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

WASTE CHARACTERIZATION INSPECTION 

CONTINUED COMPLIANCE REPORT 

EPA INSPECTION OF THE CENTRAL CHARACTERIZATION PROJECT 

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 Spectrometer...................... 18

6.2.2 Technical Evaluation: Stored Waste Examination Pilot 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 Waste Characterization Processes 

Implemented by INL-CCP .............................................................................................................. 3

Table 2. Tiering of Remote-Handled Transuranic Waste Characterization Processes 

Implemented by INL-CCP .............................................................................................................. 5

Table 3. Contact-Handled Containers Evaluated for Traceability ................................................ 10

Table 4. Remote-Handled Containers Evaluated for Traceability ................................................ 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, Issue No. INL-CCP-CH-WC-14-01C, 

Final 

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

Attachment D.2 AK Continued Compliance Inspection Checklist: 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 SRP21732 – WAGS 

Attachment F.2 Replicate Testing Data for Drum SRP21773 – WAGS 

Attachment F.3 Replicate Testing Data for Drum SRP18745– WAGS 

Attachment G Dose-to-Curie Continued Compliance Inspection Checklist 

Attachment H NDE Continued Compliance Inspection Checklist: 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 Inspection 
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 Center 

ITR Independent Technical Reviewer 

IWTS Integrated Waste Tracking System 

keV kilo electron volt 

kg kilogram 

kg/L kilogram per liter 
v 

kV kilovolt 

La3Br(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 
vii 

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 Protection Agency’s (EPA’s) determination that the 

waste characterization program at the U.S. Department 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 transuranic (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 compliance inspection of the site’s program to 

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

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

activities: 

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

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

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

(SWEPP), Gamma-Ray Spectrometer (SGRS) and the Super 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 inspection, EPA confirms that the INL-CCP 

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

inspection are consistent with the limitations described 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) approvals. 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 and RTR Tier 2 (T2) designations which 

require DOE action: 

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

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

operators, Expert Analysts (EAs) and Independent Technical 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 operators, 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 the INL-CCP tiering designations consistent 

with the requirements at other TRU sites and to support 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 regarding AK documentation applies to all INLCCP waste streams. 

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

requiring a response regarding documentation of formal and informal calibration verifications. 

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

during the evaluation and provided them to EPA. Attachment 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 through the EPA website and by sending emails to 

the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3). 
3 

Table 1. Tiering of Contact-Handled Transuranic Waste Characterization Processes Implemented 

(Based on May 3–5, 2005, Baseline Inspection and Subsequent Evaluations, Updated June 

Process Elements INL-CCP CH Waste Characterization Processes – T1 Changes INL-CCP CH Waste Characterizati

Acceptable Knowledge, including Load Management 

Any new waste category Changes to the accelerated retrieval project targeted wastes from 

what was presented in CCP-AK-INL-001, Revision 7 

Submission of a list of active INL-CCP CH Notification to EPA upon completion of o

• AK-NDA memoranda • AK accuracy reports (annually, at a mi• AK-AK and AK-NDA/NDE discrepan

• WSPFs, including updates or additions 

approved waste category 

• New and revised AK summary reports • The load management status of approv

• Site procedures requiring CBFO appro• Any analysis evaluating effectiveness o

Process 

Nondestructive Assay New equipment or substantive physical modifications** to approved 

equipment Extension of or changes to approved calibration range for approved equipment 

Submission of a list of INL-CCP NDA operformed work during the previous quNotification to EPA upon substantive mod

• Software for approved equipment • Operating ranges upon CBFO approva• Site procedures requiring CBFO appro

Real-Time Radiography None Submission of a list of INL-CCP RTR o

performed work during the previous qu

Notification to EPA upon: 

• Substantive modification** to site proc

• New equipment or substantive physica

equipment 

Visual Examination and Visual Examination Technique 

Changes in the vendor performing visual examination or visual 

examination technique 

Submission of a list of INL-CCP VE opethat performed work during the previouNotification to EPA upon substantive modrequiring CBFO approval 

WIPP Waste Data System 

Changes to WDS algorithms specific to load management requiring 

revisions to the load management provisions of DOE’s CH WAC 

Notification to EPA upon substantive mod

• Site procedures requiring CBFO appro• WDS algorithms corresponding to cha

provisions of the CH WAC 

New T1s, T2s and significant modifications to existing T1s or T2s are in bold text; T1s or T2s that were only revised for style are not shown in 

* 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 documentatio

are solely related to the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act; or that are editori

address administrative concerns. EPA may request copies of new references that DOE adds during a document revision. 
5 

Table 2. Tiering of Remote-Handled Transuranic Waste Characterization Processes Implemented 

(Based on June 12–16 and August 9 and 26, 2006, Baseline Inspection and Subsequent Tier 1 Evaluations, 

Process Elements INL-CCP RH Waste Characterization Process – T1 Changes INL-CCP RH Waste Character

Acceptable Knowledge Any new waste stream not approved under the baseline 

Addition of containers to approved waste streams if new or different radionuclide scaling factors are required Substantive modification** to AKSRs and certification confirmation 

test plans (e.g., CCP-AK-INL-500, CCP-AK-INL-502) Load management for any RH waste stream 

Submission of a list of active INL-Notification to EPA upon availabimodification** of AKSRs and cer(e.g., CCP‐AK‐INL-500, CCP-AK

Notification to EPA upon availabi

• CCP-TP-005, Attachment 4 th

Source Document Reference L

• The WSPF or WSPF change n

including the CRR, CIS and Suprovided with each requested W

• AK accuracy reports (annually

• Discrepancy resolution reports 

• AK documentation as a result 

Program Implementation Plan 

• Correlation or surrogate summ

containers in this waste stream based on measured dose rates tresults for assayed containers 

Notification to EPA of the intentioapproved waste stream, including containers and volume of waste, thcharacterization, and disposal and documenting that the pedigree of tsame as those covered by the baseapprovals*** Submission of a list of fully characpopulation of additional containers above*** 

Radiological Characterization, including Dose-to-Curie 

Any new waste stream not approved under the baseline or subsequent T1 evaluations or addition of containers to an approved waste stream that requires changing the established radionuclide scaling factors Use of any alternate radiological characterization procedure other than 

DTC with established scaling factors as documented in CCP-TP-504 Use of any alternate gamma detector with the OSPREYTM system 

characterization procedure other than the La3Br(Ce) detector observed 

Submission of a list of INL-CCP 

that performed work during the Notification to EPA upon nonsubsprocedures or radiological technicCCP-AK-INL-501) requiring CBFSubmission of an updated radiologAK-INL-501) documenting that th

processes used for the additional c
6 

Process Elements INL-CCP RH Waste Characterization Process – T1 Changes INL-CCP RH Waste Character

in July 2010 Application of new (i.e., not EPA-approved) scaling factor development processes for isotopic determination (applies to new RH waste streams and to the addition of containers to an approved waste stream) Substantive modification** to EPA-approved procedures or radiological characterization technical reports (e.g., CCP-TP-504, CCP-AK-INL-501) 

covered by the baseline or subsequ

Submission of BDRs or calculatio

by EPA from a list of fully charactINL-CCP*** 

Visual Examination Visual examination by any new process for SCG S3000, S4000 or 

S5000 waste. Visual examination by review of existing audio/visual recordings for 

SCG S3000 or S4000 waste.

Submission of a list of INL-CCP ITRs that performed work durin

Notification to EPA upon substantprocedures requiring CBFO approSubmission of BDRs for container

fully characterized containers prov

Real-Time Radiography Any new debris waste stream or waste from SCG S3000 or S4000 

Addition of any new RTR units 

Submission of a list of INL-CCP 

performed work during the prevNotification to EPA upon substantprocedures requiring CBFO approSubmission of BDRs for container

fully characterized containers prov

WIPP Waste Data System None Notification to EPA upon substant

procedures requiring CBFO appro

New T1s, T2s and significant modifications to existing T1s or T2s are in bold text; T1s or T2s that were only revised for style are not shown i

* 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 documentati

are solely related to the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act; or that are editor

address 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 the 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 42571–42583, 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 applicable conditions and limitations, can 

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

TRU wastes destined for disposal at the WIPP. 

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

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

processes to characterize the waste, and (2) remains 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 approved waste characterization program by 

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

EPA performs annual continued compliance inspections of each TRU waste characterization 

program, covering all elements of the programs, including the common elements of waste 

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

of the common characterization elements are personnel training, procedures and equipment 

capabilities. EPA will consider the results of continued 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 continued compliance inspection. Thus, EPA 

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

change request, evaluation and approval (e.g., waste-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 contacted represented a sample of the CH and RH 

TRU waste characterization staff. The EPA inspection 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 wastes. Specifically, this report: 

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

this inspection. 
8 

• Identifies all areas where waste characterization systems have changed relative to what 

was approved during the baseline inspection and other subsequent EPA T1 evaluations 

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

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

waste characterization systems. 

• Describes any tests or demonstrations completed during 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 included 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 and subsequent T1 evaluations. Waste 

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

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

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

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

debris), and VE operations for multiple CH and RH SCGs. 

6.0 TECHNICAL EVALUATION 

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

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

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

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

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

discussed in section 6.2.1, Item (8), of this report. 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 address: 

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 EPA-approved AK procedures for CH 

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

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

S5000 (heterogeneous debris) waste. INL-CCP management 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-SRP-S3000 since EPA’s 2013 

continued compliance inspection. EPA reviewed a selection 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 Program procedures and found them to be 

adequate. 

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

and disposition of nonconformances for technical sufficiency and scope. Specifically, EPA 

reviewed: 

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

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

2013. 

• CCP-TP-002, Revision 26, “Reconciliation of DQOs and 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 last time EPA reviewed these procedures. 

The procedure revisions are mostly editorial or changes that do not significantly impact the EPAapproved waste characterization program. The revision 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 result 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 these changes. 

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

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

below. 

Notification to EPA upon completion of or substantive modification to site procedures requiring 

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

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

including acceptable knowledge assembly, compilation and verification, was adequately 

implemented. 

EPA evaluated INL-CCP’s completion of each of the 15 attachments associated with CCP 

procedure CCP-TP-005 (AK documentation) by reviewing 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 subsurface disposal area (SDA) since 2009. 

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

for the impact of expected WMPs from the newly added 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 ARP-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 generation at INL-CCP through INL-CCP 

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

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

documented. 

Table 3. Contact-Handled Containers Evaluated for Traceability 

The waste in Waste Streams ID-AECHDM and ID-RF-S3114 is traceable from the DOE facility 

of origin through INL-CCP characterization. 

(4) EPA assessed the acceptable knowledge summary reports 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-INL-025 for Waste Streams 

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

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

source documents, to support the following statements: 

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

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

• All waste within the waste stream has similar radiological 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 nuclear fuel (SNF).2

 

2As defined by U.S. Code, Title 42, “The Public Health 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. Explanations and source documents 

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

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

AKEs inconsistently apply the labels “waste” or “packaging 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 packaged inside paint cans within the larger drum. The 

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

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

homogenous solid SCG (S3000). During a recent INL-CCP 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 SCG (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 somewhat meaningless. As long as the AKSR 

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

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

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

matrix code (WMC) to the drums. According to the INL-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 operating under a separate approval from EPA. 

EPA will discuss the “waste” versus “not waste” determinations 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 aspects, and related change notices for Waste 

Streams ID-AECHDM, ID-AECHHM and ID-SRP-S3000 and found 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 training 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 program. INL-CCP provided completed 

qualification cards and documentation showing familiarity of the AKEs with the current 

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

qualification cards for several SPMs listed in Attachment D.1. The primary SPM for the INL-
12 

CCP CH waste characterization program is Rich Kantrowitz. Training records for the personnel 

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

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

continued compliance inspection. 

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

1). 

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

be adequate. 

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

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

reports for Waste Streams ID-AECHDM and ID-SRP-S3000. EPA found that INL-CCP 

adequately prepared these documents as necessary. 

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

(8) EPA assessed acceptable knowledge accuracy and found 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 calculated by comparing AK against 

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

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

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

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

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

based on AK alone. 

Notification to EPA upon completion of or substantive modification to AK accuracy reports 

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

(9) EPA assessed communication between acceptable knowledge and nondestructive assay 

personnel and found it to be adequate. 

EPA reviewed the current AK-NDA memorandum for Waste Streams ID-AECHDM, IDAECHHM, ID-SDA-DEBRIS, ID-SDA-SOIL and ID-SDA-SLUDGE. EPA evaluated the 

memoranda for completeness and compared the memoranda with the AKSRs. 

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

review the AK record to ensure that information addressing americium-241 (241Am) in-growth is 

incorporated as appropriate. 

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

remains a T2 change (see Table 1). 
13 

(10) EPA found load management to be adequately implemented. 

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

measure less than 100 nanocuries per gram (nCi/g) of 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 management must include an estimate of the 

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

TAAC. Each container selected for payload management 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 measureable), 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 management for Waste Stream ID-RF-S3114. 

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

because it is composed of waste from Waste Stream ID-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 containers 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 than 100 nCi/g of alpha emitting isotopes with 

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

one measureable TRU radionuclide but has a TAAC below 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 management for Waste Stream ID-SRP-S3000 is 

acceptable. 

Notification to EPA upon modification to the load management 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 substantive 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 compliance inspection with the T2 

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

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

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

AKEs and SPMs for the previous quarter were not reported until the 2nd quarter report for fiscal 

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

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

the FY2014 2nd quarter T2 report was the first opportunity they had to report this list. EPA 

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

stated otherwise. The tiering changes identified during 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 related to AK for CH waste as a result of this 

continued compliance inspection. 

There are no changes to the T1 or T2 designations for CH 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 characterization compliance for CH waste streams. 

6.1.2 Technical Evaluation: Remote-Handled Waste 

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

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

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

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

inspection. EPA has approved T1 changes for the active 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 representative sample of the INL-CCP RH AK 

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

Attachment D.2. 

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

adequate. 

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

of nonconformances for technical sufficiency and scope. 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 implementation is evidenced by adequate 

preparation and maintenance of the required documentation, as reviewed below. 

Notification to EPA upon completion of or substantive modification to site procedures requiring 

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

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

characterization process for containers, including acceptable knowledge assembly, 

compilation and verification. 

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

attachments as necessary to incorporate the ongoing waste characterization and whether INLCCP prepared the attachments using forms from the appropriate 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 Attachments 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 appropriately revised attachments during 

the inspection. EPA found that the rest of the attachments 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 change (see Table 2). 

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

EPA examined traceability from waste generation through 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 identification and characterization and these data 

show that the final drums can be traced to the original sources. 

Table 4. Remote-Handled Containers Evaluated for Traceability 

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

demonstrated. 

(4) EPA assessed the acceptable knowledge summary report 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 all 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 include 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 section 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 identified any changes to the radiological or 

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

either waste stream since the last time EPA reviewed 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 substantive modification to WSPFs remains a T2 

change (see Table 2). 

(6) EPA assessed acceptable knowledge personnel training 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 also trained for INL waste and primarily 

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

documentation of familiarity with the current revision 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 resolution documentation and found it to 

be adequate. 

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

(NCR) and discrepancy resolution (DR) reports during 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 modification to DR reports and NCRs for AK 

nonconformances remains a T2 change (see Table 2). 

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

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

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

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

AK alone. 

Notification to EPA upon completion of or substantive modification to AK accuracy reports 

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

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

certification plan, and found them to be adequate. 

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

of containers in the waste stream. INL-CCP indicated 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 nonsubstantive 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 management 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 substantive 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 compliance inspection with the T2 

notification reports provided to EPA by CBFO. 

Most of the examined documents were appropriately reported. 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 RH baseline inspection and subsequent T1 

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

Summary of Acceptable Knowledge for Remote-Handled Waste 

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

continued compliance inspection. 

There are no changes to the T1 or T2 designations for RH 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 characterization compliance for RH waste streams. 

6.1.3 Acceptable Knowledge Findings and Approval 

Summary of Acceptable Knowledge Findings and Concerns

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

compliance inspection. 

Acceptable Knowledge Approval

There are no changes to the T1 or T2 designations for 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 characterization compliance. 
18 

6.2 Nondestructive Assay for Contact-Handled Waste Characterization 

EPA approved the WAGS and SGRS NDA systems initially 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 2007 (EPA Docket No. A-98-49; II-A4-86). 

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

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

the following: 

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

and software had not changed since EPA’s last inspection. 

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

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

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

6.2.1 Technical Evaluation: Waste Assay Gamma Spectrometer for Contact-Hanlded 

Waste 

EPA evaluated INL-CCP’s continued compliance with the EPA-approved waste characterization 

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

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

WAGS were evaluated during this inspection. 

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

that EPA approved previously. 

The WAGS system is located at INL in the facility formerly 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 the Waste Assay Gamma Spectrometer 

and found them to be unchanged from the last inspection 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 Drum No. 22862, which was 85% full and 

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

the time of the inspection. 

EPA Inspectors reviewed BDRs INNDAW130104 and INND140033 and found them to 

adequately document drum assays. WAGS operators appropriately recorded all daily 

performance measurements, which were in control. Specifically, WAGS operators evaluated 

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

(gain) and barium-133 (133Ba) transmission source checks, as evidenced in the WAGS daily 

operational logbook and BDRs. INL-CCP had established and documented warning and control 
19 

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

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

The software performs decay correction of the 133Ba transmission sources. Due to the short halflife of 133Ba (approximately 10 years), the count rate boundary 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 of the transmission sources in July 2013. 

