DOCKET NO: A-98-49; II-A4-86 

WASTE CHARACTERIZATION REPORT FOR A TIER 1 CHANGE: 

EVALUATION OF THE SUPER HIGH EFFICIENCY NEUTRON COUNTER 

(SuperHENC) NON DESTRUCTIVE ASSAY SYSTEM AT 

THE CENTRAL CHARACTERIZATION PROJECT 

AT THE IDAHO NATIONAL LABORATORY (INL) 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center of Federal Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

February 2007
i

TABLE OF CONTENTS 

Section Page

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

2.0 Purpose of Inspections ........................................................................................................ 1 

3.0 Purpose of This Report........................................................................................................ 2 

4.0 Scope of Review.................................................................................................................. 2 

5.0 Evaluation Team ................................................................................................................. 2 

6.0 Evaluation of the CCP SuperHENC.................................................................................... 3 

7.0 Summary of Results ............................................................................................................ 8 

7.1 Conclusions ............................................................................................................. 9 
ii

ATTACHMENTS 

Attachment A SuperHENC Inspection Checklist 

Attachment B.1 Replicate Testing CCP SuperHENC Data for Container BN10139128 

(100-gallon Drum) 

Attachment B.2 Replicate Testing CCP SuperHENC Results for Container BN10139128 

(100-gallon Drum) 

Attachment B.3 Replicate Testing CCP SuperHENC Data for Container BN10141587 

(SWB) 

Attachment B.4 Replicate Testing CCP SuperHENC Results for Container BN10141587 

(SWB) 
1

1.0 EXECUTIVE SUMMARY 

In accordance with 40 CFR 194.8(b), the U.S. Environmental Protection Agency (EPA or the 

Agency) conducted Baseline Inspection No. EPA-INL-CCP-05.05-8 of the Central 

Characterization Project (CCP), located at the Idaho National Laboratory (INL) from May 3-5, 

2005. As a result of this baseline inspection, EPA approved the INL-CCP waste characterization 

(WC) program with conditions and limitations as documented in the INL Baseline Final 

Inspection Report (see EPA Docket No. A-98-49; II-A4-59). This baseline approval specified 

four nondestructive assay (NDA) systems. INL-CCP recently requested EPA approval of a Tier 

1 (T1) change at INL in the form of the addition of the Super High Efficiency Neutron Counter 

(SuperHENC) for assaying two types of waste containers. Based on EPA’s evaluation detailed 

in this report, EPA approves the SuperHENC for assaying contact-handled (CH) transuranic 

(TRU) wastes in the following configurations: 

• Standard Waste Boxes (SWBs) containing four 55-gallon drums of retrievably-stored 

S3000 sludge waste 

• 100-gallon overpacks containing compacted 55-gallon drums (pucks) of newlygenerated S5000 debris waste 

• SWBs containing 100-gallon drums, each of which contain compacted 55-gallon drums 

(pucks) of newly-generated S5000 debris waste 

This report serves as EPA’s evaluation of the SuperHENC for CH TRU wastes at INL-CCP as a 

T1 change. Using the information provided in this report, EPA has determined that the 

SuperHENC is adequate for characterization of CH TRU waste. This approval does not make 

any changes to the tiering table provided with the baseline approval. Changes to the approved 

components of the SuperHENC system at INL-CCP, must follow the tiering requirements 

described in the baseline inspection report issued for the INL-CCP CH program (Docket no. A98-49; II-A4-59, Dated November 1, 2005). 

 

2.0 PURPOSE OF INSPECTIONS 

Any changes to the WC activities from the date of the baseline inspection must be reported to, 

and, if applicable, approved by EPA, according to the tiering requirements set forth in the INLCCP Baseline Final Report cited above. 

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 WC program. 

The purpose of the baseline inspection is to approve the site’s WC program based on the 

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

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

TRU wastes destined for disposal at the WIPP. An EPA inspection team conducts an onsite 

inspection to verify that the site’s system of controls is technically adequate and properly 

implemented. 
2

Following EPA’s approval of WC processes evaluated during the baseline inspection, EPA is 

authorized to evaluate and approve, if necessary, changes to the site’s approved WC program by 

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

194.24, EPA has the authority to conduct continued compliance inspections to verify that the site 

continues to use only the approved WC processes to characterize the waste and remains in 

compliance with all the regulatory requirements. Based on the adequacies of the WC processes 

demonstrated during the baseline inspection, including all conditions and limitations, EPA 

specified which subsequent WC program changes or modifications must undergo further EPA 

approval under 40 CFR 194.24. This was accomplished by assigning a tier level to each aspect 

of the CCP’s characterization program. T1 activities have more stringent reporting requirements 

and require that DOE notify EPA, and that EPA provide approval prior to implementation. The 

rule under which baseline inspections are conducted can be found in the Federal Register (Vol. 

69, No.136, pages 42571–42583 of July 16, 2004). 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of the EPA’s evaluation of a T1 change of the implementation of 

the SuperHENC NDA system for assaying CH TRU wastes by INL-CCP. This inspection report 

documents the basis for EPA’s approval decision and explains the results of the technical 

evaluation of the SuperHENC at INL-CCP. 

EPA’s final approval decision regarding the SuperHENC located at INL-CCP has been conveyed 

to DOE separately by letter. EPA will also announce the decision on its website at 

www.epa.gov/radiation/WIPP, in accordance with 40 CFR 194.8(b)(3). 

4.0 SCOPE OF REVIEW

The scope of this evaluation was the operation of the SuperHENC NDA system located at INLCCP. The SuperHENC was evaluated with respect to its ability to identify and quantify the 

activities of the 10 WIPP-tracked radionuclides, lower limit of detection (LLD), Total 

Measurement Uncertainty (TMU), and other related technical aspects including the performance 

of replicate analyses of containers and the statistical evaluation of those replicates as described in

Section 6 of this report. 

5.0 EVALUATION TEAM 

All personnel involved in the SuperHENC evaluation are listed in Table 1 along with each 

person’s affiliation and function for the purpose of this inspection. For logistical reasons, Patrick

Kelly and Alan Simpson did not participate in the on-site evaluation at INL, but did participate in 

the subsequent teleconference. 

