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

WASTE CHARACTERIZATION REPORT

TIER 1 CHANGE EVALUATION:

ADDITION OF THE MOBILE ISOCS LARGE CONTAINER COUNTE R 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 Confirmatio n ........................................... 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 Wa ste 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 Contac t-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 M ultiple 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 Protect ion 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 Characteriza tion Program’s (CCP’s) approved waste

characterization program at Oak Ridge National Labo ratory (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 conducte d a continued compliance inspection of

the ORNL-CCP waste characterization program and eva luated 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 (se e EPA Docket Nos. A-98-49, II-A4-186

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

characterization program are listed in Attachment A

.

On May 30, 2014, the Carlsbad Field Office (CBFO) r equested 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 a nd 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 Examin ation (VE) of CH TRU waste at that

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

EPA evaluated the proposed T1 change by reviewing O RNL-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 MILC C2 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 th e EPA-approved calibration remains

valid. If the EPA-approved calibration is successfu lly 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 recal ibrate 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 co ntainers other than 55-gallon drums [i.e.,

Standard Waste Boxes (SWBs) or Standard Large Box-2 s (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 co nfigurations 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 substanti ve 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

.2Table 1. Tiering of Contact-Handled Transuranic Waste Characterization Processes Implemented by ORNL-CCP(Based on November 2007 Baseline Inspection and Subsequent Tier 1 Evaluation, Updated October 2014)Process ElementsORNL-CCP CH Waste Characterization Process – T1 ChangesORNL-CCP CH Waste Characterization Process – T2 Changes*Acceptable Knowledge,including LoadManagementAny new waste category other than retrievably stored debris,soils/gravel and solids (i.e., any type of newly generated waste)Load managementSubmission of a list of active ORNL-CCP CH AKEs andSPMsNotification to EPA upon completion of or substantive modification** to:•AK accuracy reports (annually, at a minimum)•AK-AK and AK-NDA/NDE Discrepancy Resolution Reports•WSPFs and related attachments (e.g., CIS) for all new or modified wastestreams, including change notices•AKSRs (new and updated versions)•CCP-TP-005, Attachments 4, 6, 7 and 8 and/or associated memoranda,including “Add Container” memoranda•Site AK procedures requiring CBFO approvalNondestructive Assay New equipment or substantive physical modifications** to approvedequipmentExtension of or changes to approved calibration range for approvedequipmentActivities that require system recalibrationAddition of new measurement configurations or container typesSubmission of a list of ORNL-CCP NDA operators, EAsand ITRs thatperformed work during the previous quarterNotification to EPA upon substantive modification**to:•Software for approved equipment•Operating ranges upon CBFO approval•Site NDA procedures requiring CBFO approvalNotification to EPA upon successful calibration verification ofMILCC2 following on-site relocation or other equipment changesReal-Time Radiography NoneSubmission of a list of ORNL-CCP RTR operators andITRs that performedwork during the previous quarterNotification to EPA upon:•New equipment or substantive physical modifications** to approvedequipment•Substantive modification** to site RTR procedures requiring CBFOapprovalVisual Examination andVisual ExaminationTechniqueAny use of visual examination Submission of a listof ORNL-CCP VE operators, VE Experts and ITRs thatperformed work during the previous quarterWIPP Waste Data System Load managementNotification to EPA upon substantive modification**to site WDSprocedures requiring CBFO approval* ORNL-CCP will report all T2 changes to EPA everythree months.** “Substantive modification” refers to a change with the potential to affect ORNL-CCP’s CH waste characterization processes or documentation of them, excluding changesthat are solely related to the environment, safetyand health; nuclear safety; or the Resource Conservation and Recovery Act, or that are editorial in nature or are required toaddress 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 activ ities 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 th e July 16, 2004, Federal Register notice

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

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

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

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

characterize TRU wastes and comply with the regulat ory requirements imposed on TRU wastes

destined for disposal at the WIPP.

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

necessary, to the site’s approved waste characteriz ation 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 req uiring post-implementation notification (T2)

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

reports. When evaluating proposed T1 changes for ap proval, 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 ch aracterize and dispose of any previously

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

risk of subsequent EPA disapproval.

3.0 PURPOSE OF THIS REPORT

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

MILCC2 for assaying 55-gallon drums. This report do cuments 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 de cision on its website at

www.epa.gov/radiation/wipp, in accordance with 40 C FR 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, i mplementation and effectiveness of the

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

evaluated personnel qualifications and training, op erating 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 eva luation, 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 procedu res.

• Knowledge and understanding of the personnel involv ed 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 discu ssed below. Upon evaluation, EPA concluded

that Items 6.4 – 6.10 discussed below are implement ed 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 O RNL. 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 c ontainer 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 detector s are connected wirelessly to computers with

the ISOCS user interface software.

The BEGe detectors are appropriate for the direct q uantification of plutonium-238 ( 238 

# Pu), 239 

# Pu,

240 

# Pu, americium-241 ( 241 

# Am), uranium-233 ( 233 

# U), 235 

# U, 238 

# U, cesium-137 ( 137 

# Cs), neptunium237 ( 237 

# Np) and other gamma-emitting radionuclides. The MIL CC2 is capable of assaying

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

soils, gravel and homogeneous solids matrices. Ther e 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 dis tance is measured for each item assayed as

described below, as shown in Figure 1, below.