INL-CCP NDA personnel indicated that they expect additional 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 of 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 unchanged 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 acceptable and appropriately documented. 

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

two measurement control updates on the WAGS and documented 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 personnel P. Abbott and D. Brasier. The updates 

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

NDA system. 

(4) Determination and documentation for the total measurement uncertainty for the Waste 

Assay Gamma Spectrometer are adequate. 

INL-CCP documented the total measurement uncertainty (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 regarding TMU for the WAGS NDA system. 

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

minimum detectable concentration of the Waste Assay Gamma Spectrometer, as 

required. 

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

system’s LLD, including reporting thresholds for specific non-measured radionuclides 242Pu and 

strontium-90 (90Sr). The EPA inspection team verified that this document was unchanged from 

EPA’s last inspection. There were no concerns regarding 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-sponsored Performance Demonstration 

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

annually and will participate in Cycle 21A in May 2014. 

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

Currently there are 11 operators and four EAs approved 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 the list of qualified individuals (LOQI) dated 

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

training of personnel for the WAGS NDA system. 

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

evaluated during future T1 change evaluations. 

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

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

Environmental Protection Agency Replicate Testing Protocol. 

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

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

determination of the quantity of 10 WIPP-tracked radionuclides [241Am, cesium-137 (137Cs), 

plutonium-238 (238Pu), 239Pu, 240Pu, 242Pu, 90Sr, uranium-233 (233U), 234U and 238U] and the 

TAAC.4

 This is accomplished by having the WAGS reassay drums it previously measured to 

demonstrate the system’s ability to do the following: 

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

deviation for a number of replicate measurements taken 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 assayed on the WAGS, and EPA selected the 

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

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

original assay data. INL-CCP performed two statistical 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 evaluation. 
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 test or the chi-squared test for 

independence, is used to show how observed data compare 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 measurement. 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 is 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 data to see if there are statistically significant 

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

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

results except 238Pu were not statistically different. The 238Pu 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 attention at this time. Common reasons for the 

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

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

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

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

to query. In this instance, 238Pu 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 238Pu 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 238Pu, such that the multi-group 

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

spectral area to quantify 238Pu. The original assay and replicate assay No. 2 showed enough 

counts to quantify 238Pu; however, the assays barely met the MGA criteria. For the remaining 

replicates, MGA could not effectively determine 238Pu without an unreasonably high level of 

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

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

238Pu results because, in fact, these two groups do represent different populations by virtue of 

how the final results were obrtained. 

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

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

and reviewing an email memorandum dated May 27, 2014, EPA is satisfied that the WAGS is 

functioning properly and produces reproducible results for the determination of the quantity of 
22 

10 WIPP-tracked radionuclides. There are no concerns 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 verifications. This concern is documented on 

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

6.2.2 Technical Evaluation: Stored Waste Examination Pilot Plant Gamma-Ray 

Spectrometer for Contact-Handled Waste 

EPA evaluated INL-CCP’s continued compliance with the 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 following 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 Waste Management Complex (RWMC) in 

the facility formerly called the SWEPP, INL Building 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 changes with successful calibration 

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

SGRS NDA system. 

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

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

and were adequate for the wastes currently being assayed. 

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

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

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

however, on a typical day approximately 32 are assayed. 

SGRS operators appropriately recorded all daily performance measurements, which were in 

control. Specifically, operators evaluated background, 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 control limits (2 and 3 σ limits) for all 

parameters, as appropriate, and boundary limits controlled 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 operational 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 performed calibration verifications following 

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

calibration verification were technically acceptable and appropriately documented. There were 

no concerns regarding the calibration of the SGRS NDA system. 

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

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

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

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

radionuclides 234U, 238Pu, 239Pu, 242Pu and 90Sr. The EPA inspection team verified that this 

document was unchanged from EPA’s last T1 evaluation. 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 program. 

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

SGRS is scheduled to participate in the PDP annually 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 areas, 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 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. EPA added this requirement to ensure that EPA has a complete picture of INLCCP waste characterization activities, which will inform 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 documentation 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, which 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 the EPA-approved waste characterization 

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

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

Building WMF-610, South Bay, and is officially designated 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 modality at INL-CCP, INL-CCP only 

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

INL-CCP indicated to EPA inspectors that they do not expect the frequency of use to increase in 

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

instrument to keep the instrument functioning properly. 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 higher 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 SuperHENC during this inspection. 

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

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

wastes currently being assayed. 

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

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

concerns regarding these aspects of the SuperHENC NDA system. 

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

the Super High Efficiency Neutron Counter as required. 

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

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

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

NDA system. 

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

performed on the Super High Efficiency Neutron Counter as required. 

EPA verified that INL-CCP had not changed the system’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 SuperHENC NDA system. 
25 

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

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

required. 

The EPA inspection team verified that INL-CCP had not 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 LLD determination of the SuperHENC NDA 

system. 

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

The SuperHENC participated in Cycle B13-A of the CBFO-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 applicable areas, as evidenced by the LOQI dated 

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

personnel training for the SuperHENC NDA system. 

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

evaluated during future T1 change evaluations. 

6.2.4 Nondestructive Assay for Contact-Handled Waste Findings and Approval 

Summary of Nondestructive Assay Findings and Concerns 

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

waste. EPA, however, identified one concern regarding 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. INL-CCP-CH-WC-14-01C, which 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. 

Nondestructive Assay for Contact-Hanlded Waste Approval

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 data examined, EPA determines that INL-CCP 

demonstrated continued compliance with the EPA-approved 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 EPA-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 Idaho Nuclear Technology and 

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

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

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

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

performing the operational check on Scale No. 724422, 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 operator weighed the drums and recorded the 

weight on the measurement control report (CCP-TP-504, Revision 13, Attachment 2) and 

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

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

15, Attachment 1 and in the DTC operational logbook. 

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

Measuring Unit with FHZ 612 Probe (Instrument No. 02055) attached to Probe No. XC0674, 

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

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

measurement control report and summarized them in the DTC operational logbook. DTC 

personnel consulted “CCP Operator Aid: RH-DM-INL-002, 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 checks. DTC operators also performed a source 

check for the OSPREY La3Br5

 Probe No. 13000014 using 137Cs 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 [La3Br(Ce)]. 
27 

When EPA entered the DTC observation room, DTC operators had already taken background 

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

measurements. EPA observed four measurements made at 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, Attachment 2), a copy of which INL-CCP 

provided to EPA. Contact dose rates for this drum exceeded 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 acceptable. 

There were no concerns regarding INL-CCP’s execution 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 DTC and OSPREY documenting that all 

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

for DTC. 

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. EPA added this requirement to ensure that EPA has a complete picture of INLCCP waste characterization activities, which will inform 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 DTC 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 data examined, EPA determines that INL-CCP 

demonstrated continued compliance with the EPA-approved waste characterization program for 

DTC. 

 

6 Rem or millirem is a unit of dose equivalent, which is often commonly called dose or when it is expressed 

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

while technically incorrect, is commonly used. Additionally, gamma measurements which technically represent 

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 EPA-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 inspection 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 process for Drum No. FCO108C from BDR 

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

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

container’s contents and entered characterization data 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 container. After the demonstration, EPA 

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

signed by the RTR operator. The operator used procedure CCP-TP-508,7 to guide the 

examination. 

EPA determined the procedure continues to be adequate 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 for selected containers from BDR Nos. 

INLRHRTR14002 and INLRHRTR14003 and determined that the records were complete and 

generated in accordance with INL-CCP procedures. The 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 properly examined each container’s contents 

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

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

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

prohibited items in the containers from the reviewed BDRs. 

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

reviews on the appropriate forms from CCP-TP-508 and CCP-TP-001.8

 

EPA determined that INL-CCP continues to generate and 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 operators, including qualification cards and 

training-container examination records. 

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

and that training records were readily available for 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 who performed work during the previous 

quarter is a new RTR T2 change (see Table 2). Specifically, 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 inform 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 Concerns 

EPA did not identify any findings or concerns related 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 who performed work during the previous 

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

and ITRs. 

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

demonstrated continued RTR compliance for RH SCG S5000 (heterogeneous debris) waste. 

6.5 Visual Examination 

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

and RH waste characterization. The VE checklists used 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-handled 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 entered 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 any prohibited items during the demonstration. 

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

completed them correctly. The operators used procedure CCP-TP-0069

 to guide the examination. 

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

compliant CH VE data. 

(2) EPA examined contact-handled visual examination characterization 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 processed the characterization records. EPA 

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

procedures. Operators recorded the WMP of each waste 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, INL-CCP had not generated any NCRs for the 

containers in these BDRs. 

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

adequate. 

EPA reviewed training records for selected operators 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-site 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 Waste 

EPA did not identify any findings or concerns related to VE for CH wastes 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 VE compliance for SCG S3000, S4000 and S5000 CH TRU waste. 

 

9

 CCP-TP-006, CCP Visual Examination Technique for Idaho 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 examination expert in lieu of observing 

visual examination for remote-handled waste and found 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 operators and a VEE and determined that 

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

interviewed were able to answer all questions asked by EPA. 

(2) EPA examined remote-handled visual examination characterization 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 this report and determined that INLCCP completed and properly processed the characterization records. EPA verified that INL-CCP 

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

WMP of each waste item, verified the WMC and confirmed 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 training records and found them to be 

adequate. 

EPA reviewed training records for selected operators 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 Waste 

EPA did not identify any findings or concerns related to VE for RH wastes 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 VE compliance for SCG S5000 RH TRU waste. 

 

10 CCP-TP-500, CCP Remote-Handled Waste Visual Examination, 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 VE 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 characterization 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 data examined, EPA determines that INL-CCP 

demonstrated continued VE compliance. 

7.0 FINDINGS AND CONCERNS 

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

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

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

INL-CCP-CH-WC-14-01C, which is included in Attachment 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 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. 

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 include all VE and RTR operators, ITRs and 

VEEs. 

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

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

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

with the requirements at other TRU sites and to support 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 regarding AK documentation applies to all INLCCP waste streams. 
33 

Approval 

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

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

completed May 6–8, 2014.
A-1 

ATTACHMENT A.1: APPROVAL SUMMARY FOR INL-CCP CONTACT-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 November 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 September 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 for 

the WAGS to Allow Filters June 23, 2011 A-98-49, II-A4-150 

Unannounced Inspection – Waste Stream ID-NRD.1 January 4, 2012 A-98-49, II-A4-157 

T1 Change – Approval of Recalibration of the SGRS February 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 February 12, 2007 A-98-49; II-A4-80 

T1 Change – Approval of K Cell Wastes January 1, 2008 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-A4-183 
B-1 

ATTACHMENT B: INSPECTION PERSONNEL 

Personnel Affiliation Area of Expertise/Function Entrance Meeting Interviewed 

Rajani Joglekar U.S. EPA ORIA Inspector–Team Leader  Ed Feltcorn U.S. EPA ORIA Inspector  Dorothy Gill SC&A, Inc. RTR/VE Inspector  Connie Walker SC&A, Inc. AK Inspector  Kira Darlow SC&A, Inc. AK Inspector  Rose Gogliotti SC&A, Inc. NDA/DTC Inspector  Ben Roberts DOE Bill Verlanic CCP CCP CH  Brad Stark CCP CH VEE  Brent Dial INL-CCP DTC/OSPREY Brett Gyorfy CCP Records Bruce LaRue DEQ Observer Carrie Johnson CCP CCP AKE CH/RH   Chris G. Davis INL-CCP RH RTR ITR, RH VEO/ITR David Brasier CCP NDA  David Pinnock INL-CCP DTC Doug Pruitt DOE Ed Gulbransen NWP CCP Manager  Irene Joo CCP RH Project Manager   J. Bret Palmer INL-CCP RH VEO/ITR Jeff Poole INL-CCP RH VEE/VPM  Jennifer Law INL-CCP NDA Jeri Miles NWP CH VE VPM   Jodi M. Stanton INL-CCP CH VEO Kevin Peters INL-CCP AK/AKE  Larry Klingler CCP QA Lashell Alade INL-CCP RH RTR Operator Lisa Frost CWI CH TRU Lori Muntean INL-CCP CH VEO Marcus A. Pinzel DOE 
B-2 

Mary Carroll INL-CCP RH DTC  

Mike Grenfell INL-CCP Container Manager Porf Martinez CBFO/CTAC Observer  Preston Abbott CCP NDA  Raj Bhatt CWI RH TRU Richard Kantrowitz NWP SPM   Scott Smith CCP AK/AKE   Steve Schafer CCP AKE Tom Clements CWI Observer Tom Johnsen CWI CH TRU STR  Trisha Pimentel CCP Records Tyson 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-115 references non-WAC required 

calibration verifications as "calibration verification checks" while CCP-TP-019 refers to the 

them as "calibration verifications." The non-required calibration verifications do not produce 

the same level of documentation as a WAC-required calibration. 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 applicable 
D-1 

ATTACHMENT D.1: AK CONTINUED COMPLIANCE INSPECTION CHECKLIST: CONTACT-HA

EPA Inspection No.: INL-CC-2014 Contact-Handled Waste Insp

Technical Elements Objective Evidence Comm

General AK-1: Confirm that AK, training and nonconformance procedures adequately reflect the requirements of 40 CFR 194. 

CCP-QP-002, Revision 36, training and qualification plan CCP-QP-005, Revision 24, nonconforming item reporting CCP-TP-002, Revision 26, WSPF package development CCP-TP-005, Revision 26, AK documentation Revised sample AKE Qualification Card 

40 CFR Part 194.24 (c) requir

of controls to characterize wascomponents. The procedures lcharacterization method, WSPnonconformance reporting, anhelp fulfill the requirements oThis report and its attachmentadequate implementation of ea

AK-2: Confirm that AKE and SPM training records and qualification cards are complete and that each individual’s training was conducted prior to them performing work on this waste stream. 

Carrie Johnson, AKE, 6/16/2011 Kevin Peters, AKE, 6/16/2011 Scott Smith, AKE, 6/22/2011 Steve Schafer, AKE, 6/16/2011 Barbara Broomfield, SPM, 11/2/2004 Adela Cantu, SPM, 11/4/2002 Jimmy D. Eastham, SPM, 5/12/2009 Jerry Fisher, SPM, 10/31/2013 Joshua Houghton, SPM, 5/31/2011 Rich Kantrowitz, SPM, 5/2/2006; Revised 5/6/2014 Jake Knox, SPM, 10/23/2013 David Moody, SPM, 6/24/2005; Revised 5/6/2014 Laura Nelson, SPM, 6/21/2010 Brandye Pyeatt, SPM, 8/27/2012 Mike Ramirez, SPM, 5/26/2009; Revised 5/6/2014 Beverly Schrock, SPM, 6/23/2010; Revised 2/5/2014 Carolina Soaterna, SPM, 5/31/2011 Andrew Stallings, SPM, 8/27/2012 Charles Turner, SPM, 4/19/2007; Revised 5/6/2014 Jim Vernon, SPM, 6/11/2009 Daniel Wade, SPM, 10/23/2013 Veronica Waldram, SPM, 8/4/2009 Roger Whiteaker, SPM, 5/3/2012 Rick Whiteley, SPM, 10/31/2013 CCP-QP-002, Revision 36, Assigned Reading Report, provided 4/24/2014 

The qualification cards indicatthe procedure in effect at the t

sign-off. EPA verified Kevin PJohnson’s, Steve Schafer’s anby interview during the inspectraining of remaining personneReading Reports. CCP implemented CCP-QP-0immediately prior to the start o

reviewed the Assigned Readin

Rev. 23, during this inspection revision in place at the time Eprovided) the Assigned ReadinSPMs Jim Eastham and Jim Vprevious year. CCP provided tbecause they signed various dof interest for this inspection. work for INL-CCP going forwassess their familiarity with cu
D-2 

EPA Inspection No.: INL-CC-2014 Contact-Handled Waste Insp

Technical Elements Objective Evidence Comm

CCP-QP-005, Revision 23, Assigned Reading Report, provided 4/24/2014 CCP-TP-002, Revision 26, Assigned Reading Report, provided 4/24/2014 CCP-TP-005, Revision 26, Assigned Reading Report, provided 4/24/2014 WP 15-GM1002, Revision 2, Assigned Reading Acknowledgement Report, provided 5/6/2014 

AK-3: Confirm that nonconformances are documented appropriately. 

NCR-INL-0097-013 NCR-INL-0343-013 NCR-INL-0351-013 NCR-INL-0007-014 NCR-INL-0293-014 NCR-INL-0294-014 NCR-INL-0300-014 

Example NCRs examined werappropriately dated form. 

CCP-TP-005 Implementation AK-4: Confirm that Attachment 1, Acceptable Knowledge Documentation Checklist, is complete. 

ID-AECHDM: CCP-TP-005, Revision 24, Attachment 1, Signed by Kevin Peters, 5/31/2013 ID-AECHHM: CCP-TP-005, Revision 24, Attachment 1, Signed by Kevin Peters, 5/31/2013 ID-SRP-S3000: CCP-TP-005, Revision 26, Attachment 1, Signed by Sheri Nance, 2/5/2014 

INL-CCP consistently produc

the proper form revision. The generated and while they meet requirements, they are not vervarious options to improve the 

AK-5: Confirm that Attachment 2, Record of Communication, is completed as necessary. 