Table 1. Inspection Personnel

Personnel Affiliation Inspection Function - Area of 

Expertise 

Edward Feltcorn US EPA ORIA EPA Inspection Team Leader, NDA 
3

Table 1. Inspection Personnel

Personnel Affiliation Inspection Function - Area of 

Expertise 

Patrick Kelly SC&A EPA Inspector, NDA 

David Steunkel CTAC CTAC Technical Specialist 

Joe Wachter Canberra Industries Technical Support, SuperHENC 

John West BIL Technical Support, SuperHENC 

Martin Clapham BIL AMWTP Observer 

Alan Simpson BIL Technical Support, SuperHENC 

Joe Harvill CCP Technical Support, SuperHENC 

Porf Martinez CTAC Observer 

Mark Pearcy CCP Technical Support, NDA Records 

Dave Kimbro CTAC CBFO Audit Team Leader 

6.0 EVALUATION OF THE CCP SUPERHENC 

EPA inspected one SuperHENC NDA system that will be used to characterize CH TRU wastes 

at INL-CCP. The inspection occurred in two parts: (1) an onsite evaluation of the SuperHENC 

system and associated records and personnel at INL on January 23 – 24, 2007; and (2) a 

teleconference on January 31, 2007, during which additional details were provided and the 

system’s operational aspects were discussed. As part of the inspection, EPA reviewed the 

following elements of the SuperHENC process: 

• Capability of the measurement hardware and software to perform the required analyses 

• Technical adequacy of the NDA documents and procedures 

• Knowledge and understanding of the personnel involved in the NDA program 

Attachment A identifies the objective evidence that was examined for EPA’s evaluation. The 

following documents were among those examined to assess the INL-CCP SuperHENC: 

• CCP-TP-146, CCP SuperHENC Operating Procedure, Revision 1, January 4, 2007 

• CCP-TP-170, CCP SuperHENC Calibration Procedure, Revision 1, January 10, 2007 

• CCP-TP-148, CCP SuperHENC Data Reviewing, Validating and Reporting Procedure, 

Revision 1, January 10, 2007 

• BII-5221-CVR-001, Calibration and Validation Report SuperHENC Mobile Assay 

System, Revision 0, November 2006 

• CCP-SHENC-07-001, INL SuperHENC (HENC) Calibration Verification, Revision 0, 

January 10, 2007 

• BII-5169-ADD-001, SuperHENC Algorithm Definition Document 

• BII-5221-SRF-001, SUPERHENC RFETS Calibration Documentation Package, October 

31, 2006 
4

• CSM-01-06, Idaho National Laboratory Central Characterization Facility Standard Waste 

Box Matrix Surrogate Inspection Summary Report, September 18, 2006 

• BDR INNDAB070001 – Two SWBs, Nos. BN10141587 & BN10141586 

• BDR INNDAB070002 – Two 100-gallon overpacks, Nos. BN10139131 & BN10139128 

During the inspection, the EPA inspection team members assessed several technical elements of 

the SuperHENC system that are detailed in Attachment A and are discussed below. 

(1) The design and operational history of the SuperHENC was assessed. 

The SuperHENC system is located in a trailer on site at INL in the Radioactive Waste 

Management Complex (RWMC) adjacent to the Stored Waste Examination Pilot Plant 

(SWEPP), a building that houses other INL-CCP NDA systems used for characterizing TRU 

wastes. The SuperHENC was originally operational at the DOE’s Rocky Flats Environmental 

Technology Site (RFETS) in Golden, Colorado, where the site used this equipment to assay CH 

TRU wastes from 2001 until the site’s closure in 2006. At RFETS, this system was used to assay 

CH TRU wastes in SWBs1

 and 55-gallon (208-liter) drums; it was also used for nuclear material 

accountability and criticality safety compliance. At INL, this system will assay SWBs as well as 

100-gallon overpacks containing compacted 55-gallon drums referred to as pucks. Pucks are 

produced at a super compaction facility operated by the Advanced Mixed Waste Treatment 

Project (AMWTP) co-located in the RWMC at INL and are provided to INL-CCP post 

compaction. The three possible assay configurations for the SuperHENC are as follows: 

• SWBs containing four 55-gallon drums of retrievably-stored S3000 sludge waste 

• 100-gallon overpacks containing compacted 55-gallon drums (pucks) of newlygenerated S5000 debris waste 

• SWBs containing two 100-gallon drums, each of which contains compacted 55-gallon 

drums (pucks) of newly-generated S5000 debris waste. 

The materials the system will assay fall into two categories: S5000 debris which will have been 

loaded into 55-gallon drums and compacted into pucks by AMWTP that are overpacked in 

100-gallon drums; or S3000 sludge (solids) which will be packaged in 55-gallon drums and will 

not be compacted. 

 

This system consists of a passive neutron counter and an integral gamma-ray spectrometer, the 

SuperHENC Gamma Energy Analysis System (SGEAS). The passive neutron counter uses 240 

3He proportional counters in a 4-Β geometry and an external 252Cf source for the Add-a-Source 

(AAS) matrix correction function and an ANTEC advanced multiplicity shift register. The 

neutron component determines the mass of spontaneously fissioning material in waste 

containers, referred to as the 240PuEffective (

240PuEff). The 240PuEff is defined as the amount of 240Pu 

that would produce the observed true coincidence rate, after correcting for the neutron 

 

1

 A Standard Waste Box or SWB is a rectangular container with somewhat rounded corners whose 

measurements are approximately 54.5 inches wide by 37 inches high by 71 inches long. The cavity will accept 

containers up to 59 inches wide by 59 inches high by 91.5 inches long. 
5

moderation properties of the waste matrix. The system’s calibration was based on measurements 

of a non-interfering matrix and it includes a curve that relates the measured doubles rate for each 

container with the 240PuEff, as documented in BII-5221-CVR-001. Note that a development of an 

AAS correction factor is necessary to convert the observed doubles rate (with the sample matrix) 

to the equivalent calibration doubles rate (no matrix). The AAS correction curve is sufficiently 

robust to enable corrections over a wide range of materials or matrices. The SuperHENC is 

operated by a custom-tailored version of the Los Alamos National Laboratory (LANL) Neutron 

Coincidence Counting (NCC) software that controls data collection and analysis, AAS 

movements and all calibration and exception handling functions. 

 

The SGEAS consists of a single high-purity germanium (HPGe) detector that functions in two 

modes: relative ratio mode, where isotopic ratios are determined using the PCFRAM2

 isotopic 

code; and absolute mode, where the absolute quantities of specific radionuclides are determined 

based on analyzing gamma spectra. INL-CCP personnel stated that only the relative ratio mode 

will be used and that radionuclides will not be quantified on the basis of photon (gamma) 

emission only. Due to the levels of 241Am and its intense 59 keV photons anticipated in the 

SuperHENC samples, the HPGe is fitted with a fixed 1.09 mm cadmium/polyethylene filter that 

effectively removes photons below approximately 80 keV. There is an additional 10 mm steel 

filter that may be used for containers where 241Am concentrations are such that assay dead-time 

exceeds 25%. Each HPGe measurement consists of one 450-second count, following which the 

waste container is rotated 180°and a second 450-second count HPGe is initiated. The reported 

gamma results consist of the composite of both 450-second counts. 

