EPA DOCKET NO. A-98-49; II-A4-192 

WASTE CHARACTERIZATION REPORT 

TIER 1 CHANGE EVALUATION: 

ADDITION OF THE MOBILE ISOCS LARGE CONTAINER COUNTER 2 

FOR THE CENTRAL CHARACTERIZATION PROGRAM 

AT THE OAK RIDGE NATIONAL LABORATORY 

 

August 5–6, 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 

October 2014 
i 

TABLE OF CONTENTS 

1.0 Introduction ......................................................................................................................... 1

2.0 Purpose of Tier 1 Evaluations ............................................................................................. 3

3.0 Purpose of This Report ....................................................................................................... 3

4.0 Scope of Review ................................................................................................................. 3

5.0 Evaluation Personnel .......................................................................................................... 4

6.0 Technical Evaluation .......................................................................................................... 4

6.1 System Description ................................................................................................. 4

6.2 Documents Reviewed ............................................................................................. 5

6.3 Evaluation Checklist ............................................................................................... 6

6.4 Measurement Geometries ....................................................................................... 6

6.5 Calibration, Calibration Validation and Confirmation ........................................... 8

6.6 Operating Range ..................................................................................................... 9

6.7 Lower Limit of Detection Determination ............................................................... 9

6.8 Total Measurement Uncertainty ........................................................................... 10

6.9 Batch Data Reports ............................................................................................... 11

6.10 Replicate Assays ................................................................................................... 11

7.0 Findings and Concerns ...................................................................................................... 13

8.0 Conclusions ....................................................................................................................... 13

TABLES 

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

Implemented by ORNL-CCP ........................................................................................... 2

Table 2. Evaluation Personnel ........................................................................................................ 4

FIGURES 

Figure 1. 55-Gallon Drum Measurement Configurations ............................................................... 7

ATTACHMENTS 

Attachment A Approval Summary for ORNL-CCP Contact-Handled Waste 

Characterization Program 

Attachment B Mobile ISOCS Large Container Counter Evaluation Checklist 

Attachment C.1 MILCC2 Replicate Testing Results for Container No. X10CSATN02626B, 

Near-Field Position 

Attachment C.2 MILCC2 Replicate Testing Results for Container No. X10CSATN02023P, 

Mid-Field Position 

Attachment C.3 MILCC2 Replicate Testing Results for Container No. X10CSATN01937AG, 

Far-Field Position 
ii 

ACRONYMS AND ABBREVIATIONS 

AK acceptable knowledge 

AKE acceptable knowledge expert 

AKSR AK summary report 

Am americium 

ASTM American Society for Testing and Materials 

BDR batch data report 

BEGe Broad Energy Germanium 

CBFO Carlsbad Field Office 

CCP Central Characterization Program 

CFR Code of Federal Regulations

CH contact-handled 

Ci curie 

CIS characterization information summary 

CMB corrugated metal boxes 

Cs cesium 

CTAC CBFO Technical Assistance Contractor 

DOE U.S. Department of Energy 

DWAS Digital Waste Assay System 

EA Expert Analyst 

EPA U.S. Environmental Protection Agency 

FRAM Fixed-Energy Response-Function Analysis with Multiple Efficiencies 

g gram 

g/cc grams per cubic centimeter 

in. inch 

IPAN imaging passive active neutron 

ISOCS In Situ Object Counting System 

ITR Independent Technical Reviewer 

IUE ISOCS Uncertainty Estimator 

keV kilo-electron volt 

ORNL Los Alamos National Laboratory 

LLD lower limit of detection 
iii 

LOQI list of qualified individuals 

MCNP Monte Carlo N-Particle Transport Code 

MCS Mobile Characterization Services 

MDA minimum detectable activity 

MDC minimum detectable concentration 

MeV mega-electron volt 

MGA Multi-Group Analysis 

MILCC2 Mobile ISOCS Large Container Counter-2 

nCi/g nanocuries per gram 

NCR nonconformance report 

NDA nondestructive assay 

NDE nondestructive evaluation 

NFS Nuclear Fuel Services 

NIST National Institute of Standards and Technology

Np neptunium 

NWP Nuclear Waste Partnership, LLC 

OA operator aid 

ORNL Oak Ridge National Laboratory 

PDP Performance Demonstration Program 

Pu plutonium 

QA quality assurance 

RDS Radioassay Data Sheet 

RTR real-time radiography 

SCG Summary Category Group 

SGS segmented gamma scanner 

SLB2 Standard Large Box-2 

SNM special nuclear material 

SPM Site Project Manager 

Sr strontium 

SWB Standard Waste Boxes 

T1 Tier 1 

T2 Tier 2 

TMU total measurement uncertainty 
iv 

TRU transuranic 

TWPC Transuranic Waste Processing Center 

U uranium 

VE visual examination 

WG Pu weapons grade plutonium 

WIPP Waste Isolation Pilot Plant 

WSPF waste stream profile form 
1 

1.0 INTRODUCTION 

This report supports the U.S. Environmental Protection Agency’s (EPA’s) approval of a Tier 1 

(T1) change to add a Mobile In Situ Object Counting System (ISOCS) Large Container 

Counter-2 (MILCC2) unit to the Central Characterization Program’s (CCP’s) approved waste 

characterization program at Oak Ridge National Laboratory (ORNL). In accordance with Title 

40 of the Code of Federal Regulations (40 CFR) 194.8(b), EPA conducted a baseline inspection 

of CCP’s waste characterization program for contact-handled (CH) transuranic (TRU) wastes at 

the U.S. Department of Energy’s (DOE’s) ORNL in Oak Ridge, TN, in 2008. As a result, EPA 

approved the ORNL-CCP CH TRU waste characterization program (see EPA Docket No. A-98-

49, II-A4-103). On February 4–6, 2014, EPA conducted a continued compliance inspection of 

the ORNL-CCP waste characterization program and evaluated two T1 changes: modification of 

the MCS IQ3 NDA system and the addition of summary category group (SCG) S3000 

(homogenous solid) waste to ORNL-CCP’s approval (see EPA Docket Nos. A-98-49, II-A4-186 

and A-98-49, II-A4-189). EPA’s reviews and approvals of ORNL-CCP’s CH waste 

characterization program are listed in Attachment A. 

On May 30, 2014, the Carlsbad Field Office (CBFO) requested EPA approval of a T1 change to 

add the MILCC2 as a new nondestructive assay (NDA) system at ORNL. The MILCC2 will 

assay SCGs S3000 (homogenous solids), S4000 (soil and gravel) and S5000 (debris) waste in 

55-gallon drums. On August 5–6, 2014, EPA conducted an on-site inspection to evaluate the 

MILCC2 NDA system. EPA also evaluated Visual Examination (VE) of CH TRU waste at that 

time, the results of the VE evaluation will be presented in a separate report. 

EPA evaluated the proposed T1 change by reviewing ORNL-CCP documents and conducting an 

onsite evaluation of the MILCC2 at ORNL on August 5–6, 2014. During the evaluation, EPA 

and ORNL-CCP agreed that ORNL may relocate the MILCC2 on site or make other system 

changes (e.g., changing system components in a like-for-like replacement). Following such 

changes to the MILCC2, ORNL-CCP must verify that the EPA-approved calibration remains 

valid. If the EPA-approved calibration is successfully verified, ORNL-CCP may continue to 

operate the MILCC2 and notify EPA as a Tier 2 (T2) change. However, if the EPA-approved 

calibration cannot be verified, ORNL-CCP must recalibrate the MILCC2. EPA must approve the 

new calibration as a T1 change prior to shipment to WIPP of any containers that were 

characterized using the new calibration. 

The MILCC2 may not be used to formally assay any containers other than 55-gallon drums [i.e., 

Standard Waste Boxes (SWBs) or Standard Large Box-2s (SLB2s)] at any distance or 55-gallon 

drums at distances other than the three measurement configurations discussed in this report. The 

addition of other container types or measurement configurations to the MILCC2 approval is a 

new T1 change. 