ID-SRP-S3000: C154, C159, C170, C171 The Record of Communicatio

not mandatory. Example refercomplete although in different 

AK-6: Confirm that an Attachment 3, Acceptable Knowledge Source Document Summary, is complete for every source document. 

See reference list in Attachment J to this report All reviewed source documen

Attachment 3. 

AK-7: Confirm that Attachment 4, Acceptable Knowledge Information List, is complete and up to date. 

ID-AECHDM: CCP-TP-005, Revision 24, Attachment 4, Signed by Kevin Peters, 5/31/2013 ID-AECHDM: CCP-TP-005, Revision 24, Attachment 4, Signed by Kevin Peters, 5/31/2013 ID-SDA-DEBRIS, -SLUDGE, -SOIL: CCP-TP005, Revision 24, Attachment 4, Signed by Carrie Johnson, 5/30/2013 (three separate files) 

The SRP Att. 4 provided prior 

several different CCP-TP-005number headers. INL-CCP revportray a single revision numbof CCP-TP-005). 
D-3 

EPA Inspection No.: INL-CC-2014 Contact-Handled Waste Insp

Technical Elements Objective Evidence Comm

ID-SRP-S3000: CCP-TP-005, Revision 26, Attachment 4, Signed by Sherri Nance, 5/8/2014 

AK-8: Confirm that Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, and Packaging, is complete and up to date. 

ID-AECHDM, -AECHHM: CCP-TP-005, Revision 23, Attachment 6, Signed by Kevin Peters, 9/29/2011 (two separate files) ID-AECHDM, -AECHHM: WMP analysis memorandum, Signed by Kevin Peters, 3/23/2011 ID-SDA-DEBRIS, -SLUDGE, -SOIL: CCP-TP005, Revision 26, Attachment 6, Signed by Carrie Johnson, 5/8/2014 (three separate files) ID-SDA-DEBRIS, -SLUDGE, -SOIL: WMP analysis memorandum, Signed by Carrie Johnson, 5/8/2014 

Att. 6s and the WMP memora

revised as necessary when new 

established waste streams. INLmemorandum and three Att. 6include ARP V–VIII. 

AK-9: Confirm that Attachment 7, Radionuclides, is complete and up to date and that AK-NDA communication is appropriately documented. 

ID-AECHDM: CCP-TP-005, Revision 23, Attachment 7, Signed by Steve Schafer, 10/14/2011 ID-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), 8/13/2013 ID-AECHHM: CCP-TP-005, Revision 23, Attachment 7, Signed by Steve Schafer, 10/14/2011 ID-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), 10/27/2011 ID-SDA-DEBRIS, -SLUDGE, -SOIL: CCP-TP005, Revision 24, Attachment 7, Signed by Carrie Johnson, 5/15/2013 (three separate files) ID-SDA-DEBRIS, -SLUDGE, -SOIL: NDA memorandum, Signed by Carrie Johnson (AKE), John West (MCS EA), Bart Morales (MCS EA), Joe Wachter (MCS Technical Director) and Neil Dickes (CCP Project Office), 6/6/2013 

AKEs said that there is no set 

Att. 7s. The radionuclide infor

to bound the waste stream and information in the NDA memopractice, most AKEs update Amatch the AKSR and NDA mThe SDA NDA memorandum through ARP-VIII including n

but does not address the unusumay be in the waste if ARP Vinadvertently mixed with the Ryet required as the intent of w

these non-RFP waste, but futu

if assay finds the ARP-VIII w

radionuclides.

AK-10: Confirm that Attachment 8, Waste Containers List, is complete and up to date. 

ID-AECHDM: CCP-TP-005, Revision 24, Attachment 8, Signed by Kevin Peters, 5/31/2013 ID-AECHDM: CCP-TP-005, Revision 23, 

INL-CCP wrote the January 2memorandum to try to meet thcontainers to the waste stream 
D-4 

EPA Inspection No.: INL-CC-2014 Contact-Handled Waste Insp

Technical Elements Objective Evidence Comm

Attachment 8, Signed by Kevin Peters, 9/29/2011 ID-AECHDM: Waste Stream Container Evaluation Memorandum, Addition of 38 Containers to Waste Stream AECHDM-PK and ID-AECHDM, Signed by Kevin Peters, 1/16/2013, Draft revision provided5/7/2014 ID-RF-S3114: CCP-TP-005, Revision 23, Attachment 8, Signed by Scott Smith, 4/22/2013 ID-SRP-S3000: CCP-TP-005, Revision 26, Attachment 8, Signed by Scott Smith, 1/24/2014 ID-SRP-S3000: Memorandum of Evaluation of Additional Containers for Sludge Repackage Project (SRP) Waste Stream ID-SRP-S3000, Signed by Scott Smith, 11/18/2013 AKTSS 

ANL-E to INL) and the waste characterizing and emplacemememorandum did not clearly ccontainers were bound by the 

revised the memorandum to re

only and clarified that the concurrent AKSR. INL-CCP characterized over 3S3114 waste since May 2013, 

a new Att. 8 because all the nerepackaged from drums that wAtt. 8s. The AKTSS indicates that 1,5S3000 waste are fully charactecontrast to the Att. 8 which shstream as of 1/24/2014. This daggressive characterization sch

AK-11: Confirm that Attachment 10, Acceptable Knowledge Re-evaluation Checklist, is completed as necessary. 

N/A INL-CCP has not conducted a

the last inspection (May 2013)10 (AK re-evaluation) is not rediscrepancies or AK-PK discr

AK-12: Confirm that Attachment 11, Acceptable Knowledge Source Document Discrepancy Resolution, 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 adequ

AK-13: Confirm that Attachment 13, CCP Waste Stream 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), 10/21/2013 ID-RF-S3114: CCP-TP-005, Revision 24, Attachment 13, Lot 102, Signed by Roger Whiteaker (SPM) and Scott Smith (AKE), 5/2/2013 ID-RF-S3114: CCP-TP-005, Revision 25, Attachment 13, Lot 128, Signed by Steve Castro (SPM) and Scott Smith (AKE), 8/9/2013 ID-RF-S3114: CCP-TP-005, Revision 26, 

Characterization checklists ad
D-5 

EPA Inspection No.: INL-CC-2014 Contact-Handled Waste Insp

Technical Elements Objective Evidence Comm

Attachment 13, Lot 183, Signed by Roger Whiteaker (SPM) and Scott Smith (AKE), 3/10/2014 ID-SDA-SLUDGE: CCP-TP-005, Revision 24, Attachment 13, Lot 334, Signed by Beverly Schrock (SPM) and Carrie Johnson (AKE), 6/12/2013 ID-SRP-S3000: CCP-TP-005, Revision 26, Attachment 13, Lot 1 through Lot 23, numerous signatures, dated 2/21/2014 through 3/28/2014 

AK-14: Confirm that Attachment 14, CCP Acceptable Knowledge Accuracy Report, is completed annually and verify that the AK accuracy report memorandum is technically adequate. 

ID-AECHDM: AK Accuracy Lot 4, cumulative for Lots 1–4, 5/29/2014 ID-RF-3114: AK Accuracy Lots 101–183, cumulative for Lots 1–183, 5/29/2014 ID-SDA-SLUDGE, AK Accuracy Lots 314–333, cumulative for Lots 1–333, 6/13/2013 ID-SDA-DEBRIS, Lots 1-62, Prepared by J. Vernon, 5/20/2013 

AK accuracy reports are technAK accuracy is calculated by measurement data, long after t

filtered to remove troublesome other pre-screening methods. Tinitially included in a waste st

prior to the WIPP-certifiable cagainst AK accuracy. The AK 

used to evaluate the accuracy decision to include or exclude waste stream based on AK alo

AK-15: Confirm that Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form, is completed as necessary. 

N/A Att. 15 is only required for RH 

allowed to use it for CH waste

CCP AKEs have never preparstream. 

AK-16: Confirm that the AKSR is complete and accurately describes the subject waste. 

CCP-AK-INL-001, Revision 12 CCP-AK-INL-025, Revision 2 CCP-AK-INL-026, Revision 0 

AKSRs include all required co

19 and AK-21–AK-23 of this 

Waste Stream Definition and Waste Identification AK-17: Verify that all waste within the waste stream was generated from a single process/activity and that the generating process/activity is adequately described. 

ID-AECHHM, -AECHDM SDs: AE-P-095, P3001, P3002, P3003, P4002, P4003, P4005, U3003 and U3004 ID-SRP-S3000 SDs: C701, P507, P513, P542, P543, P544, P545, P546, P713, P714, P722, P723, P724 

ID-AECHHM, ID-AECHDMactivities conducted by the ANgenerated from laboratory and The WMO routinely comminggenerators in a single drum foID-SRP-S3000: Generated by wastes in drums with free wat
D-6 

EPA Inspection No.: INL-CC-2014 Contact-Handled Waste Insp

Technical Elements Objective Evidence Comm

Waste Stream BNINW216 and ID-RF-S3114 are treated and rS3000. 

AK-18: Verify that all waste within the waste stream is similar in material and physical form and that the expected physical parameters are adequately described. 

ID-AECHDM, -AECHHM SDs: C3002, C3003, C4004, DR3002, P3001, P3002, P3003, P4002, P4003, U3001, U3003, U3004, U4003, U4004, U4005 and U4010 ID-AECHDM, -AECHHM: CCP-TP-005, Revision 23, Attachment 6, Signed by Kevin Peters, 9/29/2011 (two separate files) ID-AECHDM, -AECHHM: WMP analysis memorandum, Signed by Kevin Peters, 3/23/2011 ID-SDA-DEBRIS, -SLUDGE, -SOIL: CCP-TP005, Revision 26, Attachment 6, Signed by Carrie Johnson, 5/8/2014 (three separate files) ID-SDA-DEBRIS, -SLUDGE, -SOIL: WMP analysis memorandum, Signed by Carrie Johnson, 5/8/2014 

ID-AECHDM: Contains organ

debris. ID-AECHHM: Contains mixegenerated during the neutraliz

aqueous and organic liquids orlaboratory and maintenance opID-SDA DEBRIS, ID-SDA-SCharacterized during VE of re

are divided into waste streams 

AK-19: Verify that the expected radiological characteristics are adequately described. 

ID-AECHDM, -AECHHM SDs: AE-I-201, C3004, C4005, U3002, U3003, U3005, U3006, U4003, U4011 and U4012 ID-SDA-DEBRIS, -SLUDGE, -SOIL: CCP-TP005, Revision 24, Attachment 7, Signed by Carrie Johnson, 5/15/2013 (three separate files) ID-SDA-DEBRIS, -SLUDGE, -SOIL: NDA memorandum, Signed by Carrie Johnson (AKE), John West (MCS EA), Bart Morales (MCS EA), Joe Wachter (MCS Technical Director) and Neil Dickes (CCP Project Office), 6/6/2013 ID-SRP-S3000: CCP-TP-005, Revision 26, Attachment 7, Signed by Scott Smith, 12/2/2013 ID-SRP-S3000: NDA memorandum, Signed by Scott Smith (AKE), John West (MCS EA), David Brasier (MCS EA), Joe Wachter (MCS Technical Director) and Neil Dickes (CCP Project Office), 11/11/2013 

ID-AECHHM, -AECHDM: Eon certified results for old AN

certified information for the cu

shipment from ANL-E); WMO 

TRU/Non-TRU and determine

present based on generator recstreams, prevalent radionuclid

239Pu, and the prevalent radion

and 239Pu. 

ID-SDA DEBRIS, ID-SDA-SThe ARP retrieval activities tawaste with a defined radiologicontains waste with unique radincluding 232Th, 137Cs and 226R

are in targeted waste and are thretrieved waste stream. ID-SRP-S3000: Composed of potentially containing WG Pu
D-7 

EPA Inspection No.: INL-CC-2014 Contact-Handled Waste Insp

Technical Elements Objective Evidence Comm

AK-20: Verify that waste containers are traceable from 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, RTR13-00129 NDA BDR Nos. ASY11-00880, INNDAS120025, INNDAS120034, INNDAS130054, INNDAS130055, INNDAS140017, INNDAS140051, INNDAW120021, INNDAW120025, INNDAW140037 ID-SRP-S3000 SDs: ID-P249, ID-P287, ID-P396, ID-P421, ID-P422, ID-P426, ID-P452, ID-P453 SRP Spreadsheet tracking weekly input, by source drum, to the SRP repackaging process AMWTP Offsite Waste Stream Profile, AECHDMPK, 4/1/2013 Container travelers from AMWTP to INL-CCP 

Waste is adequately traceable characterization. ID-RF-S3114: Drum Nos. SRID-AECHDM: Drum Nos. RWSDA: Drum Nos. ARP70264, ARP71044 ID-SRP-S3000: Drum Nos. SRSRP21731 

Land Withdrawal Act Requirements AK-21: Verify that all of the waste in the waste stream is defense in origin. 

ID-AECHDM, -AECHHM: CCP-AK-INL-025, Revision 2 SDs: P3001, P3002, P3003, P3004, P4001, P4002, P4003, P4005, U4003 and U4004 ID-SRP-S3000: CCP-AK-INL-026, Revision 0 SDs: C702, P004, P053 

Waste Streams ID-AECHHM eligible for disposal at WIPP a

waste stream generated “in pa

activities. 

ID-SRP-S3000 waste originat

defense origin. 

AK-22: Verify that none of the waste in the waste stream is HLW. 

ID-AECHDM, -AECHHM: CCP-AK-INL-025, Revision 2 SDs: U3003, U3004, U4003 and U4004 ID-SRP-S3000: CCP-AK-INL-026, Revision 0 SDs: C702, P004, P053, P539 and P702 

Waste Streams ID-AECHHM contain some waste from reseaseparations; however, these re

were not production operationreprocessing of constituent elethe CH waste does not include products. Waste Stream ID-SRP-S3000 waste that is not HLW or SNF

AK-23: Verify that none of the waste in the waste stream is SNF. 

ID-AECHDM, -AECHHM: CCP-AK-INL-025, Revision 2 

Waste Streams ID-AECHHM contain any of the following: t
D-8 

EPA Inspection No.: INL-CC-2014 Contact-Handled Waste Insp

Technical Elements Objective Evidence Comm

SDs: U3003, U3004, U4003 and U4004 ID-SRP-S3000: CCP-AK-INL-026, Revision 0 SDs: C702, P004, P053, P539 and P702 

test specimens that were mana

cell waste, test residues, test mfragments from the fuel pin teWaste Stream ID-SRP-S3000 waste that is not HLW or SNF

Waste Stream Certification AK-24: Verify that the WSPF is complete and accurate. 

WSPF, Waste Stream ID-AECHDM, Revision 0, 12/7/2011 WSPF, Waste Stream ID-AECHHM, Revision 1, 1/23/2014 WSPF, Waste Stream ID-SRP-S3000, Revision 0, 2/13/2014 

INL-CCP SPM signed the WSAECHDM on 12/7/2011, but f

On 5/6/2014, a current INL-Cto include the original signaturdiscusses the procedures used the waste. In 2011, INL-CCP this waste stream. Therefore it WSPF list only the CCP RTR AMWTP is performing all RTprocedure. If a WSPF revision Line 28 with also be modified AMWTP procedures, as are ciAECHHM WSPF. 

AK-25: Confirm that a characterization information summary and summation of aspects are included in the WSPF package and are complete and accurate. 

ID-AECHDM: WSPF package, Revision 0, 12/7/2011 ID-AECHHM: WSPF package, Revision 1, 1/23/2014 ID-SRP-S3000: WSPF package, Revision 0, 2/13/2014 

WSPF packages are complete 

AK-26: Confirm that a characterization information summary is adequately completed for each characterization lot. 

ID-AECHDM: Lot 4, 10/21/2013 ID-RF-S3114: Lot 104, 5/13/2013; Lot 115, 6/26/2013, Lot 138, 10/3/2013; Lot 183, 3/10/2014 ID-SRP-S3000: Lot 2, 2/21/2014; Lot 12, 3/3/2014; Lot 23, 3/28/2014 

ID-AECHDM: INL-CCP comcampaign into one characterizID-RF-S3114: INL-CCP complast inspection. ID-SRP-S3000: INL-CCP com

inspection. All reviewed CISs are compleplace for an AKE review signprocedural requirement for thiAKEs do not review CH CISs
D-9 

EPA Inspection No.: INL-CC-2014 Contact-Handled Waste Insp

Technical Elements Objective Evidence Comm

Tier 2 Reporting AK-27: Verify that INL-CCP has reported to EPA completion or revision of the AK-NDA memoranda. 

FY2013 3rd Quarter T2 report 

FY2013 4th Quarter T2 report FY2014 1st Quarter T2 report 

FY2014 2nd Quarter T2 report 

ID-SDA-DEBRIS, -SLUDGEmemorandum (6/6/2013) repo

T2 report. ID-SRP-S3000: AK-NDA mereported on FY2014 1st Quarte

ID-AECHDM: AK-NDA memshould have been reported on report, but was not. 

AK-28: Verify that INL-CCP has reported to EPA completion or revision of AK accuracy reports annually, at a minimum. 

FY2013 3rd Quarter T2 report 

FY2013 4th Quarter T2 report FY2014 1st Quarter T2 report 

FY2014 2nd Quarter T2 report 

2013 AK accuracy reports for DEBRIS, ID-SDA-SLUDGE, S5300A, ID-RF-S3114 and IDFY2013 3rd Quarter T2 report. 

AK-29: Verify that INL-CCP has reported to EPA completion or revision of AK-AK and AKNDA/NDE DR reports. 