The combination of neutron and isotopic distribution information allows quantification of 238Pu, 

239Pu, 240Pu, 241Am, 233U, 235U, 238U, 137Cs and 237Np. The 242Pu content is determined using 

BII’s Efficiency Times Attenuation (ETA) calculations in an approach that has been evaluated 

previously on several BII NDA systems at other TRU WC facilities. Each waste container’s 234U 

content is performed by application of scaling factors that are based on observed values for 235U 

and 238U. The determination of 90Sr is performed by application of a scaling factor based on 

137Cs. The CTAC Technical Specialist identified one documentation issue related to the use of 

radionuclide scaling factors. Procedure CCP-TP-148, Appendix 1, indicates that the scaling 

factors used to quantify 234U and 90Sr are obtained from AK and are specified by memorandum. 

However, these scaling factors were derived from report LA-UR-00-2584, and this discrepancy 

was noted in CBFO Corrective Action Report (CAR) No. 07-006. 

There are no EPA technical concerns regarding the design and ability of the SuperHENC to 

quantify the 10 WIPP-tracked radionculides. 

(2) The passive neutron and gamma calibrations of the SuperHENC had been performed as 

required. 

The original calibration of the SuperHENC was performed at RFETS in 2001, and is 

documented in BII-5221-SRF-001, SUPERHENC RFETS Calibration Documentation Package. 

 

2

 PCFRAM or FRAM is an initialization for Fixed-Energy Response Function Analysis with Multiple 

Efficiencies, a software code that is often used to determine the relative abundance (isotopic distribution) of 

radionuclides in weapons grade (WGP) Pu. 
6

This is the calibration of record for the INL-CCP SuperHENC. This calibration was confirmed 

at INL in 2006, and is documented in BII-5221-CVR-001, Calibration and Validation Report 

SuperHENC Mobile Assay System, Revision 0, November 2006. Calibration confirmation was 

performed with six measurements of an empty SBW over a range of Pu loadings from 0.913 to 

12.658 g 240PuEff (15.035 to 203.616 g Pu Total). The acceptance criteria for accuracy (Percent 

Recovery) and precision (Percent Relative Standard Deviation) were met for each of the six runs. 

The calibration itself is matrix independent, and additional testing will be performed in the future 

through the Weekly Interfering Matrix Checks that are required in DOE-WIPP-02-3122. The 

system’s stated operational ranges for neutron assays are from the Limit of Detection or LLD 

(discussed below) to 12.658 g 240PuEff, equivalent to 203.616 g weapons grade (WG) Pu as stated 

in BII-5221-CVR-001. These values conflicted with values for the system’s operational range 

found in CCP-TP-146 and CCP-TP-170. INL-CCP personnel acknowledged this discrepancy 

and committed to changing the two procedures to agree with BII-5221-CVR-001. This was 

acceptable. The energy versus channel calibration for the HPGe was performed using three 

photon lines from 152Eu at 121.8, 344.8 and 778.9 keV. This relationship is checked daily to 

ensure that the 344.8 keV peak’s centroid and Full-Width-a-Half-Maximum (FWHM) are within 

predetermined criteria shown in BII-5221-CVR-001, Table 2. Because the HPGe is used in 

relative ratio mode only, there is no true gamma operational range, although between 1 and 5 g 

of WG Pu are needed to successfully execute FRAM, depending on the matrix. 

Regarding matrix checks, INL-CCP stated that the SWB matrix surrogates that were used 

previously at RFETS were independently evaluated for the purpose of using them for the 

SuperHENC at INL-CCP. These efforts are documented in WTS CCP INL SWB Summary 

Report WIPP1-406914, Idaho National Laboratory Central Characterization Facility Standard 

Waste Box Matrix Surrogate Inspection Summary Report dated September 18, 2006. This is a 

reasonable approach to procuring additional matrix standards suitable for the SuperHENC. At 

this time there was no plan to obtain standards for the 100-gallon geometry. 

There are no technical concerns regarding the passive neutron and gamma calibrations of the 

SuperHENC. 

(3) The TMU of assays performed on the SuperHENC had been determined and documented. 

The determination of the TMU for the SuperHENC is documented in BII-5221-CVR-001, 

Section 4.1.1. This section addresses the effects on the passive neutron assay of the 

contributions from source position, calibration uncertainty and counting statistics, background, 

self-shielding, systematic end and spatial effects, neutron multiplication, and isotopics. For the 

HPGe, the TMU evaluation was minimal because the system will not be used to generate 

quantitative gamma data. There are no technical concerns regarding the determination and 

documentation of the SuperHENC’s TMU. 

(4) The LLD, including the minimum detectable concentration (MDC) of the SuperHENC had 

been determined and documented. 

The LLD was defined in CCP-PO-002, “CCP Transuranic Waste Certification Plan,” as: 
7

That level of radioactivity which, if present, yields a measured value greater than 

the critical level with a 95% probability, where the critical level is defined as that 

value which measurements of the background will exceed with 5% probability. 

In order to be able to discriminate TRU and non-TRU wastes, a NDA system must have an LLD 

less than 100 nCi of TRU alpha activity per gram (nCi/g) of waste. The LLD of any given NDA 

measurement depends on the type of measurement (passive neutron or gamma), the properties of 

the waste matrix being assayed, the data acquisition (measurement) time, and the environmental 

background. For this reason, the LLD is expected to vary from drum to drum and also may vary 

between measurements of the same drum. A neutron-based 240PuEff LLD was determined using 

eight measurements of a full SWB containing surrogate matrices (combustibles and metals) 

without any added Pu sources. The results of these assays were used to generate the matrixrelated and background-dependent terms that were incorporated in the Neutron Gamma 

Interrogation (NGI) software. NGI makes a determination of the LLD for each assay based on 

the sample’s measured net matrix mass using the matrix specific parameters that are stored in a 

NGI parameter file. BII-5221-CVR-001, Table 20 provides values for the neutron-based LLDs 

for a variety of net matrix masses from empty (0 kg) to very light (161.2 kg) to heavy (1925.7 kg) 

over a range of three 240Pu contents, WG (6% 240Pu), 12% 240Pu and 18% 240Pu. The limiting 

case of a very light matrix and Pu provides an LLD of 100 nCi/g and the heavier matrices and 

higher 240Pu contents provide LLD values less than 100 nCi/g. 