EPA modified the ORNL-CCP CH tiering table (Table 1) to reflect the requirements described in 

the previous paragraph. Table 1 shows the substantive T1 and T2 changes in bold text. T1 and 

T2 changes that were initiated during the baseline and subsequent continued compliance 

inspections and T1 approvals remain in effect. The language in Table 1 regarding AK 

documentation applies to all ORNL-CCP waste streams. 
2 

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

(Based on November 2007 Baseline Inspection and Subsequent Tier 1 Evaluation, Updated Octo

Process Elements ORNL-CCP CH Waste Characterization Process – T1 Changes ORNL-CCP CH Waste Characteriz

Acceptable Knowledge, including Load Management 

Any new waste category other than retrievably stored debris, 

soils/gravel and solids (i.e., any type of newly generated waste) 

Load management 

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

• AK accuracy reports (annually, at a mi

• AK-AK and AK-NDA/NDE Discrepan

• WSPFs and related attachments (e.g., C

streams, including change notices 

• AKSRs (new and updated versions) 

• CCP-TP-005, Attachments 4, 6, 7 and 

including “Add Container” memorand

• Site AK procedures requiring CBFO a

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

equipment

Extension of or changes to approved calibration range for approved equipment Activities that require system recalibration Addition of new measurement configurations or container types 

Submission of a list of ORNL-CCP NDA performed work during the previous quartNotification to EPA upon substantive mod

• Software for approved equipment 

• Operating ranges upon CBFO approva• Site NDA procedures requiring CBFO 

Notification to EPA upon successful calMILCC2 following on-site relocation or 

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

work during the previous quarter Notification to EPA upon: 

• New equipment or substantive physica

equipment 

• Substantive modification** to site RTR 

approval 

Visual Examination and Visual Examination Technique 

Any use of visual examination Submission of a list of ORNL-CCP VE op

performed work during the previous quart

WIPP Waste Data System Load management Notification to EPA upon substantive mod

procedures requiring CBFO approval 

* ORNL-CCP will report all T2 changes to EPA every three months. ** “Substantive modification” refers to a change with the potential to affect ORNL-CCP’s CH waste characterization processes or documentat

that are solely related to the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act, or that are editoriaaddress administrative concerns. EPA may request copies of new references that DOE adds during a document revision. 
3

2.0 PURPOSE OF TIER 1 EVALUATIONS 

Certain changes to the waste characterization activities from the date of the site’s baseline 

inspection must be reported to and, if applicable, approved by EPA according to the tiering 

requirements set forth in 40 CFR 194.8 regulations and incorporated into the SRS-CCP baseline 

final report (see EPA Docket No. A-98-49, II-A4-103). 

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

(Vol. 69, No. 136, pages 42571–42583), EPA must perform a single baseline inspection of a 

TRU waste generator site’s waste characterization program. The purpose of EPA’s baseline 

inspection is to approve the site’s waste characterization program, based on the demonstration 

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

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

destined for disposal at the WIPP. 

Following EPA’s baseline approval, EPA is authorized to evaluate and approve changes, if 

necessary, to the site’s approved waste characterization program by conducting additional 

inspections under the authority of 40 CFR 194.24(h). Changes requiring EPA notification and 

approval prior to implementation (T1) and those requiring post-implementation notification (T2) 

are identified in the site-specific baseline inspection reports and subsequent T1 evaluation 

reports. When evaluating proposed T1 changes for approval, EPA may conduct a site inspection 

to observe implementation of the change or can opt to conduct a desktop review of information 

provided specific to a change. DOE may choose to characterize and dispose of any previously 

approved TRU waste using processes, procedures or equipment implemented as T2 changes at 

risk of subsequent EPA disapproval. 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of EPA’s evaluation of a T1 change to allow the use of the 

MILCC2 for assaying 55-gallon drums. This report documents the basis for EPA’s approval 

decision and explains the results of the technical evaluation of the system, including any 

limitations. EPA’s approval decision regarding the MILCC2 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). 

Documents provided by CBFO for this evaluation and listed in Section 6.2 of this report can be 

requested from CBFO at the following address: 

U.S. Department of Energy 

Carlsbad Field Office 

TRU Sites and Transportation Division 

P.O. Box 3090 

Carlsbad, NM 88221-3090 

4.0 SCOPE OF REVIEW

The scope of this review is limited to the addition of a new ORNL-CCP NDA system, the 

MILCC2. Use of the MILCC2 is limited to assaying 55-gallon drums containing SCG S3000, 
4

S4000 and S5000 wastes. EPA evaluated this proposed change request in accordance with 

40 CFR 194.8(b) to assess the technical adequacy, implementation and effectiveness of the 

technical processes implemented by ORNL-CCP for the MILCC2. As part of this review, EPA 

evaluated personnel qualifications and training, operating procedures, the physical configuration 

of the measurement system and replicate testing of the MILCC2 to assess the system’s adequacy. 

5.0 EVALUATION PERSONNEL 

Table 2 lists all personnel involved in this T1 evaluation, along with their professional 

affiliations and T1 evaluation functions. 

Table 2. Evaluation Personnel 

6.0 TECHNICAL EVALUATION 

EPA evaluated the MILCC2 NDA system on-site at ORNL on August 5–6, 2014. As part of the 

evaluation, EPA reviewed the following elements of the MILCC2 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. 

Section 6.2 identifies the objective evidence that was examined for EPA’s evaluation. During the 

evaluation, the EPA team members assessed technical elements of the MILCC2 system that are 

detailed in the checklist in Attachment B and discussed below. Upon evaluation, EPA concluded 

that Items 6.4 – 6.10 discussed below are implemented in a technically adequate manner. 

6.1 System Description 

The MILCC2 is operated by ORNL-CCP and is currently located in Building (trailer) 7880AC at 

the Transuranic Waste Processing Center (TWPC) at ORNL. This is a new NDA system and it 

consists of two ISOCS Broad Energy Germanium (BEGe) gamma detectors that are affixed to 

wheeled mobile carts and placed at fixed distances equidistant and on opposite sides of the 

container to be measured. During measurement, the container sits on a turntable that allows 

Personnel Name Affiliation T1 Evaluation Function 

Ed Feltcorn EPA EPA Evaluation Lead 

Rose Gogliotti SC&A/EPA Technical Evaluator 

Dorothy Gill SC&A/EPA Technical Evaluator 

Tom Morgan DOE/CBFO CBFO Observer 

Ed Gulbransen NWP/CCP CCP Management 

Ron Reeves NWP/CCP Project Manager 

Andrew Stallings NWP/CCP Vendor Project Manager 

Berry Pace CBFO/CTAC CTAC Observer 

Beverly Schrock NWP/CCP ORNL SPM 

Ron Whitson MCS/CCP NDA Technical Lead 

Kevin Meyer Canberra Industries NDA EA 
5

continual rotation during measurement. The detectors are connected wirelessly to computers with 

the ISOCS user interface software. 

The BEGe detectors are appropriate for the direct quantification of plutonium-238 (238Pu), 239Pu, 

240Pu, americium-241 (241Am), uranium-233 (233U), 235U, 238U, cesium-137 (137Cs), neptunium237 (237Np) and other gamma-emitting radionuclides. The MILCC2 is capable of assaying 

materials with densities from 0 to 2.5 grams per cubic centimeter (g/cc), which includes debris, 

soils, gravel and homogeneous solids matrices. There are three acceptable assay configurations 

for 55-gallon drums on the MILCC2, the Near-, Mid- and Far-Field positions, discussed in 

Section 6.4, below. The actual drum-to-detector distance is measured for each item assayed as 

described below, as shown in Figure 1, below. 

Unlike most other CH NDA systems used around the DOE complex, the MILCC2 system is 

designed to be a mobile system. ORNL-CCP conveyed to EPA that they intend to use the system 

only in its current location in the near term; however, it is possible the system may be relocated 

in the future. Currently the turntable used on the instrument is bolted to the floor of Building 

7880AC.. 

