will look for this

list in the next T2 report for both RH and CH AKEs and SPMs active in the INL-CCP waste

characterization program.

The tiering changes identified during the INL-CCP R H baseline inspection and subsequent T1

inspections remain in effect and are included as Ta ble 2 of this document.

Summary of Acceptable Knowledge for Remote-Handled Waste

EPA did not identify any findings or concerns relat ed to AK for RH waste as a result of this

continued compliance inspection.

There are no changes to the T1 or T2 designations f or RH AK as a result of this continued

compliance inspection.

Based on the results of this evaluation and the dat a examined, EPA determines that INL-CCP

demonstrated continued AK characterization complian ce for RH waste streams.

6.1.3 Acceptable Knowledge Findings and Approval

Summary of Acceptable Knowledge Findings and Concer ns

EPA did not identify any findings or concerns relat ed to AK as a result of this continued

compliance inspection.

Acceptable Knowledge Approval

There are no changes to the T1 or T2 designations f or AK as a result of this continued

compliance inspection. Based on the results of this evaluation and the data examined, EPA

determines that INL-CCP demonstrated continued AK c haracterization compliance.

# 18



# 6.2 Nondestructive Assay for Contact-Handled Waste Char acterization

EPA approved the WAGS and SGRS NDA systems initiall y during the CH baseline inspection

in November 2005 (EPA Docket No. A-98-49; II-A4-59) . The SuperHENC was added to the

INL-CCP approval through a T1 change in February 20 07 (EPA Docket No. A-98-49; II-A4-86).

The systems’ abilities to perform the required anal yses were demonstrated during the baseline

and confirmed by the continued compliance inspectio ns. Accordingly, this inspection focused on

the following:

• Confirmation that the design and technical capabili ties of the NDA systems’ hardware

and software had not changed since EPA’s last inspe ction.

• Adequacy of the current revisions to the INL-CCP ND A procedures and documents.

• Operational and maintenance history of the NDA syst ems since the last EPA inspection.

• Knowledge, understanding and training status of INL -CCP NDA personnel.

6.2.1 Technical Evaluation: Waste Assay Gamma Spectromete r for Contact-Hanlded

Waste

EPA evaluated INL-CCP’s continued compliance with t he EPA-approved waste characterization

program for CH waste using the Waste Assay Gamma Sp ectrometer (WAGS) NDA system. The

checklist used for this inspection is included in A ttachment E.1. The following aspects of the

WAGS were evaluated during this inspection.

(1) The Waste Assay Gamma Spectrometer nondestructive a ssay system is the same system

that EPA approved previously.

The WAGS system is located at INL in the facility f ormerly called the SWEPP, INL building

WMF-610. INL-CCP has not moved or renamed the WAGS since the last continued compliance

inspection. There were no concerns regarding these aspects of the WAGS NDA system.

(2) EPA assessed the design and operational range of th e Waste Assay Gamma Spectrometer

and found them to be unchanged from the last inspec tion and adequate for the wastes

currently being assayed.

Between June 7, 2013, and April 30, 2014, the WAGS assayed 1,378 drums that were compiled

in 114 BDRs. EPA inspectors observed the assay of D rum No. 22862, which was 85% full and

had a net weight of 117.8 kilograms (kg). A BDR num ber had not been assigned to the drum at

the time of the inspection.

EPA Inspectors reviewed BDRs INNDAW130104 and INND1 40033 and found them to

adequately document drum assays. WAGS operators app ropriately recorded all daily

performance measurements, which were in control. Sp ecifically, WAGS operators evaluated

background, daily performance check, full width at half maximum (FWHM), energy calibration

(gain) and barium-133 ( 133 

# Ba) transmission source checks, as evidenced in the WAGS daily

operational logbook and BDRs. INL-CCP had establish ed and documented warning and control

# 19



# limits [2 and 3 sigma ( σ ) limits] for all parameters, as appropriate, and b oundary limits

controlled background [~40 counts per second (cps), full spectrum], FWHM and gain.

The software performs decay correction of the 133 

# Ba transmission sources. Due to the short halflife of 133 

# Ba (approximately 10 years), the count rate boundar y limits of the sources must be

adjusted throughout their operational lives. Since the last EPA continued compliance inspection

in May 2013, INL-CCP adjusted the boundary limits o f the transmission sources in July 2013.

INL-CCP NDA personnel indicated that they expect ad ditional adjustments will be made in July

2014. EPA finds this acceptable.

EPA observed that WAGS personnel had available and were using the current revisions of the

WAGS operating procedure. All operational aspects o f the WAGS operation were acceptable.

(3) INL-CCP performed and documented system calibration and calibration confirmation of

the Waste Assay Gamma Spectrometer as required.

EPA verified that the system’s calibration was unch anged since the last inspection. INL-CCP

performed two calibration verifications in the last year after replacing the power supplies for

detector Nos. DET1NB and DET2NB. INL-CCP documented this in CCP-INL-WAGS-14-001

(NCR-INL-0005-14) and CCP-INL-WAGS-14-003 (NCR-INL- 0013-14); all aspects of the

calibration verification were technically acceptabl e and appropriately documented.

EPA inspectors confirmed that in addition to the ca libration verifications, INL-CCP performed

two measurement control updates on the WAGS and doc umented these updates in CCP-INLWAGS-13-002 and CCP-INL-WAGS-13-003. EPA inspectors reviewed documentation of the

updates and discussed the updates with NDA personne l P. Abbott and D. Brasier. The updates

are appropriately documented. There were no concern s regarding the calibration of the WAGS

NDA system.

(4) Determination and documentation for the total measu rement uncertainty for the Waste

Assay Gamma Spectrometer are adequate.

INL-CCP documented the total measurement uncertaint y (TMU) of assays performed on the

WAGS, as required. The EPA inspection team verified that this document was unchanged from

EPA’s last inspection. There were no concerns regar ding TMU for the WAGS NDA system.

(5) INL-CCP determined and documented the lower limit o f detection, including the

minimum detectable concentration of the Waste Assay Gamma Spectrometer, as

required.

CCP-INL-WAGS-001, Revision 1, April 2008, adequatel y documents the technical basis for the

system’s LLD, including reporting thresholds for sp ecific non-measured radionuclides 242 

# Pu and

strontium-90 ( 90 

# Sr). The EPA inspection team verified that this doc ument was unchanged from

EPA’s last inspection. There were no concerns regar ding the determination of the LLD for the

WAGS NDA system.

# 20



# (6) The Waste Assay Gamma Spectrometer had successfully participated in the performance

demonstration program, as required.

The WAGS participated in Cycle 20 of the CBFO-spons ored Performance Demonstration

Program (PDP) for drums in May 2013. The WAGS is sc heduled to participate in the PDP

annually and will participate in Cycle 21A in May 2 014.

(7) EPA assessed personnel training and found it to be adequate.

Currently there are 11 operators and four EAs appro ved for the WAGS. All NDA personnel

associated with the calibration, operation and data review and approval of the WAGS had current

training in the applicable areas, as evidenced by t he list of qualified individuals (LOQI) dated

May 1, 2014, that was provided during the inspectio n. There were no concerns regarding the

training of personnel for the WAGS NDA system.

Submission to EPA of a list of all NDA personnel wh o performed work during the previous

quarter is a new NDA T2 change (see Table 1). Speci fically, the list must include all operators,

EAs and ITRs. EPA added this requirement to ensure that EPA has a complete picture of INLCCP waste characterization activities, which will i nform the scope of NDA components

evaluated during future T1 change evaluations.

(8) INL-CCP performed replicate testing of the Waste As say Gamma Spectrometer unit.

EPA evaluated the results and found the testing to comply with the criteria for the

Environmental Protection Agency Replicate Testing P rotocol.

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

an independent means to verify that the WAGS can pr ovide reproducible results for the

determination of the quantity of 10 WIPP-tracked ra dionuclides [ 241 

# Am, cesium-137 ( 137 

# Cs),

plutonium-238 ( 238 

# Pu), 239 

# Pu, 240 

# Pu, 242 

# Pu, 90 

# Sr, uranium-233 ( 233 

# U), 234 

# U and 238 

# U] and the

TAAC. 4 

# This is accomplished by having the WAGS reassay dr ums it previously measured to

demonstrate the system’s ability to do the followin g:

• Produce results consistent with the reported TMU by comparing the sample standard

deviation for a number of replicate measurements ta ken over several hours or days to the

reported TMU.

• Provide reproducible results over longer periods of time, such as weeks or months, by

comparing the results of the replicate measurements to the original reported values.

As part of this inspection, EPA requested that INL- CCP reassay three drums. EPA selected two

drums randomly from a list of drums previously assa yed on the WAGS, and EPA selected the

third from drums onsite that INL-CCP could easily a ccess and retrieve. INL-CCP reassayed

Drum Nos. SRP18745, SRP21732 and SRP21733 five time s, and compared the results to the

original assay data. INL-CCP performed two statisti cal tests, a chi-squared ( χ 2 

# ) test and a t test,

4 

# Revision 2 of the Environmental Protection Agency Replicate Testing Protocol provides the details of the

replicate testing assay protocol and data evaluatio n.

# 21



# on the results. Data and results of the statistical analyses are included in Attachments F.1 through

F.3.

The χ 2 

# test, which is also known as the goodness-of-fit t est or the chi-squared test for

independence, is used to show how observed data com pare with data we would expect to obtain

according to a specific hypothesis. EPA applied it in this instance to show if the replicate

measurements differed from the expected original me asurement. When INL-CCP applied the χ 2



# test to the replicate assays for Drum Nos. SRP18745 , SRP21732 and SRP21733, it showed that

the replicate measurements match what was expected based on the original measurement. INLCCP found all results to be not significant. This i s an indication that the WAGS is functioning

properly.

The t test is a statistical tool that is used to tell if two sets of data are statistically different from

one another. INL-CCP applied it to the replicate da ta to see if there are statistically significant

differences between the original assay values and t he average of the five replicate measurements.

When INL-CCP applied the t-test to the replicate as says for Drum Nos. SRP18745 and

SRP21732, it showed that the original and replicate measurements were not statistically

different. When INL-CCP applied the t-test to the r eplicate assays for Drum Nos. SRP18733, all

results except 238 

# Pu were not statistically different. The 238 

# Pu replicate measurements indicated a

Significant

difference from the original assay.

Although the software identified these variances as Significant , this does not necessarily indicate

a measurement issue that warrants additional attent ion at this time. Common reasons for the

Significant

differences in replicate values versus original va lues include: (1) actual changes in

the physical configuration of the drum’s contents d ue to movement or settling, (2) fluctuations in

the measurement system’s background, (3) temporal f actors such as radioactive growth or decay,

or (4) actual changes in the measurement system, wh ich is the aspect that these tests are designed

to query. In this instance, 238 

# Pu activity is a value based on isotopic fractions and could not be

explained by the four common reasons listed above.

EPA and INL-CCP representatives discussed the 238 

# Pu Significant result for Drum No.

SRP18733 on a conference call on May 28, 2014. The INL-CCP EA D. Remington explained

that the flag resulted from the drum containing low quantities of 238 

# Pu, such that the multi-group

analysis (MGA) isotopic program would not reliably find enough counts in the appropriate

spectral area to quantify 238 

# Pu. The original assay and replicate assay No. 2 sh owed enough

counts to quantify 238 

# Pu; however, the assays barely met the MGA criteria . For the remaining

replicates, MGA could not effectively determine 238 

# Pu without an unreasonably high level of

uncertainty, and for these replicates default (AK-b ased) weapons grade plutonium (WG Pu)

isotopics were used. Therefore, the t-test identifi ed the Significant difference with respect to

238 

# Pu results because, in fact, these two groups do re present different populations by virtue of

how the final results were obrtained.

EPA reviewed the values and while they are statisti cally significant, the measurement differences

are modest in comparison to the measurement uncerta inty. After discussions with D. Remington

and reviewing an email memorandum dated May 27, 201 4, EPA is satisfied that the WAGS is

functioning properly and produces reproducible resu lts for the determination of the quantity of

# 22



# 10 WIPP-tracked radionuclides. There are no concern s regarding replicate tesing for the WAGS

NDA system.

Summary of Findings and Concerns for WAGS:

EPA did not identify any findings for WAGS, however , EPA did identify one concern regarding

documentation of formal and informal calibration ve rifications. This concern is documented on

the EPA Inspection Issue Tracking Form, Issue No. I NL-CCP-CH-WC-14-01C, which is

included in Attachment C. EPA discussed this concer n with EA P. Abbott. EPA and P. Abbot

agreed that the documentation concern would be addr essed in the next revision of CCP-TP-019.

6.2.2 Technical Evaluation: Stored Waste Examination Pilo t Plant Gamma-Ray

Spectrometer for Contact-Handled Waste

EPA evaluated INL-CCP’s continued compliance with t he EPA-approved waste characterization

program for CH waste using the SGRS NDA system. The checklist used for this inspection is

included in Attachment E.2. EPA evaluated the follo wing aspects of the SWEPP Gamma-Ray

Spectrometer (SGRS) during this inspection:

(1) The Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer is the same system

that EPA approved previously.

The SGRS system is located at the INL Radioactive W aste Management Complex (RWMC) in

the facility formerly called the SWEPP, INL Buildin g WMF-610. There were two substantial

hardware changes in the last year: INL-CCP replaced detector DETA1 and the bearings on the

door hinge. INL-CCP appropriately documented both c hanges with successful calibration

verifications prior to resuming operations. There w ere no concerns regarding these aspects of the

SGRS NDA system.

(2) EPA assessed the design and operational range of th e Stored Waste Examination Pilot

Plant Gamma-Ray Spectrometer and found them to be u nchanged from the last inspection

and were adequate for the wastes currently being as sayed.

Between June 7, 2013, and April 30, 2014, the SGRS assayed 4,096 drums (includes production

drums and information-only drums) that were compile d in 155 BDRs. SGRS operators conveyed

to EPA reviewers that the SGRS has the capability t o assay up to 36 55-gallon drums in a day;

however, on a typical day approximately 32 are assa yed.

SGRS operators appropriately recorded all daily per formance measurements, which were in

control. Specifically, operators evaluated backgrou nd, daily performance check, FWHM and

energy calibration (gain), as evidenced in the SGRS daily operational logbook and BDRs. INLCCP had established and documented warning and cont rol limits (2 and 3 σ limits) for all

parameters, as appropriate, and boundary limits con trolled background (~40 cps, full spectrum),

FWHM and gain. EPA observed that SGRS personnel had available and were using the current

revisions of the SGRS operating procedure. All oper ational aspects of the SGRS operation were

acceptable. There were no concerns regarding these aspects of the SGRS NDA system.

# 23



# (3) INL-CCP performed and documented system calibration and calibration confirmation of

the Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer nondestructive

assay system as required.

The EPA inspection team verified that the system’s calibration was unchanged since the

recalibration approved in February 2013. INL-CCP pe rformed calibration verifications following

the replacements of detector DETA1 and the steel be arings in the door hinge. All aspects of the

calibration verification were technically acceptabl e and appropriately documented. There were

no concerns regarding the calibration of the SGRS N DA system.

(4) INL-CCP determined and documented the lower limit o f detection, including the

minimum detectable concentration of the Stored Wast e Examination Pilot Plant GammaRay Spectrometer, as required.

CCP-INL-SGRS-001, Revision 2, November 14, 2012, se ction 6.0, adequately documents the

technical basis for the system’s LLD, including rep orting thresholds for the nonmeasured

radionuclides 234 

# U, 238 

# Pu, 239 

# Pu, 242 

# Pu and 90 

# Sr. The EPA inspection team verified that this

document was unchanged from EPA’s last T1 evaluatio n. There were no concerns regarding the

LLD determination of the SGRS NDA system.

(5) The Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer sussessfully

participated in the performance demonstration progr am.

The SGRS participated in Cycle 20 of the CBFO-spons ored PDP for drums in May 2013. The

SGRS is scheduled to participate in the PDP annuall y and will participate in Cycle 21A in May

2014.

(6) EPA assessed personnel training and found it to be adequate.

All NDA personnel associated with the calibration, operation and data review and approval of

the SGRS had current training in the applicable are as, as evidenced by the LOQI dated May 1,

2014, that INL-CCP provided during the inspection. There were no concerns regarding personnel

training for the SGRS NDA system.

Submission to EPA of a list of all NDA personnel wh o performed work during the previous

quarter is a new NDA T2 change (see Table 1). Speci fically, the list must include all operators,

EAs and ITRs. EPA added this requirement to ensure that EPA has a complete picture of INLCCP waste characterization activities, which will i nform the scope of NDA components

evaluated during future T1 change evaluations.

Summary of Findings and Concerns:

EPA did not identify any finding for SGRS. Like the WAGS system above, EPA, however,

identified the same concern for SGRS regarding docu mentation of formal and informal

calibration verifications. This concern is same as that documented on the EPA Inspection Issue

Tracking Form, Issue No. INL-CCP-CH-WC-14-01C, whic h is included in Attachment C. EPA

discussed this concern with EA P. Abbott. EPA and P . Abbot agreed that the documentation

concern would be addressed in the next revision of CCP-TP-019.

# 24



# 6.2.3 Technical Evaluation: Super High Efficiency Neutron Counter for Contact-Handled

Waste

EPA evaluated INL-CCP’s continued compliance with t he EPA-approved waste characterization

program for CH waste using the Super High Efficienc y Neutron Counter (SuperHENC) NDA

system. The SuperHENC is located at INL in the faci lity formerly called the SWEPP, INL

Building WMF-610, South Bay, and is officially desi gnated as NDA SHENC-01. EPA verified

that INL-CCP has not made any substantive hardware or software changes to this system since

the last EPA inspection.

Although the SuperHENC is an approved measurement m odality at INL-CCP, INL-CCP only

used it for WIPP assays on four days since EPA’s co ntinued compliance inspection of 2013.

INL-CCP indicated to EPA inspectors that they do no t expect the frequency of use to increase in

the near future. Despite the lack of use, INL-CCP c ontinues to run weekly checks on the

instrument to keep the instrument functioning prope rly. Because INL-CCP is using the

SuperHENC infrequently, EPA elected to abridge its review of the SuperHENC and focus

instead on the SGRS and WAGS, which have much highe r throughput of routine waste drums.

EPA requested that INL-CCP notify EPA if there is a significant increase in the use of the

SuperHENC.

EPA evaluated the following aspects of the SuperHEN C during this inspection.

(1) EPA assessed the design and operational range of th e Super High Efficiency Neutron

Counter and found them to be unchanged from the las t inspection and adequate for the

wastes currently being assayed.

EPA verified that INL-CCP has not changed the origi nal operational ranges for all of the

system’s previously approved assay configurations s ince the last EPA inspection. There were no

concerns regarding these aspects of the SuperHENC N DA system.

(2) INL-CCP performed and documented system calibration and calibration confirmation of

the Super High Efficiency Neutron Counter as requir ed.

EPA verified that INL-CCP had not changed the syste m’s original calibrations for all previously

approved assay configurations. INL-CCP had not perf ormed any calibration verifications since

the last EPA inspection. There were no concerns reg arding the calibration of the SuperHENC

NDA system.

(3) INL-CCP determined and documented the total measure ment uncertainty of assays

performed on the Super High Efficiency Neutron Coun ter as required.

EPA verified that INL-CCP had not changed the syste m’s original determinations of TMU for all

previously approved assay configurations since the last EPA inspection. There were no concerns

regarding the determination of TMU for the SuperHEN C NDA system.

# 25



# (4) INL-CCP determined and documented the lower limit o f detection, including the

minimum detectable concentration of the Super High Efficiency Neutron Counter, as

required.

The EPA inspection team verified that INL-CCP had n ot changed the system’s original

determinations of LLDs for all previously approved assay configurations since the last EPA

inspection. There were no concerns regarding the LL D determination of the SuperHENC NDA

system.

(5) The SuperHENC sussessfully participated in the perf ormance demonstration program.

The SuperHENC participated in Cycle B13-A of the CB FO-sponsored PDP for boxes in January

2014. The SuperHENC is secheduled to participate in the PDP annually and will participate in

the next box cycle currently scheduled for December 2014.

(6) EPA assessed personnel training and found it to be adequate.

All NDA personnel associated with the calibration, operation and data review and approval of

the SuperHENC had current training in the applicabl e areas, as evidenced by the LOQI dated

May 1, 2014, that was provided during the inspectio n. There were no concerns regarding

personnel training for the SuperHENC NDA system.

Submission to EPA of a list of all NDA personnel wh o performed work during the previous

quarter is a new NDA T2 change (see Table 1). Speci fically, the list must include all operators,

EAs and ITRs. EPA added this requirement to ensure that EPA has a complete picture of INLCCP waste characterization activities, which will i nform the scope of NDA components

evaluated during future T1 change evaluations.

6.2.4 Nondestructive Assay for Contact-Handled Waste Find ings and Approval

Summary of Nondestructive Assay Findings and Concer ns

EPA did not identify any findings for NDA at INL-CC P used for characterizing contact-handled

waste. EPA, however, identified one concern regardi ng documentation of formal and informal

calibration verifications that applies to both WAGS and SGRS. This concern is documented on

the EPA Inspection Issue Tracking Form, Issue No. I NL-CCP-CH-WC-14-01C, which is

included in Attachment C. EPA discussed this concer n with EA P. Abbott. EPA and P. Abbot

agreed that the documentation concern would be addr essed in the next revision of CCP-TP-019.

Nondestructive Assay for Contact-Hanlded Waste Appr oval

There are no changes to the T1 designations for NDA as a result of this continued compliance

inspection. Submission to EPA of a list of all NDA personnel who performed work during the

previous quarter is a new NDA T2 change (see Table 1). Specifically, the list must include all

operators, EAs and ITRs.

# 26



# Based on the results of this evaluation and the dat a examined, EPA determines that INL-CCP

demonstrated continued compliance with the EPA-appr oved waste characterization program for

all NDA systems.

6.3 Dose-to-Curie for Remote-Handled Waste

EPA approved the Dose-to-Curie (DTC) process at INL -CCP initially during the RH baseline

inspection in June 2007 (EPA Docket No. A-98-49; II -A4-72).

Technical Evaluation

EPA evaluated INL-CCP’s continued compliance with E PA-approved DTC procedures for RH

waste characterization. The checklist used for this inspection is included in Attachment G. EPA

evaluated the following aspects of DTC during this inspection:

(1) EPA observed the dose-to-curie technique, including source checks, and found it to be

adequate.

EPA observed the DTC technique on May 7, 2014, at I daho Nuclear Technology and

Engineering Center (INTEC) in INL Building 659, Roo m 306, from screens in the operator

control room, Room 302. The INL-CCP DTC operators w ere David Pinnock, Mary Carroll and

Brent Dial, who were listed on the current LOQI dat ed May 1, 2014. The INL-CCP

DTC/OSPREY operator, Brent Dial, used the gamma sof tware. DTC personnel began by

performing the operational check on Scale No. 72442 2, which is due for recalibration on June

18, 2014. EPA inspectors did not witness this check ; the DTC operator had documented it

appropriately in the DTC operational logbook. The o perator weighed the drums and recorded the

weight on the measurement control report (CCP-TP-50 4, Revision 13, Attachment 2) and

summarized this activity in the DTC operational log book. EPA inspectors did not witness this

measurement; the DTC operator had documented it app ropriately in the CCP-TP-504, Revision

15, Attachment 1 and in the DTC operational logbook

.

DTC personnel performed the source checks for Therm o Scientific Model FH 40 G Dose Rate

Measuring Unit with FHZ 612 Probe (Instrument No. 0 2055) attached to Probe No. XC0674,

with the option of using Probe No. XC0675. DTC pers onnel measured the ambient background

and performed source checks for the high and low ra nges, and recorded all measurements on the

measurement control report and summarized them in t he DTC operational logbook. DTC

personnel consulted “CCP Operator Aid: RH-DM-INL-00 2, Revision 19, 05/06/14,” which listed

tolerances for the test drum weights, scale error, operational ranges for the Geiger Mueller

probes and acceptance criteria for the source check s. DTC operators also performed a source

check for the OSPREY La 3 

# Br 5 

# Probe No. 13000014 using 137 

# Cs source No. 1181-64 INL 1D;

CP-7CS001 positioned with the appropriate jig. DTC operators took a background dose reading

while all containers were in a shielded position.