The SuperHENC uses LLD equivalents for 241Am, 238Pu, 239Pu, 240Pu, 241Pu and 242Pu because 

these are not determined directly by the SuperHENC. LLD equivalents are also used for 235U, 

238U and 137Cs because INL AK does not provide useable isotopic values for these radionuclides. 

These are called LLD equivalents because an absolute LLD is not determined for each of these 

radionuclides but instead is derived by applying each radionuclide’s mass fraction relative to 

240PuEff (isotopic contribution) to the 240PuEff neutron-based LLD. These values are summarized 

in BII-5221-CVR-001, Table 21. Only measured values that exceeded the reported LLD for that 

measurement were to be reported and were used in calculations of derived quantities, such as 

total TRU alpha activity and TRU alpha activity concentration. 

There are no technical concerns regarding the technical derivation and application of LLDs and 

LLD equivalents relative to the SuperHENC. 

(5) EPA replicate testing of the SuperHENC was performed and evaluated. 

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

an independent means to verify that the SuperHENC can provide consistent, reproducible results 

for the determination of the quantity of 10 WIPP-tracked radionuclides (241Am, 137Cs, 238Pu, 

239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U and 238U) and the TRU alpha concentration. This is normally 

accomplished by requesting that the site reassay drums that were previously characterized on the 

same system or instrument in order to demonstrate the following: 

• The instrument produces 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. 
8

• The instrument provides reproducible results over longer periods of time, such as weeks 

or months, by comparing the results of the replicate measurement(s) to the original 

reported values. 

EPA requested that INL-CCP reassay two waste containers that EPA randomly selected from a 

list of containers previously assayed on the SuperHENC. Due to the system’s short operational 

history, the list of potential candidates for replicate assays was small and the time between the 

original measurement and the five replicates was short. The following containers were chosen: 

• One 100-gallon drum containing S5000 debris, Container No. BN10139128 

• One SWB containing S3000 sludge (solid), Container No. BN10141587 

At EPA’s request, each of these previously assayed drums was reassayed five times on the 

SuperHENC for this inspection. Two statistical tests, a chi squared (χ2

) test and a t test, were 

performed on the replicate analyses of each container. Analytical data for each assay event and 

results of the statistical analysis are included in Attachments B.1 through B.4. 

For the 100-gallon drum Container No. BN10139128 the t test showed no statistically significant 

differences between the original measurement assay values and the average of the five replicate 

measurements for all measurement parameters. The χ2

 test for this same container showed that 

the observed variances in the replicate measurements were less than or equal to the reported 

uncertainties for all values within the statistical limits of the test. There are no outstanding issues 

with either statistical test for this container. 

For SWB Container No. BN10141587 the t test showed a highly significant flag for the 

difference between the original measurement assay values and the average of the five replicate 

measurements for 238Pu and 242Pu. This is probably attributable to the fact that the original 

measurements used isotopic information (mass fractions) from the SGEAS FRAM analysis, 

while for each of the five replicate assays, the FRAM analysis failed to produce reportable 

isotopics within the required uncertainty, i.e., they were not usable. The original FRAM-based 

measurement reported the 238Pu and 242Pu contents for this container as zero. However, for each 

of the five replicates, the AK-based isotopic value was used, based on the lack of a FRAM-based 

value, and the AK-based 238Pu and 242Pu values by definition are non-zero. The mass of nuclear 

material in the container appears to be close to the SuperHENC’s measurement threshold for the 

proper execution of FRAM. The χ2

 test for this same container showed that the observed 

variances in the replicate measurements were less than or equal to the reported uncertainties for 

all values within the statistical limits of the test. There are no outstanding issues with either 

statistical test for this container. 

7.0 SUMMARY OF RESULTS 

During this evaluation, the EPA did not identify any concerns or findings related to the operation 

of the INL-CCP SuperHENC. 
9

7.1 Conclusions 

During this T1 evaluation, EPA evaluated the performance of the INL-CCP SuperHENC. Based 

on the results of this evaluation, EPA is approving the INL-CCP SuperHENC NDA system for 

assaying retrievably-stored and/or newly-generated wastes in the following configurations: 

• Standard Waste Boxes (SWBs) containing four 55-gallon drums of retrievably-stored 

S3000 sludge waste 

• 100-gallon overpacks containing compacted 55-gallon drums (pucks) of newlygenerated S5000 debris waste 

• SWBs containing 100-gallon drums, each of which contain compacted 55-gallon drums 

(pucks) of newly-generated S5000 debris waste 

This approval does not make any changes to the tiering table provided with the baseline 

approval. Changes to the approved components of the SuperHENC system at INL-CCP, must 

follow the tiering requirements described in the baseline inspection report issued for the INLCCP CH program (Docket no. A-98-49; II-A4-59, Dated November 1, 2005). 

. 
Attachment A 

SuperHENC Inspection Checklist 
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-1 

Required Technical Elements Y/N Location Verification of Activity Y/N 

System Description Identify the NDA system by name, location and number, as appropriate. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The SHENC system has been identified and described. 

Y B

RDBaSS2

Describe the system’s operational history including deployment at other DOE sites. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The SHENC was previously deployed at RFETS from 2001 to 2006. Activities relative to the SHENC’s operation at RFETS have been documented. 

Y B

RDBaSS2

For systems that have been deployed at multiple DOE sites document pertinent aspects of each system’s development, e.g., installation of new or different detectors, software or other relevant features. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The SHENC was previously deployed at RFETS where the neutron calibration of record was performed. In 2006 it was refurbished by BIL in Santa Fe, New Mexico, prior to implementation at INL. These activities have been documented. 

Y B

RDBaSS2

System Performance Identify the period of performance relevant to this inspection and if this NDA system has 

prior EPA approval(s). 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The period of performance relevant to this inspection began with the first WIPP assays performed early in 2007. The SHENC’s prior EPA approval at RFETS has been documented. 

Y B

aSS2S
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-2 

Required Technical Elements Y/N Location Verification of Activity Y/N 

DIMS

Identify the type and number of waste containers this system assayed during the 

period of performance. Of these, indicate 

how many Batch Data Reports (BDRs) were assembled. Of the assembled BDRs, indicate how many have been promoted through Project Level Review and are available for evaluation during this inspection. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

INL-CCP assembled two BDRs: one for SWBs and one for 100-gallon overpacks, and both have been through Project Level Review. These and assays from 6 other containers were available for evaluation during this inspection. 