6.2 Documents Reviewed 

EPA evaluated the following documents to support the approval of the addition of the MILCC2: 

• CI-MILCC2-NDA-1001, “Mobile ISOCS Large Container Counter Calibration Report,” 

Revision 0, March 10, 2014 

• CI-MILCC2-NDA-1002, Canberra Factory Document, “Oak Ridge MILC Counter Total 

Measurement Uncertainty Report,” Revision 0, March 13, 2014 

• Canberra Factory Document, “Canberra Services Group ISOCS Measurement and 

Analysis Procedure,” Revision A, August 13, 2009 

• ISOCS Detector QA Measurement Check and Detector Specification and Performance 

Data, detector BE8879, December 6, 2013 

• ISOCS Detector QA Measurement Check and Detector Specification and Performance 

Data, detector BE8903, December 6, 2013 

• MILCC2 BDR Nos. OR-MILCC2-0002, OR-MILCC2-0028, OR-MILCC2-0029, ORMILCC2-0034, OR-MILCC2-0002 and OR-MILCC2-0011 (55-gallon drums) 

• CI-MILCC2-NDA-1004, “ Calibration Verification Report for the MCS MILCC2,” April 

15, 2014 

• CCP-Oak Ridge National Laboratories List of Qualified Individuals, July 9, 2014 and 

July 24, 2014 

• ORNL MILCC2 NDA Qualification Cards for Susan Anderson, Bob Ceo, Dan Crosby, 

Chad Gerlock, Kevin Meyen, Maria Steade, and Ron Whitson 

• Operator Aids: OA-ORNL-0135, Revision 0, OA-ORNL-0134-14 Revision 0 and OAORNL-0123-11, Revision 1 
6

• Standing Orders: CCP-SO-ORNL-014, Revision 7; and CCP-SO-112, Revision 0 

• Logbooks CCP-ORNL-NDA-MILCC-001 (entries dated April 7- 18, 2014) and CCPORNL-NDA-MILCC-002 (August 5, 2014) 

• CCP-TP-076, CCP Operating the Mobile ISOCS Large Container Counter Using NDA 

2000, Revision 1, March 25, 2014 

• CCP-TP-077, CCP Calibrating the Mobile ISOCS Large Container Counter Using NDA 

2000, Revision 1, April 1, 2014 

• CCP-TP-048, CCP ORNL NDA System Data Reviewing, Validating, and Reporting 

Procedure, Revision 16, November 1, 2013 

6.3 Evaluation Checklist 

Based on EPA’s review of the ORNL-CCP documents listed above, EPA prepared a revised 

checklist for this evaluation that addressed the relevant aspects of the proposed change to the 

measurement configuration. The checklist is included as Attachment B to this report. 

6.4 Measurement Geometries 

ORNL-CCP will use the MILCC2 to characterize TRU waste in 55-gallon drums with the 

detectors placed in three fixed distances. These positions include: 

• Near-Field position with 180o

 collimator, detectors located approximately 17 inches (in.) 

from drum 

• Mid-Field position with 180o collimator, detectors located approximately 69 in. from 

drum 

• Far-Field position with 90o

 collimator, detectors located approximately 115 in. from 

drum 

The placement of the detectors is illustrated in Figure 1, below. The Near-Field position is 

intended to maximize gamma detection efficiency for low-activity containers. The Mid-Field and 

Far-Field positions accommodate the measurement of higher activity drums to reduce system 

dead-time1

. An operator aide (OA-ORNL-0134-14, Revision 0) is posted in the Control Room of 

the instrument indicating the allowed detector distances and their collimation. There are lines on 

the floor of Building 7880AC to guide operators regarding approximate locations of detectors; 

however, laser distance measurements are taken to confirm the distance and assign detectors for 

every measurement, as described below. 

Containers are moved from storage to the instrument by forklift. The forklift operator places the 

drum to be measured on a turntable that is bolted to the floor of Building 7880AC. The operator 

then positions the detectors for assay. All drum-to-detector distances are measured prior to assay 

using a tape measure or a laser, both of which are stored in the operational area. The laser is held 

 

1

“Dead time” is the time during which a detector cannot record a new photon because it is busy recording a 

previous photon, i.e., the detector is idle or dead. The number of photons that are not counted are called “dead-time 

losses” and can be considerable for drums with high concentrations of photon emitting radionuclides. 
7

in-line with the detector face to ensure the detector is aligned correctly with the midline of the 

drum’s height. The detector height on the cart is fixed and is subject to minor height fluctuations 

caused from the extent of inflation of the cart’s tires. The detector aligns with the center height of

the 55-gallon drum. The detector height and fluctuations are incorporated in the modeling of the 

ISOCS geometry and calibration uncertainty. 

Figure 1. 55-Gallon Drum Measurement Configurations

ORNL-CCP indicated that 55-gallon drums would initially be informally assayed with one 

detector at the Near-Field position and one at the Far-Field position to determine if the dead time 

was too great at either location. If the dead-time is appropriate at the Near-Field position, the 

other detector will be moved to the Near-Field position and the assay will be performed at that 

position. If the dead-time is excessive at the Near-Field position but appropriate at the Mid-Field 

position, both detectors will be moved to the Mid-Field position and the assay will be performed 

at that position. If the dead-time is excessive at both the Near- and Mid-Field positions, both 

detectors will be moved to the Far-Field position and the assay will be performed at that position. 

If an acceptable assay cannot be obtained at any one of the three positions using routine counting 

times, NDA personnel may elect to increase the counting time. There were no concerns 

regarding the technical adequacy and determination of the measurement configurations for the 

MILCC2. 

The MILCC2 may not be used to formally assay any containers other than 55-gallon drums (i.e., 

SWBs or SLB2s) at any distance or 55-gallon drums at distances other than the three 

measurement configurations discussed above and shown in Figure 1, above. The addition of 

other container types or measurement configurations to the MILCC2 approval is a T1 change 

requiring prior EPA approval. 

55-

gallon

drum 

Near-Field Position 

Near-Field Position 

Mid-Field Position 

17” 

Mid-Field Position 

69” 69” 

17” 

Far-Field Position 

115” 

Far-Field Position 

115” 

Turntable 
8

6.5 Calibration, Calibration Validation and Confirmation 

The MILCC2’s calibration of record is documented in CI-MILCC2-NDA-1001, Revision 0. The 

calibration of record does not contain all relevant information because the two BEGe detectors 

were ISOCS characterized at Canberra in Meriden, CT, as discussed in detail in section 6.5.3, 

below. 

6.5.1 Gamma Ray Peak Shape and Energy Calibrations 

In January 2014, the gamma ray peak shape and energy calibrations for both detectors were 

performed. The spectral gain was set at approximately 0.90 kilo-electron volt (keV)/channel with 

an offset of approximately 0.0 keV. The results of the gamma energy and peak shape calibrations 

are shown in Appendix 3 of the Calibration Report. EPA reviewed this documentation and found 

it to be technically adequate. There were no concerns regarding the technical adequacy and 

documentation of these calibrations for the MILCC2.

6.5.2 Reference Peak Calibration 

No reference peak calibration was needed for the calibration of the MILCC2 because this system 

does not use a pulser. Instead, a digital amplifier has an algorithm that serves the same function 

of the reference peak calibration. EPA reviewed and found it to be technically adequate. 

6.5.3 Efficiency Calibration/Detector Characterization 

The MILCC2 uses two ISOCS model BE5030 planar BEGe detectors, each with an area of 5,000 

square millimeters. Canberra performed an ISOCS-generated multi-curve efficiency calibration 

of each detector at their Meriden, CT, location. Appendix 9.0 of the Calibration Report 

documents the parameters used to generate the multi-curve efficiency calibrations. Calibration 

efficiency charts spanning nine densities are depicted in Figures 1–3 of the Calibration Report. 

Both detectors were ISOCS characterized by their manufacturer Canberra. EPA has previously 

evaluated the technical aspects of this process through technical discussions with Canberra 

personnel at the Meriden, CT, facility. Although the exact method Canberra uses to characterize 

detectors is proprietary, it was described to EPA with sufficient detail to support its use in 

characterizing gamma detectors for assaying WIPP-bound waste. It involves the development 

and validation of an MCNP model for each detector, which includes generating efficiency data 

sets to predict a detector’s response to point-like sources at many locations. A detector 

characterization file that contains the relationship of the detector to the point-efficiency data and 

the validation of the resulting characterization file is generated, and this file is then used by the 

ISOCS user interface software. EPA reviewed both Canberra detector characterization reports 

and found them to adequately document the characterization of the detectors.2

Detector No. 01 is currently located on the south side of the instrument trailer and has serial 

number (SN) 8903. It was originally characterized by Canberra in Meriden, CT, in November 

2013, as listed on the detector. Detector No. 02 is currently located on the north side of the 

 

2

 As a result of this characterization, the BEGe detectors are described as “ISOCS-characterized detectors.” 
9

instrument trailer and has a SN 8879. It was originally characterized by Canberra in Meriden, 

CT, in July 2013, as listed on the detector. Upon receipt of each detector from Canberra, ORNLCCP performed a calibration validation to confirm that the calibration was still technically 

adequate. There were no concerns regarding the efficiency calibration and detector 

characterization for the MILCC2. 