FY2013 3rd Quarter T2 report 

FY2013 4th Quarter T2 report FY2014 1st Quarter T2 report 

FY2014 2nd Quarter T2 report 

DR701 reported on FY2014 1

AK-30: Verify that INL-CCP has reported to EPA completion or revision of WSPFs, including updates or additions to waste streams within an approved waste category. 

FY2013 3rd Quarter T2 report 

FY2013 4th Quarter T2 report FY2014 1st Quarter T2 report 

FY2014 2nd Quarter T2 report 

Initial issue ID-SRP-S3000, RAECHHM, Rev. 1, WSPF rep

Quarter T2 report. 

AK-31: Verify that INL-CCP has reported to EPA completion or revision of AKSRs. 

FY2013 3rd Quarter T2 report 

FY2013 4th Quarter T2 report FY2014 1st Quarter T2 report 

FY2014 2nd Quarter T2 report 

CCP-AK-INL-001, Rev. 12, a2, reported on FY2013 3rd Qua

CCP-AK-INL-026, Rev. 0, rep

Quarter T2 report. 

AK-32: Verify that INL-CCP has reported to EPA changes in load management status of approved waste streams. 

FY2013 3rd Quarter T2 report 

FY2013 4th Quarter T2 report FY2014 1st Quarter T2 report 

FY2014 2nd Quarter T2 report 

ID-SRP-S3000 load managemFY2014 1st Quarter T2 report. 

AK-33: Verify that INL-CCP has provided to EPA a list of active INL-CCP CH AKEs and SPMs for the previous quarter. 

FY2013 3rd Quarter T2 report 

FY2013 4th Quarter T2 report FY2014 1st Quarter T2 report 

FY2014 2nd Quarter T2 report 

List first reported on FY2014 

CCP SPM said that the requirecontinued compliance inspectiwork instructions until spring 2nd Quarter T2 report was the 

report this list. 
D-10 

ATTACHMENT D.2: AK CONTINUED COMPLIANCE INSPECTION CHECKLIST: REMOTE-HA

EPA Inspection No.: INL-CC-2014 Remote-Handled Waste Insp

Technical Elements Objective Evidence Comm

GeneralAK-1: Confirm that AK, training and nonconformance procedures adequately reflect the requirements of 40 CFR 194. 

See list of procedures in Attachment D.1, AK-1 CCP-TP-506, Revision 4, preparation of RH CRR 

This report and its attachment

adequate implementation of ea

AK-2: Confirm that AKE and SPM training records and qualification cards are complete and that each individual’s training was conducted prior to them performing work on this waste stream. 

Kevin Peters, AKE, 6/16/2011 Scott Smith, AKE, 6/22/2011 Steve Schafer, AKE, 6/16/2011 Carrie Johnson, AKE, 6/16/2011 Joshua Houghton, RH SPM, 8/19/2013 Irene Joo (Quintana), RH SPM, 9/17/2009 Rich Kantrowitz, RH SPM, 10/29/2012 David Moody, RH SPM, 8/28/2013 Laura Nelson, RH SPM, 6/21/2010 Charles Turner, RH SPM, 8/15/2013 See list of Assigned Reading Reports in Attachment D.1, AK-2 CCP-QP-005, Revision 24, Assigned Reading Report, Joshua Houghton, provided 5/8/2014 CCP-TP-506, Revision 4, Assigned Reading Report, provided 5/6/2014 DOE WIPP-02-3214 (WCPIP), Revision 3, Assigned Reading Report, provided 4/24/2014 

The qualification cards indicatthe procedure in effect at the t

sign-off. EPA verified Kevin PSmith’s skills by interview duof the other INL-CCP RH AKverified through review of the 

CCP released CCP-QP-005, R

the continued compliance insp24 for adequacy, but did not redocumentation that all AKEs athe new revision. EPA will revReport for Rev. 24 (or the curr

during a future inspection or T

CCP-managed sites. Joshua Houghton was missing 

23, Assigned Reading Report; 

that Mr. Houghton is familiar procedure. 

AK-3: Confirm that nonconformances are documented appropriately. 

NCR-RHINL-0215-14 NCR-RHINL-0355-14 NCR-RHINL-0438-13 

Example NCRs examined werappropriately dated form. 

CCP-TP-005 Implementation AK-4: Confirm that Attachment 1, Acceptable Knowledge Documentation Checklist, is complete. 

ID-HFEF-S5400-RH: CCP-TP-005, Revision 26, Attachment 1, signed by Scott Smith, 5/8/2014 

Att. 1 provided prior to the insand did not include more recenprovided May 8 included addi

AK-5: Confirm that Attachment 2, Record of Communication, is completed as necessary. 

N/A EPA did not review any sourc

should have been records of co

AK-6: Confirm that an Attachment 3, Acceptable Knowledge Source Document Summary, is complete 

See reference list in Attachment J to this report All reviewed source documen

Attachment 3. 
D-11 

EPA Inspection No.: INL-CC-2014 Remote-Handled Waste Insp

Technical Elements Objective Evidence Comm

for every source document. AK-7: Confirm that Attachment 4, Acceptable Knowledge Information List, is complete and up to date. 

ID-HFEF-S5400-RH: CCP-TP-005, Revision 24, Attachment 4, Signed by Scott Smith, 2/27/2013 ID-HFEF-S5400-RH: CCP-TP-005, Revision 26, Attachment 4, Signed by Scott Smith, 5/8/2014 

The Att. 4 provided prior to th

5/7/2014 and did not include aback of the AKSR. INL-CCP and this version included the m

AK-8: Confirm that Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, and Packaging, is complete and up to date. 

N/A The WMPs for both waste stre

the last time EPA reviewed co

AK-9: Confirm that Attachment 8, Waste Containers List, is complete and up to date. 

ID-ANLE-S5000: CCP-TP-005, Revision 24, Attachment 8, Signed by Scott Smith, 6/4/2013 ID-ANLE-S5000: Waste Stream Container Evaluation Memorandum, Revision 1, Evaluation of Drums from Repack of ANL-E High Gamma TRU Waste Containers at INL in Waste Stream IDANLE-S5000, Signed by Scott Smith, 4/22/2013 ID-HFEF-S5400-RH: CCP-TP-005, Revision 22, Attachment 8, Signed by Scott Smith, 5/17/2011 ID-HFEF-S5400-RH: C4117, C4128 

ID-ANLE-S5000: EPA limite

to 51 canisters unless addition

INL-CCP has not provided anexplained that all of the contaistream since May 2013 are da

INL-CCP from some of the 51 waste in Waste Stream ID-ANthe daughter containers to Att. ID-HFEF-S5400-RH: The com

container memoranda providecontainers in the waste stream generated C4128. The AKTSS 

more recent snapshot of curren

AK-10: Confirm that Attachment 10, Acceptable Knowledge Re-evaluation Checklist, is completed as necessary. 

N/A None required at this time. 

AK-11: Confirm that Attachment 11, Acceptable Knowledge Source Document Discrepancy Resolution, is completed as necessary. 

ID-ANLE-S5000: DR010 Discrepancy resolution is adeq

AK-12: Confirm that Attachment 13, CCP Waste Stream 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), 7/2/2013 ID-ANLE-S5000: CCP-TP-005, Revision 25, Attachment 13, Lot 38, Signed by Laura Nelson (SPM) and Scott Smith (AKE), 8/12/2013 ID-ANLE-S5000: CCP-TP-005, Revision 26, Attachment 13, Lot 39, Signed by Laura Nelson (SPM) and Scott Smith (AKE), 9/5/2013 

Characterization checklists are 

none required AK re-evaluatio
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EPA Inspection No.: INL-CC-2014 Remote-Handled Waste Insp

Technical Elements Objective Evidence Comm

ID-ANLE-S5000: CCP-TP-005, Revision 26, Attachment 13, Lot 40, Signed by Laura Nelson (SPM) and Scott Smith (AKE), 4/15/2014 ID-HFEF-S5400-RH: CCP-TP-005, Revision 26, Attachment 13, Lot 23, Signed by Laura Nelson (SPM) and Scott Smith (AKE), 4/7/2014 

AK-13: Confirm that Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form, is completed as necessary. 

N/A None prepared or required. 

AK-14: Confirm that the AKSR is complete and accurately describes the subject waste. 

CCP-AK-INL-500, Revision 11 CCP-AK-INL-580, Revision 4 

INL-CCP prepared the most re

waste streams in response to Echange evaluations. The AKSmodifications. 

Waste Stream Definition and Waste Identification AK-15: Verify that all waste within the waste stream was generated from a single process/activity. 

N/A The waste stream definitions h

last T1 evaluations. This aspecchange evaluation. 

AK-16: Verify that all waste within the waste stream is similar in material and physical form. 

N/A The waste stream definitions h

last T1 evaluations. This aspecchange evaluation. 

AK-17: Verify that all waste within the waste stream has similar radiological properties. 

N/A The waste stream definitions h

last T1 evaluations. This aspecchange evaluation. 

AK-18: Verify that waste containers are traceable from retrieval through CCP’s EPA-approved characterization process? 

ID-ANLE-S5000: Drum Nos. ANLE3D-1, ANLE43L and ANLE45A NDE BDR Nos.: INLRHVE13001, INLRHRTR14002 DTC BDR Nos. INLRHDTC13010, INLRHDTC14002 AKTSS SDs: U552, U4032 ID-HFEF-S5400-RH: Drum Nos. B521A, B521B, FC010012-3 and IDAWANL870203C NDE BDR Nos. INLRHRTR10013, INLRHRTR13006, INLRHRTR14003 

Sealion database printout, IWT

disposal requests, and waste c

to document the traceability oHFEF-5 or sodium loop safety subsequently placed in carbon configurations. INL-CCP demForm 880 documentation of cacans into liners as documented (Reference U552 for both wastransfer and repackaging of co
D-13 

EPA Inspection No.: INL-CC-2014 Remote-Handled Waste Insp

Technical Elements Objective Evidence Comm

DTC BDR Nos. INLRHDTC1006, INLRHDTC10016, INLRHDTC12007, INLRHDTC14003 AKTSS SDs: C4117, U552, U992, U484, P848 

Land Withdrawal Act Requirements AK-19: Verify that all of the waste in the waste stream is defense in origin. 

N/A The waste stream definitions h

last T1 evaluations. This aspecchange evaluation. 

AK-20: Verify that none of the waste in the waste stream is SNF. 

N/A The waste stream definitions h

last T1 evaluations. This aspecchange evaluation. 

AK-21: Verify that none of the waste in the waste stream is HLW. 

N/A The waste stream definitions h

last T1 evaluations. This aspecchange evaluation. 

Waste Stream Certification AK-22: Confirm that the certification plan is complete and adequately describes the role of AK inthe waste characterization methodology. 

CCP-AK-INL-582, Revision 4 CCP-RC-INL-581, Revision 0 CCP-AK-INL-580, Revision 4 

The certification plan does not 

AKSR with regard to the num

stream. INL-CCP indicated th

plan is ongoing and the noted description of AK’s role in the methodology as presented in t

AK-23: Verify that the WSPF is complete and accurate. 

N/A Waste characterization activiti

streams have not required revi

AK-24: Confirm that a characterization information summary is adequately completed for each characterization lot. 

ID-ANLE-S5000: Lot 37, Revision 1, 7/2/2013; Lot 38, 8/12/2013; Lot 39, 9/5/2013 ID-HFEF-S5400-RH: Lot 22, Revision 1, 7/10/2013; Lot 24, Draft, 3/18/2014 

CIS are adequately completed

AK-25: Confirm that a characterization reconciliation report is adequately completed for each 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 5/7/2014 ID-HFEF-S5400-RH: Lot 22, 6/27/2013; Lot 24, Draft provided 4/24/2014 

ID-ANLE-S5000: INL-CCP rcover pages to use the correct The cover page template did n

Rev. 3; therefore only the revileft corner needed revision. Al

CRR were completed using thID-HFEF-S5400-RH: The Dra
D-14 

EPA Inspection No.: INL-CC-2014 Remote-Handled Waste Insp

Technical Elements Objective Evidence Comm

provided for informational purINL CCP representatives that most current AKSR that addretypographical errors. 

AK-26: Confirm that the AK accuracy report memorandum is technically adequate. 

ID-ANLE-S5000: Revised AK Accuracy Lots 1–36, 5/28/2013 ID-ANLE-S5000: AK Accuracy Lots 1–40, 5/5/2014 ID-HFEF-S5400-RH: AK Accuracy, Lots 1–23, 5/5/2014 

AK accuracy reports are technSee Attachment D.1, AK-14. 

Data Quality Objectives AK-27: Identify how INL-CCP will meet the DQO for defense waste, HLW and SNF determination. 

N/A INL-CCP’s plans to meet the D

EPA’s last evaluation of these 

AK-28: Identify how INL-CCP will meet the DQOs for radioactive properties: TRU waste determination, RH waste determination and activity determination. 

N/A INL-CCP’s plans to meet the D

EPA’s last evaluation of these 

AK-29: Identify how INL-CCP will meet the DQOs for physical properties: liquids and physical form.

N/A INL-CCP’s plans to meet the D

EPA’s last evaluation of these 

Tier 2 Reporting AK-30: Verify that INL-CCP has reported to EPA completion or revision of AKSRs and certification plans. 

FY2013 3rd Quarter T2 report 

FY2013 4th Quarter T2 report FY2014 1st Quarter T2 report 

FY2014 2nd Quarter T2 report 

INL-CCP reported: CCP-AK-FY2013 4th Quarter T2 report; 

and CCP-AK-INL-582, Rev. 4

report; CCP-AK-INL-580, Re4, CCP-AK-INL-592, Rev. 2, and CCP-AK-INL-602, Rev. 2

report. 

AK-31: Verify that INL-CCP has reported to EPA completion or revision of CCP-TP-005, Attachment 4s that reflect the updated AKSR Source Document Reference Lists. 

FY2013 3rd Quarter T2 report 

FY2013 4th Quarter T2 report FY2014 1st Quarter T2 report 

FY2014 2nd Quarter T2 report 

INL-CCP revised Att. 4 for WRH during this inspection. EPnotification on the FY2014 3rd 

AK-32: Verify that INL-CCP has reported to EPA completion or revision of the WSPF, including change notices, and the associated documentation. 

FY2013 3rd Quarter T2 report 

FY2013 4th Quarter T2 report FY2014 1st Quarter T2 report 

FY2014 2nd Quarter T2 report 

INL-CCP did not revise or gen

May 2013–May 2014 time per
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EPA Inspection No.: INL-CC-2014 Remote-Handled Waste Insp

Technical Elements Objective Evidence Comm

AK-33: Verify that INL-CCP has reported to EPA completion or revision of AK accuracy reports annually, at a minimum. 

FY2013 3rd Quarter T2 report 

FY2013 4th Quarter T2 report FY2014 1st Quarter T2 report 

FY2014 2nd Quarter T2 report 

INL-CCP reported AK accuraWaste Streams ID-ANLE-S50the FY2013 4th Quarter T2 rep

2014 AK accuracy reports (thainspection) on the FY2014 3rd 

AK-34: Verify that INL-CCP has reported to EPA completion or revision of DRs and nonconformance reports. 

FY2013 3rd Quarter T2 report 

FY2013 4th Quarter T2 report FY2014 1st Quarter T2 report 

FY2014 2nd Quarter T2 report 

INL-CCP did not generate any AK for the examined waste str

May 2014 time period. 

AK-35: Verify that INL-CCP has reported to EPA completion or revision of AK documentation as a result of WCPIP revisions (e.g., CRR). 

N/A CCP did not revise the WCPIP 

2014 time period; therefore, n

result of WCPIP revision. 

AK-36: Verify that INL-CCP has reported to EPA completion or revision of a CSSF for each of the RHcontainers identified as CH, based on measured doserates that present NDA results for assayed containers. 

N/A CSSF is not applicable to eithe

streams. 

AK-37: Verify that INL-CCP has reported to EPA notification of the intent to add containers to an approved waste stream. 

N/A INL-CCP did not add new con

examined except those from reapproved containers and those evaluation. 

AK-38: Verify that INL-CCP has provided to EPA a list of active INL-CCP RH AKEs and SPMs for the previous quarter. 

FY2013 3rd Quarter T2 report 

FY2013 4th Quarter T2 report FY2014 1st Quarter T2 report 

FY2014 2nd Quarter T2 report 

Not reported as required. The INL-CCP SPM said that t2013 continued compliance ininto his work instructions in spthe list of RH AKEs and SPM

T2 report. 
E-1 

ATTACHMENT E.1: NDA CONTINUED COMPLIANCE INSPECTION CHECKLIST: W

EPA Inspection No.: INL-CC-2014 Waste Assay Gamma Spectrometer Insp

Technical Elements Objective Evidence Ad

General WAGS-1: Confirm the NDA system is the WAGS, its location and number. 

Located in Building WMF-610 at INL RWMC. The WAGS has no other name or location designations. 

EPA inspeclocated in Bthe previou

WAGS-2: Describe the WAGS. The WAGS utilizes six high-resolution BEGe gamma detectors, a drum 

turntable and a shielded enclosure. The system has thee calibrations that are approved for use by EPA. 

N/A 

WAGS-3: Identify the consensus standards that were used for the system calibration 

ASTM C-1030, C-1133, C-1215, E-181. CCP-INL-WAGS-003, Revision 0. 