Y B

N
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-3 

Required Technical Elements Y/N Location Verification of Activity Y/N 

General Reporting Requirements Assay systems must report quantitative values and uncertainties for 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 233U, 234U, 238U, 90Sr, and 137Cs. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Quantitative values and uncertainties for 

238Pu, 239Pu, 240Pu, 242Pu, 241Am, 233U, 234U, 238U, 90Sr and 137Cs are reported. 

Y B

aSS

2a

Each container characterized and intended for disposal at WIPP must contain TRU waste. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Containers classified as TRU waste all contain greater than 100 nCi/g of TRU radionuclides. 

Y B

aSS2a

NDA instruments and procedures are 

appropriate for the waste streams being assayed. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The SHENC and supporting CCP operational procedures are appropriate for the S5000 debris and S3000 solid waste streams being assayed. 

Y C

OJCP1SVPJ

NDA instruments and procedures result in 

unbiased values for the cumulative activity of the WIPP radionuclide inventory. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Operation of the SHENC and supporting procedures result in unbiased values for the cumulative activity of the WIPP radionuclide inventory. 

Y B

aSS2a

Some radionuclides are derived by the application of scaling factors or correlation techniques. Identify all radionuclides that are 

Y CCP-PO-002, CCP 

Transuranic Waste 

All radionuclides derived by the application of scaling factors or 

Y B

aS
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-4 

Required Technical Elements Y/N Location Verification of Activity Y/N 

quantified in this manner. Certification Plan correlation techniques are identified. S

2

Assess the technical adequacy of the calculations involving the application of scaling factors and/or correlation techniques. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The scaling factors are technically appropriate and documented. 

Y B

aSS2

Identify the procedures that govern this function and where the results of these calculations are documented. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The procedures that govern the application of scaling factors are identified, and the results of these calculations are documented. 

Y B

Nb

A

Acceptable Knowledge (AK) If isotopic ratios based on AK are used the values are qualified by confirmatory testing. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Isotopic ratios used in quantifying radionuclides are qualified by confirmatory testing when AK is used. 

Y B

aSS2

Do NDA personnel use AK derived isotopic values to calculate radionuclide values? If so, is this function performed according to a formal procedure? Assess the technical adequacy of this process(s). 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The EA uses AK-based or FRAMderived isotopics values in conjunction with passive neutron data to calculate radionuclide values, as described in a INL-CCP technical procedure. 

Y C

BaSS2

Identify the procedure and where the results of these calculations are documented. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The procedure for these calculations and their results are documented. 

Y C

N

s

Isotopic Determination Identify the radionuclides that are measured directly and the specific radiation type ((, AN 

Y CCP-PO-002, CCP 

Transuranic Waste 

240PuEff is measured directly based on a 

passive neutron assay. Other Pu 

Y C

Ba
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-5 

Required Technical Elements Y/N Location Verification of Activity Y/N 

or PN) that is measured. Certification Plan radioisotopes are scaled to the 240PuEff. S

S2

Identify the method(s) used to derive the isotopic contribution for the unmeasured radionuclides, e.g., MGA, PC FRAM, or other technique. 

 CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

PC FRAM and/or AK is used to derive the isotopic contribution for the unmeasured radionuclides. 

Y C

BaSS2
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-6 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Lower Level of Detection (LLD) The LLD for each NDA system must be determined. For multi-modal systems, this may require a separate determination for each mode, i.e., active neutron, passive neutron and gamma. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The LLD for the SHENC in the passive neutron mode has been determined and documented. The system’s gamma mode is only quantitative and is not applicable. 

Y B

aSS2

LLD determinations must account for sitespecific environmental backgrounds and container-specific interferences. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

LLD determinations account for sitespecific environmental backgrounds and container specific interferences. 

Y B

aSS2

NDA instruments performing TRU/NonTRU waste discrimination measurements are 

required to have a LLD no greater than 100 nCi/g. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The SHENC is used to perform TRU/Non-TRU waste discrimination and it has a LLD of less than 100 nCi/g. 

Y B

aSS2

The technical basis and derivation for LLDs must be adequate and appropriately documented. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The technical basis and derivation for LLDs are adequate and documented. 

Y B

aSS2a

For radionuclides that are not determined 

primarily by measurement of an LLD analog, 

i.e., a reporting threshold must be used when it is technically feasible. Identify all instances when this occurs and the form of the documentation of these activities. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

LLD equivalents for 241Am, 238Pu, 239Pu, 

240Pu, 241Pu, and 242Pu are determined by 

ratioing them to the LLD for the passive neutron-based 240PuEff based on their 

mass fractions (isotopic contribution). 

LLD equivalents for 234U and 90Sr are 

derived by scaling them to 235U and 

238U, and 137Cs, respectively. 

Y B

aSS2
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-7 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Identify any/all instances where an LLD value for a non-measured radionuclide is not 

provided based on a lack of technical 

feasibility. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

There are no instances where INL-CCP does not provide an LLD value or analog (equivalent) for a radionuclide 

based on a lack of technical feasilibilty. 

NA N

Are LLD values container/assay event specific or are typical LLD values applied to a class or type of wastes, i.e., those with similar attributes? If LLD values are not container/assay event specific, identify the attributes or characteristics whereby waste containers are grouped. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

LLDs are container or assay event specific. The technical basis for LLD values and LLD equivalents has been 

determined and documented. 

Y B

RDBaSS2II

Total Measurement Uncertainty (TMU) The method used to calculate the TMU for all required quantities must be documented and technically justified. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The method used to calculate the TMU for the SHENC is documented and technically justified. 

Y B

RDBaSS2

TMU determination accounts for all sources of uncertainty, specifically 

• Background • Calibration • Isotopic determination • Matrix heterogeneity • Difference between waste and matrix 

specific calibration 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The TMU determination accounts for all sources of uncertainty, specifically: 

• Background • Calibration • Isotopic determination • Matrix heterogeneity • Difference between waste and 

matrix specific calibration 

Y B

RDBaSS2
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-8 

Required Technical Elements Y/N Location Verification of Activity Y/N 

• Source position effects • End effects 

• Self shielding • Neutron multiplication

• Source position effects • End effects • Self shielding • Neutron multiplication 

Methods to determine TMU must be documented, reviewed, and approved by CBFO for each NDA instrument. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Methods to determine TMU have been documented, reviewed, and approved by CBFO for the SHENC. 

Y B

RDBaSS2
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-9 

Required Technical Elements Y/N Location Verification of Activity Y/N 

System Calibration Each NDA instrument must be calibrated 

before its initial use. Determine the date of 

the system’s calibration of record and where this is documented. For multi-modal systems, specify the calibration for each mode. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The SHENC had been calibrated at RFETS before its initial use and the calibration of record has been documented. Calibrations include 

passive neutron for 240PuEff and gamma 

(for relative ratio mode operation only). 