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

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

only in its current location in the near term; howe ver, 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 th e approval of the addition of the MILCC2:

• CI-MILCC2-NDA-1001, “Mobile ISOCS Large Container C ounter 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 Sp ecification and Performance

Data, detector BE8879, December 6, 2013

• ISOCS Detector QA Measurement Check and Detector Sp ecification 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 Repo rt for the MCS MILCC2,” April

15, 2014

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

July 24, 2014

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

Chad Gerlock, Kevin Meyen, Maria Steade, and Ron Wh itson

• Operator Aids: OA-ORNL-0135, Revision 0, OA-ORNL-01 34-14 Revision 0 and OAORNL-0123-11, Revision 1

# 6



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

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

• CCP-TP-076, CCP Operating the Mobile ISOCS Large Co ntainer 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, Val idating, and Reporting

Procedure, Revision 16, November 1, 2013

6.3 Evaluation Checklist

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

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

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

6.4 Measurement Geometries

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

detectors placed in three fixed distances. These po sitions include:

• Near-Field position with 180 o 

# collimator, detectors located approximately 17 inc hes (in.)

from drum

• Mid-Field position with 180 o 

# collimator, detectors located approximately 69 in. from

drum

• Far-Field position with 90 o 

# collimator, detectors located approximately 115 in . from

drum

The placement of the detectors is illustrated in Fi gure 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-time 1 

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

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

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

however, laser distance measurements are taken to c onfirm 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 t o 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 can not record a new photon because it is busy recordin g a

previous photon, i.e., the detector is idle or dead . The number of photons that are not counted are ca lled “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 detect or is aligned correctly with the midline of the

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

caused from the extent of inflation of the cart’s t ires. The detector aligns with the center height of

the 55-gallon drum. The detector height and fluctua tions 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 initi ally 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 posi tion 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-F ield 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 a nd the assay will be performed at that position.

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

times, NDA personnel may elect to increase the coun ting 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 co ntainers other than 55-gallon drums (i.e.,

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

measurement configurations discussed above and show n 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

drumNear-Field PositionNear-Field PositionMid-Field PositionMid-Field Position



# 17”

69” 69” 17”Far-Field Position



# 115”Far-Field Position



# 115” Turntable

# 8



# 6.5 Calibration, Calibration Validation and Confirmatio n

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 energ y calibrations for both detectors were

performed. The spectral gain was set at approximate ly 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 concer ns 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 ca libration 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-gen erated multi-curve efficiency calibration

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

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

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

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

evaluated the technical aspects of this process thr ough technical discussions with Canberra

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

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

characterizing gamma detectors for assaying WIPP-bo und 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 relationshi p of the detector to the point-efficiency data and

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

ISOCS user interface software. EPA reviewed both Ca nberra detector characterization reports

and found them to adequately document the character ization of the detectors. 2



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

number (SN) 8903. It was originally characterized b y 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 det ectors are described as “ISOCS-characterized detect ors.”

# 9



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

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

adequate. There were no concerns regarding the effi ciency calibration and detector

characterization for the MILCC2.

6.5.4 Calibration Verification

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

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

assays were done on each container using National I nstitute 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 th e Calibration Report. Using the four matrix

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

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

were in compliance with the limits in DOE/WIPP-02-3 122 3 

# , Appendix A, Table A-2, and EPA

determined that the results of the calibration veri fication indicated that the MILCC2 is operating

within the acceptable limits. There were no concern s 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. M easured 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 crit eria in DOE/WIPP-02-3122, Appendix A,

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

6.6 Operating Range

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

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

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

in the population of S3000, S4000 and S5000 waste c ontainers 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. Th ere were no concerns regarding the

determination and documentation of the operating ra nge for the MILCC2.

6.7 Lower Limit of Detection Determination

Instruments performing TRU/Non-TRU waste discrimina tion 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 Crite ria for the Waste Isolation Pilot Plant,”

DOE/WIPP-02-3122, Revision 7.4, Carlsbad, New Mexic o, April 22, 2013.

# 10



# Minimum detectable activities (MDAs) are variable a nd 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 surroga te matrix 55-gallon drum with no

radioactive sources at the Near-, Mid- and Far-Fiel d 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, a s 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 po sition. At the Mid- and Far-Field positions, the

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

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

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

the dead-time is excessive for the Near-Field posit ion 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 po sition, a condition that indicates the

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

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

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

# Pu, 234 

# U

and strontium-90 ( 90 

# Sr). There were no concerns regarding the determina tion 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,” Revi sion 0, dated February 3, 2014. The TMU

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

generates models associated with errors caused by t he 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 s tatistically 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 TM U for the MILCC2.

# 11



# 6.9 Batch Data Reports

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

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

documented in 63 batch data reports (BDRs). ORNL-CC P 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-MILC C2-0001 through OR-MILCC2-

0035. The EPA reviewed BDR Nos. OR-MILCC2-0002, O R-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, R evision 21, Attachment 3.

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

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

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

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

Attachment 3.

• Assay Report for each container listed on Attachmen t 1.

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

• Automated ITR for each container listed on Attachme nt 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 list ed on Attachment 1.