6.5.4 Calibration Verification 

ORNL-CCP performed a calibration verification of the MILCC2 using PDP drums containing 

combustibles, sludge and metals matrices and an ORNL foam matrix 55-gallon drum. Three 

assays were done on each container using National Institute of Standards and Technology 

(NIST) traceable mixed-gamma line sources to verify the calibration. These sources and their 

placement in the 55-gallon drum are discussed in the Calibration Report. Using the four matrix 

drums with varying different densities, the multi-curve efficiency calibration was verified, as 

detailed in the Calibration Report. The accuracy and precision of the calibration verification data 

were in compliance with the limits in DOE/WIPP-02-31223

, Appendix A, Table A-2, and EPA 

determined that the results of the calibration verification indicated that the MILCC2 is operating 

within the acceptable limits. There were no concerns regarding the calibration verification for the 

MILCC2. 

6.5.5 Calibration Confirmation 

The gamma calibration was confirmed by measuring Pu sources in a 55-gallon drum. The drum 

was measured six times at the Near-Field, Mid-Field and Far-Field detector positions with total 

Pu mass loadings of approximately 0.975 grams (g), 31.5 g, and 175 g. Sources in each mass 

loading are summarized in the Calibration Report. Measured isotopic fractions were used if they 

were available; otherwise, declared or certificate isotopics are used. The confirmation 

measurements listed in the Calibration Report show that the percent recovery and precision of 

each of the six replicate measurements met the criteria in DOE/WIPP-02-3122, Appendix A, 

Table A-2. There were no concerns regarding the calibration confirmation for the MILCC2. 

6.6 Operating Range 

The operating range for the MILCC2 is limited by density, spectral parameters, dead time and 

lower limit of detection (LLD). The MILCC2 may assay wastes with densities ranging from 

0.001–2.50 g/cc. This includes and exceeds the density ranges ORNL-CCP expects to encounter 

in the population of S3000, S4000 and S5000 waste containers the MILCC2 will assay. Although 

not a formal operating range, ORNL-CCP stated that the expected operating range of the 

MILCC2 is a total Pu mass from the LLD to 325 g. There were no concerns regarding the 

determination and documentation of the operating range for the MILCC2. 

6.7 Lower Limit of Detection Determination 

Instruments performing TRU/Non-TRU waste discrimination must have a minimum detectable 

concentration (MDC) of less than 100 nanocuries per gram (nCi/g) of TRU radionuclides. 

 

3

 U.S. DOE CBFO, “Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant,” 

DOE/WIPP-02-3122, Revision 7.4, Carlsbad, New Mexico, April 22, 2013. 
10

Minimum detectable activities (MDAs) are variable and depend on measurement conditions such 

as background rate and matrix. To establish an MDA typical of a MILCC2 assay, ORNL-CCP 

performed three replicate measurements on a surrogate matrix 55-gallon drum with no 

radioactive sources at the Near-, Mid- and Far-Field positions. The NDA 2000 software 

calculated MDAs from these measurements by applying weapons-grade Pu (WG Pu) isotopic, 

and the calculated MDAs were used to derive MDCs, as shown in Tables 8a-8cd of the 

Calibration Report. All WIPP-tracked radionuclides were found to have an MDA below 100 

nCi/g in a typical waste assay in the Near-Field position. At the Mid- and Far-Field positions, the 

total MDCs were found to be above 100 nCi/g in a typical waste assay. This was discussed with 

ORNL-CCP NDA personnel who stated that this is unlikely to be a problem because the default 

assay position for a drum is the Near-Field position, for which the MDA was acceptable. Only if 

the dead-time is excessive for the Near-Field position is a drum assayed with detectors in the 

Mid- or Far-Field positions. The drum would only be assayed at the Mid- and Far-Field positions 

if the dead-time was excessive at the Near-Field position, a condition that indicates the 

container’s activity would exceed the MDC. EPA agreed with ORNL-CCP’s explanation. 

Because the LLD is a measurement-based parameter, ORNL-CCP personnel stated that it is not 

technically feasible to calculate for radionuclides that are not directly measured, i.e., 242Pu, 234U 

and strontium-90 (90Sr). There were no concerns regarding the determination and documentation 

of the LLD for the MILCC2. 

6.8 Total Measurement Uncertainty 

Total measurement uncertainty (TMU) for the MILCC2 is documented in “Oak Ridge MILC 

Counter Total Measurement Uncertainty Report,” Revision 0, dated February 3, 2014. The TMU 

determination was performed with the ISOCS Uncertainty Estimator (IUE), a software tool that 

generates models associated with errors caused by the evaluation of these parameters. The 

primary components of uncertainty include: 

• Calibration source. 

• ISOCS model. 

• Detector positioning. 

• Matrix in homogeneity. 

• Non-uniform source distribution. 

• Fill-height. 

• Self-attenuation of special nuclear material (SNM) “lumps.” 

• Counting statistics. 

• Background fluctuations. 

• Radionuclide interferences. 

• Isotopic measurement uncertainty. 

Other potential sources of uncertainty are expected to be small. The uncertainty for each of the 

quantifiable uncertainty sources is assumed to be statistically independent and is added in 

quadrature to derive the TMU, as documented in the TMU report. EPA discussed the evaluation 

of TMU with ORNL-CCP and found it to be technically appropriate. There were no concerns 

regarding the determination and documentation of TMU for the MILCC2. 
11

6.9 Batch Data Reports 

At the time of EPA’s evaluation, 574 drums (excluding 24 PDP drums) had been assayed on the 

MILCC2 since the instrument became operational on April 16, 2014. The assays were 

documented in 63 batch data reports (BDRs). ORNL-CCP indicated that as many as 20 drums 

can be assayed on a given day; however, the system averages between 9 and 10 assays per day. 

ORNL-CCP provided EPA with MILCC2 BDRs Nos. OR-MILCC2-0001 through OR-MILCC2-

0035. The EPA reviewed BDR Nos. OR-MILCC2-0002, OR-MILCC2-0028, OR-MILCC2-

0029, OR-MILCC2-0034, OR-MILCC2-0002 and OR-MILCC2-0011. EPA verified that each 

BDR included the following: 

• Site Project Manager (SPM) Checklist, CCP-TP-001, Revision 21, Attachment 3. 

• BDR Cover Sheet, CCP-TP-048, Revision 16, Attachment 4. 

• BDR Table of Contents, CCP-TP-048, Revision 16, Attachment 2. 

• NDA Batch Report Narrative Summary, CCP-TP-048, Revision 16, Attachment 5. 

• Independent Technical Reviewer (ITR) Review Checklist, CCP-TP-048 Revision 16, 

Attachment 3. 

• Assay Report for each container listed on Attachment 1. 

• Radioassay Data Sheet (RDS) for each container listed on Attachment 1. 

• Automated ITR for each container listed on Attachment 1. 

• Genie Quality Assurance Reports. 

• CCP Records Transmittal/Receiving Form, CCP-QP-008 Rev. 22, Attachment 2. 

• Evidence of signatures by the ITR on Attachment 1, an SPM on Attachment 3 and an EA 

on the Automated ITR report for each container listed on Attachment 1. 

• Correct revisions of CCP-TP-0014

 and CCP-TP-048. 

The MILCC2 reports direct quantitative values and uncertainties for 238Pu, 239Pu, 241Am, 233U, 

235U, 238U, 137Cs, and 237Np. Values for 90Sr, 234U, and 242Pu are obtained through the application 

of scaling factors. The Pu isotopic ratios are determined using the Multi-Group Analysis (MGA) 

or Fixed-Energy Response-Function Analysis with Multiple-Efficiencies (FRAM) Software, or 

are based on site-approved acceptable knowledge (AK). Each assayed container contained TRU 

radionuclides at concentrations greater than 100 nCi/g. There were no concerns regarding the 

technical adequacy of the radionuclide documentation in NDA BDRs for the MILCC. 

6.10 Replicate Assays 

The purpose of replicate testing is to provide EPA with an independent means to verify that the 

MILCC2 can provide reproducible results for determination of the 10 WIPP-tracked 

radionuclides (241Am, 137Cs, 238Pu, 239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U and 238U) and the TRU 

 

4

 CCP-TP-001, CCP Project Level Data Validation and Verification, Revision 20, September 27, 2012. 
12

alpha concentration.5 This is accomplished by the MILCC2 reassaying containers it previously 

measured to demonstrate the system’s ability to: 

• 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 by comparing the results of the 

replicate measurements to the original reported values. 