5 

# The OSPREY detector is a cerium-drifted lanthanum bromide crystal [La 3 

# Br(Ce)].

# 27



# When EPA entered the DTC observation room, DTC oper ators had already taken background

readings and weighed Drum No. FC0108C-1B. INL-CCP a ppropriately documented these

measurements. EPA observed four measurements made a t different points on the drum’s

circumference, i.e., at 0 ° , 90 ° , 180 ° and 270 ° . The operator recorded all measurements on the

container data sheet (CCP-TP-504, Revision 15, Atta chment 2), a copy of which INL-CCP

provided to EPA. Contact dose rates for this drum e xceeded 200 millirem per hour (mrem/hr) 6



# and exceeded three times the measured background as required by the WCPIP, and all

measurements and accompanying parameters were accep table.

There were no concerns regarding INL-CCP’s executio n and documentation of DTC.

(2) EPA assessed personnel training and found it to be adequate.

INL-CCP provided the LOQI dated May 1, 2014, for DT C and OSPREY documenting that all

DTC personnel were appropriately trained. There wer e no concerns regarding personnel training

for DTC.

Submission to EPA of a list of all DTC personnel wh o performed work during the previous

quarter is a new DTC T2 change (see Table 2). Speci fically, the list must include all operators,

EAs and ITRs. EPA added this requirement to ensure that EPA has a complete picture of INLCCP waste characterization activities, which will i nform the scope of DTC components

evaluated during future T1 change evaluations.

6.3.1 Dose-to-Curie for Remote-Handled Waste Findings and Approval

Summary of Dose-to-Curie Findings and Concerns

EPA did not identify any findings or concerns for D TC at INL-CCP.

Radiological Characterization Approval

There are no changes to the T1 designations for DTC as a result of this continued compliance

inspection. Submission to EPA of a list of all DTC personnel who performed work during the

previous quarter is a new DTC T2 change (see Table 2). Specifically, the list must include all

operators, EAs and ITRs.

Based on the results of this evaluation and the dat a examined, EPA determines that INL-CCP

demonstrated continued compliance with the EPA-appr oved waste characterization program for

DTC.

6 

# Rem or millirem is a unit of dose equivalent, which is often commo nly called dose or when it is expressed

per unit time, a dose rate . The criterion for RH determination is expressed i n terms of a dose rate in rem, which,

while technically incorrect, is commonly used. Addi tionally, gamma measurements which technically repr esent

exposure in Roentgens (R) or milliRoentgens (mR) are commonly misstated in rem . In this report, the terms dose and

dose rate are used in place of the technically correct term dose equivalent or dose equivalent rate , and the terms R

and rem are used interchangably

. The actual differences among these values for the purpose of this report are

negligible.

# 28



# 6.4 Real-Time Radiography for Remote-Handled Waste

EPA evaluated INL-CCP’s continued compliance with E PA-approved RTR procedures for RH

waste and found compliance to be adequate. INL-CCP does not perform RTR for CH waste

containers. The RTR checklist used for this inspect ion is included in Attachment H.

Technical Evaluation

(1) EPA observed real-time radiography examination of a drum and found it to be adequate.

On May 6, 2014, INL-CCP demonstrated the RTR proces s for Drum No. FCO108C from BDR

No. INLRHRTR14004, Waste Stream ID-HFEF-S5000-RH. T he operator had already performed

the necessary equipment checks prior to EPA’s arriv al. The operator properly examined the

container’s contents and entered characterization d ata into the electronic data sheet. The operator

determined that the waste matched the waste stream description and verified the WMC. The

operator did not find any prohibited items in the c ontainer. After the demonstration, EPA

reviewed the container data sheets and determined t hat they had been completed correctly and

signed by the RTR operator. The operator used proce dure CCP-TP-508, 7 

# to guide the

examination.

EPA determined the procedure continues to be adequa te and effective for generation of

compliant RH RTR data.

(2) EPA examined real-time radiography characterization records and found them to be

adequate.

EPA reviewed the audio/visual and written records f or selected containers from BDR Nos.

INLRHRTR14002 and INLRHRTR14003 and determined that the records were complete and

generated in accordance with INL-CCP procedures. Th e operators had performed an image

quality check prior to each RTR event for the BDRs examined and had performed the required

quality control (QC) examinations. The operators pr operly examined each container’s contents

and entered characterization data into an electroni c data sheet. The drums in the BDRs reviewed

contained SCG S5000 (heterogeneous debris) waste. T he operators determined that the waste

matched the waste stream description and verified t he WMC. The operators did not identify any

prohibited items in the containers from the reviewe d BDRs.

INL-CCP reviewed the data at the data generation an d SPM level; INL-CCP recorded the

reviews on the appropriate forms from CCP-TP-508 an d CCP-TP-001. 8



# EPA determined that INL-CCP continues to generate a nd record compliant RH RTR data in

accordance with written procedures.

7 

# CCP-TP-508, CCP RH Standard Real-Time Radiography Inspection Procedure, Revision 9, September

26, 2013

8 

# CCP-TP-001, CCP Project Level Data Validation and Verification, Revision 21, June 6, 2013

# 29



# (3) EPA examined real-time radiography training records and found them to be adequate.

EPA reviewed training records for selected RTR oper ators, including qualification cards and

training-container examination records.

EPA determined that RTR operators continue to be tr ained in accordance with CCP procedures

and that training records were readily available fo r review. EPA reviewed an LOQI and

determined that the operator performing the onsite RTR demonstration was properly trained and

qualified.

Submission to EPA of a list of all RTR personnel wh o performed work during the previous

quarter is a new RTR T2 change (see Table 2). Speci fically, the list must include all operators

and ITRs. EPA added this requirement to ensure that EPA has a complete picture of INL-CCP

waste characterization activities, which will infor m the scope of RTR components evaluated

during future T1 change evaluations.

6.4.1 Real-Time Radiography Findings and Approval

Summary of Real-Time Radiography Findings and Conce rns

EPA did not identify any findings or concerns relat ed to RTR for RH wastes as a result of this

continued compliance inspection.

Real-Time Radiography Approval

Submission to EPA of a list of all RTR personnel wh o performed work during the previous

quarter is a new RTR T2 change (see Table 2). Speci fically, the list must include all operators

and ITRs.

Based on the results of this evaluation and the dat a examined, EPA determines that INL-CCP

demonstrated continued RTR compliance for RH SCG S5 000 (heterogeneous debris) waste.

6.5 Visual Examination

EPA evaluated INL-CCP’s continued compliance with E PA-approved VE procedures for CH

and RH waste characterization. The VE checklists us ed for this inspection are included in

Attachments I.1 and I.2.

6.5.1 Visual Examination of Contact-Handled Waste

Technical Evaluation

(1) EPA observed visual examination of a contact-handle d drum and found it to be adequate.

During the onsite inspection, INL-CCP demonstrated the CH VE process for containers

SRP23081 and SRP23106 from BDR No. IN-SRP-VE-000737 ). The operators properly

examined and identified the waste’s contents and en tered characterization data into an electronic

data sheet. The operators determined that the waste matched the waste stream description and

# 30



# verified the WMC. The operators did not identify an y prohibited items during the demonstration.

After the demonstration, EPA reviewed the VE data s heets and determined that the operators

completed them correctly. The operators used proced ure CCP-TP-006 9 

# to guide the examination.

EPA determined the procedure and process to be adeq uate and effective for generation of

compliant CH VE data.

(2) EPA examined contact-handled visual examination cha racterization records and found

them to be adequate.

EPA reviewed selected container data from CH VE BDR Nos. INL-ARP-VE-002942, INL-ARPVE-002943, INL-SRP-VE-000496, INL-SRP-VE-000699 and INL-SRP-VE-000700. EPA

determined that INL-CCP completed and properly proc essed the characterization records. EPA

also verified that INL-CCP generated and recorded t he VE data in accordance with CCP

procedures. Operators recorded the WMP of each wast e item, verified the WMC and confirmed

the absence of prohibited items. Two operators and a VEE signed the data sheets as required by

procedure CCP-TP-006. At the time of inspection, IN L-CCP had not generated any NCRs for the

containers in these BDRs.

(3) EPA examined contact-handled visual examination tra ining records and found them to be

adequate.

EPA reviewed training records for selected operator s and VEEs. The qualification cards and

other training records were complete and available for review. Review of the latest LOQI

demonstrated that the operators performing the on-s ite demonstration were properly qualified.

Submission to EPA of a list of all VE personnel who performed work during the previous quarter

is a new VE T2 change (see Table 1). Specifically, the list must include all operators, VEEs and

ITRs. EPA added this requirement to ensure that EPA has a complete picture of INL-CCP waste

characterization activities, which will inform the scope of VE components evaluated during

future T1 change evaluations.

Summary of Visual Examination for Contact-Handled W aste

EPA did not identify any findings or concerns relat ed to VE for CH wastes as a result of this

continued compliance inspection.

Based on the results of this evaluation and the dat a examined, EPA determines that INL-CCP

demonstrated continued VE compliance for SCG S3000, S4000 and S5000 CH TRU waste.

9 

# CCP-TP-006, CCP Visual Examination Technique for I daho National Laboratory (INL) Newly Generated

TRU Waste, Revision 18, January 30, 2014

# 31



# 6.5.2 Visual Examination of Remote-Handled Waste

Technical Evaluation

(1) EPA interviewed two operators and a visual examinat ion expert in lieu of observing

visual examination for remote-handled waste and fou nd them to be adequately

knowledgeable.

INL-CCP was not able to perform a demonstration of the RH VE process during the onsite visit

due to equipment malfunction. EPA interviewed two o perators and a VEE and determined that

they were knowledgeable regarding generation and re cording of RH VE data. The personnel

interviewed were able to answer all questions asked by EPA.

(2) EPA examined remote-handled visual examination char acterization records and found

them to be adequate.

The only RH VE BDR that INL-CCP generated since the last EPA continued compliance

inspection was BDR No. INLRHVE13001. EPA reviewed t his report and determined that INLCCP completed and properly processed the characteri zation records. EPA verified that INL-CCP

generated and recorded VE data in accordance with C CP procedures. The operators recorded the

WMP of each waste item, verified the WMC and confir med the absence of prohibited items.

Two operators signed the data sheets as required by procedure CCP-TP-500. 10 

# At the time of

inspection, INL-CCP had not generated any NCRs for the containers in this BDR.

(3) EPA examined remote-handled visual examination trai ning records and found them to be

adequate.

EPA reviewed training records for selected operator s and VEEs. The qualification cards and

other training records were complete and available for review.

Submission to EPA of a list of all VE personnel who performed work during the previous quarter

is a new VE T2 change (see Table 2). Specifically, the list must include all operators, VEEs and

ITRs. EPA added this requirement to ensure that EPA has a complete picture of INL-CCP waste

characterization activities, which will inform the scope of VE components evaluated during

future T1 change evaluations.

Summary of Visual Examination for Remote-Handled Wa ste

EPA did not identify any findings or concerns relat ed to VE for RH wastes as a result of this

continued compliance inspection.

Based on the results of this evaluation and the dat a examined, EPA determines that INL-CCP

demonstrated continued VE compliance for SCG S5000 RH TRU waste.

10 

# CCP-TP-500, CCP Remote-Handled Waste Visual Examin ation, Revision 13, April 21, 2013

# 32



# 6.5.3 Visual Examination Findings and Approval

Summary of Visual Examination Findings and Concerns

EPA did not identify any findings or concerns for V E at INL-CCP.

Visual Examination Approval

Submission to EPA of a list of all VE personnel who performed work during the previous quarter

is a new VE T2 change for the RH and CH waste chara cterization programs (see Tables 1 and 2).

Specifically, the list must include all operators, VEEs and ITRs.

Based on the results of this evaluation and the dat a examined, EPA determines that INL-CCP

demonstrated continued VE compliance.

7.0 FINDINGS AND CONCERNS

EPA did not identify any findings during this conti nued compliance inspection. EPA identified

one concern not requiring a response regarding docu mentation of formal and informal calibration

verifications. This concern is documented on the EP A Inspection Issue Tracking Form, Issue No.

INL-CCP-CH-WC-14-01C, which is included in Attachme nt C. The concern is closed and there

are no open concerns as a result of this continued compliance inspection.

8.0 CONCLUSIONS

Changes to Tiering

There are no changes to the T1 designations in any waste characterization area as a result of this

inspection. There are substantive changes to the RH and CH AK T2 designations. DOE needs to:

1. Submit to EPA of a list of all INL-CCP NDA personne l who performed work during the

previous quarter is a new NDA T2 change (see Table 1). Specifically, the list must

include all operators, EAs and ITRs.

2. Submit to EPA of lists of all INL-CCP RH and CH RTR and VE personnel who

performed work during the previous quarter are new RTR and VE T2 changes (see

Tables 1 and 2). Specifically, the list must includ e all VE and RTR operators, ITRs and

VEEs.

3. Submit to EPA of a list of all INL-CCP DTC operator s, EAs and ITRs that performed

work during the previous quarter is a new DTC T2 ch ange (see Table 2).

The T2 changes listed above are necessary to make t he INL-CCP tiering designations consistent

with the requirements at other TRU sites and to sup port EPA’s process for conducting T1

evaluations. Tables 1 and 2 show the substantive T2 changes for CH and RH in bold text. T1 and

T2 changes that were initiated during the CH and RH baseline and subsequent T1 approvals

remain in effect. The language in Tables 1 and 2 re garding AK documentation applies to all INLCCP waste streams.

# 33



# Approval

EPA determined that the INL-CCP waste characterizat ion program activities continue to be

technically adequate. The scope of the compliance d ecision is based on EPA’s inspection

completed May 6–8, 2014.

# A-1



# ATTACHMENT A.1: APPROVAL SUMMARY FOR INL-CCP CONTAC T-HANDLED

WASTE CHARACTERIZATION PROGRAM

Approved Activity EPA Inspection Number,

Approval Dates EPA Docket Number

INL-CCP CH Baseline Approval EPA-INL-CCP-05.05-8,

November 1, 2005 A-98-49, II-A4-59

T1 Change – Approval of the HENC November 16, 2005 A-98-49; II-A4-60

T1 Change – Approval of Visual Examination as a

Quality Control Check for Real-time Radiography November 16, 2005 A-98-49, II-A4-61

T1 Change – Approval of Pit 4 and Pit 6 (ARP-I and

ARP-II) Waste (plus Addendum) August 3, 2006

(December 5, 2006) A-98-49, II-A4-67

(A-98-49, II-A4-71)

T1 Change – Approval of the SuperHENC February 28, 2007 A-98-49, II-A4-86

Unannounced Continued Compliance Inspection Novembe r 26, 2007 A-98-49, II-A4-94

T1 Change – Approval of Multi-Curve Efficiency

Calibration for the WAGS October 7, 2008 A-98-49, II-A4-107

T1 Change – Approval of Visual Examination by

Review of Waste Packaging Audio/Visual

Recordings March 4, 2009 A-98-49, II-A4-110

2008 Continued Compliance Inspection March 25, 2009 A-98-49, II-A4-112

T1 Change – Approval of Recalibration of the HENC S eptember 22, 2009 A-98-49, II-A4-119

2010 Continued Compliance Inspection March 16, 2011 A-98-49, II-A4-142

T1 Change – Approval of Supplemental Calibration fo r

the WAGS to Allow Filters June 23, 2011 A-98-49, II-A4-150

Unannounced Inspection – Waste Stream ID-NRD.1 Janu ary 4, 2012 A-98-49, II-A4-157

T1 Change – Approval of Recalibration of the SGRS F ebruary 26, 2013 A-98-49, II-A4-172

2013 Continued Compliance Inspection July 16, 2013 A-98-49, II-A4-175

# A-2



# ATTACHMENT A.2: APPROVAL SUMMARY FOR INL-CCP REMOTE -HANDLED

WASTE CHARACTERIZATION PROGRAM

Approved Activity EPA Inspection Number,

Approval Dates EPA Docket Number

INL-CCP RH Baseline Approval EPA-INL-CCP-RH-6.06-8,

January 12, 2007 A-98-49; II-A4-72

T1 Change – Approval of WIPP Waste Information

System January 17, 2007 A-98-49; II-A4-74

T1 Change – Approval of Visual Examination January 25, 2007 A-98-49; II-A4-75

T1 Change – Approval of Real-Time Radiography Febru ary 12, 2007 A-98-49; II-A4-80

T1 Change – Approval of K Cell Wastes January 1, 20 08 A-98-49; II-A4-97

T1 Change – Approval of High-Range Gamma Probe

for DTC April 11, 2008 A-98-49; II-A4-98

T1 Change – Approval of Visual Examination

Technique September 22, 2009 A-98-49; II-A4-118

T1 Change – Addition of Twelve Containers to Waste

Stream ID-ANLE-S5000 and Addition of Waste

Stream ID-HFEF-S5400-RH February 1, 2010 A-98-49; II-A4-122

T1 Change – Approval of Waste Stream

ID-MFC-S5400-RH June 8, 2010 A-98-49; II-A4-126

T1 Change – Approval of Waste Stream

ID-INTEC-S5400-RH August 17, 2010 A-98-49; II-A4-130

T1 Change – Addition of Lot 1B to Waste Stream

ID-HFEF-S5400-RH August 23, 2010 A-98-49; II-A4-131

T1 Change – Approval of Waste Stream

IN-ID-NRF-153 November 1, 2010 A-98-49; II-A4-135

T1 Change – Approval of Waste Stream

ID-RTC-S3000 November 1, 2010 A-98-49; II-A4-137

2010 Continued Compliance Inspection March 16, 2011 A-98-49; II-A4-142

T1 Change – Addition of Lot 4A to Waste Stream

ID-HFEF-S5400-RH March 23, 2011 A-98-49; II-A4-145

T1 Change – Approval of Waste Stream

IN-ID-NRF-SPC March 12, 2012 A-98-49; II-A4-159

T1 Change – Addition of Lot 2 to Waste Stream

ID-ANLE-S5000 July 25, 2012 A-98-49; II-A4-163

2013 Continued Compliance Inspection July 16, 2013 A-98-49, II-A4-175

T1 Change – Approval of Waste Stream ID-EBRS5000 April 16, 2014 A-98-49, II-A4-183B-1ATTACHMENT B: INSPECTION PERSONNELPersonnelAffiliationArea of Expertise/FunctionEntranceMeetingInterviewedExitMeetingRajani Joglekar U.S. EPA ORIAInspector–Team LeaderEd Feltcorn U.S. EPA ORIA InspectorDorothy Gill SC&A, Inc. RTR/VE InspectorConnie Walker SC&A, Inc. AK InspectorKira Darlow SC&A, Inc. AK InspectorRose Gogliotti SC&A, Inc. NDA/DTC InspectorBen Roberts DOEBill Verlanic CCP CCP CHBrad Stark CCP CH VEEBrent Dial INL-CCP DTC/OSPREYBrett Gyorfy CCP RecordsBruce LaRue DEQ ObserverCarrie Johnson CCP CCP AKE CH/RHChris G. Davis INL-CCP RH RTR ITR, RH VEO/ITRDavid Brasier CCP NDADavid Pinnock INL-CCP DTCDoug Pruitt DOEEd Gulbransen NWP CCP ManagerIrene Joo CCP RH Project ManagerJ. Bret Palmer INL-CCP RH VEO/ITRJeff Poole INL-CCP RH VEE/VPMJennifer Law INL-CCP NDAJeri Miles NWP CH VE VPMJodi M. Stanton INL-CCP CH VEOKevin Peters INL-CCP AK/AKELarry Klingler CCP QALashell Alade INL-CCP RH RTR OperatorLisa Frost CWI CH TRULori Muntean INL-CCP CH VEOMarcus A. Pinzel DOEB-2Mary Carroll INL-CCP RH DTCMike Grenfell INL-CCP Container ManagerPorf Martinez CBFO/CTAC ObserverPreston Abbott CCP NDARaj Bhatt CWI RH TRURichard Kantrowitz NWP SPMScott Smith CCP AK/AKESteve Schafer CCP AKETom Clements CWI ObserverTom Johnsen CWI CH TRU STRTrisha Pimentel CCP RecordsTyson Christensen CCP RH RTR Lead Operator

# C-1 

# ATTACHMENT C: EPA INSPECTION ISSUE TRACKING FORM,

ISSUE NO. INL-CCP-CH-WC-14-01C, FINAL

Inspection No. INL-CC-2014 Issue Number: INL-CCP-CH-WC-14-01C

Date: May 6, 2014

Inspector: R. Gogliotti

Attachments? YES NO Sample Size: NA

Population size (if known): NA

Description of Issue: EPA notes a discrepancy between the text of CCP- TP-019 and CCP-TP115 concerning calibration verifications. CCP-TP-11 5 references non-WAC required

calibration verifications as "calibration verificat ion checks" while CCP-TP-019 refers to the

them as "calibration verifications." The non-requir ed calibration verifications do not produce

the same level of documentation as a WAC-required c alibration. EPA is concerened that this

nomenclature is a source of confusion.