As stated in 1, CCP-INLWAGS-00during inte

WAGS-4: Describe the system’s operational history since the baseline approval. 

The WAGS assay system has been in operation supporting the work performed by INL-CCP since 4/26/2005. During this time, various QC criteria have been monitored to verify the continued acceptable performance of the system. 

As stated in 1, CCP-INLWAGS-00during inte

WAGS-5: Identify the container types assayed on the WAGS 

The WAGS may assay 55-gallon drums only. Visual insp

larger than by the instr

WAGS-6: Identify the period of performance relevant to the WAGS and the number of BDRs and waste containers this system assayed during the period. 

From June 7, 2013, to April 30, 2014, the WAGS assayed 1,378 drums 

contained in 114 BDRs. The WAGS can assay a maximum of 17 drums each day, currently performs14 assays per day on the average. 

As stated binspection. 

WAGS-7: Confirm that the WAGS is able to report quantitative values for the WIPP-tracked radionuclides 

Direct Measurements: 239Pu, 241Am, 233U, 235U, 238U and 137Cs. 

Isotopic Fractions: 238Pu, 240Pu, 241Pu, 242Pu by correlation and 241Am 

relative to Pu. Radionuclides by Scaling: 90Sr and 234U. 

CCP-INL-WAGS-003, Revision 0. 

As stated in 1, CCP-INLWAGS-00NDA perso

WAGS-8: Confirm the WAGS’s calibration of record. 

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 inspection. 

WAGS-9: Identify the procedures that govern this function and where the results of these calculations 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 procrevisions. Cand easily operator sta
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EPA Inspection No.: INL-CC-2014 Waste Assay Gamma Spectrometer Insp

Technical Elements Objective Evidence Ad

WAGS-10: Confirm that the methods used to derive the isotopic contribution for unmeasured radionuclides are MGA and MGA-U. 

MGA and MGA-U are integral parts of the WAGS operation as shown in 

CCP-TP-019, Operating Procedure (Revision 6, 4/2013). 

Confirmed CCP WAGinspection. 

WAGS-11: Confirm the WAGS operational range with respect to matrix (density) and activity. 

~0.010 g to 200 g total Pu (calibration-based and administrative), limited by LLD and system dead time. Calibration assumes that the matrices consists of materials that are Z < 15. Waste matrices outside density range 

require expert review. 

EPA confirpersonnel. previously 

Calibration Verification and ConfirmationWAGS-12: Identify the date of the last calibration verification. Have any others been completed in the last year? 

INL-CCP performed the last calibration verification on April 30, 2014, after replacing the DSA power supply for detector DET2NM. The calibration verification is documented in CCP-INL-WAGS-14-003. 

INL-CCP also performed a calibration verification following replacement 

of the DSA power supply for detector DET1INT. This calibration verification is documented in CCP-INL-WAGS-14-001. 

Confirmed the inspecteach calibrverificationadequate dfunctioning 

WAGS-13: Confirm the pedigree of all radionuclide standards that were used for calibration 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 Attachment 1 of the respective documents. 

EPA reviewfound in CINL-WAGWAGS-00independenuse for the 

WAGS-14: Requirements for accuracy and precision must be met, as specified in DOE/WIPP-02-3122, Appendix A, Table A-3.2 for calibration verifications. 

The calibration verification results are contained in Section 5 of CCP-INLWAGS-001, Revision 1, Section 5 of CCP-INL-WAGS-08-002 and 

Section 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 afor all calib

WAGS-16: The 133Be transmission source has a ~10-year half-life. When was the count rate last reevaluated in the system? 

INL-CCP installed the sources in January 2009 and evaluated them in July 2011 and July 2013. This is documented in CCP-INL-WAGS-13-002. Reevaluation is prompted when the counts start to fall below the boundary conditions due to the decay of 133Ba. 

Confirmed the inspectthey have nsource, but be replaced 

LLD WAGS-17: Confirm that the LLD for the WAGS has been determined. 

The LLD is documented in Section 6 of CCP-INL-WAGS-001, Revision 1, Section 6 of CCP-INL-WAGS-08-002 and Section 5 of CCP-INLWAGS-003, Revision 0. All transmission-corrected LLD results indicate that the instrument is able to discriminate TRU and Non-TRU wastes at 100 nCi/g TAAC, with the exception of 241Am in a plastic foam matrix 

drum. 

Confirmed CCP WAGinspection. 
E-3 

EPA Inspection No.: INL-CC-2014 Waste Assay Gamma Spectrometer Insp

Technical Elements Objective Evidence Ad

WAGS-18: Confirm if the WAGS is used to discriminate TRU/non-TRU wastes at the 100 nCi/g criterion and that it has the required sensitivity. 

The WAGS can discriminate TRU and Non-TRU waste for all measured radionuclides 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 is 241Am, which, if indicated but not reported in a drum with a density less than 0.44 kg/L, is quantified using higher energy gamma lines (662 and 722 keV). 

Total nCi/g the BDR asseveral instthe BDRs wnCi/g. INLwill be load 

WAGS-19: Identify any/all instances where an LLD value for a non-measured radionuclide is 

not provided based on a lack of technical feasibility. 

Because an LLD is a measurement-based parameter, it is not technically feasible to calculate for radionuclides that are not directly measured. Pu isotopes 238Pu, 240Pu and 242Pu are not usually directly measured and are 

derived by ratios to measured 239Pu. The reporting threshold for 90Sr is 

based on the reported 137Cs LLD using an activity ratio determined from 

AK NDA memoranda. INL-CCP states that it is not technically feasible to provide an LLD equivalent for 234U and that it is derived by an algorithm 

based on measured values of 235U, 238U and 238Pu. 

This is conINL-WAGCCP-INL-Wof CCP-IN

Quality Control WAGS-20: All operators have current CCP training as verified on LOQI. 

LOQI provided on 5/7/2014 (dated 5/1/2014) contains 11 operators, all with current training. 

EPA verifithe LOQI mlogbook. Nhas expandanticipation increase ththis will be

WAGS-21: Confirm the WAGS’s status with respect to the CBFO NDA PDP and last cycle. 

The WAGS successfully participated in drum Cycle 20 of the CBFO NDA PDP in July 2013. Cycle 21A is scheduled to begin in May 2014. 

EPA verifiin the PDP 

WAGS-22: All WAGS data must be reviewed and approved by qualified personnel. Identify the name and function of the individuals performing technical 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 individreview are 
E-4 

EPA Inspection No.: INL-CC-2014 Waste Assay Gamma Spectrometer Insp

Technical Elements Objective Evidence Ad

WAGS-23: Identify any system wide NCRs within the last year. 

There have been 4 NCRs on the WAGS in the last year: NCR-INL-066-13. NCR-INL-071-13 NCR-INL-005-14 NCR-INL-112-13 

Confirmed CCP persoreceived a (excludes cthem to adeprocess. 

TMU WAGS-24: Identify any changes to the method or details of the TMU calculation since baseline. 

INL-CCP did not make any changes to the TMU since EPA’s last inspection. 

Confirmed CCP perso

WAGS-25: Evaluate the magnitude of the TMU values observed in the WAGS BDRs that were examined during this inspection. 

The TMU for the WAGS is documented in CCP-INL-WAGS-002, Total 

Measurement Uncertainty for the WAGS System, dated April 20, 2005. This document does not have a revision number. The components of 

uncertainty included in the TMU determination consist of calibration 

source uncertainties, counting statistics, self-absorption effects, matrix 

nonhomogeneities, nonuniform source distributions and isotopic measurement uncertainties. The software for TMU calculations is embedded in NDA 2000. CCP-INL-WAGS-002 calls for administrative procedures that would define a minimum fill-height requirement to reduce the potential for increased uncertainties due to end effects. TMU values in BDRs are generally consistent with expectations. 

Confirmed CCP perso

Background and Performance Checks WAGS-26: Confirm that WAGS background measurements have been taken daily. 

Confirm that WAGS background measurements have been taken daily. EPA confir

interviews logbook enEPA to revthese meas

WAGS-27: Assess how often background radiation was problematic to the extent that measurement personnel had to make adjustments.

WAGS operators did not observe any instances of problematic backgrounds in the last year. 

EPA confirwith NDA 

WAGS-28: Confirm that system performance checks have been performed at least once per operational day. Confirm that performance checks include gamma and neutron efficiency, matrix correction checks, and gamma peak position and resolution checks. 

WAGS operators conduct performance checks once per day as stated in CCP-TP-019, Revision 6. 

EPA confirinterviews logbook enEPA to revthese check
E-5 

EPA Inspection No.: INL-CC-2014 Waste Assay Gamma Spectrometer Insp

Technical Elements Objective Evidence Ad

Data Management WAGS-29: WAGS BDRs contain: • Testing facility name, testing batch number, 

container numbers, and signature of the SPM or designee 

• Table of contents 

• Background and performance check data or 

control charts for the relevant time period 

• Separate testing report sheets for each 

container 

EPA reviewed WAGS BDR Nos. INNDAW130104 and INND140033 and found them to contain appropriate information. 

N/A 

WAGS-30: WAGS RDSs must include: • Title “Radioassay Data Sheet” 

• Method/procedure used 

• Date of radioassay 

• Activities and associated TMU for individual 

radionuclides 

• TAAC and its associated TMU 

• Operator and reviewer signatures 

EPA reviewed WAGS BDR Nos. INNDAW130104 and INND140033 and 

found that each drum contained in the two BDRs had an RDS containing the correct elements. 

N/A 
E-6 

ATTACHMENT E.2: NDA CONTINUED COMPLIANCE INSPECTION CHECKLIST: S

EPA Inspection No.: INL-CC-2014 Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer Insp

Technical Elements Objective Evidence A

GeneralSGRS-1: Confirm the NDA system is the SGRS, its location and number. 

Located in Building WMF-610 at INL RWMC. EPA inspe

located in Bthe previou

SGRS-2: Describe the SGRS. The SGRS is a gamma-based system that uses four high-resolution BEGe 

gamma detectors, a turntable, shielded enclosure, and supporting electronics. The SGRS performs quantitative assays and corrects the summed gamma peaks for attenuation using a multi-curve calibration that computes efficiency as a function of waste density and photon energy. A pluser performs live-time corrections and MGA/MGA-U determine isotopics from the same spectra. NDA EA applies default isotopics when measured results are not useable. The four gamma detectors are arranged vertically and acquire spectra for all segments simultaneously. The system runs NDA 2000 as well as MGA and MGA-U. The SGRS derives a value for 242Pu by correlation, and determines 90Sr by application of a scaling 

factor based on 137Cs. 234U is quantified based on measured values for 235U 

and 238U. 

N/A 

SGRS-3: Identify the consensus standards that were 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 i

2, and confNDA perso

SGRS-4: Describe the system’s operational history since the last EPA inspection. 

Since the 2013 EPA inspection, INL-CCP replaced DETA1 and replaced the steel door bearings because of hinge wear caused by the weight of the 

door. INL-CCP performed calibration verifications following both changes (CCP-INL-SGRS-13-004 and CCP-INL-SGRS-14-001, respectively) and determined that a new calibration was not needed in either case. 

As stated i2, and confNDA perso

SGRS-5: Identify the container types assayed on the SGRS. 

The SGRS can only assay 55-gallon drums. Visual insp

larger than by the instr

SGRS-6: Identify the period of performance relevant to this application of the SGRS. Since this time, identify the number of waste containers this system has assayed and then number of BDRs assembled. 

From June 7, 2013, to April 30, 2014, the SGRS assayed 4,095 drums contained in 155 BDRs. The SGRS can assay a maximum of 36 drums each day with current operational hours. The SGRS currently assays 32 

drums per day on average. 

NDA persooperators abecause CCshifts to in
E-7 

EPA Inspection No.: INL-CC-2014 Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer Insp

Technical Elements Objective Evidence A

SGRS-7: Confirm that the SGRS is able to report quantitative values for the WIPP-tracked radionuclides 

Direct Measurements: 239Pu, 241Am, 233U, 235U, 238U and 137Cs. 

Isotopic Fractions: 238Pu, 240Pu, 241Pu, 242Pu by correlation and 241Am 

relative to Pu. Radionuclides by Scaling: 90Sr and 234U. 

As stated i2. EPA alspersonnel d

SGRS-8: Confirm the SGRS’s calibration of record. 

The calibration of record is documented in CCP-INL-SGRS-001, Revision 2. This is the same calibration document that EPA reviewed during the most recent SGRS T1 approval in February 2013. 

Confirmed inspection. 

SGRS-9: Identify the procedures that govern this function and where the results of these calculations 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 procrevisions. Cand easily operator st

SGRS-10: Confirm that the methods used to derive the isotopic contribution for unmeasured radionuclides are MGA and MGA-U. 

MGA and MGA-U are integral parts of the SGRS operation as shown in 

CCP-TP-115, Operating Procedure (Revision 6, 4/2013). Interviews with INL-CCP SGRS personnel during inspection. 

Confirmed CCP SGRS 

SGRS-11: Where is the actual efficiency calibration for the SGRS documented? 

It is documented in CCP-INL-SGRS-001, Revision 2, and its attachments. N/A 

SGRS-12: Confirm the SGRS operational range with respect to matrix (density) and activity. 

~0.010 g to 200 g total Pu (calibration-based and administrative). Limited by LLD and system dead time. Calibration assumes that matrices are mainly Z < 15. Waste matrices outside density range require expert review.

EPA confiris the same been previ

Calibration Verification and Confirmation SGRS-13: Identify the date of the last calibration verification. Have any others been completed in the last year? 

9/18/2013, following the replacement of DETA1, as described 4, above (CCP-INL-SGRS-13-004). 

EPA confir

SGRS-14: Confirm the pedigree of all radionuclide standards that were used for calibration confirmation and/or verifications. Listor reference all standards used. 

The standards are summarized in Table 1 of CCP-INL-SGRS-001, SGRS Calibration, Confirmation and Verification Report, Revision 2, November 14, 2012. Source certifications are listed in Attachment 1 of the same document. 

EPA reviewfound in CAll standarand acceptcalibration

SGRS-15: Requirements for accuracy and precision must be met, as specified in DOE/WIPP-02-3122, Appendix A, Table A-3.2 for calibration verifications. 

The calibration verification results are contained in 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 less than 14%. 

Accuracy afor all calib

LLD SGRS-16: Confirm that the LLD for the SGRS has been determined. 

Section 6 of CCP-INL-SGRS-001, Revision 2, documents the LLD determination of measured radioisotopes. LLDs for all measured radionuclides in plastic foam, soft board, particle board and sand matrices 

were below the 100 nCi/g TRU threshold. 

Interviews personnel d
E-8 

EPA Inspection No.: INL-CC-2014 Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer Insp

Technical Elements Objective Evidence A

SGRS-17: Confirm if the SGRS is used to discriminate TRU/non-TRU wastes at the 100 nCi/g criterion and that it has the required sensitivity. 

The SGRS can discriminate between TRU and Non-TRU waste based on the LLDs reported in Section 6 of CCP-INL-SGRS-001, Revision 2, for all measured radionuclides. 

Total nCi/g the BDR aseveral insthe BDRs wnCi/g. INLwill be loa

SGRS-18: Identify any/all instances where an LLD value for a non-measured radionuclide is 

not provided based on a lack of technical feasibility. 

Because an LLD is a measurement-based parameter, it is not technically feasible to calculate for radionuclides that are not directly measured. Plutonium isotopes 238Pu, 240Pu and 242Pu are not usually directly measured 

and are derived by ratios to measured 239Pu. The reporting threshold for 

90Sr is based on the reported 137Cs LLD using an activity ratio determined 

from AK-NDA memoranda. INL-CCP states that it is not technically feasible to provide an LLD equivalent for 234U and it is derived by an 

algorithm based on the measured values of 235U and 238U. 

This is conINL-SGRS

Quality Control SGRS-19: All operators have current CCP training as verified on LOQI 

LOQI provided on May 7, 2014 (dated May 1, 2014), contains 11 operators, all with current training. 

EPA verifithe LOQI mlogbook. 

SGRS-20: Confirm the SGRS’s status with respect to the CBFO NDA PDP and last cycle. 

The SGRS successfully participated in Cycle 20 with an approval dated 

July 10, 2013. Cycle 21A is scheduled to begin in May 

EPA verifiin the PDP 

SGRS-21: All SGRS data must be reviewed and approved by qualified personnel. Identify the name and function of the individuals performing technical 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 individreview are 
E-9 

EPA Inspection No.: INL-CC-2014 Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer Insp

Technical Elements Objective Evidence A

SGRS-22: Identify any hardware and/or software changes made to the SGRS since the baseline approval. Determine which changes, if any, are significant, where they are documented, and how they affect the SGRS’s baseline approval. 

INL-CCP replaced the steel door hinge bearings on the SGRS on March 11, 2014. It required replacement due to the weight of the door being supported. After the replacement, INL-CCP performed a calibration 

verification 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 found the detector to be not functioning correctly. Following the replacement, INL-CCP performed calibration verification and documented it in CCPINL-SGRS-13-004. 

Confirmed CCP persoexamined tboth changadequately and subseq

SGRS-23: Identify any NCRs within the last year. 

There have been 4 NCRs on the SGRS in the last year: NCR-INL-0067-13 NCR-INL-0068-13 NCR-INL-0083-13 NCR-INL-0102-13 

Confirmed CCP persoreviewed a correspondthis reviewproperly do

TMU SGRS-24: Identify any changes to the method or details of the TMU calculation since baseline. 