As part of this evaluation, EPA requested that ORNL-CCP reassay three 55-gallon drums. EPA 

randomly selected these containers from a list of all containers previously assayed on the 

MILCC2 that were accessible. EPA selected Drum No. X10CSATN02626B for the Near-Field 

position, Drum No. X10CSATN02023P for the Mid-Field position and Drum No. 

X10CSATN01937AG for the Far-Field position. All three drums were reassayed five times and 

the results were compared to the original assay data. EPA Inspectors witnessed the assay of 

Drum No. X10CSATN02023P on the first of five assays. 

Two statistical tests, a chi-squared (χ

2

) test and a t-test, were performed. Data and results of the 

statistical analyses are included in Attachments C.1 and C.2 of this report. The χ

2

 test (also 

known as the goodness-of-fit test or the chi-squared test for independence) is used to show how 

observed data compare with what we would expect to obtain according to a specific hypothesis. 

It is applied in this instance to assess the difference between the replicate and original 

measurements. The t-test is used to tell if two sets of data are statistically different. It is applied 

in this instance to determine if there is a statistically significant difference between the original 

assay values and the average of the five replicate measurements. 

For Container Nos. X10CSATN02626B and X10CSATN02023P, the χ

2

 test showed that the 

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

uncertainties within the statistical limits of the test. The t-test for Drum Nos. 

X10CSATN02626B, X10CSATN02023P, and X10CSATN01937AG showed no statistically 

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

measurements. 

For Drum No. X10CSATN01937AG , the t-test showed Highly Significant statistical differences 

between the original assay values and the average of the five replicate measurements for 237Np. It 

is important to keep this in mind when evaluating replicate data and to realize that Significant or

Highly Significant results are not always representative of true measurement issues. 

There are several possible reasons for the Highly Significant differences in 237Np replicate values 

versus original values: actual changes in the physical configuration of the drum’s contents due to 

movement or settling; fluctuations in the measurement system’s background; temporal factors 

such as radioactive growth or decay; or, actual changes in the measurement system, the aspect 

that these tests are designed to query. Although the software identified these variances as Highly 

Significant, this does not necessarily indicate a measurement issue that warrants additional 

 

5

 Revision 2 of the EPA Replicate Testing Protocol provides the details of the replicate testing assay 

protocol and data evaluation. 
13

attention at this time. Further investigation into the results showed that the statistical flag was 

caused by the original measurement reporting a very small value for 237Np of 1.52E-05 Ci. In 

comparison, two of the replicate values were reported as less than the LLD and entered into the 

replicate worksheet as zeroes. The two zero values drove the average of the five replicates to be 

calculated at a much lower value (9.86E-06 Ci) and resulted in the subsequent calculation of a 

relatively large standard deviation for the population of the five replicate measurements. This 

caused a failure of the statistical test and resulted in a Highly Significant flag. The three positive 

replicate results showed an average activity of 1.64E-05 Ci, which is in good agreement with the 

original result, differing by only 8% from the original measurement.

7.0 FINDINGS AND CONCERNS 

There were no findings or concerns regarding the use of the MILCC2 by ORNL-CCP. 

8.0 CONCLUSIONS 

Changes to Tiering 

During the evaluation, EPA and ORNL-CCP agreed that ORNL may relocate the MILCC2 on 

site or make other system changes (e.g., changing system components in a like-for-like 

replacement). Following such changes to the MILCC2, ORNL-CCP must verify that the EPAapproved calibration remains valid. If the EPA-approved calibration is successfully verified, 

ORNL-CCP may continue to operate the MILCC2 and notify EPA as a T2 change. However, if 

the EPA-approved calibration cannot be verified, ORNL-CCP must recalibrate the MILCC2. 

EPA must approve the new calibration as a T1 change prior to shipment to WIPP of any 

containers that were characterized using the new calibration. 

The MILCC2 may not be used to formally assay any containers other than 55-gallon drums (i.e., 

SWBs or SLB2s) at any distance or 55-gallon drums at distances other than the three 

measurement configurations discussed in this report. The addition of other container types or 

measurement configurations to the MILCC2 approval is a new T1 change. 

Table 1 shows the T1 and T2 changes based on this evaluation in bold text. T1 and T2 changes 

that were initiated during the baseline and subsequent continued compliance inspections and T1 

approvals remain in effect. The language in Table 1 regarding AK documentation applies to all 

ORNL-CCP waste streams. 

Approval 

During this T1 evaluation, EPA evaluated the ORNL-CCP MILCC2. EPA did not identify any 

concerns or findings and based on the results of this evaluation, EPA is approving the ORNLCCP MILCC2 NDA system for assaying 55-gallon drums in the three configurations described 

in this report. 

ORNL-CCP may make changes to the MILCC2 (e.g., changing system components in a like-forlike replacement, or relocating the system to another area at ORNL) followed by verification of 

the EPA-approved calibration. The tiering requirements for these changes are described above 

and in Table 1. 
A-1 

ATTACHMENT A 

APPROVAL SUMMARY FOR ORNL-CCP 

CONTACT-HANDLED WASTE CHARACTERIZATION PROGRAM 

Approved Activity EPA Inspection Number, 

Approval Dates EPA Docket Number 

ORNL-CCP CH Baseline Approval EPA-ORNL-CCP-CH-11.07-8, 

August 21, 2008 A-98-49, II-A4-103 

T1 Change – Extension of the Calibration and Density 

Ranges for the SGS NDA System October 8, 2008 A-98-49; II-A4-108 

T1 Change – Extension of the Passive Mode 

Calibration Range for the DWAS/IPAN SGS January 8, 2009 A-98-49, II-A4-109 

T1 Change – Addition of SCG S4000 October 7, 2009 A-98-49, II-A4-117 

Unannounced Continued Compliance Inspection November 23, 2009 A-98-49, II-A4-121 

T1 Change – Addition of the MCS IQ3 NDA System 

and Visual Examination March 30, 2010 A-98-49, II-A4-125 

T1 Change – Addition of NFS Trench B Soils to Waste

Stream OR-NFS-CH-SOIL March 23, 2011 A-98-49; II-A4-144 

Continued Compliance Inspection and T1 Change for 

Modifications to the IQ3 NDA System June 18, 2014 A-98-49, II-A4-186 

T1 Change – Addition of SCG S3000 July 9, 2014 A-98-49, II-A4-189 
B-1 

ATTACHMENT B 

MOBILE ISOCS LARGE CONTAINER COUNTER-2 EVALUATION CHECKLIST 

Technical Elements Objective Evidence Additio

General Confirm the NDA system is the MILCC2, its location and number. 

The instrument is located in Building (trailer) 7880AC at the Transuranic Waste Processing Center in Oak Ridge. MILCC2 stands for Mobile ISOCS Large Container Counter-2, and is also referred to as the Oak Ridge MILC Counter in the TMU documentation. 

This was confirmed during evaluation. Econfirmed the instru

Describe the MILCC2. The detectors are BEGe detectors, i.e., planar detectors that provide excellent 

response and energy resolution from 45 keV to 3 MeV. The detectors are 

identified as Nos. 8903 (detector 1) and 8879 (detector 2), and were ISOCS characterized in 2013. Both detectors are chilled by liquid nitrogen to protect the germanium crystals. The two MILCC2 detectors are placed equidistant from and on opposite sides of the container to be assayed. Three distances are fixed for a 55-gallon drum, the selection of which is determined by the dead time of the detector. The closest position (Near-Field, 17 in. drum-to-detector) accommodates containers with low dead times, uses a 180° collimator with typical assay time of 15 minutes The middle position (Mid-Field, 69 in. drum-to-detector) accommodates 

containers with midrange dead times, uses 180° collimator with typical assay time of 15 minutes The farther position (Far-Field, 115 in. drum-to-detector), accommodates containers with high dead times, uses a 90° collimator with typical assay time 

of 30 minutes. 

This was confirmed during evaluation. 

Identify the consensus standards that were used for the system calibration. 

ORNL-CCP used consensus standards ASTM C-1030, C-1133, C-1207 and C-1500 for the MILCC2 calibration. 