• Correct revisions of CCP-TP-001 4 

# and CCP-TP-048.

The MILCC2 reports direct quantitative values and u ncertainties for 238 

# Pu, 239 

# Pu, 241 

# Am, 233 

# U,

235 

# U, 238 

# U, 137 

# Cs, and 237 

# Np. Values for 90 

# Sr, 234 

# U, and 242 

# Pu are obtained through the application

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

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

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

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

technical adequacy of the radionuclide documentatio n 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 determi nation of the 10 WIPP-tracked

radionuclides ( 241 

# Am, 137 

# Cs, 238 

# Pu, 239 

# Pu, 240 

# Pu, 242 

# Pu, 90 

# Sr, 233 

# U, 234 

# U and 238 

# U) 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 cont ainers 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 ta ken 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 val ues.

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

randomly selected these containers from a list of a ll 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 thr ee drums were reassayed five times and

the results were compared to the original assay dat a. 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-square d 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 differ ence between the replicate and original

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

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

assay values and the average of the five replicate measurements.

For Container Nos. X10CSATN02626B and X10CSATN02023 P, the χ 2 

# test showed that the

observed variances in the replicate measurements ar e 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 o f the five replicate measurements for 237 

# Np. It

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

Highly Significant

results are not always representative of true meas urement issues.

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

# Np replicate values

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

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

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

that these tests are designed to query. Although th e 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 p rovides 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 237 

# Np of 1.52E-05 Ci. In

comparison, two of the replicate values were report ed 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 populat ion of the five replicate measurements. This

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

replicate results showed an average activity of 1.6 4E-05 Ci, which is in good agreement with the

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

7.0 FINDINGS AND CONCERNS

There were no findings or concerns regarding the us e 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 s ystem 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-appr oved calibration is successfully verified,

ORNL-CCP may continue to operate the MILCC2 and not ify EPA as a T2 change. However, if

the EPA-approved calibration cannot be verified, OR NL-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 ca libration.

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

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

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

measurement configurations to the MILCC2 approval i s a new T1 change.

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

that were initiated during the baseline and subsequ ent 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-C CP MILCC2. EPA did not identify any

concerns or findings and based on the results of th is 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., chan ging system components in a like-forlike replacement, or relocating the system to anoth er area at ORNL) followed by verification of

the EPA-approved calibration. The tiering requireme nts 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 Densit y