INL-CCP did not make any changes to the TMU since EPA’s last inspection. 

Confirmed CCP perso

SGRS-25: Evaluate the magnitude of the TMU values observed in the SGRS BDRs that were examined during this inspection. 

INL-CCP documents TMU for the SGRS in CCP-INL-SGRS-002, April 21, 2005; this document does not have a revision number. The components of uncertainty included in the TMU determination are: calibration source uncertainties, counting statistics, self-absorption effects, matrix nonhomogeneities, nonuniform source distributions and isotopic measurement uncertainties. The software for TMU calculations is embedded in NDA 2000. CCP-INL-SGRS-002 calls for “administrative procedures” that would define a minimum fill-height requirement to reduce the potential for increased uncertainties due to end effects. Addressing this is left to the EA, who “should assess those assays for the 

potential end effects uncertainties and add the appropriate uncertainty 

amounts to the TMU, where applicable.” TMU values in BDRs are generally consistent with expectations based on CCP-INL-SGRS-002. 

Confirmed CCP perso

Background and Performance Checks SGRS-26: Confirm that SGRS background measurements have been taken daily. 

All records evaluated indicate compliant background performance. EPA confir

interviews logbook enEPA to revthese meas
E-10 

EPA Inspection No.: INL-CC-2014 Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer Insp

Technical Elements Objective Evidence A

SGRS-27: Assess how often background radiation was problematic to the extent that measurement personnel had to make adjustments.

SGRS operators have not observed any instances of problematic backgrounds. Between the SGRS and the outside wall of Building 610 is a layer of lead sheeting designed to reduce background from material being moved outside of the building. This layer has been in place since before EPA’s last inspection. 

EPA confiroccur dailyduring inte

SGRS-28: Confirm that system performance checks have been performed at least once per operational day. Confirm that performance checks include gamma and neutron efficiency, matrix correction checks, and gamma peak position and resolution checks. 

SGRS operators conduct performance checks once per day as stated in CCP-TP-115, Revision 5. 

EPA confirinterviews logbook enEPA to revthese check

Data Management SGRS-29: SGRS BDRs contain: • Testing facility name, testing batch number, 

container numbers, and signature of the SPM or designee 

• Table of contents 

• Background and performance check data or 

control charts for the relevant time period 

• Data validation per the QAPD and site 

procedures 

• Separate testing report sheets for each 

container 

EPA reviewed SGRS BDR Nos. INNDAS130099 and INNDAS140043 and found them to contain appropriate information. 

N/A 

SGRS-30: SGRS RDSs must include: • Title “Radioassay Data Sheet” 

• Method/procedure used 

• Date of radioassay 

• Activities and associated TMU for individual 

radionuclides 

• TAAC and its associated TMU 

• Operator and reviewer signatures 

EPA reviewed SGRS BDR Nos. INNDAS130099 and INNDAS140043 and found that each drum contained in the two BDRs had an RDS containing the correct elements. 

N/A 
F-1 

ATTACHMENT F.1: REPLICATE TESTING DATA FOR DRUM SRP21732 – WAG

Instrument: WAGS Drum: SRP21732 

Quantity of Interest 

Original Measurement Replicate #1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) 2.13E-05 1.28E-05 6.01E-01 2.18E-05 1.31E-05 6.01E-01 2.14E-05 238U Activity (Ci) 1.31E-05 4.42E-06 3.37E-01 1.36E-05 4.60E-06 3.38E-01 1.38E-05 238Pu Activity (Ci) 2.00E-04 1.02E-04 5.10E-01 1.89E-04 9.63E-05 5.10E-01 2.01E-04 239Pu Activity (Ci) 7.31E-03 2.47E-03 3.38E-01 6.89E-03 2.33E-03 3.38E-01 7.33E-03 240Pu Activity (Ci) 1.62E-03 5.66E-04 3.49E-01 1.53E-03 5.34E-04 3.49E-01 1.63E-03 242Pu Activity (Ci) 2.13E-07 1.31E-07 6.15E-01 2.01E-07 1.23E-07 6.12E-01 2.13E-07 241Am Activity (Ci) 8.41E-03 2.86E-03 3.40E-01 8.73E-03 3.61E-03 4.14E-01 8.53E-03 90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TAAC (nCi/g) 1.19E+02 2.60E+01 2.18E-01 1.18E+02 2.94E+01 2.49E-01 1.20E+02 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) 2.20E-05 1.32E-05 6.00E-01 2.11E-05 1.27E-05 6.02E-01 2.19E-05 238U Activity (Ci) 1.34E-05 4.51E-06 3.37E-01 1.26E-05 4.25E-06 3.37E-01 1.54E-05 238Pu Activity (Ci) 1.87E-04 9.53E-05 5.10E-01 1.91E-04 9.72E-05 5.09E-01 1.97E-04 239Pu Activity (Ci) 6.83E-03 2.31E-03 3.38E-01 6.97E-03 2.35E-03 3.37E-01 7.19E-03 240Pu Activity (Ci) 1.52E-03 5.29E-04 3.48E-01 1.55E-04 5.38E-05 3.47E-01 1.60E-03 242Pu Activity (Ci) 1.99E-07 1.22E-07 6.13E-01 2.03E-07 1.24E-07 6.11E-01 2.10E-07 241Am Activity (Ci) 8.60E-03 2.86E-03 3.33E-01 8.73E-03 2.91E-03 3.33E-01 8.56E-03 90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TAAC (nCi/g) 1.17E+02 2.53E+01 2.16E-01 1.19E+02 2.57E+01 2.16E-01 1.19E+02 
F-2 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <|c

Reported 

Value 

Absolute 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N234U Activity (Ci) 2.13E-05 1.28E-05 2.16E-05 3.78E-07 1.75E-02 3.49E-03 1.00E238U Activity (Ci) 1.31E-05 4.42E-06 1.38E-05 1.02E-06 7.44E-02 2.15E-01 9.95E238Pu Activity (Ci) 2.00E-04 1.02E-04 1.93E-04 5.83E-06 3.02E-02 1.31E-02 1.00E239Pu Activity (Ci) 7.31E-03 2.47E-03 7.04E-03 2.11E-04 3.00E-02 2.92E-02 1.00E240Pu Activity (Ci) 1.62E-03 5.66E-04 1.29E-03 6.35E-04 4.93E-01 5.03E+00 2.85E242Pu Activity (Ci) 2.13E-07 1.31E-07 2.05E-07 6.02E-09 2.93E-02 8.44E-03 1.00E241Am Activity (Ci) 8.41E-03 2.86E-03 8.63E-03 9.46E-05 1.10E-02 4.38E-03 1.00E90Sr Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N137Cs Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A NTAAC (nCi/g) 1.19E+02 2.60E+01 1.19E+02 1.14E+00 9.61E-03 7.69E-03 1.00E

Quantity of Interest t Pr(x <|t|) χ2 Test t Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable 234U Activity (Ci) -8.21E-01 4.58E-01 Not Significant Not Significant 238U Activity (Ci) -5.89E-01 5.88E-01 Not Significant Not Significant 238Pu Activity (Ci) 1.10E+00 3.35E-01 Not Significant Not Significant 239Pu Activity (Ci) 1.16E+00 3.11E-01 Not Significant Not Significant 240Pu Activity (Ci) 4.79E-01 6.57E-01 Not Significant Not Significant 242Pu Activity (Ci) 1.18E+00 3.02E-01 Not Significant Not Significant 241Am Activity (Ci) -2.12E+00 1.01E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A Not Applicable Not Applicable 137Cs Activity (Ci) N/A N/A Not Applicable Not Applicable TAAC (nCi/g) 3.20E-01 7.65E-01 Not Significant Not Significant 
F-3 

ATTACHMENT F.2: REPLICATE TESTING DATA FOR DRUM SRP21773 – WAG

Instrument: WAGS Drum: SRP21773 

Quantity of Interest 

Original Measurement Replicate #1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) 1.58E-05 9.23E-06 5.84E-01 1.46E-05 8.51E-06 5.83E-01 1.56E-05 238U Activity (Ci) 1.79E-05 5.49E-06 3.07E-01 1.77E-05 5.43E-06 3.07E-01 1.90E-05 238Pu Activity (Ci) 8.35E-04 5.53E-04 6.62E-01 3.26E-04 1.59E-04 4.88E-01 6.38E-04 239Pu Activity (Ci) 1.21E-02 3.69E-03 3.05E-01 1.19E-02 3.64E-03 3.06E-01 1.18E-02 240Pu Activity (Ci) 2.22E-03 8.07E-04 3.64E-01 2.65E-03 8.39E-04 3.17E-01 2.28E-03 242Pu Activity (Ci) 4.98E-07 1.70E-07 3.41E-01 3.47E-07 2.07E-07 5.97E-01 7.32E-07 241Am Activity (Ci) 2.07E-02 6.30E-03 3.04E-01 2.03E-02 6.16E-03 3.03E-01 2.08E-02 90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TAAC (nCi/g) 3.01E+02 6.19E+01 2.06E-01 2.96E+02 6.05E+01 2.04E-01 2.98E+02 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) 1.54E-05 9.00E-06 5.84E-01 1.54E-05 8.99E-06 5.84E-01 1.50E-05 238U Activity (Ci) 2.03E-05 6.21E-06 3.06E-01 1.79E-05 5.47E-06 3.06E-01 1.97E-05 238Pu Activity (Ci) 3.38E-04 1.65E-04 4.88E-01 3.21E-04 1.57E-04 4.89E-01 3.37E-04 239Pu Activity (Ci) 1.23E-02 3.79E-03 3.08E-01 1.17E-02 3.61E-03 3.09E-01 1.23E-02 240Pu Activity (Ci) 2.74E-03 8.74E-04 3.19E-01 2.60E-03 8.32E-04 3.20E-01 2.73E-03 242Pu Activity (Ci) 3.59E-07 2.14E-07 5.96E-01 3.41E-07 2.04E-07 5.98E-01 3.58E-07 241Am Activity (Ci) 2.01E-02 7.86E-03 3.91E-01 2.11E-02 8.23E-03 3.90E-01 1.99E-02 90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TAAC (nCi/g) 2.98E+02 7.38E+01 2.48E-01 3.00E+02 7.58E+01 2.53E-01 2.96E+02 
F-4 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <

Reported 

Value 

Absolute 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 234U Activity (Ci) 1.58E-05 9.23E-06 1.52E-05 4.00E-07 2.63E-02 7.51E-03 1.00E238U Activity (Ci) 1.79E-05 5.49E-06 1.89E-05 1.12E-06 5.94E-02 1.67E-01 9.97238Pu Activity (Ci) 8.35E-04 5.53E-04 3.92E-04 1.38E-04 3.51E-01 2.48E-01 9.93239Pu Activity (Ci) 1.21E-02 3.69E-03 1.20E-02 2.83E-04 2.36E-02 2.35E-02 1.00E240Pu Activity (Ci) 2.22E-03 8.07E-04 2.60E-03 1.88E-04 7.23E-02 2.17E-01 9.95242Pu Activity (Ci) 4.98E-07 1.70E-07 4.27E-07 1.70E-07 3.99E-01 4.02E+00 4.03241Am Activity (Ci) 2.07E-02 6.30E-03 2.04E-02 4.98E-04 2.44E-02 2.50E-02 1.00E90Sr Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 137Cs Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A TAAC (nCi/g) 3.01E+02 6.19E+01 2.98E+02 1.67E+00 5.62E-03 2.92E-03 1.00E

Quantity of Interest t Pr(x <|t|) χ2Test t Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable 234U Activity (Ci) 1.37E+00 2.43E-01 Not Significant Not Significant 238U Activity (Ci) -8.29E-01 4.54E-01 Not Significant Not Significant 238Pu Activity (Ci) 2.94E+00 4.25E-02 Not Significant Significant 239Pu Activity (Ci) 3.23E-01 7.63E-01 Not Significant Not Significant 240Pu Activity (Ci) -1.85E+00 1.39E-01 Not Significant Not Significant 242Pu Activity (Ci) 3.78E-01 7.25E-01 Not Significant Not Significant 241Am Activity (Ci) 4.77E-01 6.59E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A Not Applicable Not Applicable 137Cs Activity (Ci) N/A N/A Not Applicable Not Applicable TAAC (nCi/g) 1.85E+00 1.37E-01 Not Significant Not Significant 
F-5 

ATTACHMENT F.3: REPLICATE TESTING DATA FOR DRUM SRP18745– WAG

Instrument: WAGS Drum: SRP18745 

Quantity of Interest 

Original Measurement Replicate #1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) 9.60E-07 5.59E-07 5.82E-01 1.06E-06 6.18E-07 5.83E-01 1.02E-06 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 3.87E-04 3.00E-04 7.75E-01 3.49E-04 2.67E-04 7.65E-01 5.10E-04 239Pu Activity (Ci) 1.47E-02 4.46E-03 3.03E-01 1.36E-02 4.10E-03 3.02E-01 1.45E-02 240Pu Activity (Ci) 2.61E-03 8.37E-04 3.21E-01 2.89E-03 9.10E-04 3.15E-01 2.92E-03 242Pu Activity (Ci) 1.85E-07 6.62E-08 3.58E-01 2.06E-07 7.15E-08 3.47E-01 2.11E-07 241Am Activity (Ci) 1.26E-03 3.83E-04 3.04E-01 1.24E-03 3.75E-04 3.02E-01 1.23E-03 90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TAAC (nCi/g) 1.94E+02 4.68E+01 2.41E-01 1.85E+02 4.34E+01 2.35E-01 1.97E+02 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) 1.04E-06 6.05E-07 5.82E-01 1.13E-06 6.61E-07 5.85E-01 1.18E-06 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 1.10E-03 4.35E-04 3.95E-01 6.70E-04 3.51E-04 5.24E-01 3.08E-04 239Pu Activity (Ci) 1.38E-02 4.17E-03 3.02E-01 1.37E-02 4.15E-03 3.03E-01 1.32E-02 240Pu Activity (Ci) 3.50E-03 1.11E-03 3.17E-01 2.49E-03 8.00E-04 3.21E-01 2.36E-03 242Pu Activity (Ci) 2.63E-07 9.13E-08 3.47E-01 1.77E-07 6.33E-08 3.58E-01 1.65E-07 241Am Activity (Ci) 1.22E-03 3.70E-04 3.04E-01 1.14E-03 3.48E-04 3.05E-01 1.14E-03 90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TAAC (nCi/g) 2.01E+02 4.47E+01 2.22E-01 1.85E+02 4.36E+01 2.36E-01 1.75E+02 
F-6 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <

Reported 

Value 

Absolute 

Uncertainty 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 234U Activity (Ci) 9.60E-07 5.59E-07 1.09E-06 6.69E-08 6.16E-02 5.73E-02 1.00E238U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 238Pu Activity (Ci) 3.87E-04 3.00E-04 5.87E-04 3.20E-04 5.45E-01 4.56E+00 3.35239Pu Activity (Ci) 1.47E-02 4.46E-03 1.38E-02 4.72E-04 3.43E-02 4.48E-02 1.00E240Pu Activity (Ci) 2.61E-03 8.37E-04 2.83E-03 4.46E-04 1.58E-01 1.14E+00 8.88242Pu Activity (Ci) 1.85E-07 6.62E-08 2.04E-07 3.80E-08 1.86E-01 1.32E+00 8.58241Am Activity (Ci) 1.26E-03 3.83E-04 1.19E-03 4.98E-05 4.17E-02 6.77E-02 9.9990Sr Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 137Cs Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A TAAC (nCi/g) 1.94E+02 4.68E+01 1.89E+02 1.04E+01 5.53E-02 1.99E-01 9.95

Quantity of Interest t Pr(x <|t|) χ2 Test t Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable 234U Activity (Ci) -1.72E+00 1.61E-01 Not Significant Not Significant 238U Activity (Ci) N/A N/A Not Applicable Not Applicable 238Pu Activity (Ci) -5.71E-01 5.99E-01 Not Significant Not Significant 239Pu Activity (Ci) 1.82E+00 1.43E-01 Not Significant Not Significant 240Pu Activity (Ci) -4.54E-01 6.73E-01 Not Significant Not Significant 242Pu Activity (Ci) -4.66E-01 6.66E-01 Not Significant Not Significant 241Am Activity (Ci) 1.21E+00 2.93E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A Not Applicable Not Applicable 137Cs Activity (Ci) N/A N/A Not Applicable Not Applicable TAAC (nCi/g) 4.73E-01 6.61E-01 Not Significant Not Significant 
G-1 

ATTACHMENT G: DOSE-TO-CURIE CONTINUED COMPLIANCE INSPECTION 

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 operators 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 Mueller)

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 137Cs 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 to 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 @ 0o: 162 mR/h

Dose Rate @ 90o: 165 mR/h

Dose Rate @ 180o: 187 mR/h

Dose Rate @ 270o: 206 mR/h

Highest measured Dose Rate >3 x BKG: Yes

Dose Rate Average: 180 mR/h

Estimated Contact Dose Rate: >200 mR/h 
H-1 

ATTACHMENT H: REAL-TIME RADIOGRAPHY CONTINUED COMPLIANCE INSPECTION CHEC

EPA Inspection No.: INL-CC-2014 RH Real-Time Radiography Inspection 

Establishment of Required Technical Elements in 

Procedures Execution of Procedures Objectiv

RTR-1: Site procedures identify required training and qualifications for RTR personnel. CCP-TP-028, Revision 8. CCP-QP-002, Revision 36. 