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable

D. Discussed with: Preston Abbott

E. Additional Comments: None

F. Site Response Information:

Site Response Required? YES NO

Site Response Due Date: Not applicableD-1ATTACHMENT D.1: AK CONTINUED COMPLIANCE INSPECTIONCHECKLIST: CONTACT-HANDLED WASTEEPA Inspection No.: INL-CC-2014 Contact-Handled WasteInspection Date: May 6–8, 2014Technical ElementsObjective EvidenceCommentsGeneralAK-1:Confirm that AK, training andnonconformance procedures adequately reflect therequirements of 40 CFR 194.CCP-QP-002, Revision 36, training andqualification planCCP-QP-005, Revision 24, nonconforming itemreportingCCP-TP-002, Revision 26, WSPF packagedevelopmentCCP-TP-005, Revision 26, AK documentationRevised sample AKE Qualification Card40 CFR Part 194.24 (c) requires establishment of asystemof controls to characterize waste critical and limiting wastecomponents. The procedures listed provide the AK wastecharacterization method, WSPF development,nonconformance reporting, and training requirementsthathelp fulfill the requirements of 40 CFR Part 194.24(c).This report and its attachments provide examples ofadequate implementation of each listed document.AK-2:Confirm that AKE and SPM training recordsand qualification cards are complete and that eachindividual’s training was conducted prior to themperforming work on this waste stream.Carrie Johnson, AKE, 6/16/2011Kevin Peters, AKE, 6/16/2011Scott Smith, AKE, 6/22/2011Steve Schafer, AKE, 6/16/2011Barbara Broomfield, SPM, 11/2/2004Adela Cantu, SPM, 11/4/2002Jimmy D. Eastham, SPM, 5/12/2009Jerry Fisher, SPM, 10/31/2013Joshua Houghton, SPM, 5/31/2011Rich Kantrowitz, SPM, 5/2/2006; Revised 5/6/2014Jake Knox, SPM, 10/23/2013David Moody, SPM, 6/24/2005; Revised 5/6/2014Laura Nelson, SPM, 6/21/2010Brandye Pyeatt, SPM, 8/27/2012Mike Ramirez, SPM, 5/26/2009; Revised 5/6/2014Beverly Schrock, SPM, 6/23/2010; Revised2/5/2014Carolina Soaterna, SPM, 5/31/2011Andrew Stallings, SPM, 8/27/2012Charles Turner, SPM, 4/19/2007; Revised 5/6/2014Jim Vernon, SPM, 6/11/2009Daniel Wade, SPM, 10/23/2013Veronica Waldram, SPM, 8/4/2009Roger Whiteaker, SPM, 5/3/2012Rick Whiteley, SPM, 10/31/2013CCP-QP-002, Revision 36, Assigned ReadingReport, provided 4/24/2014The qualification cards indicated training to the version ofthe procedure in effect at the time of Qualification Cardsign-off. EPA verified Kevin Peters’, Scott Smith’s, CarrieJohnson’s, Steve Schafer’s and Rich Kantrowitz’s skillsby interview during the inspection. Verified currenttraining of remaining personnel by review of the AssignedReading Reports.CCP implemented CCP-QP-005, Rev. 24, on 4/29/2014,immediately prior to the start of this inspection.EPAreviewed the Assigned Reading Report for CCP-QP-005,Rev. 23, during this inspection because that was therevision in place at the time EPA requested (and CCPprovided) the Assigned Reading Reports.SPMs Jim Eastham and Jim Vernon retired during theprevious year. CCP provided their qualification cardsbecause they signed various documents during the periodof interest for this inspection. Neither SPM will performwork for INL-CCP going forward; therefore, EPA didnotassess their familiarity with current procedure revisions.D-2EPA Inspection No.: INL-CC-2014 Contact-Handled WasteInspection Date: May 6–8, 2014Technical ElementsObjective EvidenceCommentsCCP-QP-005, Revision 23, Assigned ReadingReport, provided 4/24/2014CCP-TP-002, Revision 26, Assigned ReadingReport, provided 4/24/2014CCP-TP-005, Revision 26, Assigned ReadingReport, provided 4/24/2014WP 15-GM1002, Revision 2, Assigned ReadingAcknowledgement Report, provided 5/6/2014AK-3:Confirm that nonconformances aredocumented appropriately.NCR-INL-0097-013NCR-INL-0343-013NCR-INL-0351-013NCR-INL-0007-014NCR-INL-0293-014NCR-INL-0294-014NCR-INL-0300-014Example NCRs examined were complete and used theappropriately dated form.CCP-TP-005 ImplementationAK-4:Confirm that Attachment 1, AcceptableKnowledge Documentation Checklist, is complete.ID-AECHDM: CCP-TP-005, Revision 24,Attachment 1, Signed by Kevin Peters, 5/31/2013ID-AECHHM: CCP-TP-005, Revision 24,Attachment 1, Signed by Kevin Peters, 5/31/2013ID-SRP-S3000: CCP-TP-005, Revision 26,Attachment 1, Signed by Sheri Nance, 2/5/2014INL-CCP consistently produces compliant Att. 1s usingthe proper form revision. The forms are automaticallygenerated and while they meet the regulatoryrequirements, they are not very useful. CCP is consideringvarious options to improve the utility of Att. 1s.AK-5:Confirm that Attachment 2, Record ofCommunication, is completed as necessary.ID-SRP-S3000: C154, C159, C170, C171 The Record ofCommunication format in CCP-TP-005 isnot mandatory. Example references are sufficientlycomplete although in different format.AK-6:Confirm that an Attachment 3, AcceptableKnowledge Source Document Summary, is completefor every source document.See reference list in Attachment J to this report All reviewed source documents had an accompanyingAttachment 3.AK-7:Confirm that Attachment 4, AcceptableKnowledge Information List, is complete and up todate.ID-AECHDM: CCP-TP-005, Revision 24,Attachment 4, Signed by Kevin Peters, 5/31/2013ID-AECHDM: CCP-TP-005, Revision 24,Attachment 4, Signed by Kevin Peters, 5/31/2013ID-SDA-DEBRIS, -SLUDGE, -SOIL: CCP-TP005, Revision 24, Attachment 4, Signed by CarrieJohnson, 5/30/2013 (three separate files)The SRP Att. 4 provided prior to the inspection exhibitedseveral different CCP-TP-005, Attachment 4, revisionnumber headers. INL-CCP revised Att. 4 to correctlyportray a single revision number: Rev. 26 (currentrevisionof CCP-TP-005).D-3EPA Inspection No.: INL-CC-2014 Contact-Handled WasteInspection Date: May 6–8, 2014Technical ElementsObjective EvidenceCommentsID-SRP-S3000: CCP-TP-005, Revision 26,Attachment 4, Signed by Sherri Nance, 5/8/2014AK-8:Confirm that Attachment 6, Waste Form,Waste Material Parameters, Prohibited Items, andPackaging, is complete and up to date.ID-AECHDM, -AECHHM: CCP-TP-005, Revision23, Attachment 6, Signed by Kevin Peters,9/29/2011 (two separate files)ID-AECHDM, -AECHHM: WMP analysismemorandum, Signed by Kevin Peters, 3/23/2011ID-SDA-DEBRIS, -SLUDGE, -SOIL: CCP-TP005, Revision 26, Attachment 6, Signed by CarrieJohnson, 5/8/2014 (three separate files)ID-SDA-DEBRIS, -SLUDGE, -SOIL: WMPanalysis memorandum, Signed by Carrie Johnson,5/8/2014Att. 6s and the WMP memoranda should be reviewed andrevised as necessary when new populations are addedtoestablished waste streams. INL-CCP revised the SDAmemorandum and three Att. 6s during this inspectiontoinclude ARP V–VIII.AK-9:Confirm that Attachment 7, Radionuclides, iscomplete and up to date and that AK-NDAcommunication is appropriately documented.ID-AECHDM: CCP-TP-005, Revision 23,Attachment 7, Signed by Steve Schafer, 10/14/2011ID-AECHDM: NDA memorandum, Revision 1,Signed by Steve Shafer (AKE), David Brasier(MCS EA), Joe Wachter (MCS Technical Director)and Neil Dickes (CCP Project Office), 8/13/2013ID-AECHHM: CCP-TP-005, Revision 23,Attachment 7, Signed by Steve Schafer, 10/14/2011ID-AECHHM: NDA memorandum, Revision 0,Signed by Steve Shafer (AKE), David Brasier(MCS EA), Joe Wachter (MCS Technical Director)and Neil Dickes (CCP Project Office), 10/27/2011ID-SDA-DEBRIS, -SLUDGE, -SOIL: CCP-TP005, Revision 24, Attachment 7, Signed by CarrieJohnson, 5/15/2013 (three separate files)ID-SDA-DEBRIS, -SLUDGE, -SOIL: NDAmemorandum, Signed by Carrie Johnson (AKE),John West (MCS EA), Bart Morales (MCS EA), JoeWachter (MCS Technical Director) and Neil Dickes(CCP Project Office), 6/6/2013AKEs said that there is no set rule for when to update theAtt. 7s. The radionuclide information in the AKSR is usedto bound the waste stream and the NDA EAs use theinformation in the NDA memorandum. As a generalpractice, most AKEs update Att. 7 when necessary tomatch the AKSR and NDA memorandum.The SDA NDA memorandum address waste up to andthrough ARP-VIII including non-RFP mass/Ci estimates,but does not address the unusual radionuclide mix thatmay be in the waste if ARP VIII non-RFP waste isinadvertently mixed with the RFP target waste. Thisis notyet required as the intent of waste extraction is to excludethese non-RFP waste, but future revisions may be requiredif assay finds the ARP-VIII waste to contain unexpectedradionuclides.AK-10:Confirm that Attachment 8, WasteContainers List, is complete and up to date.ID-AECHDM: CCP-TP-005, Revision 24,Attachment 8, Signed by Kevin Peters, 5/31/2013ID-AECHDM: CCP-TP-005, Revision 23,INL-CCP wrote the January 2013 AECHDMmemorandum to try to meet the requirements for addingcontainers to the waste stream PK (for shipping fromD-4EPA Inspection No.: INL-CC-2014 Contact-Handled WasteInspection Date: May 6–8, 2014Technical ElementsObjective EvidenceCommentsAttachment 8, Signed by Kevin Peters, 9/29/2011ID-AECHDM: Waste Stream Container EvaluationMemorandum, Addition of 38 Containers to WasteStream AECHDM-PK and ID-AECHDM, Signedby Kevin Peters, 1/16/2013, Draft revision provided5/7/2014ID-RF-S3114: CCP-TP-005, Revision 23,Attachment 8, Signed by Scott Smith, 4/22/2013ID-SRP-S3000: CCP-TP-005, Revision 26,Attachment 8, Signed by Scott Smith, 1/24/2014ID-SRP-S3000: Memorandum of Evaluation ofAdditional Containers for Sludge RepackageProject (SRP) Waste Stream ID-SRP-S3000, Signedby Scott Smith, 11/18/2013AKTSSANL-E to INL) and the waste stream AK (forcharacterizing and emplacement in WIPP). The resultingmemorandum did not clearly convey that the additionalcontainers were bound by the existing AKSR. INL-CCPrevised the memorandum to reflect the addition to AKonly and clarified that the containers are bound bythecurrent AKSR.INL-CCP characterized over 3,000 containers of ID-RFS3114 waste since May 2013, but did not need to generatea new Att. 8 because all the new drums were actuallyrepackaged from drums that were included in previousAtt. 8s.The AKTSS indicates that 1,583 containers of ID-SRP-S3000 waste are fully characterized as of 4/24/2014, incontrast to the Att. 8 which shows 560 containers in thestream as of 1/24/2014. This difference is due to theaggressive characterization schedule for this wastestream.AK-11:Confirm that Attachment 10, AcceptableKnowledge Re-evaluation Checklist, is completed asnecessary.N/AINL-CCP has not conducted any AK re-evaluations sincethe last inspection (May 2013). AKEs stated that anAtt.10 (AK re-evaluation) is not required for AK-AKdiscrepancies or AK-PK discrepancies.AK-12:Confirm that Attachment 11, AcceptableKnowledge Source Document DiscrepancyResolution, is completed as necessary.ID-AECHDM: DR3004, CCP-TP-005, Revision 23,Attachment 11, Signed by Kevin Peters, 11/4/2011(drum contained unexpected BeO)ID-SRP-S3000: DR701, CCP-TP-005, Revision 26,Attachment 11, Signed by Scott Smith, 11/4/2013(assignment of HWNs)Discrepancy resolutions adequately prepared.AK-13:Confirm that Attachment 13, CCP WasteStream Characterization Checklist, is completed foreach characterization lot.ID-AECHDM: CCP-TP-005, Revision 26,Attachment 13, Lot 4, Signed by Jim Vernon (SPM)and Kevin Peters (AKE), 10/21/2013ID-RF-S3114: CCP-TP-005, Revision 24,Attachment 13, Lot 102, Signed by RogerWhiteaker (SPM) and Scott Smith (AKE), 5/2/2013ID-RF-S3114: CCP-TP-005, Revision 25,Attachment 13, Lot 128, Signed by Steve Castro(SPM) and Scott Smith (AKE), 8/9/2013ID-RF-S3114: CCP-TP-005, Revision 26,Characterization checklists adequately prepared.D-5EPA Inspection No.: INL-CC-2014 Contact-Handled WasteInspection Date: May 6–8, 2014Technical ElementsObjective EvidenceCommentsAttachment 13, Lot 183, Signed by RogerWhiteaker (SPM) and Scott Smith (AKE),3/10/2014ID-SDA-SLUDGE: CCP-TP-005, Revision 24,Attachment 13, Lot 334, Signed by BeverlySchrock (SPM) and Carrie Johnson (AKE),6/12/2013ID-SRP-S3000: CCP-TP-005, Revision 26,Attachment 13, Lot 1 through Lot 23, numeroussignatures, dated 2/21/2014 through 3/28/2014AK-14:Confirm that Attachment 14, CCPAcceptable Knowledge Accuracy Report, iscompleted annually and verify that the AK accuracyreport memorandum is technically adequate.ID-AECHDM: AK Accuracy Lot 4, cumulative forLots 1–4, 5/29/2014ID-RF-3114: AK Accuracy Lots 101–183,cumulative for Lots 1–183, 5/29/2014ID-SDA-SLUDGE, AK Accuracy Lots 314–333,cumulative for Lots 1–333, 6/13/2013ID-SDA-DEBRIS, Lots 1-62, Prepared by J.Vernon, 5/20/2013AK accuracy reports are technically adequate.AK accuracy is calculated by comparing AK againstmeasurement data, long after the waste stream has beenfiltered to remove troublesome containers by fast scan andother pre-screening methods. These containers thatwereinitially included in a waste stream but then wereremovedprior to the WIPP-certifiable characterization do not countagainst AK accuracy. The AK accuracy report cannotbeused to evaluate the accuracy of the original AK orthedecision to include or exclude certain containers in thewaste stream based on AK alone.AK-15:Confirm that Attachment 15, CCP TRUWaste Correlation and Surrogate Summary Form, iscompleted as necessary.N/AAtt. 15 is only required for RH waste streams. An AKE isallowed to use it for CH waste, but as of May 2014,INLCCP AKEs have never prepared an Att. 15 for a CH wastestream.AK-16:Confirm that the AKSR is complete andaccurately describes the subject waste.CCP-AK-INL-001, Revision 12CCP-AK-INL-025, Revision 2CCP-AK-INL-026, Revision 0AKSRs include all required components. See AK-17–AK-19 and AK-21–AK-23 of this Attachment.Waste Stream Definition and Waste IdentificationAK-17:Verify that all waste within the waste streamwas generated from a single process/activity and thatthe generating process/activity is adequatelydescribed.ID-AECHHM, -AECHDM SDs: AE-P-095, P3001,P3002, P3003, P4002, P4003, P4005, U3003 andU3004ID-SRP-S3000 SDs: C701, P507, P513, P542,P543, P544, P545, P546, P713, P714, P722, P723,P724ID-AECHHM, ID-AECHDM: Generated by repackagingactivities conducted by the ANL-E WMO for wastegenerated from laboratory and maintenance operations.The WMO routinely commingled waste from numerousgenerators in a single drum for efficient storage.ID-SRP-S3000: Generated by remediation of sludgewastes in drums with free water. Drums from AMWTPD-6EPA Inspection No.: INL-CC-2014 Contact-Handled WasteInspection Date: May 6–8, 2014Technical ElementsObjective EvidenceCommentsWaste Stream BNINW216 and INL-CCP Waste StreamID-RF-S3114 are treated and repackaged as ID-SRPS3000.AK-18:Verify that all waste within the waste streamis similar in material and physical form and that theexpected physical parameters are adequatelydescribed.ID-AECHDM, -AECHHM SDs: C3002, C3003,C4004, DR3002, P3001, P3002, P3003, P4002,P4003, U3001, U3003, U3004, U4003, U4004,U4005 and U4010ID-AECHDM, -AECHHM: CCP-TP-005, Revision23, Attachment 6, Signed by Kevin Peters,9/29/2011 (two separate files)ID-AECHDM, -AECHHM: WMP analysismemorandum, Signed by Kevin Peters, 3/23/2011ID-SDA-DEBRIS, -SLUDGE, -SOIL: CCP-TP005, Revision 26, Attachment 6, Signed by CarrieJohnson, 5/8/2014 (three separate files)ID-SDA-DEBRIS, -SLUDGE, -SOIL: WMPanalysis memorandum, Signed by Carrie Johnson,5/8/2014ID-AECHDM: Contains organic and inorganic laboratorydebris.ID-AECHHM: Contains mixed homogeneous solidsgenerated during the neutralization and solidification ofaqueous and organic liquids originating from ANL-Elaboratory and maintenance operations.ID-SDA DEBRIS, ID-SDA-SLUDGE, ID-SDA SOLID:Characterized during VE of retrieved target waste.Wastesare divided into waste streams based on the assigned SCG.AK-19:Verify that the expected radiologicalcharacteristics are adequately described.ID-AECHDM, -AECHHM SDs: AE-I-201, C3004,C4005, U3002, U3003, U3005, U3006, U4003,U4011 and U4012ID-SDA-DEBRIS, -SLUDGE, -SOIL: CCP-TP005, Revision 24, Attachment 7, Signed by CarrieJohnson, 5/15/2013 (three separate files)ID-SDA-DEBRIS, -SLUDGE, -SOIL: NDAmemorandum, Signed by Carrie Johnson (AKE),John West (MCS EA), Bart Morales (MCS EA), JoeWachter (MCS Technical Director) and Neil Dickes(CCP Project Office), 6/6/2013ID-SRP-S3000: CCP-TP-005, Revision 26,Attachment 7, Signed by Scott Smith, 12/2/2013ID-SRP-S3000: NDA memorandum, Signed byScott Smith (AKE), John West (MCS EA), DavidBrasier (MCS EA), Joe Wachter (MCS TechnicalDirector) and Neil Dickes (CCP Project Office),11/11/2013ID-AECHHM, -AECHDM: Expected radionuclides basedon certified results for old ANL-E waste streams plus noncertified information for the current containers (assay preshipment from ANL-E); WMO characterized material asTRU/Non-TRU and determined which radionuclides werepresent based on generator records. For both wastestreams, prevalent radionuclides by mass are238U and239Pu, and the prevalent radionuclides by activity are241Puand239Pu.ID-SDA DEBRIS, ID-SDA-SLUDGE, ID-SDA SOLID:The ARP retrieval activities target retrieval of Rocky Flatswaste with a defined radiological signature. ARP-VIIIcontains waste with unique radiological signaturesincluding232Th,137Cs and226Ra. However, none of theseare in targeted waste and are therefore not expected in theretrieved waste stream.ID-SRP-S3000: Composed of Rocky Flats wastepotentially containing WG Pu, EU and/or DU.D-7EPA Inspection No.: INL-CC-2014 Contact-Handled WasteInspection Date: May 6–8, 2014Technical ElementsObjective EvidenceCommentsAK-20:Verify that waste containers are traceablefrom retrieval or generation through CCP’s EPAapproved characterization process?NDE BDR Nos. IN-ARP-VE-002731, IN-ARP-VE002735, IN-ARP-VE-002769, IN-ARP-VE-002793,IN-SRP-VE-000496, IN-SRP-VE-000501, IN-SRPVE-000529, IN-SRP-VE-000649, RTR11-00141,RTR13-00127, RTR13-00129NDA BDR Nos. ASY11-00880, INNDAS120025,INNDAS120034, INNDAS130054,INNDAS130055, INNDAS140017,INNDAS140051, INNDAW120021,INNDAW120025, INNDAW140037ID-SRP-S3000 SDs: ID-P249, ID-P287, ID-P396,ID-P421, ID-P422, ID-P426, ID-P452, ID-P453SRP Spreadsheet tracking weekly input, by sourcedrum, to the SRP repackaging processAMWTP Offsite Waste Stream Profile, AECHDMPK, 4/1/2013Container travelers from AMWTP to INL-CCPWaste is adequately traceable from generation throughcharacterization.ID-RF-S3114: Drum Nos. SRP19302, 10187486ID-AECHDM: Drum Nos. RW49567, RW88680SDA: Drum Nos. ARP70264, ARP70164, ARP70625,ARP71044ID-SRP-S3000: Drum Nos. SRP19363, SRP19813,SRP21731Land Withdrawal Act RequirementsAK-21:Verify that all of the waste in the wastestream is defense in origin.ID-AECHDM, -AECHHM:CCP-AK-INL-025, Revision 2SDs: P3001, P3002, P3003, P3004, P4001, P4002,P4003, P4005, U4003 and U4004ID-SRP-S3000:CCP-AK-INL-026, Revision 0SDs: C702, P004, P053Waste Streams ID-AECHHM and ID-AECHDM areeligible for disposal at WIPP as a commingled defensewaste stream generated “in part” by atomic energy defenseactivities.ID-SRP-S3000 waste originated at Rocky Flats and isofdefense origin.AK-22:Verify that none of the waste in the wastestream is HLW.ID-AECHDM, -AECHHM:CCP-AK-INL-025, Revision 2SDs: U3003, U3004, U4003 and U4004ID-SRP-S3000:CCP-AK-INL-026, Revision 0SDs: C702, P004, P053, P539 and P702Waste Streams ID-AECHHM and ID-AECHDM maycontain some waste from research associated with UREXseparations; however, these research laboratory operationswere not production operations involving the separation orreprocessing of constituent elements from reactor fuel andthe CH waste does not include the high-level fissionproducts.Waste Stream ID-SRP-S3000 is composed of Rocky Flatswaste that is not HLW or SNF.AK-23:Verify that none of the waste in the wastestream is SNF.ID-AECHDM, -AECHHM:CCP-AK-INL-025, Revision 2Waste Streams ID-AECHHM and ID-AECHDM do notcontain any of the following: the intact irradiatedfuel pinD-8EPA Inspection No.: INL-CC-2014 Contact-Handled WasteInspection Date: May 6–8, 2014Technical ElementsObjective EvidenceCommentsSDs: U3003, U3004, U4003 and U4004ID-SRP-S3000:CCP-AK-INL-026, Revision 0SDs: C702, P004, P053, P539 and P702test specimens that were managed separately from the hotcell waste, test residues, test materials, or the resultant testfragments from the fuel pin test specimens.Waste Stream ID-SRP-S3000 is composed of Rocky Flatswaste that is not HLW or SNF.Waste Stream CertificationAK-24:Verify that the WSPF is complete andaccurate.WSPF, Waste Stream ID-AECHDM, Revision 0,12/7/2011WSPF, Waste Stream ID-AECHHM, Revision 1,1/23/2014WSPF, Waste Stream ID-SRP-S3000, Revision 0,2/13/2014INL-CCP SPM signed the WSPF for Waste Stream IDAECHDM on 12/7/2011, but forgot to date the signature.On 5/6/2014, a current INL-CCP SPM revised the WSPFto include the original signature date. WSPF, Line28,discusses the procedures used to physically characterizethe waste. In 2011, INL-CCP was performing the RTRforthis waste stream. Therefore it is appropriate thattheWSPF list only the CCP RTR procedure. Currently,AMWTP is performing all RTR according to theirprocedure. If a WSPF revision is triggered for anyreason,Line 28 with also be modified to include both the CCP andAMWTP procedures, as are cited in Rev. 1 of the IDAECHHM WSPF.AK-25:Confirm that a characterization informationsummary and summation of aspects are included inthe WSPF package and are complete and accurate.ID-AECHDM: WSPF package, Revision 0,12/7/2011ID-AECHHM: WSPF package, Revision 1,1/23/2014ID-SRP-S3000: WSPF package, Revision 0,2/13/2014WSPF packages are complete and accurate.AK-26:Confirm that a characterization informationsummary is adequately completed for eachcharacterization lot.ID-AECHDM: Lot 4, 10/21/2013ID-RF-S3114: Lot 104, 5/13/2013; Lot 115,6/26/2013, Lot 138, 10/3/2013; Lot 183, 3/10/2014ID-SRP-S3000: Lot 2, 2/21/2014; Lot 12, 3/3/2014;Lot 23, 3/28/2014ID-AECHDM: INL-CCP combined the whole 2012campaign into one characterization lot: Lot 4ID-RF-S3114: INL-CCP completed Lots 104–183 sincelast inspection.ID-SRP-S3000: INL-CCP completed Lots 1–23 since lastinspection.All reviewed CISs are complete. The CIS form includes aplace for an AKE review signature, but there is notaprocedural requirement for this review and, in practice, theAKEs do not review CH CISs.D-9EPA Inspection No.: INL-CC-2014 Contact-Handled WasteInspection Date: May 6–8, 2014Technical ElementsObjective EvidenceCommentsTier 2 ReportingAK-27:Verify that INL-CCP has reported to EPAcompletion or revision of the AK-NDA memoranda.FY2013 3rdQuarter T2 reportFY2013 4thQuarter T2 reportFY2014 1stQuarter T2 reportFY2014 2ndQuarter T2 reportID-SDA-DEBRIS, -SLUDGE, -SOIL: AK-NDAmemorandum (6/6/2013) reported on FY2013 3rdQuarterT2 report.ID-SRP-S3000: AK-NDA memorandum (12/9/2013)reported on FY2014 1stQuarter T2 report.ID-AECHDM: AK-NDA memorandum (8/13/2013)should have been reported on FY2013 4thQuarter T2report, but was not.AK-28:Verify that INL-CCP has reported to EPAcompletion or revision of AK accuracy reportsannually, at a minimum.FY2013 3rdQuarter T2 reportFY2013 4thQuarter T2 reportFY2014 1stQuarter T2 reportFY2014 2ndQuarter T2 report2013 AK accuracy reports for Waste Streams ID-SDADEBRIS, ID-SDA-SLUDGE, ID-SDA-SOIL, ID-RFS5300A, ID-RF-S3114 and ID-RF-S3150-A reported onFY2013 3rdQuarter T2 report.AK-29:Verify that INL-CCP has reported to EPAcompletion or revision of AK-AK and AKNDA/NDE DR reports.FY2013 3rdQuarter T2 reportFY2013 4thQuarter T2 reportFY2014 1stQuarter T2 reportFY2014 2ndQuarter T2 reportDR701 reported on FY2014 1stQuarter T2 report.AK-30:Verify that INL-CCP has reported to EPAcompletion or revision of WSPFs, including updatesor additions to waste streams within an approvedwaste category.FY2013 3rdQuarter T2 reportFY2013 4thQuarter T2 reportFY2014 1stQuarter T2 reportFY2014 2ndQuarter T2 reportInitial issue ID-SRP-S3000, Rev. 0, WSPF and IDAECHHM, Rev. 1, WSPF reported on FY2014 2ndQuarter T2 report.AK-31:Verify that INL-CCP has reported to EPAcompletion or revision of AKSRs.FY2013 3rdQuarter T2 reportFY2013 4thQuarter T2 reportFY2014 1stQuarter T2 reportFY2014 2ndQuarter T2 reportCCP-AK-INL-001, Rev. 12, and CCP-AK-INL-025, Rev.2, reported on FY2013 3rdQuarter T2 report.CCP-AK-INL-026, Rev. 0, reported on FY2014 1stQuarter T2 report.AK-32:Verify that INL-CCP has reported to EPAchanges in load management status of approvedwaste streams.FY2013 3rdQuarter T2 reportFY2013 4thQuarter T2 reportFY2014 1stQuarter T2 reportFY2014 2ndQuarter T2 reportID-SRP-S3000 load management approval reported onFY2014 1stQuarter T2 report.AK-33:Verify that INL-CCP has provided to EPA alist of active INL-CCP CH AKEs and SPMs for theprevious quarter.FY2013 3rdQuarter T2 reportFY2013 4thQuarter T2 reportFY2014 1stQuarter T2 reportFY2014 2ndQuarter T2 reportList first reported on FY2014 2ndQuarter T2 report. INLCCP SPM said that the requirement (new from the 2013continued compliance inspection) did not make it into hiswork instructions until spring 2014 and that the FY20142ndQuarter T2 report was the first opportunity he hadtoreport this list.D-10ATTACHMENT D.2: AK CONTINUED COMPLIANCE INSPECTIONCHECKLIST: REMOTE-HANDLED WASTEEPA Inspection No.: INL-CC-2014 Remote-Handled WasteInspection Date: May 6–8, 2014Technical ElementsObjective EvidenceCommentsGeneralAK-1:Confirm that AK, training andnonconformance procedures adequately reflect therequirements of 40 CFR 194.See list of procedures in Attachment D.1, AK-1CCP-TP-506, Revision 4, preparation of RH CRRThis report and its attachments provide examples ofadequate implementation of each listed document.AK-2:Confirm that AKE and SPM training recordsand qualification cards are complete and that eachindividual’s training was conducted prior to themperforming work on this waste stream.Kevin Peters, AKE, 6/16/2011Scott Smith, AKE, 6/22/2011Steve Schafer, AKE, 6/16/2011Carrie Johnson, AKE, 6/16/2011Joshua Houghton, RH SPM, 8/19/2013Irene Joo (Quintana), RH SPM, 9/17/2009Rich Kantrowitz, RH SPM, 10/29/2012David Moody, RH SPM, 8/28/2013Laura Nelson, RH SPM, 6/21/2010Charles Turner, RH SPM, 8/15/2013See list of Assigned Reading Reports in AttachmentD.1, AK-2CCP-QP-005, Revision 24, Assigned ReadingReport, Joshua Houghton, provided 5/8/2014CCP-TP-506, Revision 4, Assigned ReadingReport, provided 5/6/2014DOE WIPP-02-3214 (WCPIP), Revision 3,Assigned Reading Report, provided 4/24/2014The qualification cards indicated training to the version ofthe procedure in effect at the time of Qualification Cardsign-off. EPA verified Kevin Peters’, Irene Joo’s,and ScottSmith’s skills by interview during the inspection.The skillsof the other INL-CCP RH AKEs and SPMs were alsoverified through review of the Assigned Reading Reports.CCP released CCP-QP-005, Rev. 24, immediately priortothe continued compliance inspection. EPA reviewed Rev.24 for adequacy, but did not require INL-CCP to providedocumentation that all AKEs and SPMs are familiar withthe new revision. EPA will review the Assigned ReadingReport for Rev. 24 (or the current-at-the-time version)during a future inspection or T1 evaluation at anyof theCCP-managed sites.Joshua Houghton was missing from the CCP-QP-005, Rev.23, Assigned Reading Report; INL-CCP provided evidencethat Mr. Houghton is familiar with Rev. 24 of the sameprocedure.AK-3:Confirm that nonconformances aredocumented appropriately.NCR-RHINL-0215-14NCR-RHINL-0355-14NCR-RHINL-0438-13Example NCRs examined were complete and used theappropriately dated form.CCP-TP-005 ImplementationAK-4:Confirm that Attachment 1, AcceptableKnowledge Documentation Checklist, is complete.ID-HFEF-S5400-RH: CCP-TP-005, Revision 26,Attachment 1, signed by Scott Smith, 5/8/2014Att. 1 provided prior to the inspection was dated June 2011and did not include more recent lot additions. TheAtt. 