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 Novembe r 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-A4-189B-1ATTACHMENT BMOBILE ISOCS LARGE CONTAINER COUNTER-2 EVALUATION CHECKLISTTechnicalElementsObjective EvidenceAdditional CommentsGeneralConfirm the NDA system is theMILCC2, its location andnumber.The instrument is located in Building (trailer) 7880AC at the TransuranicWaste Processing Center in Oak Ridge. MILCC2 standsfor Mobile ISOCSLarge Container Counter-2, and is also referred toas the Oak Ridge MILCCounter in the TMU documentation.This was confirmed with NDA personnelduring evaluation. EPA inspectors visuallyconfirmed the instrument’s location.Describe the MILCC2. The detectors are BEGe detectors, i.e., planar detectors that provide excellentresponse and energy resolution from 45 keV to 3 MeV. The detectors areidentified as Nos. 8903 (detector 1) and 8879 (detector 2), and were ISOCScharacterized in 2013. Both detectors are chilled by liquid nitrogen to protectthe germanium crystals. The two MILCC2 detectors are placed equidistantfrom and on opposite sides of the container to be assayed. Three distances arefixed for a 55-gallon drum, the selection of whichis determined by the deadtime of the detector.The closest position (Near-Field, 17 in. drum-to-detector) accommodatescontainers with low dead times, uses a 180° collimator with typical assay timeof 15 minutesThe middle position (Mid-Field, 69 in. drum-to-detector) accommodatescontainers with midrange dead times, uses 180° collimator with typical assaytime of 15 minutesThe farther position (Far-Field, 115 in. drum-to-detector), accommodatescontainers with high dead times, uses a 90° collimator with typical assay timeof 30 minutes.This was confirmed with NDA personnelduring evaluation.Identify the consensus standardsthat were used for the systemcalibration.ORNL-CCP used consensus standards ASTM C-1030, C-1133, C-1207 andC-1500 for the MILCC2 calibration.CI-MILCC2-NDA-1001, confirmed withNDA personnel during evaluation.Identify the container and wastestypes assayed on the MILCC2.The MILCC2 is capable of assaying debris, soils andgravel, andhomogeneous solid wastes in 55-gallon drums.The MILCC2 is limited by waste density anddead time, calibrated to assay wastes withdensities of 0-2.50 g/cc. All ORNL TRUwaste is expected to fall in this range.B-2TechnicalElementsObjective EvidenceAdditional CommentsIdentify the period ofperformance relevant to theMILCC2 and the number ofBDRs and waste containers thissystem assayed during the period.The MILCC2 is a new system with a limited performance history. The systembecame operational on April 16, 2014, and ORNL-CCPhas been assayingdrums at risk.Including the containers initially assayed atrisk, the MILCC2 has assayed ~ 574containers (excluding 24 PDP drums) whichare contained in 64 BDRs. Not all BDRshave been finalized at the time of inspectionConfirm that the MILCC2 is ableto report quantitative values forthe WIPP-tracked radionuclides.Direct Measurements:238Pu,239Pu,241Am,233U,235U,238U,137Cs and237Np.Radionuclides by Scaling:90Sr,234U and242Pu.Pu and other TRU isotopic ratios are determined using the MGA or FRAMsoftware, or AK.This was confirmed with NDA personnelduring evaluation.Confirm the MILCC2’scalibration of record.The calibration is documented in CI-MILCC2-NDA-1001, Revision 0. Eachdetector factory characterization report was provided to EPA reviewers.This was confirmed with NDA personnelduring evaluation.Identify the procedures thatgovern this function and wherethe results of these calculationsare 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 confirmed with NDA personnel.Copies of the current operating andcalibration procedures were available in thecontrol room to operators.Confirm the methods used toderive the isotopic contributionfor unmeasured radionuclides.241Am and Pu isotopics determined by MGA or FRAM software when enoughmass exists.This was confirmed with NDA personnelduring evaluation.Calibration Verification and ConfirmationConfirm the pedigree of allradionuclide standards that wereused for calibration confirmationand/or verifications. List orreference 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 source certificates found inAppendix 2; All standards are independentlycertified and acceptable for the MILCC2calibration.Confirm the MILCC2 operationalrange with respect to matrix(density) and activity.Acceptable density range for gamma is approximately0.001–2.50 g/cc;activity is limited by spectral parameters (peak shape and resolution) andsystem dead time.This was confirmed with NDA personnelduring evaluation.B-3TechnicalElementsObjective EvidenceAdditional CommentsIdentify the date of the lastcalibration verification. Have anyothers been completed in the lastyear?One calibration verification was performed on the system other than the initialverifications performed on site when detectors werereceived, documented inCI-MILCC2-NDA-1004. Following the initial calibration confirmation,ORNL-CCP observed intermittent instabilities in the1274.5 keV peak