 CI-MILCC2-NDA-NDA personnel dur

Identify the container and wastes types assayed on the MILCC2. 

The MILCC2 is capable of assaying debris, soils and gravel, and 

homogeneous solid wastes in 55-gallon drums. 

The MILCC2 is limdead time, calibratedensities of 0-2.50 gwaste is expected to 
B-2 

Technical Elements Objective Evidence Additio

Identify the period of performance relevant to the MILCC2 and the number of BDRs and waste containers this system assayed during the period.

The MILCC2 is a new system with a limited performance history. The system became operational on April 16, 2014, and ORNL-CCP has been assaying drums at risk. 

Including the contairisk, the MILCC2 hcontainers (excludinare contained in 64 have been finalized 

Confirm that the MILCC2 is able to report quantitative values for the WIPP-tracked radionuclides. 

Direct Measurements: 238Pu, 239Pu, 241Am, 233U, 235U, 238U, 137Cs and 237Np. Radionuclides by Scaling: 90Sr, 234U and 242Pu. 

Pu and other TRU isotopic ratios are determined using the MGA or FRAM software, or AK. 

This was confirmed during evaluation. 

Confirm the MILCC2’s calibration of record. 

The calibration is documented in CI-MILCC2-NDA-1001, Revision 0. Each 

detector factory characterization report was provided to EPA reviewers. 

This was confirmed during evaluation. 

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

CCP-TP-076, Operating Procedure (Revision 1, 3/2014) CCP-TP-077, Calibration Procedure (Revision 1, 4/2014) CCP-TP-048, Data Review Procedure (Revision 16, 11/2013) 

These were confirmCopies of the currencalibration procedurcontrol room to ope

Confirm the methods used to derive the isotopic contribution for unmeasured radionuclides. 

241Am and Pu isotopics determined by MGA or FRAM software when enough 

mass exists. 

This was confirmed during evaluation. 

Calibration Verification and ConfirmationConfirm the pedigree of all radionuclide standards that were used for calibration confirmation and/or verifications. List or reference all standards used. 

Sources are summarized in Table 6.1 of CI-MILCC2-NDA-1001, Revision 0, with source certificates in Attachment 1. 

EPA reviewed all soAppendix 2; All stacertified and acceptcalibration. 

Confirm the MILCC2 operational range with respect to matrix (density) and activity. 

Acceptable density range for gamma is approximately 0.001–2.50 g/cc; 

activity is limited by spectral parameters (peak shape and resolution) and 

system dead time. 

This was confirmed during evaluation. 
B-3 

Technical Elements Objective Evidence Additio

Identify the date of the last calibration verification. Have any others been completed in the last year? 

One calibration verification was performed on the system other than the initial verifications performed on site when detectors were received, documented in CI-MILCC2-NDA-1004. Following the initial calibration confirmation, ORNL-CCP observed intermittent instabilities in the 1274.5 keV peak for Detector 1. To stabilize the detector, the preamp, pre-amp cables and electrical power strip were replaced, Additionally, cables for Detector 2 were replaced and a calibration verification found the changes in improvements had 

no adverse impacts on the operation of the instrument. 

This was confirmed personnel during ev

Requirements for accuracy and precision must be met, as specified in DOE/WIPP-02-3122, Appendix A, Table A-2 for calibration verifications. 

The calibration confirmation documented in the MILCC2 report indicate that the %R was between 70-130 % and % RSD was less than 14% for six replicates, as required. 

This was confirmed during the EPA eva

LLD Confirm that the LLD for the MILCC2 has been determined. 

Typical MDAs are determined by performing three replicate assays of each container type and detector position with matrix containers without radioactive sources. MDAs are averaged and converted to MDCs using matrix weight. The MDAs documented in CI-MILCC2-NDA-1001 indicate that the instrument meets the TRU discrimination criterion of 100 nCi/g only for the 

Near-Field configuration. It is expected that all low-activity containers will be run at the Near-Field position. TRU determinations at the Mid- and FarField positions may not be possible for drums with low activity. 

MDAs are variable measurement condirate and matrix typeexample MDAs and combustibles and slall three positions. 

Confirm if the MILCC2 is used to discriminate TRU/Non-TRU wastes at the 100 nCi/g criterion and that it has the required sensitivity. 

See previous entry. This was confirmed 

during the EPA eva

Identify any/all instances where an LLD value for a non-measured radionuclide is not provided based on a lack of technical feasibility. 

Reporting thresholds are not discussed in the Calibration Report. This 

information is now reported in NDA memoranda. 

This was discussed during the EPA evais a measurement-bCCP personnel statefeasible to calculate not directly measure
B-4 

Technical Elements Objective Evidence Additio

Quality Control All Operators have current CCP training as verified on LOQI. 

A July 9, 2014 and July 24, 2014, LOQI was provided to EPA reviewers. Five NDA operators were listed on the LOQI, all with current training requirements met. The LOQI lists two; typically, EAs are not NDA-approved operators. 

EPA confirmed the operator on their rescards. 

Confirm the MILCC2’s status with respect to the CBFO NDA PDP and last cycle. 

The MILCC2 successfully participated in the PDP Drum Cycle 21A.This cycle tested 4 drum matrices and three alpha activity ranges. 

ORNL-CCP providapproval letter dated 

All MILCC2 data must be reviewed and approved by qualified personnel. Identify the name and function of the individuals performing technical review and approval of MILCC2 BDRs. 

Data review in the BDRs obtained by EPA was performed by: Ron Whitson, ITR Daniel Wade, SPM Susan Anderson, NDA Operator Chad Gerlock, QA Engineer, ITR Beverly Schrock, SPM 

EPA reviewed Qualpersonnel listed. 

Identify any NCRs within the last year. 

There were no systems NCRs. There have been several assay NCRs; however, this is expected on the MILCC2 because all MILCC2 assays are first done in the Near-Field position and any container that requires reassay at the Mid-Field or Far-Field positions requires an NCR prior to reassay. 

This was discussed personnel. If a suffiobtained using a 30ORNL-CCP may co
B-5 

Technical Elements Objective Evidence Additio

TMU Evaluate the magnitude of the TMU values observed in the MILCC2 BDRs that were examined during this evaluation. 

This system is effectively equivalent to the MILC counter at LANL. Therefore the TMU document borrows heavily from the LANL TMU document. TMU for the MILCC is documented in “Total Measurement Uncertainty for the MCS/LANL ISOCS ‘Box Counter’,” Revision 2, March 

27, 2013. The TMU for the MILCC2 is documented in “Oak Ridge MILC 

Counter Total Measurement Uncertainty Report’,” Revision 2, March 13, 2014. The components of uncertainty included in the TMU determination consist of calibration source uncertainties, ISOCS Model uncertainties, detector 

positioning, matrix in homogeneity, non-uniform source distribution, fillheight uncertainty, self-attenuation of SNM “lumps”, counting statistics, background fluctuations, radionuclide interferences and isotopic measurement uncertainty. The ISOCS Uncertainty estimator is used to calculate TMU. This is a companion program to the MILCC2 system. 

EPA evaluated the Bwithin the expected 

Background and Performance Checks Confirm that MILCC2 background measurements have been taken daily. 

Background measurements are required in CCP-TP-076, Operating Procedure (Revision 1, 3/2014). Evidence of daily background measurements was seen 

in the logbook pages reviewed. 

EPA reviewed logbdetailed reviews of 2014 and April 7-1showed that backgromade and acceptabl

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

This has not been an issue for the MILCC2. This was discussed 

personnel who indicrelative to surround

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

Performance measurements are required in CCP-TP-076, Operating Procedure (Revision 0, 5/2013). Evidence of daily performance checks was seen in the logbook pages reviewed. 

EPA reviewed logbdetailed reviews of 2014 and April 7-18showed that performmeasurements were 
B-6 

Technical Elements Objective Evidence Additio

MILCC2 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 MILCC2 BDR Nos. OR-MILCC2-0002, OR-MILCC2-0028, OR-MILCC2-0029, OR-MILCC2-0034, OR-MILCC2-0002, OR-MILCC2-0011. The BDRs contained all required information.

NA 

MILCC2 RDSs must include: • Title “Radioassay Data 

Sheet.” 

• Method/procedure used. 

• Date of radioassay. 

• Activities and associated 

TMU for individual radionuclides. 

• TRU alpha concentration and 

its associated TMU. 

• Operator and reviewer 

signatures. 