1provided May 8 included additional references.AK-5:Confirm that Attachment 2, Record ofCommunication, is completed as necessary.N/AEPA did not review any source documents that were orshould have been records of communication.AK-6:Confirm that an Attachment 3, AcceptableKnowledge Source Document Summary, is completeSee reference list in Attachment J to this report All reviewed source documents had an accompanyingAttachment 3.D-11EPA Inspection No.: INL-CC-2014 Remote-Handled WasteInspection Date: May 6–8, 2014Technical ElementsObjective EvidenceCommentsfor every source document.AK-7:Confirm that Attachment 4, AcceptableKnowledge Information List, is complete and up todate.ID-HFEF-S5400-RH: CCP-TP-005, Revision 24,Attachment 4, Signed by Scott Smith, 2/27/2013ID-HFEF-S5400-RH: CCP-TP-005, Revision 26,Attachment 4, Signed by Scott Smith, 5/8/2014The Att. 4 provided prior to the inspection was dated5/7/2014 and did not include all references that are in theback of the AKSR. INL-CCP regenerated Att. 4 on May8,and this version included the missing AKSR references.AK-8:Confirm that Attachment 6, Waste Form,Waste Material Parameters, Prohibited Items, andPackaging, is complete and up to date.N/AThe WMPs for both waste streams have not changed sincethe last time EPA reviewed completion of Att. 6.AK-9:Confirm that Attachment 8, Waste ContainersList, is complete and up to date.ID-ANLE-S5000: CCP-TP-005, Revision 24,Attachment 8, Signed by Scott Smith, 6/4/2013ID-ANLE-S5000: Waste Stream ContainerEvaluation Memorandum, Revision 1, Evaluation ofDrums from Repack of ANL-E High Gamma TRUWaste Containers at INL in Waste Stream IDANLE-S5000, Signed by Scott Smith, 4/22/2013ID-HFEF-S5400-RH: CCP-TP-005, Revision 22,Attachment 8, Signed by Scott Smith, 5/17/2011ID-HFEF-S5400-RH: C4117, C4128ID-ANLE-S5000: EPA limited approval of Lot 2 containersto 51 canisters unless additional notification is provided.INL-CCP has not provided any such notification andexplained that all of the containers added to the wastestream since May 2013 are daughter drums packaged byINL-CCP from some of the 51 canisters approved as Lot 2waste in Waste Stream ID-ANLE-S5000. INL-CCP addsthe daughter containers to Att. 8 as they are generated.ID-HFEF-S5400-RH: The combination of Att. 8 and addcontainer memoranda provides an understanding ofcontainers in the waste stream at the time INL-CCPgenerated C4128. The AKTSS dated 4/3/2014 providesamore recent snapshot of current container status.AK-10:Confirm that Attachment 10, AcceptableKnowledge Re-evaluation Checklist, is completed asnecessary.N/ANone required at this time.AK-11:Confirm that Attachment 11, AcceptableKnowledge Source Document DiscrepancyResolution, is completed as necessary.ID-ANLE-S5000: DR010 Discrepancy resolution is adequately prepared.AK-12:Confirm that Attachment 13, CCP WasteStream Characterization Checklist, is completed foreach characterization lot.ID-ANLE-S5000: CCP-TP-005, Revision 25,Attachment 13, Lot 37, Signed by Laura Nelson(SPM) and Scott Smith (AKE), 7/2/2013ID-ANLE-S5000: CCP-TP-005, Revision 25,Attachment 13, Lot 38, Signed by Laura Nelson(SPM) and Scott Smith (AKE), 8/12/2013ID-ANLE-S5000: CCP-TP-005, Revision 26,Attachment 13, Lot 39, Signed by Laura Nelson(SPM) and Scott Smith (AKE), 9/5/2013Characterization checklists are adequately preparedandnone required AK re-evaluation.D-12EPA Inspection No.: INL-CC-2014 Remote-Handled WasteInspection Date: May 6–8, 2014Technical ElementsObjective EvidenceCommentsID-ANLE-S5000: CCP-TP-005, Revision 26,Attachment 13, Lot 40, Signed by Laura Nelson(SPM) and Scott Smith (AKE), 4/15/2014ID-HFEF-S5400-RH: CCP-TP-005, Revision 26,Attachment 13, Lot 23, Signed by Laura Nelson(SPM) and Scott Smith (AKE), 4/7/2014AK-13:Confirm that Attachment 15, CCP TRUWaste Correlation and Surrogate Summary Form, iscompleted as necessary.N/ANone prepared or required.AK-14:Confirm that the AKSR is complete andaccurately describes the subject waste.CCP-AK-INL-500, Revision 11CCP-AK-INL-580, Revision 4INL-CCP prepared the most recent AKSR revision forbothwaste streams in response to EPA comments during T1change evaluations. The AKSRs include all requestedmodifications.Waste Stream Definition and Waste IdentificationAK-15:Verify that all waste within the waste streamwas generated from a single process/activity.N/AThe waste stream definitions have not changed sinceEPA’slast T1 evaluations. This aspect is reviewed duringevery T1change evaluation.AK-16:Verify that all waste within the waste streamis similar in material and physical form.N/AThe waste stream definitions have not changed sinceEPA’slast T1 evaluations. This aspect is reviewed duringevery T1change evaluation.AK-17:Verify that all waste within the waste streamhas similar radiological properties.N/AThe waste stream definitions have not changed sinceEPA’slast T1 evaluations. This aspect is reviewed duringevery T1change evaluation.AK-18:Verify that waste containers are traceablefrom retrieval through CCP’s EPA-approvedcharacterization process?ID-ANLE-S5000:Drum Nos. ANLE3D-1, ANLE43L and ANLE45ANDE BDR Nos.: INLRHVE13001,INLRHRTR14002DTC BDR Nos. INLRHDTC13010,INLRHDTC14002AKTSSSDs: U552, U4032ID-HFEF-S5400-RH:Drum Nos. B521A, B521B, FC010012-3 andIDAWANL870203CNDE BDR Nos. INLRHRTR10013,INLRHRTR13006, INLRHRTR14003Sealion database printout, IWTS container profiles,wastedisposal requests, and waste can loading logs wereavailableto document the traceability of each container fromoriginalHFEF-5 or sodium loop safety facility cans that weresubsequently placed in carbon steel liners in variousconfigurations. INL-CCP demonstrated traceability throughForm 880 documentation of can contents and placement ofcans into liners as documented on waste packaging logs(Reference U552 for both waste streams), and subsequenttransfer and repackaging of containers into existing drums.D-13EPA Inspection No.: INL-CC-2014 Remote-Handled WasteInspection Date: May 6–8, 2014Technical ElementsObjective EvidenceCommentsDTC BDR Nos. INLRHDTC1006,INLRHDTC10016, INLRHDTC12007,INLRHDTC14003AKTSSSDs: C4117, U552, U992, U484, P848Land Withdrawal Act RequirementsAK-19:Verify that all of the waste in the wastestream is defense in origin.N/AThe waste stream definitions have not changed sinceEPA’slast T1 evaluations. This aspect is reviewed duringevery T1change evaluation.AK-20:Verify that none of the waste in the wastestream is SNF.N/AThe waste stream definitions have not changed sinceEPA’slast T1 evaluations. This aspect is reviewed duringevery T1change evaluation.AK-21:Verify that none of the waste in the wastestream is HLW.N/AThe waste stream definitions have not changed sinceEPA’slast T1 evaluations. This aspect is reviewed duringevery T1change evaluation.Waste Stream CertificationAK-22:Confirm that the certification plan iscomplete and adequately describes the role of AK inthe waste characterization methodology.CCP-AK-INL-582, Revision 4CCP-RC-INL-581, Revision 0CCP-AK-INL-580, Revision 4The certification plan does not agree precisely with theAKSR with regard to the number of canisters in thewastestream. INL-CCP indicated that revision of the certificationplan is ongoing and the noted discrepancies do notalter thedescription of AK’s role in the waste characterizationmethodology as presented in the certification plan.AK-23:Verify that the WSPF is complete andaccurate.N/AWaste characterization activities for these two wastestreams have not required revision of the WSPFs.AK-24:Confirm that a characterization informationsummary is adequately completed for eachcharacterization lot.ID-ANLE-S5000: Lot 37, Revision 1, 7/2/2013; Lot38, 8/12/2013; Lot 39, 9/5/2013ID-HFEF-S5400-RH: Lot 22, Revision 1,7/10/2013; Lot 24, Draft, 3/18/2014CIS are adequately completed.AK-25:Confirm that a characterizationreconciliation report is adequately completed foreach characterization lot.ID-ANLE-S5000: Lot 37, 7/2/2013; Lot 38,8/12/2013; Lot 39, 9/9/2013, Corrected 5/7/2014;Lot 40, 4/15/2014, Corrected 5/7/2014ID-HFEF-S5400-RH: Lot 22, 6/27/2013; Lot 24,Draft provided 4/24/2014ID-ANLE-S5000: INL-CCP revised the Lot 39 and 40 CRRcover pages to use the correct revision of the procedure.The cover page template did not change between Rev.2 andRev. 3; therefore only the revision reference in the upperleft corner needed revision. All of the other pagesof theCRR were completed using the correct procedure revision.ID-HFEF-S5400-RH: The Draft CRR was not complete andD-14EPA Inspection No.: INL-CC-2014 Remote-Handled WasteInspection Date: May 6–8, 2014Technical ElementsObjective EvidenceCommentsprovided for informational purposes only. EPA relayed toINL CCP representatives that the final should reference themost current AKSR that addresses Lot 5C, and correct othertypographical errors.AK-26:Confirm that the AK accuracy reportmemorandum is technically adequate.ID-ANLE-S5000: Revised AK Accuracy Lots 1–36,5/28/2013ID-ANLE-S5000: AK Accuracy Lots 1–40,5/5/2014ID-HFEF-S5400-RH: AK Accuracy, Lots 1–23,5/5/2014AK accuracy reports are technically adequate.See Attachment D.1, AK-14.Data Quality ObjectivesAK-27:Identify how INL-CCP will meet the DQOfor defense waste, HLW and SNF determination.N/AINL-CCP’s plans to meet the DQOs have not changed sinceEPA’s last evaluation of these waste streams.AK-28:Identify how INL-CCP will meet the DQOsfor radioactive properties: TRU waste determination,RH waste determination and activity determination.N/AINL-CCP’s plans to meet the DQOs have not changed sinceEPA’s last evaluation of these waste streams.AK-29:Identify how INL-CCP will meet the DQOsfor physical properties: liquids and physical form.N/AINL-CCP’s plans to meet the DQOs have not changed sinceEPA’s last evaluation of these waste streams.Tier 2 ReportingAK-30:Verify that INL-CCP has reported to EPAcompletion or revision of AKSRs and certificationplans.FY2013 3rdQuarter T2 reportFY2013 4thQuarter T2 reportFY2014 1stQuarter T2 reportFY2014 2ndQuarter T2 reportINL-CCP reported: CCP-AK-INL-645A, Rev. 0, onFY2013 4thQuarter T2 report; CCP-AK-INL-542, Rev. 2,and CCP-AK-INL-582, Rev. 4, on FY2014 1stQuarter T2report; CCP-AK-INL-580, Rev. 4, CCP-AK-INL-590, Rev.4, CCP-AK-INL-592, Rev. 2, CCP-AK-INL-600, Rev. 1and CCP-AK-INL-602, Rev. 2, on FY2014 2ndQuarter T2report.AK-31:Verify that INL-CCP has reported to EPAcompletion or revision of CCP-TP-005, Attachment4s that reflect the updated AKSR Source DocumentReference Lists.FY2013 3rdQuarter T2 reportFY2013 4thQuarter T2 reportFY2014 1stQuarter T2 reportFY2014 2ndQuarter T2 reportINL-CCP revised Att. 4 for Waste Stream ID-HFEF-S5400-RH during this inspection. EPA expects to see the T2notification on the FY2014 3rdQuarter T2 report.AK-32:Verify that INL-CCP has reported to EPAcompletion or revision of the WSPF, includingchange notices, and the associated documentation.FY2013 3rdQuarter T2 reportFY2013 4thQuarter T2 reportFY2014 1stQuarter T2 reportFY2014 2ndQuarter T2 reportINL-CCP did not revise or generate any WSPFs duringtheMay 2013–May 2014 time period.D-15EPA Inspection No.: INL-CC-2014 Remote-Handled WasteInspection Date: May 6–8, 2014Technical ElementsObjective EvidenceCommentsAK-33:Verify that INL-CCP has reported to EPAcompletion or revision of AK accuracy reportsannually, at a minimum.FY2013 3rdQuarter T2 reportFY2013 4thQuarter T2 reportFY2014 1stQuarter T2 reportFY2014 2ndQuarter T2 reportINL-CCP reported AK accuracy report completion forWaste Streams ID-ANLE-S5000 and IN-ID-NRF-153 onthe FY2013 4thQuarter T2 report. EPA expects to see the2014 AK accuracy reports (that were provided duringthisinspection) on the FY2014 3rdQuarter T2 report.AK-34:Verify that INL-CCP has reported to EPAcompletion or revision of DRs and nonconformancereports.FY2013 3rdQuarter T2 reportFY2013 4thQuarter T2 reportFY2014 1stQuarter T2 reportFY2014 2ndQuarter T2 reportINL-CCP did not generate any RH DRs or NCRs relatedtoAK for the examined waste streams during the May 2013–May 2014 time period.AK-35:Verify that INL-CCP has reported to EPAcompletion or revision of AK documentation as aresult of WCPIP revisions (e.g., CRR).N/ACCP did not revise the WCPIP during the May 2013–May2014 time period; therefore, no documents were revised as aresult of WCPIP revision.AK-36:Verify that INL-CCP has reported to EPAcompletion or revision of a CSSF for each of the RHcontainers identified as CH, based on measured doserates that present NDA results for assayedcontainers.N/ACSSF is not applicable to either of the examined wastestreams.AK-37:Verify that INL-CCP has reported to EPAnotification of the intent to add containers to anapproved waste stream.N/AINL-CCP did not add new containers to the waste streamsexamined except those from repackaging previouslyapproved containers and those requiring T1 changeevaluation.AK-38:Verify that INL-CCP has provided to EPA alist of active INL-CCP RH AKEs and SPMs for theprevious quarter.FY2013 3rdQuarter T2 reportFY2013 4thQuarter T2 reportFY2014 1stQuarter T2 reportFY2014 2ndQuarter T2 reportNot reported as required.The INL-CCP SPM said that the requirement (new fromthe2013 continued compliance inspection) just worked its wayinto his work instructions in spring 2014. EPA willlook forthe list of RH AKEs and SPMs in the FY2014 3rdQuarterT2 report.E-1ATTACHMENT E.1: NDA CONTINUED COMPLIANCE INSPECTIONCHECKLIST: WAGSEPA Inspection No.: INL-CC-2014Waste Assay Gamma Spectrometer Inspection Date: May 6–8, 2014TechnicalElementsObjective EvidenceAdditional CommentsGeneralWAGS-1: Confirm the NDA system is theWAGS, its location and number.Located in Building WMF-610 at INL RWMC. The WAGS has no othername or location designations.EPA inspectors found the WAGS to belocated in Building 610, unmoved sincethe previous inspection.WAGS-2: Describe the WAGS.The WAGS utilizes six high-resolution BEGe gamma detectors, a drumturntable and a shielded enclosure. The system hasthee calibrations thatare approved for use by EPA.N/AWAGS-3: Identify the consensus standards thatwere used for the system calibrationASTM C-1030, C-1133, C-1215, E-181.CCP-INL-WAGS-003, Revision 0.As stated in CCP-INL-WAGS-001, Rev.1, CCP-INL-WAGS-08-002, CCP-INLWAGS-003, Rev. 0, and confirmedduring interview with NDA personnel.WAGS-4: Describe the system’s operationalhistory since the baseline approval.The WAGS assay system has been in operation supporting the workperformed by INL-CCP since 4/26/2005. During this time, various QCcriteria have been monitored to verify the continued acceptableperformance of the system.As stated in CCP-INL-WAGS-001, Rev.1, CCP-INL-WAGS-08-002, CCP-INLWAGS-003, Rev. 0, and confirmedduring interview with NDA personnel.WAGS-5: Identify the container types assayed onthe WAGSThe WAGS may assay 55-gallon drums only. Visual inspection confirms no containerslarger than 55-gallons could be assayedby the instrument.WAGS-6: Identify the period of performancerelevant to the WAGS and the number of BDRsand waste containers this system assayed duringthe period.From June 7, 2013, to April 30, 2014, the WAGS assayed 1,378 drumscontained in 114 BDRs. The WAGS can assay a maximumof 17 drumseach day, currently performs14 assays per day on the average.As stated by NDA personnel duringinspection.WAGS-7: Confirm that the WAGS is able toreport quantitative values for the WIPP-trackedradionuclidesDirect Measurements:239Pu,241Am,233U,235U,238U and137Cs.Isotopic Fractions:238Pu,240Pu,241Pu,242Pu by correlation and241Amrelative to Pu.Radionuclides by Scaling:90Sr and234U.CCP-INL-WAGS-003, Revision 0.As stated in CCP-INL-WAGS-001, Rev.1, CCP-INL-WAGS-08-002, CCP-INLWAGS-003, Rev. 0, and confirmed withNDA personnel during inspection.WAGS-8: Confirm the WAGS’s calibration ofrecord.The three calibrations are documented in the following:CCP-INL-WAGS-001, Revision 1 (4/2008).CCP-INL-WAGS-08-002 (no revision 4/2008).CCP-INL-WAGS-003, Revision 0 (5/2011).Confirmed with NDA personnel duringinspection.WAGS-9: Identify the procedures that governthis function and where the results of thesecalculations are documented.CCP-TP-019, Operating Procedure (Revision 6, 4/2013).CCP-TP-010, Calibration Procedure (Revision 4, 3/2011).CCP-TP-009, Data Validation Procedure (Revision 9,2/2013).Purpose of 2013 revisions was to clarify operator responsibilities.These procedures are the most currentrevisions. Copies of each were foundand easily accessible at the WAGSoperator station.E-2EPA Inspection No.: INL-CC-2014Waste Assay Gamma Spectrometer Inspection Date: May 6–8, 2014TechnicalElementsObjective EvidenceAdditional CommentsWAGS-10: Confirm that the methods used toderive the isotopic contribution for unmeasuredradionuclides are MGA and MGA-U.MGA and MGA-U are integral parts of the WAGS operation as shown inCCP-TP-019, Operating Procedure (Revision 6, 4/2013).Confirmed through interviews with INLCCP WAGS personnel duringinspection.WAGS-11: Confirm the WAGS operationalrange with respect to matrix (density) andactivity.~0.010 g to 200 g total Pu (calibration-based and administrative), limitedby LLD and system dead time. Calibration assumes that the matricesconsists of materials that areZ< 15. Waste matrices outside density rangerequire expert review.EPA confirmed this with NDApersonnel. This range is the same aspreviously approved by EPA.Calibration Verification and ConfirmationWAGS-12: Identify the date of the last calibrationverification. Have any others been completed inthe last year?INL-CCP performed the last calibration verificationon April 30, 2014,after replacing the DSA power supply for detector DET2NM. Thecalibration verification is documented in CCP-INL-WAGS-14-003.INL-CCP also performed a calibration verification following replacementof the DSA power supply for detector DET1INT. Thiscalibrationverification is documented in CCP-INL-WAGS-14-001.Confirmed with NDA personnel duringthe inspection. EPA received a copy ofeach calibration verification report. Allverifications evaluated includedadequate documentation of the systemfunctioning properlyWAGS-13: Confirm the pedigree of allradionuclide standards that were used forcalibration confirmation and/or verifications. Listor reference all standards used.Sources are summarized in Table 1 of CCP-INL-WAGS-001, Revision 1,Table 1 of CCP-INL-WAGS-08-002 and Table 3 of CCP-INL-WAGS003. Source certifications are listed in Attachment1 of the respectivedocuments.EPA reviewed all source certificatedfound in CCP-INL-WAGS-001, CCPINL-WAGS-08-002, and CCP-INLWAGS-003, Att. 1. All standards areindependently certified and acceptable touse for the WAGS calibration.WAGS-14: Requirements for accuracy andprecision must be met, as specified inDOE/WIPP-02-3122, Appendix A, Table A-3.2for calibration verifications.The calibration verification results are containedin Section 5 of CCP-INLWAGS-001, Revision 1, Section 5 of CCP-INL-WAGS-08-002 andSection 5 of CCP-INL-WAGS-003. The %R was between 70 and 130 %and the %RSD was less than 14% in all three calibrations.Accuracy and precision criteria were metfor all calibration verifications.WAGS-16: The133Be transmission source has a~10-year half-life. When was the count rate lastreevaluated in the system?INL-CCP installed the sources in January 2009 and evaluated them in July2011 and July 2013. This is documented in CCP-INL-WAGS-13-002.Reevaluation is prompted when the counts start to fall below the boundaryconditions due to the decay of133Ba.Confirmed with NDA personnel duringthe inspection. NDA personnel indicatedthey have no current plans to replace thesource, but it is possible it will need tobe replaced in the next few years.LLDWAGS-17: Confirm that the LLD for the WAGShas been determined.The LLD is documented in Section 6 of CCP-INL-WAGS-001, Revision1, Section 6 of CCP-INL-WAGS-08-002 and Section 5 of CCP-INLWAGS-003, Revision 0. All transmission-corrected LLD results indicatethat the instrument is able to discriminate TRU andNon-TRU wastes at100 nCi/g TAAC, with the exception of241Am in a plastic foam matrixdrum.Confirmed through interviews with INLCCP WAGS personnel duringinspection.E-3EPA Inspection No.: INL-CC-2014Waste Assay Gamma Spectrometer Inspection Date: May 6–8, 2014TechnicalElementsObjective EvidenceAdditional CommentsWAGS-18: Confirm if the WAGS is used todiscriminate TRU/non-TRU wastes at the 100nCi/g criterion and that it has the requiredsensitivity.The WAGS can discriminate TRU and Non-TRU waste forall measuredradionuclides based on the LLDs in Section 6 of CCP-INL-WAGS-001,Revision 1; Section 6 of CCP-INL-WAGS-08-002; and Section 5 of CCPINL-WAGS-003, Revision 0. Exception is241Am, which, if indicated butnot reported in a drum with a density less than 0.44 kg/L, is quantifiedusing higher energy gamma lines (662 and 722 keV).Total nCi/g of each drum is reported inthe BDR associated with the drum. Inseveral instances, EPA found drums inthe BDRs with activity less than 100nCi/g. INL-CCP indicated these drumswill be load managed.WAGS-19: Identify any/all instances where anLLD value for anon-measuredradionuclide isnot provided based on a lack of technicalfeasibility.Because an LLD is a measurement-based parameter, itis not technicallyfeasible to calculate for radionuclides that are not directly measured. Puisotopes238Pu,240Pu and242Pu are not usually directly measured and arederived by ratios to measured239Pu. The reporting threshold for90Sr isbased on the reported137Cs LLD using an activity ratio determined fromAK NDA memoranda. INL-CCP states that it is not technically feasible toprovide an LLD equivalent for234U and that it is derived by an algorithmbased on measured values of235U,238U and238Pu.This is confirmed in section 7 of CCPINL-WAGS-001, Rev. 1, Section 7 ofCCP-INL-WAGS-08-002 and section 6of CCP-INL-WAGS-003, Rev. 0.Quality ControlWAGS-20: All operators have current CCPtraining as verified on LOQI.LOQI provided on 5/7/2014 (dated 5/1/2014) contains11 operators, allwith current training.EPA verified that the operators listed inthe LOQI match those listed in thelogbook. NDA personnel indicated staffhas expanded significantly inanticipation of going to longer shifts toincrease throughput. It is uncertain whenthis will begin.WAGS-21: Confirm the WAGS’s status withrespect to the CBFO NDA PDP and last cycle.The WAGS successfully participated in drum Cycle 20of the CBFO NDAPDP in July 2013. Cycle 21A is scheduled to begin in May 2014.EPA verified the successful participationin the PDP approval letter.WAGS-22: All WAGS data must be reviewedand approved by qualified personnel. Identify thename and function of the individuals performingtechnical review and approval of WAGS BDRs.Preston Abbott, ITR/SME/OJT, 5/2015.Blake Brahears, ITR, 3/2016.Brent Dial, ITR, 10/2015.Mary Carrol, ITR, 7/2015.Sharon Cummings, ITR, 6/2014.Davis W. Crary, ITR/SME/OJT, 7/2014.Jennifer Law, ITR, 3/2016.David Brasier, ITR/SME/OJT/EA, 4/2015.Alan Shumaker, ITR, 3/2016.Laura Walker, ITR, 4/2016.William Williams, ITR, 2/2016.Bob Ceo, EA.Bart Morales, EA.Tim Southwort, EA.Daniel Remmington, EA.All individuals performing the technicalreview are qualified.E-4EPA Inspection No.: INL-CC-2014Waste Assay Gamma Spectrometer Inspection Date: May 6–8, 2014TechnicalElementsObjective EvidenceAdditional CommentsWAGS-23: Identify any system wide NCRswithin the last year.There have been 4 NCRs on the WAGS in the last year:NCR-INL-066-13.NCR-INL-071-13NCR-INL-005-14NCR-INL-112-13Confirmed during interviews with INLCCP personnel during inspection. EPAreceived a copy of each system NCR(excludes container NCRs) and foundthem to adequately document theprocess.TMUWAGS-24: Identify any changes to the methodor details of the TMU calculation since baseline.INL-CCP did not make any changes to the TMU since EPA’s lastinspection.Confirmed during interviews with INLCCP personnel during inspectionWAGS-25: Evaluate the magnitude of the TMUvalues observed in the WAGS BDRs that wereexamined during this inspection.The TMU for the WAGS is documented in CCP-INL-WAGS-002, TotalMeasurement Uncertainty for the WAGS System, datedApril 20, 2005.This document does not have a revision number. Thecomponents ofuncertainty included in the TMU determination consist of calibrationsource uncertainties, counting statistics, self-absorption effects, matrixnonhomogeneities, nonuniform source distributions and isotopicmeasurement uncertainties. The software for TMU calculations isembedded in NDA 2000. CCP-INL-WAGS-002 calls for administrativeprocedures that would define a minimum fill-heightrequirement to reducethe potential for increased uncertainties due to end effects. TMU values inBDRs are generally consistent with expectations.Confirmed during interviews with INLCCP personnel during inspection.Background and Performance ChecksWAGS-26: Confirm that WAGS backgroundmeasurements have been taken daily.Confirm that WAGS background measurements have beentaken daily. EPA confirmed this occurs duringinterviews