forDetector 1. To stabilize the detector, the preamp,pre-amp cables andelectrical power strip were replaced, Additionally,cables for Detector 2 werereplaced and a calibration verification found the changes in improvements hadno adverse impacts on the operation of the instrument.This was confirmed and discussed with NDApersonnel during evaluation.Requirements for accuracy andprecision must be met, asspecified in DOE/WIPP-02-3122,Appendix A, Table A-2 forcalibration verifications.The calibration confirmation documented in the MILCC2 report indicate thatthe %R was between 70-130 % and % RSD was less than14% for sixreplicates, as required.This was confirmed with NDA personnelduring the EPA evaluation.LLDConfirm that the LLD for theMILCC2 has been determined.Typical MDAs are determined by performing three replicate assays of eachcontainer type and detector position with matrix containers withoutradioactive sources. MDAs are averaged and converted to MDCs using matrixweight. The MDAs documented in CI-MILCC2-NDA-1001 indicate that theinstrument meets the TRU discrimination criterion of 100 nCi/g only for theNear-Field configuration. It is expected that alllow-activity containers willbe run at the Near-Field position. TRU determinations at the Mid- and FarField positions may not be possible for drums withlow activity.MDAs are variable and depend onmeasurement conditions such as backgroundrate and matrix type. ORNL-CCP providedexample MDAs and MDCs for a metals,combustibles and sludge on 55-gallon drum inall three positions.Confirm if the MILCC2 is usedto discriminate TRU/Non-TRUwastes at the 100 nCi/g criterionand that it has the requiredsensitivity.See previous entry.This was confirmed with NDA personnelduring the EPA evaluation.Identify any/all instances wherean LLD value for anon-measuredradionuclide is not providedbased on a lack of technicalfeasibility.Reporting thresholds are not discussed in the Calibration Report. Thisinformation is now reported in NDA memoranda.This was discussed with NDA personnelduring the EPA evaluation. Because the LLDis a measurement-based parameter, ORNLCCP personnel stated that it is not technicallyfeasible to calculate for radionuclides that arenot directly measured, i.e.,242Pu,234U and90Sr.B-4TechnicalElementsObjective EvidenceAdditional CommentsQuality ControlAll Operators have current CCPtraining as verified on LOQI.A July 9, 2014 and July 24, 2014, LOQI was providedto EPA reviewers. FiveNDA operators were listed on the LOQI, all with current trainingrequirements met. The LOQI lists two; typically, EAs are not NDA-approvedoperators.EPA confirmed the qualifications of eachoperator on their respective qualificationcards.Confirm the MILCC2’s statuswith respect to the CBFO NDAPDP and last cycle.The MILCC2 successfully participated in the PDP Drum Cycle 21A.Thiscycle tested 4 drum matrices and three alpha activity ranges.ORNL-CCP provided EPA with a copy of theapproval letter dated June 25, 2014.All MILCC2 data must bereviewed and approved byqualified personnel. Identify thename and function of theindividuals performing technicalreview and approval of MILCC2BDRs.Data review in the BDRs obtained by EPA was performed by:Ron Whitson, ITRDaniel Wade, SPMSusan Anderson, NDA OperatorChad Gerlock, QA Engineer, ITRBeverly Schrock, SPMEPA reviewed Qualification Cards for allpersonnel listed.Identify any NCRs within thelast year.There were no systems NCRs. There have been severalassay NCRs;however, this is expected on the MILCC2 because allMILCC2 assays arefirst done in the Near-Field position and any container that requires reassay atthe Mid-Field or Far-Field positions requires an NCR prior to reassay.This was discussed with ORNL-CCP NDApersonnel. If a sufficient assay cannot beobtained using a 30-minute count time,ORNL-CCP may consider a longer assay.B-5TechnicalElementsObjective EvidenceAdditional CommentsTMUEvaluate the magnitude of theTMU values observed in theMILCC2 BDRs that wereexamined during this evaluation.This system is effectively equivalent to the MILC counter at LANL.Therefore the TMU document borrows heavily from theLANL TMUdocument. TMU for the MILCC is documented in “TotalMeasurementUncertainty for the MCS/LANL ISOCS ‘Box Counter’,”Revision 2, March27, 2013. The TMU for the MILCC2 is documented in “Oak Ridge MILCCounter Total Measurement Uncertainty Report’,” Revision 2, March 13,2014.The components of uncertainty included in the TMU determination consist ofcalibration source uncertainties, ISOCS Model uncertainties, detectorpositioning, matrix in homogeneity, non-uniform source distribution, fillheight uncertainty, self-attenuation of SNM “lumps”, counting statistics,background fluctuations, radionuclide interferencesand isotopic measurementuncertainty. The ISOCS Uncertainty estimator is used to calculate TMU. Thisis a companion program to the MILCC2 system.EPA evaluated the BDRs provided. TMU waswithin the expected range in all instances.Background and Performance ChecksConfirm that MILCC2background measurements havebeen taken daily.Background measurements are