Y B

RDBaSS2

The range of applicability of the system’s calibration(s) must be specified in site 

procedures or other formal documentation. 

Identify the manner in which the range is expressed, i.e., curies or Pu/SNM mass for activity and salient physical characteristics for matrix. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The range of applicability of the SHENC’s calibration has been specified and documented. BII-5221-CVR-00112 states the system’s range as 12.658 g 

240PuEff (203.8 g Pu total) which 

conflicts with CCP-TP-146 and CCP-TP-170 (14.35 240PuEff or 208 g Pu 

Total). INL-CCP changed CCP-TP-146 and CCP-TP-170 to agree with BII-5221-CVR-0011. 

Y B

aSS2

Any matrix/source surrogate waste combinations must be representative of the activity ranges and relevant waste matrix characteristics currently in use or planned for use by the system. The system must be calibrated to 100% recovery. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Matrix/source surrogate waste combinations are representative of the activity ranges and relevant physical characteristics of the matrices currently measured by the SHENC but only for the SWB geometry, not for the 100-gallon drums. The SHENC is calibrated to 100% recovery. 

Y B

aSS2

The use of consensus standards for calibration is required, when such standards exist. If consensus standards do not exist, the calibration technique must be approved by CBFO. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Neutron calibration of the SHENC is based on consensus standard ASTM C 

1207-03, Standard Test Method for 

Nondestructive Assay of Plutonium in 

Scrap and Waste by Passive Neutron Counting. Gamma energy versus 

Y B

aSS2
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-10 

Required Technical Elements Y/N Location Verification of Activity Y/N 

channel calibration is based on ASTM C1030, Standard Method for the 

Determination of Plutonium Isotopic 

Composition by Gamma-Ray Spectroscopy.

Identify the specific consensus standards that were used for the system calibration or, in their absence, the alternate calibration technique. If applicable, evaluate the formal CBFO approval of the alternate technique. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

See preceding checklist item. Y S

Primary standards must be obtained from suppliers maintaining a nationally accredited measurement program. Identify the nationally accredited measurement program. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Primary PuO2 standards were obtained 

from Bob Marshall’s NDA CEP WRM Production Group at LANL. This organization maintains a nationally accredited measurement program. The standards used for the system’s initial calibration at RFETS were identified 

but were not examined during this 

inspection. 

Y B

RDBaSS2

List the standards used for calibration and verify the pedigree of each standard. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The calibration standards used for the SHENC calibration, calibration confirmation, and calibration verification are listed. The pedigree of the standards used for calibration confirmation and verification were verified. Certificates for the standards used for the system’s initial passive neutron calibration at RFETS were not examined during this inspection. 

Y B

aSS2SD

Calibration Verification & Confirmation Verification of an NDA instrument’s calibration must be performed after any of 

Y CCP-PO-002, CCP 

Transuranic Waste 

Verification of the SHENC’s calibration has been performed and documented as 

Y B

B
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-11 

Required Technical Elements Y/N Location Verification of Activity Y/N 

the following occurrences: major system repairs and/or modifications, replacement of the system’s components, significant changes to the system’s software, and relocation of the system. 

Certification Plan required. a

SS2

Recalibration of the system must occur if the calibration verification demonstrates that the system’s response has significantly changed. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Recalibration of the SHENC has not 

been performed at this time. One 

calibration verification was performed to ensure that the system’s response had not significantly changed following mechanical repairs. 

Y C

SV1

The system calibration must be confirmed by 

performing replicate measurements of a noninterfering matrix. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The SHENC’s calibration has been confirmed by performing replicate measurements of a non-interfering matrix. 

Y B

aSS2

Replicate measurements must be performed with containers of the same nominal size and according to the same procedures used for actual waste assays. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Replicate measurements have been 

performed on the SHENC with SWBs 

only; 100-gallon drums have not been used at this time. 

Y B

aSS2

Replicate measurements must be performed using nationally recognized standards or standards derived from nationally recognized standards that span the range of use of the instrument with respect to disintegration rate and/or matrix effects. Identify all standards that were used and indicate their application (verification or confirmation). 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Replicate measurements have been 

performed using nationally recognized 

standards that span the range of use of the instrument with respect to disintegration rate and/or matrix. All standards used for verification and confirmation have been identified and their applications have been documented. 

Y B

aSS2

Identify the nationally accredited measurement program. List the standards 

Y CCP-PO-002, CCP 

Transuranic Waste 

Bob Marshall’s NDA CEP WRM Production Group at LANL participates 

Y B

a
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-12 

Required Technical Elements Y/N Location Verification of Activity Y/N 

used for verification/confirmation and verify the pedigree of each standard. 

Certification Plan in a nationally accredited measurement 

program. The pedigree of the each 

standard used for verification and/or confirmation has been verified. 

SS2

The standards used for calibration confirmation must be different from the sources used for the system’s calibration of record. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The standards used for calibration confirmation are different from the sources used for the SHENC’s calibration of record. 

Y B

aSS2

Requirements for accuracy, expressed as %R, and precision, expressed as %RSD, must be met as specified in DOE/WIPP-02-3122, Appendix A, Table A-3.2 for precision and ∀30% for accuracy. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Requirements for accuracy and 

precision have been met as specified in 

DOE/WIPP-02-3122, Appendix A, Table A-3.2 for precision and ∀30% for 

accuracy. 

Y B

aSS2
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-13 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Quality Control All radioassay and data validation must be 

performed by appropriately trained and 

qualified personnel. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

SHENC data validation is performed by appropriately trained and qualified 

personnel. There are 2 Expert Analysts 

(EA) −John West and Alan Simpson. 

Y C

d

Identify the name, title and function of all 

personnel performing NDA data validation. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

John West, BII SuperHENC Principal Scientist; and Alan Simpson, BII SuperHENC Principal Scientist 

Y C

d

Requalification of personnel must be based on evidence of continued satisfactory 

performance and must be performed at least 

every two years. 

Y CCP-TP-148, Revision 1; 

discussions with John West 

Not assessed during this inspection. NA N

All computer programs, including spreadsheets used for data reduction or analysis, must meet the applicable requirements in the CBFO QAPD. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Not assessed during this inspection. NA N

The site must participate in relevant measurement comparison programs sponsored or approved by CBFO, including the NDA PDP. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The SHENC has participated in the CBFO sponsored NDA PDP by assaying a non-interfering, metal and combustible matrices, all in the SWB geometry. Results must be submitted to CBFO for scoring by February 16, 2007, and were not available during this inspection. 100-gallon containers were not measured for the PDP. 