with NDA personnel. Thelogbook entries selected at random byEPA to review contained evidence ofthese measurements.WAGS-27: Assess how often backgroundradiation was problematic to the extent thatmeasurement personnel had to make adjustments.WAGS operators did not observe any instances of problematicbackgrounds in the last year.EPA confirmed this during interviewswith NDA personnel.WAGS-28: Confirm that system performancechecks have been performed at least once peroperational day. Confirm that performancechecks include gamma and neutron efficiency,matrix correction checks, and gamma peakposition and resolution checks.WAGS operators conduct performance checks once perday as stated inCCP-TP-019, Revision 6.EPA confirmed this occurs duringinterviews with NDA personnel. Thelogbook entries selected at random byEPA to review contained evidence ofthese checks.E-5EPA Inspection No.: INL-CC-2014Waste Assay Gamma Spectrometer Inspection Date: May 6–8, 2014TechnicalElementsObjective EvidenceAdditional CommentsData ManagementWAGS-29: WAGS BDRs contain:•Testing facility name, testing batch number,container numbers, and signature of the SPMor designee•Table of contents•Background and performance check data orcontrol charts for the relevant time period•Separate testing report sheets for eachcontainerEPA reviewed WAGS BDR Nos. INNDAW130104 and INND140033 andfound them to contain appropriate information.N/AWAGS-30: WAGS RDSs must include:•Title “Radioassay Data Sheet”•Method/procedure used•Date of radioassay•Activities and associated TMU for individualradionuclides•TAAC and its associated TMU•Operator and reviewer signaturesEPA reviewed WAGS BDR Nos. INNDAW130104 and INND140033 andfound that each drum contained in the two BDRs hadan RDS containingthe correct elements.N/AE-6ATTACHMENT E.2: NDA CONTINUED COMPLIANCE INSPECTIONCHECKLIST: SGRSEPA Inspection No.: INL-CC-2014Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer Inspection Date: May 6–8, 2014TechnicalElementsObjective EvidenceAdditional CommentsGeneralSGRS-1: Confirm the NDA system is the SGRS,its location and number.Located in Building WMF-610 at INL RWMC. EPA inspectors found the SGRS to belocated in Building 610, unmoved sincethe previous inspection.SGRS-2: Describe the SGRS.The SGRS is a gamma-based system that uses four high-resolution BEGegamma detectors, a turntable, shielded enclosure, and supportingelectronics. The SGRS performs quantitative assaysand corrects thesummed gamma peaks for attenuation using a multi-curve calibration thatcomputes efficiency as a function of waste densityand photon energy. Apluser performs live-time corrections and MGA/MGA-Udetermineisotopics from the same spectra. NDA EA applies default isotopics whenmeasured results are not useable. The four gamma detectors are arrangedvertically and acquire spectra for all segments simultaneously. The systemruns NDA 2000 as well as MGA and MGA-U. The SGRS derives a valuefor242Pu by correlation, and determines90Sr by application of a scalingfactor based on137Cs.234U is quantified based on measured values for235Uand238U.N/ASGRS-3: Identify the consensus standards thatwere used for the system calibration.The consensus standards that are used in the calibration are ASTM C1030, C-1133, C-1215 and E-181.As stated in CCP-INL-SGRS-001, Rev.2, and confirmed during interview withNDA personnel.SGRS-4: Describe the system’s operationalhistory since the last EPA inspection.Since the 2013 EPA inspection, INL-CCP replaced DETA1 and replacedthe steel door bearings because of hinge wear caused by the weight of thedoor. INL-CCP performed calibration verifications following both changes(CCP-INL-SGRS-13-004 and CCP-INL-SGRS-14-001, respectively) anddetermined that a new calibration was not needed ineither case.As stated in CCP-INL-SGRS-001, Rev.2, and confirmed during interview withNDA personnel.SGRS-5: Identify the container types assayed onthe SGRS.The SGRS can only assay 55-gallon drums. Visual inspection confirms no containerslarger than 55-gallons could be assayedby the instrument.SGRS-6: Identify the period of performancerelevant to this application of the SGRS. Sincethis time, identify the number of wastecontainers this system has assayed and thennumber of BDRs assembled.From June 7, 2013, to April 30, 2014, the SGRS assayed 4,095 drumscontained in 155 BDRs. The SGRS can assay a maximumof 36 drumseach day with current operational hours. The SGRS currently assays 32drums per day on average.NDA personnel indicated that additionaloperators and EAs have been addedbecause CCP anticipates adding moreshifts to increase output.E-7EPA Inspection No.: INL-CC-2014Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer Inspection Date: May 6–8, 2014TechnicalElementsObjective EvidenceAdditional CommentsSGRS-7: Confirm that the SGRS is able to reportquantitative values for the WIPP-trackedradionuclidesDirect Measurements:239Pu,241Am,233U,235U,238U and137Cs.Isotopic Fractions:238Pu,240Pu,241Pu,242Pu by correlation and241Amrelative to Pu.Radionuclides by Scaling:90Sr and234U.As stated in CCP-INL-SGRS-001, Rev.2. EPA also confirmed with NDApersonnel during inspection.SGRS-8: Confirm the SGRS’s calibration ofrecord.The calibration of record is documented in CCP-INL-SGRS-001, Revision2. This is the same calibration document that EPA reviewed during themost recent SGRS T1 approval in February 2013.Confirmed with NDA personnel duringinspection.SGRS-9: Identify the procedures that govern thisfunction and where the results of thesecalculations are documented.CCP-TP-115, Operating Procedure (Revision 5.1, 4/2013).CCP-TP-010, Calibration Procedure (Revision 4, 3/2011).CCP-TP-109, Data Validation Procedure (Revision 9,2/2013).2013 revisions clarified operator responsibilities.These procedures are the most currentrevisions. Copies of each were foundand easily accessible at the SGRSoperator station.SGRS-10: Confirm that the methods used toderive the isotopic contribution for unmeasuredradionuclides are MGA and MGA-U.MGA and MGA-U are integral parts of the SGRS operation as shown inCCP-TP-115, Operating Procedure (Revision 6, 4/2013).Interviews with INL-CCP SGRS personnel during inspection.Confirmed through interviews with INLCCP SGRS personnel during inspection.SGRS-11: Where is the actual efficiencycalibration for the SGRS documented?It is documented in CCP-INL-SGRS-001, Revision 2, and its attachments. N/ASGRS-12: Confirm the SGRS operational rangewith respect to matrix (density) and activity.~0.010 g to 200 g total Pu (calibration-based and administrative). Limitedby LLD and system dead time. Calibration assumes that matrices aremainlyZ< 15. Waste matrices outside density range requireexpert review.EPA confirmed with NDA personnel. Itis the same operational range that hasbeen previously approved by EPA.Calibration Verification and ConfirmationSGRS-13: Identify the date of the last calibrationverification. Have any others been completed inthe last year?9/18/2013, following the replacement of DETA1, as described 4, above(CCP-INL-SGRS-13-004).EPA confirmed with NDA personnel.SGRS-14: Confirm the pedigree of allradionuclide standards that were used forcalibration confirmation and/or verifications. Listor reference all standards used.The standards are summarized in Table 1 of CCP-INL-SGRS-001, SGRSCalibration, Confirmation and Verification Report,Revision 2, November14, 2012. Source certifications are listed in Attachment 1 of the samedocument.EPA reviewed all source certificatesfound in CCP-INL-SGRS-001, Att. 1.All standards are independently certifiedand acceptable to use for the SGRScalibration.SGRS-15: Requirements for accuracy andprecision must be met, as specified inDOE/WIPP-02-3122, Appendix A, Table A-3.2for calibration verifications.The calibration verification results are containedin Section 5 of CCP-INLSGRS-003, SGRS Calibration, Confirmation and Verification Report,Revision 2. The %R was between 70 and 130% and the%RSD was lessthan 14%.Accuracy and precision criteria were metfor all calibration verifications.LLDSGRS-16: Confirm that the LLD for the SGRShas been determined.Section 6 of CCP-INL-SGRS-001, Revision 2, documents the LLDdetermination of measured radioisotopes. LLDs for all measuredradionuclides in plastic foam, soft board, particleboard and sand matriceswere below the 100 nCi/g TRU threshold.Interviews with INL-CCP SGRSpersonnel during inspection.E-8EPA Inspection No.: INL-CC-2014Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer Inspection Date: May 6–8, 2014TechnicalElementsObjective EvidenceAdditional CommentsSGRS-17: Confirm if the SGRS is used todiscriminate TRU/non-TRU wastes at the 100nCi/g criterion and that it has the requiredsensitivity.The SGRS can discriminate between TRU and Non-TRU waste based onthe LLDs reported in Section 6 of CCP-INL-SGRS-001,Revision 2, for allmeasured radionuclides.Total nCi/g of each drum is reported inthe BDR associated with the drum. Inseveral instances, EPA found drums inthe BDRs with activity less than 100nCi/g. INL-CCP indicated these drumswill be load managed.SGRS-18: Identify any/all instances where anLLD value for anon-measuredradionuclide isnot provided based on a lack of technicalfeasibility.Because an LLD is a measurement-based parameter, itis not technicallyfeasible to calculate for radionuclides that are not directly measured.Plutonium isotopes238Pu,240Pu and242Pu are not usually directly measuredand are derived by ratios to measured239Pu. The reporting threshold for90Sr is based on the reported137Cs LLD using an activity ratio determinedfrom AK-NDA memoranda. INL-CCP states that it is not technicallyfeasible to provide an LLD equivalent for234U and it is derived by analgorithm based on the measured values of235U and238U.This is confirmed in section 7 of CCPINL-SGRS-001, Rev. 2.Quality ControlSGRS-19: All operators have current CCPtraining as verified on LOQILOQI provided on May 7, 2014 (dated May 1, 2014), contains 11operators, all with current training.EPA verified that the operators listed inthe LOQI match those listed in thelogbook.SGRS-20: Confirm the SGRS’s status withrespect to the CBFO NDA PDP and last cycle.The SGRS successfully participated in Cycle 20 withan approval datedJuly 10, 2013. Cycle 21A is scheduled to begin in MayEPA verified the successful participationin the PDP letter.SGRS-21: All SGRS data must be reviewed andapproved by qualified personnel. Identify thename and function of the individuals performingtechnical review and approval of SGRS BDRs.Preston Abbott, ITR/SME/OJT, 5/2015.Blake Brahears, ITR, 3/2016.Brent Dial, ITR, 10/2015.Mary Carrol, ITR, 7/2015.Sharon Cummings, ITR, 6/2014.Davis W. Crary, ITR/SME/OJT, 7/2014.Jennifer Law, ITR, 3/2016.David Brasier, ITR/SME/OJT/EA, 4/2015.Alan Shumaker, ITR, 3/2016.Laura Walker, ITR, 4/2016.William Williams, ITR, 2/2016.Bob Ceo, EA.Bart Morales, EA.Tim Southwort, EA.Daniel Remmington, EA.All individuals performing the technicalreview are qualified.E-9EPA Inspection No.: INL-CC-2014Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer Inspection Date: May 6–8, 2014TechnicalElementsObjective EvidenceAdditional CommentsSGRS-22: Identify any hardware and/or softwarechanges made to the SGRS since the baselineapproval. Determine which changes, if any, aresignificant, where they are documented, and howthey affect the SGRS’s baseline approval.INL-CCP replaced the steel door hinge bearings on the SGRS on March11, 2014. It required replacement due to the weightof the door beingsupported. After the replacement, INL-CCP performeda calibrationverification and documented it in CCP-INL-SGRS-14-001.Additionally, INL-CCP replaced detector DETA1 on September 9, 2013.Following a prolonged site power outage (8/26-9/4/2013), INL-CCP foundthe detector to be not functioning correctly. Following the replacement,INL-CCP performed calibration verification and documented it in CCPINL-SGRS-13-004.Confirmed during interviews with INLCCP personnel during inspection. EPAexamined the logbook pages surroundingboth changes and found them toadequately document the replacementand subsequent calibration verifications.SGRS-23: Identify any NCRs within the lastyear.There have been 4 NCRs on the SGRS in the last year:NCR-INL-0067-13NCR-INL-0068-13NCR-INL-0083-13NCR-INL-0102-13Confirmed during interviews with INLCCP personnel during inspection. EPAreviewed a copy of each NCR andcorresponding logbook pages. Based onthis review, EPA found the NCRs to beproperly documented.TMUSGRS-24: Identify any changes to the method ordetails of the TMU calculation since baseline.INL-CCP did not make any changes to the TMU since EPA’s lastinspection.Confirmed during interviews with INLCCP personnel during inspection.SGRS-25: Evaluate the magnitude of the TMUvalues observed in the SGRS BDRs that wereexamined during this inspection.INL-CCP documents TMU for the SGRS in CCP-INL-SGRS-002, April21, 2005; this document does not have a revision number. The componentsof uncertainty included in the TMU determination are: calibration sourceuncertainties, counting statistics, self-absorptioneffects, matrixnonhomogeneities, nonuniform source distributions and isotopicmeasurement uncertainties. The software for TMU calculations isembedded in NDA 2000. CCP-INL-SGRS-002 calls for “administrativeprocedures” that would define a minimum fill-heightrequirement toreduce the potential for increased uncertainties due to end effects.Addressing this is left to the EA, who “should assess those assays for thepotential end effects uncertainties and add the appropriate uncertaintyamounts to the TMU, where applicable.” TMU values in BDRs aregenerally consistent with expectations based on CCP-INL-SGRS-002.Confirmed during interviews with INLCCP personnel during inspection.Background and Performance ChecksSGRS-26: Confirm that SGRS backgroundmeasurements have been taken daily.All records evaluated indicate compliant backgroundperformance. EPA confirmed this occurs duringinterviews with NDA personnel. Thelogbook entries selected at random byEPA to review contained evidence ofthese measurements.E-10EPA Inspection No.: INL-CC-2014Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer Inspection Date: May 6–8, 2014TechnicalElementsObjective EvidenceAdditional CommentsSGRS-27: Assess how often backgroundradiation was problematic to the extent thatmeasurement personnel had to make adjustments.SGRS operators have not observed any instances of problematicbackgrounds. Between the SGRS and the outside wallof Building 610 is alayer of lead sheeting designed to reduce background from material beingmoved outside of the building. This layer has beenin place since beforeEPA’s last inspection.EPA confirmed background checksoccur daily, but have not been a problemduring interviews with NDA personnel.SGRS-28: Confirm that system performancechecks have been performed at least once peroperational day. Confirm that performancechecks include gamma and neutron efficiency,matrix correction checks, and gamma peakposition and resolution checks.SGRS operators conduct performance checks once perday as stated inCCP-TP-115, Revision 5.EPA confirmed this occurs duringinterviews with NDA personnel. Thelogbook entries selected at random byEPA to review contained evidence ofthese checks.Data ManagementSGRS-29: SGRS BDRs contain:•Testing facility name, testing batch number,container numbers, and signature of the SPMor designee•Table of contents•Background and performance check data orcontrol charts for the relevant time period•Data validation per the QAPD and siteprocedures•Separate testing report sheets for eachcontainerEPA reviewed SGRS BDR Nos. INNDAS130099 and INNDAS140043and found them to contain appropriate information.N/ASGRS-30: SGRS RDSs must include:•Title “Radioassay Data Sheet”•Method/procedure used•Date of radioassay•Activities and associated TMU for individualradionuclides•TAAC and its associated TMU•Operator and reviewer signaturesEPA reviewed SGRS BDR Nos. INNDAS130099 and INNDAS140043and found that each drum contained in the two BDRshad an RDScontaining the correct elements.N/AF-1ATTACHMENT F.1: REPLICATE TESTING DATA FOR DRUM SRP21732 – WAGSInstrument: WAGSDrum: SRP21732Quantity of InterestOriginal Measurement Replicate #1 Replicate #2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci) 2.13E-051.28E-056.01E-012.18E-051.31E-056.01E-012.14E-051.29E-056.03E-01238U Activity (Ci) 1.31E-054.42E-063.37E-011.36E-054.60E-063.38E-011.38E-054.65E-063.37E-01238Pu Activity (Ci) 2.00E-041.02E-045.10E-011.89E-049.63E-055.10E-012.01E-041.02E-045.07E-01239Pu Activity (Ci) 7.31E-032.47E-033.38E-016.89E-032.33E-033.38E-017.33E-032.47E-033.37E-01240Pu Activity (Ci) 1.62E-035.66E-043.49E-011.53E-035.34E-043.49E-011.63E-035.67E-043.48E-01242Pu Activity (Ci) 2.13E-071.31E-076.15E-012.01E-071.23E-076.12E-012.13E-071.31E-076.15E-01241Am Activity (Ci) 8.41E-032.86E-033.40E-018.73E-033.61E-034.14E-018.53E-033.53E-034.14E-0190Sr Activity (Ci)N/AN/AN/A137Cs Activity (Ci)N/AN/AN/ATAAC (nCi/g) 1.19E+022.60E+012.18E-011.18E+022.94E+012.49E-011.20E+022.96E+012.47E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci) 2.20E-051.32E-056.00E-012.11E-051.27E-056.02E-012.19E-051.32E-056.03E-01238U Activity (Ci) 1.34E-054.51E-063.37E-011.26E-054.25E-063.37E-011.54E-055.18E-063.36E-01238Pu Activity (Ci) 1.87E-049.53E-055.10E-011.91E-049.72E-055.09E-011.97E-041.00E-045.08E-01239Pu Activity (Ci) 6.83E-032.31E-033.38E-016.97E-032.35E-033.37E-017.19E-032.43E-033.38E-01240Pu Activity (Ci) 1.52E-035.29E-043.48E-011.55E-045.38E-053.47E-011.60E-035.57E-043.48E-01242Pu Activity (Ci) 1.99E-071.22E-076.13E-012.03E-071.24E-076.11E-012.10E-071.28E-076.10E-01241Am Activity (Ci) 8.60E-032.86E-033.33E-018.73E-032.91E-033.33E-018.56E-033.54E-034.14E-0190Sr Activity (Ci)N/AN/AN/A137Cs Activity (Ci)N/AN/AN/ATAAC (nCi/g) 1.17E+022.53E+012.16E-011.19E+022.57E+012.16E-011.19E+022.94E+012.47E-01F-2Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|c2|)ReportedValueAbsoluteUncertainty233U Activity (Ci) 0.00E+00 N/AN/A N/A N/AN/A N/A234U Activity (Ci) 2.13E-05 1.28E-052.16E-05 3.78E-07 1.75E-023.49E-03 1.00E+00238U Activity (Ci) 1.31E-05 4.42E-061.38E-05 1.02E-06 7.44E-022.15E-01 9.95E-01238Pu Activity (Ci) 2.00E-04 1.02E-041.93E-04 5.83E-06 3.02E-021.31E-02 1.00E+00239Pu Activity (Ci) 7.31E-03 2.47E-037.04E-03 2.11E-04 3.00E-022.92E-02 1.00E+00240Pu Activity (Ci) 1.62E-03 5.66E-041.29E-03 6.35E-04 4.93E-015.03E+00 2.85E-01242Pu Activity (Ci) 2.13E-07 1.31E-072.05E-07 6.02E-09 2.93E-028.44E-03 1.00E+00241Am Activity (Ci) 8.41E-03 2.86E-038.63E-03 9.46E-05 1.10E-024.38E-03 1.00E+0090Sr Activity (Ci) 0.00E+00 N/AN/A N/A N/AN/A N/A137Cs Activity (Ci) 0.00E+00 N/AN/A N/A N/AN/A N/ATAAC (nCi/g) 1.19E+02 2.60E+011.19E+02 1.14E+00 9.61E-037.69E-03 1.00E+00Quantity of InteresttPr(x<|t|)χ2TesttTest233U Activity (Ci)N/A N/ANot Applicable Not Applicable234U Activity (Ci) -8.21E-01 4.58E-01Not Significant Not Significant238U Activity (Ci) -5.89E-01 5.88E-01Not Significant Not Significant238Pu Activity (Ci) 1.10E+00 3.35E-01Not Significant Not Significant239Pu Activity (Ci) 1.16E+00 3.11E-01Not Significant Not Significant240Pu Activity (Ci) 4.79E-01 6.57E-01Not Significant Not Significant242Pu Activity (Ci) 1.18E+00 3.02E-01Not Significant Not Significant241Am Activity (Ci) -2.12E+00 1.01E-01Not Significant Not Significant90Sr Activity (Ci) N/A N/ANot Applicable Not Applicable137Cs Activity (Ci) N/A N/ANot Applicable Not ApplicableTAAC (nCi/g) 3.20E-01 7.65E-01Not Significant Not SignificantF-3ATTACHMENT F.2: REPLICATE TESTING DATA FOR DRUM SRP21773– WAGSInstrument: WAGSDrum: SRP21773Quantity of InterestOriginal Measurement Replicate #1 Replicate #2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci) 1.58E-059.23E-065.84E-011.46E-058.51E-065.83E-011.56E-059.10E-065.83E-01238U Activity (Ci) 1.79E-055.49E-063.07E-011.77E-055.43E-063.07E-011.90E-055.81E-063.06E-01238Pu Activity (Ci) 8.35E-045.53E-046.62E-013.26E-041.59E-044.88E-016.38E-042.04E-043.20E-01239Pu Activity (Ci) 1.21E-023.69E-033.05E-011.19E-023.64E-033.06E-011.18E-023.60E-033.05E-01240Pu Activity (Ci) 2.22E-038.07E-043.64E-012.65E-038.39E-043.17E-012.28E-039.99E-044.38E-01242Pu Activity (Ci) 4.98E-071.70E-073.41E-013.47E-072.07E-075.97E-017.32E-072.99E-074.08E-01241Am Activity (Ci) 2.07E-026.30E-033.04E-012.03E-026.16E-033.03E-012.08E-028.10E-033.89E-0190Sr Activity (Ci)N/AN/AN/A137Cs Activity (Ci)N/AN/AN/ATAAC (nCi/g) 3.01E+026.19E+012.06E-012.96E+026.05E+012.04E-012.98E+027.50E+012.52E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci) 1.54E-059.00E-065.84E-011.54E-058.99E-065.84E-011.50E-058.78E-065.85E-01238U Activity (Ci) 2.03E-056.21E-063.06E-011.79E-055.47E-063.06E-011.97E-056.01E-063.05E-01238Pu Activity (Ci) 3.38E-041.65E-044.88E-013.21E-041.57E-044.89E-013.37E-041.65E-044.90E-01239Pu Activity (Ci) 1.23E-023.79E-033.08E-011.17E-023.61E-033.09E-011.23E-023.78E-033.07E-01240Pu Activity (Ci) 2.74E-038.74E-043.19E-012.60E-038.32E-043.20E-012.73E-038.72E-043.19E-01242Pu Activity (Ci) 3.59E-072.14E-075.96E-013.41E-072.04E-075.98E-013.58E-072.14E-075.98E-01241Am Activity (Ci) 2.01E-027.86E-033.91E-012.11E-028.23E-033.90E-011.99E-027.75E-033.89E-0190Sr Activity (Ci)N/AN/AN/A137Cs Activity (Ci)N/AN/AN/ATAAC (nCi/g) 2.98E+027.38E+012.48E-013.00E+027.58E+012.53E-012.96E+027.29E+012.46E-01F-4Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|c2|)ReportedValueAbsoluteUncertainty233U Activity (Ci) 0.00E+00 N/AN/A N/A N/AN/A N/A234U Activity (Ci) 1.58E-05 9.23E-061.52E-05 4.00E-07 2.63E-027.51E-03 1.00E+00238U Activity (Ci) 1.79E-05 5.49E-061.89E-05 1.12E-06 5.94E-021.67E-01 9.97E-01238Pu Activity (Ci) 8.35E-04 5.53E-043.92E-04 1.38E-04 3.51E-012.48E-01 9.93E-01239Pu Activity (Ci) 1.21E-02 3.69E-031.20E-02 2.83E-04 2.36E-022.35E-02 1.00E+00240Pu Activity (Ci) 2.22E-03 8.07E-042.60E-03 1.88E-04 7.23E-022.17E-01 9.95E-01242Pu Activity (Ci) 4.98E-07 1.70E-074.27E-07 1.70E-07 3.99E-014.02E+00 4.03E-01241Am Activity (Ci) 2.07E-02 6.30E-032.04E-02 4.98E-04 2.44E-022.50E-02 1.00E+0090Sr Activity (Ci) 0.00E+00 N/AN/A N/A N/AN/A N/A137Cs Activity (Ci) 0.00E+00 N/AN/A N/A N/AN/A N/ATAAC (nCi/g) 3.01E+02 6.19E+012.98E+02 1.67E+00 5.62E-032.92E-03 1.00E+00Quantity of InteresttPr(x<|t|)χ2TesttTest233U Activity (Ci)N/A N/ANot Applicable Not Applicable234U Activity (Ci) 1.37E+00 2.43E-01Not Significant Not Significant238U Activity (Ci) -8.29E-01 4.54E-01Not Significant Not Significant238Pu Activity (Ci) 2.94E+00 4.25E-02Not SignificantSignificant239Pu Activity (Ci) 3.23E-01 7.63E-01Not Significant Not Significant240Pu Activity (Ci) -1.85E+00 1.39E-01Not Significant Not Significant242Pu Activity (Ci) 3.78E-01 7.25E-01Not Significant Not Significant241Am Activity (Ci) 4.77E-01 6.59E-01Not Significant Not Significant90Sr Activity (Ci) N/A N/ANot Applicable Not Applicable137Cs Activity (Ci) N/A N/ANot Applicable Not ApplicableTAAC (nCi/g) 1.85E+00 1.37E-01Not Significant Not SignificantF-5ATTACHMENT F.3: REPLICATE TESTING DATA FOR DRUM SRP18745– WAGSInstrument: WAGSDrum: SRP18745Quantity of InterestOriginal Measurement Replicate #1 Replicate #2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci) 9.60E-075.59E-075.82E-011.06E-066.18E-075.83E-011.02E-065.94E-075.82E-01238U Activity (Ci)N/AN/AN/A238Pu Activity (Ci) 3.87E-043.00E-047.75E-013.49E-042.67E-047.65E-015.10E-043.21E-046.29E-01239Pu Activity (Ci) 1.47E-024.46E-033.03E-011.36E-024.10E-033.02E-011.45E-024.39E-033.03E-01240Pu Activity (Ci) 2.61E-038.37E-043.21E-012.89E-039.10E-043.15E-012.92E-039.28E-043.18E-01242Pu Activity (Ci) 1.85E-076.62E-083.58E-012.06E-077.15E-083.47E-012.11E-077.42E-083.52E-01241Am Activity (Ci) 1.26E-033.83E-043.04E-011.24E-033.75E-043.02E-011.23E-033.74E-043.04E-0190Sr Activity (Ci)N/AN/AN/A137Cs Activity (Ci)N/AN/AN/ATAAC (nCi/g) 1.94E+024.68E+012.41E-011.85E+024.34E+012.35E-011.97E+024.65E+012.36E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci) 1.04E-066.05E-075.82E-011.13E-066.61E-075.85E-011.18E-066.89E-075.84E-01238U Activity (Ci)N/AN/AN/A238Pu Activity (Ci) 1.10E-034.35E-043.95E-016.70E-043.51E-045.24E-013.08E-042.53E-048.21E-01239Pu Activity (Ci) 1.38E-024.17E-033.02E-011.37E-024.15E-033.03E-011.32E-024.03E-033.05E-01240Pu Activity (Ci) 3.50E-031.11E-033.17E-012.49E-038.00E-043.21E-012.36E-037.59E-043.22E-01242Pu Activity (Ci) 2.63E-079.13E-083.47E-011.77E-076.33E-083.58E-011.65E-075.91E-083.58E-01241Am Activity (Ci) 1.22E-033.70E-043.04E-011.14E-033.48E-043.05E-011.14E-033.48E-043.05E-0190Sr Activity (Ci)N/AN/AN/A137Cs Activity (Ci)N/AN/AN/ATAAC (nCi/g) 2.01E+024.47E+012.22E-011.85E+024.36E+012.36E-011.75E+024.23E+012.42E-01F-6Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|c2|)ReportedValueAbsoluteUncertainty233U Activity (Ci) 0.00E+00 N/AN/A N/A N/AN/A N/A234U Activity (Ci) 9.60E-07 5.59E-071.09E-06 6.69E-08 6.16E-025.73E-02 1.00E+00238U Activity (Ci) 0.00E+00 N/AN/A N/A N/AN/A N/A238Pu Activity (Ci) 3.87E-04 3.00E-045.87E-04 3.20E-04 5.45E-014.56E+00 3.35E-01239Pu Activity (Ci) 1.47E-02 4.46E-031.38E-02 4.72E-04 3.43E-024.48E-02 1.00E+00240Pu Activity (Ci) 2.61E-03 8.37E-042.83E-03 4.46E-04 1.58E-011.14E+00 8.88E-01242Pu Activity (Ci) 1.85E-07 6.62E-082.04E-07 3.80E-08 1.86E-011.32E+00 8.58E-01241Am Activity (Ci) 1.26E-03 3.83E-041.19E-03 4.98E-05 4.17E-026.77E-02 9.99E-0190Sr Activity (Ci) 0.00E+00 N/AN/A N/A N/AN/A N/A137Cs Activity (Ci) 0.00E+00 N/AN/A N/A N/AN/A N/ATAAC (nCi/g) 1.94E+02 4.68E+011.89E+02 1.04E+01 5.53E-021.99E-01 9.95E-01Quantity of InteresttPr(x<|t|)χ2TesttTest233U Activity (Ci)N/A N/ANot Applicable Not Applicable234U Activity (Ci) -1.72E+00 1.61E-01Not Significant Not Significant238U Activity (Ci) N/A N/ANot Applicable Not Applicable238Pu Activity (Ci) -5.71E-01 5.99E-01Not Significant Not Significant239Pu Activity (Ci) 1.82E+00 1.43E-01Not Significant Not Significant240Pu Activity (Ci) -4.54E-01 6.73E-01Not Significant Not Significant242Pu Activity (Ci) -4.66E-01 6.66E-01Not Significant Not Significant241Am Activity (Ci) 1.21E+00 2.93E-01Not Significant Not Significant90Sr Activity (Ci) N/A N/ANot Applicable Not Applicable137Cs Activity (Ci) N/A N/ANot Applicable Not ApplicableTAAC (nCi/g) 4.73E-01 6.61E-01Not Significant Not Significant