required in CCP-TP-076,Operating Procedure(Revision 1, 3/2014). Evidence of daily backgroundmeasurements was seenin the logbook pages reviewed.EPA reviewed logbook entries includingdetailed reviews of entries from August 5,2014 and April 7-18, 2014. All entriesshowed that background measurements weremade and acceptable.Assess how often backgroundradiation was problematic to theextent that measurementpersonnel had to makeadjustments.This has not been an issue for the MILCC2. This was discussed with ORNL-CCP NDApersonnel who indicated background is lowrelative to surrounding ORNL areas.Confirm that system performancechecks have been performed atleast once per operational day.Confirm that performance checksinclude gamma matrix correctionchecks, and gamma peak positionand resolution checks.Performance measurements are required in CCP-TP-076, OperatingProcedure (Revision 0, 5/2013). Evidence of daily performance checks wasseen in the logbook pages reviewed.EPA reviewed logbook entries includingdetailed reviews of entries from August 5,2014 and April 7-18, 2014. All entriesshowed that performance checkmeasurements were made and acceptable.B-6TechnicalElementsObjective EvidenceAdditional CommentsMILCC2 BDRs contain•Testing facility name, testingbatch number, containernumbers, and signature of theSPM or designee.•Table of Contents.•Background and performancecheck data or control chartsfor the relevant time period.•Separate testing report sheetsfor 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.NAMILCC2 RDSs must include:•Title “Radioassay DataSheet.”•Method/procedure used.•Date of radioassay.•Activities and associatedTMU for individualradionuclides.•TRU alpha concentration andits associated TMU.•Operator and reviewersignatures.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.NAC.1-1ATTACHMENT C.1. MILCC2 REPLICATE TESTING RESULTS FOR CONTAINER No. X10CSATN02626B, Near-Field PositionInstrument: MILCC2Drum: X10CSATN02626BOriginal Measurement Replicate #1 Replicate #2Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty90Sr Activity (Ci) 2.43E-02 1.52E-04 0.6%2.40E-02 1.51E-04 0.6%2.40E-02 1.51E-04 0.6%137Cs Activity (Ci) 1.41E-03 8.83E-06 0.6%1.39E-03 8.74E-06 0.6%1.39E-03 8.73E-06 0.6%233U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A234U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A235U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A237Np Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A238Pu Activity (Ci) 1.90E-03 2.94E-04 15.5%1.96E-03 4.98E-04 25.4%1.75E-03 2.73E-04 15.6%238U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A239Pu Activity (Ci) 1.95E-02 1.23E-03 6.3%2.02E-02 4.27E-03 21.1%1.80E-02 1.17E-03 6.5%240Pu Activity (Ci) 7.92E-03 1.23E-03 15.5%8.18E-03 2.08E-03 25.4%7.31E-03 1.14E-03 15.6%241Am Activity (Ci) 1.73E-02 6.55E-04 3.8%1.59E-02 6.50E-04 4.1%1.65E-02 6.55E-04 4.0%241Pu Activity (Ci) 5.78E-02 8.95E-03 15.5%5.92E-02 1.51E-02 25.5%5.29E-02 8.24E-03 15.6%242Pu Activity (Ci) 2.05E-06 3.18E-07 15.5%2.12E-06 5.39E-07 25.4%1.89E-06 2.95E-07 15.6%TRU Alpha Conc. (nCi/g) 3,050 123 4.0%3,020 315 10.4%2,850 117 4.1%Original Measurement Replicate #1 Replicate #2Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyQuantityofInterestReportedValueAbsoluteUncertaintyRelativeUncertaintyQuantity ofInterestReportedValue90Sr Activity (Ci) 2.40E-02 1.51E-04 0.6%2.40E-02 1.64E-04 0.7%2.40E-02 1.63E-04 0.7%137Cs Activity (Ci) 1.39E-03 8.73E-06 0.6%1.39E-03 9.49E-06 0.7%1.39E-03 9.47E-06 0.7%233U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A234U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A235U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A237Np Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A238Pu Activity (Ci) 1.81E-03 2.84E-04 15.7%1.96E-03 3.52E-04 18.0%1.83E-03 2.92E-04 16.0%238U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A239Pu Activity (Ci) 1.87E-02 1.26E-03 6.7%2.02E-02 2.23E-03 11.0%1.89E-02 1.39E-03 7.4%240Pu Activity (Ci) 7.57E-03 1.19E-03 15.7%8.19E-03 1.47E-03 17.9%7.66E-03 1.22E-03 15.9%241Am Activity (Ci) 1.81E-02 6.67E-04 3.7%1.74E-02 7.48E-04 4.3%1.81E-02 6.63E-04 3.7%241Pu Activity (Ci) 5.48E-02 8.58E-03 15.7%5.93E-02 1.06E-02 17.9%5.55E-02 8.84E-03 15.9%242Pu Activity (Ci) 1.96E-06 3.07E-07 15.7%2.12E-06 3.80E-07 17.9%1.98E-06 3.16E-07 16.0%TRU Alpha Conc. (nCi/g) 3,020 123 4.1%3,120 183 5.9%3,040 130 4.3%C.1-2Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|c2|)ReportedValueAbsoluteUncertainty90Sr Activity (Ci) 2.43E-02 1.52E-042.40E-02 0.00E+00 N/A0.000 1.000137Cs Activity (Ci) 1.41E-03 8.83E-061.39E-03 0.00E+00 N/A0.000 1.000233U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!234U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!235U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!237Np Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!238Pu Activity (Ci) 1.90E-03 2.94E-041.86E-03 9.42E-05 5.1%0.410 0.982238U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!239Pu Activity (Ci) 1.95E-02 1.23E-031.92E-02 9.72E-04 5.1%2.499 0.645240Pu Activity (Ci) 7.92E-03 1.23E-037.78E-03 3.90E-04 