Y D

Background and Performance Checks Assay system background measurements must be taken daily, unless otherwise approved by CBFO. Determine the form of CBFO approval documentation of the 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Daily background measurements have 

been taken and recorded for the 

SHENC. Contributions to backgrounds from nearby radiation sources have been 

Y B

N

it
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-14 

Required Technical Elements Y/N Location Verification of Activity Y/N 

alternate approach to backgrounds, if applicable. Contributions to backgrounds from nearby radiation sources must be carefully controlled, or more frequent 

backgrounds must be measured. 

controlled. Site operators control the gamma detector’s field of view. Since the neutron system could be affected by the SHENC’s proximity to another 

NDA system that assays radionuclidebearing samples and has gamma 

transmission sources (INL-CCP SGRS), the gamma system’s axis is rotated 90°. 

t

Assess how often background radiation was 

problematic to the extent that measurement personnel had to make adjustments. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Background records document the SHENC’s performance over time. 

Y B

N

Identify the criteria used to evaluate instrument backgrounds and assess the technical adequacy of this criterion, i.e., statistical or administrative. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Backgrounds have been evaluated against a technically appropriate acceptance criterion, and the nature and results of these evaluations have been documented. 

Y B

N

BaSS2

Identify the number of data points required to derive the initial control limit. At what interval(s) will new limits be calculated? 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The number of data points required to derive the initial control limits and the interval(s) at which new limits be calculated are documented. 

Y B

aSS2

System performance checks must be 

performed at least once per operational day. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Performance checks have been 

performed at least once per operational 

day and all checks have been documented. 

Y S

B

N

BaSS2
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-15 

Required Technical Elements Y/N Location Verification of Activity Y/N 

System performance checks must include, as applicable, efficiency, matrix correction checks, and systems peak position and resolution for spectrometric systems. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Performance checks include efficiency, matrix correction checks, and peak 

position and resolution for 

spectrometric systems. 

Y B

N

BaSS2

At a minimum of once per operational week, an interfering matrix must be assayed to assess the long-term stability of the NDA instrument and its matrix corrections and how this performance is documented. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Three interfering matrix checks have 

been performed to date, all using the 

SWB geometry. At least one has been 

performed per operational week. 100-

gallon standards are not available. 

Y B

N

Interfering surrogate waste matrices must be constructed in a way that the salient matrix characteristics do not change over time. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Interfering surrogate waste matrices are adequate. Matrix standards from RFETS have been independently evaluated and may be refurbished and used for the SHENC in the future. 

Y C

LCSSR

The radionuclide sources used for 

performance checks must be long-lived and 

of sufficient strength (activity) to provide statistically sufficient results over a short measurement time. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The radionuclide sources used for 

performance checks are long-lived and 

are of sufficient strength (activity) to 

provide statistically sufficient results 

over a short measurement time. 

Y B

aSS2

Radioactive sources are decay corrected as a function of their physical half-life, as appropriate, specifically133Ba, 252Cf, 137Cs, 75Se and 109Cd. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Documentation indicates that the 252Cf 

source is decay corrected as a function of its physical half-life, as appropriate. 

Y B

N

Performance checks must be quantitative and 

based on two and three sigma limits. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

SHENC performance checks are quantitative and based on two and three sigma limits. 

Y 
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-16 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Identify how many data points are used for the initial evaluation and at what interval(s) new limits are calculated. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Nine (9) data points are used for the 

initial evaluation. New limits are calculated after acumulating approximately 30 data points 

Y B

N

C

MN
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-17 

Required Technical Elements Y/N Location Verification of Activity Y/N 

Data Management All radioassay data must be reviewed and approved by qualified personnel before being reported to WWIS. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

All radioassay data have been reviewed and approved by qualified personnel 

before being reported to WWIS. 

Y B

N

Identify the name, title, and function of the individual(s) performing technical review and approval of NDA BRDs. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The name, title and function of the individual(s) performing technical review and approval of SHENC BRDs are documented. 

Y B

N

Radioassay BDRs must consist of the following elements: 

• Testing facility name, testing batch 

number, container numbers, and signature of the Site Project Officer (SPO) or designee(s) 

• 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. 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

SHENC BRDs contain the following: 

• Testing facility name, testing batch 

number, container numbers, and signature of the Site Project Officer (SPO) or designee(s) 

• 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. 

BDRs were found to exclude ROI Reports, Neutron Background Reports, 

Neutron 252Cf Normalization Reports 

and Daily Plutonium Standard Check Reports. 

Y B

N

C0

Radioassay data sheets must include: 

• Title “Radioassay Data Sheet” • Method/procedure used 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

Radioassay data sheets include: 

• Title “Radioassay Data Sheet” • Method/procedure used 

Y B

N
NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: INL-CCP T1 Change 

Inspection Date: January 23 – 25, 2007

NDA System: Super High Efficiency Neutron Counter (SHENC)

A-18 

Required Technical Elements Y/N Location Verification of Activity Y/N 

• Date of radioassay • Activities and associated TMU for 

individual radionuclides 

• TRU alpha concentration and its 

associated TMU 

• Operator signature 

• Reviewer signature 

• Date of radioassay • Activities and associated TMU for 

individual radionuclides 

• TRU alpha concentration and its 

associated TMU 

• Operator signature • Reviewer signature 

The following nonpermanent records must be maintained at the radioassay-testing facility or forwarded to the site project office: 

• Testing batch reports • All raw data, including instrument 

readouts, calculation records, and radioassay QC results 

• All applicable instrument calibration 

reports 

Y CCP-PO-002, CCP 

Transuranic Waste Certification Plan 

The following nonpermanent records are maintained at the radioassay testing facility on a CD and the originals are stored at the CCP offices in Carlsbad, 

New Mexico: 

• Testing batch reports • All raw data, including AAS data 

and raw neutron counts required to regenerate the results 

• All applicable instrument 

calibration reports 

Y I
Attachments B.1 through B.4
Attachment B.1 Replicate Testing CCP SuperHENC Data for Container BN10139128 (100-gall

B-1 

Instrument: SuperHENC

Container: BN10139128, 100-gallon drum

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 1.75E-05 5.53E-06 3.16E-01 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 9.97E-04 1.60E-04 1.60E-01 1.10E-03 1.86E-04 1.69E-01 9.97E-04 239Pu Activity (Ci) 3.79E-02 6.06E-03 1.60E-01 4.18E-02 7.06E-03 1.69E-01 3.79E-02 240Pu Activity (Ci) 8.63E-03 1.38E-03 1.60E-01 9.54E-03 1.61E-03 1.69E-01 8.63E-03 242Pu Activity (Ci) 7.37E-07 1.18E-07 1.60E-01 8.15E-07 1.38E-07 1.69E-01 7.37E-07 241Am Activity (Ci) 8.96E-03 2.36E-03 2.63E-01 1.07E-02 2.09E-03 1.95E-01 4.96E-03 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 2.19E+02 3.58E+01 1.63E-01 2.45E+02 4.15E+01 1.70E-01 2.03E+02 