# G-1



# ATTACHMENT G: DOSE-TO-CURIE CONTINUED COMPLIANCE IN SPECTION

CHECKLIST

EPA Inspectors Present: Rose Gogliotti and Ed Feltcorn

Location of DTC: DTC occurs in Room 306 and observed by operators in Room 302

Location of Waste Storage: EDR Room 418

CCP-TP-504 Revision: Revision 15, April 16, 2014

Operators and Training Renewal Due:

Lashall Adade DTC Operator/ITR due 6/2015

Sway Andrews DTC Operator/ITR due 5/2015

Mary Carroll DTC Operator/ITR due 4/2016

OSPREY Operator/ITR due 8/2014

Chris Davis DTC Operator/ITR due 4/2016

Crary Davis DTC Operator/ITR due 9/2014

OSPREY Operator/ITR due 10/2014

Brent Dial DTC Operator/ITR due 4/2016

OSPREY Operator/ITR due 4/2016

Spencer Pattee DTC Operator/ITR due 1/2016

Dave Pinnock DTC Operator/ITR due 8/2015

EPA reviewed the logbook pages and found that all o perators listed in the logbook have

current training in LOQI dated May 1, 2014

Scale No: 724422 Same as previously observed by EPA

Scale Calibration Due Date: June 18, 2014

Instrument No: 020555 with option to use 02558 (Thermo Geiger Muel ler)

Instrument Calibration Due Date: NA

Probe No.: XC060674 with option to also use Probe No: XC060675

Probe Calibration/Due Date: January 27, 2015

Probe Range: low range: 10 μR/hr–800 mR/h; high range: 800 mR/hr –1,000 R/hr

DSC Source No: Both high and low range 137 

# Cs source INL-ID: CP-TCS001 (Manufacturer

Serial # 181-64)

Source Activity: 744.9 Ci

Reference Date: May 1, 2010

Operator Aide(s) Used: RH-DM-INL-003, Revision 2, November 29, 2012

RH-DM-INL-002, Revision 19, May 6, 2014

Copies of both operator aids were posted in the DTC Control Area. EPA received copies of

both forms.

BDR No: Not yet assigned number. INL-CCP will provide BDR t o EPA when it is

finalized.