5.0%0.402 0.982241Am Activity (Ci) 1.73E-02 6.55E-041.72E-02 9.80E-04 5.7%8.951 0.062241Pu Activity (Ci) 5.78E-02 8.95E-035.63E-02 2.82E-03 5.0%0.398 0.983242Pu Activity (Ci) 2.05E-06 3.18E-072.01E-06 1.02E-07 5.1%0.415 0.981TRU Alpha Conc. (nCi/g) 3,050 1233,010 98 3.3%2.565 0.633Quantity of Interest t Pr(x<|t|)χ2Testt Test90Sr Activity (Ci) N/A N/ANot Significant Not Applicable137Cs Activity (Ci) N/A N/ANot Significant Not Applicable233U Activity (Ci) N/A N/A#VALUE! Not Applicable234U Activity (Ci) N/A N/A#VALUE! Not Applicable235U Activity (Ci) N/A N/A#VALUE! Not Applicable237Np Activity (Ci) N/A N/A#VALUE! Not Applicable238Pu Activity (Ci) 0.368 0.731Not Significant Not Significant238U Activity (Ci) N/A N/A#VALUE! Not Applicable239Pu Activity (Ci) 0.282 0.792Not Significant Not Significant240Pu Activity (Ci) 0.323 0.763Not Significant Not Significant241Am Activity (Ci) 0.093 0.930Not Significant Not Significant241Pu Activity (Ci) 0.472 0.661Not Significant Not Significant242Pu Activity (Ci) 0.321 0.764Not Significant Not SignificantTRU Alpha Conc. (nCi/g) 0.371 0.730Not Significant Not SignificantC.2-1ATTACHMENT C.2. MILCC2 REPLICATE TESTING RESULTS FOR CONTAINER No. X10CSATN02023P, Mid-Field PositionInstrument: MILCC2Drum: X10CSATN02023POriginal Measurement Replicate #1 Replicate #2Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty90Sr Activity (Ci) 3.09E-02 7.94E-04 2.6%3.08E-02 7.91E-04 2.6%3.08E-02 7.91E-042.6%137Cs Activity (Ci) 1.79E-03 4.60E-05 2.6%1.79E-03 4.58E-05 2.6%1.79E-03 4.59E-052.6%233U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/AN/A234U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/AN/A235U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/AN/A237Np Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/AN/A238Pu Activity (Ci) 7.89E-04 1.85E-03 234.5%8.15E-04 1.91E-03 234.4%8.01E-04 1.88E-03234.7%238U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/AN/A239Pu Activity (Ci) 7.40E-04 1.24E-03 167.6%7.64E-04 1.28E-03 167.5%7.52E-04 1.26E-03167.6%240Pu Activity (Ci) 1.26E-03 2.12E-03 168.3%1.30E-03 2.19E-03 168.5%1.28E-03 2.15E-03168.0%241Am Activity (Ci) 3.60E-03 1.90E-04 5.3%3.53E-03 1.86E-04 5.3%3.50E-03 1.85E-045.3%241Pu Activity (Ci) 1.25E-02 2.09E-02 167.2%1.29E-02 2.16E-02 167.4%1.27E-02 2.13E-02167.7%242Pu Activity (Ci) 1.21E-06 2.04E-06 168.6%1.25E-06 2.11E-06 168.8%1.23E-06 2.07E-06168.3%TRU Alpha Conc. (nCi/g) 370 171 46.2%372 176 47.3%368 17347.0%Original Measurement Replicate #1 Replicate #2Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyQuantityofInterestReportedValueAbsoluteUncertaintyRelativeUncertaintyQuantity ofInterestReportedValue90Sr Activity (Ci) 3.08E-02 7.91E-04 2.6%3.08E-02 7.90E-04 2.6%3.07E-02 7.87E-04 2.6%137Cs Activity (Ci) 1.79E-03 4.59E-05 2.6%1.79E-03 4.58E-05 2.6%1.78E-03 4.56E-05 2.6%233U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A234U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A235U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A237Np Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A238Pu Activity (Ci) 8.20E-04 1.93E-03 235.4%8.04E-04 1.89E-03 235.1%8.33E-04 1.96E-03 235.3%238U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A239Pu Activity (Ci) 7.70E-04 1.29E-03 167.5%7.54E-04 1.27E-03 168.4%7.82E-04 1.31E-03 167.5%240Pu Activity (Ci) 1.31E-03 2.20E-03 167.9%1.29E-03 2.16E-03 167.4%1.33E-03 2.24E-03 168.4%241Am Activity (Ci) 3.58E-03 1.88E-04 5.3%3.56E-03 1.87E-04 5.3%3.56E-03 1.87E-04 5.3%241Pu Activity (Ci) 1.30E-02 2.18E-02 167.7%1.27E-02 2.13E-02 167.7%1.32E-02 2.21E-02 167.4%242Pu Activity (Ci) 1.26E-06 2.12E-06 168.3%1.24E-06 2.08E-06 167.7%1.28E-06 2.15E-06 168.0%TRU Alpha Conc. (nCi/g) 376 178 47.3%371 174 46.9%378 180 47.6%C.2-2Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|c2|)ReportedValueAbsoluteUncertainty90Sr Activity (Ci) 3.09E-02 7.94E-043.08E-02 4.47E-05 0.1%0.013 1.000137Cs Activity (Ci) 1.79E-03 4.60E-051.79E-03 4.47E-06 0.3%0.038 1.000233U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!234U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!235U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!237Np Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!238Pu Activity (Ci) 7.89E-04 1.85E-038.15E-04 1.29E-05 1.6%0.000 1.000238U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/A#VALUE! #VALUE!239Pu Activity (Ci) 7.40E-04 1.24E-047.64E-04 1.23E-05 1.6%0.039 1.000240Pu Activity (Ci) 1.26E-03 2.12E-031.30E-03 1.92E-05 1.5%0.000 1.000241Am Activity (Ci) 3.60E-03 1.90E-043.55E-03 3.13E-05 0.9%0.109 0.999241Pu Activity (Ci) 1.25E-02 2.09E-021.29E-02 2.12E-04 1.6%0.000 1.000242Pu Activity (Ci) 1.21E-06 2.04E-061.25E-06 1.92E-08 1.5%0.000 1.000TRU Alpha Conc. (nCi/g) 370 171373 4 1.1%0.002 1.000Quantity of Interest t Pr(x<|t|)χ2Testt Test90Sr Activity (Ci) 2.449 0.070Not Significant Not Significant137Cs Activity (Ci) 0.408 0.704Not Significant Not Significant233U Activity (Ci) N/A N/A#VALUE! Not Applicable234U Activity (Ci) N/A N/A#VALUE! Not Applicable235U Activity (Ci) N/A N/A#VALUE! Not Applicable237Np Activity (Ci) N/A N/A#VALUE! Not