EPA reviewed MILCC2 BDR Nos. OR-MILCC2-0002, OR-MILCC2-0028, OR-MILCC2-0029, OR-MILCC2-0034, OR-MILCC2-0002, OR-MILCC2-0011. The RDSs contained all required information.

NA 
C.1-1 

ATTACHMENT C.1. MILCC2 REPLICATE TESTING RESULTS FOR CONTAINER No. X10CSATN0262

Instrument: MILCC2 Drum: X10CSATN02626B 

Original Measurement Replicate #1 Rep

Quantity of Interest 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Abs

Unce

90Sr Activity (Ci) 2.43E-02 1.52E-04 0.6% 2.40E-02 1.51E-04 0.6% 2.40E-02 1137Cs Activity (Ci) 1.41E-03 8.83E-06 0.6% 1.39E-03 8.74E-06 0.6% 1.39E-03 8233U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 235U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 237Np Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 238Pu Activity (Ci) 1.90E-03 2.94E-04 15.5% 1.96E-03 4.98E-04 25.4% 1.75E-03 2238U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 239Pu Activity (Ci) 1.95E-02 1.23E-03 6.3% 2.02E-02 4.27E-03 21.1% 1.80E-02 1240Pu Activity (Ci) 7.92E-03 1.23E-03 15.5% 8.18E-03 2.08E-03 25.4% 7.31E-03 1241Am Activity (Ci) 1.73E-02 6.55E-04 3.8% 1.59E-02 6.50E-04 4.1% 1.65E-02 6241Pu Activity (Ci) 5.78E-02 8.95E-03 15.5% 5.92E-02 1.51E-02 25.5% 5.29E-02 8242Pu Activity (Ci) 2.05E-06 3.18E-07 15.5% 2.12E-06 5.39E-07 25.4% 1.89E-06 2TRU Alpha Conc. (nCi/g) 3,050 123 4.0% 3,020 315 10.4% 2,850 

Original Measurement Replicate #1 Rep

Quantity of Interest 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Quantity of Interest 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

QuaInter

90Sr Activity (Ci) 2.40E-02 1.51E-04 0.6% 2.40E-02 1.64E-04 0.7% 2.40E-02 137Cs Activity (Ci) 1.39E-03 8.73E-06 0.6% 1.39E-03 9.49E-06 0.7% 1.39E-03 233U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 235U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 237Np Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 238Pu Activity (Ci) 1.81E-03 2.84E-04 15.7% 1.96E-03 3.52E-04 18.0% 1.83E-03 238U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 239Pu Activity (Ci) 1.87E-02 1.26E-03 6.7% 2.02E-02 2.23E-03 11.0% 1.89E-02 240Pu Activity (Ci) 7.57E-03 1.19E-03 15.7% 8.19E-03 1.47E-03 17.9% 7.66E-03 241Am Activity (Ci) 1.81E-02 6.67E-04 3.7% 1.74E-02 7.48E-04 4.3% 1.81E-02 241Pu Activity (Ci) 5.48E-02 8.58E-03 15.7% 5.93E-02 1.06E-02 17.9% 5.55E-02 242Pu Activity (Ci) 1.96E-06 3.07E-07 15.7% 2.12E-06 3.80E-07 17.9% 1.98E-06 TRU Alpha Conc. (nCi/g) 3,020 123 4.1% 3,120 183 5.9% 3,040 
C.1-2 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <|

Reported 

Value 

Absolute 

Uncertainty 

90Sr Activity (Ci) 2.43E-02 1.52E-04 2.40E-02 0.00E+00 N/A 0.000 1137Cs Activity (Ci) 1.41E-03 8.83E-06 1.39E-03 0.00E+00 N/A 0.000 1233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VAL234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VAL235U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VAL237Np Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VAL238Pu Activity (Ci) 1.90E-03 2.94E-04 1.86E-03 9.42E-05 5.1% 0.410 0238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VAL239Pu Activity (Ci) 1.95E-02 1.23E-03 1.92E-02 9.72E-04 5.1% 2.499 0240Pu Activity (Ci) 7.92E-03 1.23E-03 7.78E-03 3.90E-04 5.0% 0.402 0241Am Activity (Ci) 1.73E-02 6.55E-04 1.72E-02 9.80E-04 5.7% 8.951 0241Pu Activity (Ci) 5.78E-02 8.95E-03 5.63E-02 2.82E-03 5.0% 0.398 0242Pu Activity (Ci) 2.05E-06 3.18E-07 2.01E-06 1.02E-07 5.1% 0.415 0TRU Alpha Conc. (nCi/g) 3,050 123 3,010 98 3.3% 2.565 0

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

90Sr Activity (Ci) N/A N/A Not Significant Not Applicable 137Cs Activity (Ci) N/A N/A Not Significant Not Applicable 233U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A #VALUE! Not Applicable 235U Activity (Ci) N/A N/A #VALUE! Not Applicable 237Np Activity (Ci) N/A N/A #VALUE! Not Applicable 238Pu Activity (Ci) 0.368 0.731 Not Significant Not Significant 238U Activity (Ci) N/A N/A #VALUE! Not Applicable 239Pu Activity (Ci) 0.282 0.792 Not Significant Not Significant 240Pu Activity (Ci) 0.323 0.763 Not Significant Not Significant 241Am Activity (Ci) 0.093 0.930 Not Significant Not Significant 241Pu Activity (Ci) 0.472 0.661 Not Significant Not Significant 242Pu Activity (Ci) 0.321 0.764 Not Significant Not Significant TRU Alpha Conc. (nCi/g) 0.371 0.730 Not Significant Not Significant 
C.2-1 

ATTACHMENT C.2. MILCC2 REPLICATE TESTING RESULTS FOR CONTAINER No. X10CSATN020

Instrument: MILCC2 Drum: X10CSATN02023P 

Original Measurement Replicate #1 Rep

Quantity of Interest 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Abs

Unce

90Sr Activity (Ci) 3.09E-02 7.94E-04 2.6% 3.08E-02 7.91E-04 2.6% 3.08E-02 7137Cs Activity (Ci) 1.79E-03 4.60E-05 2.6% 1.79E-03 4.58E-05 2.6% 1.79E-03 4233U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 235U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 237Np Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 238Pu Activity (Ci) 7.89E-04 1.85E-03 234.5% 8.15E-04 1.91E-03 234.4% 8.01E-04 1238U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 239Pu Activity (Ci) 7.40E-04 1.24E-03 167.6% 7.64E-04 1.28E-03 167.5% 7.52E-04 1240Pu Activity (Ci) 1.26E-03 2.12E-03 168.3% 1.30E-03 2.19E-03 168.5% 1.28E-03 2241Am Activity (Ci) 3.60E-03 1.90E-04 5.3% 3.53E-03 1.86E-04 5.3% 3.50E-03 1241Pu Activity (Ci) 1.25E-02 2.09E-02 167.2% 1.29E-02 2.16E-02 167.4% 1.27E-02 2242Pu Activity (Ci) 1.21E-06 2.04E-06 168.6% 1.25E-06 2.11E-06 168.8% 1.23E-06 2TRU Alpha Conc. (nCi/g) 370 171 46.2% 372 176 47.3% 368 

Original Measurement Replicate #1 Rep

Quantity of Interest 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Quantity of Interest 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

QuaInter

90Sr Activity (Ci) 3.08E-02 7.91E-04 2.6% 3.08E-02 7.90E-04 2.6% 3.07E-02 137Cs Activity (Ci) 1.79E-03 4.59E-05 2.6% 1.79E-03 4.58E-05 2.6% 1.78E-03 233U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 235U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 237Np Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 238Pu Activity (Ci) 8.20E-04 1.93E-03 235.4% 8.04E-04 1.89E-03 235.1% 8.33E-04 238U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 239Pu Activity (Ci) 7.70E-04 1.29E-03 167.5% 7.54E-04 1.27E-03 168.4% 7.82E-04 240Pu Activity (Ci) 1.31E-03 2.20E-03 167.9% 1.29E-03 2.16E-03 167.4% 1.33E-03 241Am Activity (Ci) 3.58E-03 1.88E-04 5.3% 3.56E-03 1.87E-04 5.3% 3.56E-03 241Pu Activity (Ci) 1.30E-02 2.18E-02 167.7% 1.27E-02 2.13E-02 167.7% 1.32E-02 242Pu Activity (Ci) 1.26E-06 2.12E-06 168.3% 1.24E-06 2.08E-06 167.7% 1.28E-06 TRU Alpha Conc. (nCi/g) 376 178 47.3% 371 174 46.9% 378 
C.2-2 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <|