Packaging Configuration: 55-gallon drum

# G-2



# Container No: FC0108C-1B

Container Gross Wt: 56.2 kg

BKG: 0.013 mR/h

Dose Rate @ 0 o 

# : 162 mR/h

Dose Rate @ 90 o 

# : 165 mR/h

Dose Rate @ 180 o 

# : 187 mR/h

Dose Rate @ 270 o 

# : 206 mR/h

Highest measured Dose Rate >3 x BKG: Yes

Dose Rate Average: 180 mR/h

Estimated Contact Dose Rate: >200 mR/hH-1ATTACHMENT H: REAL-TIME RADIOGRAPHY CONTINUED COMPLIANCE INSPECTION CHECKLIST: RH WASTEEPA Inspection No.: INL-CC-2014RH Real-Time Radiography Inspection Date: May 6–8,2014Establishment of Required Technical Elements inProceduresExecution of ProceduresObjective EvidenceRTR-1: Site procedures identify required training andqualifications for RTR personnel.CCP-TP-028, Revision 8.CCP-QP-002, Revision 36.RTR operators receive training on the WMPs andtypical packaging configurations expected in eachwaste stream.To become qualified, the RTR operator must pass acomprehensive written test based on trainingobjectives with a minimum score of 80%.Unsatisfactory performance – failed to identifyprohibited item during OJT of score of less than80% on exam.Demonstrate capability (At initial qualification,requalification, and semiannually, successfullyexamine atrainingcontainer).At initial qualification, and subsequent requalification, successfully examine atestdrum.RTR operators re-qualified every 2 years based oncontinued satisfactory performance.EPA reviewed the Qualification Cards and other trainingrecords for RH RTR personnel. These records includedtraining DVDs and evaluation sheets for operators andlead operators. EPA determined that the training recordswere complete and demonstrated that qualified operatorswere performing the RH RTR examinations.Objective evidence:1.Qualification Cards for selected RTR personnel2.Training DVDs for various RTR personnel3.Practical demonstration summary for RH INL RTRpersonnel4.LOQIs for VE and RTR operators5.A list of RH INL RTR personnel training containersand inventory sheets6.Training Container Evaluation Data Sheets forvarious RTR operators7.Inventory sheets for RTR training containers NDETRAINING-25, NDE-TRAINING-26, NDETRAINING-1, NDE-TRAINING-25, NDETRAINING-33RTR-2: Site procedures provide complete instructionsfor operators to perform the RTR examination andcompletion of the associated documentation.CCP-TP-053, Revision 9, section 4.0.RTR operator adequately explained the processfollowed for examining a drum and entering datainto data forms (whether hard copy or electronicdata entry is used).EPA observed the RTR examination of containerFCO108C in building 659. The operator identified thewaste items contained within the drum and recordedthese data on an electronic data form.Objective evidence:1.LOQIs for VE and RTR operators.2.Data sheets for demonstration drum FCO108C.3.BDR Nos. INLRHRTR14002 andINLRHRTR14003.4.Audio/visual recordings and written records forBDR Nos. INLRHRTR14002 andINLRHRTR14003.H-2EPA Inspection No.: INL-CC-2014RH Real-Time Radiography Inspection Date: May 6–8,2014Establishment of Required Technical Elements inProceduresExecution of ProceduresObjective EvidenceRTR-3: The RTR procedures require an image qualitycheck to be performed.CCP-TP-053, Revision 14, section 4.2, Attachment 1.Operator adequately explained how theacceptability of an image is determined.Image quality check is performed once per day(RTR Measurement Control Report).Performance of the image quality check isdocumented and recorded.The operator manipulated the container image to identifythe contents of the drum and to check for prohibiteditems. At the time of the demonstration, the operator hadalready completed the necessary equipment checks priorto examining any containers. EPA reviewed BDRs toverify that image quality checks were performed prior tocontainer examinations.Objective evidence:1.Data sheets for demonstration drum FCO108C.2.BDR Nos. INLRHRTR14002 andINLRHRTR14003.3.Audio/visual recordings and written records forBDR Nos. INLRHRTR14002 andINLRHRTR14003.RTR-4: The procedure allows the operator to adjustthe RTR to accommodate the physical properties ofthe waste and waste containers likely to beencountered at the site.CCP-TP-508, Revision 9, section 4.3.Operator could identify applicable policies andprocedures governing the operation of RTRequipment.The RTR system could be adjusted.High-density material was examined with the Xray device set on the maximum voltage and lowdensity material at a lower voltage.Operator adequately explained what is done if animage is unacceptable (e.g., the waste is solidifiedor the container is lead-lined).EPA observed the RTR examination of containerFCO108C. The operator had performed the requiredimage quality check prior to EPA’s arrival.The operator rotated the drum to facilitate identificationof waste items and changed the kV settings on the unit toaccommodate materials of different densities. Theoperator entered waste items into an electronic data sheetas they were identified. The operator “rocked” thedrumto check for the presence of liquids. The operatorverifiedthe Waste Stream Description and WMC and the absenceof any prohibited items. The operator generated anaudio/visual recording of the examination.The operator used procedure CCP-TP-508 to guide theexamination and had a copy of the applicable AKSRavailable for reference. The operator was able to explainthe NCR process used if a prohibited item was identified.Objective evidence:1.Audio/visual recordings and written records forBDR Nos. INLRHRTR14002 andINLRHRTR14003.2.Written record for demonstration drum FCO108C.3.Operator Qualification Card and training records.4.LOQI for RH RTR personnel.H-3EPA Inspection No.: INL-CC-2014RH Real-Time Radiography Inspection Date: May 6–8,2014Establishment of Required Technical Elements inProceduresExecution of ProceduresObjective EvidenceRTR-5: Data records are of sufficiently high qualityfor complete review.CCP-TP-508, Revision 9, section 4.3, Attachments 1and 2.RTR tape is high quality, the sound track isaudible, and the required information is containedon the audible portion of the tape.The RTR tape is consistent with the data packagefor the same drum.EPA reviewed two BDRs to verify that audio/visualrecordings were of sufficient quality to allow foradetailed review. EPA also verified that the audio/visualand written records were consistent.Objective evidence:1.Audio/visual recordings and written records forBDR Nos. INLRHRTR14002 andINLRHRTR14003.RTR-6: There is a procedure for determining whetherthe waste matches the waste stream description andWaste Matrix Code, and for determining WasteMaterial Parameters and weights.CCP-TP-508, Revision 9, Table 2, Attachment 2.The procedure is adequately implemented.Operators verify that the waste matches the wastestream description.WMC is verified. If not, corrective action is taken.WMP weights are estimated by compiling aninventory of waste items and residual/packagingmaterials.Does the RTR operator use a standard weightlookup table to provide an estimate of WMPweights? If so, has the table been updated to reflectadditional information gained through previousRTR/VE exams or updated AK information?Objective evidence:1.Audio/visual recordings and written records forBDR Nos. INLRHRTR14002 andINLRHRTR14003.2.Written record for demonstration drum FCO108C.3.Operator Qualification Card and training records.4.LOQI for RH RTR personnel.RTR-7: The RTR procedure provides instructions foridentifying prohibited items and for processing drumscontaining prohibited items.CCP-TP-508, Revision 9, Table 1, Attachment 2.Operator could name prohibited items.Operator adequately explained how the presence ofprohibited liquids is determined.Operator’s explanation of required actions ifprohibited items were encountered was consistentwith procedure.The operator used procedure CCP-TP-508 to guideperformance of the RTR demonstration. Table 1 of theprocedure describes prohibited items. During thedemonstration, the operator “rocked” the drum tofacilitate identification of liquids within the drum andstated that an NCR would be initiated if any prohibiteditems were located.Objective evidence:1.Audio/visual recordings and written records forBDR Nos. INLRHRTR14002 andINLRHRTR14003.2.Written record for demonstration drum FCO108C.RTR-8: RTR procedures include the required QCexaminations, evaluation accuracy and reproducibilityof the RTR process.An independent replicate scan is performed on onewaste container per day or on one container pertesting batch (whichever is less frequent).An independent observation of one scan (not theEPA reviewed two BDRs to verify that QC examinationswere performed on a batch basis. Both BDRs includedanIndependent Observation and Replicate scan which hadbeen performed and recorded in the proper manner and inH-4EPA Inspection No.: INL-CC-2014RH Real-Time Radiography Inspection Date: May 6–8,2014Establishment of Required Technical Elements inProceduresExecution of ProceduresObjective EvidenceCCP-TP-508, Revision 9, sections 4.4 and 4.5. replicate) is performed, by a qualified RTRoperator (anyone but the initial RTR operator).accordance with procedure CCP-TP-508.Objective evidence:1.Audio/visual recordings and written records forBDR Nos. INLRHRTR14002 andINLRHRTR14003RTR-9: Procedures contain standardized forms forrecording RTR data.CCP-TP-508, Revision 09, Attachment 2.RTR operator adequately explained the processfollowed for examining a drum and entering datainto data forms (whether hard copy or electronicdata entry is used).Direct data entry into an electronic form is done bythe RTR operator using a computer while theoperator is still in the RTR booth.The electronic data file undergoes the same QCchecks used for hand-written data entries.The operator performed the demonstration drumexamination in accordance with procedure CCP-TP-508and entered data into an electronic data sheet as the wasteitems were identified.Objective evidence:1.Audio/visual recordings and written records forBDR Nos. INLRHRTR14002 andINLRHRTR14003.2.Data sheets for demonstration drum FCO108C.RTR-10: Site procedures require review of BDRs atthe data generation and project level.CCP-TP-508, Revision 9, section 4.9, Attachments 3and 4.Data generation level reviews are performed anddocumented (ITR).Project level reviews are performed anddocumented (SPM).An ITR and an SPM had reviewed the two EPAreviewed BDRs as required by procedure CCP-TP-508.Objective evidence:1.Audio/visual recordings and written records forBDR Nos. INLRHRTR14002 andINLRHRTR14003.I-1ATTACHMENT I.1: VISUAL EXAMINATION CONTINUED COMPLIANCE INSPECTION CHECKLIST: CH WASTEEPA Inspection No.: INL-CC-2014CH Visual Examination Inspection Date: May 6–8, 2014Establishment of Required Technical Elements inProceduresExecution of ProceduresObjective EvidenceCHVE-1: Site procedures identify required trainingand qualifications for CH VE personnel.CCP-QP-002, Revision 36.Formal training elements include: projectrequirements, container identification and labeling,applicable state andfederalregulations.Site-specific training program:OJT,identification of summary category groups, WMPs,packaging configurations, residual liquids.EPA reviewed the Qualification Cards for selected VEOsand VEEs and determined that they were trained inaccordance with CCP procedures. The Qualification Cardswere complete and available for review. The operatorsinterviewed were able to answer all questions posedby EPAand were knowledgeable regarding the contents of the wastestream being processed.Objective Evidence:1.Qualification cards for selected VE operators and VEEs.2.Appointment emails for various VEEs, dated 3/1/2007,8/31/2009 and 12/10/20133.LOQIs for VE operators and VE SME/OJT Experts.CHVE-2: Operator qualification and re-qualificationrequirements are described.CCP-QP-002, Revision 36, section 4.3.6.To become qualified, the CH VE operator must passa comprehensive written test with an 80 percent orbetter grade that addresses VE operations,documentation, characterization, formal trainingelements, and procedural elements.VE Operators must demonstrate capability in thepresence of the site VEE during OJT. However, theformal and OJT training is conducted by a qualifiedSME.Objective Evidence:1.Qualification cards for selected VE operators and VEEs.2.Appointment emails for various VEEs, dated 3/1/2007,8/31/2009 and 12/10/20133.LOQIs for VE operators and VE SME/OJT Experts.CHVE-3: Each site has a designated VEE.CCP-QP-002, Revision 36, section 4.4.CCP-PO-001, QAPP, Revision 21.CCP-TP-006, Revision 18, section 3.1.VEE designation is documented.VEE has knowledge of the CH TRU waste beingcharacterized.Responsible for overall direction andimplementation of VE at the facility.Certification Planspecifies the selection,qualification, and training requirements of VEE.EPA reviewed the appointment emails for some VEEs.Theprocess used at INL-CCP for CH VE is that the VEE mustbe actually present at each examination to guide and directthe processes implemented. There are three qualified VEEsfor this process at INL-CCP.Objective Evidence:1.Appointment emails for various VEEs, dated 3/1/2007,8/31/2009 and 12/10/20132.LOQIs for VE operators and VE SME/OJT Experts.CHVE-4: Procedures and technical guidancedocuments provide complete instructions forperforming VE.CCP-TP-006, Revision 18.Verify container is empty.Empty container is weighed.100% of containers will be subject to VE at the timeof packaging.The EPA Inspectors observed the VE of S3000 waste fromWaste Stream ID-SRP-3000 (CCP-AK-INL-026) inBuilding 1617, ARP-V. The waste was delivered to the ARPand operators sorted and identified different wasteitems.After estimating WMPs and recording these data, thewasteI-2EPA Inspection No.: INL-CC-2014CH Visual Examination Inspection Date: May 6–8, 2014Establishment of Required Technical Elements inProceduresExecution of ProceduresObjective EvidenceWaste Stream Description and WMC verified.Presence/absence of prohibited items confirmed.Two operators used even if audio/visual recordingof VE is generated.A VE form is used to document results ofexamination, WMC and estimated WMP weights.Prohibited items segregated and documented.was loaded into 55-gallon drums. The VE operators andVEE present were trained and qualified in accordance withCCP procedures. CCP-TP-006 was used to guide the processand data were recorded on the applicable electronicdatasheets from this procedure.Operators verified the Waste Stream Description andWMCand the absence of any prohibited items. The operatorsdescribed the processes used if prohibited items areidentified in the waste but could not recall a specificinstance of this occurring.Two operators perform the VE with the assistance ofa VEE.Containers SRP23093 and SRP23106, from BDR No. INSRP-VE-000737, were used to repackage the sludge afterthe VE observed by EPA. EPA reviewed the data sheets forthese containers and determined that they were complete andproperly processed. Both operators and the VEE are requiredto sign the data sheets after completion of operations.EPA reviewed BDR Nos. INL-ARP-VE-002942, INL-ARPVE-002943, INL-SRP-VE-000496, INL-SRP-VE-000699and INL-SRP-VE-000700 and verified that VE data weregenerated and recorded in accordance with procedureCCPTP-006.Objective Evidence:1.Qualification cards for selected VE operators and VEEs.2.Appointment emails for various VEEs, dated 3/1/2007,8/31/2009 and 12/10/2013.3.LOQIs for VE operators and VE SME/OJT Experts.4.Data sheets for containers SRP23093 and SRP23106.5.VE BDR Nos. INL-ARP-VE-002942, INL-ARP-VE002943, INL-SRP-VE-000496 and INL-SRP-VE000699, INL-SRP-VE-000700.CHVE-5: Corrective actions are taken whennecessary.CCP-TP-006, Revision 18, section 2.4.2.Operators were able to describe how they initiate acorrective action.Operators could not recall the last time an NCR wasinitiatedfor this waste stream, but were able to describe how theprocess is implemented. No NCRs had been initiatedforcontainers in the BDRs reviewed.Objective Evidence:1.Qualification cards for selected VE operators and VEEs.I-3EPA Inspection No.: INL-CC-2014CH Visual Examination Inspection Date: May 6–8, 2014Establishment of Required Technical Elements inProceduresExecution of ProceduresObjective Evidence2.Appointment emails for various VEEs, dated 3/1/2007,8/31/2009 and 12/10/2013.3.LOQIs for VE operators and VE SME/OJT Experts.4.Data sheets for containers SRP23093 and SRP23106.5.VE BDR Nos. INL-ARP-VE-002942, INL-ARP-VE002943, INL-SRP-VE-000496, INL-SRP-VE-000699and INL-SRP-VE-000700.CHVE-6: Site procedures require data generation andproject level reviews of BDRs.CCP-TP-006, Revision 18, Attachments 2–4.ITR review Attachment 2.SPM review Attachment 3.The EPA Inspectors reviewed selected BDRs to ensurethatthe requisite reviews were performed and recorded.EPAdetermined that the reviews were performed in accordancewith the applicable CCP procedures.Objective Evidence:1.VE BDR No. INL-ARP-VE-002942, INL-ARP-VE002943, INL-SRP-VE-000496, INL-SRP-VE-000699and INL-SRP-VE-000700.CHVE-7: Records are available for review.CCP-TP-006, Revision 18, section 5.0.Lifetime/QA records – Attachments 1–5, Copy ofNCRs.QA/nonpermanent records – VHS tape or DVD(primary and backup).CH VE is performed at INL-CCP by two VE operators andis not recorded by audio/visual equipment.CCP personnel were able to provide all records requested byEPA for review.Objective Evidence:1.VE BDR No. INL-ARP-VE-002942, INL-ARP-VE002943, INL-SRP-VE-000496, INL-SRP-VE-000699and INL-SRP-VE-000700.2.Qualification cards for selected VE operators and VEEs.3.Appointment emails for various VEEs, dated 3/1/2007,8/31/2009 and 12/10/2013.4.LOQIs for VE operators and VE SME/OJT Experts.5.Data sheets for containers SRP23093 and SRP23106.6.VE BDR Nos. INL-ARP-VE-002942, INL-ARP-VE002943, INL-SRP-VE-000496, INL-SRP-VE-000699and INL-SRP-VE-000700.I-4ATTACHMENT I.1: VISUAL EXAMINATION CONTINUED COMPLIANCE INSPECTION CHECKLIST: RH WASTEEPA Inspection No.: INL-CC-2014RH Visual Examination Inspection Date: May 6–8, 2014Establishment of Required Technical Elements inProceduresExecution of ProceduresObjective EvidenceRHVE-1: Site procedures identify required trainingand qualifications for RH VE personnel.CCP-QP-002, Revision 36.Formal training elements include: projectrequirements, container identification and labeling,applicable state andfederalregulations.Site-specific training program:OJT,identification of summary category groups, WMPs,packaging configurations, residual liquids.EPA reviewed the Qualification Cards for selected VEOs andVEEs and determined that they were trained in accordancewith CCP procedures. The Qualification Cards werecomplete and available for review. The operators interviewedwere able to answer all questions posed by EPA andwereknowledgeable regarding the contents of the waste streambeing processed.Objective Evidence:1.Qualification cards for selected VE operators and VEEs.2.Appointment emails for various VEEs, dated 3/1/2007,8/31/2009 and 12/10/2013.3.LOQIs for VE operators and VE SME/OJT Experts.RHVE-2: Operator qualification and re-qualificationrequirements are described.CCP-QP-002, Revision 36, section 4.3.2.To become qualified, the operator must pass acomprehensive written test with an 80 percent orbetter grade that addresses VE operations,documentation, characterization, formal trainingelements, and procedural elements.VE Operators must demonstrate capability in thepresence of the site VEE during OJT. However, theformal and OJT training is conducted by a qualifiedSME.EPA reviewed the Qualification Cards for selected VEOs andVEEs and determined that they were trained in accordancewith CCP procedures. The Qualification Cards werecomplete and available for review. The operators interviewedwere able to answer all questions from EPA and wereknowledgeable regarding the contents of the waste streambeing processed. The operators were able to describe howprohibited items are identified, processed, and recorded.Objective Evidence:1.Qualification cards for selected VE operators and VEEs.2.Appointment emails for various VEEs, dated 3/1/2007,8/31/2009 and 12/10/2013.3.LOQIs for VE operators and VE SME/OJT Experts.RHVE-3: Each site has a designated VEE.CCP-QP-002, Revision 36, section 4.4.1.CCP-PO-001, QAPP, Revision 21.VEE designation is documented.VEE has knowledge of the RH TRU waste beingcharacterized.Responsible for overall direction andimplementation of VE at the facility.Certification Planspecifies the selection,qualification, and training requirements of VEE.EPA reviewed the appointment emails for some VEEs.VEEswere qualified and trained in accordance with CCPprocedures and training records were available forreview.Objective Evidence:1.Appointment emails for various VEEs, dated March 1,2007, August 31, 2009 and December 10, 20132.LOQIs for VE operators and VE SME/OJT Experts.RHVE-4: Procedures and technical guidancedocuments provide complete instructions for100% of containers will be subject to VE at the timeof packaging.INL-CCP had scheduled to provide EPA with a practicaldemonstration of the RH VE process during the on-siteI-5EPA Inspection No.: INL-CC-2014RH Visual Examination Inspection Date: May 6–8, 2014Establishment of Required Technical Elements inProceduresExecution of ProceduresObjective Evidenceperforming VE.CCP-TP-500, Revision 13, sections 4.1 and 4.2,Attachment 1.Waste Stream Description and WMC verified.Presence/absence of prohibited items confirmed.Two operators used even if audio/visual recordingof VE is generated.inspection. However, due to a broken manipulator arm, thisdemonstration could not take place. The EPA Inspectorsinterviewed two VEOs and one VEE in lieu of thisdemonstration. The RH VE personnel interviewed wereknowledgeable, experienced operators and were abletoprovide EPA with answers to all questions asked bytheinspectors. INL-CCP had performed very little RH VEduring the past year and were only able to provideone BDRfor review. The BDR was complete and properly reviewed.Two operators had signed the data sheets as required byprocedure CCP-TP-500.Objective Evidence:1.LOQIs for VE operators and VE SME/OJT Experts.2.BDR No. INLRHVE13001.RHVE-5: Corrective actions are taken whennecessary.CCP-TP-500, Revision 13, section 2.4.2.Operators were able to describe how they initiate acorrective action.RH VE personnel interviewed by EPA were able to explainhow they would initiate an NCR if necessary. No NCRs hadbeen initiated for the one BDR reviewed by EPA.Objective Evidence:1.Qualification Cards for selected RH VE personnel.2.LOQIs for VE operators and VE SME/OJT Experts.3.BDR No. INLRHVE13001.RHVE-6: Site procedures require data generation andproject level reviews of BDRs.CCP-TP-500, Revision 13.ITR review Attachment 2.SPM review Attachment 3.BDR No. INLRHVE13001 had been reviewed at the datageneration level by an ITR and at the project levelby anSPM.Objective evidence:1.BDR No. INLRHVE13001.RHVE-7: Records are available for review.CCP-TP-500, Revision 13, section 5.0.Lifetime/QA records – Attachments 1–5, Copy ofNCRs.QA/nonpermanent records – VHS tape or DVD(primary and backup).INL-CCP was able to provide EPA all requested records anddocuments.Objective Evidence:1.Qualification cards for selected VE operators and VEEs.2.Appointment emails for various VEEs, dated 3/1/2007,8/31/2009 and 12/10/2013.3.LOQIs for VE operators and VE SME/OJT Experts.4.BDR No. INLRHVE13001.RHVE-8: Quality assurance objectives are definedand met.Data Accuracy:194.22, b, (1) the degree to which data agree withData Accuracy & Comparability:Qualification and requalification records for VE operatorsI-6EPA Inspection No.: INL-CC-2014RH Visual Examination Inspection Date: May 6–8, 2014Establishment of Required Technical Elements inProceduresExecution of ProceduresObjective Evidence40 CFR Part 194.22(b)an acceptable reference or true value.WCPIP: maintained by requiring operators to passa comprehensive test with a score of 80% anddemonstrated satisfactory performance for initialqualification and re-qualification.Data Precision:194.22, b, (2) a measure of the mutual agreementbetween comparable data gathered or developedunder similar conditions expressed in terms of astandard deviation.WCPIP: – maintained by reconciling anydiscrepancies between 2 operators (or operator andITR) with regard to physical form of waste, absenceof residual liquid.Data Representativeness194.22, b, (3) the degree to which data accuratelyand precisely represent a characteristic of apopulation, a parameter, variations at a samplingpoint, or environmental conditions.WCPIP: Contents placed in a container will bedescribed on the data forms.Data Completeness194.22, b, (4) a measure of the amount of valid dataobtained compared to the amount that was expected.WCPIP: Relevant waste information must becollected and documented on a videotape and/ordata form or other unalterable media.Data Comparability194.22, b, (5) a measure of the confidence withwhich one data set can be compared to another.WCPIP: ensured by site meeting trainingrequirements and complying with the minimumstandards used to implement VE.demonstrate that operators pass a comprehensive writtenexamination as required by the WCPIP and CCP trainingprocedure CCP-QP-002.Data Precision:Two operators perform VE and concur with entries made intothe data forms. This is evidenced by the operator signatures.Data Representativeness & Completeness:EPA determined that all waste items are recorded ondataforms. EPA verified this by review of one BDR.Objective evidence:1.BDR No. INLRHVE13001.2.Qualification Cards and other training records forselected VE operators.

# J-1



# ATTACHMENT J: LIST OF DOCUMENTS REVIEWED FOR THIS I NSPECTION

AK

Common to multiple waste streams:

AKE Qualification Card for Carrie Johnson, June 16, 2011

AKE Qualification Card for Kevin Peters, June 16, 2 011

AKE Qualification Card for Scott Smith, June 22, 20 11

AKE Qualification Card for Steve Schafer, June 16, 2011

AKE-01, Acceptable Knowledge Expert (AKE) Qualifica tion Card, Sample Form, Revision 10,

November 8, 2013

Assigned Reading Report, CCP-QP-002, Revision 36, p rovided April 24, 2014

Assigned Reading Report, CCP-QP-005, Revision 23, p rovided April 24, 2014

Assigned Reading Report, CCP-QP-005, Revision 24, J oshua Houghton, provided May 8, 2014

Assigned Reading Report, CCP-TP-002, Revision 26, p rovided April 24, 2014

Assigned Reading Report, CCP-TP-005, Revision 26, p rovided April 24, 2014

Assigned Reading Report, CCP-TP-506, Revision 4, pr ovided May 6, 2014

CH INL-CCP AK Tracking Spreadsheet, April 18, 2014

DOE WIPP-02-3214 (WCPIP), Revision 3, Assigned Read ing Report, provided April 24, 2014

Fiscal Year 2013 3rd Quarter T2 report, provided Ju ly 22, 2013

Fiscal Year 2013 4th Quarter T2 report, provided No vember 19, 2013

Fiscal Year 2014 1st Quarter T2 report, provided Ja nuary 22, 2014

Fiscal Year 2014 2nd Quarter T2 report, provided Ma y 1, 2014

Lists of fully characterized containers for Waste S treams ID-RF-S5300-A, ID-RF-S3114 and IDSDA-SOIL, provided April 26, 2013

RH INL-CCP AK Tracking Spreadsheet, April 3, 2014

SPM CH Qualification Card for Adela Cantu, November 4, 2002

SPM CH Qualification Card for Andrew Stallings, Aug ust 27, 2012

SPM CH Qualification Card for Barbara Broomfield, N ovember 2, 2004

SPM CH Qualification Card for Beverly Schrock, June 23, 2010, Revised February 5, 2014

SPM CH Qualification Card for Brandye Pyeatt, Augus t 27, 2012

SPM CH Qualification Card for Carolina Soaterna, Ma y 31, 2011

SPM CH Qualification Card for Charles Turner, April 19, 2007, Revised May 6, 2014

SPM CH Qualification Card for Daniel Wade, October 23, 2013

SPM CH Qualification Card for David Moody, June 24, 2005, Revised May 6, 2014

# J-2



# SPM CH Qualification Card for Jake Knox, October 23 , 2013

SPM CH Qualification Card for Jerry Fisher, October 31, 2013

SPM CH Qualification Card for Jim Vernon, June 11, 2009

SPM CH Qualification Card for Jimmy D. Eastham, May 12, 2009

SPM CH Qualification Card for Joshua Houghton, May 31, 2011

SPM CH Qualification Card for Laura Nelson, June 21 , 2010

SPM CH Qualification Card for Mike Ramirez, May 26, 2009, Revised May 6, 2014

SPM CH Qualification Card for Rich Kantrowitz, May 2, 2006, Revised May 6, 2014

SPM CH Qualification Card for Rick Whiteley, Octobe r 31, 2013

SPM CH Qualification Card for Roger Whiteaker, May 3, 2012

SPM CH Qualification Card for Veronica Waldram, Aug ust 4, 2009

SPM RH Qualification Card for Charles Turner, Augus t 15, 2013

SPM RH Qualification Card for David Moody, August 2 8, 2013

SPM RH Qualification Card for Irene Joo (Quintana), September 17, 2009

SPM RH Qualification Card for Joshua Houghton, Augu st 19, 2013

SPM RH Qualification Card for Laura Nelson, June 21 , 2010

SPM RH Qualification Card for Rich Kantrowitz, Octo ber 29, 2012

SRP spreadsheet tracking weekly input, by source dr um, to the SRP repackaging process,

provided May 7, 2014

WP 15-GM1002, Revision 2, Assigned Reading Acknowle dgement Report, provided May 6,

2014

CH AK

ID-SRP-S3000

C154, Interview Record of W.V. Conner by T. Widner and J. Lamb, August 13, 1991

C159, Interview Record of R. Hoffman by D. Herrick and J. Lamb, September 4, 1991

C170, Telecon between AI Morgan of Rocky Flats (ret ired) and Jeff Harrison, February 17, 1997

C171, Telecon between Bill Connor of Kaiser-Hill LA TO and Jeff Harrison, February 13, 1997

C701, Memorandum to CCP Records: Waste Stream Volum e Estimate for ID-SRP-S3000, SRP

Combined Sludge Waste, Scott Smith, October 30, 201 3

C702, Defense Waste Streams Generated at Rocky Flat s Environmental Technology Site

(RFETS) George E. Dials, May 20, 1987

CCP-AK-INL-026, Central Characterization Program Ac ceptable Knowledge Summary Report

for Idaho National Laboratory Sludge Repackage Proj ect Combined Sludge Waste, Waste

Stream: ID-SRP-S3000, Revision 0, November 18, 2013

# J-3



# CCP-TP-002, Revision 26, CCP Reconciliation of DQOs and Reporting Characterization Data,

Attachment 2 – CCP Waste Stream Profile Form (Examp le), ID-SRP-S3000, Revision 0,

February 13, 2014

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste

Containers List, ID-SRP-S3000, January 24, 2014

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 1 –

Acceptable Knowledge Documentation Checklist, ID-SR P-S3000, February 5, 2014

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 4 –

Acceptable Knowledge Source Document Information Li st, ID-SRP-S3000, May 8, 2014

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP

Waste Stream Characterization Checklist – Example F orm, ID-SRP-S3000, Lots 1–23, dated

February 21, 2014, through March 28, 2014

Characterization Information Summary, WSPF No. ID-S RP-S3000, Revision 0, Lot 2, February

21, 2014

Characterization Information Summary, WSPF No. ID-S RP-S3000, Revision 0, Lot 12, March 3,

2014

Characterization Information Summary, WSPF No. ID-S RP-S3000, Revision 0, Lot 23, March

28, 2014

DR701, Acceptable Knowledge Source Document Discrep ancy Report, Scott Smith, DR701,

October 30, 2013

Memorandum from Scott Smith to CCP Records, Evaluat ion of Additional Containers for Sludge

Repackage Project (SRP) Waste Stream ID-SRP-S3000, November 18, 2013

NCR No. NCR-INL-0007-014

NCR No. NCR-INL-0300-014

NDA BDR Nos. INNDAS140017, INNDAS140051 and INNDAW1 40037

P004, Rocky Flats Plant Waste Management Site Plan, December 1987

P053, (Tasks 3&4 Final Draft Report) Reconstruction of Historical Rocky Flats Operations and

Identification of Release Points, August 1992

P507, Acceptable Knowledge Document for INEEL Store d Transuranic Waste – Rocky Flats

Plant Waste, INEL-96/0280, Revision 3, February 28, 2003

P513, Determination of Radioisotopic Content in TRU Waste based on Acceptable Knowledge,

BNFL Inc., BNFL-5232-RPT- TRUW-07, Revision 5, Dece mber 16, 2004

P539, Acceptable Knowledge Document for INL Stored Transuranic Waste -Rocky Flats Plant,

AMWTP, RPT-TRU-56, Revision 3, August 19, 2010

P542, SRP DPS Waste Packaging, Idaho Completion Pro ject, TPR-7866, Draft, not dated

P543, SRP RA V Waste Processing, Idaho Completion P roject, TPR-7867, not dated

P544, WMF-1617 SPR-Support Systems, Idaho Completio n Project, TPR-7418-5, Revision 6

LFU V1, September 20, 2012

# J-4



# P545, RWMC Waste Handling and Overpacking, Idaho Co mpletion Project, TPR-7601,

Revision 45, Draft, not dated

P546, Risk-Based Disposal Approval Application for Management of Polychlorinated Biphenyl

(PCB) Remediation Waste Contaminated with Transuran ic Radioisotopes at the Idaho Cleanup

Project (ICP) Accelerated Retrieval Project V (ARP V) Facility, Idaho Cleanup Project,

September 2012

P702, Waste Stream Summary for BNINW216, AMWTP, RPT -TRUW-09, Revision 9, March

27, 2013

P713, Hazardous Waste Constituents of INEL Contact- Handled Stored Transuranic Waste, D.E.