Replicate #3 Replicate #4 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 1.13E-03 1.86E-04 1.65E-01 1.08E-03 1.86E-04 1.73E-01 9.45E-04 239Pu Activity (Ci) 4.28E-02 7.06E-03 1.65E-01 4.08E-02 7.05E-03 1.73E-01 3.59E-02 240Pu Activity (Ci) 9.77E-03 1.61E-03 1.65E-01 9.32E-03 1.61E-03 1.73E-01 8.18E-03 242Pu Activity (Ci) 8.35E-07 1.38E-07 1.65E-01 7.96E-07 1.37E-07 1.73E-01 6.99E-07 241Am Activity (Ci) 5.61E-03 9.25E-04 1.65E-01 5.35E-03 9.24E-04 1.73E-01 4.70E-03 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 2.30E+02 3.79E+01 1.65E-01 2.19E+02 3.79E+01 1.73E-01 1.93E+02 
Attachment B.2 Replicate Testing CCP SuperHENC Results for Container BN10139128 (100-ga

B-2 

Instrument: SuperHENC Container: BN10139128, 100-gallon drum

Original Measurement Sample Relative 

Quantity of Reported Absolute Sample Standard Standard Interest Value Uncertainty Mean Deviation Deviation χ

2 Pr(

x <|χ

2|) 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE234U Activity (Ci) 1.75E-05 5.53E-06 0.00E+00 0.00E+00 N/A 0.00E+00 1.00E+0238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE238Pu Activity (Ci) 9.97E-04 1.60E-04 1.05E-03 7.65E-05 7.29E-02 9.20E-01 9.22E-0239Pu Activity (Ci) 3.79E-02 6.06E-03 3.98E-02 2.90E-03 7.29E-02 9.19E-01 9.22E-0240Pu Activity (Ci) 8.63E-03 1.38E-03 9.09E-03 6.63E-04 7.29E-02 9.19E-01 9.22E-0242Pu Activity (Ci) 7.37E-07 1.18E-07 7.76E-07 5.66E-08 7.29E-02 9.19E-01 9.22E-0241Am Activity (Ci) 8.96E-03 2.36E-03 6.27E-03 2.52E-03 4.01E-01 4.56E+00 3.35E-090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUETRU Alpha Conc. (nCi/g) 2.19E+02 3.58E+01 2.18E+02 2.09E+01 9.56E-02 1.36E+00 8.51E-0Quantity of Interest χ

2 Test t Test 

233U Activity (Ci) #VALUE! Not Applicable 234U Activity (Ci) Not Significant Not Applicable 238U Activity (Ci) #VALUE! Not Applicable 238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) Not Significant Not Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) #VALUE! Not Applicable 137Cs Activity (Ci) #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
Attachment B.3 Replicate Testing CCP SuperHENC Data for Container BN10141587 (SW

B-3 

Instrument: SuperHENCContainer: BN10141587, SWB 

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 4.12E-03 1.13E-03 2.75E-01 4.02E-03 239Pu Activity (Ci) 1.56E-01 4.95E-02 3.17E-01 1.56E-01 4.30E-02 2.75E-01 1.52E-01 240Pu Activity (Ci) 3.84E-02 1.11E-02 2.89E-01 3.57E-02 9.82E-03 2.75E-01 3.48E-02 242Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 3.05E-06 8.38E-07 2.75E-01 2.97E-06 241Am Activity (Ci) 3.01E-02 9.78E-03 3.25E-01 2.46E-02 7.75E-03 3.15E-01 3.39E-02 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 2.78E+02 8.85E+01 3.18E-01 2.73E+02 7.53E+01 2.76E-01 2.79E+02 

Replicate #3 Replicate #4 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 4.02E-03 1.13E-03 2.82E-01 4.15E-03 1.16E-03 2.80E-01 4.30E-03 239Pu Activity (Ci) 1.52E-01 4.30E-02 2.82E-01 1.57E-01 4.40E-02 2.80E-01 1.63E-01 240Pu Activity (Ci) 3.48E-02 9.81E-03 2.82E-01 3.59E-02 1.00E-02 2.80E-01 3.73E-02 242Pu Activity (Ci) 2.97E-06 8.37E-07 2.82E-01 3.07E-06 8.59E-07 2.80E-01 3.18E-06 241Am Activity (Ci) 3.74E-02 1.12E-02 2.99E-01 3.61E-02 1.13E-02 3.13E-01 3.43E-02 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 2.83E+02 8.00E+01 2.83E-01 2.89E+02 8.11E+01 2.81E-01 2.96E+02 
Attachment B.4 Replicate Testing CCP SuperHENC Results for Container BN10141587 (S

B-4 

Instrument: SuperHENC Container: BN10141587, SWB 

Original Measurement Sample Relative 

Quantity of Reported Absolute Sample Standard Standard Interest Value Uncertainty Mean Deviation Deviation χ

2 Pr(

x <|χ

2|) 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE238Pu Activity (Ci) 0.00E+00 N/A 4.12E-03 1.19E-04 2.88E-02 #VALUE! #VALUE239Pu Activity (Ci) 1.56E-01 4.95E-02 1.56E-01 4.51E-03 2.88E-02 3.32E-02 1.00E+0240Pu Activity (Ci) 3.84E-02 1.11E-02 3.57E-02 1.03E-03 2.88E-02 3.45E-02 1.00E+0242Pu Activity (Ci) 0.00E+00 N/A 3.05E-06 8.78E-08 2.88E-02 #VALUE! #VALUE241Am Activity (Ci) 3.01E-02 9.78E-03 3.32E-02 5.04E-03 1.52E-01 1.06E+00 9.00E-090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUETRU Alpha Conc. (nCi/g) 2.78E+02 8.85E+01 2.84E+02 8.92E+00 3.14E-02 4.07E-02 1.00E+0Quantity of Interest χ

2 Test t Test 

233U Activity (Ci) #VALUE! Not Applicable 234U Activity (Ci) #VALUE! Not Applicable 238U Activity (Ci) #VALUE! Not Applicable 238Pu Activity (Ci) #VALUE! Highly Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) #VALUE! Highly Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) #VALUE! Not Applicable 137Cs Activity (Ci) #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Not Significant