Reported 

Value 

Absolute 

Uncertainty 

90Sr Activity (Ci) 3.09E-02 7.94E-04 3.08E-02 4.47E-05 0.1% 0.013 1137Cs Activity (Ci) 1.79E-03 4.60E-05 1.79E-03 4.47E-06 0.3% 0.038 1233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VAL234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VAL235U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VAL237Np Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VAL238Pu Activity (Ci) 7.89E-04 1.85E-03 8.15E-04 1.29E-05 1.6% 0.000 1238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VAL239Pu Activity (Ci) 7.40E-04 1.24E-04 7.64E-04 1.23E-05 1.6% 0.039 1240Pu Activity (Ci) 1.26E-03 2.12E-03 1.30E-03 1.92E-05 1.5% 0.000 1241Am Activity (Ci) 3.60E-03 1.90E-04 3.55E-03 3.13E-05 0.9% 0.109 0241Pu Activity (Ci) 1.25E-02 2.09E-02 1.29E-02 2.12E-04 1.6% 0.000 1242Pu Activity (Ci) 1.21E-06 2.04E-06 1.25E-06 1.92E-08 1.5% 0.000 1TRU Alpha Conc. (nCi/g) 370 171 373 4 1.1% 0.002 1

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

90Sr Activity (Ci) 2.449 0.070 Not Significant Not Significant 137Cs Activity (Ci) 0.408 0.704 Not Significant Not Significant 233U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A #VALUE! Not Applicable 235U Activity (Ci) N/A N/A #VALUE! Not Applicable 237Np Activity (Ci) N/A N/A #VALUE! Not Applicable 238Pu Activity (Ci) -1.812 0.144 Not Significant Not Significant 238U Activity (Ci) N/A N/A #VALUE! Not Applicable 239Pu Activity (Ci) -1.814 0.144 Not Significant Not Significant 240Pu Activity (Ci) -1.993 0.117 Not Significant Not Significant 241Am Activity (Ci) 1.575 0.190 Not Significant Not Significant 241Pu Activity (Ci) -1.721 0.160 Not Significant Not Significant 242Pu Activity (Ci) -1.993 0.117 Not Significant Not Significant TRU Alpha Conc. (nCi/g) -0.685 0.531 Not Significant Not Significant 
C.3-1 

ATTACHMENT C.3. MILCC2 REPLICATE TESTING RESULTS FOR CONTAINER No. X10CSATN0193

Instrument: MILCC2 Drum: X10CSATN01937AG 

Original Measurement Replicate #1 Rep

Quantity of Interest 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Abs

Unce

90Sr Activity (Ci) 1.32E-01 4.68E-03 3.5% 1.30E-01 4.63E-03 3.6% 1.34E-01 4137Cs Activity (Ci) 7.64E-03 2.71E-04 3.5% 7.56E-03 2.68E-04 3.5% 7.79E-03 2233U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 235U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 237Np Activity (Ci) 1.52E-05 1.16E-06 7.6% 1.85E-05 1.39E-06 7.5% 0.00E+00 0.238Pu Activity (Ci) 4.03E-03 9.47E-03 235.0% 3.87E-03 9.08E-03 234.6% 3.97E-03 9238U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 239Pu Activity (Ci) 3.78E-03 6.35E-03 168.0% 3.63E-03 6.09E-03 167.8% 3.72E-03 6240Pu Activity (Ci) 6.45E-03 1.08E-02 167.4% 6.19E-03 1.04E-02 168.0% 6.35E-03 1241Am Activity (Ci) 1.10E+00 4.49E-02 4.1% 1.10E+00 4.58E-02 4.2% 1.14E+00 4241Pu Activity (Ci) 6.38E-02 1.07E-01 167.7% 6.11E-02 1.03E-01 168.6% 6.28E-02 1242Pu Activity (Ci) 6.21E-06 1.04E-05 167.5% 5.95E-06 1.00E-05 168.1% 6.11E-06 1TRU Alpha Conc. (nCi/g) 75,400 3,250 4.3% 75,600 3,290 4.4% 78,200 

Original Measurement Replicate #1 Rep

Quantity of Interest 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Quantity of Interest 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

QuaInter

90Sr Activity (Ci) 1.30E-01 4.62E-03 3.6% 1.32E-01 4.67E-03 3.5% 1.30E-01 137Cs Activity (Ci) 7.55E-03 2.68E-04 3.5% 7.63E-03 2.71E-04 3.6% 7.55E-03 233U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 234U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 235U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 237Np Activity (Ci) 1.54E-05 1.36E-06 8.8% 1.54E-05 1.21E-06 7.9% 0.00E+00 0238Pu Activity (Ci) 3.96E-03 9.29E-03 234.6% 3.74E-03 8.78E-03 234.8% 3.83E-03 238U Activity (Ci) 0.00E+00 N/A N/A 0.00E+00 N/A N/A 0.00E+00 239Pu Activity (Ci) 3.71E-03 6.23E-03 167.9% 3.51E-03 5.89E-03 167.8% 3.59E-03 240Pu Activity (Ci) 6.33E-03 1.06E-02 167.5% 5.98E-03 1.01E-02 168.9% 6.13E-03 241Am Activity (Ci) 1.09E+00 4.55E-02 4.2% 1.14E+00 4.68E-02 4.1% 1.13E+00 241Pu Activity (Ci) 6.26E-02 1.05E-01 167.7% 5.91E-02 9.93E-02 168.0% 6.06E-02 242Pu Activity (Ci) 6.09E-06 1.02E-05 167.5% 5.76E-06 9.67E-06 167.9% 5.90E-06 TRU Alpha Conc. (nCi/g) 75,000 3,280 4.4% 78,000 3,340 4.3% 77,700 
C.3-2 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <|

Reported 

Value 

Absolute 

Uncertainty 

90Sr Activity (Ci) 1.32E-01 4.68E-03 1.31E-01 1.79E-03 1.4% 0.408 0137Cs Activity (Ci) 7.64E-03 2.71E-04 7.62E-03 1.03E-04 1.4% 0.213 0233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A 235U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A 237Np Activity (Ci) 1.52E-05 1.16E-06 9.86E-06 9.09E-06 92.2% 0.536 0238Pu Activity (Ci) 4.03E-03 9.47E-03 3.87E-03 9.56E-05 2.5% 1.490 0238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A N/A 239Pu Activity (Ci) 3.78E-03 6.35E-03 3.63E-03 8.73E-05 2.4% 1.548 0240Pu Activity (Ci) 6.45E-03 1.08E-02 6.20E-03 1.52E-04 2.5% 1.523 0241Am Activity (Ci) 1.10E+00 4.49E-02 1.12E+00 2.35E-02 2.1% -0.778 0241Pu Activity (Ci) 6.38E-02 1.07E-01 6.12E-02 1.52E-03 2.5% 1.533 0242Pu Activity (Ci) 6.21E-06 1.04E-05 5.96E-06 1.44E-07 2.4% 1.571 0TRU Alpha Conc. (nCi/g) 75,400 3,250 76,900 1,487 1.9% -0.921 0

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

90Sr Activity (Ci) N/A N/A Not Significant Not Significant 137Cs Activity (Ci) N/A N/A Not Significant Not Significant 233U Activity (Ci) N/A N/A #VALUE! Not Applicable 234U Activity (Ci) N/A N/A #VALUE! Not Applicable 235U Activity (Ci) N/A N/A #VALUE! Not Applicable 237Np Activity (Ci) N/A N/A Highly Significant Not Significant 238Pu Activity (Ci) 0.368 0.731 Not Significant Not Significant 238U Activity (Ci) N/A N/A #VALUE! Not Applicable 239Pu Activity (Ci) 0.282 0.792 Not Significant Not Significant 240Pu Activity (Ci) 0.323 0.763 Not Significant Not Significant 241Am Activity (Ci) 0.093 0.930 Not Significant Not Significant 241Pu Activity (Ci) 0.472 0.661 Not Significant Not Significant 242Pu Activity (Ci) 0.321 0.764 Not Significant Not Significant TRU Alpha Conc. (nCi/g) 0.371 0.730 Not Significant Not Significant