Applicable238Pu Activity (Ci) -1.812 0.144Not Significant Not Significant238U Activity (Ci) N/A N/A#VALUE! Not Applicable239Pu Activity (Ci) -1.814 0.144Not Significant Not Significant240Pu Activity (Ci) -1.993 0.117Not Significant Not Significant241Am Activity (Ci) 1.575 0.190Not Significant Not Significant241Pu Activity (Ci) -1.721 0.160Not Significant Not Significant242Pu Activity (Ci) -1.993 0.117Not Significant Not SignificantTRU Alpha Conc. (nCi/g) -0.685 0.531Not Significant Not SignificantC.3-1ATTACHMENT C.3. MILCC2 REPLICATE TESTING RESULTS FOR CONTAINER No. X10CSATN01937AG, Far-Field PositionInstrument: MILCC2Drum: X10CSATN01937AGOriginal Measurement Replicate #1 Replicate #2Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty90Sr Activity (Ci) 1.32E-01 4.68E-03 3.5%1.30E-01 4.63E-03 3.6%1.34E-01 4.77E-03 3.6%137Cs Activity (Ci) 7.64E-03 2.71E-04 3.5%7.56E-03 2.68E-04 3.5%7.79E-03 2.76E-04 3.5%233U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A234U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A235U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A237Np Activity (Ci) 1.52E-05 1.16E-06 7.6%1.85E-05 1.39E-06 7.5%0.00E+00 0.00E+00 N/A238Pu Activity (Ci) 4.03E-03 9.47E-03 235.0%3.87E-03 9.08E-03 234.6%3.97E-03 9.32E-03 234.8%238U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A239Pu Activity (Ci) 3.78E-03 6.35E-03 168.0%3.63E-03 6.09E-03 167.8%3.72E-03 6.25E-03 168.0%240Pu Activity (Ci) 6.45E-03 1.08E-02 167.4%6.19E-03 1.04E-02 168.0%6.35E-03 1.07E-02 168.5%241Am Activity (Ci) 1.10E+00 4.49E-02 4.1%1.10E+00 4.58E-02 4.2%1.14E+00 4.69E-02 4.1%241Pu Activity (Ci) 6.38E-02 1.07E-01 167.7%6.11E-02 1.03E-01 168.6%6.28E-02 1.05E-01 167.2%242Pu Activity (Ci) 6.21E-06 1.04E-05 167.5%5.95E-06 1.00E-05 168.1%6.11E-06 1.03E-05 168.6%TRU Alpha Conc. (nCi/g) 75,400 3,250 4.3%75,600 3,290 4.4%78,200 3,370 4.3%Original Measurement Replicate #1 Replicate #2Quantity of InterestReportedValueAbsoluteUncertaintyRelativeUncertaintyQuantityofInterestReportedValueAbsoluteUncertaintyRelativeUncertaintyQuantity ofInterestReportedValue90Sr Activity (Ci) 1.30E-01 4.62E-03 3.6%1.32E-01 4.67E-03 3.5%1.30E-01 4.63E-03 3.6%137Cs Activity (Ci) 7.55E-03 2.68E-04 3.5%7.63E-03 2.71E-04 3.6%7.55E-03 2.68E-04 3.5%233U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A234U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A235U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A237Np Activity (Ci) 1.54E-05 1.36E-06 8.8%1.54E-05 1.21E-06 7.9%0.00E+00 0.00E+00 N/A238Pu Activity (Ci) 3.96E-03 9.29E-03 234.6%3.74E-03 8.78E-03 234.8%3.83E-03 8.99E-03 234.7%238U Activity (Ci) 0.00E+00 N/A N/A0.00E+00 N/A N/A0.00E+00 N/A N/A239Pu Activity (Ci) 3.71E-03 6.23E-03 167.9%3.51E-03 5.89E-03 167.8%3.59E-03 6.04E-03 168.2%240Pu Activity (Ci) 6.33E-03 1.06E-02 167.5%5.98E-03 1.01E-02 168.9%6.13E-03 1.03E-02 168.0%241Am Activity (Ci) 1.09E+00 4.55E-02 4.2%1.14E+00 4.68E-02 4.1%1.13E+00 4.69E-02 4.2%241Pu Activity (Ci) 6.26E-02 1.05E-01 167.7%5.91E-02 9.93E-02 168.0%6.06E-02 1.02E-01 168.3%242Pu Activity (Ci) 6.09E-06 1.02E-05 167.5%5.76E-06 9.67E-06 167.9%5.90E-06 9.91E-06 168.0%TRU Alpha Conc. (nCi/g) 75,000 3,280 4.4%78,000 3,340 4.3%77,700 3,360 4.3%C.3-2Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|c2|)ReportedValueAbsoluteUncertainty90Sr Activity (Ci) 1.32E-01 4.68E-031.31E-01 1.79E-03 1.4%0.408 0.704137Cs Activity (Ci) 7.64E-03 2.71E-047.62E-03 1.03E-04 1.4%0.213 0.842233U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/AN/A N/A234U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/AN/A N/A235U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/AN/A N/A237Np Activity (Ci) 1.52E-05 1.16E-069.86E-06 9.09E-06 92.2%0.536 0.620238Pu Activity (Ci) 4.03E-03 9.47E-033.87E-03 9.56E-05 2.5%1.490 0.210238U Activity (Ci) 0.00E+00 N/A0.00E+00 0.00E+00 N/AN/A N/A239Pu Activity (Ci) 3.78E-03 6.35E-033.63E-03 8.73E-05 2.4%1.548 0.197240Pu Activity (Ci) 6.45E-03 1.08E-026.20E-03 1.52E-04 2.5%1.523 0.202241Am Activity (Ci) 1.10E+00 4.49E-021.12E+00 2.35E-02 2.1%-0.778 0.480241Pu Activity (Ci) 6.38E-02 1.07E-016.12E-02 1.52E-03 2.5%1.533 0.200242Pu Activity (Ci) 6.21E-06 1.04E-055.96E-06 1.44E-07 2.4%1.571 0.191TRU Alpha Conc. (nCi/g) 75,400 3,25076,900 1,487 1.9%-0.921 0.409Quantity of Interest t Pr(x<|t|)χ2Testt Test90Sr Activity (Ci) N/A N/ANot Significant Not Significant137Cs Activity (Ci) N/A N/ANot Significant Not Significant233U Activity (Ci) N/A N/A#VALUE! Not Applicable234U Activity (Ci) N/A N/A#VALUE! Not Applicable235U Activity (Ci) N/A N/A#VALUE! Not Applicable237Np Activity (Ci) N/A N/AHighly SignificantNot Significant238Pu Activity (Ci) 0.368 0.731Not Significant Not Significant238U Activity (Ci) N/A N/A#VALUE! Not Applicable239Pu Activity (Ci) 0.282 0.792Not Significant Not Significant240Pu Activity (Ci) 0.323 0.763Not Significant Not Significant241Am Activity (Ci) 0.093 0.930Not Significant Not Significant241Pu Activity (Ci) 0.472 0.661Not Significant Not Significant242Pu Activity (Ci) 0.321 0.764Not Significant Not SignificantTRU Alpha Conc. (nCi/g) 0.371 0.730Not Significant Not Significant