Kudera, RWMC-369, May 19, 1989

P714, Chemical Constituents in Transuranic Storage Area (TSA) Waste, C.K. Abbott, EDF-803,

Revision 7, December 16, 2002

P722, Excavation Plan for the Accelerated Retrieval Project (WMF-1617) -Pit 9 Retrieval Area

(ARP V), Idaho Cleanup Project, EDF-9751, Revision 0, June 4, 2010

P723, Removal Action Plan for the Accelerated Retri eval Project for a Described Area within Pit

4, Idaho Cleanup Project, DOE/NE-ID-11178, Revision 2, August 2006

P724, Excerpt from the HWMA/RCRA Permit, October 18 , 2012

VE BDR Nos. IN-SRP-VE-000501, IN-SRP-VE-000529 and IN-SRP-VE-000649

ID-RF-S3114

CCP-TP-005, Revision 23, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste

Containers List, ID-RF-S3114, April 22, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP

Waste Stream Characterization Checklist – Example F orm, ID-RF-S3114, Lot 102, May 2, 2013

CCP-TP-005, Revision 25, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP

Waste Stream Characterization Checklist – Example F orm, ID-RF-S3114, Lot 128, August 9,

2013

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP

Waste Stream Characterization Checklist – Example F orm, ID-RF-S3114, Lot 183, March 10,

2014

Characterization Information Summary, WSPF No. ID-R F-S3114, Revision 1, Lot 104, May 13,

2013

Characterization Information Summary, WSPF No. ID-R F-S3114, Revision 1, Lot 115, June 26,

2013

Characterization Information Summary, WSPF No. ID-R F-S3114, Revision 1, Lot 138, October

3, 2013

Characterization Information Summary, WSPF No. ID-R F-S3114, Revision 1, Lot 183, March

10, 2014

# J-5



# Inter-Office Correspondence from R.P. Kantrowitz to W.F. Verlanic, Acceptable Knowledge

Accuracy Report: Idaho National Laboratory Waste St ream Number ID-RF-S3114 Revision 1

(CCP-AK-INL-005), Organic Setups, Lots 101–183, Cum ulative for Lots 1–183, May 29, 2014

NCR No. NCR-INL-0097-013

NCR No. NCR-INL-0293-014

NCR No. NCR-INL-0294-014

NDA BDR Nos. ASY11-00880 and INNDAS120025

NDE BDR Nos. IN-SRP-VE-000496 and RTR11-00141

ID-SDA-SLUDGE, -SOIL, -DEBRIS

NCR No. NCR-INL-0343-013, Waste Stream ID-SDA-SLUDG E

CCP-AK-INL-001, Central Characterization Program Ac ceptable Knowledge Summary Report

for Waste Retrieved from Designated Areas within th e Subsurface Disposal Area at the Idaho

National Laboratory, Transuranic Waste Streams ID-S DA-DEBRIS, ID-SDA-SLUDGE and IDSDA-SOIL, Revision 12, August 2, 2013

NDA BDR Nos. INNDAS120034, INNDAS130054 and INNDAS1 30055

VE BDR Nos. IN-ARP-VE-002731, IN-ARP-VE-002735, IN- ARP-VE-002769 and IN-ARPVE-002793

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 6 – Waste

Form, Waste Material Parameters, Prohibited Items, and Packaging, ID-SDA-SOIL, May 8,

2014

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 6 – Waste

Form, Waste Material Parameters, Prohibited Items, and Packaging, ID-SDA-SLUDGE, May 8,

2014

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 6 – Waste

Form, Waste Material Parameters, Prohibited Items, and Packaging, ID-SDA-DEBRIS, May 8,

2014

Waste Material Parameter Analysis Memorandum, CCP-A K-INL-001, May 8, 2014

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 4 –

Acceptable Knowledge Source Document Information Li st, ID-SDA-SOIL, May 31, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 4 –

Acceptable Knowledge Source Document Information Li st, ID-SDA-SLUDGE, May 31, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 4 –

Acceptable Knowledge Source Document Information Li st, ID-SDA-DEBRIS, May 31, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 7 –

Radionuclides, ID-SDA-SOIL, May 15, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 7 –

Radionuclides, ID-SDA-SLUDGE, May 15, 2013

# J-6



# CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 7 –

Radionuclides, ID-SDA-DEBRIS, May 15, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP

Waste Stream Characterization Checklist – Example F orm, ID-SDA-SLUDGE, Lot 334, June

12, 2013

Inter-Office Correspondence from S. Castro to W.F. Verlanic, Acceptable Knowledge Accuracy

Report: Idaho National Laboratory Waste Stream Numb er ID-SDA-SLUDGE, Homogeneous

Solids from the Subsurface Disposal Area, Lots 314– 333, Cumulative for Lots 1–333, June 13,

2013

Inter-Office Correspondence from J.A. Vernon to W.F . Verlanic, Acceptable Knowledge

Accuracy Report: Idaho National Laboratory Waste St ream Number ID-SDA-DEBRIS,

Heterogeneous Debris from the Subsurface Disposal A rea, Lots 60–62, Cumulative for Lots 11–

62, May 20, 2013

Memorandum from Carrie Johnson to CCP Records, Eval uation of the Radiological

Characterization of Waste Streams ID-SDA-SLUDGE, ID A-SDA-SOIL and ID-SDA-DEBRIS,

CCP-AK-INL-001 NDA Memo, June 6, 2013

ID-AECHHM, –AECHDM

AE-I-201, Radiological Properties Worksheets, not d ated

AE-P-095, Waste Operations Operating Manual, ANL-E Waste Management Operations,

Revision 1, August 2, 1999

AMWTP Offsite Waste Stream Profile, AECHDM-PK, Apri l 1, 2013

C3002, Evaluation of Waste Material Parameter Weigh ts for Waste Streams AECHDM-PK and

AECHHM-PK, Kevin Peters, March 23, 2011

C3003, Interview and Follow-up Correspondence with Robert Schulten: Packaging of Waste

Streams AECHDM-PK and AECHHM-PK, Kevin Peters, May 25, 2010

C3004, Default Plutonium Distributions in Waste Str eams ID-AECHDM and ID-AECHHM,

John West, October 25, 2011

C4004, CBFO Discrete Radiological Source Notificati on and Approval, D. Dietzel, June 11,

2012

C4005, Review of Non-Certified NDA Data for Prevale nt Radionuclides in Waste Streams

AECHDM-PK and AECHHM-PK, Steve Schafer, December 12 , 2012

CCP-AK-INL-025, Central Characterization Program Ac ceptable Knowledge Summary Report

for Idaho National Laboratory Argonne Contact-Handl ed Transuranic Waste from Facility

Maintenance and Laboratory Operations, Waste Stream s: ID-AECHDM and ID-AECHHM,

Revision 2, July 9, 2013

CCP-TP-002, Revision 23, CCP Reconciliation of DQOs and Reporting Characterization Data,

Attachment 2 – CCP Waste Stream Profile Form (Examp le), ID-AECHDM, Revision 0,

December 7, 2011

# J-7



# CCP-TP-002, Revision 26, CCP Reconciliation of DQOs and Reporting Characterization Data,

Attachment 2 – CCP Waste Stream Profile Form (Examp le), ID-AECHHM, Revision 1, January

23, 2014

CCP-TP-005, Revision 23, CCP Acceptable Knowledge D ocumentation, Attachment 7 –

Radionuclides, ID-AECHDM, October 14, 2011, Draft r evision provided May 7, 2014

CCP-TP-005, Revision 23, CCP Acceptable Knowledge D ocumentation, Attachment 7 –

Radionuclides, ID-AECHHM, October 14, 2011, Draft r evision provided May 7, 2014

CCP-TP-005, Revision 23, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste

Containers List, ID-AECHDM, September 29, 2011

CCP-TP-005, Revision 23, CCP Acceptable Knowledge D ocumentation, Attachment 6 – Waste

Form, Waste Material Parameters, Prohibited Items, and Packaging, ID-AECHHM, September

29, 2011

CCP-TP-005, Revision 23, CCP Acceptable Knowledge D ocumentation, Attachment 6 – Waste

Form, Waste Material Parameters, Prohibited Items, and Packaging, ID-AECHDM, September

29, 2011

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 1 –

Acceptable Knowledge Documentation Checklist, ID-AE CHHM, May 31, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 1 –

Acceptable Knowledge Documentation Checklist, ID-AE CHDM, May 31, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste

Containers List, ID-AECHDM, May 31, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 4 –

Acceptable Knowledge Source Document Information Li st, ID-AECHHM, May 31, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 4 –

Acceptable Knowledge Source Document Information Li st, ID-AECHDM, May 31, 2013

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP

Waste Stream Characterization Checklist – Example F orm, ID-AECHDM, Lot 4, October 21,

2013

Characterization Information Summary, WSPF No. ID-A ECHDM, Revision 0, Lot 4, October

21, 2013

Container travelers from AMWTP to INL-CCP for Drum Nos. RW49567 and RW88680

DR3002, CCP Discrepancy Resolution: Resolution of D iscrepancies Associated with the

Assignment of Containers RW48078 and RW48190 to Was te Stream AECHDM-PK, K. Peters,

DR3002, June 20, 2011

DR3004, Resolution of Discrepancies Associated with Beryllium Oxide in Container RW48190,

K.J. Peters, DR3004, November 4, 2011

Inter-Office Correspondence from R.P. Kantrowitz to W.F. Verlanic, Acceptable Knowledge

Accuracy Report: Idaho National Laboratory Waste St ream Number ID-AECHDM, (CCP-AKINL-025), Heterogeneous Debris Waste from Facility Maintenance and Laboratory Operations,

Lot 4, Cumulative for Lots 1–4, May 29, 2014

# J-8



# Memorandum from Kevin Peters to CCP Records, Waste Stream Container Evaluation

Memorandum re: Addition of 38 Containers to Waste S tream AECHDM-PK and ID-AECHDM,

January 16, 2013, Draft revision provided May 7, 20 14

Memorandum from Steve Schafer to CCP Records, Radio logical Evaluation of Argonne CH

TRU Debris Waste from Facility Maintenance and Labo ratory Operations: Waste Stream IDAECHDM, NDA Memo Waste Stream ID-AECHDM (CCP-AK-INL -025), Revision 1, August

13, 2013

Memorandum from Steve Schafer to CCP Records, Radio logical Evaluation of Argonne CH

TRU Homogeneous Waste from Facility Maintenance and Laboratory Operations: Waste Stream

ID-AECHHM, NDA Memo Waste Stream ID-AECHHM (CCP-AK- INL-025), Revision 0,

October 27, 2011

NCR No. NCR-INL-0351-013, Waste Stream ID-AECHDM

NDA BDR Nos. INNDAW120021 and INNDAW120025

P3001, Packaging CH-TRU Waste for Shipment to Idaho National Laboratory (INL) and Final

Disposition at the Waste Isolation Pilot Plant (WIP P), WMO, WMO-DOC-6, Revision 0,

December 9, 2009

P3002, Solidification and Packaging CH-TRU Liquid W aste for Shipment to Idaho National

Laboratory (INL) and Final Disposition at the Waste Isolation Pilot Plant (WIPP); Bulking Tub

Neutralization and Solidification, WMO, Work Plan 0 9-WM-093, not dated

P3003, Solidification and Packaging CH-TRU Liquid W aste for Shipment to Idaho National

Laboratory and Final Disposition at the Waste Isola tion Pilot Plant; Bench Scale Neutralization

and Solidification, WMO, Work Plan 09-WM-094, not d ated

P3004, Project-Specific Sampling and Analysis Plan (PSAP) Containerized Waste Material

DQO and SAP Instructions; CH TRU Liquids Bulking/Ne utralization/Solidification Project,

WMO, CHTRU-001, December 3, 2009

P4001, Sorting, Inspection, and Packaging of CH-TRU Solid Waste Building 205 Glove Boxes,

for Shipment to Idaho National Laboratory (INL) and Final Disposition at the Waste Isolation

Pilot Plant (WIPP), WMP, JP-12-205G-004, not dated

P4002, Solidification and Packaging CH-TRU Liquid W aste for Shipment to Idaho National

Laboratory (INL) and Final Disposition at the Waste Isolation Pilot Plant (WIPP), WMO, Work

Plan 09-WM-093, Revision 2, not dated

P4003, Solidification and Packaging CH-TRU Liquid W aste for Shipment to Idaho National

Laboratory and Final Disposition at the Waste Isola tion Pilot Plant, WMO, Work Plan 09-WM094, Revision 1, not dated

P4005, Sort and Package CH-TRU Solid Waste for Ship ment to Idaho National Laboratory

(INL) and Final Disposition at the Waste Isolation Pilot Plant (WIPP), WMO, WP-12-WM-016,

Revision 1, not dated

RTR BDR Nos. RTR13-00127 and RTR13-00129

U3001, CH TRU Project Inventory to be Repackaged, A rgonne, January 18, 2010

# J-9



# U3002, WDS Query and Compilation of Radiological Da ta for Waste Streams AECHDM and

AECHHM, Chris Chancellor, May 5, 2010

U3003, Historic WMO-195 Waste Requisitions for Cont ainers Repackaged into Waste Streams

AECHDM-PK and AECHHM-PK, WMO, various dates

U3004, Waste Streams AECHDM-PK and AECHHM-PK Waste Container Packaging Forms

and Supporting Documentation, WMO, various dates

U3005, WMS Query for Repackaged CH Waste Streams AE CHDM-PK and AECHHM-PK,

WMO, September 29, 2011

U3006, Radionuclide Data for Waste Streams ID-AECHD M and ID-AECHHM, September 26,

2011

U4003, Historic WMO-195 Radioactive and Mixed Waste Disposal Requisition and WMO-200

Recoverable Materials Processing Requisition Forms for Containers Repackaged into Waste

Streams AECHDM-PK and AECHHM-PK, WMO, various dates

U4004, Waste Streams AECHDM-PK and AECHHM-PK Waste Container Packaging Forms

and Supporting Documentation – 2012 Campaign, WMO, various dates

U4005, 2012 Repackaging Campaign Inventory Summary, Kevin Peters, December 4, 2012

U4010, Discrete Radiological Source Pictures and Co ntainer Documentation, WMO, various

dates

U4011, Radionuclide Data for Waste Streams AECHDM-P K and AECHHM-PK with

Containers Added during 2012 Campaign, WMO, Decembe r 7, 2012

U4012, AMWTP Response to EPA regarding AMWTP-Derive d Weighted Averages for

Prevalent Radionuclides in Argonne Homogeneous Wast e Streams, AMWTP, November 25,

2012

Waste Material Parameter Analysis Memorandum, CCP-A K-INL-025, March 23, 2011

RH AK

ID-ANLE-S5000

CCP-AK-INL-500, CCP AK Summary Report for RH TRU De bris Waste from ANL-E Stored at

INL, Waste Stream: ID-ANLE-S5000, Revision 11, Nove mber 20, 2012

CCP-TP-005, CCP Acceptable Knowledge Documentation, Revision 24, Attachment 8 – Waste

Containers List, ID-ANLE-S5000, June 4, 2013

CCP-TP-005, Revision 25, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP

Waste Stream Characterization Checklist – Example F orm, ID-ANLE-S5000, Lot 37, July 2,

2013

CCP-TP-005, Revision 25, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP

Waste Stream Characterization Checklist – Example F orm, ID-ANLE-S5000, Lot 38, August 12,

2013

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP

Waste Stream Characterization Checklist – Example F orm, ID-ANLE-S5000, Lot 39, September

5, 2013

# J-10



# CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP

Waste Stream Characterization Checklist – Example F orm, ID-ANLE-S5000, Lot 40, April 15,

2014

Characterization Information Summary, WSPF No. ID-A NLE-S5000, Lot 37, Revision 1, July 2,

2013

Characterization Information Summary, WSPF No. ID-A NLE-S5000, Lot 38, August 12, 2013

Characterization Information Summary, WSPF No. ID-A NLE-S5000, Lot 39, September 5, 2013

Characterization Reconciliation Report, ID-ANLE-S50 00, Lot 37, July 2, 2013

Characterization Reconciliation Report, ID-ANLE-S50 00, Lot 38, August 12, 2013

Characterization Reconciliation Report, ID-ANLE-S50 00, Lot 39, September 9, 2013, Corrected

May 7, 2014

Characterization Reconciliation Report, ID-ANLE-S50 00, Lot 40, April 14, 2014, Corrected

May 7, 2014

DR010, Discrepancy Regarding the Volume of 7-Gallon Waste Cans, K. Peters, DR010, June 7,

2006

DTC BDR Nos. INLRHDTC13010 and INLRHDTC14002

Inter-Office Correspondence from L. Nelson to I.S. Joo, EPA Acceptable Knowledge Accuracy

Report: CCP-AK-INL-500, Idaho National Laboratory R emote-Handled Transuranic (RH-TRU)

Waste Stream Number ID-ANLE-S5000, Lots 1–40, May 5 , 2014

Inter-Office Correspondence from L. Nelson to I.S. Joo, Revised Acceptable Knowledge

Accuracy Report: Idaho National Laboratory Waste St ream Number ID-ANLE-S5000, Lots 1–

36, May 28, 2013

Memorandum from Scott Smith to CCP Records, Revisio n 1, Evaluation of Drums from Repack

of ANL-E High Gamma TRU Waste Containers at INL in Waste Stream ID-ANLE-S5000, April

22, 2013

NDE BDR Nos. INLRHRTR14002 and INLRHVE13001

U4032, RH TRU Container Repackaging Datasheets for ANLE Canisters in Waste Stream IDANLE-S5000, FRM-880, various dates

U552, Compilation of MFC Liner Documents, various a uthors, various document numbers,

various dates

ID-HFEF-S5400-RH

C4117, Evaluation of 13 RH-TRU Containers for Addit ion to Waste Stream ID-HFEF-S5400-

RH, John Kleckner, September 30, 2010

C4128, Memorandum to CCP Records from Scott Smith, re: Evaluation of Drums from Repack

of MFC HFEF Remote-Handled TRU Waste in Waste Strea m ID-HFEF-S5400-RH, Scott Smith,

January 6, 2014

# J-11



# CCP-AK-INL-580, CCP AK Summary Report for Remote-Ha ndled TRU Debris Waste from

Materials and Fuels Complex Hot Fuel Examination Fa cility at the Idaho National Laboratory,

Waste Stream ID-HFEF-S5400-RH, Revision 4, March 24 , 2014

CCP-AK-INL-582, CCP RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance for

INL RH Waste Stream ID-HFEF-S5400-RH, Revision 4, N ovember 25, 2013

CCP-RC-INL-581, CCP Remote-Handled Transuranic Radi ological Characterization Technical

Report for RH TRU Debris Waste from Materials and F uels Complex Hot Fuel Examination

Facility at the Idaho National Laboratory, Waste St ream ID-HFEF-S5400-RH, Revision 0,

September 25, 2013

CCP-TP-005, Revision 22, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste

Containers List, ID-HFEF-S5400-RH, May 17, 2011

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 4 –

Acceptable Knowledge Source Document Information Li st, ID-HFEF-S5400-RH, February 27,

2013

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 1 –

Acceptable Knowledge Documentation Checklist, ID-HF EF-S5400-RH, May 8, 2014

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 4 –

Acceptable Knowledge Source Document Information Li st, ID-HFEF-S5400-RH, May 8, 2014

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP

Waste Stream Characterization Checklist – Example F orm, ID-HFEF-S5400-RH, Lot 23, April

7, 2014

Characterization Information Summary, WSPF No. ID-H FEF-S5400-RH, Lot 22, Revision 1,

July 10, 2013

Characterization Information Summary, WSPF No. ID-H FEF-S5400-RH, Lot 24, Draft, March

18, 2014

Characterization Reconciliation Report, ID-HFEF-S54 00-RH, Lot 22, June 27, 2013

Characterization Reconciliation Report, ID-HFEF-S54 00-RH, Lot 24, Draft provided April 24,

2014

DTC BDR Nos. INLRHDTC1006, INLRHDTC10016, INLRHDTC1 2007 and

INLRHDTC14003

Inter-Office Correspondence from L. Nelson to I.S. Joo, EPA Acceptable Knowledge Accuracy

Report, CCP-AK-INL-580, Idaho National Laboratory R emote-Handled Transuranic (RH-TRU)

Waste Stream Number ID-HFEF-S5400-RH, Lots 1–23, Ma y 5, 2014

NCR No. NCR_RHINL-0215-14

NCR No. NCR_RHINL-0355-14

NCR No. NCR_RHINL-0438-13

P848, Engineering Calculations and Analysis Report, MFC Inter-Facility Transfer of Radioactive

Materials in the HFEF-14 Cask with Comment Page, N. A. Stewart, EDF-7659, Revision 6,

October 22, 2009

# J-12



# RTR BDR Nos. INLRHRTR10013, INLRHRTR13006 and INLRH RTR14003

U484, Radioactive Scrap and Waste Storage/Disposal Request and Authorization Forms and

Related Documents, not dated

U992, RH TRU Container Repackaging Datasheets for H FEF Canisters in Waste Stream IDHFEF-S5400-RH, INL CWI, FRM-880, November 11, 2010

NDA

BII-5221-CVR-001, Pajarito Scientific Corporation, Calibration and Validation Report:

SuperHENC Mobile Assay System, March 18, 2009

CCP-Idaho National Laboratory List of Qualified Ind ividuals, May 1, 2014

CCP-INL-174, Operator Aid: WAGS Pulser Parameter Da ta, December 21, 2009

CCP-INL-266, Operator Aid: SGRS Pulser Parameter Da ta, September 17, 2013

CCP-INL-251, Operator Aid: SGRS/WAGS Weekly Perform ance check drum, November 28,

2012

CCP-INL-SGRS-001, SGRS Calibration Confirmation and Verification Report, Revision 2,

November 14, 2012

CCP-INL-SGRS-12-003, Calibration Verification of th e SGRS System after Detector

Replacement and Energy Calibration, August 8, 2012

CCP-INL-SGRS-12-005, Measurement Control Limit Upda te on the SGRS, October 17, 2012

CCP-INL-WAGS-001, Revision 1, April 2008

CCP-INL-WAGS-003, WAGS Calibration, Confirmation an d Verification Report, Revision 0,

May 18, 2011

CCP-INL-WAGS-12-003, Measurement Control Limit Upda te for 356 keV count rate on the

WAGS, July 19, 2012

CCP-INL-WAGS-12-005, Calibration Verification of th e WAGS System after replacement of

DSA 1000 power supply for DET3NB, December 3, 2012

SGRS BDR Nos. INNDAS130099 and INNDAS140043

SGRS Operational Logbook, May 6, 2014, correspondin g to day of EPA inspection and

sampling of entries

SuperHENC BDR No. INNDAD13003

SuperHENC Operational Logbook, May 6, 2013, corresp onding to day of EPA inspection and

sampling of entries

Summary of Containers Assayed on SGRS, WAGS and HEN C, June 7, 2013 to April 30, 2014,

prepared for inspection

WAGS BDR Nos. INNDAW140033 and INNDAW130104

WAGS Operational Logbook, May 6, 2014, correspondin g to day of EPA inspection and

sampling of entries

# J-13



# DTC

DTC Operational Logbook, May 7, 2014, corresponding to day of EPA inspection and sampling

of entries

NIST Report of Calibration for detector XY022481, O ctober 25, 2002

RH-DM-INL-002, Operator Aid, Posted in Control Room of DTC, CCP, Revision 19, May 6,

2014

RH-DM-INL-003, Operator Aid Posted in Control Room of DTC, CCP, Revision 2, November

29, 2012

Source Calibration Certificates and Source Capsule Descriptions of DTC Sources, March 29,

2007

NDE

A list of RH INL RTR personnel training containers and inventory sheets

Appointment emails for various VEEs, dated March 1, 2007, August 31, 2009, and December

10, 2013

Audio/visual recordings for selected containers fro m the listed RH BDRs

CCP-AK-INL-026, Central Characterization Program Ac ceptable Knowledge Summary Report

for Idaho National Laboratory Sludge Repackage Proj ect Combined Sludge Waste, Waste

Stream: ID-SRP-S3000, Revision 0, November 18, 2013

CH VE BDR No. INL-ARP-VE-002942, INL-ARP-VE-002943, INL-SRP-VE-000496, INLSRP-VE-000699 and INL-SRP-VE-000700

CH VE data sheets for demonstration Container Nos. SRP23106 and SRP23093

CH VE data sheets for demonstration Container Nos. SRP23106 and SRP23093

Container and BDR listing as of May 2013, provided April 24, 2014

Inventory sheets for RTR Container Nos. NDE-TRAININ G-25, NDE-TRAINING-26, NDETRAINING-1, NDE-TRAINING-25 and NDE-TRAINING-33

List of CH VE BDRs generated since May 1, 2013, pro vided April 24, 2014

List of Fully Characterized CH Containers, provided April 24, 2014

List of INL CH VE BDRs and NCRs, provided April 24, 2014

LOQIs for VE and RTR operators

Practical demonstration summary for RH INL RTR pers onnel

Qualification Cards for selected VE and RTR personn el

RH RTR BDR No. INLRHRTR14002 and INLRHRTR14003

RH RTR data sheets for demonstration Container No. FCO108C

RH VE BDR No. INLRHVE13001

Training Container Evaluation Data Sheets for vario us RTR operators

# J-14



# Training DVDs for various RTR personnel