RTR operators receive training on the WMPs and typical packaging configurations expected in each waste stream. To become qualified, the RTR operator must pass a comprehensive written test based on training objectives with a minimum score of 80%. Unsatisfactory performance – failed to identify prohibited item during OJT of score of less than 80% on exam. Demonstrate capability (At initial qualification, requalification, and semiannually, successfully examine a training container). 

At initial qualification, and subsequent requalification, successfully examine a test drum. 

RTR operators re-qualified every 2 years based on continued satisfactory performance. 

EPA reviewed the Qualificarecords for RH RTR person

training DVDs and evaluati

lead operators. EPA determwere complete and demonswere performing the RH RTObjective evidence: 

1. Qualification Cards for 

2. Training DVDs for var

3. Practical demonstration 

personnel 

4. LOQIs for VE and RTR 

5. A list of RH INL RTR 

and inventory sheets 

6. Training Container Eva

various RTR operators 

7. Inventory sheets for RT

TRAINING-25, NDE-TTRAINING-1, NDE-TTRAINING-33

RTR-2: Site procedures provide complete instructions for operators to perform the RTR examination and completion of the associated documentation. CCP-TP-053, Revision 9, section 4.0. 

RTR operator adequately explained the process followed for examining a drum and entering data into data forms (whether hard copy or electronic data entry is used). 

EPA observed the RTR exaFCO108C in building 659. 

waste items contained withithese data on an electronic dObjective evidence: 

1. LOQIs for VE and RTR 

2. Data sheets for demons

3. BDR Nos. INLRHRTR

INLRHRTR14003. 

4. Audio/visual recording

BDR Nos. INLRHRTRINLRHRTR14003. 
H-2 

EPA Inspection No.: INL-CC-2014 RH Real-Time Radiography Inspection 

Establishment of Required Technical Elements in 

Procedures Execution of Procedures Objectiv

RTR-3: The RTR procedures require an image quality check to be performed. CCP-TP-053, Revision 14, section 4.2, Attachment 1.

Operator adequately explained how the acceptability of an image is determined. Image quality check is performed once per day (RTR Measurement Control Report). Performance of the image quality check is documented and recorded.

The operator manipulated th

the contents of the drum anitems. At the time of the dealready completed the nece

to examining any containerverify that image quality ch

container examinations. Objective evidence: 

1. Data sheets for demons

2. BDR Nos. INLRHRTR

INLRHRTR14003. 

3. Audio/visual recording

BDR Nos. INLRHRTRINLRHRTR14003. 

RTR-4: The procedure allows the operator to adjust the RTR to accommodate the physical properties of the waste and waste containers likely to be encountered at the site. CCP-TP-508, Revision 9, section 4.3. 

Operator could identify applicable policies and procedures governing the operation of RTR equipment. The RTR system could be adjusted. High-density material was examined with the Xray device set on the maximum voltage and low density material at a lower voltage. Operator adequately explained what is done if an image is unacceptable (e.g., the waste is solidified or the container is lead-lined). 

EPA observed the RTR exaFCO108C. The operator haimage quality check prior to The operator rotated the dru

of waste items and changed 

accommodate materials of doperator entered waste itemas they were identified. The to check for the presence of the Waste Stream Descriptiof any prohibited items. Thaudio/visual recording of thThe operator used procedurexamination and had a copy available for reference. The the NCR process used if a pObjective evidence: 

1. Audio/visual recording

BDR Nos. INLRHRTRINLRHRTR14003. 

2. Written record for dem

3. Operator Qualification 

4. LOQI for RH RTR per
H-3 

EPA Inspection No.: INL-CC-2014 RH Real-Time Radiography Inspection 

Establishment of Required Technical Elements in 

Procedures Execution of Procedures Objectiv

RTR-5: Data records are of sufficiently high quality for complete review. CCP-TP-508, Revision 9, section 4.3, Attachments 1 and 2. 

RTR tape is high quality, the sound track is audible, and the required information is contained on the audible portion of the tape. The RTR tape is consistent with the data package for the same drum. 

EPA reviewed two BDRs to recordings were of sufficiendetailed review. EPA also vand written records were coObjective evidence: 

1. Audio/visual recording

BDR Nos. INLRHRTRINLRHRTR14003. 

RTR-6: There is a procedure for determining whetherthe waste matches the waste stream description and Waste Matrix Code, and for determining Waste Material Parameters and weights. CCP-TP-508, Revision 9, Table 2, Attachment 2. 

The procedure is adequately implemented. Operators verify that the waste matches the waste stream description. WMC is verified. If not, corrective action is taken. WMP weights are estimated by compiling an inventory of waste items and residual/packaging materials. Does the RTR operator use a standard weight lookup table to provide an estimate of WMP weights? If so, has the table been updated to reflect additional information gained through previous RTR/VE exams or updated AK information? 

Objective evidence: 

1. Audio/visual recording

BDR Nos. INLRHRTRINLRHRTR14003. 

2. Written record for dem

3. Operator Qualification 

4. LOQI for RH RTR per

RTR-7: The RTR procedure provides instructions for identifying prohibited items and for processing drums containing prohibited items. CCP-TP-508, Revision 9, Table 1, Attachment 2. 

Operator could name prohibited items. Operator adequately explained how the presence of prohibited liquids is determined. Operator’s explanation of required actions if prohibited items were encountered was consistent with procedure. 

The operator used procedurperformance of the RTR de

procedure describes prohibidemonstration, the operator facilitate identification of li

stated that an NCR would bitems were located. Objective evidence: 

1. Audio/visual recording

BDR Nos. INLRHRTRINLRHRTR14003. 

2. Written record for dem

RTR-8: RTR procedures include the required QC examinations, evaluation accuracy and reproducibility of the RTR process. 

An independent replicate scan is performed on one waste container per day or on one container per testing batch (whichever is less frequent). An independent observation of one scan (not the 

EPA reviewed two BDRs to were performed on a batch 

Independent Observation an

been performed and recorde
H-4 

EPA Inspection No.: INL-CC-2014 RH Real-Time Radiography Inspection 

Establishment of Required Technical Elements in 

Procedures Execution of Procedures Objectiv

CCP-TP-508, Revision 9, sections 4.4 and 4.5. replicate) is performed, by a qualified RTR 

operator (anyone but the initial RTR operator). 

accordance with procedure Objective evidence: 

1. Audio/visual recording

BDR Nos. INLRHRTRINLRHRTR14003 

RTR-9: Procedures contain standardized forms for recording RTR data. CCP-TP-508, Revision 09, Attachment 2. 

RTR operator adequately explained the process followed for examining a drum and entering data into data forms (whether hard copy or electronic data entry is used). Direct data entry into an electronic form is done by the RTR operator using a computer while the operator is still in the RTR booth. The electronic data file undergoes the same QC checks used for hand-written data entries. 

The operator performed the examination in accordance and entered data into an eleitems were identified. Objective evidence: 

1. Audio/visual recording

BDR Nos. INLRHRTRINLRHRTR14003. 

2. Data sheets for demons

RTR-10: Site procedures require review of BDRs at the data generation and project level. CCP-TP-508, Revision 9, section 4.9, Attachments 3 and 4. 

Data generation level reviews are performed and documented (ITR). Project level reviews are performed and documented (SPM). 

An ITR and an SPM had rereviewed BDRs as required Objective evidence: 

1. Audio/visual recording

BDR Nos. INLRHRTRINLRHRTR14003. 
I-1 

ATTACHMENT I.1: VISUAL EXAMINATION CONTINUED COMPLIANCE INSPECTION CHECK

EPA Inspection No.: INL-CC-2014 CH Visual Examination Ins

Establishment of Required Technical Elements in 

Procedures Execution of Procedures Objective 

CHVE-1: Site procedures identify required training and qualifications for CH VE personnel. CCP-QP-002, Revision 36. 

Formal training elements include: project requirements, container identification and labeling, applicable state and federal regulations. 

Site-specific training program: OJT, identification of summary category groups, WMPs, packaging configurations, residual liquids. 

EPA reviewed the Qualificatiand VEEs and determined thaaccordance with CCP proceduwere complete and available finterviewed were able to answand were knowledgeable regastream being processed. Objective Evidence: 

1. Qualification cards for se2. Appointment emails for v

8/31/2009 and 12/10/201

3. LOQIs for VE operators 

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 pass a comprehensive written test with an 80 percent or better grade that addresses VE operations, documentation, characterization, formal training elements, and procedural elements. VE Operators must demonstrate capability in the presence of the site VEE during OJT. However, the formal and OJT training is conducted by a qualified

SME. 

Objective Evidence: 

1. Qualification cards for se2. Appointment emails for v

8/31/2009 and 12/10/201

3. LOQIs for VE operators 

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 being characterized. Responsible for overall direction and implementation of VE at the facility. Certification Plan specifies the selection, qualification, and training requirements of VEE. 

EPA reviewed the appointmen

process used at INL-CCP for be actually present at each exathe processes implemented. Tfor this process at INL-CCP. Objective Evidence: 

1. Appointment emails for v

8/31/2009 and 12/10/201

2. LOQIs for VE operators 

CHVE-4: Procedures and technical guidance documents provide complete instructions for performing VE. CCP-TP-006, Revision 18. 

Verify container is empty. Empty container is weighed. 100% of containers will be subject to VE at the time of packaging. 

The EPA Inspectors observed 

Waste Stream ID-SRP-3000 (Building 1617, ARP-V. The w

and operators sorted and iden

After estimating WMPs and r
I-2 

EPA Inspection No.: INL-CC-2014 CH Visual Examination Ins

Establishment of Required Technical Elements in 

Procedures Execution of Procedures Objective 

Waste Stream Description and WMC verified. Presence/absence of prohibited items confirmed. Two operators used even if audio/visual recording of VE is generated. A VE form is used to document results of examination, WMC and estimated WMP weights. Prohibited items segregated and documented. 

was loaded into 55-gallon druVEE present were trained and CCP procedures. CCP-TP-00

and data were recorded on the sheets from this procedure. Operators verified the Waste and the absence of any prohibdescribed the processes used iidentified in the waste but couinstance of this occurring. Two operators perform the VE Containers SRP23093 and SRSRP-VE-000737, were used tthe VE observed by EPA. EPA these containers and determinproperly processed. Both operto sign the data sheets after coEPA reviewed BDR Nos. INLVE-002943, INL-SRP-VE-00and INL-SRP-VE-000700 and generated and recorded in accTP-006. Objective Evidence: 1. Qualification cards for se2. Appointment emails for v

8/31/2009 and 12/10/201

3. LOQIs for VE operators 4. Data sheets for container

5. VE BDR Nos. INL-ARP

002943, INL-SRP-VE-00000699, INL-SRP-VE-00

CHVE-5: Corrective actions are taken when necessary. CCP-TP-006, Revision 18, section 2.4.2. 

Operators were able to describe how they initiate acorrective action. 

Operators could not recall the for this waste stream, but werprocess is implemented. No Ncontainers in the BDRs review

Objective Evidence: 

1. Qualification cards for se
I-3 

EPA Inspection No.: INL-CC-2014 CH Visual Examination Ins

Establishment of Required Technical Elements in 

Procedures Execution of Procedures Objective 

2. Appointment emails for v

8/31/2009 and 12/10/201

3. LOQIs for VE operators 4. Data sheets for container

5. VE BDR Nos. INL-ARP

002943, INL-SRP-VE-00and INL-SRP-VE-00070

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 

the requisite reviews were perdetermined that the reviews wwith the applicable CCP procObjective Evidence: 

1. VE BDR No. INL-ARP-V

002943, INL-SRP-VE-00and INL-SRP-VE-00070

CHVE-7: Records are available for review. CCP-TP-006, Revision 18, section 5.0. 

Lifetime/QA records – Attachments 1–5, Copy of NCRs. QA/nonpermanent records – VHS tape or DVD (primary and backup). 

CH VE is performed at INL-C

is not recorded by audio/visuaCCP personnel were able to pEPA for review. Objective Evidence: 

1. VE BDR No. INL-ARP-V

002943, INL-SRP-VE-00and INL-SRP-VE-00070

2. Qualification cards for se

3. Appointment emails for v

8/31/2009 and 12/10/201

4. LOQIs for VE operators 5. Data sheets for container

6. VE BDR Nos. INL-ARP

002943, INL-SRP-VE-00and INL-SRP-VE-00070
I-4 

ATTACHMENT I.1: VISUAL EXAMINATION CONTINUED COMPLIANCE INSPECTION CHECK

EPA Inspection No.: INL-CC-2014 RH Visual Examination Ins

Establishment of Required Technical Elements in 

Procedures Execution of Procedures Objectiv

RHVE-1: Site procedures identify required training and qualifications for RH VE personnel. CCP-QP-002, Revision 36.

Formal training elements include: project requirements, container identification and labeling, applicable state and federal regulations. 

Site-specific training program: OJT, identification of summary category groups, WMPs, packaging configurations, residual liquids. 

EPA reviewed the QualificatiVEEs and determined that thewith CCP procedures. The Qucomplete and available for revwere able to answer all questiknowledgeable regarding the being processed. Objective Evidence: 1. Qualification cards for se

2. Appointment emails for v

8/31/2009 and 12/10/201

3. LOQIs for VE operators 

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 a comprehensive written test with an 80 percent or better grade that addresses VE operations, documentation, characterization, formal training elements, and procedural elements. VE Operators must demonstrate capability in the presence of the site VEE during OJT. However, the formal and OJT training is conducted by a qualified

SME. 

EPA reviewed the QualificatiVEEs and determined that thewith CCP procedures. The Qucomplete and available for revwere able to answer all questiknowledgeable regarding the being processed. The operatorprohibited items are identifiedObjective Evidence: 1. Qualification cards for se

2. Appointment emails for v

8/31/2009 and 12/10/201

3. LOQIs for VE operators 

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 being characterized. Responsible for overall direction and implementation of VE at the facility. Certification Plan specifies the selection, qualification, and training requirements of VEE. 

EPA reviewed the appointmen

were qualified and trained in aprocedures and training recordObjective Evidence: 

1. Appointment emails for v

2007, August 31, 2009 an

2. LOQIs for VE operators 

RHVE-4: Procedures and technical guidance documents provide complete instructions for 

100% of containers will be subject to VE at the time of packaging. 

INL-CCP had scheduled to pr

demonstration of the RH VE p
I-5 

EPA Inspection No.: INL-CC-2014 RH Visual Examination Ins

Establishment of Required Technical Elements in 

Procedures Execution of Procedures Objectiv

performing 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 recording of VE is generated. 

inspection. However, due to a 

demonstration could not take 

interviewed two VEOs and ondemonstration. The RH VE pe

knowledgeable, experienced o

provide EPA with answers to 

inspectors. INL-CCP had perf

during the past year and were 

for review. The BDR was com

Two operators had signed the 

procedure CCP-TP-500. Objective Evidence: 

1. LOQIs for VE operators 

2. BDR No. INLRHVE130

RHVE-5: Corrective actions are taken when necessary. CCP-TP-500, Revision 13, section 2.4.2. 

Operators were able to describe how they initiate acorrective action. 

RH VE personnel interviewed how they would initiate an NCbeen initiated for the one BDR Objective Evidence: 

1. Qualification Cards for se

2. LOQIs for VE operators 3. BDR No. INLRHVE130

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 hageneration level by an ITR an

SPM. Objective evidence: 

1. BDR No. INLRHVE1300

RHVE-7: Records are available for review. CCP-TP-500, Revision 13, section 5.0. 

Lifetime/QA records – Attachments 1–5, Copy of NCRs. QA/nonpermanent records – VHS tape or DVD (primary and backup). 

INL-CCP was able to provide documents. Objective Evidence: 

1. Qualification cards for se

2. Appointment emails for v

8/31/2009 and 12/10/201

3. LOQIs for VE operators 4. BDR No. INLRHVE130

RHVE-8: Quality assurance objectives are defined and met. 

Data Accuracy: 194.22, b, (1) the degree to which data agree with 

Data Accuracy & ComparabQualification and requalificati
I-6 

EPA Inspection No.: INL-CC-2014 RH Visual Examination Ins

Establishment of Required Technical Elements in 

Procedures Execution of Procedures Objectiv

40 CFR Part 194.22(b) an acceptable reference or true value. 

WCPIP: maintained by requiring operators to pass a comprehensive test with a score of 80% and demonstrated satisfactory performance for initial qualification and re-qualification. Data Precision: 194.22, b, (2) a measure of the mutual agreement 

between comparable data gathered or developed under similar conditions expressed in terms of a standard deviation. WCPIP: – maintained by reconciling any discrepancies between 2 operators (or operator and ITR) with regard to physical form of waste, absenceof residual liquid. Data Representativeness 194.22, b, (3) the degree to which data accurately and precisely represent a characteristic of a population, a parameter, variations at a sampling point, or environmental conditions. WCPIP: Contents placed in a container will be described on the data forms. Data Completeness 194.22, b, (4) a measure of the amount of valid data obtained compared to the amount that was expected.WCPIP: Relevant waste information must be collected and documented on a videotape and/or data form or other unalterable media. Data Comparability 194.22, b, (5) a measure of the confidence with which one data set can be compared to another. WCPIP: ensured by site meeting training requirements and complying with the minimum standards used to implement VE. 

demonstrate that operators paexamination as required by thprocedure CCP-QP-002. Data Precision: Two operators perform VE anthe data forms. This is evidenData Representativeness & EPA determined that all waste forms. EPA verified this by reObjective evidence: 

1. BDR No. INLRHVE1300

2. Qualification Cards and o

selected VE operators. 
J-1 

ATTACHMENT J: LIST OF DOCUMENTS REVIEWED FOR THIS INSPECTION 

AK 

Common to multiple waste streams: 

AKE Qualification Card for Carrie Johnson, June 16, 2011 

AKE Qualification Card for Kevin Peters, June 16, 2011 

AKE Qualification Card for Scott Smith, June 22, 2011 

AKE Qualification Card for Steve Schafer, June 16, 2011 

AKE-01, Acceptable Knowledge Expert (AKE) Qualification Card, Sample Form, Revision 10, 

November 8, 2013 

Assigned Reading Report, CCP-QP-002, Revision 36, provided April 24, 2014 

Assigned Reading Report, CCP-QP-005, Revision 23, provided April 24, 2014 

Assigned Reading Report, CCP-QP-005, Revision 24, Joshua Houghton, provided May 8, 2014 

Assigned Reading Report, CCP-TP-002, Revision 26, provided April 24, 2014 

Assigned Reading Report, CCP-TP-005, Revision 26, provided April 24, 2014 

Assigned Reading Report, CCP-TP-506, Revision 4, provided May 6, 2014 

CH INL-CCP AK Tracking Spreadsheet, April 18, 2014 

DOE WIPP-02-3214 (WCPIP), Revision 3, Assigned Reading Report, provided April 24, 2014 

Fiscal Year 2013 3rd Quarter T2 report, provided July 22, 2013 

Fiscal Year 2013 4th Quarter T2 report, provided November 19, 2013 

Fiscal Year 2014 1st Quarter T2 report, provided January 22, 2014 

Fiscal Year 2014 2nd Quarter T2 report, provided May 1, 2014 

Lists of fully characterized containers for Waste Streams 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, August 27, 2012 

SPM CH Qualification Card for Barbara Broomfield, November 2, 2004 

SPM CH Qualification Card for Beverly Schrock, June 23, 2010, Revised February 5, 2014 

SPM CH Qualification Card for Brandye Pyeatt, August 27, 2012 

SPM CH Qualification Card for Carolina Soaterna, May 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, October 31, 2013 

SPM CH Qualification Card for Roger Whiteaker, May 3, 2012 

SPM CH Qualification Card for Veronica Waldram, August 4, 2009 

SPM RH Qualification Card for Charles Turner, August 15, 2013 

SPM RH Qualification Card for David Moody, August 28, 2013 

SPM RH Qualification Card for Irene Joo (Quintana), September 17, 2009 

SPM RH Qualification Card for Joshua Houghton, August 19, 2013 

SPM RH Qualification Card for Laura Nelson, June 21, 2010 

SPM RH Qualification Card for Rich Kantrowitz, October 29, 2012 

SRP spreadsheet tracking weekly input, by source drum, to the SRP repackaging process, 

provided May 7, 2014 

WP 15-GM1002, Revision 2, Assigned Reading Acknowledgement 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 (retired) and Jeff Harrison, February 17, 1997 

C171, Telecon between Bill Connor of Kaiser-Hill LATO and Jeff Harrison, February 13, 1997 

C701, Memorandum to CCP Records: Waste Stream Volume Estimate for ID-SRP-S3000, SRP 

Combined Sludge Waste, Scott Smith, October 30, 2013 

C702, Defense Waste Streams Generated at Rocky Flats Environmental Technology Site 

(RFETS) George E. Dials, May 20, 1987 

CCP-AK-INL-026, Central Characterization Program Acceptable Knowledge Summary Report 

for Idaho National Laboratory Sludge Repackage Project 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 (Example), ID-SRP-S3000, Revision 0, 

February 13, 2014 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, ID-SRP-S3000, January 24, 2014 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, ID-SRP-S3000, February 5, 2014 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, ID-SRP-S3000, May 8, 2014 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, ID-SRP-S3000, Lots 1–23, dated 

February 21, 2014, through March 28, 2014 

Characterization Information Summary, WSPF No. ID-SRP-S3000, Revision 0, Lot 2, February 

21, 2014 

Characterization Information Summary, WSPF No. ID-SRP-S3000, Revision 0, Lot 12, March 3, 

2014 

Characterization Information Summary, WSPF No. ID-SRP-S3000, Revision 0, Lot 23, March 

28, 2014 

DR701, Acceptable Knowledge Source Document Discrepancy Report, Scott Smith, DR701, 

October 30, 2013 

Memorandum from Scott Smith to CCP Records, Evaluation 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 INNDAW140037 

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 Stored 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, December 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 Project, TPR-7866, Draft, not dated 

P543, SRP RA V Waste Processing, Idaho Completion Project, TPR-7867, not dated 

P544, WMF-1617 SPR-Support Systems, Idaho Completion Project, TPR-7418-5, Revision 6 

LFU V1, September 20, 2012 
J-4 

P545, RWMC Waste Handling and Overpacking, Idaho Completion Project, TPR-7601, 

Revision 45, Draft, not dated 

P546, Risk-Based Disposal Approval Application for Management of Polychlorinated Biphenyl 

(PCB) Remediation Waste Contaminated with Transuranic 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 Retrieval 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 Documentation, Attachment 8 – Waste 

Containers List, ID-RF-S3114, April 22, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, ID-RF-S3114, Lot 102, May 2, 2013 

CCP-TP-005, Revision 25, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, ID-RF-S3114, Lot 128, August 9, 

2013 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, ID-RF-S3114, Lot 183, March 10, 

2014 

Characterization Information Summary, WSPF No. ID-RF-S3114, Revision 1, Lot 104, May 13, 

2013 

Characterization Information Summary, WSPF No. ID-RF-S3114, Revision 1, Lot 115, June 26, 

2013 

Characterization Information Summary, WSPF No. ID-RF-S3114, Revision 1, Lot 138, October 

3, 2013 

Characterization Information Summary, WSPF No. ID-RF-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 Stream Number ID-RF-S3114 Revision 1 

(CCP-AK-INL-005), Organic Setups, Lots 101–183, Cumulative 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-SLUDGE 

CCP-AK-INL-001, Central Characterization Program Acceptable Knowledge Summary Report 

for Waste Retrieved from Designated Areas within the Subsurface Disposal Area at the Idaho 

National Laboratory, Transuranic Waste Streams ID-SDA-DEBRIS, ID-SDA-SLUDGE and IDSDA-SOIL, Revision 12, August 2, 2013 

NDA BDR Nos. INNDAS120034, INNDAS130054 and INNDAS130055 

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 Documentation, 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 Documentation, 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 Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, ID-SDA-DEBRIS, May 8, 

2014 

Waste Material Parameter Analysis Memorandum, CCP-AK-INL-001, May 8, 2014 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, ID-SDA-SOIL, May 31, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, ID-SDA-SLUDGE, May 31, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, ID-SDA-DEBRIS, May 31, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 7 – 

Radionuclides, ID-SDA-SOIL, May 15, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 7 – 

Radionuclides, ID-SDA-SLUDGE, May 15, 2013 
J-6 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 7 – 

Radionuclides, ID-SDA-DEBRIS, May 15, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, 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 Number 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 Stream Number ID-SDA-DEBRIS, 

Heterogeneous Debris from the Subsurface Disposal Area, Lots 60–62, Cumulative for Lots 11–

62, May 20, 2013 

Memorandum from Carrie Johnson to CCP Records, Evaluation of the Radiological 

Characterization of Waste Streams ID-SDA-SLUDGE, IDA-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 dated 

AE-P-095, Waste Operations Operating Manual, ANL-E Waste Management Operations, 

Revision 1, August 2, 1999 

AMWTP Offsite Waste Stream Profile, AECHDM-PK, April 1, 2013 

C3002, Evaluation of Waste Material Parameter Weights 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 Streams ID-AECHDM and ID-AECHHM, 

John West, October 25, 2011 

C4004, CBFO Discrete Radiological Source Notification and Approval, D. Dietzel, June 11, 

2012 

C4005, Review of Non-Certified NDA Data for Prevalent Radionuclides in Waste Streams 

AECHDM-PK and AECHHM-PK, Steve Schafer, December 12, 2012 

CCP-AK-INL-025, Central Characterization Program Acceptable Knowledge Summary Report 

for Idaho National Laboratory Argonne Contact-Handled Transuranic Waste from Facility 

Maintenance and Laboratory Operations, Waste Streams: 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 (Example), 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 (Example), ID-AECHHM, Revision 1, January 

23, 2014 

CCP-TP-005, Revision 23, CCP Acceptable Knowledge Documentation, Attachment 7 – 

Radionuclides, ID-AECHDM, October 14, 2011, Draft revision provided May 7, 2014 

CCP-TP-005, Revision 23, CCP Acceptable Knowledge Documentation, Attachment 7 – 

Radionuclides, ID-AECHHM, October 14, 2011, Draft revision provided May 7, 2014 

CCP-TP-005, Revision 23, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, ID-AECHDM, September 29, 2011 

CCP-TP-005, Revision 23, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, ID-AECHHM, September 

29, 2011 

CCP-TP-005, Revision 23, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, ID-AECHDM, September 

29, 2011 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, ID-AECHHM, May 31, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, ID-AECHDM, May 31, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, ID-AECHDM, May 31, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, ID-AECHHM, May 31, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, ID-AECHDM, May 31, 2013 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, ID-AECHDM, Lot 4, October 21, 

2013 

Characterization Information Summary, WSPF No. ID-AECHDM, 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 Discrepancies Associated with the 

Assignment of Containers RW48078 and RW48190 to Waste 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 Stream 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 Stream AECHDM-PK and ID-AECHDM, 

January 16, 2013, Draft revision provided May 7, 2014 

Memorandum from Steve Schafer to CCP Records, Radiological Evaluation of Argonne CH 

TRU Debris Waste from Facility Maintenance and Laboratory 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, Radiological 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 (WIPP), WMO, WMO-DOC-6, Revision 0, 

December 9, 2009 

P3002, Solidification and Packaging CH-TRU Liquid Waste 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 09-WM-093, not dated 

P3003, Solidification and Packaging CH-TRU Liquid Waste for Shipment to Idaho National 

Laboratory and Final Disposition at the Waste Isolation Pilot Plant; Bench Scale Neutralization 

and Solidification, WMO, Work Plan 09-WM-094, not dated 

P3004, Project-Specific Sampling and Analysis Plan (PSAP) Containerized Waste Material 

DQO and SAP Instructions; CH TRU Liquids Bulking/Neutralization/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 Waste 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 Waste for Shipment to Idaho National 

Laboratory and Final Disposition at the Waste Isolation Pilot Plant, WMO, Work Plan 09-WM094, Revision 1, not dated 

P4005, Sort and Package CH-TRU Solid Waste for Shipment 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, Argonne, January 18, 2010 
J-9 

U3002, WDS Query and Compilation of Radiological Data for Waste Streams AECHDM and 

AECHHM, Chris Chancellor, May 5, 2010 

U3003, Historic WMO-195 Waste Requisitions for Containers 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 AECHDM-PK and AECHHM-PK, 

WMO, September 29, 2011 

U3006, Radionuclide Data for Waste Streams ID-AECHDM 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 Container Documentation, WMO, various 

dates 

U4011, Radionuclide Data for Waste Streams AECHDM-PK and AECHHM-PK with 

Containers Added during 2012 Campaign, WMO, December 7, 2012 

U4012, AMWTP Response to EPA regarding AMWTP-Derived Weighted Averages for 

Prevalent Radionuclides in Argonne Homogeneous Waste Streams, AMWTP, November 25, 

2012 

Waste Material Parameter Analysis Memorandum, CCP-AK-INL-025, March 23, 2011 

RH AK 

ID-ANLE-S5000 

CCP-AK-INL-500, CCP AK Summary Report for RH TRU Debris Waste from ANL-E Stored at 

INL, Waste Stream: ID-ANLE-S5000, Revision 11, November 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 Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, ID-ANLE-S5000, Lot 37, July 2, 

2013 

CCP-TP-005, Revision 25, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, ID-ANLE-S5000, Lot 38, August 12, 

2013 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, ID-ANLE-S5000, Lot 39, September 

5, 2013 
J-10 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, ID-ANLE-S5000, Lot 40, April 15, 

2014 

Characterization Information Summary, WSPF No. ID-ANLE-S5000, Lot 37, Revision 1, July 2, 

2013 

Characterization Information Summary, WSPF No. ID-ANLE-S5000, Lot 38, August 12, 2013 

Characterization Information Summary, WSPF No. ID-ANLE-S5000, Lot 39, September 5, 2013 

Characterization Reconciliation Report, ID-ANLE-S5000, Lot 37, July 2, 2013 

Characterization Reconciliation Report, ID-ANLE-S5000, Lot 38, August 12, 2013 

Characterization Reconciliation Report, ID-ANLE-S5000, Lot 39, September 9, 2013, Corrected 

May 7, 2014 

Characterization Reconciliation Report, ID-ANLE-S5000, 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 Remote-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 Stream Number ID-ANLE-S5000, Lots 1–

36, May 28, 2013 

Memorandum from Scott Smith to CCP Records, Revision 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 authors, various document numbers, 

various dates 

ID-HFEF-S5400-RH 

C4117, Evaluation of 13 RH-TRU Containers for Addition 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 Stream ID-HFEF-S5400-RH, Scott Smith, 

January 6, 2014 
J-11 

CCP-AK-INL-580, CCP AK Summary Report for Remote-Handled TRU Debris Waste from 

Materials and Fuels Complex Hot Fuel Examination Facility 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, November 25, 2013 

CCP-RC-INL-581, CCP Remote-Handled Transuranic Radiological Characterization Technical 

Report for RH TRU Debris Waste from Materials and Fuels Complex Hot Fuel Examination 

Facility at the Idaho National Laboratory, Waste Stream ID-HFEF-S5400-RH, Revision 0, 

September 25, 2013 

CCP-TP-005, Revision 22, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, ID-HFEF-S5400-RH, May 17, 2011 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, ID-HFEF-S5400-RH, February 27, 

2013 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, ID-HFEF-S5400-RH, May 8, 2014 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, ID-HFEF-S5400-RH, May 8, 2014 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, ID-HFEF-S5400-RH, Lot 23, April 

7, 2014 

Characterization Information Summary, WSPF No. ID-HFEF-S5400-RH, Lot 22, Revision 1, 

July 10, 2013 

Characterization Information Summary, WSPF No. ID-HFEF-S5400-RH, Lot 24, Draft, March 

18, 2014 

Characterization Reconciliation Report, ID-HFEF-S5400-RH, Lot 22, June 27, 2013 

Characterization Reconciliation Report, ID-HFEF-S5400-RH, Lot 24, Draft provided April 24, 

2014 

DTC BDR Nos. INLRHDTC1006, INLRHDTC10016, INLRHDTC12007 and 

INLRHDTC14003 

Inter-Office Correspondence from L. Nelson to I.S. Joo, EPA Acceptable Knowledge Accuracy 

Report, CCP-AK-INL-580, Idaho National Laboratory Remote-Handled Transuranic (RH-TRU) 

Waste Stream Number ID-HFEF-S5400-RH, Lots 1–23, May 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 INLRHRTR14003 

U484, Radioactive Scrap and Waste Storage/Disposal Request and Authorization Forms and 

Related Documents, not dated 

U992, RH TRU Container Repackaging Datasheets for HFEF 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 Individuals, May 1, 2014 

CCP-INL-174, Operator Aid: WAGS Pulser Parameter Data, December 21, 2009 

CCP-INL-266, Operator Aid: SGRS Pulser Parameter Data, September 17, 2013 

CCP-INL-251, Operator Aid: SGRS/WAGS Weekly Performance 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 the SGRS System after Detector 

Replacement and Energy Calibration, August 8, 2012 

CCP-INL-SGRS-12-005, Measurement Control Limit Update on the SGRS, October 17, 2012 

CCP-INL-WAGS-001, Revision 1, April 2008 

CCP-INL-WAGS-003, WAGS Calibration, Confirmation and Verification Report, Revision 0, 

May 18, 2011 

CCP-INL-WAGS-12-003, Measurement Control Limit Update for 356 keV count rate on the 

WAGS, July 19, 2012 

CCP-INL-WAGS-12-005, Calibration Verification of the 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, corresponding to day of EPA inspection and 

sampling of entries

SuperHENC BDR No. INNDAD13003 

SuperHENC Operational Logbook, May 6, 2013, corresponding to day of EPA inspection and 

sampling of entries

Summary of Containers Assayed on SGRS, WAGS and HENC, June 7, 2013 to April 30, 2014, 

prepared for inspection 

WAGS BDR Nos. INNDAW140033 and INNDAW130104 

WAGS Operational Logbook, May 6, 2014, corresponding 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, October 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 from the listed RH BDRs 

CCP-AK-INL-026, Central Characterization Program Acceptable Knowledge Summary Report 

for Idaho National Laboratory Sludge Repackage Project 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-TRAINING-25, NDE-TRAINING-26, NDETRAINING-1, NDE-TRAINING-25 and NDE-TRAINING-33 

List of CH VE BDRs generated since May 1, 2013, provided 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 personnel 

Qualification Cards for selected VE and RTR personnel 

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 various RTR operators 
J-14 

Training DVDs for various RTR personnel